213800SA1M6NZ4YSQU91-2024-12-31-0-en.xhtml

STATEMENTS BY MEMBERS OF THE BOARD OF DIRECTORS

(in accordance with article 4(2) of Law 3556/2007)

The

1. Georgios Stergios, Chairman of the Board of Directors

2. Charalambos Sahinis, CEO

3. Marina Mavrommati, Member of the Board of Directors, specially appointed for this purpose by the

Board of Directors

In accordance with the provisions of paragraph 2 of article 4 of Law 3556/2007, we declare to the best

of our knowledge that:

α. The attached Financial Statements for the financial year from 01.01.2024 to 31.12.2024 of EYDAP

S.A., prepared in accordance with the applicable International Financial Reporting Standards, present

fairly the assets and liabilities, net assets and results of operations of EYDAP S.A. and the companies

included in the consolidation, taken as a whole.

β. The annual Consolidated Report of the Board of Directors, presents fairly the development,

performance and position of EYDAP S.A. and the businesses included in the consolidation taken as a

whole, including a description of the principal risks and uncertainties they face.

Athens, 29 April 2025

The Chairman of the Board.

The Chief Executive Officer

The Member of the Board of

Directors

George Stergios

A.D.T. A.S. 525749

Charalambos Sahinis

A.D.A.T. AO 568292

Marina Mavrommatis

AA080295

ANNUAL MANAGEMENT REPORT OF THE MANAGEMENT BOARD

Ladies and Gentlemen Shareholders,

We submit to you the annual report of the Board of Directors for the financial year from 01.01.2024 to

31.12.2024, which has been prepared in accordance with Law 4548/2018, the provisions of article 4 of

Law 3556/2007, as amended and in force today, as well as the decisions of the Board of Directors of

the Hellenic Capital Market Commission (CySEC) pursuant to the same Law.

This report presents the performance, development and position of the Athens Water Supply and

Sewerage Company S.A., with the distinctive title EYDAP S.A. (hereinafter referred to as the "Company"

or "EYDAP") and the Group. The annual report for the year is presented, with a discussion of the

significant events that took place during Fiscal Year 2024 and their effect on the Financial Statements

for the same period, a description of the principal risks and uncertainties and a list of the significant

transactions entered into between the Company and its related parties in accordance with IAS 24 as

well as the most significant events after the end of the financial year. In addition, for the financial year

2024 , after the issuance of

● Regulation (EU) 2023/2772 of 31.7.2024 supplementing Directive 2013/34/EU of the European

Parliament and of the Council as regards sustainability reporting standards, which is mandatory and

universally applicable to public interest entities and large entities; and

● the publication of Law 5164/2024 (A' 202) which incorporated the provisions of Directive (EU)

2022/2464 of the European Parliament and

the Council of 14 December 2022 amending

Regulation (EU) No 537/2014, Directive 2004/109/EC and Directive 2013/34/EU as regards the

submission of sustainability reports and, inter alia, amended the provisions of Law 4548/18 and Law

3556/07

and as part of the Annual Report of its Board of Directors (p.115), EYDAP publishes a Sustainability

Statement in compliance with the Corporate Sustainability Reporting Directive (CSRD) for the

submission of Sustainability Statements and the European Sustainability Reporting Standards (ESRS), as

well as the requirements of the European Classification Regulation 2020/852.

In addition, the Report of the Board of Directors shall include the explanatory report referred to in par.

7 of article 4 of Law No. 3556/2007 as well as the Corporate Governance Statement.

In 2024, the prolonged drought, combined with the increase in consumption due to the high

temperatures that prevailed, led to a significant reduction in the reserves in the reservoirs of EYDAP

Fixed Assets Company, the company owned by the Greek State, which supplies the undiluted water to

EYDAP S.A. according to the contract of Law 4812/2021 between the Greek State, EYDAP Fixed Assets

Company L.E.P.L. and EYDAP S.A. EYDAP, due to the importance of the sufficiency of untreated water

in its operation, as a supporter of the Ministry of Energy and Environment and in continuous

cooperation with it, proceeded in accordance with the existing planning to mitigate the effects of water

scarcity by activating alternative sources of water supply (boreholes, Lake Yliki) and consumer

awareness campaigns to avoid wasting the natural resource. The company has also already studied

medium and long-term projects and measures to ensure that the safe water supply of citizens is not

threatened.

EYDAP continued to give priority to the implementation of its investment plan, which is a guarantee of

sustainable development and safeguards the right of access of the residents of Attica to vital water

supply and sewerage services. The absorption of the plan has increased by 37% compared to 2023,

while investments in 2024 in absolute terms have quadrupled compared to the four-year period 2017-

2020, as the Company's investments in 2024 amounted to €60.7 million, up from an average of €15.6

million per year.

In 2024, turnover increased by 6.3% to €373.7 million from €351.6 million in 2023, up 6.3% (+€22.1

million) due to increased consumption. Operating costs, however, increased by +8.6% or +€28.5 million

to €358.3 million from €329.8 million in 2023, mainly due to the increase in staff salaries and expenses

and third-party fees and expenses

The Company's strategy is by nature an ESG strategy combined with the important triple bottom line

of safety - efficiency - growth. From this strategy flow the Company's objectives which include:

Environment: energy neutrality policy and environmental protection and circular economy

Society: Ensuring water quality along the entire transmission and distribution system, safety health and

well-being of employees, customer satisfaction, effective demand management and leakage reduction,

new business development and customer expansion, community support, and human resource

attraction and development.

Governance: Operational Resilience, regulatory compliance and adherence to standards, optimal

financial management, business transformation and leveraging technology.

The achievement of the above objectives creates significant value for consumers, society, shareholders

and the Company's own human resources, which, with their specialized experience, excellent training

and the love with which they surround the Company, are a driving force and helper in the work of

EYDAP and act as a catalyst for its development.

CONSTITUTION, LEGAL FRAMEWORK & COMPANY ACTIVITY

CONSTITUTION AND LEGAL FRAMEWORK

The 'Athens Water Supply and Sewerage Company SA'. (hereinafter referred to as 'EYDAP' or 'the

Company') was established by Law 1068/1980 through the merger of the 'Anonymous Greek Water

Company of the cities of Athens - Piraeus and Surroundings' (E.E.Y.) and the 'Capital Sewerage Agency'

(O.A.P.) as the exclusive provider of water supply and sewerage services to the cities of Athens - Piraeus

and the surrounding municipalities and communities in the legal form of a joint stock company under

the full control of the Greek State.

Subsequently, with Law 2744/1999 "Regulating issues of the Athens Water Supply and Sewerage

Company and other provisions", the legal status of EYDAP was re-regulated and the Company took its

current form with the listing of all its shares on the Athens Stock Exchange and under the supervision

of the Minister of Infrastructure and Transport.

• Article 2 of Law 2744/1999 granted to EYDAP the exclusive and non-transferable right to

provide water supply and sewerage services in the capital area for a period of twenty (20)

years with the possibility of renewal according to the terms of the contract that EYDAP would

conclude with the Greek State. The said contract, which was signed on 9.12.1999 (hereinafter

the 1999 Contract), determined, among other things, the price, quantity, quality and method

of supply of the untreated water that the Greek State undertook to make available to EYDAP,

so that the latter would be able to meet its water supply service obligations (Article 6(1) of Law

2744/1999).

• By Article 4 of Law 2744/1999, a public limited liability company was established under the

name "EYDAP Property Company", to which the ownership of strategic real estate assets of

EYDAP was transferred free of charge. The EIF Asset Company has since then been responsible

for the proper operation and maintenance of the transferred assets.

By Law 4812/2021 (article fourteenth hundred and one) renewed until 31.12.2040 the exclusive right

to provide water supply and sewerage services granted to EYDAP under par. 1 of Article 2 of Law

2744/1999.

● With par. 2 of the same article provided for the conclusion of a contract between the Greek

State, on the one hand, and EYDAP, on the other hand, and as a third party the N.P.D.D. "EYDAP

Fixed Assets Company" regarding the terms and conditions of exercising the right granted.

● With par. 3 provided that the price paid for the supply of raw water shall be paid by EYDAP to

the EYDAP Fixed Assets Company, in accordance with par. 1 of Article 6 of Law 2744/1999 and

further allocated by the State to finance the operation, maintenance and upgrading of the

External Water Supply System (E.W.S.) of the greater Capital Region.

● With par. 4 provided for the conclusion of a contract between the Greek State, the EYDAP

Fixed Assets Company L.E.P.L.and EYDAP, which entrusts the latter with the maintenance and

operation of the E.W.S. of the major area of the Capital Region for a period of three (3) years,

which may be extended by agreement of the parties.

Pursuant to the above provisions, on 2.2.2022, the following agreements were signed between the

Greek State, the EYDAP Fixed Assets Company L.E.P.L.and EYDAP:

● the Exclusive Right Contract whereby, inter alia, the State grants to EYDAP for consideration

the intangible right of exclusive supply of raw water and agrees to supply raw water on an

annual basis and for twenty (20) years, as specifically set out in Article 10 of this Contract,

● the SLA (Service Level Agreement) for the operation and maintenance of the EIS with an initial

term of three (3) years and the possibility of extension for six (6) months. Pursuant to the

decision of the Board of Directors of the EYDAP Fixed Assets Company L.E.P.L.No. 17/8.8.2023,

the extension of the SLA of 2.2.2022 for the operation and maintenance of the EIS was

approved, with the same terms, for a period of 6 months, i.e. until June 30, 2024. Already

under the provisions of Article 18 of Law 5106/2024, the contract for the operation and

maintenance services of the EIS was extended until 31 December 2025 under

the

same

conditions.

By Law 5037/2023 (Government Gazette A' 78), the supervision of EYDAP was transferred to the

Ministry of Environment and Energy, while the supervision of the provision of water services and urban

waste management was assigned to the Waste, Energy and Water Regulatory Authority (R.A.A.E.Y.).

The pricing policy of EYDAP is exercised through the application of the general rules of costing and

pricing of water services, which are determined by a joint decision of the Ministers of Environment and

Energy, Finance, Interior and Rural Development and Food, in accordance with the provisions of Article

12 of Law 3199/2003, as replaced by Article 34 of Law 5037/2023. By the same EIA, the procedures and

the method of recovery of the cost of water services in the different uses are also determined, while

the tariffs of water services for the different categories of consumers and users are approved by a five-

year decision of RAAEY in accordance with Article 12A of Law 4001/2011, as introduced under Article

11 of Law 5037/2023. In application of the above provisions, on 27

.9.2024, the Ministry of Environment

and Natural Resources/GRGFPY/103755/2994/2024 (Government Gazette 5438/B/27.9.2024) entitled

'Determination of general rules for costing and pricing of water services, measures for their

improvement. Procedures and method of recovery of costs of water services in its various uses'. It should

be noted that Article 19 of Law 5106/2024 provided for the possibility of approving the tariffs of EYDAP

by decision of the Minister of Environment and Energy until the completion of the staffing of RUEY.

As regards the share capital of the Company:

● By Law 4389/2016 (Annex E), as amended by Law 4512/2018, all the shares owned by the

Greek State were transferred with effect from 1.1.2018 to the

Hellenic Holding and Property

Company S.A.

● The above transfer was deemed unconstitutional by decision No 190/2022 of the Supreme

Court.

● By decision no. 7/2023 of the Conformity Council of the Council of State, the Greek State was

found to be in non-compliance with the 190/2022 annulment decision of the Supreme Council

of State and the Ministry of Finance was ordered to comply within 8 months.

● Article 64 of Law 5045/2023 transferred the ownership shares of EESYP to the Greek State and

provided for the exercise of the relevant rights of the State by the Ministers of Finance and

Environment and Energy. This automatic and gratuitous transfer was completed on 3.8.2023

according to the relevant notification of the Ministry of Economy and Finance.

● Pursuant to Articles 188A and 188B of Law 4389/2016, as added by Articles 5 and 6 of Law

5131/2024 (Government Gazette A' 128/02-08-2024), the provisions of Law 4601/2019 as in

force, and the merger agreement of 23-12-2024 (Government Gazette B' 7093/24-12-2024),

which was registered in the General Commercial Register (G.On 31-12-2024, the "PUBLIC

PROPERTY DEVELOPMENT FUND OF THE PUBLIC S.A.", which directly held 11.33% of the share

capital and voting rights of EYDAP, was absorbed by the company "HELLENIC PETROLEUM

COMPANY AND PROPERTY S.A.". Following the merger, the 11,33% of the share capital and

voting rights of EYDAP directly held by the joint stock company " Hellenic Republic Asset

Development Fund S.A." (T.A.I.P.E.D.) was transferred on 31-12-2024 to the company named

"Hellenic Holding and Property Company S.A.".

Today, the total percentage of voting rights (direct and indirect) controlled by the Greek State in EYDAP

amounts to 65.319.740 (61,33%) of which the direct voting rights are 53.250.001 common nominal

shares (50% +1 share) and the indirect voting rights are 12.069.739 (11,33%) common nominal shares.

In terms of company law, EYDAP is currently governed by the provisions of the Law on Public Limited

Companies 4548/2018, the Law on Corporate Governance 4706/2020, as well as by all stock exchange

legislation (Regulation (EU) 596/2014, Law 4443/2016, Law 3556/2007, etc.) and the decisions and

instructions of the Hellenic Capital Market Commission, by which it is supervised.

ACTIVITY

The Company is active in the refining and supply of water and the provision of sewerage and

wastewater treatment services in the Attica region. According to its Articles of Association, EYDAP is

responsible for the design, construction, installation, operation, exploitation, maintenance,

development and modernisation/renovation of water supply and sewerage facilities and networks

within its area of responsibility. In addition to the activities of EYDAP, the possibility of using the water

supply and sewerage networks for the development of telecommunications and energy activities has

been added. In addition, the statutes provide for the possibility to develop activities such as, but not

limited to, the provision of water meter maintenance services, camera inspection of third party

sewerage networks, undertaking of third party water quality control programmes at the EAFRD's

chemistry facilities, undertaking of on-line measurement and recording of water quality parameters of

water bodies with corresponding service provision, parallel meter reading of other utilities, provision

of education, training and lifelong learning services and the establishment and operation of technical

and vocational training schools.

The geographical activity of EYDAP, as established by article 68 of Law 4313/2014 which amended

article 8 of Law 2744/1999, extends to the municipalities of the Region of Attica, as defined in

subsection i' of par. 3 of Article 3 of Law 3852/2010, except for the municipalities of Aegina, Troizinia,

Kythira, Agistri, Spetses, Hydra and Poros of the Regional Unit of the Islands of the Region of Attica.

According to Article 1 par. 6 of Law 2744/1999, as amended by Article 35 par. 2 of Law 4053/2012,

EYDAP may, through its subsidiaries, undertake activities outside its area of competence through

programmatic contracts under Article 100 of Law 3852/2010.

In July 2011, the subsidiary company "ANONYMOUS ISLANDS WATER SUPPLY COMPANY" was

established with the distinctive title "EYDAP NISON S.A.", in whose share capital EYDAP holds 100%.

Today the above subsidiary is called " Islands Water Supply and Sewerage Development Corporation

S.A " with the distinctive title "EYDAP NISON DEVELOPEMENT S.A.".

EYDAP provides water supply services through its water supply network consisting of approximately

14,300 km of pipeline network. The Company also operates four Water Treatment Plants with a total

capacity of 1.8 million cubic metres of water per day. The population served in the water supply sector

amounts to approximately 4,400,000 inhabitants. In September 2023, EYDAP took over the municipal

water supply networks of the city of Megara and the municipal water supply networks of the areas of

Kinetta, Vlychada (Agios Panteleimonas), Nea Zoi, Kandylion, Koumindriou, Lakka, Agia Triada, Eremou

Kima and Pachi with their associated facilities. The total length of these water supply networks is 270

km of pipelines, supplying 13 500 connections.

The sewerage network has a total length of about 8,716 km. The system is separate (sewers -

stormwater pipes), except in the Athens city centre area, where the system is all-flow (common sewers

and stormwater pipes). The population served amounts to 3.695.500 inhabitants. The collection of

wastewater is carried out through the pipelines of the secondary sewage network of the sewage areas,

through the connection of each property along the sewerage network, which (connection) is mandatory

for the owners of the properties, within six (6) months from the relevant written notification of EYDAP

in accordance with the provisions of Article 169 of Law 4951/2022 and under penalty of a fine in favour

of the Greek State.

For the treatment of wastewater, EYDAP now has 5 wastewater treatment centres (WWTPs),

● the WWTP of Psyttaleia with a treatment capacity (average design flow) of 1,000,000 m3/day

of wastewater (currently the average flow of incoming wastewater is in the range of 650,000

m3/day),

● the Metamorphosis WWTP has a treatment capacity (average design flow) of 44,000 m3/day

of wastewater (20,000 m3/day of urban wastewater and 24,000 m3/day of urban sewage),

(currently the average flow of incoming wastewater is 16,900 m3/day and of sewage is 9,800

m3/day) and

● the Thriasio WWTP has the capacity to treat (average design flow) 21,000 m3/day of

wastewater (currently, the average flow of incoming wastewater is 6,700 m3/day)

● the K.E.L. of Megara which was received by the Municipality of Megareon in September 2023.

The capacity of the constructed facility is 43,330 (IP) and the average daily design flow of

incoming wastewater is 1,990 m3/d.

● the Paiania-Koropi WWTP was received by the Region of Attica in December 2023, has a

treatment capacity (average design flow) of 18,000 m3/day of wastewater (currently-2024,

the average flow of incoming wastewater is of 1750 m3/day.

The KEL of Psyttaleia includes three CHP units, one CHP unit with natural gas combustion of 12.9 MWe

electrical power and 17.3 MWth thermal power and two CHP units with biogas combustion, with a total

electrical power of 11.4 MWe (7.14 MWe & 4.25 MWe) and 17.2 MWth thermal power and a small

hydroelectric power plant with a capacity of 489 KW to recover the energy contained in the treated

effluent stream before its disposal in the Saronic Gulf.

EYDAP with the Psyttalia Wastewater Treatment Centre has joined the European Union's Greenhouse

Gas Emissions Trading Scheme, implementing the relevant EU and national legislation.

In addition, EYDAP manages the sewerage projects of East Attica for the collection and treatment of

urban wastewater and the reuse-disposal of treated effluents. In 2024, significant progress was

achieved in the implementation of the wastewater projects. The planning for the construction and

operation of integrated wastewater management systems in East Attica includes projects in the

municipalities of Rafina-Pikermio, Spata Artemida, Marathon, Pallini, Peania, Saronikos and Kropias. In

2021, EYDAP developed the special website katharonero.eydap.gr to keep citizens informed about

important sewerage projects in Eastern Attica and the environmental benefits of the projects.

In the context of the optimization of its energy balance and the utilization of renewable energy

sourcesEYDAP: (a) has installed and operates five small hydroelectric power stations at the locations of

Kirfi, Elikonas, Kithaironas, Mandra of the Mornos Aqueduct and the small hydroelectric power station

of Evinos; and (b) has installed a photovoltaic (PV) power station with a capacity of 1.9712 MW at its

premises in the Municipality of Acharnon, in order to sell the electricity produced.

EYDAP supplies Attica with one of the highest quality water in the world. The main water sources and

the reservoirs used are located in pure areas, free from agricultural and industrial activity, so that the

Greek capital is supplied with excellent quality water, while the water is transported naturally by

gravity, with low energy consumption.

Our vision is the uninterrupted provision of high quality water supply and wastewater services in

Athens and the rest of Greece by a company that is a model in ESG and zero carbon water issues.

FINANCIAL DEVELOPMENTS AND ALLOWANCES FOR THE FINANCIAL YEAR 2024

Presentation of the Company’s Key Financial Results

The Company's turnover amounted to € 373,7 million compared to € 351.6 million in 2023, recording

an increase of 6.3% (+€ 22,1 million). Overall, from its main activities (water supply and sewerage), the

Company presented an increase in revenue of +€ 21.4 million (+6.6%).

In particular, revenues from water supply and related services recorded an increase of € +16.3 million

(+7.3%), while revenues from sewerage services recorded an increase of €+5.1 million (+5.0%).

Similarly, revenues from the sale of electricity increased by € +24 k (+1.2%) as well as revenues from

the sale of inventories which increased by € 746 k (+621%).

Regarding revenues from water supply and related services, water consumption was increased by + €

14.635 k (+6.8%) which consists of the main category of water revenues.

Other categories of water and related services revenues recorded increasing trends (except for

rehabilitation works which remained stable). More specifically, revenues from new water supplies

recorded an increase of €+527 k (+13%), connection fees and contributions, an increase of +13.5% (€+41

k), while other revenues, consisting mainly of revenues from hydrometer

outages/replacements/removals, showed a significant increase of €+1,106 k (+42%).

It should be noted that the revenues from water consumption (as well as the revenues from the right

to use sewerage related services), in addition to the invoiced revenue shown in issued water bills, also

include the adjustment to this revenue on an accrued basis. In 2024, these amounts stood at € 234,245

k and €-4,200 k respectively.

The last category includes the following:

● Changes in the provisions for non-invoiced as well as invoiced revenues of € -64 k (compared

to € +2,195 k in 2023).

● Revenue cancellations amounting to € -2,387 k (compared to € -1,817 k in 2023)

● Adjustments from the implementation of IFRS 15, amounting to € -1,750 k (compared to € -

1,546 k in 2023). These adjustments are linked to income invoiced after termination of water

supply (fixed charge, minimum consumption, water price in case of violation) and which, due

to the application of IFRS 15 and the respective revenue recognition criteria, are deducted

from revenues and therefore are recognized as revenues only upon the cash collection from

the customer.

The main category of sewerage revenues, which is that of revenues from sewerage use, increased by €

+4,974 k (+5.0%). In the other categories, connection rights increased by € +115 k (+13%), sewerage

works increased by € +12 k (+1%). Finally, a decrease was recorded in the category of sewerage fees of

€ -50 k or -42%. It is to be noted that revenues from the sewerage use include the invoiced revenues

from sewerage use which amounted to € 102,587 k, as well as their adjustment on an accrual basis

which amounted to € +1,464 k.

This last category includes:

• Changes in the provisions for non-invoiced as well as invoiced revenues of € -631 k

(compared to € +1,199 k in 2023).

• Cancellations of income amounting to € -1,523 k (compared to € -1,128 k in 2023).

• Adjustments from the application of IFRS 15, amounting to € -382 k (compared to € -626

k in 2023). These adjustments are linked to revenues priced after the termination of water supply (fixed

charge, minimum consumption, water price in case of violation) and which, due to the application of

In k €

2022

2023

2024

Revenues from water consumption

210.479

215.410

230.045

New water supply accounts

3.899

3.985

4.511

Connection rights & customer contribution

300

306

347

Restoration works

319

583

Other

4.101

2.634

3.739

Revenues from water supply and related

services

219.099

222.918

239.226

In k €

2022

2023

2024

Revenues from right to use sewerage

related services

94.999

99.077

104.051

Connection rights

710

868

983

Sewerage fees

1.638

1.540

1.552

Sewerage works

120

Revenues from sewerage services

97.412

101.606

106.656

the revenue recognition criteria in the context of IFRS 15, are deducted from revenues and therefore

are recognized as revenues only upon the cash collection from the customer.

• Estimation of Sewerage Revenues outside the Water Supply Network of EYDAP S.A.

amounting to € +4,000 k (compared to € 4,400 k in 2023).

The Company’s total operating expenses (i.e. the sum of Cost of Sales, Administrative Expenses,

Distribution Expenses and Impairment of Financial Assets) increased by +8.6% or € +28.5 million

amounting to € 358.3 million from € 329.8 million in 2023. In particular, the cost of sales increased by

€+3.3 million (+1.5%) amounting to € 221.1 million from € 217.7 million in 2023, as well as the

Administrative Expenses that recorded an increase of € +15.8 million (+20.6%) and the Distribution

expenses also increased by € +2.4 million (+6.5%).

The above developments resulted in an increase in the Company's Gross Profit Margin by € +18.8 million

(+14.0%) standing at € 152.6 million from € 133.8 million in 2023. Gross profit margin as a percentage

of turnover increased to 40.8% from 38.1% in 2023.

Other operating income amounted to €10.3 million, from €3.2 million in 2023, increased by +226% or

€ 7.1 million. This increase is linked to the income from EPEYDAP for electricity from water pumping

under the agreement for the operation and maintenance of the External Water Supply System for an

amount of € 6,998 thousand, which is an equal expense paid by EYDAP S.A. for electricity consumption

and is reflected in “Other expenses” item.

Moreover, these revenues include a number of categories of revenues, such as income from legal

expenditure, subsidies and grants collected from the Greek Manpower Employment Organization

(OAED) for the training of personnel and for internships, forfeitures of guarantees and penalties, grants

related to research programs, other extraordinary and non-operating income, previous years’ income,

profit from the liquidation of materials, income for the provision of services to third parties etc.

With regard to the course of the total operating expenses of the Company (meaning the sum of Cost of

Sales, Administrative Expenses, Distribution Expenses and Impairment of Financial Assets) depending

on each category, the following changes compared to 2023 were recorded:

• Cost for raw water amounted to € 29.1 million compared to € 27.8 million in 2023

• Personnel fees and expenses increased by € +11.6 million (+9%)

• Third party fees and expenses increased by € +9 million (+16%)

• Utilities increased by € +1,1 million (+2%)

• Depreciation/amortization increased by € 2.7 million (+7%)

• Various provisions decreased by € -5 k (-0.4%)

• Miscellaneous expenses increased by € +3 million (+23%)

• Consumables increased by € +2 million (+17%)

• Self-construction cost (comprising an item that reduces the total cost) increased by €

+2,372 k (+36%)

Third party fees and expenses increased by +€ 9 million (+16%) amounting to € 67 million versus € 58

million in 2023. Depending on the type of expenditure, the largest increases were in the categories of

maintenance contractors by € 2,671 k (+9%), third-party fees net of tax by € 2,249 k (+43%), security-

fire security costs by € 1,984 k (+47%), costs for support operations by € 1,144 k (+11%). Smaller

increases were recorded in the categories of lawyers +369 k (+16%), doctors € 240 k (+23%), various

other fees (transport and disposal services for dried sludge as waste etc.) € 208 k (+20%), consultants'

fees €+78 k (+19%), the fees of various third parties +€ 70 k (+8%), fees for other freelancers +€ 33 k

(+3), while there was a decrease only in employer's contributions of third parties -€ 11 k (-5%).

Employee fees and expenses stood at € 140.3 million versus € 128.6 million in 2023 (+9%). Wages and

salaries increased by € +10 million (+11%) as did employer contributions which increased by € +1,531 k

(+7%). There was also an increase in healthcare provisions (+€ 227 k) and a decrease in provisions for

defined benefit plans (€ -169 k). It should be noted that these provisions include only past service costs

as interest costs are transferred to financial expenses. It should be noted that the Employee

contributions item includes a provision of € 3,058 k (€ 3,058 k in 2023) due to the need to make a

provision, for employee obligation provided for in the Collective Labour Agreement (CLA).

Utilities recorded a slight increase standing at € 55.9 million in 2023 against € 57 million in 2024 (+2%).

In particular, there was a decrease of € -2,878 k in electricity generation costs (-9%) and a decrease of

€ -51 k in natural gas generation costs (-47%). On the other hand, repair and maintenance expenses

increased by € 2,011 k (+29%), other third-party services by € 1,525 k (+49%), rentals by € 449 k (+5%)

and communication expenses by € 22 k (+1%).

Miscellaneous expenses amounted to € 16.2 million from € 13.2 million in 2023, recording an increase

of € +2,995 k or 23%. It should be noted that they consist of taxes and fees (excluding income tax),

consumables, promotion and advertising expenses, transportation expenses, donations-grants and

other miscellaneous expenses. The latter are mainly related to interest charges validated by courts,

costs of deposition of Material from the Waste Management & treatment Plants toward ESDNA (Special

Institutional Body for Waste Management in Attica), stationery-printing, publication costs, travel

expenses, as well as acquisition of property, plant and equipment for own projects. Other miscellaneous

expenses increased by € +1,062 k (+49%) mainly due to the increase in purchases of property, plant and

equipment for self-produced assets by € 788 k (+626%).

Other categories of miscellaneous expenses increased in terms of promotion and advertising expenses

by € +717 k (+64%), direct material by € +609 k (+19%), donations-grants by € +335 k (+33%), taxes-

duties by € +258 k (+5%) and finally transport expenses by € +15 k (+1%).

As at 31/12/2024, in the context of the application of IFRS 9, the Company reviewed the provision for

impairment of receivables made on 31/12/2023 amounting to € 99,126 k. This review resulted in an

increase in the provision by € +6,501 k, which is presented separately in the interim Income Statement

entitled: “Impairment of financial assets “.

This change of € +6,501 k is analyzed as follows:

+64% due to the increase in receivables (Exposures at Default) with the same credit risk parameters as

on 31/12/2023

+39% in deterioration of the credit risk parameter: Losses Given Default with the same requirements

and estimated default probabilities as at 31/12/2023

-4% in the improvement of the credit risk parameter: Probabilities of Default with the same

requirements and Losses Given Default as on 31/12/2023.

On 31/12/2024, in total, the provision for bad debts amounted to € 105,627 k. The percentage of bad

debts compared to the gross customer balance in 2024 stood at 36% from 37% in 2023.

Overall, various provisions (expense) during 2024 decreased by € -5 k (-0.4%) compared to the

corresponding amount in 2023 and amounted to € +1,301 k compared to € +1,306 k in 2023. The

provisions made in 2024 include: provisions for doubtful accounts ("Impairment of financial assets" €

+6,501 k), provisions for litigation (€ -4,703 k) and provisions for obsolescence of inventories/third

parties projects (€ -496 k).

Provision for litigation (income) amounted to approximately €- 4,703 k, resulting in provisions in the

statement of financial position amounting to € 34.9 million in 2024 (from € 39.6 million in 2023). Overall,

the Company decreased the provision for labour cases by €-8,628 k, while it increased the provision for

civil cases by € +3,925 k.

Finally, in the other categories of expenses, consumables increased by € 2,053 k (+17%) while the cost

of self-construction (a cost-reducing element of expenses) increased by € 2,372 k (+36%).

Compared to other expenses (which are all expenses not allocated to operations, i.e. excluding Cost of

Sales, Administrative and Distribution Expenses), there was a significant increase of € +7.3 million

(+213%) amounting to € 10,666 k from € 3,412 k in 2023. In 2024, the Company included in these

expenses the charge for electricity consumption for water pumping under the operation and

maintenance contract for the second half of 2024, amounting to € 6,998 k, which represents an equal

amount of income of EYDAP SA from EPEYDAP and is reflected in the other operating income item.

These expenses usually include compensation from accidents and network damage, various tax

charges, other surcharges and fines, etc. It should be noted that in the previous period the item included

an amount of approximately € 415 k which concerned provision for impairment of other receivables

due to non-recoverability (Note 24 of the Financial Statements). The Company took into account the

developments within 2024 and formed a provision of € +1,318 k in relation to other receivables. In

other categories, the largest category is compensation from accidents and network damage, amounting

to € 1.3 million from € 2 million, recording a decrease of € -737 k (-37%).

In k €

Balance of Doubtful Receivables

and Contractual Assets

Balance of Customers prior to Provision for Doubtful

Receivables and Contractual Assets

(1)

(2)

(3)=(1)/(2)

2020

99.573

278.502

36%

2021

103.306

328.877

31%

2022

99.603

269.380

37%

2023

99.126

268.980

37%

2024

105.627

293.140

36%

In k €

Provisions for Doubtful Receivables for the Year/

Impairment of Financial Assets

Provision for Litigations for the Year

2019

2.609

-4.479

2020

11.367

-4.268

2021

3.733

498

2022

-3.703

-7.512

2023

-477

1.992

2024

6.501

-4.703

The total result of the above changes was the decrease of EBITDA of the Company by €- 3.8 million (-

6%), which amounted to € 57.1 million compared to € 60.8 million in 2023. The EBITDA margin stood at

15.3% from 17.3% in 2023.

Depreciation and amortization for the year presented an increase of +7% or € 2.7 million and amounted

to € 42 million from € 39.3 million in 2023.

The decrease in EBITDA combined with the increase in depreciation and amortization affected the

Company's earnings before interest and tax (EBIT), decreased from € 21.5 k in 2023 to € 15.1 million in

2024. The EBIT margin stood at 4.0% from 6.1% in 2023.

Financial income increased by €+2,216 k (+12%) to € 20 million from € 17.8 million in 2023. Financial

income consists mainly of the surcharges-interest on overdue customer debts and interest/advances

on the products in which the cash available is invested (Bank of Greece cash management account and

term deposits of credit institutions). Interest income from customers amounted to € 8.8 million from €

8.4 million in 2023, including interest on arrears of the Greek State amounting to € 0.6 million from the

collection of a receivable following a judicial claim (by decision of the Supreme Court), recording an

increase of € +319 k (+4%). Interest on deposits changed in the same direction, amounting to € 10.8

million from € 8.9 million in 2023, recording an increase of € +1,892 k (+21%).

Financial expenses decreased by -11% amounting to € 10,041 k from € 11,335 k in 2023. In 2024,

interest on the actuarial liability amounted to € 8,049 k compared to € 9,381 k in 2023. The remaining

financial expenses are mainly related to interest on lump-sum compensation (€ 915 k), customer

settlement costs (€ 456 k), other bank expenses (€ 459 k), financial expenses for lease liabilities (€ 95 k)

and letters of guarantee fees (€ 67 k).

The Company's profit (loss) before tax amounted to € 25.1 million from € 28 million in 2023, recording

a decrease of -10% or € -2.9 million.

Income tax amounted to € 10.4 million from € 7.7 million in 2023, recording a decrease of -28% in the

Company's profit after tax amounting to € 14.6 million from €20.3 million in 2023. Net profit margin

stood at 3.9% from 5.8% in 2023.

The Group’s Net Operating Cash Flow increased from € +20.6 million in 2023 to € +26.3 million in 2024,

an increase of approximately +€ 6 million. Profit/loss before tax decreased by € -3 million, while non-

cash adjustments decreased by € -10 million and operating account adjustments increased by € +28

million. Tax paid increased from €-2.5 million in 2023 to € -9.6 million in 2024. Customer surcharges

collected continued to move at high levels (€ 7,082 k in 2024 compared to € 8,467 k in 2023).

The Group’s Net Investing Cash Flow amounted to outflow of € -41 million, compared to outflow of € -

14.1 million in 2023. Property, plant and equipment acquisition amounted to approximately € 63.7

million in 2024, from € 44.2 million in 2023, while in terms of interest received there was an increase,

from € 9.9 million in 2023 to € 11.2 million in 2024. Grants received decreased to € 14,495 k compared

to € 21,049 k in 2023.

Finally, the Group’s Free Cash Flows to the Firm

* amounted € -14.6 million from € +6.5 million in 2023.

Alternative Performance Measurement Indicators: For explanations and calculation of indicators see Section,

“Alternative Performance Measurement Indicators”

where

ROE= Earnings after Tax/Average Equity

Tax Burden = Earnings after Tax / Earnings before Tax

Interest Burden = Earnings before Tax / ΕΒΙΤ

EBIT Margin = EBIT / Turnover

Asset Turnover = Turnover / Average Assets

Leverage = Average Assets / Average Equity

The effect of the Subsidiary on the consolidated items is negligible and does not need further analysis.

ALTERNATIVE PERFORMANCE MEASURES (“APMs”)

In the Annual Management Report, as well as in its disclosures to the investors, the Group utilizes

Alternative Performance Measures (APMs) in addition to the financial sizes included in its financial

statements which are prepared in accordance with the current financial reporting framework.

The objective of the analysis of the APMs is that both - the Company's Management and the investors

– should have a more complete picture of the Group's profitability, capital structure, operations and

liquidity and in no case should they be taken into account independently of the measurement indicators.

arising directly from the financial statements.

The Group uses the following Alternative Performance Measures:

EBITDA

This Ratio prevails in the investment community and is part of the general category of profitability ratios,

having the advantage of isolating the effects of financial-investment results, income tax and the main

category of non-cash expenses which are depreciation and amortization.

The Ratio is calculated by deducting the cost of sales, distribution expenses, administrative expenses,

other expenses and adding other operating income and total depreciation/amortization. Moreover, the

item “Impairment of financial assets” of the Income Statement is deducted, which relates to the

provision-expense of doubtful receivables for the period. These sizes are used without any adjustment

in the Financial Statements and Notes.

Return on Equity Analysis in 5 separate factors (for the Group)

2024

2023

2022

ROE

1,75%

2,41%

0,61%

Tax Burden

0,58

0,72

0,47

Interest Burden

1,66

1,30

120,57

EBIT Margin

4,03%

6,12%

0,03%

Asset Turnover

0,25

0,24

0,22

Leverage

1,78

1,75

1,91

Reconciliation of EBITDA

GROUP

COMPANY

Amounts in k Euro

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Turnover

373.747

351.602

373.703

351.574

Cost of sales

-221.081

-217.752

-221.081

-217.738

Administrative expenses

-92.403

-76.602

-92.359

-76.578

Distribution expenses

-38.311

-35.960

-38.311

-35.960

Impairment of financial assets

-6.501

477

-6.501

477

Other expenses

-10.666

-3.413

-10.666

-3.413

Other operating income

10.290

3.159

10.290

3.155

Depreciation and Amortization

48.124

45.446

48.124

45.446

Grants amortization

-6.135

-6.139

-6.135

-6.139

EBITDA

57.064

60.818

57.064

60.824

● EBITDA Margin

This ratio arises from the aforementioned table dividing EBITDA by Turnover. It expresses the

percentage of EBITDA profit on Turnover or alternatively how much EBITDA earnings correspond to an

item of sales. The Company Management uses the specific Ratio in the context of the wider evaluation

of the Company’s operating performance.

Reconciliation of EBITDA margin

GROUP

COMPANY

Amounts in k Euro

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Turnover

373.747

351.602

373.703

351.574

EBITDA

57.064

60.818

57.064

60.824

EBITDA margin

15,27%

17,30%

15,27%

17,30%

● EBIT

This Ratio, like the previous one (EBITDA), is prevailing in the investment community and is part of the

general category of profitability ratios, having the advantage of isolating the effects of financial-

investment results and income tax.

The ratio is calculated by deducting the cost of sales, distribution expenses, administrative expenses,

other expenses and adding other operating income. Moreover, the item “Impairment of financial

assets” of the Income Statement is deducted, which relates to the provision-expense of doubtful

receivables for the period, which in previous periods was included in cost of sales. These sizes are used

without any adjustment from the financial statements.

Reconciliation of EBIT

GROUP

COMPANY

Amount in k Euro

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Turnover

373.747

351.602

373.703

351.574

Cost of sales

-221.081

-217.752

-221.081

-217.738

Administrative expenses

-92.403

-76.602

-92.359

-76.578

Distribution expenses

-38.311

-35.960

-38.311

-35.960

Impairment of assets

-6.501

477

-6.501

477

Other expenses

-10.666

-3.413

-10.666

-3.413

Other operating expenses

10.290

3.159

10.290

3.155

EBIT

15.075

21.511

15.075

21.517

• EBIT Margin

This ratio arises from the table above dividing EBIT by Turnover. It expresses the percentage of EBIT

profit over Turnover. Company Management uses the specific Ratio in the context of the wider

evaluation of the Company’s operating performance.

Reconciliation of EBIT margin

GROUP

COMPANY

Amounts in k Euro

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Turnover

373.747

351.602

373.703

351.574

EBIT

15.075

21.511

15.075

21.517

EBIT margin

4,0%

6,1%

4,0%

6,1%

• Free Cash Flows to the Firm

This Ratio is part of the general category of profitability ratios as it shows the amount of cash available

for distribution to shareholders and the Company lenders and at the same time is one of the key

financial strength ratios.

The Ratio is calculated by adding the total inflows (outflows) in the Statement of Cash Flows from

Operating Activities to the total inflows / (outflows) from Investing Activities.

Free Cash Flows to the Firm-FCFF

GROUP

COMPANY

Amounts in k Euro

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Total inflows / (outflows) from Operating

Activities

26.290

20.563

26.283

20.568

Total inflows / (outflows) from Investing

Activities

-40.864

-14.050

-40.877

-14.060

FCFF

-14.574

6.513

-14.594

6.508

• Return on Equity/ROE

In general, return on equity presents the profit that corresponds to the investment of the company’s

shareholders. It belongs to the group of profitability ratios and is also generally used for the purpose of

comparing similar companies and evaluating the company’s management. The ratio is calculated by

dividing net income (Profit after Tax) by the average of opening and closing period equity. It can also

be calculated by multiplying five factors, each one of them is corresponding to a separate ratio.

Separate ratios are as follows:

Tax Burden: which is the ratio of Net Income (Profit after Tax) to Profit before Tax

Interest Burden: which is the ratio of Earnings before Tax to EBIT

EBIT margin: is the ratio of EBIT to Turnover

Assets Turnover: which is the ratio of Turnover to Total Assets (average Total Assets at the opening and

closing period).

Leverage: which is the ratio of Total Assets (average Assets Total at the opening and closing period) to

Equity (average Equity at the opening and closing period).

Reconciliation Table of ROE at GROUP level

By means of analysing the Return on Equity Ratio into five separate factors, the Company’s

Management, as well as the stakeholders, can be aware of what part of the net profit is burdened with

tax (Tax Burden), what part is burdened or benefits from the financial or investing activity (Interest

Burden), what is the contribution of operating profit margin (at EBIT level - the EBIT margin), what is the

Asset Turnover and finally what is the contribution of Leverage.

• Operating Expenses (OPEX)

The Ratio is used by the Company’s Management in decision making and in its communication with

investors as it includes all the categories of expenses that are divided into operations, i.e. cost of sales,

administrative expenses and distribution expenses net of depreciation. It also includes the item

"Impairment of financial assets" in the Income Statement, which concerns the provision-expense of

doubtful receivables for the period, which in previous periods was included in cost of sales. Other

expenses are excluded as they cannot be allocated to operations.

Amounts in k Euro

31.12.2024

31.12.2023

31.12.2022

31.12.2021

31.12.2020

Turnover

(a)

373.747

351.602

343.493

360.764

330.325

Profit after Tax

(b)

14.652

20.275

5.016

30.648

-66.100

Profit before Tax

(c)

25.069

27.992

10.610

59.382

-80.442

EBIT

(d)

15.075

21.511

46.280

-92.182

Total Assets

(e)

1.503.979

1.479.046

1.467.858

1.696.021

1.613.996

Average Assets at the opening and closing period

(f)

1.491.513

1.473.452

1.581.940

1.655.008

1.588.432

Total Equity

(g)

827.528

847.259

837.379

815.167

827.812

Average Equity at the opening and closing period

(h)

837.394

842.319

826.273

821.490

889.476

Tax Burden

=(b)/(c)

0,58

0,72

0,47

0,52

0,82

Interest Burden

=(c)/(d)

1,66

1,30

120,57

1,28

0,87

EBIT Margin

=(d)/(a)

4,03%

6,12%

0,03%

12,83%

-27,91%

Asset Turnover

=(a)/(f)

0,25

0,24

0,22

0,21

Leverage

=(f)/(h)

1,78

1,75

1,91

2,01

1,79

RΟΕ

=(b)/(h)

1,75%

2,41%

0,61%

3,73%

-7,43%

Reconciliation of OPEX

GROUP

COMPANY

Amounts in k Euro

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Cost of sales

221.081

217.752

221.081

217.738

Administrative expenses

92.403

76.602

92.359

76.578

Distribution expenses

38.311

35.960

38.311

35.960

Impairment of financial assets

6.501

-477

6.501

-477

Depreciation / Amortization

-48.124

-45.446

-48.124

-45.446

Grants amortization

6.135

6.139

6.135

6.139

OPEX

316.307

290.530

316.263

290.492

• Gross Profit Margin (%)

This ratio arises from dividing Gross Margin by Turnover precisely as these two sizes are presented in

the financial statements. It is used by the Company's Management in addition to the Gross Margin in

value. It is to be noted that from 1/1/2018, in the Cost of Sales (and therefore the Gross Margin of Profit)

is not included the provision-expense of doubtful receivables for the period, which in previous periods

was included in cost of sales. This provision is referred to, from 1/1/2018 separately, as “Impairment of

financial assets” in the Income Statement.

Reconciliation of Gross Profit Margin (%)

GROUP

COMPANY

Amounts in k Euro

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Turnover

373.747

351.602

373.703

351.574

Gross Profit Margin

152.665

133.850

152.622

133.836

Gross Profit Margin %

40,8%

38,1%

40,8%

38,1%

Alternative Performance Measures less the effect of provision for the additional cost of raw water

• Adjusted EBITDA

In 2021 the Company was burdened, based on the consideration provided in the contract signed with

the Greek State, by € 28,395 k. Moreover, based on the Operation and Maintenance contract of EYS, it

formed an Intangible Asset of € 87,500 k (due to the granting of a lower price for the real estate than

the original). In 2021, the Company depreciated one twentieth of this amount, which corresponds to €

4,375 k. Having undertaken an equal obligation of 87,500, it entered the corresponding obligation for

the provision of operation and maintenance services at the beginning of the fiscal year and decreased

it by € 25,000 k, recognizing an equal amount of income.

To facilitate the separation of adjustments first recorded in the Financial Statements of 2020 in relation

to raw water and finalized in 2021 with both the concession contract and the operation and

maintenance contract of the EYS and to capture in the best possible way the performance of the

company regardless of these events, we adjusted EBITDA, deducting the relevant effects.

In particular, the Ratio is calculated if the cost of sales, distribution expenses, administrative expenses,

other expenses are deducted from turnover and other operating income and total depreciation are

added. The item “Impairment of financial assets” in the Income Statement is also deducted, which

concerns the provision-expense of doubtful receivables for the period. The cost of raw water based on

the agreement is added to the relevant sum (because it is included in the cost of sales) while revenue

of operation and maintenance contract (included in the turnover).

Reconciliation of Adjusted EBITDA

• Adjusted EBITDA-I

To facilitate the separation of the:

● adjustments recorded in the Financial Statements of 2021 and 2022 for the first time in

relation to raw water as well as

● significant change in the impairment of financial assets

and in order to present in the best possible way the performance of the company regardless of these

extraordinary events, we adjusted EBITDA, deducted the relevant effects.

In particular, the Ratio is calculated by deducting the cost of sales, distribution expenses, administrative

expenses, other expenses from turnover and the other operating income and by adding the total

depreciation/amortization. In the relevant sum:

The cost of raw water is added and revenue from Operation and Maintenance Agreement of the EYS is

deducted.

GROUP

COMPANY

Amounts in k Euro

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Turnover

373.747

351.602

373.703

351.574

Cost of sales

-221.081

-217.752

-221.081

-217.738

Administrative expenses

-92.403

-76.602

-92.359

-76.578

Distribution expenses

-38.311

-35.960

-38.311

-35.960

Impairment of financial assets

-6.501

477

-6.501

477

Other expenses

-10.666

-3.413

-10.666

-3.413

Other operating expenses

10.290

3.159

10.290

3.155

Depreciation / Amortization

48.124

45.446

48.124

45.446

Grants amortization

-6.135

-6.139

-6.135

-6.139

Revenue from Operation and Maintenance Contract of the EWS

-25.000

Cost of raw water

29.133

27.785

29.133

27.785

Adjusted EBITDA

61.197

63.603

61.197

63.609

Reconciliation of Adjusted EBITDA-I

GROUP

COMPANY

Amounts in k Euro

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Turnover

373.747

351.602

373.703

351.574

Cost of sales

-221.081

-217.752

-221.081

-217.738

Administrative expenses

-92.403

-76.602

-92.359

-76.578

Distribution expenses

-38.311

-35.960

-38.311

-35.960

Impairment of financial assets

-10.666

-3.413

-10.666

-3.413

Other expenses

10.290

3.159

10.290

3.155

Other operating expenses

48.124

45.446

48.124

45.446

Depreciation / Amortization

-6.135

-6.139

-6.135

-6.139

Revenue from Operation and Maintenance Contract of

the EWS

-25.000

Cost of raw water

29.133

27.785

29.133

27.785

Adjusted EBITDA-Ι

67.698

63.126

67.698

63.132

ΙΙ. Operations Review – Development of water consumption and income from water supply and right-

of-use sewerage

Total consumption in 2024 remained at about the same level as in 2023, showing a significant increase

of 6.2%.

The following contributed to the formation of the consumption level, compared to the previous year:

● +5.9% increase in the outgoing quantity from the Water Treatment Units (WTUs) and

● +0.3% due to the increase in water supply support for the areas of the Municipality of

Oropos, with water pumped from the Mavrosovala boreholes.

In 2024, the consumption related to the outflow of water from the WTUs was affected by the warmer

weather conditions prevailed, with less rainfall compared to the previous year, combined with the

African dust transport episodes observed in spring and early summer.

The year's temperatures averaged above the seasonal long-term trend, peaking significantly in summer

and April, when they surpassed the long-term maximum. Starting in September, temperatures declined

to slightly above seasonal norms. However, October, November, and December experienced lower

temperatures than the previous year. Despite this cooler final quarter, water demand remained higher

than the previous year's levels for the same period.

Similarly favouring consumption, annual rainfall was lower than the long-term average in both the

number of rainy days and total volume. This was especially pronounced between February and June

2024 compared to the previous year, and also during October and November, which saw reduced

rainfall compared to seasonal norms and slightly less than last year.

This shift in climatic patterns began in the second half of 2023, marked by prolonged high temperatures

throughout the summer. It intensified in the first half of 2024, peaking in June and persisting through

the rest of the summer.

Invoiced consumption increased by 4.9%, less than the overall consumption increase. This discrepancy

resulted in a rise in non-invoiced consumption, which is the difference between total consumption and

the sum of priced and free consumption. The non-invoiced consumption rate, calculated as the ratio of

non-invoiced water in EYDAP's Internal Water Supply System (IWSS) to the volume of water, was 26.2%

in 2024, increased from 25.1% in 2023 (+1.1%). Despite this annual increase, the medium-term non-

invoiced consumption rate remains below 25%.

The increase in the percentage of non-invoiced consumption for the year is due to two factors:

● the prolonged period of intensified use of the existing network (following municipal network

receipts) to meet increased water demand; and

● the part of the increased consumption to be invoiced at the beginning of next year 2025, due

to the required period of time for metering and issuing water invoices, which incorporate a

consumption period as defined for every customer category (three months in the domestic

tariff).

The total consumption

(invoiced, non-invoiced and free) for the years 2022, 2023 and 2024 is

presented in the following table:

T1. Total Water Consumption (c.m.)

Invoice Category

Year

2024

2023

2022

Invoiced Consumption

305.142

290.801

308.067

Non-invoiced Consumption

106.735

96.922

80.071

Free of charge consumption

(firefighting uses)

Total Consumption

411.889

387.731

388.154

The development of invoiced consumption, respectively, is presented in the following table:

T2. Invoiced consumption (c.m.)

Invoice Category

Year

2024

2023

2022

General Tariff

196.092

186.073

200.050

Industrial – Business

24.149

23.816

23.660

Public services – Local Authorities

17.909

16.544

17.117

Network upgrade

63.075

62.281

61.494

Other Invoices

3.917

2.087

5.746

Total

305.142

290.801

308.067

The increase in invoiced consumption of 4.9%, corresponding to 14.3 million cubic meters, is mainly

due to the General Tariff, which showed an increase of 5.4%, corresponding to 10.0 million cubic

meters. In terms of the evolution over time, the cubic meters of consumption invoiced under the

General Tariff for the year 2022 were particularly high, due to the recovery of the suspension of invoices

that has been reported in previous financial reports.

Fluctuations in water supply aid to the Municipality of Oropos primarily drive the changes in invoiced

consumption for Other Invoices, as other raw water supplies have been discontinued according to the

agreement with the Greek State. In 2024, invoiced consumption within the Other Invoices category

The total water consumption is the sum of the following separate quantities:

• Output quantity from the Water Treatment Units (WTUs).

• Recorded quantity of supplied refined water of external aqueducts from rapid refineries.

• Recorded amount of raw water supplied from hydrometers, connected to the external

aqueducts and related to the Company's wells in the area of Mavrosouvala and other raw water

supplies along the Mornos canal and the Yliki aqueduct.

Other invoices include the following categories: Unpurified water, Vessel Supply, Charity and imputed charges

(loss of water due to third party damage to the network, arising in the course of their operations).

increased by 1.8 million cubic meters, aligning with increased needs in the Municipality (+1.5 million

cubic meters) and ship supply (+0.2 million cubic meters), which is also included in this category. This

increase occurred between April and December, reflecting the demand of these sectors.

In 2024, there was also an increase in the invoiced consumption of the Public Sector-OTA category,

which increased by 8.2%, corresponding to 1.4 million cubic meters.

The OTA Network Aid category, which represents the second largest customer category in terms of

consumption, increased by 0.8 million cubic meters, showing a small percentage increase of 1.3%. The

slight increase is mainly due to the shift in consumption of the Municipality of Megara, following the

assumption of the water supply and sewerage network of the Municipality by EYDAP SA.

A small percentage increase of 1.4% was also recorded in the Industrial - Professional tariff category,

equating to approximately 0.3 million cubic meters. Notably, the HELPE company's consumption

accounts for 44% of the total invoiced consumption within this category. In 2024, HELPE's water usage

increased by 1.2 million cubic meters. Conversely, the combined consumption of other industrial and

professional users (excluding HELPE) decreased by 0.9 million cubic meters, a reduction likely

attributable to fewer water supplies covered by this tariff.

The following table presents the development of the invoiced revenues from water sales, for the main

categories of invoices, for the years 2022, 2023 and 2024:

T3. Invoiced Revenues from Water Sales* (k €)

Invoice Category

Year

2024

2023

2022

General Tariff

163.359

147.380

156.780

Industrial – Business

18.602

19.273

19.261

Public services-Local Authorities

17.980

16.640

17.199

Network upgrade

30.866

30.480

30.097

Other Invoices

3.437

2.780

3.307

Total

234.244

216.553

226.644

*Includes water price revenues with compulsory and imputed consumption, as well as Fixed Asset revenues

The increase of €17.7 million in invoiced water revenues in 2024 is mainly due to a 10.8% increase in

revenues from the main category, which is the General Tariff (domestic).

The following table presents the development of the invoiced revenues from sales of right-to-use

sewerage, in relation to the main invoice categories:

T4. Invoiced revenues for sewerage (k €)

Invoice Category

Year

2024

2023

2022

General Tariff

89.138

81.305

87.316

Industrial – Business

6.512

7.309

7.027

Public services-Local Authorities

6.622

6.266

6.255

Network upgrade

Other Invoices

Total

102.312

94.916

100.646

Finally, the following table presents the total of the invoiced revenues from sales of water & right-of-

use sewerage, in relation to the main categories of invoices, for the years 2022, 2023 and 2024:

T5. Total Invoiced Revenues from Water Sales & Right-of-use Sewerage (k €)

Invoice Category

Year

2024

2023

2022

General Tariff

252.497

228.685

244.096

Industrial – Business

25.114

26.582

26.288

Public services-Local Authorities

24.602

22.906

23.454

Network upgrade

30.866

30.480

30.097

Other Invoices

3.477

2.816

3.355

Total

336.556

311.469

327.290

The 8.1% increase in invoiced revenues from the sale of water and sewerage rights, corresponding to

€25.1 million, is due to the increase in revenues from the General Tariff category, which represents 75%

of the invoiced revenues for the year.

Five (5) scales of monthly consumption are applied in invoicing of water with general tariff, based on

the principle of gradual invoicing, according to which, the more water is consumed, the higher the unit

sale price is, which corresponds to the revenue per cubic meter of water. The following table presents

the relative allocation (%) of the invoiced quantity of General Tariff water, in relation to the invoicing

scales.

T6. Allocation of Invoiced quantity of Water of General Tariff in the Invoicing Scale (%)

Invoice Category

Year

2024

2023

2022

Scale (1-15 m

per three months)

49,2

51,1

50,4

Scale (16-60 m

per three months)

41,7

41,9

42,7

Scale (61-81 m

per three months)

2,6

2,3

2,4

Scale (82-105 m

per three months)

1,3

1,1

1,2

Scale (>105 m

per three months)

5,2

3,6

3,3

The 1

Scale corresponds to the lowest selling price of the General tariff per cubic meter of water and

the quantity of the first cubic meters of consumption of the water supply invoices. The 2

Scale

corresponds to the next highest level of sales price and the amount of cubic meters of water

consumption in the water supply invoices, and so on for the following tiers.

In 2024, domestic consumers increased their consumption within the highest tier of the 1st scale,

leading to a decrease in its share from 51.1% to 49.2% (percentage differance-1.9%). Conversely, the

share of the 5th scale, which has the highest price and represents consumption exceeding the highest

threshold, rose from 3.6% to 5.2% (percentage difference +1.6%). This relative increase in consumption

within the higher-priced scales resulted in a higher average invoiced revenue per cubic meter of water

for domestic tariffs compared to the previous year.

IMPORTANT EVENTS OF 2024

Implementation of the regulatory framework

On 27 September 2024, the new KYA (Law 5438/2024) "Determination of general rules for costing and

pricing of water services, measures for their improvement. Procedures and method of recovery of costs

of water services in its various uses" which replaced the decision of the inter-ministerial National Water

Commission on water pricing rules, annulled by the CoE No. 135275/19.05.2017.

In February 2025, the appeal of trade unions, employees of water supply and sewerage companies and

natural persons, users of the services offered by these companies, against the EIA (Law 5438/2024) was

discussed in the plenary session of the Council of State.

On 11 October 2024, the Minister of Environment and Energy published in the Government Gazette

(Government Gazette B' 5657/11.10.2024) the act of determination regarding the staffing and the

exercise of the new responsibilities of RAEAY for water and urban waste.

The Company, in relation to the implementation of the regulatory framework based on the EIA, is in

constant contact with the regulator. The process is in the process of reviewing the data from RAEAY in

order to calculate the allowed revenue of EYDAP S.A. from which the new tariffs will be derived.

The Ministry of Environment and Energy's Climate Change Bill.

In May 2024, Law 5106/2024 (Government Gazette A 63 - 01.05.2024) "Arrangements for addressing

the multi-level impacts of climate change in the areas of: a) water management, b) forest management

and protection, c) urban resilience and policy, d) combating unauthorized construction, e) energy

security and other urgent provisions" was passed.

Law 5106/2024 contains favourable provisions regarding the operational flexibilities and expansion

possibilities of the EIF. In addition, according to announcements by the Ministry of Energy and

Environment, a new legislative framework is expected regarding the possibilities of, inter alia,

geographical expansion of EYDAP. The above development initiatives require the immediate

reinforcement of human resources, both in terms of numbers and skills.

Water scarcity

To address the climate crisis and the prolonged drought, the Greek State, in cooperation with EYDAP,

has developed a comprehensive plan to ensure the water supply of Attica. The plan includes immediate

interventions, such as the interconnection of rivers with the Evinos reservoir and the reopening of

pumping stations and boreholes, as well as long-term solutions, such as the use of groundwater, the

use of brackish and seawater through desalination, and the possible transfer of water from the

Acheloos. At the same time, public awareness of water saving is being raised, with the aim of protecting

water resources and ensuring their sustainable use in the future.

If the same climatic and hydrological conditions continue and the State in cooperation with EYDAP do

not proceed with the necessary actions and actions, it is presumed that the reserves in the reservoirs

that supply Attica will last until the end of the hydrological period 2026-2027. The diagram below

shows, over time and by hydrological year, the total reserves in the reservoirs of EYDAP Fixed Assets

Company L.E.P.L., which supplies water to EYDAP.

The actions and plans to address water scarcity are detailed in the "Risks and Uncertainties" section of

this document.

Investment programme

In 2024 the absorption of the project investment programme amounted to EUR 60.7 million, an increase

of 37% compared to the absorption in 2023. 24% of the 2024 absorption was paid by the E.U.

Investment in 2024 in absolute terms has quadrupled compared to the four-year period 2017-2020 as

the Company invested €60.7 million in 2024, up from €15.6 million per year. Q4 2024 saw an increase

in quarterly absorption to 99% compared to the absorption of Q3 2024 (78%), Q2 2024 (59%) and Q1

2024 (57%).

The approved investment programme 2025-2034 of €2.16 billion concerns :

- major projects in East Attica (€968.8 million)

- water supply network projects (€715.8 million)

- sewerage projects (€370.3 million)

- building, digital governance and transformation projects (€108.6 million)

50% of the project budget is funded by the EU

Signing of a new CLA

In May 2024, the new three-year Collective Labour Agreement was signed with a series of positive

interventions for the benefit of employees. Among other things, an average annual wage increase of

5.5% is foreseen for the next three years, in order to cover the inflation of the three years since the

previous Collective Agreement.

Also according to the CBA, the Company has the right to terminate the employment contracts of those

employees of its regular staff who reach the age of 67

and are entitled to receive a full main pension.

The Company undertakes to recruit new employees to the extent permitted by its institutional

framework.

Actions to reduce the carbon footprint

100

200

300

400

500

600

700

800

900

1000

1100

1200

1300

1400

1500

Οκτ Νοε Δεκ Ιαν Φεβ Μαρ Απρ Μαϊ Ιουν Ιουλ Αυγ Σεπ

2008-09 2009-10 2010-11

2011-12 2012-13 2013-14

2014-15 2015-16 2016-17

2017-18 2018-19 2019-20

2020-21 2021-22 2022-23

647.258

October

2024

October

2023

October

2022

Τotal available reserves of recent hydrological years (in million m3)

With Mornos pumping (Total dead volume=92 million m3)

Date

Available volume

(hm

)

Current hydrological year 17/4/2025 647.258

17/4/2024 913,062

17/4/2023 1.108,860

Average of the last 10

years

2016-2025 1.177,385

Recent years

As part of its environmental strategy and with the aim of transitioning to a low-carbon economy, EYDAP

S.A. implements an integrated programme of actions to achieve a zero carbon footprint, which focuses

on recording, reducing and offsetting greenhouse gas emissions.

1. Emissions Monitoring and Transparency

● The annual carbon footprint report was submitted to the official platform of the Ministry of

Environment and Natural Resources, certified by an independent evaluator.

● An energy audit is planned for 2025 for all EYDAP facilities, as required by the current

legislation.

2. Energy Transformation & Renewable Energy

● EYDAP collaborates with a specialized consultant for the financial evaluation and promotion

of the NET ZERO strategic programme, which includes:

o Production and supply of energy from RES

o Implementation of an energy plan for sustainable operation

● From 1 August 2024, a new electricity supply contract came into force, with a minimum of

50% from Renewable Energy Sources, with guarantees of origin.

3. Installation of Photovoltaic and MES

● The final terms of connection for photovoltaic net metering stations, with a total capacity of

11.72 MW, at EYDAP facilities, were approved by DEDDIE. An open tender is planned for their

construction within 2025.

● At the same time, applications for capacity increase and new Small Hydroelectric Projects

(SHPs), with a total capacity of 2.06 MW, for which a tender procedure is being prepared,

were approved by RAEAY.

● Photovoltaic stations with a total capacity of 2 MW are under construction in Acharnes and

Polydendri, Attica, which are expected to be completed within 2025.

4. Electrification and Sustainable Mobility

● The delivery of electric vehicles for the renewal of the fleet is underway.

● The installation of charging infrastructure (chargers) in selected EYDAP facilities is promoted.

EYDAP, consistent with the principles of sustainable development, invests strategically in energy

transformation and in reducing its environmental footprint, ensuring the resilience of its infrastructure

and compliance with national and European climate targets.

Ordinary General Assembly

The 42nd

Annual General Meeting of the Company's Shareholders was held on Thursday, July 11, 2024,

at 10.00 a.m.

During the meeting 82.991.596 common nominal shares and corresponding voting rights were

represented for a total of 106.500.000 common nominal shares, i.e. 77,93 % of the paid-up share

capital. Consequently, the quorum required by law and the Articles of Association for discussing and

deciding on the items on the agenda has been met.

The General Assembly:

-On the first item, it approved the Individual and Consolidated Annual Financial Statements of E.Y.D.A.P.

S.A., in accordance with International Accounting Standards and International Financial Reporting

Standards (IFRS/IFRS) for the financial year from 1 January 2023 to 31 December 2023, the

Management Report of the Board of Directors of E.Y.D.A.P. S.A. and the Audit Report of the Statutory

Auditors of E.Y.D.A.P. S.A. thereon.

-On the second issue, it approved the distribution of the dividend of the profit for the financial year

2023 in the amount of € 10.650.000, i.e. a dividend of € 0,10 per share and determined the beneficiaries

of the dividend and the date of payment. After withholding tax of 5% (€0.005 per share), the net

dividend payable amounts to €0.095 per share. The cut-off date was set on July 22

, 2024 and the

beneficiaries were determined to be the holders of the Company's shares registered in the S.A.T. on

July 23

, 2024 (Record date). The dividend payment date was set on July 29

(a),

2024 in accordance with

the procedure provided for by the Athens Exchange Regulation. The General Meeting further

authorized the Board of Directors to take all necessary actions to implement this resolution, including

the selection of the paying bank.

- On the third item, it adopted, pursuant to Rules 108 and 117(1) of Law 4548/2018, the overall

management of E.Y.D.A.P. S.A. by the Board of Directors and released the Auditors from any liability for

compensation for the financial year 01.01.2023-31.12.2023.

- On the fourth issue, it approved the amendment of the Articles of Association of E.Y.D.A.P. S.A. in

order to harmonize its provisions with the new legislative and regulatory framework for the operation

of E.Y.D.A.P. S.A. and in particular Law 5037/2023 (G.G. A' 78), Law 5045/2023 (G.G. A' 136) and Law

5106/2024 (G.G. A' 63).

In particular, it approved the amendment of the Preamble and Articles 1, 4, 8, 11, 13, 17, 18, 20, 22, 28,

35 and 36 and the repeal of the transitional provision in Article 46.

The amended Articles of Association are posted on the Company's website www.eydap.gr.

-On the fifth issue, approved the fees and expenses paid to the Members of the Board of Directors from

01.09.2023 to 31.12.2023, in accordance with the Remuneration Policy and the decision of the Annual

General Meeting of Shareholders of 06.09.2023.

- On the sixth issue, it determined the fees and expenses of the Members of the Board of Directors of

Hellenic Republic for the fiscal year 2024, following the decision of the Board of Directors No.

21778/14.06.2024, the relevant recommendation of the Remuneration and Nominations Committee

and the recommendation of 10.7.2024 proposal made by the Majority Shareholder "Hellenic State"

regarding the reconfiguration of item 4 of the Board of Directors on the sixth item of the agenda as

follows: "For the Chief Executive Officer, the payment of €140,000.00 gross salary, plus employer

contributions, per annum.

- On the seventh item, approved with an advisory vote the Report of the Remuneration of the Members

of the Board of Directors for the financial year 2023 in accordance with article 112 of Law 4548/2018.

The Remuneration Report is available on the Company's website www.eydap.gr.

- On the eighth item, it approved the revision of the Remuneration Policy following the Board of

Directors' decision 21780/14.06.2024 and the relevant recommendation of the Remuneration and

Nominations Committee. The revised Remuneration Policy is posted on the Company's website

www.eydap.gr .

- On the ninth item, it approved the revised Nomination Policy following the Board of Directors' decision

No. 21781/14.06.2024 and the relevant recommendation of the Remuneration and Nomination

Committee The revised Nomination Policy is posted on the Company's website www.eydap.gr.

- On the tenth item, it elected the Audit Company "GRANT THORNTON S.A." setting at the same time

its fees in the total amount of 139.000,00 €, plus VAT for: a) the audit of the Annual Financial

Statements, b) the Review Report of the Interim Condensed Half-Yearly Financial Statements, c) the

issuance of the Tax Certificate, d) the issuance of the Independent Auditor's Report for the audit of the

completeness of the information included in the Remuneration Report, in accordance with article 112

of Law 4548/2018, e) the issuance of a Verification Report by an Independent Certified Public

Accountant for the inclusion of electricity consumption of electricity suppliers in the reduced charges

of the Special Tax for the Reduction of Air Pollution Emissions, in accordance with article 14 of the G.G.

B' 3152/30.07.2020, f) the issuance of an External Assurance Report of a limited scope of the entire

Sustainability Report 2024, in accordance with the European Sustainability Reporting Standards ESRS-

European Sustainability Reporting Standards, g) the issuance of an Assurance Report on the compliance

of the financial statements with the provisions of the ESEF Regulation, as applicable on the basis of the

relevant regulations on the European Standard Electronic Reporting Format (ESEF) and h) the issuance

of an Audit Report for the certification of scientific and technological research expenditures in

accordance with Article 22A of the Law.4172/2013 as amended by Law 4965/2022.

On items 11 and 12, for which no decision is required, the General Meeting took note of the submitted

Annual Report of the Audit Committee of the Board of Directors for the financial year 2023 as well as

the Report of the Independent Non-Executive Members, which they submitted jointly to the General

Meeting. The above are available on the Company's website www.eydap.gr.

Law 5131/2024 (G.G. 128/A/2-8-2024) "Restructuring of the Hellenic Holding and Property Company

and its subsidiaries and other provisions".

In August 2024, Law 5131 was passed, which concerns the restructuring of the Hellenic State Property

Fund (Hellenic State Property Fund).According to article 5 of the law, until 31 December 2024, the

Hellenic State Property Fund (Hellenic State Property Fund) will be absorbed by and merged with the

Hellenic Holding and Property Company (Hellenic State Property Company). For this purpose, a contract

is signed between the Boards of Directors of T.A.I.P.E.D. and E.E.SY.P., which is countersigned by the

Minister of National Economy and Finance as the representative of the sole shareholder of E.E.SY.P, is

published in the Government Gazette and registered in the G.E.I.M.E. With the registration of the

merger agreement in the G.E.M.E., E.E.SY.P. is automatically substituted as the universal successor to

all the property, rights, obligations, powers and legal relations of T.A.I.P.E.D. in general.

The merger agreement was signed on 23 December 2024 (G.G. B' 7093/24-12-2024), which was

registered in the General Commercial Register (G.E.M.I.) on 31-12-2024. Following the merger, the

11.33% of the share capital and voting rights of EYDAP directly held by the joint stock company named

"PUBLIC PROPERTY DEVELOPMENT FUND OF THE PUBLIC SOCIETY S.A." (H.I.I.P.E.D.) was transferred on

31-12-2024 to the company named "Hellenic Holding and Property Company S.A.".

Also, article 15 of the law stipulates that the compensation from the re-transfer of all the shares of

E.Y.D.A.P S.A. and E.Y.A.TH S.A. held by E.E.SY.P. to the Greek State, according to para. 1 of article 64 of

Law 5045/2023, which amounts to EUR 607,000,000, is returned to E.E.SY.P. and is allocated as follows:

a) 50 % of the compensation is paid by E.E.SY.P. directly to the Greek State, within 30 days of its

collection and is allocated for the repayment of the international obligations of Law 5045/2023.

4336/2015 and b) the remaining 50% of the compensation is allocated for the formation of a special

reserve, in order to be used as initial investment capital of E.E.SY.P. for the establishment of its

Investment Fund.

Cooperation with EIB (EIB).

On 5 July 2024, a Technical Assistance Agreement was signed between the European Investment Bank

(EIB) and EYDAP to support the implementation of its investment programme. The cooperation

between the two parties is ongoing.

The support is provided through the INVEST EU ADVISORY HUB programme and Agreement No AA-

011391, signed to explore the possibilities of cooperation and the inclusion of EYDAP projects in an EIB

programme.

In the framework of the project, the Investment Programme of EYDAP was evaluated in terms of its

viability, in line with the financial and operational assessment of the company, and in terms of its

feasibility, in line with the strategic axes and strategic priorities of EYDAP. In addition, it has been

examined in terms of its alignment with EU policy priorities (EU Strategic Agenda 2024-2029) and the

investment priorities of the EU Structural Funds/ NSRF 2021-2027.

Through the cooperation with the EIB, it is expected to support actions to strengthen existing water

and sanitation infrastructure in adverse climate crisis conditions in the context of strengthening

resilience and adaptation to climate change.

The agreement will overcome investment barriers and ensure project financing to address market

weaknesses and mitigate investment gaps.

DEVELOPMENT OF WORKS AND ACTIVITIES 2024

Water supply

● Contracts were signed and work started on the E-894 works, which concern projects to

optimise the operation of the water supply network.

● The construction of the project "Utilization of water from the Adrian Aqueduct for the

irrigation of the green areas of the Municipality of Halandri" was further developed.

● The project "Renovation - Upgrading of Tanks and Pumping Stations of the Water Supply

Network of E.Y.D.A.P. S.A." continued, interventions have been implemented in 8 tanks

of the water supply network.

● The tender procedure for the project for the restoration of the two-way operation of the

closed Mornos-Marathon Unitary Aqueduct F1800 with code E-907 was completed.

● At the end of the first half of 2024, the drilling of Mavrosouvala and the floating pump

stations of Yliki were put into operation, in order to start supplying the water supply

system of the basin with water from the reserve operating branch, due to the reduction

of water reserves in the reservoirs of EYDAP SA.

● The procedures for the activation of the project "Restoration of the functionality and

reintegration into the EIS, of the Middle Roo Boeotiko Kifissos boreholes

(implementation in two stages)" have been initiated in order to evaluate their water

potential and determine their existing pumping capacity.

● The studies of the following projects, which were awarded to EYDAP SA by virtue of the

contract no. YPEN/D18/117253/524/29.10.2024 Decision of the Minister of Environment

and Energy and their execution is scheduled within the year 2025:

1. Stabilisation and sealing project in the Kithero Canal in the Kokkini area. Project code

E-925

2. Project for the protection of the Mornos Aqueduct from rock falls in the Kithairon

Canal. Project Code E-916

3. Intervention Completion Project in the Thibon Canal of the Mornos Aqueduct.

Project Code E-924.

● The 4th sludge drying unit in the Galatsion ICU was completed. Through the completion

of all four (4) respective projects at the four (4) WWTPs of EYDAP SA, the saving of water

resources and full compliance with the approved environmental conditions of the

WWTPs is achieved.

Sewerage

● The contract for "Digitisation and Integrated Fault Management" was implemented.

Upgrading of the Sewer Portal database by recording the most frequent faults for their

more efficient resolution.

● A tender was launched for the provision of services for a pilot project for the application

of bioenhancement in the sewerage network and sewage pumping stations.

● Renovations/repairs were carried out in the newly delivered networks of the

Municipalities of Salamina and Megareon.

● Automation systems (panels, PLCs, meters, 24V power supply panels, metering units)

were installed and the new pumping stations of the Municipality of Salamina and the

Municipality of Megara were integrated into the new SCADA.

● Disinfection systems were installed at pumping stations No29 and No31, to address the

environmental impact in emergency situations when the overflow pipeline is activated,

● Best innovative technologies and practices were applied:

1. Thermography service

This service aims at the early detection of critical points and the prevention of electric

field faults and vulnerabilities during normal use of the installations

By recording the status of the components (electrical or mechanical), it is possible to plan

in relation to spare parts and their availability.

2. Surveillance and diagnostic control system of rotating electrical machinery SAMPRO

(XYLEM) at pumping station A29 and NOVA /ICT at pumping station No4

The algorithm has the ability to detect deviations in operation much earlier than the time

when the user would be aware of them. Utilizing this information results in fewer

mechanical failures and proper preventive maintenance.

● Increased the number of sampling of controlled businesses by 50% (1,454 sampling in

2024 compared to 973 sampling in 2023) and conducted 233 autopsies in controlled

businesses

● They participated in the research project TRINEFLEX of KEL Koropi which includes the

creation of a digital twin of KEL with the aim of energy optimization

● K.E.L. Psyttalia

1. Contractual energy optimisation and facility upgrade works were carried out on

schedule.

2. Achieved a Percentage Reduction of Annual Energy Supply (ARP) during the second

contract year (02.04.2023 - 01.04.2024) of 26,65%, against a guaranteed target of

18,07%, compared to the base year ("July 2017 ÷ June 2018")

Internal Infrastructure and Operations

Digital governance

Digital transformation is a priority for EYDAP, aiming to effectively serve customers and optimize

its services. Its strategy focuses on growth, efficiency and security, through the implementation

of digital services that meet the needs of citizens and safer operation of the company.

In 2024, EYDAP took significant actions to strengthen cybersecurity, such as the installation of a

security operations centre (SOC/SIEM), the alignment of its security policy with international

standards and the assessment of cybersecurity risks. In addition, upgrades to central information

systems such as ERP with SAP B1 and Sharepoint (Aquaportal) were completed, as well as the

interface with the AADE for electronic invoicing.

The digitisation and automation of processes has helped to reduce operational costs and increase

transparency. EYDAP introduced a "one-stop-shop" facility for customers and notification of

planned breakdowns. Infrastructure upgrades and expansion of network systems include new

facilities in Salamina, Megara and East Attica, while upgrades to SCADA systems continue to

improve monitoring of water and wastewater networks.

EYDAP also set up a data governance system and an Open Data Hub, providing public data on

water and wastewater management. In addition, digital services for customers were enhanced,

offering features such as downloading bills in pdf format and online debt repayment.

These actions strengthen EYDAP's digital infrastructure and support its strategy to modernize and

better serve its customers.

Projects in East Attica

Regarding the sewerage projects in Eastern Attica, which constitute the largest part of EYDAP's

investment programme, in 2024, 171 million euros worth of contracts were under construction.

● New contracts for the construction of sewerage networks

In April 2024, the contract for the construction of the sewage network in the settlements

of Grammatiko, Kalentzi, Ano Souli and Agios Panteleimon (part of the settlement) of the

Municipality of Marathon, 31 km long, was signed.The project is currently underway and

is co-financed by the Recovery and Resilience Fund.

In 2024, the tender procedure for the award of the 192 km long sewage network

construction project for the settlements of Spata and Artemis was completed and the

contract was signed in February 2025. The project is currently underway and is co-

financed by the Cohesion Fund through the Environment and Climate Change

Programme 2021-2027.

● Manufactured physical object (to date)

Since the start of the works to date, a total of 316 km of sewerage pipelines have been

constructed in the Municipalities of Pallini, Peania, Rafina-Pikermio, Spaton-Artemis and

Marathon, 10.500 external branches to connect the properties, and the 1,070 m long

hydraulic tunnel (May 2024) of the sewerage project of the Municipalities of Rafina-

Pikermio and Spata-Artemida has been fully opened, which is part of the project with

special and complex construction requirements.

● Progress of economic object (Dec 2024)

Based on the signed contracts, the approved amendments (APE, PPA) and the approved

work certifications, the absorption from the start of the works until December 2024

amounted to €55.8 million, which corresponds to 32.6% of the total contract value of

€171 million.

During 2024, management issues arose regarding the flow of funding of projects from

the NSRF, which are not related to EYDAP SA. In order to ensure the smooth continuation

of the works and their accompanying sub-projects, EYDAP SA has covered part of the

costs that were temporarily not feasible to be covered by the NSRF (through the PDE).

The costs paid will be reimbursed to EYDAP SA through the relevant procedure and

cooperation with the funding bodies.

Despite the difficulties and delays that occurred in the flow of NSRF funding during 2024

as well as in the construction of the projects due to the detection of archaeological finds,

extreme weather phenomena, etc. that had an impact on the absorption/disbursement

of the funds, the progress of the annual investment programme of EYDAP S.A.'s projects

in East Attica reached, at the end of the year 2024, 78% of the total annual planning.

● Progress of the physical object (Dec 2024)

As regards the implementation of the physical scope of the sewerage projects underway

in Eastern Attica, the constructed length of pipelines amounts to 44% of the total.

The external branches to connect the properties to the sewerage network have been

constructed in 35 % of the total.

TOTAL

IN PROGRESS

CONSTRUCTED

UP TO DEC 2024

Pipeline Length Meters

692.110

304.512

No. external connections

29.180

10.131

EYDAP Nison Development S.A.

In July 2011, EYDAP NISON S.A. was established, in whose share capital EYDAP S.A. participates with a

100% stake.At the Extraordinary General Meeting of 21/9/17 it was decided to change the name to

EYDAP NISON DEVELOPMENT S.A.

The purpose of the company is to provide consulting services in water supply, sewerage and a variety

of activities related to the above, in the Greek territory outside the areas of jurisdiction of EYDAP S.A.

By decision of the Extraordinary General Assembly at 10

November 2023, the composition of the

Board of Directors was modified as follows:

Charalambos Sahinis Chairman of the Board and CEO

Petros Matsoukis Member of the Board of Directors and General Manager

Georgios Karagiannis Member

Konstantinos Vougiouklakis Member

Emmanouil Aggelakis Member

The term of office of the Board members expires 25-5-2027 according to the General Assembly of

November 10, 2023.

During 2024:

• A contract was signed with the Municipality of Zakynthos for "Support and Consulting

Services by EYDAP NISON DEVELOPMENT S.A. for Water Supply Network Improvement

Projects" and is in progress

• Completed on 17/10/24 the contract with the subject "Provision of Technical Support for

water supply projects and services of the municipality of Heroic Island of Kasos"

• Completed the contract signed on 16/7/24 with the subject " Repair and maintenance

services of Kalamata sewerage networks.

• Contract executed with DEYA Larissa for the cleaning of the central sewage pumping station

of Larissa

• Contracts were executed with the Municipality of Tinos for the cleaning and blocking of

sewerage pipelines as well as the cleaning of pumping station tanks, sewerage & control of

the operation of the E/M systems.

• Signed a contract with the Municipality of Astypalaia for a) cleaning of four sewage

pumping stations and b) cleaning of 900 meters of the sewerage network of the settlement

of Astypalaia.

• In the framework of the Memorandum of Understanding signed on 6-5-22 between EYDAP

SA and the Ministry of Agriculture, Rural Development and Environment, Nicosia Water

Supply Council, Limassol Drainage Board, Larnaca Drainage Board, meetings for the exchange

of scientific and technical information were held in Cyprus and Athens. The coordination

between the working groups of Greece and Cyprus has been undertaken by the General

Manager of EYDAP NISON DEVELOPMENT S.A.

As part of its Corporate Social Responsibility, EYDAP NISON DEVELOPMENT S.A. conducted a video

inspection of sections of the sewage network in very narrow streets of Aegina.

Regarding the prospects of cooperation in 2025, the Municipality of Heroes Island of Kasos asks for the

continuation of the provision of consulting services with a new annual contract, while it is in

cooperation with the Municipality of Central Corfu regarding water supply problems of the island.

Cooperation is also expected with the Municipalities of Tinos, Zakynthos and Amyntaio-Florina.

FORESEEABLE FUTURE AND EVOLUTION

EYDAP, having the exclusive right to provide water supply and distribution services and sewerage

services in the Attica region until 2040, serves 40% of the Greek population.

As the largest water supply and wastewater services company in Greece and one of the largest in

Europe, it ensures with consistency, responsibility and sensitivity to provide excellent quality water

along with modern and uninterrupted wastewater and biological treatment services to the population

of Attica, while at the same time safeguarding the natural environment.

Having as its primary objective the best possible service to its customers, as well as the perfect

management of water, its high level of expertise guarantees the coverage of the needs of the

population served and the efficiency of the use of resources.

In 2024, the prolonged drought, combined with the increase in consumption due to the high

temperatures that prevailed, led to a significant reduction in the reserves in the reservoirs of EYDAP

Pagion, the company owned by the Greek State, which supplies the undiluted water to EYDAP S.A.

according to the contract of Law 4812/2021 between the Greek State, EYDAP Fixed Assets and EYDAP

S.A. EYDAP, due to the importance of the sufficiency of untreated water in its operation, as a supporter

of the Ministry of Energy and Environment and in continuous cooperation with it, proceeded in

accordance with the existing planning to mitigate the effects of water scarcity by activating alternative

sources of water supply (boreholes, Lake Yliki) and consumer awareness campaigns to avoid wasting

the natural resource. The company has also already studied medium and long-term projects and

measures to ensure that the safe water supply of citizens is not threatened.

EYDAP continued to give priority to the implementation of its investment plan, which is a guarantee of

sustainable development and safeguards the right of access of the residents of Attica to vital water

supply and sewerage services. The absorption of the plan has increased by 37% compared to 2023,

while investments in 2024 in absolute terms have quadrupled compared to the four-year period 2017-

2020, as the Company has made investments of €60.7 million in 2024, up from €15.6 million per year.

Regarding the Company's projected course in 2025, the Company expects the full implementation of

the regulatory framework, while continuing its important investment project mainly in East Attica.

EYDAP, in relation to the implementation of the regulatory framework based on the new EIA, is in

constant contact with the regulator. The implementation of the regulatory framework is essential for

the viability of the Company and the continuation of its important investment programme which is

necessary to meet the needs of consumers and to protect the natural resource and the environment.

The process is currently underway for the examination of the data by RAEAY in order to calculate the

allowable revenue of EVDAP from which the new tariff will be derived.

In February 2025, the public consultation on the draft law of the Ministry of Environment and Energy

entitled: "Modernization of the framework of water supply and sewerage services and urgent energy

and urban planning regulations". The new law is expected to provide, inter alia, opportunities for

geographical expansion to EYDAP.

The Company has placed particular emphasis on strengthening its ESG strategy. To this end, it has

established measurable indicators for the environment, society and good governance, based on

internationally recognised standards, which are systematically monitored and for which improvement

actions have been developed, linked to the strategic triple bottom line of Safety, Efficiency, Growth. A

clear objective of the Company's strategy is to reduce our carbon footprint and make a substantial

contribution to strengthening the resilience of its infrastructure and the communities in which it

operates and develops, as well as to enhancing its adaptive capacity against the risks and natural

disasters resulting from climate change.

MAIN RISKS & SAFETIES

CAPITAL MANAGEMENT

The Company manages its capital in such a way that it fulfils its objectives as stated in paragraph 4a of

article 1 of Law 2744/99. Furthermore, in accordance with paragraph 8 of the same Article, the creation

of a right in rem over its immovable fixed assets used for the exercise of its activities related to the

provision of water supply and sewerage services is prohibited. It is noted that according to Article 5 of

the same law, no compulsory execution may be levied on the assets of EYDAP used for the exercise of

its activities related to the provision of water supply and sewerage services.

The Company currently has no borrowings, either long-term or short-term. Since its listing in 2000 and

up to 2013, the Company had mainly engaged in short-term borrowings to meet its operating

obligations due to non-payment of water bills by certain local authorities and other public bodies.

The Company ensures that it maintains a sufficient amount of capital to serve its purposes by applying

an appropriate dividend policy.

Debt burden index

GROUP

COMPANY

Amounts in thousands of Euros

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Borrowings

Cash Available & Equivalents

(299.639)

(325.795)

(298.797)

(324.974)

Total equity

827.528

847.259

827.827

847.571

Net debt to equity ratio

FINANCIAL RISK MANAGEMENT

Financial risk management is carried out by the Company's relevant Directorates, which operate under

specific rules approved by the Board of Directors.

The Board of Directors sets the objectives, defines the policy, selects the risk management framework,

the implementation of which is entrusted to the Company's executives. The existence of a risk

management framework is of central importance and the monitoring process is structured, continuous

and ongoing.

(1) Credit risk

The Company's exposure to credit risk is limited to the following financial assets which are analysed as

follows:

GROUP

COMPANY

Categories of financial assets

31.12.2024

31.12.2023

31.12.2024

31.12.2023

Financial assets at fair value through other

comprehensive income

853

907

853

907

Cash and cash equivalents

299.639

325.795

298.797

324.974

Trade and other receivables and Contractual Assets

203.864

181.786

203.807

181.720

Long-term receivables

22.793

15.418

22.793

15.418

Investments in subsidiaries

1.210

Total

527.150

523.906

527.460

524.229

Trade and other receivables include receivables from retail customers, for which there is a related risk,

which is mitigated by the measures and actions taken by the relevant Directorates. The actions relate

to the taking of measures to deal with overdue debts and the provision of facilities for their repayment.

For the category of local government debts, the Company examines the possibility of collecting the

overdue debts through the drafting of contracts (network management or settlements) or through

legislation.

The Group and the Company use a methodology for measuring the impairment of financial assets in

accordance with IFRS 9.

Below is a time analysis table for the Company's requirements:

Amounts in thousands of Euros

CHRONOLOGICAL ANALYSIS OF OUTSTANDING CLAIMS

2024

Not overdue

0-1 month

1-6 months

6 months-2

years

2 years-5

years

> 5 years

Total

PRIVATE

32.412

9.996

21.037

30.236

29.070

55.502

178.253

PUBLIC

2.330

809

2.057

3.915

2.888

10.155

22.154

OTA

6.110

1.808

7.007

17.327

8.034

3.690

43.976

Total

40.851

12.613

30.101

51.478

39.992

69.347

244.383

2023

Not overdue

0-1 month

1-6

months

6 months-2

years

2 years-5

years

> 5

years

Total

PRIVATE

30.213

6.117

22.219

34.010

28.681

52.349

173.589

PUBLIC

2.360

134

1.635

3.127

2.398

10.244

19.899

OTA

5.644

331

9.267

11.216

3.723

3.340

33.521

Total

38.218

6.583

33.121

48.353

34.802

65.933

227.009

The Directorate for Revenue Management & Receivables and the Special Clients Management Division

continuously monitor the Company's receivables from customers, either separately or by group (invoice

codes, customer categories) and incorporate this information into the credit control procedures.

In order to address the credit risk, the Debt Collection Service of the Legal Services Department

examines on a continuous basis and settles through the judicial process (Law 356/1974 "Code of Public

Revenue Collection") overdue debts to be collected from water abstraction, rights of use and rights of

connection of real estate from individuals and local authorities

The cash and cash equivalents are subject to impairment testing in accordance with the requirements

of IFRS 9 and the estimated impairment loss is not considered to be material. Credit risk is managed by

concentrating the majority of the Company's cash and cash equivalents with the Bank of Greece

(approximately 60%) and limiting exposure to other domestic credit institutions (mainly System Banks).

None of the financial assets are secured by a mortgage or other form of credit security.

Similarly, the Company has not assigned any financial instruments of the assets to third parties as a

form of guarantee.

(2) Liquidity risk

Liquidity risk is managed by maintaining sufficient cash and securing bank credit for use. There is no

liquidity risk due to the existence of significant cash resources sufficient to meet current operating and

investment needs.

The following table analyses the Company's financial liabilities, classified into relative grouped maturity

dates, which are calculated according to the time remaining from the balance sheet date to the

contractual maturity date, at undiscounted prices.

(3) Market risk

Market risk relates to the Company's equity portfolio, which is a long-term, strategic investment and is

therefore limited to predetermined position limits.

(4) Water scarcity

Total consumption in 2024 was affected by warmer weather conditions, with less rainfall compared to

the previous year, combined with the African dust transport episodes observed in spring and early

summer, and showed a significant increase of 6.2% compared to 2023. Temperatures for the year

moved above the long-term average for the seasonal data, and particularly in the summer and the

month of April, were even higher, exceeding the long-term maximum. Similarly, in a direction also

favourable to consumption, rainfall for the year was at a reduced level in terms of number of days and

volume compared to the long-term average, especially during the period between February and June

2024 compared to the same period of the previous year, but also in the October-November period for

seasonal data.

To ensure the water supply of Attica under the new conditions created by the climate crisis and the

repeated prolonged drought, the Greek State in cooperation with EYDAP has drawn up a plan to ensure

water sufficiency, including immediate interventions and long-term solutions for the enhancement of

water reserves, the use of alternative sources and consumer awareness.

CHRONOLOGICAL ANALYSIS OF OBLIGATIONS

2024

0-1

Months

2-3 Months

3-6 Months

6-12 Months

1- 5 years

> 5 years

Total

Borrowings

Employee benefit obligations

78.474

235.833

314.307

Provisions / Other long-term liabilities

54.467

Suppliers & Other Liabilities

36.825

52.024

7.802

5.764

102.415

Untreated water surcharge

29.133

Liabilities from leases

145

218

377

1.945

192

2.951

Total

36.898

52.169

37.153

6.142

80.419

290.493

503.273

2023

0-1

Months

2-3 Months

3-6 Months

6-12 Months

1- 5 years

> 5 years

Total

Borrowings

Employee benefit obligations

71.764

221.623

293.387

Provisions / Other long-term liabilities

58.939

Suppliers & Other Liabilities

16.681

39.310

11.945

15.872

83.809

Forecast of the unfinished charge

27.785

Liabilities from leases

139

209

394

1.715

523

3.049

Total

16.750

39.449

39.939

16.267

73.479

281.085

466.969

Specifically, in order to maintain the sufficient supply of the Athens Basin with natural flow without

pumping, projects are being promoted immediately, in cooperation with the Greek State, to

interconnect the rivers Krikeliotis and Karpenisiotis with the Euinos reservoir, ensuring in the future the

full sufficiency of water even in extreme conditions.

At the same time, the pump stations of Yliki have been put into operation, while the Mavrosouvala

wells are being modernised and reopened.

In addition, the possibility of exploiting underground aquifers along the Mornos aqueduct, including

the Boeotian Kifissos, is being considered in order to minimise the use of the Euinos-Mornos reservoirs.

At the same time, the possibility of using brackish water from exploitable deposits in the wider area of

the Mornos aqueduct (e.g. Kirra) is being explored, as well as the possibility of using seawater through

desalination plants, for which studies are being launched.

For the immediate reinforcement of the water supply system, in case of extreme water scarcity, the

transfer of water from the river Acheloos is planned. The water will be transported by sea, with special

tankers, from the port of Astakos to the ports of Aspron Homes and Thisvi, and from there it will be

pumped into the external water supply network.

Information on water saving opportunities for consumers, local authorities and industry continues to

be provided. Particular emphasis is placed on the substitution of drinking water with non-potable

(untreated or recycled) water for uses other than human consumption and hygiene.

To reduce leaks in networks, which are a cause of water loss, a target has been set to reduce them to

8%-9% by 2029 - rates that are considered optimal according to European water network management

practices.

EYDAP is implementing a demanding ten-year investment plan, which aims, among other things, to

upgrade the water supply network and improve water treatment infrastructure. Within this plan,

priority is given to projects to modernise and expand the water supply system, with the aim of ensuring

water sufficiency in Attica. These interventions include the replacement of old pipelines, the

reinforcement of storage tanks, the development of technological solutions for water management and

the reduction of leakages.

The replacement of water meters is a central pillar of EYDAP's strategy, as available data shows that old

water meters are responsible for a large part of the leaks and inaccuracies in consumption records. The

plan foresees the gradual replacement of all conventional water meters with smart meters in order to

reduce deviations in consumption and reduce unbilled water. The investment to replace the water

meters is already underway, and the plan is to complete the process by the end of 2026.

(5) Unsafe water supply in Attica due to failure of the external aqueducts

EYDAP recognised and assessed the risk of unsafe water supply to Attica due to the failure of the

External Water Supply System, which is owned by the State. EYDAP provides safe and uninterrupted

water supply services by treating raw water supplied by the Greek State. According to Article 7

'Obligation to supply Raw Water' of the current Contract, 'The State is obliged throughout the Contract

Period to supply the Beneficiary with Raw Water in accordance with the terms of this Contract and in

any case on the basis of the criteria set out in Articles 8 (Quantitative Characteristics) and 9 (Qualitative

Characteristics) of this Contract.' Therefore, in the event of failure to supply raw water to EYDAP, the

financial loss will be borne by the Greek State.

In order to mitigate this risk, it has initiated the implementation of the upgrade projects of the external

Water Supply System that it has agreed with the Addendum to the Contract of 2.2.2022 between the

Greek State and the companies "EYDAP Asset Company" and "E.YD.A.P. S.A.".

Law no. 5106 Government Gazette A 63/1.5.2024, which concerns, among other things, the regulations

for addressing the multilevel impacts of climate change in the water management sectors, requires

studies to identify the necessary works for the safe shielding of the External Water System. The Board

of Directors of EYDAP approved by its resolution no. 21861/14-6-2024 the draft contract between the

Hellenic State, EYDAP Asset Company and EYDAP for the eighteen-month extension of the contract

from 2.2.2022 contract for the awarding of the operation and maintenance services of the EIS to

EYDAP, which was due to expire on 30/6/2024, in order for EYDAP to use its experience and expertise

to meet the relevant legal requirements and to launch the necessary technical projects that will be

assigned to it. In this context, within 2024:

● The tender procedure for the project for the restoration of the two-way operation of the

closed Mornos-Marathon Unitary Aqueduct F1800 with code E-907 was completed.

● At the end of the first half of 2024, the drilling of Mavrosouvala and the floating pump stations

of Yliki were put into operation, in order to start supplying the water supply system of the

basin with water from the reserve operating branch, due to the reduction of water reserves in

the reservoirs of EYDAP SA.

● The procedures for the activation of the project "Restoration of the functionality and

reintegration into the EIS, of the Middle Roo Boeotiko Kifissos boreholes (implementation in

two stages)" have been initiated in order to evaluate their water potential and determine their

existing pumping capacity.

● The studies of the following projects, which were awarded to EYDAP SA by virtue of the

contract no. YPEN/D18/117253/524/29.10.2024 Decision of the Minister of Environment and

Energy and their execution is scheduled within the year 2025:

1. Stabilisation and sealing project in the Kithero Canal in the Kokkini area.

2. Project for the protection of the Mornos Aqueduct from rock falls in the Kithairon Canal.

Project Code

3. Intervention Completion Project in the Thibon Canal of the Mornos Aqueduct.

(6) Cyber security

Shielding against cybersecurity risks is a high priority for EYDAP, which, through an organised

framework, is harmonised with the relevant legal and regulatory requirements.

The Company, taking into account Community and national standards and regulations, has set as a

priority to ensure the uninterrupted and uninterrupted operation of its information and network

systems, in the context of protecting the digital ecosystem and enhancing digital transformation.

2024,

● Completed the installation of a Security Operations Center, Information Management and

Security Incident Management (SOC/SIEM) services for the Information and Operational

Systems of Hellenic Public Sector SA, which oversees the 24/7 operation of the information

systems.

● A study was completed on the alignment of the Information Security Policy of EYDAP S.A., the

individual security policies and procedures with international standards and methodologies

(ISO27001, ISO22301, NIST CSF, NIS, NIS II).

● A specialized Cybersecurity risk profile assessment was completed, with the assistance of an

external consultant, which involves an extensive analysis of the cybersecurity risks faced by

EYDAP, based on five standards/frameworks (ISO27001, NIS 2, NIST, GDPR and C2M2), in order

to fully capture the Company's maturity level, which is adapted to the environment and the

requirements of the new regulatory framework.

● The self-assessment exercise of the National Cybersecurity Authority was also carried out, in

accordance with the legislation in force.

● Awareness and training of all staff on cybersecurity issues continued through a specialized

training platform and targeted information graphics,

● Technical security solutions were implemented to monitor and enhance the resilience of

digital applications against external threats.

(7) Understaffing of organisational units

The understaffing of EYDAP arises as a result of long-standing governmental restrictions on sufficient

recruitment through APSEP and threatens the implementation of the Company's strategic plan, as well

as the Company's safe response to the requirements arising from the new legislative framework of

climate crisis management requirements and response to the expansion of the area of responsibility.

The Company has assessed the risks of understaffing by recognizing the average age of its staff, the

requirements for the transfer of expertise and experience, the difficulty in formulating a succession

plan for critical positions necessary for the Company's business continuity, and is implementing a

human resources management model for the next decade, incorporating the necessary actions of

adequate and appropriate staffing. Explore ways to recruit sufficient permanent staff in a timely

manner to mitigate the risk of reliance on outsourcing. In particular to ensure drought resilience,

changes in the legislative framework have been called for to ensure flexibility in staffing, deployment

and human resource management.

(8) Security and protection of premises

Risks related to the safety of all facilities are a high priority, as they are directly linked to operational

resilience and ensuring uninterrupted water supply. EYDAP implements modern technologies to shield

against threats such as floods, earthquakes, fires, power outages, communication outages, malicious

acts that are likely to create problems in the smooth operation of the facilities, which are continuously

upgraded based on new technologies and practices. Designs and implements modern security, fire

safety and surveillance systems for buildings and facilities and provides appropriate training to staff to

incorporate desired modifications and improvements.

(9) Risks from Climate Change

EYDAP approaches climate risks as an opportunity to transition to a more sustainable, low-carbon

future and implements mitigation measures:

● It has incorporated in its strategy the improvement of energy efficiency and the reduction of

its carbon footprint

● It implements water demand management and leakage reduction programmes for the rational

and sustainable management of water resources. Replacing old water meters with new 'smart'

water meters using state-of-the-art technology. Network rehabilitation and replacement of

old pipelines with new pipelines made of advanced materials compatible with the natural

environment.

● It implements circular economy practices by launching wastewater reuse projects of the East

Attica WWTP for irrigation of peri-urban greenery, industrial and municipal purposes.

● Approaches use of technologies to improve the efficiency of water and wastewater treatment

plants

● It highlights alternative water resources for irrigation use such as the exploitation and

development of the Adrian Aqueduct

● Ensures that every effort is made to save energy and resources in all its activities and actively

contributes to the reduction of greenhouse gas emissions

● Applies with zero tolerance European and Greek regulations and standards, new and existing

environmental specifications in the design of water supply and sewerage projects

● Selects materials and machinery with modern environmental standards. Monitor and optimise

the cyclicality of the materials used. It seeks to ensure that products and materials (including

raw materials) remain in the life cycle for as long as possible, and that waste is treated as a

secondary raw material that can be recycled for processing and reuse (circular economy).

● Seeks to the extent feasible to replace part of its fleet with electric vehicles to contribute to

low greenhouse gas emissions

● It upgrades and modernises its buildings and facilities with new building materials and energy

systems.

In the context of the non-linear, unpredictable and irreversible nature of climate change, and due to

the need for long-term resilience and to ensure business continuity, EYDAP S.A. undertakes a detailed

assessment of the natural and transient climate risks and opportunities by type and location of facility.

For the purposes of this assessment, the most up-to-date scientific data and climate scenarios from the

5th and 6th Assessment Reports of the Intergovernmental Panel on Climate Change (IPCC) and high-

spatial resolution climate statistical analyses are taken into account. The purpose is to quantitatively

analyse natural and transient climate risks and opportunities, identify specific adaptation measures to

mitigate them, and prepare alignment reports for No Significant Impact (NSA) on Climate Change.

(10) Energy crisis

EYDAP has incorporated in its strategy approaches to optimise the energy utilisation of all its process

products and shields the company against any impact from energy price fluctuations, which have been

proven to affect its operating costs and profitability. The company is involved in a number of projects

focused on reducing energy consumption and recycling to the maximum extent feasible. To mitigate

the risk of rising energy costs in the future, it is strategically focusing on new technologies for sludge

management and energy recovery in the management of process products.

It aims to achieve the highest possible penetration of renewable energy based on best available

technologies and practices to avoid impacts on the natural environment.

It promotes electromobility, and seeks to improve the carbon footprint of buildings and infrastructure

through modernisation of buildings and implementation of energy saving approaches.

As part of EYDAP SA's strategy to achieve a zero carbon footprint by 2030, EYDAP :

In the context of EYDAP's strategy to achieve a zero carbon footprint by 2024, the Company collaborates

with a specialized consultant for the financial evaluation of the alternative actions of the NET ZERO

strategic programme for the supply and production of energy from RES and the implementation of the

energy plan. Also:

● The contract for the supply of electricity to the EYDAP SA facilities was awarded with a

requirement that 50% of this electricity be guaranteed to be from RES. The contract was

activated on 1/8/2024.

● The final terms of connection for the installation of photovoltaic net metering stations with a

total capacity of 11.72 MW at the facilities of EYDAP SA were approved by DEDDIE. An open

tender will be launched for the construction of the above RES stations in 2025.

● Applications for capacity increase and installation of new NPPs with a total capacity of 2.06

MW were approved by RAEAY. A tender procedure is being prepared

● Under construction installation of photovoltaic power plants with a total capacity of 2 MW

net-metering in Acharnes and Polydendri, Attica. The project will be completed within 2025.

● The electric vehicles are received in sections and the installation of the charger network within

the EYDAP facilities is initiate

TRANSACTIONS WITH RELATED PARTIES (GROUP & COMPANY)

A) Transactions with Members of the Board of Directors

Amounts in thousands of Euro

31.12.2024

31.12.2023

Short-term benefits:

- Remuneration (Chairman & CEO and Executive Directors)

203

273

- Fees & expenses of Board members.

352

274

- Social security costs

Additional Benefits

Total

654

656

B) Transactions with Associated

Amounts in thousands of Euro

31.12.2024

31.12.2023

Short-term benefits:

Remuneration of associated members

610

551

Social security costs

Additional Benefits

Actuarial liability

Total

770

717

An Executive Committee was established by the Board of Directors' Decision No. 21144/ 21.12.2022.

The members of this Committee are considered to be executives who are responsible for planning and

controlling the Company's activities in accordance with IAS 24 and for comparability purposes the

Company presents the amounts for the previous financial year as well.

Remuneration of Board Members

The Chairman and the Chief Executive Officer are associated with the Company on a paid mandate basis

and their fixed remuneration is considered as income from employment. Article 38 (4) of Law

4387/2016 defines the insurance and employer's contributions of the Company's employees.

The remuneration of each executive and non-executive member of the Board of Directors is approved

by the Board of Directors following a recommendation from the Remuneration and Nomination

Committee. The approval of the remuneration of executive members is made without the presence of

such members at the relevant Board meeting. The Board, following the above procedure, formulates

and submits a proposal addressed to the General Meeting of Shareholders of the Company for their

ratification.

The remuneration policy was reviewed and approved by the 42

Annual General Meeting and is posted

on the corporate website www.eydap.gr.

The 42nd Annual General Meeting of the shareholders of 11

(th)

July 2024 approved the fees and

expenses paid to the current members of the Board of Directors for their participation in the Board of

Directors during the period from 01.09.2023 to 31.12.2023, in the total amount of € 52,000.00, plus

employer's contributions and the gross expenses for representation and travel in the amount of €

11,591.52, plus employer's contributions. Details of the amounts are set out in the 2023 Remuneration

Report posted on the Company's website https://www.eydap.gr/TheCompany/RegFramework/.

Furthermore, the 42nd Annual General Meeting of the shareholders of 11

(th)

July 2024, taking into

account that the existing remuneration of the non-executive members of E.Y.D.A.P. S.A. is below the

range of the Greek market and does not reflect the degree of responsibility, the importance of the

position as well as the time that the members spend for the preparation and participation in the Board

of Directors.Board and its Committees, decided for the fiscal year 2024, to increase: a) the annual fees

and monthly expenses of the Board members for their participation in the Board of Directors at a rate

of ≈10% and b) the annual fees and monthly expenses of the Board members for their participation in

the Board Committees at a rate of ≈25%.

In particular, the compensation received by the members of the Board of Directors for their

participation in the meetings of the Board of Directors' Committees is disclosed in the section of the

Corporate Governance Statement.

C) Transactions and balances with the Greek State and local authorities

GROUP

COMPANY

Amounts in thousands of Euro

31.12.2024

31.12.2023

31.12.2024

31.12.2023

1) Transactions

- Revenue

84.009

81.400

84.009

81.400

- Expenses

29.265

27.911

29.265

27.911

2) Balances

- Long-term receivables from customers

(Municipal Arrangements)

6.701

3.652

6.701

3.652

- Receivables from customers (local authorities,

Greek State)

75.027

52.743

75.027

52.743

- Demand from E.YD.A.P. NISSON ANAPTYΞIAKI S.A.

- Other Receivables (from EAFRD from water

pumping)

6.998

- Short-term liabilities (provision for untreated

water charge)

29.187

34.339

29.187

34.339

Transactions with the Greek State and local authorities relate to invoiced and accrued water extraction

revenues, specifically, revenues include an amount of EUR 12,500 thousand invoiced by EYDAP SA in

2024 and accrued unbilled revenue for the second half of 2024 for the provision of operation and

maintenance services for the year 2024. The expenses mainly include the provision formed for an

undiluted water charge by EIFDAP for the year 2024, amounting to EUR 29.1 million.

D) Transactions and balances with other Related Parties consolidated with EUSYP SA

Amounts in thousands of Euro

31.12.2024

31.12.2023

1) Transactions

Revenue

884

Expenses

20.709

Dividend payments

31.12.2024

31.12.2023

2) Balances

Receivables from customers

3.920

Liabilities to suppliers

5.222

The above balances include a cumulative provision of EUR 2.4 million, mainly related to balances of

receivables formed in previous years by ETVA, Marina Zeas and EDF. According to article 64 of Law

5035/29.07.23, all shares of ownership of the Hellenic Company of Participations and Assets (Hellenic

Company of Participations and Assets) in the Athens Water Supply and Sewerage Company S.A.

(Hellenic Company of Water Supply and Sewerage of the Capital Region) are transferred to the Greek

State and therefore there are no transactions and balances consolidated with EESYP SA from now on.

DIVIDEND POLICY

The Annual General Meeting of the Shareholders of July 11th, 2024 decided the distribution of a

dividend of € 10.650.000, i.e. a dividend of € 0,10 per share gross.

The Board of Directors of the Company at its meeting on 29.04.2025 approved the proposal to the

Annual General Meeting of Shareholders for the distribution of dividend, in accordance with articles

159,160 and 161 of Law 4548/2018, in the amount of seven cents (EUR 0,07) per share, (total gross

amount in EUR 7.455 thousand). The dividend is subject to approval by the Annual General Meeting of

Shareholders and is included in the balance of the "Retained earnings" account.

IMPORTANT EVENTS AFTER THE END OF THE 2024 FINANCIAL YEAR

Finding of the management adequacy of EYDAP by RAEAY

In March 2025, RAEAY, within the framework of its responsibilities as defined in the provisions of

articles 12A and 12B of Law No. 4001/2011 (A' 179), and the under No. YPEN/DSSDY/53924/460/2023

(B' 3309), found the management capacity of E.YD.A.P. S.A. for the provision of water services.

Extension of the EES operating contract

For the period after 30.6.2024, a new contract for the operation and maintenance of the External Water

Supply System (EWS) has been drawn up between the EYDAP Fixed Assets Company L.E.P.L.(EPEYDAP),

EYDAP SA and the Greek State. This contract extends, under the same terms, the duration of the award

for a period of eighteen (18) months, from July 1, 2024 to December 31, 2025.

CORPORATE GOVERNANCE STATEMENT

This Corporate Governance Statement has been drawn up in accordance with the provisions of article

152 of Law 4548/2018, article 18 of Law 4706/2020 as well as the Greek Corporate Governance Code

2021, it is a special section of the Annual Management Report of the Administrative Council and

concerns all the principles and practices adopted by the Company in order to ensure its performance,

the interests of its shareholders and the interests of all interested parties.

The basic legislative framework that governs the operation and obligations of the Company is L.

4548/2018 on the reform of the law of joint stock companies and L. 4706/2020 on corporate

governance. The Company fully complies with the relevant existing legislation.

The principles and practices applied by the Company, some of which are in addition to those provided

for in the applicable legislation, are reflected in the Articles of Association, the Operating Regulations,

the Greek Code of Corporate Governance 2021, the Code of Ethics and Professional Conduct, as well as

in other Regulations and Policies of the Company which regulate its individual functions and are

specifically mentioned below. The fundamental corporate documents are available on the Company's

website https://www.eydap.gr/TheCompany/RegFramework/ .

The structure of this Corporate Governance Statement is as follows:

A. Corporate Governance Code - Compliance Statement

Β. Deviations from the Corporate Governance Code and Explanations

C. Board of Directors and Committees of the Board of Directors - Other administrative, management or

supervisory bodies or committees

D. Diversity policy applicable to the administrative, management or supervisory bodies

Ε. General Meeting & Shareholders' Rights

F. Internal Control System

Ζ. Reference to the information provided in cases c', d', e', g' and h' of Article 4 par. 7 of Law 3556/2007.

Α. Corporate Governance Code - Compliance Statement

EYDAP with the No. 20905/7.7.2021 Decision of its Board of Directors, adopted and implemented in

accordance with Article 17 of Law No. 4706/2020 and No. 2/905/3.3.2021 Decision of the Board of

Directors of the Capital Market Commission on the Greek Corporate Governance Code for companies

with securities listed on the stock market (hereinafter "GCGC"), issued in June 2021 by the Hellenic

Corporate Governance Council and posted on its website at: http://www. esed.org.gr/code-listed. The

Hellenic Corporate Governance Council was recognized as a national body of recognized prestige by the

Board of Directors of the Hellenic Capital Market Commission during its 916th/7.6.2021 meeting.

The Company in the year 2024 complied with the provisions (specific practices) of the GCGC governed

by the "Compliance or Explanation" principle with the deviations mentioned below in paragraph B.

Β. Deviations from the Corporate Governance Code and Explanations

At the time of this publication o, deviations from the GCGC constitute the following:

Principles of GCGC

Explanation of Deviation and measures to

minimize deviation risks

Role and responsibilities of the Board of

Directors

Composition of the Board of Directors

Appointment of vice-chairman or senior

According to article 12 of the Company’s current

Articles of Association, the roles of Chairman and

Chief Executive Officer may coincide in the same

person. In this case, the Board of Directors appoints

independent member in case the Chairman

of the Board is not an independent member

(Special Practice 2.2.21)

an independent Vice-Chairman from among its

independent members. The above statutory

regulation was introduced following the adoption of

special practice 3.3 of the Greek Corporate

Governance Code for Listed Companies issued in

2013 by the ESSED, according to which: "The Board

of Directors should appoint an independent Vice-

Chairman, coming from its independent members,

in the cases he has chosen: - to assign to the same

person the duties of Chairman and Chief Executive

Officer; - to appoint an Executive Chairman."

Taking into account the above but also that:

- in compliance with article 8 of Law 4706/2020, the

current Chairman of the Board of Directors, who

was elected by decision of the Annual General

Meeting of Shareholders that took place on 12

September 2023, is a non-executive member,

therefore the qualities of the Chairman and CEO do

not coincide in the same person,

-the individual suitability of the Chairman has been

evaluated in accordance with Article 49A of the

Rules of Procedure of the Parliament by decision of

the Committee on Public Enterprises, Banks, Public

Utilities and Social Security Institutions, on the one

hand, and in the context of the Decision of the Board

of Directors /EYDAP No. 21783/14.6.2024, which

established that the criteria of individual and

collective suitability of the members of the Board of

Directors of EYDAP have been met,

-the work of the Board of Directors is always

conducted in the context of a constructive dialogue

based on the interests of all interested parties and

the Chairman seeks and encourages the

participation of all its members in accordance with

the current Rules of Procedure of the Board,

-an evaluation of the work and performance of the

Chairman of the Board of Directors is underway with

the assistance of a third independent evaluator,

this deviation is estimated to have no impact on the

functioning and effectiveness of the Board of

Directors of the Company or on the transparency

and effective supervision of the executive members.

Therefore, the amendment of the said Article 12 of

the Statute has not been deemed necessary to date.

Succession of the Board of Directors

Succession plan for Board members -

gradual replacement of Board members

(Specific Practices 2.3.1 - 2.3.3, 2.3.7, 2.3.11)

Given the special regime that governs the Company

with regard to the election of the majority of the

Board members by the Greek State (Law 5045/2023

in conjunction with the decision of the Greek State

Council of the Supreme Council of the Republic of

Greece No.190/2022 and the decision of the Council

of the State Council of the Republic of Greece

No.7/2023), there is currently no procedure for the

advance and continuous activation of the

Remuneration and Nominations Committee with

regard to the succession of the members of the

Board of Directors and the nomination of

candidates. In the event that the need arises to

replace one or more Board members appointed by

the majority shareholder, the Remuneration and

Nominations Committee is activated in order for the

Hellenic State to initiate the process for finding

suitable candidates for new members in accordance

with the Company's Nomination Policy.

With regard to the gradual replacement of Board

members, the practice followed by the Greek State,

which as a majority shareholder elects the majority

of the Board members, is that the end of the term

of office of the outgoing members is also the

beginning of the term of the new Board members.

There is, however, an explicit statutory provision in

the articles of association (Article 11(6)) regarding

the possibility of the General Assembly to decide on

the partial renewal of the Board of Directors and/or

the successive expirations of the term of office of its

members.

The above practices successfully respond to the

requirements and specificities of the complex

framework governing the election and composition

of the Eydap’s Board of Directors without any issue

of lack of governance having ever arisen.

Remuneration of Board members

Malus & clawback provisions in the contracts

of executive members (Special Practice

2.4.14)

The Remuneration Policy for Board members, which

was approved by the resolution of the 38th

Ordinary General Assembly which took place on

26.6.2020 and last revised by the resolution of the

42nd Ordinary General Assembly which took place

on 11.7.2024, includes malus & clawback provisions

regarding the variable remuneration of the

executive members. These provisions are not

included independently as terms in the indefinite-

term contract of the currently sole executive

member of the Board of Directors from the year

2020, however, there is an explicit provision in the

contract regarding the application of the applicable

Remuneration Policy. In the current Remuneration

Policy, in accordance with the resolution of the

Annual General Assembly of Shareholders of

11.7.2024, a more detailed reference (compared to

the previous one) was added to the right of the

Company to demand the reimbursement of the

variable remuneration paid (paragraph 4.2.3).

Therefore, there is no substantive issue of deviation

from provision 2.4.14 of the GCGC and it is

estimated that there is no specific risk to the

interests of the Company and all interested parties.

C. Board of Directors and Committees of the Board of Directors - Other administrative, management

or supervisory bodies or committees

1. Board of Directors

1.1 Role and responsibilities of the Board

The Board of Directors is the highest governing body of the Company, which primarily shapes the

Company's strategy and development policy, while supervising and controlling the management of its

assets.

The Board of Directors also monitors the Company's performance and the implementation of its

activities and ensures that the Company's values and strategic planning are aligned with the corporate

culture. The Board of Directors and senior management set the standard for the characteristics and

behaviors that shape the corporate culture and exemplify its implementation.

The responsibilities of the Board of Directors are set out in Article 18 of the Company's Articles of

Association and Article 2 of its Operating Regulations.

Furthermore, in accordance with Law 4706/2020 and the principles of the Greek Corporate Governance

Code, the Board of Directors:

• Defines and supervises the implementation of the Company's corporate governance system, monitors

and periodically evaluates its implementation and effectiveness at least every three (3) financial years,

taking appropriate actions to address any deficiencies.

• Ensures the adequate and efficient operation of the Company's internal Control System, which aims

at the following objectives in particular:

✓ in the consistent implementation of the operational strategy, with the effective use of

available resources,

✓ in identifying and managing the material risks associated with its business activity and

operations,

✓ in the effective operation of the internal control unit,

✓ to ensure the completeness and reliability of the data and information required for the

accurate and timely determination of the Company's financial situation and the preparation

of reliable financial statements, as well as its non-financial situation, in accordance with article

151 of Law 4548/2018,

✓ in compliance with the regulatory and legislative framework, as well as the internal regulations

governing the operation of the Company.

• Ensures that the risk management, internal control and compliance functions are independent of the

business areas they control and that they have the appropriate financial and human resources and

authority to operate effectively, as required by their role.

• Understands the Company's risks and their nature and determines the extent of the Company's

exposure to the risks it intends to undertake in the context of its long-term strategic objectives.

• Ensures that the important stakeholders for the Company are identified, depending on the Company's

characteristics and strategy, as well as understanding their collective interests and how they interact

with the Company's strategy.

The Board of Directors may delegate the powers of management and representation of the Company

to one or more persons, members or not. The Board of Directors may also delegate the internal control

of the Company to one or more persons who are not its members of the Board of Directors. Such

persons may, if provided by the decisions of the Board of Directors, further delegate the exercise of the

powers assigned to them or part of them to other members of the Board of Directors or to third parties.

According to Article 21 of the Association, an Executive Committee may be established by decision of

the Board of Directors. In application to the above provision of the Articles of Association, an Executive

Committee was formed and operates by Board Resolution No. 21144/21.12.2022, as described in more

detail in section 3.1 of this document.

1.2 Chairman, Independent Vice-Chairman, Chief Executive Officer

Chairman

The role of the Chairman involves the organization and coordination of the activities of the Board of

Directors. The Chairman heads the Board of Directors and is responsible for the overall effective and

efficient functioning and organization of its meetings, determines the agenda items, calls the members

of the Board of Directors to a meeting, writes items on the agenda, at the relevant request of the CEO

and conducts its meetings.

Additionally, the Chairman fosters a culture of open-mindedness and constructive dialogue throughout

the Board’s deliberations, facilitates and promotes the development of positive and constructive

relationships among the Board members, ensures the effective contribution of all non-executive

members to the Board’s work, while guaranteeing the timely, comprehensive, and accurate provision

of information to all members. The Chairman ensures that the Board has a satisfactory understanding

of the shareholders' views and is committed to ensuring effective communication with the

shareholders. This is done with a focus on the fair and equitable treatment of their interests and the

development of a constructive dialogue with them to fully comprehend their positions.

The President heads the evaluation process of the Board of Directors in cooperation with the

Remuneration and Nomination Committee. The Chairman is evaluated by the Board of Directors

regarding the exercise of his duties, a process in which the Remuneration and Nomination Committee

is in charge.

Finally, the Chairman has all the other responsibilities provided by the law and the Articles of

Association (e.g., signing financial statements).

Independent Vice-Chairman

According to Article 12 of the Articles of Association, in the event that the qualities of the Chairman and

the Chief Executive Officer coincide with the same person, the Board of Directors appoints an

Independent Vice-Chairman from among its independent members. In this case, the Independent Non-

Executive Vice-Chairman of the Board is responsible, in addition to substituting the Chairman in their

non-executive duties, with coordinating and ensuring effective communication between the executive

and non-executive members of the Board of Directors.

As part of this responsibility, the Independent Vice-Chairman may convene a special meeting of both

the executive and non-executive members on a quarterly basis in order to provide updates on the

company’s operations and current matters.

Lastly, the Non-Executive Vice-Chairman is required to be available and present at the General Meetings

of the Company’s shareholders in order to provide information and engage in discussions regarding the

Company’s corporate governance issues, whenever such issues arise.

Chief Executive Officer

The Chief Executive Officer (CEO) is the highest executive authority of the Company, he heads all its

Services, managing their operations, and making necessary decisions within the framework of the

provisions governing the company’s operations, approved programs and budgets, and decisions made

by the Board of Directors. In the context determined by the previous paragraph, the CEO exercises all

substantive management responsibilities and any other duties delegated by the Board of Directors.

Furthermore, the CEO supervises the daily operations of the Company and exercises oversight over the

operations of each Service, managing the Company’s personnel. The CEO represents the Company

before courts and all authorities. His responsibilities are provided in detail in Article 20 of the Company’s

Articles of Association and in the Operating Regulations of the Board of Directors.

1.3 Responsibilities and Obligations of Board Members

Each member of the Company’s Board of Directors is responsible to the Company for the management

and administration of its affairs, in accordance with the provisions of Law 4548/2018, particularly Article

102 thereof, as well as Law 4706/2020, and, in any case, in accordance with the provisions of the

applicable laws governing the operation of listed companies.

According to the Operating Regulations of the Board of Directors, the members of the Board are mainly

due to:

✓ To comply with the law, the Articles of Association, and the decisions of the General Meeting

of Shareholders.

✓ To manage corporate affairs for the sole purpose of promoting the corporate interest.

✓ Not to pursue personal interests that conflict with the interests of the Company.

✓ To disclose in a timely and sufficient manner to the other members their own interests that

may arise in relation to transactions of the Company or its affiliated companies.

✓ To refrain from voting on matters where there is a conflict of interest with the Company’s

interests.

✓ To disclose to the Board of Directors any other professional commitments (including significant

non-executive commitments with companies and non-profit organizations) prior to their

appointment and as soon as they arise.

✓ Not to compete with the Company for their own behalf or on behalf of third parties by

undertaking actions that fall within the purpose of the Company, unless authorized by the

General Assembly.

✓ To ensure collectively that the annual financial statements, as well as other reports of the

Company (management, corporate governance, remuneration), are prepared and published

in accordance with the law.

✓ To maintain records, books, and documents as required by law.

✓ To refrain from acts of abuse and unlawful disclosure of privileged information in accordance

with the law.

✓ Not to engage in transactions involving the Company’s shares, debt securities, derivative

instruments, or other related financial instruments in violation of legal provisions.

✓ To notify the Company of all transactions they carry out on their behalf concerning the

Company’s shares or debt securities or derivative instruments or other related financial

instruments, if the total value of the transactions exceeds €20,000 per year.

✓ To have sufficient time to perform their duties.

✓ Not to abstain from meetings of the Board of Directors without a valid reason.

1.4 Size, Composition of the Board of Directors, and Term of Office of Members

The number of members of the Board of Directors is redundant and may not exceed thirteen (13)

members or be less than seven (7) members. The General Assembly of Shareholders is responsible for

determining the number of members of the Board of Directors, as well as for increasing or decreasing

their number, always within the framework set by the Articles of Association and the law. The Board of

Directors consists of:

a) Two (2) representatives of the Company’s employees, elected (with their alternates) by direct and

universal voting.

b) Two (2) members representing the minority shareholders, elected in the manner defined in Article

36 of the Articles of Association.

c) Representatives of the majority shareholder, elected by the General Assembly in accordance with

Article 11 of the Articles of Association and the provisions of Law 4548/2018.

Pursuant to Article 64 of Law 5045/2023, all shares owned by the Hellenic Republic’s Single Shareholder

Company (EESYP) have been transferred to the Greek State, and all the rights of the Greek State as a

shareholder of EYDAP are exercised jointly by the Ministers of Finance and Environment and Energy.

In terms of corporate governance, the Board of Directors of the Company consists of executive, non-

executive, and independent non-executive members. The status of members as executive or non-

executive is determined by the Board of Directors. Independent non-executive members are appointed

by the General Meeting of Shareholders (GMS) and are those non-executive members of the Board of

Directors who, at the time of their appointment or election and during their term, meet the

independence criteria set out in Article 9 of Law 4706/2020.

According to paragraph 6 of Article 11 of the Articles of Association of EYDAP, the term of office of the

members of the Board of Directors is four (4) years and is automatically extended until the next annual

General Assembly must be held and until the relevant decision is taken. The extension cannot exceed

one (1) year, and the maximum term of office of the members cannot exceed five (5) years.

The Members of the Board of Directors are recalled freely. The revocation and replacement is done by

those who have the right to elect or nominate. The General Assembly may replace any of the members

of the Board of Directors that elected in accordance with paragraph 2, section (c) of Article 11 of the

Articles of Association of EYDAP and before the end of their term. Board members may be reappointed

or re-elected without limitation and are revocable at any time.

Members of the Board of Directors cannot be relatives by blood or marriage up to the third degree, nor

can they be contractors or suppliers of the Company, or members of the Board of Directors or

employees of a company that has a transactional relationship with the Company. However, members

of the Board of Directors may be members of the Board of Directors or employees of a company related

to the Company, in accordance with International Accounting Standards 24 and 27.

1.5 Composition of the Board of Directors During the 2024 Fiscal Year

According to the Decision of the Ordinary General Assembly of Shareholders dated 12.9.2023, the Board

of Directors of EYDAP consists of 13 members.

Following is a table in which its composition is depicted Administrative Council from 1 January 2024 to

31 December 2024 (and up to the date of publication of this report), as well as the designation of each

member as executive, non-executive, or independent, as determined by the General Meeting or the

Board of Directors:

Board Composition Property

Beginning of term Expiration of term

and any re-election

*George Stergiou

Chairman of the Board, non-

executive member

12.9.2023 2027

*Charalambos

Sachinis

CEO, executive member

2019

Re-election 12.9.2023 2027

Antonios

Giannikouris

Non-executive member

12.9.2023 2027

Christos Karaplis

Non-executive member

2020

Re-election 12.9.2023 2027

Eleni-Maria

Kaymenaki

Non-executive member

12.9.2023 2027

Μarika Lambrou

Independent non-executive

member

12.9.2023 2027

Anastasia Martseki

Independent non-executive

member

12.9.2023 2027

Marina

Mavrommati

Independent non-executive

member

12.9.2023 2027

BOARD OF DIRECTORS

Executive Members Non-Executive Members Intependent Members

Efthymios Sfikas

Independent non-executive

member

12.9.2023

2027

**Christos

Mistriotis

Non-executive member

First election 2008

Ε Re-election 9.6.2023 2027

(the most recent)

**Panagiotis

Skoularikis

Non-executive member

First election 2010

Re-election 9.6.2023

(the most recent) 2027

***Emmanuel

Angelakis

Non-executive member

First election 2009

Re-election 24.6.2022

(the most recent) 2026

***George

Alexandrakis

Non-executive member

First election 2017

Re-election 24.6.2022

(the most recent) 2026

The above composition of the Board of Directors meets the requirement set by Article 3A, paragraph

3 of Law 4706/2020 concerning gender balance representation and satisfies the requirement of

Article 5, paragraph 2 of Law 4706/2020 regarding the adequate representation of independent non-

executive members, in a percentage not less than one-third of the total number of members of the

Board of Directors.

According to Article 49A of the Rules of Procedure of the Hellenic Parliament, the Committee on Public

Enterprises, Banks, Public Utility Organizations, and Social Insurance Bodies, in its decision dated 13

September 2023, expressed a positive opinion on the suitability of the candidates proposed by the

majority shareholder (the Hellenic State) for the positions of Chairman of the Board of Directors and

Chief Executive Officer of EYDAP. Consequently, the Board of Directors of EYDAP was constituted in its

session on 14 September 2023, determined the roles of its members, and granted them representation

and binding powers.

*The representatives of the minority, Mr. Christos Mistriotis and Mr. Panagiotis Skoularikis, were re-

elected by the Special Meeting of Minority Shareholders held on 9 June 2023. Following the

recommendation of the Remuneration and Nomination Committee dated 16 June 2023, the Board of

Directors of EYDAP, with No. 21541/20.6.2023 decision, established the suitability of Mr. Christos

Mistriotis and Mr. Panagiotis Skoularikis in accordance with the provisions of the applicable legislation

and the current Board Members' Nomination Policy of EYDAP S.A. Subsequently, the Board of Directors

assembled into a body.

The employee representatives on the Board of Directors, Mr. Emmanouil Angelakis and Mr. Georgios

Alexandrakis, were re-elected during the employee elections held in June 2022. Following this, the

Board of Directors reconstituted itself into a body on 6 July 2022.

It is noted that, in compliance with Article 9, paragraph 3 of Law 4706/2020, the Board of Directors, in

the context of examining the fulfillment of the conditions set out in Articles 9, paragraphs 1 and 2 of

Law 4706/2020 for the designation of a Board member as independent, determined by its decision No.

21999/29.04.2025, following the relevant recommendation of the Remuneration and Nomination

Committee, that the criteria for independence of the current Independent Non-Executive Members of

the Board, namely Ms. Marika Lamprou, Ms. Anastasia Martseki, Ms. Marina Mavrommati, and Mr.

Efthymios Sfikas, have been met for the fiscal year 2024.

Curricula Vitae of those serving as members of the Board of Directors during the 2024 fiscal year

and/or until the publication of this report are provided below and are also updated on the Company’s

website: eydap.gr/TheCompany/CorporateGovernance/Board/.

Curriculum Vitae of Board Members

George Stergiou - Chairman of the Board of Directors, Non-Executive Member of the Board, Chairman

of the Risk Management Committee, and Chairman of the Strategy, Innovation, and Sustainable

Development Committee.

HE holds a degree in Electrical Engineering and a master’s degree in Environmental Governance and

Sustainable Development.

He has almost 30 years of domestic and international experience covering the private and public

sectors. In his professional career he has contributed, from various positions, to the implementation of

performance and efficiency improvement programs, change management and transformation

processes in order to reduce costs and achieve sustainable growth in private and public companies, and

has participated in complex initiatives with international organizations such as the European

Commission, the European Central Bank, the International Monetary Fund, the Organization for

Economic Co-operation and Development, the World Bank.

Up until recently he held the position of the Executive Director of Development for an engineering

consultancy firm.

He is a non-executive board member of an international group subsidiary, specializing in the

development of offshore floating wind parks.

Since 1994, when he started his professional career, he has worked in international companies in the

energy and automotive industry.

He served as a CEO of an urban transport company and as a non-executive member of various Boards

of Directors in energy and transport sector companies. He also held the position of Secretary General

for Industry, Secretary General for Consumer Affairs and Special Secretary for Market Surveillance, at

the Ministry of Development.

As of September 2023, he holds the position of non-executive Chair of the Board of Directors at EYDAP

SA.

Charalambos Sachinis - Chief Executive Officer – Executive Member of the Board of Directors, Member

of the Strategy, Innovation, and Sustainable Development Committee

Mr. Sachinis, since 2019, is the Chief Executive Officer of EYDAP, the largest water and wastewater

company in Greece. He, previously, held the position of Business Development Officer at Aegean

Airlines.He has been involved in private equity as a Partner at Global Finance, as an Operating Partner

at Advent International and independently.He was, formerly, the Chairman and CEO of DEPA Group,

where he tripled its profitability, negotiated and completed major supply contracts worth $20 billion

and contributed in the shaping of alternative gas supply routes to Europe.He has also served as

President of the McGraw-Hill Companies’ Business Information Group, which he made into one of the

top global business-to-business information companies, specializing in the energy, construction,

aviation, aerospace and defense industries.Prior to this, he was President of Platts, which he built into

the world’s largest energy and commodities price and information provider. At the same time he

actively promoted transparency and integrity in the global energy markets.He was also Group Vice

President of Standard & Poor’s, where he grew key strategic businesses in the financial information

sector.He has served as Vice Chairman of ATHEXClear, while he is Member of the Boards of Directors

of ENEXClear, Atlantic Council and the Investment Committee of CNL Capital.He holds an engineering

degree from the National Technical University of Athens, Greece and an MBA from Harvard Business

School.

Antonis Giannikouris, Non-Executive Member, Member of the Risk Management Committee, Member

of the Strategy, Innovation and Sustainable Development Committee

Antonios Giannikouris was born in Rhodes on February 18, 1979. His parents and ancestors originate

from Kos, Symi and Kalymnos. In 2002, he graduated from the Department of Architectural Engineering

of the National Technical University of Athens (NTUA), having been honoured with three awards

(Lysandros Kavtatzoglou Award, Thomaidio Award and an award from the Technical Chamber of

Greece). In 2004, he followed postgraduate studies at the Department of Business Administration

(MBA) of EEDE, from where he graduated in 2006. He worked in Athens until 2004 and he then returned

to his hometown, Rhodes, where he runs a technical office for private project studies and real estate

services, until today.He served as the head of the appropriate sections of the Ministry of Culture, for

the preservation of the morphology of the traditional settlements of the Dodecanese, as well as a

member of the organizing committee for the declaration of Patmos as an UNESCO World Heritage Site.

He also served at the Archaeological Institute of Aegean Studies of the Ministry of Culture as a

researcher for the very important project titled: "Unification of Archaeological Sites of the City of Kos"

and participated as a consultant, in the museological study and application study, of the Casa Romana

museum complex in Kos.His keen interest in public affairs led him to stand for election in 2008 of the

Panhellenic Association of Architects (SADAS-PEA) and he served the Panhellenic Association of

Architects from the position of First Vice-President of the Central Delegation.In 2014 he was elected

Municipal Councilor, assuming the duties of Secretary of the Municipal Council in the Municipality of

Rhodes and as member of the Regional Union of Municipalities of South Aegean. In 2018 he was elected

President of the Technical Chamber of Dodecanese (TEE) and served in this position until April 2023.

In 2022, by joint ministerial decision of the Ministries of Shipping & Island Policy and Environment and

Energy, he was appointed as member of the Central Council of Architecture of the Aegean (KE.S.A.A).

He is a founding member and member of the Board of Directors, in sports and cultural clubs, while he

actively participates in volunteers’ activities. He is a founding member of the Rhodes chapter of the

Hellenic American Organization AHEPA, where he was President and at the same time Vice President

of Philanthropy and Vice President of Hellenism of the Hellenic Region of AHEPA. In recognition of his

contribution, he was twice named AHEPAN of the Year at the Panhellenic Conference and International

AHEPAN of the Year in the USA.

Christos Karaplis, Non-Executive Member, Member of the Audit Committee

Christos Karaplis was born in 1975. He has twenty years of professional experience in the private and

public sector, in positions of high responsibility, having worked in the banking sector and served as an

advisor and director in administrative positions of the central government (Ministry of Finance, Mnistry

of Infrastructure and Transport and Ministry of Education).He has studied at the Geotechnical School

of the Aristotle University of Thessaloniki, specializing in agricultural economics, at undergraduate and

postgraduate level, as well as at the University of Reading (UK), specializing in economics and marketing

at postgraduate level. He is proficient in English and French.Since May 2020 until today he is a non-

executive member of the BoD of EYDAP and a member of the Audit Committee.

Marika Labrou, Non-Executive Member, Member of the Remunerations and Nominations Committee

Bylaws, Member of the Risk Management Committee

Marika Labrou is Senior Business Advisor and Author of the book "Secrets of Success for Family

Businesses in the New Era". She is a member of the Board of Directors of DEPA, TEKA and EYDAP. She

has more than 30 years of successful executive experience in major multinational and Greek companies

(BSH, HP, Microsoft, SingularLogic, Intersys, KAFKAS), the last 15 years in positions of General Manager

and CEO. She has a degree in Chemical Engineering and a postgraduate degree in Business

Administration (MBA).She is a member of WCD (Women Corporate Directors) and NED Club

(Association of Non-Executive Board Members), mentor at Endeavor and WoT (Women on Top), as well

as member of two Advisory Committees of the AUEB (Athens University of Economics and Business).

Until February 2021 she was the Vice President of ACEO (Association of CEOs in Greece) and a member

of the Women's Committee of the Hellenic-American Chamber.Being committed to compassionate

leadership and to innovative entrepreneurship, she is the Founder and CEO of CEL (Compassionate

Entrepreneurial Leadership) consulting agency.

Anastasia Martseki, Non-Executive Member, Chair of the Audit Committee, Member of the Strategy,

Innovation and Sustainable Development Committee

Natasa Martseki is a former banking executive with extensive experience in international capital

markets and stock markets. She has been Director of Foreign Institutional Clients at Alpha Finance for

19 years, where she managed the largest foreign capital investors in Greece, and has held similar

positions of responsibility in New York, London and Zurich at Shell Oil, Citibank and Lehman Brothers.

She is an Independent Non-Executive member of the Board of Directors of Fourlis Trade Estates and a

member of the Audit and Nominations Committees. She has previously served as a member of the

Board of Directors at Cepal Hellas, the Greek loan and credit receivables management Company with a

portfolio of €35 billion.

She is a Founding Member and Board Member of the NED Club in Greece, an organization that

promotes modern Corporate Governance practices in Greek Companies through the activation of the

Independent Non-Executive Members mechanism.

In 2014 she founded Bright Blue, a company active in the field of services in tourism.

She holds an MBA Degree from Columbia Business School where she studied as a Fulbright Foundation

scholar, and a Bachelor's Degree in Business Administration from the Athens University of Economics.

She is a graduate of Anavryta High School.

She is a member of the Womentors Scientific Team, a member of Women on Boards UK, the Columbia

Business School Women's Circle Club and an active volunteer at Safe Water Sports. She has participated

as a trainer in Board workshops at EcoDa, as a motivational speaker at Reload Greece, as well as in

numerous webinars on topics related to Corporate Governance, female entrepreneurship, diversity and

inclusion in the workplace as well as the empowerment of women in the today’s professional reality.

Her articles on Corporate Governance and ESG, as well as the further development of women, appear

in magazines of economic and tourism interest.

Marina Mavrommati, Non-Executive Member, Member of the Audit Committee, Member of the Risk

Management Committee

Marina Mavrommati is the CEO of Printec Group since October 2015, which is active in the field of

electronic trading systems in the Central and Eastern Europe, specifically in 16 countries and employing

over 900 people.She has extensive finance and management experience working for companies such

as IBM, Procter & Gamble and Barclays Bank Plc. Prior to joining Printec Group, she served as CFO and

Member of the Board of Directors for Michaniki S.A.Marina Mavrommati earned a BSc from Kings

College, University of London and an MSc from the London School of Economics and Political Science.In

addition, he has completed Executive Courses at Insead (France) and Board courses at Harvard Business

School (USA) and IMD (Switzerland).

Helen - Maria Kaymenaki, Non-Executive Member, Chair of the Regulatory Compliance Committee

Eleni-Maria Kaymenaki is an Attorney specialising in Public Law. She has a Law Degree as well as a

Postgraduate Degree in Public Law from the Athens Law School, as well as a Master Of Laws (LLM) from

King’s College - University of London.For more than 20 years, she has practiced law cases before the

Administrative Courts, the Council of State and the European Court of Human Rights, as well as on a

consulting basis on Public and Private Law, in the whole spectrum of public law, with emphasis on

Environmental Energy Law, Public Procurement Law, Financial Law and Human Rights Law. She is a

Member of the Editorial Board of the Law Journal «Theory and Praxis of Public Law» and she has taught

fiscal law to candidates at the National School of Jugdes.Since 2019 she has served as Legal Advisor to

the Deputy Prime Minister of the Hellenic Government as well as to the Minister of State. She holds the

position of Deputy Director of Legal Services at PPA.

Efthymios Sfikas, Non-Executive Member, Chair of the Remunerations and Nominations Committee

Bylaws, Member of the Regulatory Compliance Committee

He is an attorney-at- law at the Greek Supreme Court, a graduate of the Law School of the National and

Kapodistrian University of Athens and a Master's Degree holder from Athens Law School and a Master's

Degree holder from the Law School of the University of Hamburg, where he studied with a scholarship

from the EKPA.He is the Director of the Legal Service of the Hellenic Development Bank and a partner

in the Law Firm of Passas - Sfikas and Associates. He has been a Legal Advisor and a director of legal

services for various companies in the financial sector and private sector’s enterprises in the fields of

trade, tourism, and industry. He has more than thirty years of experience in both legal consulting and

litigation and focuses his interest in the areas of financial law, acquisition law, capital market law and

commercial law. He speaks English and German.From September 2023, he holds the position of the

independent, non-executive member of the Board of Directors of EYDAP SA.

Christos Mistriotis, Non-Executive Member, Member of the Strategy, Innovation and Sustainable

Development Committe

Christos Mistriotis has more than 18 years of experience in Treasury & Finance, and Investments. He

has held the position as Chief Financial Officer of one of the top and most historical Media Groups in

Greece, also was head of non-maritime investments in a prominent ship operator and owner of more

than 80 ships, including a Nasdaq-listed company.He has served as Group Treasurer of a global leading

gaming solutions supplier Group in 52 jurisdictions, as Chief Investment Officer of a leading

multinational Group specializing in sectors such as: fixed telephony service providers, IT solutions and

services, defense electronics, constructions and real estate. Mr Mistriotis has also served as a member

on numerous Board of Directors positions, both on non-listed and listed companies of the Athens

Exchange. He has graduated from London Imperial College, with an MSc in Finance.From 2008 until

today, he represents minority shareholders on the Board of Directors of EYDAP.

Panagiotis Skoularikis, Non-Executive Member, Member of the Remunerations and Nominations

Committee

Panagiotis Skoularikis is a banking executive with significant experience in the financial sector in key

positions of responsibility. He has expertise in strategic planning and transformation, relations with

regulators and the investment community, while focusing on corporate governance and internal control

systems. As a member of the EYDAP Board since 2010, he represents minority shareholders and also

participates in the Strategy & Innovation Committee and the Remuneration and Nomination

Committee.In the past, he has served as a member of the Board of Directors of ATE Mutual Funds. He

is a General Manager of Piraeus Bank with key responsibilities for the management of relations with

the Supervisory Authorities (ECB, SSM, SRB, BoE), the Hellenic Financial Stability Fund and the

coordination of the Group's executive functions. He has worked at Citibank NA in London in the areas

of securities and liquidity management, and for several years held various management positions at the

Agricultural Bank with a focus on strategic planning, organizational restructuring and relations with the

investment community.He is a graduate of Athens College ('89), with a degree in Economics from the

University of Athens ('92) and postgraduate studies at the London School of Economics where he

obtained an M.Sc. in Economics/Business Research and an M.Phil. in Economics/European Studies. He

also holds a certification from INSEAD in Corporate Governance & Board Decisions as a graduate of the

International Directors Program.

Emmanouel Aggelakis, Non-Executive Member, Member of the Regulatory Compliance Committee

Manolis Angelakis was born in Athens. He is a graduate of the National Kapodistrian University of

Athens and speaks English, while he has participated in a series of training seminars.He has been

working at EYDAP since 1993, as a scientific staff member. During his long career in the Company, he

has obtained various managerial positions.From 2014 until today, he holds the position of Deputy

Director of Warehouses and Transport.EYDAP employees elect him as their representative on the

Company’s Board of Directors continuously since 2009. Furthermore, Mr. Angelakis has served for many

years, among others, as President of the "EYDAP Employees Union", member of the Board of Directors

of the “Federation of EYDAP Employees”, President of AKE EYDAP and, in January 2021, he was also

elected as member of the Board of Directors of the “General Confederation of Greek Workers

(GSEE)”.Finally, he is an elected Member of the Political Committee of New Democracy Party, since

2017 until today and for two terms.

George Alexandrakis, Non-Executive Member, Member of the Risk Management Committee

Giorgos Alexandrakis was born on 11.6.1976 in Agrinio city, where he completed primary and secondary

education. He is a Mechanical Engineer TE, graduate of the Technological Applications School (STA) of

the Western Greece University of Applied Sciences. He also holds a BA degree from the Department of

Administration of Businesses and Organizations (ABO), School of Social Sciences of the Hellenic Open

University. He holds an MBA degree in Digital Business, from University of West Attica.In the years

2002-2003 he worked in Public Gas Corporation (DEPA) S.A. as an engineer. Since then and until today

he works constantly at EYDAP SA as Mechanical Engineer. He is in charge of the Department of E / M

Installations of the Wastewater Treatment Network Division.He has excellent command of English

language and is a certified adult trainer by the National Organization for the Certification of

Qualifications & Vocational Guidance (EOPPEP).He is a graduate of the GSEE Labor Academy, a member

of the Economic Chamber of Greece and holds Class B Accountant - Tax Consultant (Registration

Number 0119319).In 2004 he was elected for the first time as a member of the Board of Directors of

Union of Sewerage Workers. He has served the Union of Sewerage Workers as Chair for 10 years. He

has also been, for many years, a member of the Board of Directors of the Athens Workers Federation

of Water Supply and Sewerage Company (OME EYDAP) and also member of it’s Executive Committee.

Since July 2017, he has been a Representative of the Employees of EYDAP in the Board of Directors of

EYDAP SA..

Christina Kontaratou, Corporate Secretary

Christina Kontaratou has been working at EYDAP since 1984. Since 1985 she has been working at the

Secretariat of the Board of Directors.Since May 2010 she is the Head of the Board Secretariat Service.

By Board Resolution No. 21163/22.2.2023 he was appointed Corporate Secretary.

1.6 Operation of the Board of Directors

The Board of Directors is convened by its Chairman in accordance with the provisions of the Company’s

Articles of Association and meets, as a rule, at the Company’s headquarters whenever required by law,

the Articles of Association, or the needs of the Company—and in any case, at least once (1) per month.

The Board of Directors is in a quorum and meets validly when more than half of its members are present

or represented. However, the number of present or represented members can never be fewer than

three (3). For the calculation of the quorum, any resulting fractions are disregarded.

In meetings of the Board of Directors concerning the preparation of the Company’s financial

statements, or in meetings with an agenda that includes matters requiring approval by the General

Assembly with an increased quorum and majority in accordance with Law 4548/2018, all members of

the Board must participate either in person or are represented.

When the discussion of each item is completed, it is put to a vote. Voting is always by name and open.

Decisions of the Board are validly taken with an absolute majority of the members present or

represented. In the event of a tie, the vote of the Chairman shall not prevail.

For real-time information sharing and to facilitate the connection and information of the members of

the Board of Directors, technological tools with the necessary security specifications are used, such as

an electronic platform for distributing proposals. This platform is accessible at any time by the members

of the Board and provides detailed tracking of each proposal's progress, as well as a digital archive of

supporting documents and materials related to all agenda items.

Each Board member has the right to be informed in writing by the Chairman and the Chief Executive

Officer regarding the management of the Company and generally about the development of corporate

affairs. The Chairman of the Board of Directives works closely with the CEO and the Secretariat of the

Board of Directors for the preparation of the meetings of the Board of Directors and the full and timely

information of its members.

For better preparation of the work of the Board of Directors and the correct, complete, and timely

fulfillment of its duties, a meeting calendar and annual action plan are drawn up at the beginning of

each calendar year which can be revised as needed depending on the Company’s requirements and/or

when circumstances require it.

The Operating Regulations of the Board of Directors, approved by Board decision No.

20960/15.12.2021, regulate the details regarding how members are invited to meetings, how meetings

are held, and how decisions are made.

During the 2024 fiscal year, the Board of Directors of EYDAP S.A. held fifteen (15) meetings (from the

1479th meeting on 17.01.2024 to the 1493rd meeting on 11.12.2024).

The following table shows in detail the participations in meetings of the Board of Directors by individual:

From 01/01/2024 to 31/12/2024

Full name

Number of Board

Meetings attended

Number of Board

Meetings in which they

were represented

George Stergiou

Charalambos Sahinis

Anastasia Martseki

Marina Mavrommati

Marika Lambrou

Efthymios Sfikas

Eleni-Maria Kaymenaki

Antonios Giannikouris

Christos Karaplis

Christos Mistriotis

Panagiotis Skoularikis

Emmanuel Angelakis

George Alexandrakis

1.7 Nomination Policy – Evaluation – Executive Management Succession Plan

Nomination Policy

The Suitability and Nomination Policy for the members of the Company’s Board of Directors was

approved by the Board of Directors with decision no. 20886/2.6.2021, following a proposal by the

Remuneration and Nomination Committee, and subsequently approved by the 39th Ordinary General

Assembly of Shareholders held on 25 June 2021, in accordance with Article 3 of Law 4706/2020 on

corporate governance and Circular No. 60/18.9.2020 of the Hellenic Capital Market Commission. The

policy was later revised by Board decision no. 20939/20.10.2021, again upon recommendation of the

Remuneration and Nomination Committee. The current revised Nomination Policy was approved by

the 42nd Ordinary General Assembly of Shareholders held on 11 July 2024.

This Policy includes all the principles and criteria applied during the selection, replacement, and renewal

of Board members’ terms, as well as during the evaluation of both individual and collective suitability.

Its purpose is to ensure the high-quality composition, effective operation, and proper fulfillment of the

Board’s role, aligned with the Company’s overall strategy and medium- to long-term business goals,

with a view to promoting corporate interest.

Subject to the rights of the Hellenic Republic as majority shareholder and the provisions of special

legislative frameworks, the Board of Directors, through the Remuneration and Nomination Committee,

is responsible for initiating, guiding, and coordinating the process for identifying suitable candidates for

the Board. The Committee is tasked with recommending proposed candidates for election to the Board.

For this purpose, the Committee may seek the assistance of a third-party expert advisor or assign

specific tasks, such as conducting candidate searches, exploratory contact with prospective Board

members, interviews, and preparing a shortlist of the most suitable candidates.

The Board of Directors confirms to the General Assembly that the proposed candidates meet the

independence requirements, based on a recommendation by the Remuneration and Nomination

Committee. The Committee conducts at least an audit of publicly available sources as well as Company

records. This research and evaluation covers at least the fields/conditions that, based on objective

judgment, fall or should fall within the Committee’s scope of knowledge.

Additionally, all candidates proposed as Independent Non-Executive Members of the Board are

required—prior to their election by the General Assembly—to submit a responsible declaration to the

Remuneration and Nomination Committee confirming their compliance with independence

requirements. They also assume the responsibility to promptly inform the Board and the Regulatory

Compliance Division of any change in circumstances related to themselves or members of their

immediate family that could affect their independence.

Finally, all proposed members must submit a declaration confirming that, within one (1) year prior to

their proposed election, no final court decision has been issued holding them liable for any harmful

transactions of an anonymous company, listed or not, with related parties.

The Company ensures that upon appointment—or annually—all Board members sign responsible

declaration, with which they acknowledge their obligations under applicable legislation as well as the

internal Policies and Regulations governing Company operations. In the event of circumstances that

may compromise their impartial and objective performance of duties, Board members are obliged to

disclose such matters in a timely and sufficient manner.

The Company implements an introductory information program for new members of the Board of

Directors and ensures their continuous professional training in accordance with its established

Education Policy.

The Remuneration and Nomination Committee monitors the individual and collective suitability of

Board members, particularly to identify, in light of any new developments, cases where re-evaluation

is deemed necessary. The Committee also documents the results of such evaluations, highlighting any

identified weaknesses and recommending corrective actions where appropriate. The Committee may

be supported in its work by a third-party expert advisor.

The Remuneration and Nomination Committee, the Internal Audit Unit, and other relevant

departments (e.g., Human Resources, Risk Management Division, Regulatory Compliance Division, and

Legal Services Department) may provide effective support in the formulation and monitoring of the

implementation of the Nomination Policy. The Board of Directors, with the assistance of the

Remuneration and Nomination Committee, monitors the implementation and effectiveness of the

Policy and conducts periodic evaluations at regular intervals or whenever significant events or changes

occur. In monitoring the implementation of the Policy, any findings of the Internal Audit Division and

other competent Divisions of the Company are taken into consideration.

More information regarding the Nomination Policy and its content is available on the Company’s

website:

https://www.eydap.gr/TheCompany/RegFramework/

According to the results of the individual and collective suitability assessment of the Board of Directors

conducted during the 2024 financial year by an independent external evaluator, namely the

consultancy firm Egon Zehnder, the current composition of the Board of Directors of EYDAP reflects a

broad and relevant range of skills, as well as experience in areas related to technical, financial, and legal

matters. The Board effectively combines knowledge of both the public and private sectors, bringing the

entrepreneurial mindset, strategic orientation, and innovative thinking of the private sector into the

public sphere.

Moreover, the independent members contribute valuable experience in strategic and operational

matters, while the Chairman of the Board brings significant technical expertise. Several Board members

possess extensive management experience through participation in other boards of directors, and

effectively manage the demands of the Board's five (5) Committees, which cover the areas of audit, risk

management, innovation and sustainable development, remuneration and suitability of BoD members,

and regulatory compliance.

Based on the above, the Board of Directors, with its decision no. 21783/14.6.2024, confirmed the

fulfillment of the individual and collective suitability criteria of the members of EYDAP’s Board of

Directors.

Evaluation of the Board of Directors and its Committees

The purpose of the Board of Directors’ (BoD) evaluation is to provide appropriate insight into its

suitability and effectiveness, with a view to improving its performance, maximizing its potential, and

identifying areas requiring further development. This ensures the BoD’s efficient operation and the

fulfillment of its role as the highest management body of the Company.

The Board of Directors conducts an annual evaluation of its own effectiveness, the performance of its

duties, and that of its Committees. This process is led by the Chairman of the Board in cooperation with

the Remuneration and Nomination Committee. At least once every three years, this evaluation is

facilitated by an external consultant. The evaluation of the Chairman, in terms of the execution of his

responsibilities, is overseen by the Remuneration and Nomination Committee.

During the years 2022–2023, the evaluation of the Board’s and its Committees’ effectiveness was

conducted with the participation of Board members through the corporate governance platform of the

firm "The Board Practice", and it was completed in two phases.

The first phase of the evaluation process was completed in July 2022, and the results were presented

to the Board in August 2022. The overall performance of the Board for the year 2022 was captured, and

strategic priorities as well as areas for improvement and development were identified via an online

questionnaire.

This evaluation highlighted that the Board of Directors was effective in executing its duties, and that its

Committees are efficient and constitute key supporting structures to the Board. It is noted that during

this first phase, the Audit Committee, the Remuneration and Nomination Committee, and the Strategy

and Innovation Committee (now renamed Committee on Strategy, Innovation and Sustainable

Development) were evaluated. The evaluation of each Committee was conducted by its own members.

The Chairman of the Board was evaluated as a person of high acceptance and particularly effective in

the exercise of his duties. The Chief Executive Officer was considered effective in carrying out his

responsibilities as a Board Member, and was noted to be immediately available to all other Members,

supporting the Board in the performance of its tasks. The (former) Deputy CEO was also found to

perform his assigned duties effectively as a Board Member and was likewise immediately available to

all other Members.

The second phase of the evaluation was completed in April 2023, and the results were presented to the

Board of Directors in July 2023. This phase focused on assessing the individual effectiveness of the BoD

members, as well as the Risk Management Committee, through a self and peer-to-peer questionnaire

completed online. The evaluation demonstrated that the Board Members largely ensure the smooth

conduct of the Board’s proceedings.

In the same context, and in view of the election of new BoD members in September 2023, the

consulting firm “Stanton Chase”—as referred to by the Remuneration and Nominations Committee—

was assigned the task of providing advisory support for the evaluation of the effectiveness and

performance of the Board of Directors of EYDAP, including its Committees. This also includes

assessing the strategic profile of the BoD, conducting individual and collective suitability and

development assessments, as well as the evaluation of the Chief Executive Officer for the financial

year 2024.

It is noted that the assignment was made in accordance with the provisions of the EYDAP

Procurement and General Services Regulation.

This evaluation process is currently ongoing and aims to:

✓ to ensure that the Board of Directors effectively fulfills its duty of self-assessment, thereby

enhancing compliance and accountability,

✓ to identify the strengths and the areas that need improvement for the future operations of

the Board of Directors, and

✓ to collect information to enable the achievement of optimal suitability of the Board of

Directors' members", ensuring that the Board and the composition of its Committees reflect

the appropriate balance of skills, experience, and diversity aligned with the long-term strategy

of the Company.

The ongoing process is supported online through a digital corporate governance platform, and the

applied methodology includes self and peer-to-peer questionnaires as well as open-ended questions.

Evaluation of Executive Members

The Company implements an Executive Members Evaluation Policy, which was approved by Board

Resolution No. 20913/20.7.2021. The Remuneration and Nominations Committee, based on best

practices and in accordance with the Company's Policies and procedures, defines the evaluation

parameters and objectives in cooperation with the non-executive members of the Strategy, Innovation,

and Sustainable Development Committee, and leads the evaluation process.

The Remuneration and Nominations Committee is responsible for overseeing the planning and

updating of the executive members' evaluation process, as well as ensuring its effective

implementation. The Board of Directors, under the guidance of the Remuneration and Nominations

Committee, ensures the annual evaluation of the performance of executive members. The evaluation

results are communicated to the CEO and are taken into account in determining their variable

remuneration.

The evaluation process for executive members may be conducted internally or with the support of a

specialized external advisor, to enhance objectivity, provide expertise, and assist the Company in

updating its practices and procedures in accordance with the regulatory framework and corporate

governance best practices. An external technology provider may also be engaged to ensure anonymity

and the provision of comparable results and data.

It should be noted that the evaluation of executive members also forms part of the annual performance

review process for the purposes of determining the level of achievement of targets under the approved

Remuneration Policy, which is necessary for the payment of variable remuneration to executive

members of the Board. For the fiscal year 2023, it was decided that no variable remuneration would be

granted, while for the fiscal year 2024, the evaluation of target achievement will be completed

following the publication of the annual financial report.

It is also noted that the non-executive members of the Board of Directors discussed, without the

presence of the CEO (as the sole executive member), the numerical indicators for each quantitative

target related to the potential granting of exceptional additional variable remuneration, during the

Board meeting No. 1486/24.7.2024.

Following the results of the evaluation of the effectiveness and overall performance of the executive

members of the Board of Directors for the years 2022-2023 (first half), conducted with the support of

the consulting firm “Stanton Chase,” the evaluation of the effectiveness and performance of the CEO

(the sole executive member in the current composition of the Board) for the fiscal years 2023-2024 is

currently underway, as mentioned in the section "Evaluation of the Board of Directors and Board

Committees" above.

Specifically, the ongoing evaluation of the CEO aims to provide a substantial and comprehensive review

of his performance, with active participation from the CEO, other Board members, and members of the

Executive Committee. The evaluation focuses on effectiveness regarding sustainability issues,

leadership skills, vision, mission, values, goals, and strategic action points, aligned with established best

practices in the industry.

The goal of the evaluation is to enhance the CEO's effectiveness in addressing emerging strategic

priorities for EYDAP. The process is supported online by a corporate governance digital platform, and

the methodology used involves completing evaluation questionnaires by the CEO, Board members, and

members of the Executive Committee. The evaluation will be completed after the publication of the

2024 annual financial report.

Executive Management Succession Plan

EYDAP, aiming to incorporate best practices to ensure the sustainability of the Company and enhance

its value, has begun implementing a continuous corporate governance program.

As part of this program, in 2023, the Remuneration and Nominations Committee, wishing to establish

an ongoing evaluation and development process, designed the Executive Management Succession Plan

for EYDAP, which includes the CEO and members of the Executive Committee, including the Directors

of Operations, with the support of the consulting firm “Stanton Chase” and the company’s corporate

governance platform “The Board Practice.”

Through the review of the effectiveness of the members of EYDAP’s Executive Management, the

strengths and areas for improvement and development were identified, fulfilling one of the Company’s

essential obligations — that of succession planning, with the goal of identifying high-potential

candidates to take on leadership, management, or specialized roles and their responsibilities.

The succession planning process was based on anonymous and confidential evaluations of the members

of the Executive Management, using an online questionnaire approved by the Remuneration and

Nominations Committee (EYDAP_CEO & ExCom Succession Planning questionnaire) and individual

interviews, considering the applicable legislation, the Corporate Governance Code adopted by the

Company, and global best practices in this field.

Through this process, individual effectiveness reports were created for each participant, and feedback

sessions were conducted.

EYDAP aims for the continuous evaluation and development of its executives in order to identify the

right candidates to successfully take on leadership and other critical positions, maintaining operational

stability and ensuring the Company’s sustainability.

1.8 Compensation Policy – Remuneration of Board Members for Participation in Board Meetings

during the 2024 Fiscal Year – Remuneration of the Chairman – Remuneration of Executive Members

The Company has established a Compensation Policy in order to implement fundamental principles and

rules regarding the remuneration of Board members in a transparent, clear, and understandable

manner.

The Policy was approved by the decision of the 38th Annual General Meeting of Shareholders held on

June 26, 2020. The current Compensation Policy was revised by the decision of the 42nd Annual General

Meeting held on July 11, 2024, and was approved with 95.08% of the votes represented at the AGM.

The Policy is available on the Company’s website at

https://www.eydap.gr/TheCompany/RegFramework/.

The Policy applies to all Board members (executive and non-executive, including the Chairman of the

Board).

The Remuneration and Nomination Committee provides guidelines, ensures the development, and

reviews/pre-approves the Compensation Policy draft, with potential support from an external

consultant. The Policy is drafted/revised by the responsible Remuneration and Labor Relations Division,

with appropriate advisory support from the Legal Services Division, the Regulatory Compliance Division,

and the Internal Audit Department.

The Remuneration and Nomination Committee recommends the draft Policy to the Board of Directors.

The Board of Directors approves the Policy, which is then submitted to the General Meeting for final

approval (validation). During the General Meeting, the shareholders' vote on the Policy is binding. Board

members who are also shareholders are not involved in the vote and are not counted towards quorum

or majority formation.

The Internal Audit Department is responsible for checking the legality of remunerations and any form

of benefits at least on an annual basis. The findings are documented in a report which is communicated

to the Remuneration and Nomination Committee. Following delegation from the Board of Directors,

the Remuneration and Nomination Committee is responsible for: a) monitoring the Policy's compliance

with the applicable institutional and supervisory framework, with appropriate support from the

Company's relevant Divisions (e.g., Human Resources, Legal Services, Regulatory Compliance, Internal

Audit), b) overseeing the proper implementation of the Policy, based on the relevant findings and

reports from the Internal Audit Division, of which it is the recipient..

Annually, the Remuneration and Nomination Committee evaluates the need to update the

Compensation Policy based on proposals submitted by the Company's relevant Divisions (e.g., Human

Resources, Legal Services, Regulatory Compliance, Internal Audit). If its amendment is required, the

relevant suggestions from the Remuneration and Nomination Committee are evaluated by the Board

of Directors.

The remuneration of each executive and non-executive member of the Board of Directors is approved

by the Board following the relevant suggestion from the Remuneration and Nomination Committee.

The approval of the remuneration of executive members is made without their presence during the

relevant Board meeting. After this procedure, the Board prepares and submits a proposal to the

Company's General Assembly for ratification.

Further information regarding the Policy and its content is available on the Company's website at

https://www.eydap.gr/TheCompany/RegFramework/.

Remuneration of Board Members for Participation in the Board of Directors

According to the Compensation Policy, Board members receive an annual flat fee for their attendance

at Board meetings, while each non-executive member additionally receives a monthly remuneration

for performance and travel expenses.

The 42nd Annual General Meeting of Shareholders, held on July 11, 2024, approved the remuneration

and expenses paid to the current members of the Board of Directors for their participation in the Board

from September 1, 2023, to December 31, 2023, the amount of €52,000.00, plus employer

contributions and gross representation and travel expenses of €11,591.52, plus employer contributions.

The detailed amounts are listed in the 2023 Remuneration Report, available on the Company’s website

at https://www.eydap.gr/TheCompany/RegFramework/.

Additionally, the 42nd Annual General Meeting of Shareholders, held on July 11, 2024, recognizing that

the current remuneration of the non-executive members of EYDAP S.A. is below the range of the Greek

market and does not reflect the level of responsibility, the significance of the position, as well as the

time spent by the members in preparation for and participation in the Board and its Committees,

decided to increase for the 2024 fiscal year: a) the annual remuneration and monthly expenses of the

Board members for their participation in the Board by approximately 10%, and b) the annual

remuneration and monthly expenses of the Board members for their participation in the Committees

of the Board by approximately 25%.

Specifically, regarding the remuneration received by the Board members for their participation in the

meetings of the Board Committees, please refer to paragraphs 2.1, 2.2, and 2.3 below.

Fixed and Variable Remuneration

According to the Compensation Policy, the Chairman of the Board and the executive members of the

Board receive fixed remuneration, which is paid monthly in addition to the annual flat fee for their

participation in the Board.

The fixed remuneration of the executive members is determined through contracts signed by these

executives with the Company and is subject to the applicable deductions under the current tax and

insurance legislation.

The contracts are open-ended and include, among others, the following elements: remuneration,

duration, terms of termination, performance of duties assigned by the Board, avoidance of conflicts of

interest, confidentiality, payments related to the termination of contracts, and notice period.

The Company provides additional incentives for the executive positions in the form of variable

remuneration, linked to short-term and/or medium-term corporate objectives. The variable

remuneration is paid once a year after the publication of the Annual Financial Results, subject to the

achievement of the targets set for the Key Performance Indicators (KPIs).

Additionally, by decision of the Board of Directors, additional exceptional variable remuneration may

be paid to the executive members, linked to the achievement/completion of a strategic goal, the

amount of which shall not exceed the gross base remuneration of two monthly salaries. The objective

linked to the additional exceptional variable remuneration is proposed by the Remuneration and

Nomination Committee and approved by the Board of Directors. The additional exceptional variable

remuneration and the timing of its payment are proposed by the Remuneration and Nomination

Committee, approved by the Board of Directors, and receive final approval from the General Assembly

of Shareholders.

The 42nd Annual General Assembly of Shareholders, held on July 11, 2024, approved the remuneration

paid to the Chairman and the executive members of the Board for the period from September 1, 2023,

to December 31, 2023, as follows:

● Gross remuneration paid for the period from September 1, 2023, to September 11, 2023, to

the outgoing Chairman of the Board of Directors of EYDAP S.A., amounting to €1,584.60, plus

employer contributions.

● Gross remuneration paid for the period from September 12, 2023, to December 31, 2023, to

the Chairman of the Board of Directors of EYDAP S.A., amounting to €17,417.30, plus

employer contributions.

● Gross remuneration paid for the period from September 1, 2023, to December 31, 2023, to

the Chief Executive Officer of EYDAP S.A., amounting to €42,666.72, plus employer

contributions.

● Gross remuneration paid for the period from September 1, 2023, to December 21, 2023, to

the outgoing Deputy Chief Executive Officer of EYDAP S.A., amounting to €27,500.00, plus

severance compensation of €22,500.00, plus employer contributions.

For the 2023 fiscal year, no variable remuneration was paid to the executive members of the Board of

Directors.

With the same decision, the General Meeting pre-approved for the 2024 fiscal year the payment of:

A) To the Chairman of the Board of Directors of EYDAP S.A., an amount of €63,000.00 in gross

remuneration, plus employer contributions.

B) To the Chief Executive Officer, an amount of €140,000.00 in gross remuneration, plus employer

contributions.

Given that the immediate demand for the corporate fiscal years is to improve the performance and

results of the Company, the same General Meeting decided for the 2024 fiscal year the payment of an

additional incentive to the Chief Executive Officer in the form of variable gross remuneration, depended

on short-term goal setting (bonuses). The exceptional (variable) remuneration will be awarded to the

Chief Executive Officer for achieving the following four equally weighted objectives in the 2024 fiscal

year:

i. Reduction of operating expenses

ii. Achievement of investments

iii. Reduction of non-billed water

iv. Increase in collections from overdue debts

The bonus is set at 20% of the remuneration (5% for each objective), plus employer contributions. If

any of the above objectives are achieved for three consecutive fiscal years, then the corresponding

bonus will increase to 40% for those years and will be paid retroactively (10% for each objective).

The above variable gross remuneration is paid after the publication of the Annual Financial Results and

contingent upon the achievement of the above specific quantitative objectives (KPIs), as well as being

linked to the annual Regular Budget and the Financial Results of the Company, as approved by the Board

of Directors.

Allowances

The benefits apply solely to the Chairman and the executive members of the Board of Directors (except

for the Directors' and Officers' Liability Insurance, which also applies to non-executive members of the

Board of Directors) and are not included in the definition of variable remuneration in the Remuneration

Policy. The benefits provided to the Chairman and the executive members of the Board of Directors,

taking into account market practices and the benefits provided to the company's employees, include:

● Provision of a company car and related coverage.

● Provision of a laptop computer, telecommunications equipment, and mobile phone services.

● Coverage of the cost for participation in a private health insurance program, including

outpatient and inpatient care, as is the case for the company’s employees.

● Directors' and Officers' Liability Insurance coverage.

● Expenses for representation, travel, accommodation, and meals in connection with the duties

of the Board members, upon submission of the relevant receipts.

The executive members of the Board of Directors are entitled to the benefits that regular employees of

the Company receive, as provided in the Collective Labor Agreements and the Board of Directors'

Resolutions.

The Remuneration and Nomination Committee has the ability, during the annual review of fixed and

variable remuneration, to redefine the provision of any benefits and to propose other forms of

benefits—apart from those mentioned above—for the executive members and the Chairman of the

Board of Directors (in accordance with Articles 109 - 112 of Law 4548/2018) in order to support the

Company’s operations and ensure competitiveness with similarly sized organizations in the Greek

market.

The approved Remuneration Report for the 2023 fiscal year is available on the Company's website

https://www.eydap.gr/TheCompany/RegFramework/. At the Annual General Assembly of

Shareholders, to be held within 2025 for the approval of the 2024 fiscal year results, the Remuneration

Report for the members of the Board of Directors will be submitted, detailing the remuneration and

benefits paid during the 2024 fiscal year, in accordance with Article 112 of Law 4548/2018 and the

Remuneration Policy. No stock options were granted in the 2023 fiscal year, and no share allocation

program is currently in effect.

1.9 Conflict of Interest – Transactions with Related Parties

Conflict of Interest

The members of the Board of Directors (executive, non-executive, and independent non-executive)

must take special care to avoid the occurrence of conflicts of interest and respect the obligation of

loyalty they have towards the Company, acting with independent judgment in order to promote the

company’s best interests.

With the no. 20906/7.7.2021 Board of Directors Decision established a Conflict of Interest Policy, which

was revised with the no. 21159/16.2.2023 Board decision. This Policy provides that the members of the

Board of Directors, as well as any third person to whom their responsibilities have been assigned by the

Board of Directors that they owe in particular:

a) Not to pursue personal interests that conflict with the interests of the Company.

b) Not to engage in any competition with the Company and avoid any position or activity that creates

or appears to create a conflict between their private interests and those of the Company, including

holding positions on the Board of Directors or management of other companies, without the permission

of the General Assembly.

c) To disclose in a timely and sufficient manner to the other members of the Board of Directors their

private interests that may arise from the Company’s transactions related to their duties, as well as any

other conflict of personal interests with those of the Company or related businesses as defined by

International Accounting Standard 24, arising in the exercise of their duties.

d)To Maintain strict confidentiality regarding the Company’s affairs and any confidential information

that becomes known to them due to their position.

e) Not to engage in transactions involving the shares or other financial instruments of the Company

based on privileged information.

f)To promptly notify any transactions involving the shares or other financial instruments of the

Company.

In order to prevent and identify such situations, the members of the Board of Directors submit a conflict

of interest declaration to the Regulatory Compliance Department upon assuming their duties, in

accordance with the relevant Appendix of the Conflict of Interest Policy. In this context, members of

the Board of Directors are also required to notify the Board of Directors any participation they have in

boards of Directors or other governing bodies of other legal entities or organizations of any type or

purpose, as well as any other relationship or activity they believe may conflict or could potentially

conflict with the interests of the Company.

The Board of Directors ensures the effective management of any conflict of interest between its

members and the Company, as well as the protection of the information that members become aware

of in the course of their duties, whether or not this information constitutes corporate secrets or

privileged information.

The current members of the Board of Directors have disclosed their other professional commitments

to the Company (including significant non-executive commitments to companies and non-profit

organizations) as follows:

Board Composition Property

Other professional commitments

George Stergiou

Chairman of the Board, Non-

Executive Member

Non-executive member of the Board of

Directors " Hexicon Power ”

Charalambos Sahinis

CEO, Executive Member

Chairman and CEO of EYDAP NISON,

member of the Board of Atlantic Council”

and member of the Investment Committee

of CNL Capital

Antonios Giannikouris

Non Executive Member

Member of the Central Council of Aegean

Architecture

Christos Karaplis

Non-executive Member

Eleni – Maria Kaymenaki

Non-executive Member

Cooperation with Papapolitis & Papapolitis

Law Firm,Member of the Board of

Directors at the Legal Entity under Public

Law (LEPL) "National Centre for Social

Solidarity – EKKA", Deputy Director of Legal

Services at the Piraeus Port Authority

(PPA).

Marika Lambrou

Independent Non-executive

Member

Board member of DEPA of trade and TEKA

Member of WCD ( Women Corporate

Directors ) Foundation , Member of NED

Club (Association of Non-Executive Board

Members),

She founded and runs the consulting

company CEL (Compassionate

Entrepreneurial Leadership).

Anastasia Martseki

Independent Non-executive

Member

Member of the Board of Directors of

Fourlis Trade Estates , member of Audit

and Nominations Committees , Founding

Member and Board member at NED Club in

Greece , Member and Managing Partner of

Bright Blue P.C. (Private Company)

Marina Mavrommati

Independent Non-executive

Member

Legal representative of Printec Hellas S.A.,

Deputy CEO at Printec Payments Single-

Member S.A. (Payment Institution),

Member of the Board of Directors at

Systimiki R.M. Single-Member S.A., and at

the Hellenic Society for the Protection and

Rehabilitation of Disabled Persons

(ELEPAP); Limited partner at Arma Partners

L.P., Member of the Board of Directors at

Bioiatriki, and Advisor–Managing Director

at Printec Cash Network Single-Member

S.A.

Efthymios Sfikas

Independent Non-executive

Member

Director of the Legal Service of the Hellenic

Development Bank, Partner at the law firm

Th. Passas - Efth. Sfikas.

Christos Mistriotis

Non-executive Member

Admin of Centrus Hellas SA

Panagiotis Skularikis

Non-executive Member

General Manager of Piraeus Bank

Emmanuel Angelakis

Non-executive Member

Deputy Director of the EYDAP Warehouse

& Transport Department

George Alexandrakis

Non-executive Member

Technologist Mechanical Engineer

(Employee EYDAP)

Based on the information provided in the table above and in accordance with the applicable

Nominations Policy and none of the members of the Company's Board of Directors (executive, non-

executive, and independent non-executive) held during the 2024 fiscal year, nor do they hold at the

time of publication of this Statement, a position on the Boards of Directors of more than five companies

in total or more than three listed companies in total.

In accordance with Article 18, Paragraph 3 of Law 4706/2020, a table is provided with the number of

shares in EYDAP held by the Members of the Board of Director and the senior executive officers as of

December 31, 2024, as follows:

FULL NAME

CAPACITY

NO. OF SHARES

SAHINIS CHARALAMPOS

CEO

1000

ANGELAKIS EMMANUEL

Non-executive member of

the Board of Directors

465

SYNODINOU-KAMILOU ANTIGONE

General Manager of

Transformation

300

PANAGOPOULOU AKATERINI

Director of Risk

Management

300

Transactions with Related Parties

Regarding the management of transactions with related parties, the Company's Operating Regulations

provide a compliance procedure in line with the obligations outlined in Articles 99 to 101 of Law

4548/2018. This procedure explains the concept of transactions with related parties and identifies the

categories of individuals and entities considered related parties according to IAS 24. Additionally,

criteria are provided for determining whether a transaction occurs in the usual course of business or

not (e.g., nature, frequency, size of the transaction, etc.). These criteria are indicative and not restrictive

, and the Company must evaluate each transaction on a case-by-case basis, taking into account its

specific nature and the conditions under which it is conducted.

Before any approval for entering into a transaction with a related party, either by the Board of Directors

or the General Assembly, an opinion is obtained from an independent external advisor (certified

auditor, auditing firm, or another independent third party). This advisor, after evaluating the case, may

either issue an exemption report with a well-documented reference to the criteria under which the

transaction was assessed as falling under Article 99, Paragraph 3 of Law 4548/2018 or provide a fairness

opinion in the event that the transaction is considered not to be exempt from the general prohibition

of related party transactions.

Members of the Board of Directors and senior executive officers participating in third-party companies

are required to submit a special declaration, which is sent by the Secretariat Service of the Board of

Directors to the Board members and by the Director of Regulatory Compliance to senior executive

officers at least one month prior to the issuance of the semi-annual or annual financial statements. The

submitted declarations are immediately forwarded to the Financial Activities Department in order to

monitor transactions between related parties and disclose them through the Company's financial

statements.

1.10 Sustainable Development Policy

The long-term alignment of corporate actions with the Sustainable Development Goals is a key factor

in EYDAP's development path. The Company’s strategy is focused on the principles of Sustainable

Development and measures its performance based on the following three key pillars:

Environment

Environmental criteria assess the extent to which the Company promotes the protection of the

environment. In this context, EYDAP consistently invests in strategies related to:

Sustainable water resource management

Protection of marine ecosystems

Returning wastewater to nature (95% clean)

Biodiversity protection

Circular economy

Energy saving & reduction of carbon footprint

Tiered pricing for drinking water consumption

Development of leakage reduction programs

Large Sewerage Projects in Eastern Attica aimed at collecting, processing, and reusing treated effluents

“SEWER MINING” – Development of an innovative wastewater treatment solution from the local

sewerage network and production of water for irrigation and industrial use

Construction of a water utilization network for the Adriatic Aqueduct

Continuous Maintenance & Upgrading of Network Facilities

Development of a smart grid

Society

EYDAP consistently develops strategies and actions focused on supporting society. In this context,

EYDAP provides:

Excellent Drinking Water Quality

Access to clean water for citizens

Uninterrupted and Reliable Water Supply & Sewerage Services

Affordable pricing for all, with sensitivity to financially weak groups

Assistance for the protection of human life in emergency situations

Protection of Workers' Health & Safety

Guarantee of Human Rights in Employment

No discrimination based on gender, age, or religion

Customer-centered approach

Continuous employee training

Collaborations with Educational Institutions, Foundations & Small Businesses

EYDAP Sponsorship Program

Protection & Promotion of Cultural Heritage

Upgraded Environmental & Cultural Educational Programs

Support for youth through special employment programs

Establishment of annual Doctoral level Scholarships

Governance

EYDAP is committed to operating under the principles of Corporate Governance throughout its

activities. To this end, it promotes the perception of business ethics in decision-making and is

committed to protecting the interests of shareholders and all interested parties. Key characteristics of

Corporate Governance at EYDAP include:

Implementation of the Corporate Governance Code and Conflict of Interest Policy

Full alignment with National and EU Law

Full compliance with Environmental Legislation

Anti-Corruption & Bribery Policy

Implementation of the General Data Protection Regulation

E-Governance

Establishment of Regulations and strict application of the Public Procurement Law

Dialogue with interested parties

The Company's commitments on ESG issues are included in the Sustainable Development Policy, which

is part of the Company's Operating Regulations and its content is available on the Company’s website

at https://www.eydap.gr/TheCompany/RegFramework/. In the same context of adhering to the

principles of sustainable development, under decision number 21295/26.4.2023 of the Board of

Directors, the Environmental Policy of EYDAP was established, which includes its commitments to

minimize the impacts of its activities on the environment, transitioning to a low-carbon economy,

addressing the challenges of climate change, and contributing to the achievement of global ESG goals.

Since the fiscal year 2016, the Company publishes an annual Sustainable Development Report,

reporting on its performance on ESG issues, in accordance with recognized sustainability reporting

standards and aiming to meet the needs and expectations of its stakeholders. The impacts of the

Company were evaluated concerning the United Nations' Global Sustainable Development Goals at the

national level. In recognition of the importance of transparency and reliability of the information,

selected elements of the report were entrusted to well-known auditing firms.

For the fiscal year 2024, following the issuance of:

● Regulation (EU) 2023/2772 of 31.7.2024, supplementing Directive 2013/34/EU of the

European Parliament and the Council, regarding sustainability reporting standards, which is

mandatory and universally applicable to public interest entities and large entities; and

● The publication of Law 5164/2024 (A' 202), which incorporated the provisions of Directive (EU)

2022/2464 of the European Parliament and the Council of December 14, 2022, amending

Regulation (EU) No 537/2014, Directive 2004/109/EC, and Directive 2013/34/EU regarding

sustainability reporting, and which, among other things, amended the provisions of Laws

4548/18 and 3556/07.

As part of the Annual Report of its Board of Directors (p.96), EYDAP publishes its Sustainability

Statement in alignment with the "Corporate Sustainability Reporting Directive" (CSRD) for the

submission of Sustainability Statements and the European Sustainability Reporting Standards (ESRS), as

well as the requirements of the European Taxonomy Regulation 2020/852.

The report is subject to external assurance by a reputable auditing firm.

In the context of highlighting its material topics, the Company has conducted a Double Materiality

Analysis. The methodology for the analysis is outlined in the following steps:

Step 1: Impact Assessment

1. Mapping of activities and stakeholders across the entire value chain.

2. Definition of Impacts

3. Definition of Time Horizons

4. Definition of criteria for evaluating impacts

5. Evaluation and prioritization of impacts

Step 2: Financial Materiality

1. Identification and evaluation of risks and opportunities

2. Definition of time horizons

3. Evaluation and prioritization of risks and opportunities related to sustainable development

The process and results were validated by the Senior Management.

The Sustainability Statement and the Taxonomy Report aim to meet EYDAP’s response to the needs

and expectations of its stakeholders, who require clear, comprehensive, and high-quality information

regarding the impacts, risks, and opportunities related to sustainability issues.

2. Committees of the Board of Directors – Composition – Responsibilities – Compensation of

Members – Evaluation of Effectiveness

2.1 Audit Committee

The Audit Committee, according to its current Operating Regulations, which was updated by Decision

No. 21549/5.7.2023 of the Board of Directors, and in accordance with Article 44 of Law 4449/2017, as

amended, may either be a committee of the Board of Directors composed exclusively of non-executive

members or an independent committee made up of non-executive Board members and third parties,

or exclusively of third parties. The type of Audit Committee, its term, the number, and the qualifications

of its members are decided by the General Assembly of Shareholders.

According to the decision of the Annual General Assembly of Shareholders on September 6, 2023, the

Audit Committee is a committee of the Board of Directors, consisting exclusively of non-executive

members of the Board, with three (3) members in total, two (2) of whom have the status of

independent non-executive members of the Board, and one (1) is a simple non-executive member. The

term of the members is the same as their term as members of the Board of Directors, which is four (4)

years.

Following the election of new members of the Board of Directors by the majority shareholder on

September 12, 2023, and pursuant to Decision No. 21576/20.9.2023 of the Board of Directors, after

the recommendation by the Remuneration and Nominations Committee on September 18, 2023, the

following was confirmed:

a) The fulfillment of the independence criteria of Article 9 of Law 4706/2020 for the non-executive

members, Mrs. Anastasia Martseki and Ms. Marina Mavrommati,

b) The fulfillment of the suitability criteria of Article 44, paragraph 1 of Law 4449/2017 and the

applicable Nomination Policy of EYDAP for the non-executive members, Mrs. Anastasia Martseki, Ms.

Marina Mavrommati, and Mr. Christos Karaplis, and that these individuals are capable of performing

the duties and obligations stipulated in paragraph 3 of Article 44 of Law 4449/2017,

c) Subsequently, the members of the Audit Committee of the Board were appointed for a term

corresponding to their term as Board members as follows:

1. Anastasia Martseki, Independent Non-Executive Member

2. Marina Mavrommati, Independent Non-Executive Member

3. Christos Karaplis, Non-Executive Member

Board of directors

Control Committee

Remuneration and

Nomination Committee

Risk Management

Committee

Strategy, Innovation and

Sustainable Development

Committee

Regulatory Compliance

Committee

During the meeting on September 25, 2023, the Audit Committee was formally constituted, and by

unanimous decision of its members, Ms. Anastasia Martseki was appointed as the Chairwoman of the

Committee. The above composition remains unchanged until the date of publication of this report.

It is noted that, by Decision No 21999/29.04.2025, the Board of Directors of the Company, following a

relevant suggestion by the Remuneration and Nominations Committee, confirmed that the conditions

of independence under Article 9 of Law 4706/2020 were met for the existing independent members of

the Audit Committee during the corporate year 2024, specifically for Ms. Martseki Anastasia and Ms.

Mavrommati Marina.

Operation of the Audit Committee

The operational framework of the Audit Committee is defined by its Operating Regulation, which was

updated by the Board of Directors' Decision No. 21549/5.7.2023 and is available on the Company’s

website (https://www.eydap.gr/Investors/CorporateGovernance/BoDCommitee/). The Audit

Committee evaluates—at least every two years—the suitability and effectiveness of the Operating

Regulation to determine if there is a need for its update, especially when there are changes in the role

and responsibilities of the Committee, in the Company, or in legislation that relate to the matters

covered by the Regulation.

To fulfill its tasks, the Audit Committee meets at regular intervals and, when necessary, exceptionally.

The frequency and timing of the Committee’s meetings depend on the extent of its responsibilities,

taking into account, among other factors, the activity, size, business environment, and business model

of the Company. In any case, the Committee meets at least once per quarter on predetermined dates,

times, and locations, and exceptionally, when necessary, to discuss important matters.

The primary responsibilities of the Audit Committee, as defined by relevant legislation, include

monitoring the financial reporting process, the submission and assurance of sustainability reports,

monitoring the effective operation of the internal control system and the risk management system, as

well as ensuring the proper functioning of the internal audit unit of the entity being audited.

Additionally, these responsibilities include overseeing the mandatory audit of financial statements, as

well as reviewing and monitoring matters related to the existence and maintenance of the objectivity

and independence of the statutory auditor or auditing firm, particularly concerning the provision of

other services by the statutory auditor or auditing firm. The Audit Committee is also responsible for the

process of selecting the statutory auditor or auditing firm.

The Audit Committee maintains frequent communication with the Internal Audit Department in the

execution of its duties. In this context, the head of the Internal Audit Department is invited to

participate in most of the Committee’s meetings and provide updates on the progress of ongoing audits

and the monitoring of corrective actions decided upon during the audits. The Audit Committee also has

frequent communication and meetings with the statutory auditors to review the financial statements

and assess the financial information provided.

During the 2024 corporate year, the Audit Committee held 19 meetings on the following dates:

MEETING No 1/2024

08/01/2024

MEETING No 2/2024

12/01/2024

MEETING No 3/2024

31/01/2024

MEETING No 4/2024

27/02/2024

MEETING No 5/2024

01/04/2024

MEETING No 6/2024

18/04/2024

MEETING No 7/2024

30/04/2024

MEETING No 8/2024

04/06/2024

MEETING No 9/2024

11/07/2024

MEETING No 10/2024

24/07/2024

MEETING No 11/2024

20/09/2024

MEETING No 12/2024

30/09/2024

MEETING No 13/2024

14/10/2024

MEETING No 14/2024

31/10/2024

MEETING No 15/2024

20/11/2024

MEETING No 16/2024

27/11/2024

MEETING No 17/2024

06/12/2024

MEETING No 18/2024

13/12/2024

MEETING No 19/2024

19/12/2024

All members of the Audit Committee attended all of the meetings.

For the fiscal year 2024, the 42nd Annual General Meeting of Shareholders, taking into account the

Remuneration Policy and the Board of Directors' Decision No. 21778/14.06.2024, decided to pay the

following amounts for each meeting:

● €750 (gross, plus employer contributions) to the Chair of the Audit Committee.

● €500 (gross, plus employer contributions) to each member of the Audit Committee.

Additionally, it was decided to pay a monthly fee (for the months in which a meeting is held) of €195

(gross, plus employer contributions) per individual, both to the Chair and to the Members of the Audit

Committee, as compensation for attendance and movement expenses, with a maximum of 20

Committee meetings per calendar year.

The evaluation of the effectiveness and performance of the Audit Committee is currently underway.

For more details, please refer to section 1.7 (Evaluation of the Board of Directors and Committees).

Activities and Topics Examined by the Audit Committee in 2024

A.External Audit

• During the fiscal year 2024, the Committee held meetings with the head of the External Auditors'

project team to be updated on the progress of the audit work, as well as other matters related to the

external audit. The project team of the external auditors was invited by the Audit Committee and

attended 8 out of the 19 meetings to update the Audit Committee on matters related to the

preparation of financial information and the preparation of interim and annual financial statements.

• The Committee monitored and reviewed the process of conducting the mandatory audit of the

individual and consolidated financial statements of the Company for the fiscal year 2023 and the first

half of 2024, as well as the content of the supplementary reports of the statutory auditor.

• The Committee discussed with the External Auditors issues related to the Audit Plan for the fiscal

year 2024 and confirmed that it covers the key audit matters, in line with the Company's main areas

of business and financial risk. The Committee confirmed the accuracy and completeness of the audit

process based on relevant regulatory provisions.

• The Committee reviewed all the fees paid to the external auditors, Grant Thornton, for the audit

work conducted in 2024, and also reviewed and approved additional fees for non-audit services, in

accordance with applicable law. The Committee reviewed the provision of non-audit services, beyond

the statutory accounting and tax audits, by the External Auditors, after assessing potential threats to

their independence and the safeguards in place to reduce these risks, in accordance with applicable

legislation and Article 22b of Directive 2006/43/EC. The Committee confirmed that no non-audit

services prohibited by Article 5 of EU Regulation (EU) No 537/2014 were provided. The External

Auditors of the Company remained independent, in line with the Code of Ethics for Professional

Auditors of the International Ethics Standards Board for Accountants (IESBA), which is incorporated

into Greek law. Based on the above, the Committee unanimously gave its approval.

• The Committee confirmed the independence of the External Auditors.

• The Committee reviewed and evaluated the process of preparing financial information for the

issuance of the half-yearly and Annual Financial Statements, ensuring that it was properly executed,

and informed the Board of Directors accordingly.

• The Committee discussed with Management, the Director of Financial Activities, the Director of

Legal Services, the Head of Internal Audit, and the External Auditors on significant issues included in

the financial statements, based on the Key Audit Matters and other recommendations from the

above.

• The Committee provided its recommendations to the Board of Directors regarding the half-yearly

and annual financial statements, based on the results of the relevant audit work.

B.Internal Control Systems – Internal Control Unit

The Company’s Internal Control System consists of the policies, procedures, and authorizations

designed and assigned by the Management with the aim of achieving the Company’s objectives. The

safeguards included in this system are designed and implemented to minimize risks and protect

assets, ensure the accuracy of records, promote operational efficiency, and encourage compliance

with applicable legal and regulatory frameworks. The internal audit activity of the Company is carried

out by an independent and objective internal audit unit. The Audit Committee serves as the

supervisory body of the Internal Audit Department, which submits quarterly reports highlighting any

weaknesses identified, their impact, and the actions taken by the Management to address them.

In this context, the Audit Committee:

• Evaluated the annual audit plan for 2024, taking into account the main areas of business and

financial risk, as well as the results of previous audits and the review of the 2024 internal audit plan,

and recommended its approval by the Board of Directors.

• Was informed about all audits carried out during the review period, the findings, the corrective

actions agreed with senior management, and the timeline for their implementation. Furthermore, the

Committee was regularly updated on the progress of implementing these corrective actions as per the

established timeline.

• In accordance with the provisions of paragraph 3, item (i) and paragraph 4 of Article 14 of Law

4706/2020, and decision 1/891/30.09.2020 of the Hellenic Capital Markets Commission, the

Committee submitted to the Board of Directors quarterly reports from the Internal Audit Department

on the most important issues and proposals, along with its observations (based on Article 16 of Law

4706/2020).

• Was updated by the General Director of Digital Governance on the progress of cybersecurity

initiatives, external security assessments, internal security indicators, staff training on information

security matters, priorities, monitoring, and the security framework, as well as the implementation of

the information systems security plan and collaboration with external cybersecurity partners.

• Was informed about the ESG (Environmental, Social, Governance) objectives and results for 2024,

based on the ESG strategy, developments in European legislation regarding non-financial reporting,

upcoming sustainability obligations, and the priorities, goals, and actions for fiscal year 2024.

C. Sustainable Development

According to all the information presented to the Audit Committee during its annual work, the

Company’s Sustainable Development Policy is applied in the Company’s operational and strategic

decisions through responsible business practices that minimize negative impacts on health, safety,

and the environment resulting from the Company's activities, products, or services.

A large portion of the corporate monitoring indicators is determined by modern governance

standards based on ESG, and the Company uses appropriate KPIs to monitor the achievement of its

corporate strategy.

Regarding environmental impact (E), EYDAP focuses on the sustainable management of natural

resources and water sources, protecting ecosystems, and reducing its carbon footprint by adopting

principles of the circular economy.

Regarding social impact (S), the Company provides services and implements projects that improve

citizens' quality of life, while ensuring affordable pricing and social policies that alleviate inequalities.

Local communities are empowered, taking a leading role in comprehensive local development

approaches. Essential issues include health, safety, and employee development, with equal

opportunities and respect for diversity.

Regarding corporate governance (G), the key strategic issues for EYDAP include board composition

according to sustainable development principles, anti-corruption efforts, financial performance,

business resilience, effective supply chain management, and personal data protection.

A significant portion of the monitoring indicators of the Strategy aligns with modern ESG standards,

and the Company has a reward system to coordinate efforts and participate in achieving collective

outcomes. EYDAP is working towards aligning with the regulatory requirements of the new

Independent Regulatory Authority for Water (RAAEY).

The Strategy and Innovation Department, in collaboration with the Strategy, Innovation, and

Sustainable Development Committee of the Board of Directors, ensures that the strategy takes into

account essential issues arising from materiality analysis, as well as European and national trends,

policies, and technological developments. In this regard, EYDAP actively participates in major

European networks and in European and national consultations.

Given the Company’s extensive investment plan to achieve these goals, the main concern is providing

clean water for all at a fair price through a sustainable management and funding model.

For the above matters within its competence, the Audit Committee informed the Board of Directors

regularly (at least quarterly).

Finally, the Audit Committee has prepared and will present to the shareholders at the upcoming

Annual General Assembly its report on its activities for fiscal year 2024.

2.2 Remuneration and Nominations Committee

With the No. 20394/4.9.2019 of the Board of Directors (BoD) decision, the Remuneration Committee

of the BoD of EYDAP was established, consisting exclusively of non-executive members of the Board,

mostly independent, with the main responsibility of establishing the Remuneration Policy. Considering

the possibility of assigning the duties of the Remuneration Committee and the Nominations Committee

to a single committee under paragraph 2 of Article 10 of Law 4706/2020, the Remuneration and

Nominations Committee of the BoD was established with Decision No. 20854/5.4.2021 as an

independent and objective body, which assists the BoD of the company transparently on matters

related to the remuneration of the Chairman of the Board, as well as the executive and non-executive

members, in accordance with the applicable legislation, and in the selection of suitable candidates for

the position of BoD member of EYDAP, according to Article 12 of Law 4706/2020 and the Nominations

Policy of the company.

The Remuneration and Nominations Committee of the BoD consists exclusively of non-executive

members of the company's BoD, the majority of whom are independent. The members of the

Committee are selected and appointed by the BoD, and their number cannot exceed five (5) members

or be fewer than three (3), and it will always remain an odd number. The Chairman of the Committee

is an independent non-executive member of the BoD, responsible for planning and conducting

meetings and must have served as a member of the Committee for at least one year, unless the

Committee was not constituted or did not operate in the previous year. The term of office of the

Committee members coincides with that of the BoD, with the possibility of renewal.

The purpose of the Remuneration and Nominations Committee is to provide support and assistance

to the Board of Directors in its duties related to:

• The remuneration of the Board members, both executive and non-executive.

• Ensuring the quality staffing and smooth succession and continuity of the Board to fulfill its role

effectively for the benefit of the Company and all stakeholders. The specific duties of the Committee

and the relevant procedures for fulfilling its purpose are described in its Operating Regulation.

Following the election of new BoD members by the majority shareholder on 12th September 2023, with

Decision No. 21573/18.9.2023 of the BoD, the Remuneration and Nominations Committee was formed

by non-executive members of the BoD, the majority of whom are independent, with a term of office

corresponding to their term as BoD members, as follows:

1. Efthymios Sfikas, Independent non-executive member

2. Marika Lamprou, Independent non-executive member

3. Panagiotis Skoularikis, Non-executive member

During the meeting of 18th September 2023, the Committee was constituted and unanimously elected

Mr. Efthymios Sfikas as its Chairman, considering that he could effectively and competently fulfill the

duties of the position.

This composition remains unchanged until the publication of this document.

During the same meeting, the members confirmed the legality of the composition of the Remuneration

and Nominations Committee in accordance with paragraph 3 of Article 10 of Law 4706/2020, as it is a

three-member committee consisting exclusively of non-executive members, the majority of whom are

independent. It is reminded that the BoD, by its decision No. 21999/29.04.2025, confirmed that during

the 2024 fiscal year, the above persons met the independence criteria of Article 9 of Law 4706/2020.

Operation of the Remuneration and Nominations Committee

During the year 2024, the Remuneration and Nominations Committee held eighteen (18) meetings, of

which two were joint meetings with the Strategy, Innovation, and Sustainable Development

Committee, on the following dates:

Meeting, 11.01.2024

Meeting, 23.01.2024

Meeting, 01.02.2024

Meeting, 22.02.2024

Meeting, 29.02.2024

Meeting, 14.03.2024

Meeting, 09.05.2024

Meeting, 23.05.2024

Meeting, 24.05.2024

Meeting, 06.06.2024

Meeting, 12.06.2024

Meeting, 08.07.2024 &

12.07.2024

Meeting, 05.09.2024

Meeting , 10.10.2024

Meeting, 31.10.2024

Meeting, 21.11.2024

Meeting, 28.11.2024

Meeting, 16.12.2024

All members of the Committee participated in all of the meetings.

According to its Operating Regulations, which were revised by decision no. 21894/11.12.2024 of the

Board of Directors and are posted on the Company’s website

(https://www.eydap.gr/Investors/CorporateGovernance/BoDCommitee/), the Committee meets

regularly at least four (4) times a year and always before the preparation of the Remuneration Policy,

the annual Remuneration Report, and the proposal for the annual remuneration of the members of the

Board of Directors. It also meets exceptionally as often as deemed necessary to fulfill its mission.

For the fiscal year 2024, the 42nd Annual General Assembly of Shareholders, considering the

Remuneration Policy and decision no. 21778/14.06.2024 of the Board of Directors, decided to pay the

Chairman of the Remuneration and Nominations Committee 500 euros (gross, plus employer’s

contributions) per meeting, and the same amount of 375 euros to each member of the Committee. It

was also decided that a monthly amount of 195 euros (gross, plus employer’s contributions) will be paid

per person (for the months in which a meeting will take place) to the Chairman and members of the

Committee as a per diem and travel allowance, with a maximum of eighteen meetings of the Committee

per calendar year.

The evaluation of the effectiveness and performance of the Remuneration and Nominations Committee

is currently in progress. Please refer to the relevant details in section 1.7 (Evaluation of the Board of

Directors and Committees).

Regarding its activities, the issues examined by the Remuneration and Nominations Committee

during the fiscal year 2024 are summarized as follows:

• Update of the Remuneration Policy and related proposal to the Board of Directors and the General

Assembly

• Update of the Nominations Policy and related proposal to the Board of Directors and the General

Assembly

• Update of the Operating Regulations of the Committee and related proposal to the Board of

Directors

• Verification of the fulfillment of the independence requirements of Article 9 of Law 4706/2020 for

the independent non-executive members of the Board of Directors of EYDAP S.A.

• Evaluation of the suitability of the members of the Board of Directors

• Proposal for the approval of the Remuneration Report for the fiscal year 2023 and submission for

discussion at the Annual General Assembly in accordance with Article 112, paragraph 3 of Law

4548/2018

• Determination of the remuneration of the members of the Board of Directors

• Proposal for the approval of numerical indicators per quantitative target for the payment of

additional variable remuneration (bonus) to the CEO for the fiscal year 2024

• Discussion of the proposed first-level indicators and target-setting for 2024 & 2028, following the

presentation by the Director of Strategy and Innovation

• Provision of advisory services by an external consultant to the Committee on the effectiveness and

evaluation of the Board of Directors, its Committees, the CEO, the strategic profile of the Board of

Directors, and individual and collective assessment of suitability and development

• Verification of the fulfillment of the independence requirements of Article 9 of Law 4706/2020 for

the non-executive members of the Board of Directors of EYDAP S.A. who are not already independent

members

• Training of Board Members (on ESG topics, risk management, and the legislative framework of

EYDAP)

• Proposal to the Board of Directors regarding the re-announcement of the position of General

Director of Finance and Supply Chain

2.3 Risk Management Committee

In the context of ensuring the adequate and effective functioning of the Company’s Internal Control

System, which aims, among other things, at the identification and management of significant risks

associated with its business activities and operations, the Board of Directors, with its decision no.

20945/17.11.2021, decided to establish the Risk Management Committee of the Board of Directors of

EYDAP, consisting of members of the Board, the majority of whom are non-executive, with a term

corresponding to their term as members of the Board.

The purpose of the Risk Management Committee is to assist the Board of Directors in executing its

responsibilities regarding the management of operational risks. This is achieved through the

supervision, evaluation, and monitoring by the Risk Management Committee of the design and

implementation of the framework for managing operational, technological, climate-related, financial,

and other risks, crisis and disaster management plans, and their effective implementation, as well as

the business continuity planning, taking into account the scope of activities, critical infrastructure, and

the complexity of the Company.

To achieve the above purpose, the Risk Management Committee has the following indicative

responsibilities:

1. Supports the development of a framework for risk-taking.

2. Reviews and regularly monitors the risk management and crisis and disaster management

framework and submits proposals for changes to the Risk Management Division, the CEO, and

the Board of Directors.

3. Ensures the effective functioning of the risk management and crisis and disaster management

framework.

4. Supports, reviews, and monitors the creation of a framework and methodology for the

Company’s business continuity in risk, crisis, and disaster situations.

5. Monitors and tracks operational, technological, climate-related, financial, and other risks (risk

profile) regularly, according to the risk management procedures, taking into account the

actions taken to address the risks.

6. Evaluates the effectiveness and cost/benefit ratio of applying security measures.

7. Receives and reviews independent assessments regarding the adequacy and effectiveness of

the risk management and crisis and disaster management framework.

8. Regularly informs the Board of Directors about the progress of significant risks as well as the

adequacy and effectiveness of the risk management framework through its Chairman.

9. Evaluates information, both internal and external to the Company, on risk management issues

and processes that may periodically be required by the Company.

With the no. 21728/6.12.2023 decision of the Board of Directors, the Committee’s Operating

Regulations were revised, and according to its provisions, the Committee is at least three members and

consists of both executive and non-executive Board members, with the majority being non-executive.

At least one member is independent. The Board of Directors appoints the members and the Chairman

of the Committee from among the non-executive members. The term of the members corresponds to

the duration of their term on the Board of Directors. The Committee’s Operating Regulations are posted

on the Company’s website (https://www.eydap.gr/Investors/CorporateGovernance/BoDCommitee/).

The Committee meets at least four (4) times a year and whenever deemed necessary.

By decision no. 21728/06.12.2023, the Committee was restructured and consists of the following

members:

1. George Stergiou, Non-executive member, Chairman

2. Marika Lamprou, Independent non-executive member, Vice-Chairman

3. George Alexandrakis, Non-executive member

4. Antonios Giannikouris, Non-executive member

5. Marina Mavrommati, Independent non-executive member

The above composition remains unchanged until the date of publication of this report.

Operation of the Risk Management Committee

During the year 2024, the Risk Management Committee held a total of twelve (12) meetings, which

were conducted via videoconference on the following dates:

All members of the Risk Management Committee participated in all meetings, which were conducted

via videoconference and electronic means. Before each meeting, the Committee members, at the

initiative of the Chairman, received the Agenda and supporting materials in a timely manner.

For each meeting, an Agenda was drafted, proposed by the Chairman of the Committee. The minutes

of each meeting were recorded and subsequently approved by the members of the Committee.

Additionally, throughout 2024, the Committee was supported by an External Consultant.

Two joint meetings were held with other Committees of the Board of Directors, specifically:

● Joint meeting with the Strategy, Innovation & Sustainable Development Committee

● Joint meeting with the Audit & Compliance Committees

For the fiscal year 2024, the 42nd Annual General Assembly of Shareholders, considering the

Remuneration Policy and decision no. 21778/14.06.2024 of the Board of Directors, decided to pay the

Chairman of the Risk Management Committee €500 gross, plus employer contributions per meeting,

and €375 to each member of the Committee. It was also decided to pay monthly (for the months in

which a meeting will be held) an amount of €195 gross, plus employer contributions, to the Chairman

and the members of the Committee as attendance and travel expenses, with a maximum number of

eighteen meetings of the Committee per calendar year.

The evaluation of the effectiveness and performance of the Risk Management Committee is ongoing.

Please refer to the details in section 1.7 (Evaluation of the Board and Committees).

Issues Discussed by the Risk Management Committee / Presentations

Risk Appetite Framework

The Risk Appetite Framework was unanimously approved by the members of the Committee at the

21st meeting on 06.08.2024 and was ratified by the Board of Directors with decision no.

21877/11.09.2024, following the Committee’s recommendation. It includes qualitative and

quantitative Risk Appetite statements, limits, and early warning points, as defined in this Framework.

Revision of the Risk Management Policy

Following the approval of the Risk Appetite Framework, the Risk Management Division reviewed the

approved Risk Management Policy, and its revision is currently underway.

Once the draft of the revised Risk Management Policy is finalized and approved, the Risk

Management Committee will submit a recommendation to the Board of Directors for approval.

Meeting,

18.01.2024

Meeting,

08.02.2024

Meeting ,

21.03.2024

Meeting ,

22.04.2024

Meeting, 03.06.2024

Meeting,

06.08.2024

Meeting ,

23.09.2024

Meeting ,

18.10.2024

Meeting

, 13.11.2024

Meeting,

27.11.2024

Meeting ,

13.12.2024

Meeting ,

18.12.2024

Implementation of the Risk Appetite Framework

The implementation process of the Risk Appetite Framework was finalized at the 25th meeting on

27.11.2024, and the Board of Directors was informed accordingly at its 1493rd meeting on

11.12.2024.

Risk Register

The update of the Risk Register is in progress by the Risk Management Division.

Crisis Management Plan (CMP)

The Committee discussed the Crisis Management Plan during the 25th meeting on 27.11.2024, and it

was finalized in the 28th meeting on 14.01.2025. It was approved by the Board of Directors with

decision no. 21902/15.01.2025, following the Committee’s recommendation.

Collaboration of the Three Lines of Defense of the Internal Control System

As provided in the Committee’s Regulations ("...9. Cooperates with the Audit Committee to ensure

that the significant risks identified by the Internal Audit Division are included in the risk register and to

inform it about the risks identified by the Risk Management Committee."), a joint meeting was held

with the Audit and Compliance Committees.

The need for designing a framework governing the communication between the three lines regarding

frequency and content (communication protocol) was highlighted, which is also necessary due to the

implementation of new standards.

As part of the Committee’s update on the most significant risks identified by the Risk Management

Division at the corporate level, the following presentations took place:

● Update on actions for managing asbestos-cement waste in EYDAP projects

● Understaffing of organizational units and lack of specialized personnel

● Protection and security of installations and infrastructure

● Failure of information systems

● Cyber Maturity Assessment Report

● Presentation of the methodology for the project "Analysis of Climate Risks/Opportunities and

Development of Related Disclosures"

2.4 Strategy, Innovation, and Sustainable Development Committee

The Strategy and Innovation Committee of the Board of Directors was established by Decision No.

20853/05.04.2021 of the Board of Directors, consisting exclusively of members of the Board of Directors

of EYDAP. With the No. 21270/22.3.2023 decision, the Strategy and Innovation Committee of the Board

of Directors was renamed to the Strategy, Innovation, and Sustainable Development Committee, and

the Regulation for its Operation was accordingly amended.

The Committee is informed, analyzes, evaluates, and advises the Company’s Management and Board

of Directors on matters relating to the overall strategy of the Company, as well as on specific issues

related to strategy in new technologies and innovation, including the digital transformation of the

Company, cybersecurity, and sustainability through innovative technologies. The ultimate goal of the

Committee is the sustainable development and optimization of the Company’s value.

Indicatively, the Committee has the following responsibilities:

1. To be informed, evaluate, advise, and express opinions on the Company’s long-term strategic

goals and its mid-term strategy, in alignment with the directions and goals set by the Board of

Directors.

2. To be informed, evaluate, advise, and express opinions on the strategy regarding new

technologies, innovation, and the transformation of the Company.

3. To be informed, evaluate, advise, and express opinions on the strategy regarding risks related

to digital and new technologies, as well as issues of cybersecurity.

4. To be informed, evaluate, advise, and express opinions on the strategy regarding sustainability

and circular economy issues through the application of technology and innovative solutions.

5. To monitor the implementation of the Company’s strategy on a semi-annual basis concerning

strategic projects of the Company and innovation and digital transformation projects. The

Committee provides feedback to the Board of Directors in the context of preparing the annual

budget and investment plan regarding the above.

6. To be informed, evaluate, advise, and express opinions on the adoption of best practices in

the Greek and European/international environment. In this context, the Committee monitors

the work of other international organizations and bodies in Greece and abroad, adhering to

confidentiality principles and competition rules.

7. To organize, in collaboration with the Management, presentations upon the invitation of the

Management or the Board of Directors or on its own initiative, for the purpose of informing

the Board Members about matters under its jurisdiction.

According to the current Regulation of the Committee, which was amended by Decision No.

21270/22.3.2023 of the Board of Directors and is posted on the Company’s website

(https://www.eydap.gr/Investors/CorporateGovernance/BoDCommitee/), the Strategy and Innovation

Committee consists of at least five (5) members of the Board of Directors, the majority of whom are

non-executive, including the Chairman of the Board, the CEO, and the Deputy CEO (if applicable). The

members of the Committee are selected and appointed by the Board of Directors, and the number of

members always remains odd. The term of office for Committee members is two years, and it may be

extended by a decision of the Board of Directors.

The Committee was established by Decision No. 21717/08.11.2023 of the Board of Directors of EYDAP

SA. It consists of non-executive members of the Board of Directors, with a term corresponding to their

term as Board members. By Decision No. 21717/08.11.2023, the Committee was restructured and

consists of the following members:

1. Georgios Stergiou, Non-executive member, Chairman

2. Christos Mistriotis, Non-executive member, Vice Chairman

3. Charalampos Sahinis, Executive member

4. Antonios Giannikouris, Non-executive member

5. Anastasia Martseki, Independent non-executive member

This composition remains unchanged until the date of publication of this report.

Operation of the Strategy, Innovation, and Sustainable Development Committee

In 2024, the Strategy, Innovation, and Sustainable Development Committee held a total of seven (7)

meetings, which were conducted via videoconference, as detailed below. Additionally, three joint

meetings were held with other Committees of the Board of Directors, specifically:

● 1 Joint meeting with the Risk Management Committee

● 2 Joint meetings with the Remuneration and Nominations Committ

Meeting 07.02.2024

Meeting

21.02.2024

Meeting

29.02.2024 (Joint

meeting with the

Remuneration and

Nominations Committee)

Meeting

24.05.2024 (Joint

meeting with the

Remuneration and

Nominations Committee)

All members of the Committee participated in all meetings, which were conducted via videoconference

and using electronic means. Before each meeting, the Committee members, at the initiative of the

Chairman, received the Agenda and accompanying materials in a timely manner.

For each meeting, an Agenda was prepared, proposed by the Chairman of the Committee. The minutes

of each meeting were recorded and subsequently approved by the Committee members.

For the year 2024, the 42nd Annual General Meeting of Shareholders, taking into account the

Remuneration Policy and Decision No. 21778/14.06.2024 of the Board of Directors, decided to pay €500

gross, plus employer’s contributions, per meeting to the Chairman of the Strategy, Innovation, and

Sustainable Development Committee, and €375 gross, plus employer’s contributions, to each member

of the same Committee. It was also decided to pay a monthly amount of €195 gross, plus employer’s

contributions, per individual (for the months in which a meeting is held) to the Chairman and members

of the Committee as attendance and travel expenses, with a maximum of fourteen meetings per

calendar year.

The evaluation of the effectiveness and performance of the Strategy, Innovation, and Sustainable

Development Committee is ongoing. Please refer to the relevant information in section 1.7 (Board of

Directors and Committee Evaluation).

Matters addressed by the Strategy, Innovation, and Sustainable Development Committee /

Presentations

Investment Program 2024-2033

With a significant increase in the absorption of resources for projects in 2023, the proposed mixed

budget for 2024 amounts to €82.668 million, covering 84 projects, 55% of which are funded by the

EU. Over a ten-year period, the 2024-2033 budget totals €2.379.916 million, covering 175 projects,

categorized into contracted, funded, and projects with potential funding or cost-benefit evaluation.

The overall increase in the ten-year investment program compared to the previous one is attributed

to new projects in the network, the installation of smart meters, and cost increases due to

institutional and economic parameters.

2024 Annual Budget

The summary presentation of the 2024 budget highlighted key financial figures, with revenues

estimated at €380.5 million and expenses at €360.1 million. EBITDA is estimated at €53.2 million,

while pre-tax profits are estimated at €20.5 million. The 4.2% increase in turnover is mainly attributed

to the new pricing policy and increased water consumption. Operating costs are expected to reach

€305.8 million, showing an increase compared to 2023, due to salary increases, third-party fees, and

third-party services. Personnel costs are expected to increase by 8.6%, primarily due to salary

adjustments, contract personnel, and performance bonuses. At the same time, third-party fees have

increased by 25%, due to the strengthening of security services, consulting services, and facility

maintenance. In contrast, third-party services have decreased by 7.4%, despite increased expenses for

rents, insurance premiums, and postage.

Meeting

15.07.2024

Meeting

30.10.2024

Meeting

18.12.2024 (Joint

meeting with the Risk

Management

Committee)

Business Plan 2024-2033

The analysis included the presentation of two alternative scenarios – the inflationary and the

regulatory – along with the key assumptions for the business plan for the 2024-2033 period. In the

inflationary scenario, the financial results show the emergence of a financing gap from 2028,

necessitating borrowing. In the regulatory scenario, the regulated asset base and the permitted

revenue from the regulator are estimated. Finally, a comparative analysis of the two scenarios was

made regarding pre-tax profits, interest, and depreciation, cash liquidity, dividends, and operating

cash flow.

Qualitative and Quantitative Key Performance Indicators (KPIs) of the Company

The Strategy and Innovation Department analyzed the three main pillars of the company’s strategy –

Safety, Efficiency, and Development – as well as the strategic priorities set for each of them. Particular

emphasis was given on the importance of ESG criteria and compliance with European guidelines.

Furthermore, performance indicators to be monitored were presented, which will be linked to the

overall efficiency of the company and the evaluation of its workforce and organizational units.

Proposals for 1st Level Indicators and Target Setting for 2024-2028, and Defining KPIs for Monitoring

Strategic Priorities

The company’s goal-setting for 2024 was addressed by the Committee at the 37th meeting on

15.07.2024 and approved by Board Decision No. 21876/11.09.2025, following the Committee’s

recommendation.

As for these strategic priorities, it was proposed that they be defined based on:

● The 4 critical management KPIs approved by the Board of Directors: • Efficiency indicator in

relation to overdue receivables • Efficiency indicator in relation to operating expenses •

Growth indicator in relation to the investment plan • Efficiency indicator, including

environmental management, in relation to unmetered water

● 20 additional critical 1st level KPIs for monitoring, with which the Board of Directors can track

all strategic priorities of the company.

2.5 Compliance Committee

In the context of ensuring the adequate and effective operation of the Company's Internal Control

System, which aims, among other things, at monitoring, evaluating, and managing regulatory

compliance risks, the Regulatory Compliance Committee was established pursuant to the decision of

the Board of Directors No. 21268/22.3.2023.

The operating framework of the Regulatory Compliance Committee is defined by its Operating

Regulations, which were approved by the decision of the Board of Directors No. 21863/24.07.2024, and

are posted on the Company's website

(https://www.eydap.gr/Investors/CorporateGovernance/BoDCommitee/).

The Committee is at least three members and consists of non-executive members of the Company's

Board of Directors. At least one member of the Committee is an independent non-executive member

of the Board of Directors. The Board of Directors appoints the members and designates the President

of the Committee.

The term of office of the Committee members corresponds to their term on the Board of Directors. In

the event of resignation or loss of a Committee member, the Board of Directors may appoint one of its

members as a replacement.

The Regulatory Compliance Committee was established pursuant to the Board of Directors' decision

No. 21717/18.11.2023 as follows:

1. Eleni-Maria Kaymenaki, Non-Executive Member, President

2. Efthymios Sfikas, Independent Non-Executive Member

3. Emmanouil Angelakis, Non-Executive Member

The above composition remains unchanged until the date of publication of this document.

The purpose of the Committee is to assist the Board of Directors in fulfilling its responsibilities regarding

the continuous compliance of the Company with all provisions of applicable national and EU legislation,

decisions of competent Supervisory Authorities and Independent Authorities, and other rules governing

the operation of the Company. Therefore, the Committee supervises and evaluates the design and

implementation of the Regulatory Compliance Policy and the Regulatory Compliance Management

System adopted and implemented by the Company.

To fulfill its purpose, the Committee:

1. Contributes to the development of a "Compliance Culture."

2. In cooperation with the Compliance Department, provides information and support to the

Board of Directors on Regulatory Compliance matters.

3. Monitors the operation and work of the Compliance Department, its adequate staffing, and

oversees the coordination of compliance-related actions. In this context, it advises and

supports the Compliance Director in fulfilling their duties and work.

4. Evaluates and provides its opinion on the Annual Compliance Action Plan prepared by the

Compliance Department. The Committee then submits the Annual Action Plan to the Board of

Directors for approval.

5. Monitors the establishment, implementation, and updating of the Regulatory Compliance

Policy and the Compliance Management System. In this context, it provides information and

proposals to the Compliance Directorate.

6. Evaluates the Regulatory Compliance Policies, the Operating Regulations, and the specific

Procedures of the Compliance Department, which are submitted for the Committee’s opinion.

The Committee then recommends to the Board of Directors the approval of the Regulatory

Compliance Policies and the Operating Regulations of the Compliance Department. As for the

Compliance Procedures, they are submitted by the Directorate to the Committee for its

opinion and to the CEO for approval.

7. Oversees the full and adequate integration of Regulatory Compliance requirements into the

Company's Policies, Regulations, and Procedures.

8. Oversees the progress of the Annual Training Program developed and implemented by the

Compliance Department in collaboration with the Human Resources Training Department and

is updated on related actions.

9. Oversees the processes for the prevention and systematic management of the Company's

Regulatory Compliance risks as identified and recorded by the Compliance Department (in

collaboration with the Risk Management Department).

10. Collaborates with the Risk Management Committee to ensure that Regulatory Compliance

risks are included in the Risk Register.

11. Monitors the planning of awareness and information actions for staff on issues related to the

Code of Ethics and Professional Conduct.

12. Reviews the annual reports (activities report, report on submitting conflict of interest

statements, and whistleblowing management report, as defined in the relevant Policies)

submitted by the Compliance Director to the Committee. The Committee then submits these

reports to the Board of Directors for information.

13. Is informed about the findings of preventive compliance audits conducted by the Compliance

Directorate, as well as the proposed corrective actions, evaluating their effectiveness.

14. Manages the reports/complaints referred from the Report Evaluation Committee in cases

specified in the Whistleblowing Policy.

15. Collaborates with other Board of Directors Committees.

16. Has unobstructed and full access to the information needed in the exercise of its duties,

subject to the provisions on personal data protection.

17. Prepares an annual report of its activities to be included in the Company’s Board of Directors'

management report, detailing the Committee's work.

18. Reports, at least annually, to the Board of Directors on activities related to its purpose and

responsibilities.

19. Recommends to the Board of Directors actions to improve the Company’s performance on

Regulatory Compliance matters following a related proposal from the Compliance Directorate.

Operation of the Regulatory Compliance Committee

During the year 2024, the Regulatory Compliance Committee held 14 meetings, in which all its members

participated.

MEETING No

DATE

16/01/2024

19/02/2024

28/03/2024

15/05/2024

05/06/2024

05/07/2024

19/07/2024

19/09/2024

30/09/2024

29/10/2024

27/11/2024

13/12/2024

18/12/2024

20/12/2024

During its meetings, the Regulatory Compliance Committee addressed the following issues:

● Review of Regulations, Codes, and Policies that have been developed, are in progress, or have

been updated within the framework of the Regulatory Compliance System.

● Development of procedures for the Regulatory Compliance Department.

● Review of the results of Regulatory Compliance Audits conducted in 2024 before submitting

them to the Board of Directors for its information.

● Review of the Assessment Report of conflict-of-interest declarations in compliance with the

Company's Conflict of Interest Policy, before submitting it to the Board of Directors for its

information.

● Review of the annual whistleblowing reports for 2023 and 2024 before submitting them to the

Board of Directors for its information.

● Review of the Employee Training Procedure on Regulatory Compliance issues before

submitting it for approval to the Company's CEO.

● Review of the processes for monitoring legislative and regulatory developments and updating

the Management and organizational units about these developments by the Regulatory

Compliance Department.

● Monitoring the progress of the development of Regulatory Compliance tools and

strengthening the Regulatory Compliance System.

● Information about the contribution of the Regulatory Compliance Department to enhancing

the Corporate Governance System.

● Monitoring the development of systematic communication between the Regulatory

Compliance Department and the Company’s staff and executives to provide guidance and

clarification on issues arising during the implementation of the legislative/regulatory

framework and the Company's Policies/Regulations.

● Information on the staffing, training, and further education of the Regulatory Compliance

Department's staff.

For the fiscal year 2024, the 42nd Annual General Meeting of Shareholders, taking into account the

Remuneration Policy and Decision No. 21778/14.06.2024 of the Board of Directors, decided to pay €500

(gross, plus employer’s contributions) per meeting to the President of the Regulatory Compliance

Committee and an equivalent amount of €375 to each member of the same Committee. Furthermore,

it was decided to pay a monthly amount (for the months in which meetings are held) of €195 (gross,

plus employer’s contributions) to the Chairman and Members of the Committee as attendance and

travel expenses, with a maximum of 14 meetings per calendar year.

The evaluation of the effectiveness and performance of the Regulatory Compliance Committee is

ongoing. Please refer to Chapter 1.7 (Evaluation of the Board of Directors and Committees) for further

information.

Issues Addressed by the Regulatory Compliance Committee

In 2024, the Regulatory Compliance Committee worked with a priority to foster a culture of regulatory

compliance within EYDAP's workforce and to ensure the integrity of the way the Company operates.

The Committee intensified its activities and actions towards the following directions:

● Coordination of actions related to Regulatory Compliance.

● Establishment of strong Regulatory Compliance Policies and the establishment and

implementation of rules, ensuring that internal operations within the Company and

transactions with third parties are conducted with transparency and integrity, for the benefit

of all stakeholders.

● Timely, full, and ongoing compliance of the Company with the applicable legal and regulatory

framework governing its operations.

● Prevention and systematic management of regulatory compliance risks, following best

practices.

● Implementation of due diligence practices regarding sustainability and human rights issues.

● Continuous awareness, sensitization, and training on Regulatory Compliance issues,

encouraging Company staff to report unethical behavior or instances of non-compliance and

to seek guidance.

● Commitment to investigating cases of non-compliance or unethical behavior and proposing

suitable corrective measures and management actions.

In this context, the Committee oversees the Regulatory Compliance Department, reviews periodic

Regulatory Compliance reports by evaluating their completeness, accuracy, and correctness, and

informs the Board of Directors accordingly.

3. Other Administrative, Management, or Supervisory Bodies or Committees

3.1 Executive Committee

The Executive Committee ("EKEP") was established by Decision No. 21144/21.12.2022 of the Board of

Directors and is composed of the Chief Executive Officer, the General Directors, and the Directors of

Financial and Supply Chain Activities (until the position of General Director of Finance and Supply

Chain Activities is filled). The CEO was appointed as President of the Executive Committee and is

responsible for scheduling and conducting its meetings.

In fulfilling its duties, the Executive Committee takes into account the Board of Directors' decisions

assigning certain powers or responsibilities, the legal and regulatory framework, the financial situation,

business strategy, long-term interests, and sustainability of the Company, and other parameters based

on its judgment. The duties and functions of the Executive Committee are detailed in its Operating

Regulation, which was approved by Decision No. 21144/21.12.2022 of the Board of Directors, revised

by Decision No. 21890/13.11.2024 of the EYDAP Board of Directors, and is available on the Company's

website (https://www.eydap.gr/TheCompany/RegFramework/).

Curriculum Vitae of Senior Executives - Members of the Executive Committee

Katerina Vlastari - General Director of Human Resources

Katerina Vlastari was born in 1960 in Athens. She holds a degree from the Higher Industrial School,

Department of Business Organization and Management, and is a certified DPO (Data Protection

Officer). She also holds a Cambridge Proficiency certificate.

Currently, she holds the position of General Director of Human Resources at EYDAP S.A. From 2018 to

2021, she served as Data Protection Officer (DPO), taking on responsibilities in a newly established

institutional role. Her first managerial position in her professional career at EYDAP was Head of the

Payroll Service, from 2004 to 2007. She later served as Director of Training from 2007 to 2009 and

Assistant General Director of Human Resources from 2009 to 2010. In the private sector, she worked

from 1988-1989 at SYNEL Fertilizers as Public Relations Manager. Earlier, she worked at the tourism

company Athens Express SA as Director of the Reservations Department and in hotel businesses

Titania Hotel and Akti Messogis S.A. as Head of the Reservations Department. She also worked in key

roles at the following companies: UNICEF, Australian Embassy, Compass Tour Hellas, Hotel Atlantic.

Finally, her extensive experience has led her to be a member of the Board of Directors of the National

Water Council, contributing to more effective water management with the main goal of improving

citizens' quality of life.

Konstantinos Vougiouklakis - General Director of Sewerage

Born in Athens in September 1966, he graduated from the 5th Lyceum of Kallithea. He studied at the

National Technical University of Athens, Department of Civil Engineering. He has been working at

EYDAP since 1993, holding various positions, including Head of the B Regional Maintenance Sector

(1996-1997), Head of Preventive Maintenance of Sewerage Network (1997-2007), Director of

Sewerage Network (2009-2013), Assistant General Director of Network & Facility Operations (2013-

2014), and General Director of Development and Project Production, overseeing the Planning &

Development, Infrastructure, Quality Research & Development (R&D), Building & Energy Assets, and

Development of Relationships with Local Authorities (2014-2016). Since October 2016, he has held

the position of General Director of Sewerage, responsible for the Sewerage Network Directorate, the

Sewerage Planning & Support Functions Directorate, and the Wastewater Treatment Plants

Directorate. The General Directorate of Sewerage manages and processes all wastewater in the area

of responsibility of EYDAP S.A.

Giorgos Karagiannis - General Director of Water Supply

Giorgos Karagiannis is a graduate Civil Engineer from the Polytechnic School of Democritus University

of Thrace. He is married with two children and joined EYDAP in 1990. As a Civil Engineer, he has

designed and constructed a significant number of building projects as part of the Building Facilities

Directorate at EYDAP S.A. He worked for many years on organizing, planning, and implementing

projects and procedures in the Water Supply Networks. From 1990 to 2014, he also worked on the

study and construction of various buildings—residential, office spaces, etc.—focusing on bioclimatic

buildings and the introduction of renewable energy sources, as well as on designing and constructing

Renewable Energy Sources (Photovoltaics). He has led services and directorates across all technical

activities of the company in various positions such as Head, Deputy Director, Assistant General

Director, and General Director. From May 2013 to June 2014, he served as Assistant General Director

of Network and Facility Operations, and from June 2014 to September 2016, he was General Director

of Network and Facility Operations. Since October 2016, he has held the position of General Director

of Water Supply, overseeing the Water Intake, Water Treatment Units, Water Supply Network, Water

Supply Planning & Support Functions, and Water Systems & Data Systems directorates.

He has been a member of the Technical Chamber of Greece (TCG) and the Panhellenic Association of

Civil Engineers (P.S.P.M.E.) since 1990 and was an elected member of the TCG Delegation from 2006

to 2009.

Eftychia-Myrta Nestoridi - General Director of Digital Governance

Eftychia-Myrta Nestoridi is a graduate Civil Engineer, holding a degree from the Massachusetts

Institute of Technology (M.I.T.) (BSCE ‘83) and a master's degree from Northeastern University (MSCE

’85). She worked in the USA for three years and was hired by EYDAP in 1988, where she started her

career by designing water supply projects. Over the following years, she held managerial positions in

the fields of water and sewerage infrastructure planning & development, business analysis, and

energy. In 2016, she assumed the position of General Director of Coordination and Support Functions,

overseeing areas such as environment, energy, building infrastructure, project & study tenders, and

information technology.

From 2019 to 2021, she served as an Advisor to the Administration, focusing on supporting

negotiations with the Greek Government for a new 20-year concession agreement for the exclusive

provision of water and sewerage services in Attica. In June 2021, she became the General Director of

Digital Governance, aiming to modernize and digitally transform EYDAP.

Paraskevi Niarou - General Director of Customers

Paraskevi Niarou studied Mathematics at the National and Kapodistrian University of Athens,

specializing in Analysis, Programming, and Project Monitoring. She completed postgraduate studies in

Public Administration (MPA).

She joined EYDAP in 1988 in the IT Department, initially as an Information Systems Analyst, and in

2001, she took on a leadership position in the Computerization Service. From 2004 to 2013, she

served as Deputy Director in the IT and Technology Department. In 2013, she was appointed Deputy

Director of the Water Supply Network.

In 2016, she joined the General Directorate of Customers, specifically as Director of Special Customer

Services, and in 2022, she became Director of Customer Service. From these positions, she managed

long-standing and demanding customer issues, network handovers, and modernization changes,

alongside managing the pandemic.

Since April 2023, she has served as the General Director of Customers, working to ensure customer

satisfaction through continuous efforts to meet needs and expectations while adapting processes to

modern requirements.

Georgia Stefanakou - General Director of Major Projects

Georgia Stefanakou was born in Athens, graduated from the 2nd Arsakeio High School in Psychiko,

and studied Civil Engineering at Aristotle University of Thessaloniki. She completed postgraduate

studies (MSc) in Sanitary Engineering at the Athens School of Public Health and (MSc) in water

resources and environmental engineering at the University of North Florida, USA. She speaks English

and French.

She has worked at EYDAP since 1990, gaining significant experience in all technical activities of the

company, including the study, tendering, and construction of water and sewerage networks, water

and wastewater treatment plants, port works, industrial and energy projects, as well as the operation

and maintenance of large facilities.

With uninterrupted experience in leadership roles since 2001, she served as Head of the Psyttalia

Wastewater Treatment Plant (2001–2013), successfully managing the disposal and utilization of the

produced sludge and the integration of all facilities of the largest environmental project in Greece and

one of the largest in the world.

From 2014, in the senior management structure of EYDAP, she served as Assistant General Director of

Network and Facility Operations (2014–2016), coordinating significant modernization actions and

reducing the energy footprint of large EYDAP facilities. From March 2021, she became General

Director of Major Projects, overseeing six directorates responsible for the design, financing, and

implementation of major projects in EYDAP's investment plan.

Antigoni Synodinu-Kamilou - General Director of Transformation

Ms. Antigoni Synodinu was born in Athens. She is a graduate Chemical Engineer (National Technical

University of Athens) with a Master's in Business Administration.

Ms. Synodinu began her career in a dynamic Greek chemical industry company in marketing, as the

head of a product team. She later moved to one of the leading multinational consumer goods

companies, where she held responsibilities in production planning and logistics.

She has extensive experience at EYDAP, where she has held various leadership positions since 2003.

She served as Head of the Internal Prevention and Protection Service, Head of the Industrial Waste

and Wastewater Service, Head and responsible for the operation of the Polydenndri and Menidi

Water Treatment Plants, Director of Water Treatment Plants, and since 2016, Assistant General

Director of Water Supply. In April 2019, she assumed the General Directorate of Coordination and

Support Functions and, from June 2021, the General Directorate of Transformation.

Eleni Spyropoulou - Director of Financial Activities

Eleni Spyropoulou has been working at EYDAP S.A. since February 16, 2000. She has held the position

of Director of Financial Activities since April 2021. From October 2016 to March 2021, she was

Assistant General Director of Finance, and from May 2013 to September 2016, she was Director of

Financial Services. From May 2008, she served as Head of the Central Accounting Department. Before

joining EYDAP, she worked in the financial department of KIKIZAS A.E.B.E.T. "MELISSA." She obtained

her degree in Business Organization and Management from the Athens University of Economics and

Business in 1994, and a Master's degree in Finance and Banking in 2000, also from the Athens

University of Economics and Business.

Ms. Spyropoulou holds a Class A Accountant's License from the Economic Chamber of Athens (2001),

has received certification in the "IFRS Learning & Assessment Programme" by ICAEW in 2016, and

obtained a diploma for completing the Program Diploma in IFR (DiplIFR)/ACCA in 2017. She has

participated in working groups for the design and operation of new applications at EYDAP S.A.

Konstantina Stavroulia – Director of Supply Chain Activities

Konstantina Stavroulia has been the Director of Supply Chain Activities at EYDAP S.A. since 2021,

responsible for evaluating, optimizing the design, executing, monitoring, and controlling the company's

supply chain activities.

She studied Civil Engineering at the National Technical University of Athens and holds a Master’s degree

(M.Sc.) from the National and Kapodistrian University of Athens.

She has served as Head of the Papagou Sewerage Sector Service of EYDAP S.A. for three years,

responsible for the operation, maintenance, and improvement of the sewerage network in the Sector’s

jurisdiction (Northern & Northeastern Suburbs of South Attica), and as Technical Advisor for Sewerage

Project Management at EYDAP Islands S.A., responsible for the mapping of existing wastewater

treatment facilities and sewerage networks on more than 18 Greek islands. Additionally, she served as

the Director of the Water Supply Network of EYDAP S.A. for seven years, responsible for the operation,

maintenance, and improvement of the water supply network in Attica.

She has also worked for over 15 years, either as a consultant or as the head of engineering teams and

departments in large technical companies and consulting offices, as well as a contractor, focusing on

studies and supervision of numerous significant public works in Greece and abroad, mostly related to

hydraulic works (water supply and sewerage) and environmental projects.

3.2 Other Committees and Bodies with Advisory, Coordinating, Supervisory, or Approval Roles

● Procurement Council

● Disciplinary Councils

● Tender Committees

● Recieving Committees (Procurements, Projects, Services)

● Contract Managers

● Committee for the Registry of Pre-selection System for Contractors, Consultants, and Providers

of Technical and Other Related Scientific Services

● Committee for Damage Assessment (in the context of project contract execution)

● Employee Health and Safety Committee (E.Y.A.E.)

● Third-Party Damage Compensation Committee

● Committee for Managing Requests for Billing Reductions

● Committee for Managing Requests for Debt Settlement Agreements

● Committee for the Evaluation of Reports (whithin the Report-Complaint Management Policy)

● Committee for the Evaluation of Reports on Incidents of Violence and Harassment in the

Workplace (as part of the Policy for Preventing and Combating Violence and Harassment in the

Workplace)

● Sponsorship Committee (whithin the Sponsorship Policy)

● Medical Council

● Service Council

● Promotion Councils: A' Council, B' Council

● Technical Council

D. Diversity Policy Applied to the Administrative, Managerial, or Supervisory Bodies of the Company

The Company is committed to maintaining its philosophy of not tolerating any form of discrimination

or offensive behavior against an individual’s personality, social exclusion, or unfair treatment based on

nationality, race, color, ethnic or social origin, membership in a national minority, property, birth,

disability, age, sexual orientation, gender, genetic characteristics, family status, or religious or political

beliefs.

The Company recognizes that promoting diversity in its administrative, managerial, and supervisory

bodies is essential for its further business development. At the same time, the Company acknowledges

that diversity in the broader workplace can enhance the ability to access a wider variety of solutions

concerning its business activities.

To uphold the above values, the Company adopted the Diversity Policy, as per the decision No.

20961/15.12.2021 by the Board of Directors, which reflects its commitment to these principles.

Through this Policy, as well as the current Nomination Policy, which includes references to the diversity

of the Board members, the Company promotes an appropriate level of diversification in the Board and

a diverse team of members, as it believes that by gathering a wide range of qualifications and skills

during the selection of Board members, a variety of perspectives and experiences is ensured. This, in

turn, contributes to making informed decisions and achieving maximum team effectiveness and

performance. Therefore, the Company believes that diversity on the Board is a necessary element for

maintaining and enhancing its competitiveness, promoting innovation, and fostering cooperation

between the Board members and senior management.

The Diversity Policy includes, among other things, a reference to specific quantitative goals for gender

representation on the Company’s Board, as well as a statement that, in addition to Board members,

the policy is also applied during the selection and appointment of senior executives and applies to all

personnel.

All executive appointments should primarily be based on merit, skills, ethics, and experience,

irrespective of gender, color, race, nationality, disability, age, religion, sexual orientation, political

beliefs, or any other unfair criteria.

The process for recruiting and selecting senior executives should be conducted based on meritocratic

and objective criteria, considering the benefits that diversity brings. A prerequisite for appointing a

senior executive is the possession of the necessary qualifications and other parameters as defined by

the Company. However, the process must ensure that all genders have equal opportunities to be

selected as candidates. According to the current Policy, workplace diversity does not allow for the

exclusion of any executive from any role or position.

The Diversity Policy is reviewed by the Board of Directors at least every two years or whenever deemed

necessary, especially when changes occur in the relevant legal and regulatory framework.

At the end of the 2024 fiscal year:

● Out of the 13 members of the Board of Directors, 4 are women.

● Out of the 10 members of the Executive Committee, 7 are women.

● 32.72% of the total regular staff are women (715), compared to 31.90% in 2023.

● Out of 282 employees in management positions, 159 are women (56.38%) and 123 are men

(43.62%).

● Out of 148 employees in managerial positions (excluding Heads and Controllers B'), 83 are

women (56.09%) and 65 (43.91%) are men.

● Out of 1,903 employees without management positions, 556 are women (29.22%) and 1,347

are men (70.78%).

It is noted that as of 12.9.2023 and up until the time of publication of this report, the composition of

the Board of Directors meets the requirement set by Article 3, paragraph 1b of Law 4706/2020

regarding gender balance on the Company’s Board (as it stood before its amendment by Law

5178/2025). It is also emphasized that the Company already complies with the quantitative

representation target set by Article 3A, paragraph 3 of Law 4706/2020 (33%), which was introduced by

Law 5178/2025, effective from 30.6.2026, due to rounding to the nearest whole number (Article 3A,

paragraph 5).

However, it is noted that by decision No. 25/1027/19.7.2024, the Board of Directors of the Hellenic

Capital Market Commission imposed a reprimand on EYDAP, according to Article 24, paragraph 1 of

Law 4706/2020 and decision No. 1A/890/18.9.2020 of the Board of Directors of the Hellenic Capital

Market Commission, due to a violation of Article 3, paragraph 1b of Law 4706/2020 (as it stood before

its amendment by Law 5178/2025). From 17.7.2021 to 11.9.2023, EYDAP did not meet the required

gender representation percentage of no less than 25% of the total members, as in its 13-member Board,

it had only 2 women instead of 3. In imposing the above sanction, the Hellenic Capital Market

Commission considered, among other things:

● The specificities related to the election and composition of the EYDAP Board due to the

complex election system for Board members and the provisions of Article 114 of Law

4964/2022 following decision No. 190/2022 of the Plenary of the Council of State.

● The Company’s compliance on 12.9.2023.

● The fact that the violation did not impact the smooth functioning of the market, nor did it pose

a risk to the interests of investors and minority shareholders of the Company.

● The Company’s cooperation with the Hellenic Capital Market Commission.

Furthermore, 14.89% of the positions of responsibility in the Company are held by individuals aged

between 30 and 50 years. Regarding the age of current members of the Board of Directors, there is a

significant age variation, from 45 to 66 years, with an average age of 54 years. Regarding the age of the

members of the Executive Committee, it ranges from 50 to 67 years, with an average of 58 years.

Regarding their educational background, all current members of the Board of Directors hold university-

level degrees from either Greek or foreign institutions. Twelve out of the 13 members also hold

postgraduate degrees. The expertise of the members is characterized by diversity (various engineering

disciplines, finance, business administration, law, etc.). Finally, all members have professional

experience, either from their activity in the private market (private and multinational companies,

banking sector) or from positions related to providing advisory services in the public sector.

Regarding their educational background, all members of the Executive Committee hold university-level

degrees from either Greek or foreign institutions. Seven out of the 10 members also hold postgraduate

degrees. Given that EYDAP is primarily a technical company, the expertise of the members of the

Executive Committee mainly pertains to various branches of engineering and finance. As for their

professional background, the members of the Executive Committee have many years of experience in

their field and have advanced significantly within the Company, with several members having previous

experience in large companies.

0-4 years

54%

5-9 years

23%

10+years

23%

Number of Members per years of participation in the

Board

0-4 έτη 5-9 έτη 10+ έτη

More details regarding the information in this section can be found in chapter ESRS2 (General

Disclosures) and in chapter S1 (Familiar workforce) of the sustainability statement.

E. General Assembly & Shareholder Rights

1.1 Powers of the General Assembly – Mode of Operation

The General Assembly of the Company’s shareholders is its supreme body and has the right to decide

on any matter related to the Company. Its decisions bind even the shareholders who were absent or

disagreed. The General Assembly is the sole body authorized to decide on the following matters:

a. Any amendment to the Articles of Association. Subject to paragraph 5 of article 9 of the Articles of

Association, an amendment also includes an increase or decrease in the company’s share capital.

b. The election of the members of the Board of Directors and the auditors, subject to the provisions of

articles 11 and 13 of the Articles of Association.

c. The approval of the individual and consolidated annual financial statements of the Company.

d. The distribution of annual profits.

e. The approval of overall management in accordance with article 108 of Law 4548/2018 and the

discharge of the auditors.

f. The issuance of any type of bond loan, subject to paragraph 4 of article 9 of the Articles of

Association.

g. The merger, division, conversion, revival, extension of the duration, and dissolution of the

Company.

h. The appointment of liquidators.

i. The approval of compensation or prepayment of compensation in accordance with article 109 of

Law 4548/2018 and article 22 of the Articles of Association, as well as the approval of the

remuneration policy under article 110 and the remuneration report under article 112 of Law

4548/2018.

For the rest, the provisions of article 117 paragraph 2 of Law 4548/2018, as in force, apply.

The General Assembly is in a quorum and validly meets on the issues of the agenda if at least fifty

percent (50%) of the paid-up share capital, plus one share, is represented.

If the quorum is not reached in the first meeting, the General Assembly is invited and convenes in a

repeat meeting within twenty (20) days of the aborted meeting and after being invited at least ten (10)

full days before. In the repeat meeting, the General Assembly is in a quorum and validly meets on the

subjects of the original agenda regardless of the part of the paid-up share capital that is represented.

No new invitation is required if the time and place of the repeat meeting were already specified in the

original invitation, provided that there are at least five (5) days between the aborted meeting and the

repeated one.

Decisions of the General Assembly are made by an absolute majority of the votes represented at the

meeting.

Exceptionally, the General Assembly is considered quorate and validly meets on the matters of the

agenda if at least two-thirds (2/3) of the paid-up share capital is represented, when it concerns decisions

on the matters specified in article 130 paragraph 3 of Law 4548/2018 and article 31 of the Company’s

Articles of Association, namely:

a) Change of the nationality of the Company.

b) Change of the Company’s purpose.

c) Increase in shareholders' obligations.

d) Increase in share capital, except for increases under article 8 (paragraphs 2 and 3 of the Articles of

Association) or those imposed by laws or capitalizations of reserves.

e) Reduction of share capital, unless done according to paragraph 5 of article 21 or paragraph 6 of

article 49 of Law 4548/2018.

f) Issuance of bonds, subject to the provisions of article 9 paragraphs 4 and 5 of the Articles of

Association.

g) Change in the method of profit distribution.

h) Merger, division, conversion, revival, extension of duration, or dissolution of the Company.

i) Granting or renewal of authority to the Board of Directors for increasing the share capital or issuing

bond loans in accordance with article 8 paragraphs 2 and 3 and article 9 paragraph 4 of the Articles of

Association.

j) Any other case where the law or the Articles of Association require a special qualified quorum for a

decision by the General Assembly.

If the quorum of the previous paragraph is not reached in the first meeting, the General Assembly is

convened in a repeat session within twenty (20) days of the canceled session and after a notice at least

ten (10) full days before. In this case, the General Assembly is considered quorate and validly meets on

the matters of the original agenda when at least one-half (1/2) of the paid-up share capital is

represented. No new notice is required if the time and place of the repeat session were already

specified in the original notice, provided that there are at least five (5) days between the canceled

meeting and the repeat session.

All decisions on the above matters are made by a two-thirds (2/3) majority of the votes represented at

the General Assembly.

1.2 Convocation of the General Assembly

The General Assembly of the shareholders is convened by the Board of Directors and meets regularly

at the Company's headquarters at least once a year, no later than the tenth (10th) calendar day of the

ninth month following the end of the fiscal year, in order to decide on the approval of the annual

financial statements and the election of auditors. The General Assembly may also meet in the area of

another municipality within the jurisdiction of the headquarters, or in an adjacent municipality, or in

the jurisdiction of the municipality where the stock exchange headquarters is located.

According to article 120 paragraph 3 of Law 4548/2018, in the event of an important reason, the Board

of Directors may decide that the General Assembly will not meet in a physical location but will instead

be held entirely with shareholders participating remotely through electronic means. The General

Assembly may also be conducted in this manner if all shareholders consent.

The Board of Directors may convene an extraordinary meeting of the General Assembly when deemed

appropriate or necessary. The Board of Directors is obliged to convene the General Assembly following

a request from the Company’s regular auditor within ten (10) days of the submission of the request to

the Chairman of the Board of Directors, setting the agenda items as specified in the request.

1.3 Invitation – Agenda of the General Assembly – Shareholder Rights Prior to the General Assembly

The invitation to the General Assembly must include at least the venue with an exact address, the date

and time of the meeting, as well as the items on the agenda clearly stated, the shareholders entitled to

participate, precise instructions on how shareholders may participate in the Assembly and exercise

their rights either in person, by proxy, or potentially remotely, along with the information required

under article 121 paragraph 4 of Law 4548/2018.

The General Assembly is convened through the publication of a relevant invitation to the Company's

shareholders, in accordance with the provisions of article 27 of the Articles of Association and the

publicity rules outlined in articles 122 and 123 of Law 4548/2018.

The full text of the invitation, including the mandatory information specified in paragraphs 3 and 4 of

article 121 of Law 4548/2018, is published in a timely manner, at least twenty (20) full days prior to the

meeting, on the Company’s page on the General Commercial Registry (G.E.MI. –

www.businessportal.gr), on the Company’s website (www.eydap.gr), and is disclosed via the electronic

communication and disclosure system of the Athens Stock Exchange (ERMIS), in accordance with

articles 122 and 123 of Law 4548/2018. It is also published through other electronic or print media that

the Board of Directors reasonably considers reliable for the effective dissemination of information to

the investing public, ensuring prompt and non-discriminatory access.

Within the same twenty (20) day period, the invitation is also communicated to the competent Ministry,

in accordance with applicable legislation.

The Company may not impose any special charge on shareholders for the publication of the invitation

to convene the General Assembly via any of the above-mentioned methods.

Ten (10) days prior to the Regular General Assembly, the Company makes available to shareholders

through its website the annual financial statements, as well as the relevant reports of the Board of

Directors and the Auditors.

From the date of publication of the invitation to the General Assembly until the day of the Assembly,

the Company’s website hosts the information and documents specified in paragraphs 3 and 4 of article

123 of Law 4548/2018, as well as the information required under article 18 paragraph 1 of Law

4706/2020 regarding the candidates for the Board of Directors.

1.4 Participation in the General Assembly – Representation

Each share grants the right to one vote at the General Assembly.

Anyone recorded as a shareholder in the records of the Dematerialized Securities System (DSS),

managed by the “Hellenic Central Securities Depository S.A.” (a subsidiary of Hellenic Exchanges –

HELEX), in which the Company’s securities (shares) are registered, is entitled to participate in the

General Assembly.

Specifically, shareholder status must exist at the beginning of the fifth (5th) day prior to the date of the

General Assembly (record date). This record date also applies in the case of an adjourned or repeat

meeting, provided that the adjourned or repeat session is held within thirty (30) days from the original

record date. If this is not the case, or if a new invitation is published for the repeat General Assembly,

as provided under article 130 of Law 4548/2018, the person entitled to participate shall be the one

holding shareholder status at the beginning of the third (3rd) day prior to the date of the repeat or

adjourned General Assembly.

Proof of shareholder status may be provided by any lawful means and, in any case, based on

information received by the Company from the Central Securities Depository, as defined under Law

4659/2018. The exercise of such rights does not require the blocking of shares or the observance of any

other similar procedure that might restrict the sale or transfer of shares between the record date and

the date of the General Assembly.

By decision of the Company’s Board of Directors, participation in the General Assembly may be

permitted remotely via audiovisual or other electronic means, without physical presence at the venue,

by the shareholder or other persons entitled to attend according to the Articles of Association, as long

as it is not contrary to the Company’s interest. In such cases, the Company must ensure that:

● a) It can verify the identity of participants, allow only entitled persons to participate or attend

the Assembly, and ensure the security of the electronic connection;

● b) Participants can follow the meeting via electronic or audiovisual means, address the

Assembly verbally or in writing during the session from a distance, and vote on agenda items;

● c) The remote votes are accurately recorded.

The Board of Directors may also allow voting in advance by correspondence or electronic means before

the Assembly. Agenda items and ballot papers are made available and can be completed either

electronically via the internet or in printed form at the Company’s headquarters.

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Shareholders voting by correspondence or electronically are counted toward quorum and majority

calculations, provided their votes are received by the Company no later than twenty-four (24) hours

before the Assembly begins.

The Company encourages shareholder engagement and the submission of questions, ensuring the

presence at the General Assembly of any senior executive deemed necessary to provide further

information and clarification. If shareholder questions related to the agenda items are not answered

during the session, and the relevant information is not already available on the Company's website, the

Company will send the answers to the email addresses provided by the shareholders while ensuring

equal access to information for all shareholders. For optimal preparation of the Assembly, shareholders

may submit their questions in advance in writing to the Shareholder and Corporate Announcements

Service via email at eydap-met@eydap.gr.

Shareholders may participate and vote in the General Assembly either in person or through proxies.

Each shareholder may appoint up to three (3) proxies. Legal entities participate via their legal

representatives. If a shareholder holds shares appearing in more than one securities account, this

restriction does not prevent them from appointing different proxies for the shares in each account. A

proxy acting for multiple shareholders may vote differently for each shareholder. A proxy must disclose

to the Company, before the General Assembly begins, any specific event that could be useful to

shareholders in assessing the risk of the proxy serving interests other than those of the shareholder

they represent.

The appointment, revocation, or replacement of a representative or proxy must be made in writing or

electronically, such as by email, and must be submitted to the Company at least forty-eight (48) hours

prior to the scheduled Assembly. The Company provides on its website a proxy form that shareholders

must use, also available from the Shareholder and Corporate Announcements Service (156 Oropos

Street, Galatsi).

Failure to comply with the deadline for appointment, revocation, or replacement of a proxy does not

prevent the shareholder from participating in the General Assembly, unless the Assembly refuses

participation for a valid and justified reason.

1.5 Minority Shareholders’ Rights

The rights of minority shareholders and the manner in which they may be exercised are defined by the

applicable legislation, specifically by the provisions of Law 4548/2018, particularly articles 141, 142, and

144, as well as article 35 of the Company's Articles of Association.

1.6 Resolutions of the General Assembly of EYDAP Shareholders on Significant Matters Adopted in

2024

Beyond the standard agenda items of the Ordinary General Assembly—such as the approval of the

annual financial statements, the election of the statutory auditor, the approval of the Board of

Directors’ Remuneration Report, etc.—the Ordinary General Assembly of the Company’s Shareholders

in 2024, among others:

● Approved the distribution of dividends from the 2023 fiscal year profits, amounting to

€10,650,000, i.e., a gross dividend of €0.10 per share.

● Approved the amendment of the Articles of Association of EYDAP S.A., primarily aiming to

align its provisions with the new legislative and regulatory framework governing EYDAP S.A.,

in particular Laws 5037/2023 (Gov. Gazette A’ 78), 5045/2023 (Gov. Gazette A’ 136), and

5106/2024 (Gov. Gazette A’ 63).

● Approved the revision of the Remuneration Policy.

● Approved the revision of the Nomination Policy.

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Additionally, the Audit Committee’s Annual Activity Report for the year 2023 and the Report of the

Independent Non-Executive Members of the Board of Directors of EYDAP S.A. were submitted to the

General Assembly, in accordance with article 9, paragraph 5 of Law 4706/2020.

All obligations arising from applicable legislation and the Company’s Articles of Association were strictly

observed during the convening and preparation of the General Assembly meeting held in 2024.

F. Internal Control System

The Company adopts and implements a corporate governance system in accordance with applicable

legislation, taking into account the size, nature, scope, and complexity of its activities. The corporate

governance system includes, among other elements, an adequate and effective Internal Control System

(ICS).

The Internal Control System (ICS) is defined as the set of internal control mechanisms and procedures—

including risk management, internal audit, and regulatory compliance—that continuously covers all

activities of the Company and contributes to its secure and effective operation.

The Company applies an ICS that covers its operations and supports safe and efficient functionality. This

system is based on the internationally recognized COSO framework and consists of five (5) fundamental

components:

● Control Environment

● Risk Management

● Control Activities and Safeguards

● Information & Communication

● Monitoring

The design and monitoring of the ICS structure are based on the Three Lines Model, which provides a

structured approach to risk management and internal control, clearly defining roles, responsibilities,

and their relationships.

First Line: Operational units or individuals whose activities are directly related to service provision to

customers. They are risk owners and managers. This line directs activities (including risk management),

utilizes corporate resources to achieve goals, and reports business outcomes and operational risks to

the Board. It is also responsible for establishing and maintaining appropriate internal structures and

processes, including those related to the ICS.

Second Line: Units or individuals specializing in risk management, responsible for monitoring and

controlling risks and addressing challenges related to the Company's operations. This includes, in

particular, the Risk Management Department and the Compliance Department, which:

● Develop, implement, and continuously improve risk management practices

(including the ICS) at the enterprise, process, and systems level.

● Aim to meet risk management objectives, including regulatory compliance,

adherence to ethical standards, internal safeguards, information and technology

security, sustainability, and quality assurance.

The Second Line provides detailed information and reports to the Management and the Board

regarding the adequacy and effectiveness of risk management, including safeguards.

Third Line: The Internal Audit Unit, which is responsible for independently informing the Audit

Committee and the Board on the adequacy and effectiveness of the ICS. It maintains independence

from Management and offers assurance and consulting services regarding corporate governance, risk

management, and internal control. It also supports the achievement of corporate objectives and

promotes continuous improvement.

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Additionally, external assurance providers complement the Three Lines Model by offering independent

assurance on compliance with legal and regulatory expectations, thus protecting the Company’s

interests.

Internal Control Activities in 2024

● The Board of Directors set the corporate goals for 2024, focusing on the strategic of Security

– Efficiency – Growth, and reviewed the key business risks and the ICS.

● The Audit Committee informed the Board about the adequacy, quality, and effectiveness of

the ICS as part of its quarterly reporting on its activities.

Evaluation of the Internal Control System and Corporate Governance System

In March 2023, the evaluation of the adequacy and effectiveness of EYDAP's Internal Control System

(ICS) was completed, with a reference date of 31/12/2022 and a review period from 17/07/2021 to

31/12/2022, in accordance with article 14, paragraph 3(i) and paragraph 4 of Law 4706/2020, and the

Decision 1/891/30.09.2020 of the Capital Market Commission, as amended by Decision

2/917/17.06.2021.

The evaluation was conducted by Grant Thornton S.A. Certified Public Accountants & Business

Consultants, in accordance with ISAE 3000 (International Standard on Assurance Engagements –

Assurance other than Audits or Reviews of Historical Financial Information), and based on the

regulatory framework as defined by the ELTE decision 227/10-11-2022.

The above evaluation of the Internal Control System (ICS) encompassed the following components: the

Control Environment, Risk Management, Control Mechanisms and Safeguards, the Information and

Communication System, as well as the Monitoring processes related to the ICS of the Company.

The conclusion of the Independent Assessor, Ms. Athina Moustaki, Certified Public Accountant (Reg.

No. 28871) and Partner at Grant Thornton, as stated in the final evaluation report dated 29 March 2023,

was that based on the procedures performed and the evidence obtained regarding the assessment of

the adequacy and effectiveness of the Company’s Internal Control System, no deficiencies were

identified that could be considered material under the applicable regulatory framework, with the sole

exception of the issue concerning the insufficient gender representation on the Board of Directors.

Specifically, the proportion of female members on the Board stood at 2 out of 13, which is below the

statutory requirement of 25% for adequate gender representation.

As previously mentioned in Section D, the Company addressed this non-compliance on 12 September

2023, through the election of new Board members by its majority shareholder, namely the Hellenic

Republic.

The Board of Directors of EYDAP, within the framework of its obligations arising from the provisions of

paragraph 1 of article 4 of Law 4706/2020 and taking into account paragraph 1 of article 13 of Law

4706/2020, as well as the letter No. 604/5.3.2024 from the Hellenic Capital Market Commission, is

responsible for the evaluation of the Corporate Governance System.

In this context, the Board of Directors of EYDAP assigned the task of evaluating the adequacy and

effectiveness of the Corporate Governance System (CGS) for the reference period 17.07.2021 -

31.12.2024 to Grant Thornton S.A., Certified Public Accountants Business Consultants.

The evaluation was conducted based on the assurance engagement procedures program included in

decision I΄73/08β/14.02.2024 of the Oversight Board of the Body of Certified Public Accountants, in

accordance with the International Standard on Assurance Engagements 3000 (Revised), "Assurance

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Engagements Other than Audits or Reviews of Historical Financial Information", and took into

consideration the results of the Internal Control System evaluation.

According to the conclusion of the Independent Evaluator, namely Ms. Athina Moustaki, Certified Public

Accountant with registration number 28871 and Partner at Grant Thornton, which is included in the

final evaluation report on the adequacy and effectiveness of the CGS dated 22/04/2025, no deficiencies

were identified during the work performed and based on the evidence obtained that could be

considered material in the Company’s CGS.

I. Regulatory Compliance Management System

The Company’s compliance with the applicable legal and regulatory provisions constitutes a

fundamental obligation and a key priority. Ensuring compliance with laws and regulations, along with

zero tolerance for conflicts of interest, corruption, and bribery, reflects the Company’s unwavering

commitment to the principles of integrity, transparency, fairness, professionalism, teamwork, and

respect.

In this context, EYDAP, as a public limited company with shares listed on a regulated market, complies

with the applicable corporate governance legislation by integrating Regulations and Policies into its

operations.

The primary mission of Regulatory Compliance is the establishment and implementation of appropriate

and up-to-date Policies and Procedures, aiming to ensure timely, full, and ongoing compliance with the

current regulatory framework.

By Board of Directors decision No. 21202/21.12.2022, the applied Regulatory Compliance Management

System was approved. This system concerns the compliance of the Company’s personnel, management,

and partners with the applicable regulatory and legal framework, as well as with the Operating

Regulation, the Code of Ethics and Professional Conduct, and the Policies and Procedures governing the

Company’s operations. Its purpose is to prevent, detect, and avoid non-compliance risks and other legal

implications for the Company. In the same decision, the Regulatory Compliance Policy was also

approved, aiming to establish principles and rules incorporated into the Company’s Policies and Codes,

ensuring effective management of all types of regulatory compliance risks and promoting a compliance

"culture" as a standard of corporate conduct.

Within this framework, by Board of Directors decision No. 21269/22.3.2023, it was decided to

separate the Risk and Regulatory Compliance Management Directorate into:

a) Risk Management Directorate, reporting to the Risk Management Committee, and

b) Regulatory Compliance Directorate, reporting to the Regulatory Compliance Committee.

The operation of the Regulatory Compliance Directorate is governed by the Operating Regulation

approved by Board of Directors decision No. 21863/24.7.2024.

The Regulatory Compliance Directorate is responsible for designing and implementing the Regulatory

Compliance Management System, while its effectiveness and adequacy are overseen by the Regulatory

Compliance Committee, the Audit Committee, and the Board of Directors. Annually, the Regulatory

Compliance Directorate drafts a Compliance Plan, which is approved by Board decision. The 2025

Annual Action Plan was approved by Board decision No. 21904/12.2.2025. The same decision also

approved the Annual Audit Plan of the Regulatory Compliance Directorate.

A core pillar of the Regulatory Compliance Management System is the prevention of non-compliance

incidents, which is achieved especially through:

a) the development of compliance Policies and Procedures,

b) employee training,

c) personal guidance to employees to enable them to raise questions related to the application of legal

and regulatory provisions,

d) evaluation of compliance risks.

104

During the 2024 fiscal year, the necessary policies and regulations were developed or updated to

strengthen the Regulatory Compliance Management System. Specifically:

● Update of the Remuneration Policy (Decision of the 42nd Annual General Meeting – 11.7.2024)

● Update of the Board of Directors Members Nomination Policy (Decision of the 42nd AGM –

11.7.2024)

● Establishment of the Regulatory Compliance Committee Operating Regulation (Decision

21863/24.7.2024)

● Establishment of the Regulatory Compliance Directorate Operating Regulation (Decision

21863/24.7.2024)

● Establishment of the Personal Data Breach Management Policy (Board decision

21862/24.7.2024)

● Update of the Remuneration and Nomination Committee Operating Regulation (Board

decision 21894/11.12.2024)

Throughout the 2024 fiscal year, the Regulatory Compliance Directorate, in collaboration with the Legal

Services Directorate and the Human Resources Training Directorate, ensured employee education

through seminars focused on understanding and applying the Company’s adopted Policies and

Procedures, with the goal of fostering a "compliance culture." Indicative training included sessions on

the implementation of the Code of Ethics and Professional Conduct, the Conflict of Interest Policy, and

the Policy for the Prevention and Combating of Violence and Harassment at Work.

Beyond preventive measures, the Regulatory Compliance Directorate identifies violations related to

compliance issues and conflicts of interest, and proposes management actions and other corrective

measures. Within this framework, the Company implements a Whistleblowing Policy to allow

employees and/or third parties (e.g. clients, suppliers, partners, etc.) to report (anonymously or not)

instances of misconduct or violations of the legal and regulatory framework via communication

channels available on the corporate website.

As part of EYDAP’s continuous training and development of its employees, during the 2024 fiscal year,

executives of the Regulatory Compliance Directorate attended seminars by reputable institutions on

the identification and assessment of regulatory risks.

II. Risk Management System

EYDAP operates under the principles of corporate governance, in accordance with the requirements of

its institutional and regulatory framework.

A key component of the Internal Control System developed and implemented by the Company is the

Risk Management Directorate, whose primary role is to support EYDAP’s Management and Board of

Directors in managing risks to achieve the Company’s business objectives.

The Risk Management Directorate is independent and functions as a distinct organizational unit of the

Company. It reports to the Risk Management Committee and operates in accordance with its

Regulations, which were approved by the Board of Directors with decision No. 21282/5.4.2023.

EYDAP manages its business risks through processes of identifying, assessing, managing, and monitoring

potential events or conditions to provide reasonable assurance regarding the achievement of its

business objectives, in line with the COSO Enterprise Risk Management (ERM) Framework. Business risk

management is an integral part of strategic planning and is implemented by the Company’s Board of

Directors, Management, and staff.

Business risk management takes into account threats, opportunities, and uncertainties that may affect

EYDAP’s strategic goals and operational continuity. The objective is the timely identification and

quantification of risks, along with the development and prioritization of corrective actions for their

mitigation. Within this framework, business risks are classified into types and categories in the risk

105

Operational Risks

● O1 – Infrastructure of facilities and networks

● O2 – Crisis Management due to natural disasters and external factors

● O3 – Sales & Service Development

● O4 – Water Supply and Distribution

● O5 – Procurement and Management of External Partners

● O6 – Water and Waste Management Quality

● O7 – Human Resources Management

● O8 – Information Systems Infrastructure and Architecture

● O9 – Cybersecurity and Data Management

Financial Risks

● F1 – Market and Pricing Risks

● F2 – Capital Structure (cost of capital)

● F3 – Liquidity Management

● F4 – Credit and Collection Policy (credit risk)

● F5 – Financial Reporting

● F6 – Management Reporting and Internal Reports

● F7 – Taxation

Compliance Risks

● C1 – Code of Ethics / Fraud

● C2 – Labor Issues

● C3 – Personal Data Protection

● C4 – Health & Safety Framework

● C5 – Environmental Compliance

Strategic Risks

● S1 – Governance Structures

● S2 – Governance Structures (appears repeated in the original)

● S3 – Communication

● S4 – Planning and Resource Allocation

● S5 – Macroeconomic, Socio-political and Institutional Factors

● S6 – Climate Change Management

The goal of business risk management is to add value across the Company through risk assessment and

management activities that enable EYDAP to identify, prioritize, and evaluate its business risks. These

activities result in the creation of a risk profile, enabling the Company to align and direct resources

toward the most significant risks.

EYDAP has set the following objectives for its business risk management:

● Timely identification and management of risks

● Rationalization and optimization of risk management costs

● Implementation of conscious and well-documented risk management choices

● Improvement of the Company’s overall performance by focusing on predictable outcomes

In this context, EYDAP has established a Risk Management Policy, which outlines its approach to

defining the framework for managing business risks. This Policy was updated by Board decision No.

21948/12.3.2025.

EYDAP has defined its risk appetite and risk tolerance through a Risk Appetite Framework, based on its

objectives and the quantitative indicators approved by the Board for monitoring business performance.

The Risk Appetite Framework was approved by the Board of Directors through decision No.

21877/11.9.2024 (Corrected Version 7.10.2024), and it serves as the critical link between strategy

formulation and actual performance. This framework defines a shared understanding of corporate risk

106

limits and is communicated across the organization. It confirms EYDAP’s commitment to pursuing its

objectives within clearly defined risk boundaries or zero-tolerance thresholds.

It contributes to corporate governance by:

● Achieving business goals

● Protecting and creating added value for the company

● Strengthening relationships with stakeholders

To fulfill its responsibility for developing and implementing a comprehensive risk framework across all

Company operations, the Risk Management Directorate has developed a Risk Management Framework

aligned with its Operating Regulations and the approved Risk Management Policy.

The development of this framework is based on principles and best practices from the COSO ERM

methodology and the international standard ISO 31000, as referenced in the Company’s Risk

Management Policy.

These procedures describe approaches for identifying, assessing, monitoring, mitigating, and reporting

risks, within the responsibilities of the Risk Management Directorate.

Procedures for Risk Event Collection and Emergency Risk Event Management provide reasonable

assurance in achieving business objectives by monitoring and evaluating the impact of such events on

business risks.

Emerging Risk Management aims at the early identification of risks with the goal of enhancing the

Company’s resilience and adaptability in achieving its strategic and operational objectives.

To keep the business risk register up to date, the Risk Management Directorate monitors the external

environment, international risk trends, the legal and regulatory framework, and developments in the

Company’s business activities. Special attention has been given to protection against cybersecurity

threats, climate crisis risks, AI application risks, regulatory requirements, accountability obligations, etc.

During 2024, the Risk Management Directorate developed a methodology for evaluating business risks

to determine the Company’s high-level risks in conjunction with assessments from organizational units.

To strengthen corporate resilience, a stress-test simulation exercise was organized, and emergency

plans were developed for high-risk scenarios identified from the simulation findings.

A strategic crisis management plan was developed to address threats to business continuity.

The Risk Management Directorate monitors the Company’s high-priority risks, which include:

● Water scarcity

● Insecure water supply to Attica due to failures in the External Water Supply System

● Understaffing of organizational units

● Enhancing the resilience of Company facilities and infrastructure against climate change risks

● Aging or problematic water supply and sewerage networks

● Cybersecurity

III. Internal Audit Department

The Internal Audit Department is an independent organizational unit whose purpose is to monitor and

submit proposals for the improvement of the Company’s operations and policies regarding its Internal

Control System, thus supporting the Board of Directors and the Company’s Management in enhancing

corporate value, achieving corporate objectives, and protecting its financial resources, reputation, and

sustainability. The Internal Audit Department is functionally overseen by the Audit Committee,

maintaining its independence, and has the primary responsibility for informing the Audit Committee

and the Board of Directors about the adequacy and effectiveness of the Internal Control System.

Administratively, it reports to the CEO.

In its supervisory role, the Audit Committee exercises the responsibilities defined by applicable law and

the Internal Regulations.

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The Internal Audit Department operates according to its Operational Regulations, which are approved

by the Board of Directors and updated periodically, in compliance with the relevant laws governing

internal audits and the internal audit profession, the Code of Ethics for Internal Auditors, the

International Professional Practices Framework for Internal Auditing (as updated by the Institute of

Internal Auditors), and its Strategic Plan, which aligns with the company’s strategic priorities. The

Department’s operations are described in detail in its Operational Regulations and its Procedures

Manual.

The Internal Audit Department is the only internal audit unit in Greece certified under ISO 9001: 2015,

as well as the Business Ethics RME model by the EBEN Institute, a member of the European Network of

Business Ethics. During the International Conference of the European Business Ethics Network in May

2024, the Internal Audit Department was awarded the OLYMPIC KYNISKAS WEARTH for its high score

in meeting business ethics criteria.

To provide high-quality services in accordance with Internal Audit Standards, the Internal Audit

Department has designed and implemented a quality assurance and continuous improvement program

that covers its activities. This program includes periodic external (external quality assessments) and

internal assessments (internal quality assessments), performance indicators, and continuous

monitoring processes. It evaluates compliance with Internal Audit Standards and the Code of Ethics for

Internal Auditors, identifying areas for improvement. Internal assessments are carried out at least

annually by experienced internal audit staff, while external assessments are conducted by recognized

Consultants – Certified Internal Auditors, at least every five years, in line with International Standards

for Professional Practice of Internal Auditing, as defined by the Institute of Internal Auditors. The

Internal Audit Department of EYDAP has innovated by successfully combining and implementing the

requirements of two distinct quality systems (ISO and Global Internal Audit Standards).

The head of the Internal Audit Department is appointed by the Company’s Board of Directors upon the

Audit Committee’s recommendation. This position is full-time and exclusive, ensuring the individual’s

personal and operational independence and objectivity in carrying out their duties. The head must hold

the necessary legal professional license, a master’s degree, the CIA professional certification, and other

relevant certifications, along with the appropriate professional experience. The head of the Internal

Audit Department cannot be a member of the Board of Directors or a member with voting rights in any

permanent committees of the Company, nor can they have close ties to anyone holding such positions

in the Company or in a Group company.

The scope of the audit environment covers all activities of EYDAP S.A. and EYDAP DEVELOPMENT. Audits

are conducted based on a risk assessment, covering financial, performance-operational, compliance,

corporate governance, technical, information systems, personal data, culture and values, etc. The audit

plan is approved by the Board of Directors at the beginning of each year and updated semi-annually as

needed. During the audits, emphasis is placed on using modern auditing techniques and technological

tools. For the past three years, a successful open data platform has been used in corporate governance

audits, and since the second half of 2024, software has been installed and effectively used for audit

processes, automating and significantly strengthening the auditing procedures.

For the better organization of the Internal Audit function and due to the broad scope of the activities

of EYDAP, internal auditors are divided into three departments based on their specialty: financial

auditing and corporate governance auditing, technical auditing, and information systems auditing. All

auditors of the Department are university graduates, registered in the Registers of Auditors of the

Economic Chamber of Greece, and hold various recognized certifications in internal auditing, risk

management, regulatory compliance, auditing, system auditing, etc. (CIA, COSO, CICA, QAC, FCCA, CPA,

EKDDA, CRCO, ICFI, CPIA, CCS). Additionally, many of them have postgraduate and doctoral degrees.

EYDAP actively supports the continuous professional development of its Internal Audit Department

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staff. At the same time, its staff actively participates in professional bodies, conferences, and seminars

related to internal auditing, risk management, and corporate governance.

As defined by current legislation, the Internal Audit Department has the following indicative

responsibilities:

● It monitors, audits, and evaluates: the implementation of the Operating Regulation and the

Internal Control System, particularly regarding the adequacy and correctness of the financial

and non-financial information provided, risk management, regulatory compliance, and the

Corporate Governance Code adopted by the Company, quality assurance mechanisms, and

corporate governance mechanisms.

● It audits the compliance with the commitments outlined in the company's prospectuses and

business plans concerning the use of funds raised from the regulated market.

● It monitors, audits, and evaluates the company's compliance with the obligations arising from

corporate governance legislation and decisions of the Capital Markets Commission.

● It audits the legality of the remuneration and all kinds of benefits provided to the members of

the Board of Directors, based on the decisions of the competent bodies of the Company and

the approved Remuneration Policy of the company, and prepares relevant reports which are

communicated to the Remuneration and Nominations Committee.

● It audits the relationships and transactions of the Company with affiliated companies, in the

sense of the current legal framework and IFRS.

● It audits the confidentiality, as well as the proper disclosure of events such as: decisions

regarding substantial changes in business activity, decisions or agreements for entering into or

dissolving partnerships or business alliances, and for any significant international initiative,

decisions to submit a public offer, as well as ensuring the application of conditions for pre-

announcements of transactions by specific individuals (e.g., members of the Board of

Directors, certified auditors).

● It audits the company's information systems, including, but not limited to, the development of

information systems, changes in information systems, security, and authorized access to

systems, daily operations of the systems, and meeting user needs, ensuring business

continuity, and system recovery in the event of a crisis or disaster.

● In addition to scheduled audits, it conducts ad hoc audits at the request of the Audit

Committee, the Board of Directors, the CEO, and the Chairman of the Board of Directors,

always with the Audit Committee's approval for any changes to the Annual Audit Plan.

● It continuously monitors – via a special information system and, where appropriate, with

follow-up audits, research, and data collection – the progress of corrective actions to address

weaknesses or issues identified in previous audits and reports them to the Board of Directors.

The Internal Audit Department performs its responsibilities by conducting audits and

submitting reports to the audited units of the Company with any findings, associated risks, and

suggestions for improvement. The final reports, after incorporating the relevant comments

from the audited units, any agreed actions, or acceptance of the risk of non-action by them,

any limitations on the audit scope, the final suggestions from internal auditing, and the results

of the audited units' response to these proposals, are immediately submitted upon completion

to the Management (CEO, Chairman of the Board of Directors), the Audit Committee, and the

audited units, and at least quarterly to the Board of Directors.

The Internal Audit Department submits, upon completion, the final audit reports, and at least every

three (3) months, reports to the Audit Committee, which include the most significant issues and

proposals regarding the audits conducted. The Audit Committee presents and submits these, along with

the final audit reports and its observations, to the Board of Directors. Once a year, the Internal Audit

Department submits to the Audit Committee its Annual Report, which includes an overall opinion on

the company's Internal Control System.

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IV. Main Characteristics of Collective Bargaining Agreements (CBA) and Risk Management in Relation

to the Process of Preparing Financial Statements and the Reliability of Related Information

Process of Preparing the Statements

The assurance of the reliability of the Company's financial statements, in addition to the above

safeguards at the corporate level, is achieved through the application of a specific process for preparing

financial information. The Company prepares quarterly financial statements, interim and annual

reports. Specifically, on a quarterly basis, the Financial Services Department prepares the financial

statements, and the Financial Analysis and Investor Relations Department processes the financial data

and information, checks, and issues reports to the Company's Management. These reports are

produced in accordance with International Financial Reporting Standards. The Company's Management

is informed every quarter about the progress of the key corporate financial metrics through

management reports. Monitoring, auditing the financial statements, and performing analyses on them

are fundamental tools for controlling the quality and consistency of financial results. The Financial

Services and Financial Analysis and Investor Relations Departments provide the necessary information

to the Certified Auditors as well as to the Company’s Management. The Certified Auditors examine the

interim and annual consolidated financial statements and inform the Audit Committee about the

progress and results of the mandatory audit. The Audit Committee is kept informed about the process

and the schedule for preparing the financial statements by the Company’s Director of Financial

Activities and holds meetings with the Management/competent Senior Executives during the

preparation of the financial reports, as well as with the Certified Auditors during the planning stage of

the audit. During these meetings, the Audit Committee is also informed about the management of

financial risks and examines the effectiveness of the risk management system. If an issue arises about

which the Certified Auditors express significant concerns, the Audit Committee informs the Board of

Directors. The Audit Committee reviews the semi-annual and annual financial statements and the

accompanying reports to evaluate their completeness and consistency with the information presented

to it, as well as with the accounting principles applied by the Company, and recommends their approval

to the Board of Directors.

Asset Protection

The Company has developed and applies safeguards for its fixed assets, inventories, cash/assets, and

other company assets, such as, for example, physical security of warehouses and cash registers at

Regional Customer Service Centers, inventory counting and reconciliation of the counted quantities

with those in the accounting books, adequate asset security, and more. In this regard, the Company has

established relevant policies and procedures to define key principles and ensure their uniform

adherence by all relevant departments of the Company, such as, for example, the Operating Regulation

for Cash Registers at Regional Centers, the Video Surveillance (CCTV) Policy, the Fixed Asset

Management Policy, the Liquidation Regulation, etc.

To protect its financial position, the Company has insurance contracts for its employees and fixed assets

(such as group life and health insurance for employees, third-party liability insurance, all-risk asset

insurance, executive liability insurance, etc.) to mitigate related risks. These are monitored by the

Insurance Management and Risk Department, which works in cooperation with all relevant

departments.

Framework for Investment Policy of Cash Reserves

The Company, by the decision of the Board of Directors No. 18722/11.11.2015, as amended by the

decision No. 19078/30.11.2016, approved its Investment Policy Framework for Managing Cash

Reserves. The Financial Services Department regularly reviews or, when necessary, assesses the current

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cash liquidity and the possibilities for investing the Company’s available funds within the framework of

the Investment Policy and makes recommendations to the Director of Financial Activities for their

investment, which is implemented upon the approval of the Chief Executive Officer. The Financial

Services Department informs the Board of Directors every two months about its activities and decisions.

Authority Limits for Conducting Transactions

The powers delegated by the Board of Directors to various company executives for conducting specific

transactions or actions (e.g., collection, payment, purchase or sale of securities, entering into

agreements related to financial transactions) are designed to exercise rights in pairs, depending on the

financial nature of the transactions.

Security, Sufficiency, and Reliability of Information Systems

A large part of the Company’s operations is based on its information systems. Therefore, it is exposed

to risks such as unavailability, data integrity issues, power outages, malicious cyberattacks, and

unauthorized access to these systems. To reduce these risks, the Company takes measures to enhance

the security of its information systems, such as the establishment and continuous update of relevant

policies and standards (e.g., Information Security Policy) and covering IT systems with maintenance

contracts. Each information system is designed and operates in accordance with the Information

Security Policy, as approved by the Board of Directors Decision No. 20865/21.4.2021, and in compliance

with the applicable legislation for personal data security. For each information system, the users who

have access to it and the levels of user rights are defined.

Selection of External Auditors

According to its Operating Regulation, the Audit Committee is responsible for the process of selecting

external auditors or auditing firms and recommends the auditors or auditing firms to be elected in

accordance with Article 16 of Regulation (EU) No. 537/2014. It sets the criteria for selecting external

auditors, technical specifications, and issues of independence and conflicts of interest of candidates.

After reviewing the submitted candidacies in terms of the technical and financial aspects of their offers,

as well as issues of independence and conflicts of interest, the Audit Committee submits a proposal to

the Board of Directors regarding the appointment, reappointment, and dismissal of external auditors

and the approval of their fees. The Audit Committee's proposal, once approved by the Board, is

submitted for approval at the General Assembly. The Audit Committee reviews the engagement

contract with the elected external auditors before signing. Additionally, the Audit Committee examines

and monitors the independence of external auditors, the objectivity and effectiveness of the audit

process, taking into account the relevant professional and regulatory requirements.

Z. Information According to Cases (c), (d), (e), (z), and (h) of Article 4 Paragraph 7 of Law 3556/2007

All the information of Article 4 Paragraph 7 of Law 3556/2007 is included, in accordance with Articles 4

Paragraphs 7-8 of Law 3556/2007, in a special Explanatory Report, which is presented immediately

below.

EXPLANATORY REPORT

In accordance with Article 4 Paragraphs 7-8 of Law 3556/2007, the Company publishes detailed

information regarding the following matters:

1.Share Capital Structure

The 39th Annual General Meeting of the shareholders of EYDAP S.A., held on 25.06.2021, decided:

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A) The increase of the share capital through the capitalization of part of the reserve from the amount

of €24,495,000, with an increase in the nominal value of each share by €0.23, i.e., from €0.60 to €0.83.

Thus, the share capital of the Company amounted to eighty-eight million three hundred ninety-five

thousand euros (€88,395,000), divided into one hundred six million five hundred thousand shares

(106,500,000), each with a nominal value of €0.83.

B) The simultaneous reduction of the share capital by €24,495,000, with a corresponding reduction in

the nominal value of each share by €0.23, i.e., a change in the nominal value of each share to €0.60.

Thus, the share capital of the Company today amounts to sixty-three million nine hundred thousand

euros (€63,900,000), divided into one hundred six million five hundred thousand shares (106,500,000),

each with a nominal value of €0.60.

On 03.08.2021, the decision with Registration Number 2595919 was recorded in the General

Commercial Registry, which approved the modification of the share capital article in the Company’s

Articles of Association (Decision No. 87621/03.08.2021, issued by the General Secretariat for

Commerce and Consumer Protection of the Ministry of Development and Investments). The Corporate

Transactions Committee of the Athens Stock Exchange was informed of the aforementioned changes

to the Company’s share capital on 26 August 2021.

All shares of the Company are common nominal shares with voting rights, and there are no special

classes of shares. Each share incorporates all the rights and obligations arising from Law 4548/2018

(hereinafter referred to as the Law) and the Company’s Articles of Association. The Company’s shares

are listed for trading on the Athens Stock Exchange.

Ownership of each share automatically implies acceptance by the owner of the terms of the Company’s

Articles of Association and the legal decisions made by the General Meetings of Shareholders, even if

the shareholders did not attend these meetings. The liability of shareholders is limited to the nominal

value of the shares they hold. Shareholders participate in the management and profits of the Company

in accordance with the Law and the provisions of the Articles of Association.

2. Restrictions on the Transfer of Shares of the Company

The shares of the Company are dematerialized, freely tradable on the Athens Stock Exchange, and their

transfer is conducted as prescribed by law. There are no restrictions on their transfer arising from the

Articles of Association or from the special legal framework governing its operation (Law 1068/1980,

2744/1999). However, according to decisions No. 1906/2014 and 190/2022 of the plenary session of

the Council of State (StE), "the alienation of the Greek State's majority shareholding in EYDAP S.A.,

whose retention is necessary to prevent the public enterprise from becoming private, constitutes a

violation of Articles 5 Paragraph 5 and 21 Paragraph 3 of the Constitution." Therefore, the majority of

the shares of EYDAP S.A., i.e., 50% +1 share, must be owned by the Greek State. Under Article 64 of Law

5045/2023, the entire shareholding of the Hellenic Company for Holdings and Property (EESYP S.A.)

(53,250,001 shares) was transferred to the Greek State.

3. Significant Direct or Indirect Shareholdings under Articles 9 to 11 of Law 3556/2007

The significant direct and indirect shareholdings of individuals (natural and legal persons) in the total

voting rights of the Company, as defined by Articles 9 to 11 of Law 3556/2007, which were known to

the Company as of December 31, 2024, are presented below:

a) On March 2, 2018, EYDAP was notified by the Ministry of Finance that the total number of voting

rights (direct and indirect) controlled by the Greek State amounts to 65,319,740 (61.33%), of which the

direct voting rights concern 53,250,001 (50% +1 share) common registered shares and the indirect

voting rights concern 12,069,739 (11.33%) common registered shares. This change in the direct and

indirect shareholding of the Greek State in EYDAP S.A. is due to the transfer of 17,004,761 shares

(15.97%) from the Hellenic Republic Asset Development Fund (HRADF) directly to the Greek State,

following an off-market transaction, without compensation, as per Decision 262 of the Interministerial

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Committee for Restructurings and Privatizations (Official Government Gazette (FEK) B/614/22.02.2018)

and the correction of an error on 1.3.2018 (FEK B 697/01.03.2018), which partially revoked Decision

195/27.10.2011 (FEK B’ 759) of the Interministerial Committee for Restructurings and Privatizations, in

compliance with the Council of State's Decision 1906/2014.

The total shareholding percentage (direct and indirect) of the Greek State did not change.

b) On March 21, 2018, the Company received a related notification from the Ministry of Finance,

according to which the total number of indirect voting rights controlled by the Greek State amounts to

65,319,740 (61.33%). This change in the voting rights was due to the transfer, following an off-market

transaction, without compensation, dated March 20, 2018, from the Greek State to the "Hellenic

Company for Holdings and Property S.A." (EESYP S.A.) of 53,250,001 shares in EYDAP S.A., pursuant to

paragraph 20 of Article 380 of Law 4512/2018, which amended paragraph 1 of Article 197 of Law

4389/2016, effective from 01.01.2018.

100% of HRADF's shares are held by the "Hellenic Company for Holdings and Property S.A." (EESYP S.A.),

which directly controls the voting rights of 53,250,001 shares (50% + 1 share) and indirectly controls

the voting rights of 12,069,739 shares (11.33%) through HRADF. Therefore, the total percentage of

voting rights (direct and indirect) of EESYP S.A. amounted to 61.33%. The Greek State fully controls

EESYP S.A.

c) Following the Council of State's Decision 190/2022 and the decision of the Compliance Council (Case

No. 7/2023), Law 5045/2023 was issued (Official Government Gazette 136 A/29.7.2023), under which

Article 64 transferred all of the shares owned by EESYP S.A. (53,250,001 shares) to the Greek State,

automatically and without compensation. On August 3, 2023, the Ministry of Finance notified the

Company of the total percentage of voting rights (both direct and indirect) controlled by the Greek

State. According to this notification, the total number of shares owned by the Greek State amounts to

65,319,740 (61.33%), of which the direct voting rights concern 53,250,001 common registered shares

(50% +1 share) and the indirect voting rights concern 12,069,739 (11.33%) common registered shares.

The voting rights of the 12,069,739 common registered shares (11.33%) relate to the percentage of

share capital directly held by HRADF in EYDAP S.A.

d) On January 20, 2025, the Ministry of National Economy and Finance announced the merger by

absorption of the company "Public Private Property Exploitation Fund S.A." (TAIPED), which directly

held 11.33% of the share capital and voting rights of EYDAP, by the company "Hellenic Company for

Holdings and Property S.A." (EESYP S.A.), according to Articles 188A and 188B of Law 4389/2016, as

added by Articles 5 and 6 of Law 5131/2024 (Official Government Gazette A’ 128/02-08-2024), the

provisions of Law 4601/2019 as applicable, and the merger agreement of December 23, 2024 (Official

Government Gazette B’ 7093/24-12-2024), which was registered in the General Commercial Register

(G.E.MI) on December 31, 2024.

Following the merger, the 11.33% shareholding and voting rights of EYDAP previously held directly by

"Public Private Property Exploitation Fund S.A." (TAIPED) were transferred to "Hellenic Company for

Holdings and Property S.A." (EESYP S.A.) on December 31, 2024. The Greek State is the sole shareholder

(100%) of "Hellenic Company for Holdings and Property S.A.", which was also the sole shareholder

(100%) of "Public Private Property Exploitation Fund S.A." until December 31, 2024, which directly held

11.33% of the share capital and voting rights of EYDAP. The total percentage of the share capital and

voting rights (direct and indirect) of EYDAP controlled by the Greek State (61.33%) remains unchanged.

e) In May 2014, the investment management company “Paulson & Co. Inc.” notified the possession of

10,648,800 shares, or a 9.99% stake in the total voting rights of the Company as of April 30, 2014. The

company is controlled by Mr. John Paulson. No change in this shareholding has been reported up to the

publication date of this report.

f) From January 1, 2024, to December 31, 2024, no further significant changes occurred in direct or

indirect shareholdings or voting rights as defined under Law 3556/2007. Therefore, as of December 31,

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2024, there were no other shareholders known to the Company with significant direct or indirect

shareholdings in its paid-up share capital with corresponding voting rights under Law 3556/2007.

4. Shareholders Holding Shares Providing Special Control Rights

There are no shares that provide special control rights, except for the right of minority shareholders to

elect, in accordance with Articles 11 and 36 of the Company's Articles of Association, 2 members to the

Board of Directors through a special assembly convened specifically for this purpose. For the convening

and decision-making of this assembly, the provisions of the Law and the Company's Articles of

Association, which govern the convening and decision-making of General Assemblies, apply

accordingly. Each shareholder who is legally present and votes has the right to propose and vote for

only one board member, regardless of the number of shares they hold. Correspondingly, from the

combination of Article 64 of Law 5045/2023 and Article 11, paragraph 2c of the Articles of Association,

it follows that for the election of Board Members - representatives of the majority shareholder in its

Board of Directors, only the majority shareholder is entitled to attend and vote.

5. Restrictions on Voting Rights

The participation of the Greek State and companies in which the Greek State directly or indirectly holds

the majority of voting rights is excluded from the special assembly of minority shareholders. Similarly,

in the matter of the General Assembly concerning the election of other members of the Board of

Directors, the participation of minority shareholders is excluded.

The Company's Articles of Association do not provide for any other restrictions on voting rights arising

from its shares.

6. Shareholder Agreements Regarding Restrictions on Share Transfer or Voting Rights

The Company has not been informed of any shareholder agreements that impose restrictions on the

transfer of shares or the exercise of voting rights.

7. Rules for the Appointment and Replacement of Board Members and Amendment of the Articles of

Association

According to Articles 11, paragraphs 1 & 2 of the Articles of Association, the Company is governed by

the Board of Directors, the number of members of which must be odd and cannot exceed thirteen

(13) members or be fewer than seven (7) members.

The Board of Directors consists of:

• Two (2) representatives of the employees of the Company, who are elected (with their alternates)

through direct and universal voting.

• Two (2) members representing the minority shareholders, in accordance with the provisions of

Article 79 of Law 4548/2018, and elected as stipulated in Article 36 of this Articles of Association.

• Representatives of the majority shareholder, who are elected by the General Assembly in

accordance with the provisions of Law 4548/2018.

According to paragraph 4 of Article 11 of the Articles of Association, the two (2) members elected by

the employees are to be proposed within a period of two (2) months from their election. Until the

employee representatives are appointed, the Board of Directors can form and function legally without

these members, and their presence is not counted in forming the quorum or majority. From their

appointment onwards, they participate automatically in the composition of the body, and if it has

already been constituted, it is restructured to include these members.

According to paragraph 4(a) of Article 11 of the Articles of Association, the non-election or non-

appointment or any failure to complete the representation of the minority shareholders does not

prevent the formation and functioning of the Board of Directors, and the number of such members is

not counted for the formation of the quorum and majority.

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According to Article 13 of the Articles of Association, if any member of the Board of Directors, elected

by the General Assembly, ceases to participate in the Board of Directors due to resignation, death, or

any other reason, the following will occur:

(a) The deceased member will be replaced as soon as possible by the General Assembly of the

shareholders of the Company, using the same process as the appointment, in accordance with the

provisions of Law 4548/2018. Shareholders participating in the special assembly under Article 36 of

the Articles of Association are not allowed to participate in this election.

(b) Until a replacement is appointed by the General Assembly, the Board of Directors may convene

and decide legally with the remaining members, who will continue the management and

representation of the Company without replacing the deceased member(s), provided that their

number exceeds half of the members as they were before the event, and in any case, the remaining

members are at least three (3).

a General Assembly with the sole purpose of electing a new Board of Directors.

Furthermore, if any of the representatives elected by the employees or the minority shareholders at

the General Assembly ceases for any reason to participate in the Board of Directors, they will be

replaced by their alternate, and in the event of their removal, they will be replaced in the same manner

as originally appointed. Until a replacement is appointed in these cases, the Board of Directors will form

and operate legally, with paragraphs 4(a) and 5 of Article 11 of the Articles of Association applied

accordingly.

The rules for amending the provisions of the Articles of Association, as stipulated in the Company's

Articles of Association, do not differ from those provided for in Law 4548/2018, as in force.

8. Competence of the Board of Directors or Certain Members for the Issuance of New Shares /

Purchase of Own Shares

Regarding the issuance of new shares and the purchase of own shares from January 1, 2019, Law

4548/2018 applies. According to Article 8, paragraph 2 of the Company's Articles of Association, the

General Assembly has the possibility to delegate to the Board of Directors the authority to increase the

Company’s share capital; however, such a decision has not been made by the General Assembly of the

shareholders.

For the fiscal year 2024, no stock purchase options were granted, and no share allocation program is in

effect. No decision has been made by the General Assembly of shareholders to delegate to the Board

of Directors or another entity the authority to acquire own shares up to 10% of the paid-up share

capital, in accordance with the specific terms and procedures of Article 49 of Law 4548/2018.

9. Significant Agreements that Become Effective, Are Modified, or Terminated in the Event of a

Change of Control

There are no agreements that become effective, are modified, or terminated in the event of a change

in control of the Company following a public offer.

10. Agreements with Members of the Board of Directors or Employees of the Company

There are no agreements between the Company and its Board members or employees that provide for

compensation specifically in the event of resignation or dismissal without valid cause or termination of

their tenure or employment due to a public offer.

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SUSTAINABILITY REPORT

For the financial year 2024 , after the adoption of

● Regulation (EU) 2023/2772 of 31.7.2024 supplementing Directive 2013/34/EU of the European

Parliament and of the Council as regards sustainability reporting standards, which is mandatory and

universally applicable to public interest entities and large entities; and

● the publication of Law 5164/2024 (A' 202) which incorporated the provisions of Directive (EU)

2022/2464 of the European Parliament and

the Council of 14 December 2022 amending

Regulation (EU) No 537/2014, Directive 2004/109/EC and Directive 2013/34/EU as regards the

submission of sustainability reports and, inter alia, amended the provisions of Law 4548/18 and Law

3556/07

and as part of the Annual Report of its Board of Directors, the Sustainability Statement in compliance

with the Corporate Sustainability Reporting Directive (CSRD) for the submission of Sustainability

Statements and the European Sustainability Reporting Standards (ESRS), as well as the requirements of

the European Classification Regulation 2020/852 is provided below.

 
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Table of Contents 
General disclosures ................................................................................................................ 120 
Training base .................................................................................................................. 120 
[BP-1] General basis for the preparation of the sustainability statement ................. 120 
General disclosures ................................................................................................................ 121 
Training base .................................................................................................................. 121 
[BP-1] General basis for the preparation of the sustainability statement ................. 121 
[BP-2] Disclosures in relation to special circumstances ............................................. 123 
Governance.................................................................................................................... 126 
[GOV-1] - The role of the administrative, management and supervisory bodies ...... 126 
[GOV-2] Information received and sustainability issues considered by the company's 
administrative, management and supervisory bodies .............................................. 135 
[GOV-3] Integrating sustainability-related performance into incentive schemes ..... 137 
[GOV-4] Declaration on due diligence ....................................................................... 140 
Strategy .......................................................................................................................... 144 
[SBM-1] Strategy, business model and value chain ................................................... 144 
[SBM-2]  Interests and views of stakeholders ........................................................ 159 
[SBM-3]  Significant  impacts,  risks  and  opportunities  and  their  interaction with  the 
strategy and business model ..................................................................................... 167 
Impact, risk and opportunity management ................................................................... 178 
[IRO-1] Description of procedures for identifying and assessing significant impacts, risks 
and opportunities ...................................................................................................... 178 
[IRO-2]  Disclosure requirements in ESRS covered by the entity's viability statement
  191 
Environmental Information ................................................................................................... 192 
EU Classification Regulation. ............................................................................................ 192 
ESRS E1 - Climate Change.................................................................................................. 227 
Strategy .......................................................................................................................... 227 
[ESRS E1-1] Transition plan for achieving climate neutrality ..................................... 227 
[ESRS 2  SBM-3] Significant impacts, risks and opportunities and their interaction with 
the strategy and business model ............................................................................... 228 
Impact, risk and opportunity management ................................................................... 235 
[E1-2] Policies on climate change mitigation and adaptation ................................... 235 
[E1-3] Actions and resources related to climate change policies .............................. 236 
Measurement indicators and targets ............................................................................ 248 
[E1-4] Objectives on climate change mitigation and adaptation .............................. 248 
[E1-5] Energy consumption and energy mix .............................................................. 249 

 
117 
 
[E1-6] Gross emissions of scopes 1, 2, 3 and total greenhouse gas emissions ......... 252 
[E1-9]  Projected  financial  impacts  of  significant  material  and  transition  risks  and 
potential climate-related opportunities .................................................................... 258 
ESRS E3 - Water and marine resources ............................................................................ 260 
Impact, risk and opportunity management ................................................................... 260 
[E3-1] Policies related to water and marine resources .............................................. 260 
[E3-2] Actions and resources related to water and marine resources ...................... 262 
Measurement indicators and targets ............................................................................ 277 
[E3-3] Objectives on water and marine resources .................................................... 277 
[E3-4] Water consumption ........................................................................................ 278 
[E3-5] Projected financial consequences of impacts, risks and opportunities related to 
aquatic and marine resources  .................................................................................. 282 
ESRS S1 Domestic labour force ......................................................................................... 284 
Strategy .......................................................................................................................... 284 
[SBM-3]  Significant  impacts  and  risks  and  their  interaction  with  the  strategy  and 
business model .......................................................................................................... 284 
Impact and risk management ........................................................................................ 288 
[S1-1] Policies related to the workforce concerned .................................................. 288 
[S1-2]  Procedures  for  engaging  with  the  relevant  workforce  and  employee 
representatives on impacts ....................................................................................... 309 
[S1-3] Procedures for the remediation of negative impacts and  channels for raising 
concerns by the workers concerned .......................................................................... 313 
[S1-4] Taking action on significant impacts on the relevant workforce and approaches 
to manage significant risks in relation to the relevant workforce and the effectiveness 
of these actions ......................................................................................................... 316 
Measurement indicators and targets ............................................................................ 329 
[S1-5] Objectives related to managing significant negative impacts, promoting positive 
impacts and managing significant risks ..................................................................... 329 
[S1-6] Characteristics of the company's employees .................................................. 333 
[S1-7] Characteristics of non-salaried employees in the workforce of the enterprise 
itself ........................................................................................................................... 337 
[S1-9] Diversity measurement indicators .................................................................. 338 
[S1-10] Adequate wages ............................................................................................ 339 
[S1-11] Social protection ........................................................................................... 339 
[S1-14] Health and safety measurement indicators .................................................. 339 
[S1-16] Compensation measurement indicators (wage gap  and total compensation)
 ................................................................................................................................... 344 
[S1-17] Incidents, complaints and serious human rights impacts ............................. 345 

 
118 
 
ESRS S2 - Workers in the value chain ............................................................................... 347 
Strategy .......................................................................................................................... 347 
[SBM-3] Significant impacts and their interaction with the strategy and business model
 ................................................................................................................................... 347 
Impact management ..................................................................................................... 350 
[S2-1] Policies related to workers in the value chain ................................................. 350 
[S2-2] Procedures for engaging with employees in the value chain in relation to impacts
 ................................................................................................................................... 358 
[S2-3] Channels for employees to raise concerns in the value chain ........................ 360 
[S2-4] Taking action on the significant impacts on employees in the value chain and the 
effectiveness of these actions ................................................................................... 363 
Measurement indicators and targets ............................................................................ 365 
[S2-5] Objectives related to promoting positive impacts .......................................... 365 
ESRS S3 - Affected communities ....................................................................................... 367 
Strategy .......................................................................................................................... 367 
[SBM-3]  Significant  impacts  and  risks  and  their  interaction  with  the  strategy  and 
business model .......................................................................................................... 367 
Impact and risk management ........................................................................................ 371 
[S3-1] Policies related to the affected communities .................................................. 371 
[S3-2] Procedures for engaging with affected communities in relation to impacts .. 378 
[S3-3] Channels for raising concerns from affected communities ............................. 380 
[S3-4] Taking action on significant impacts on affected communities and approaches to 
manage significant risks in relation to affected communities and the effectiveness of 
these actions .............................................................................................................. 383 
Measurement indicators and targets ............................................................................ 392 
[S3-5] Objectives related to promoting positive impacts and managing significant risks
 ................................................................................................................................... 392 
ESRS S4 - Consumers and end users ................................................................................. 395 
Strategy .......................................................................................................................... 395 
[SBM-3] Significant impacts, risks and their interaction with the strategy and business 
model ......................................................................................................................... 395 
Impact and risk management ........................................................................................ 401 
[S4-1] Policies related to consumers and end users .................................................. 401 
[S4-2] Procedures for engaging with consumers and end-users on impacts ............ 407 
[S4-3] Channels for raising concerns from consumers and end-users ...................... 410 
[S4-4]  Taking  action  on  significant  impacts  on  consumers  and  end-users  and 
approaches to manage significant risks in relation to consumers and end-users and the 
effectiveness of such actions ..................................................................................... 413 

119

[S4-5] Objectives related to promoting positive impacts and managing significant risks

................................................................................................................................... 418

120

General disclosures

Training base

[BP-1] General basis for the preparation of the sustainability statement

BP-1_01 - 02

The viability statement has been prepared on a consolidated basis, and includes its

subsidiaries. The scope of consolidation is the same as that of the financial statements.

BP-1_03

EYDAP NISSON ANAPTYXIAKI SA is a subsidiary of EYDAP SA and EYDAP SA holds 100% of its

share capital. Its activities are included in the sustainability report of EYDAP SA.

BP-1_04

The Sustainability Statement covers the entire value chain of the Group, as it includes

information related to the impacts, risks and opportunities, which have been identified as

significant in the Dual Materiality Assessment, and relate to both EYDAP's own activities and

its upstream and downstream value chain.

121

General disclosures

Training base

[BP-1] General basis for the preparation of the sustainability statement

BP-1_01 - 02

The viability statement has been prepared on a consolidated basis, and includes its

subsidiaries. The scope of consolidation is the same as that of the financial statements.

BP-1_03

EYDAP NISSON ANAPTYXIAKI SA is a subsidiary of EYDAP SA and EYDAP SA holds 100% of its

share capital. Its activities are included in the sustainability report of EYDAP SA.

BP-1_04

The Sustainability Statement covers the entire value chain of the Group, as it includes

information related to the impacts, risks and opportunities, which have been identified as

significant in the Dual Materiality Assessment, and relate to both EYDAP's own activities and

its upstream and downstream value chain.

For the same activities, the core and secondary activities were mapped, including the mapping

of the company's entities linked to each business activity and to each category of products and

services.

For upstream activities, the analysis of business relationships was limited to first tier suppliers

(Tier 1), while for the downstream value chain, it was limited to main business partners and

main customers, including those related to the use phase of the product/service and the end

of its life cycle.

EYDAP SA uses an integrated system of ESG indicators, which covers the entire value chain and

reflects its environmental, social and economic performance through:

- monitoring of water consumption and losses,

- energy efficiency analysis and use of renewable energy sources,

- managing economic and social risks.

Furthermore, EYDAP SA applies digital technologies for the collection and analysis of ESG data.

Indicatively:

- consumption monitoring systems

- analysis of environmental and financial performance through BI and analytics

tools,

- creating ESG reports that comply with European Directives and international

standards.

122

BP-1_05

EYDAP AE has established procedures for the management of classified and sensitive

information, including data related to intellectual property, know-how and innovation results.

Management Mechanisms & Access Control

EYDAP SA applies mechanisms for the management and protection of sensitive data, which

include:

- Access Control Systems: classified access to operational and technological

information, based on roles and authorisations [does not apply to the set of stand-alone

information systems and tools - used by organisational units - for which a supervisory

governance implementation is in the planning phase].

- Data encryption: securing sensitive information through advanced security

technologies. Data protection.

- Internal Policies & Procedures: Mandatory employee compliance with classified

information management policies and ESG regulations. Compliance with ESRS Requirements.

EYDAP AE's approach to managing classified and sensitive information is aligned with ESRS

requirements, ensuring transparency and accountability while protecting high-value business

information. The possibility to omit specific information concerning intellectual property

issues, know-how or innovation results was not used.

123

[BP-2] Disclosures in relation to special circumstances

Temporal horizon

BP-2_01

The time horizons are aligned with the requirements as defined in ESRS 1 (Short-term horizon

- 1 year, Medium-term horizon - 5 years, Long-term horizon - > 5 years).

Estimation value chain data using indirect

It should be noted that the measurement indicators monitored (energy and carbon footprint

measurement indicators) are not estimated using indirect sources, but are calculated on the

basis of the Company's primary data. EYDAP SA manages and processes the primary data

related to the supply of electricity, which are received directly from the supplier. All data used

for the Scope 3 calculation are measurable, with emissions from staff movements calculated

on the basis of a questionnaire and reduction to the total number of employees. In terms of

the assessment of these indicators, EYDAP SA uses data resulting from a benchmarking

exercise with similar companies abroad. Therefore, the indicators managed by the company

are based on measurable data and not on estimates, so no measurement uncertainty arises,

in accordance with ESRS 1, section 7.2, §91.

Disclosures arising from other legislation or from generally accepted sustainability reporting

statements

BP-2_16

No information from other legislation or standard is included.

Operation according to Standardization Systems standards

BP-2_18 & BP-2_19

Recognizing the principles of Corporate Governance, EYDAP SA has a system of structured

procedures certified with:

● ISO WATER QUALITY CONTROL SERVICE ESYD, ELOT EN ISO/IEC 17025/2017, No.192-

7, IN WAITING FOR THE NEW CERTIFICATE

● Wastewater Laboratory Analysis Service EN ISO/IEC 17025:2017, No. 856-4 & 862-3,

Certification Body: ESYD, CONVERSION LABORATORIES (Pending New Certificate) &

(under the new system, with the new (new) license (under the new (new) one), valid

until 3/7/2025.

● CUSTOMER SERVICE DEPARTMENT EN ISO 9001:2015 Certification Body: TUV Hellas,

Valid until: 25/05/2025

● SPECIAL CUSTOMER SERVICE DEPARTMENT EN ISO 9001:2015, Certification Body: TUV

Hellas, Valid until: 25/05/2025

124

● DIRECTORATE FOR MANAGEMENT & CUSTOMER EXPERIENCE EN ISO 9001:2015,

Certification Body: TUV Hellas, Valid until: 25/05/2025

● HUMAN RESOURCES DEPARTMENT EN ISO 9001:2015, Certification Body: TUV

AUSTRIA, VALID UNTIL: 27/02/2026

● INTERNAL CONTROL DEPARTMENT EN ISO 9001:2015, Certification Body: TUV HELLAS,

EFFECTIVE until: 26/11/2025

● IN-HOUSE PROTECTION AND PREVENTION SERVICE (PSPS), EN ISO 9001:2015 & EN

ISO 45001:2018, Certification Body BQC, 9001 & 45001, VALID until: 10/12/2026

● DPO, DPO DATA PROTECTION KNOWLEDGE CERTIFICATION, Certification Body: TUV

HELLAS, EXPIRATION until: 13/03/2027 and certification in cyber security CC of ISC2

● ENVIRONMENT SERVICE EN ISO 14001:2015. In development process (company-wide)

expected to be completed within 2026

● QUALITY ASSURANCE SERVICE (ISO) EN ISO 9001:20015. In development process

(company-wide) expected to be completed within 2026

● QUALITY ASSURANCE SERVICE (ISO) IN ISO 45001:2018. In development process

(company-wide) expected to be completed within 2027

BP-2_20

The following information is incorporated by reference:

Incorporation by reference

Disclosure requirements

Data points

Related Report

[GOV-1] The role of the administrative,

management and supervisory bodies

GOV-1_01 GOV-

1_02

GOV-1_04

GOV-1_07

GOV-1_16

Section "Corporate Governance

Statement" of the Annual

Report 2024

[GOV-1] The role of the administrative,

management and supervisory bodies

GOV-1_08

GOV-1_09

GOV-1_14

Section "Committees of the

Board of Directors -

Composition - Responsibilities -

Compensation of members -

Evaluation of effectiveness"

[GOV-2] Information received and

sustainability issues considered by the

company's administrative, management

and supervisory bodies

GOV-2_01

Section "Corporate Governance

Statement" of the Annual

Report 2024

[GOV-5] Risk management and internal

controls on sustainability reporting

GOV-5_01

Section "Report of Financial

Results"

125

[SBM-1] Strategy, business model and

value chain

SBM-01_03

SBM-01_04

Section "Report of Financial

Results"

126

Governance

[GOV-1] - The role of the administrative, management and supervisory bodies

Information about the Board of Directors

GOV-1_01 & GOV-1_02

The Board of Directors is composed of the following members as stipulated in the Articles of

Association:

a) 2 representatives of the employees of the Company elected (with their alternates) by direct

and universal suffrage.

b) 2 members representing the minority shareholders, elected in the manner set out in Article

36 of the Articles of Association.

c) by representatives of the shareholders, elected by the General Assembly in accordance with

article 11 of the Articles of Association and the provisions of Law 4548/2018.

During the reporting period, and up to the publication of this report, the Board of Directors

consists of one (1) executive member and twelve (12) non-executive members, of which four

(4) are independent.

The relevant information is set out in the Annual Corporate Governance Statement included

in the Annual Report for 2024.

GOV-1_03

In accordance with the legislation in force (Presidential Decree 17/1996, Law 3850/2010), an

Employees' Health and Safety Committee (EHRC) has been established by the employees, an

advisory body consisting of elected representatives of the employees, with the power to

identify occupational hazards.

In the event of a serious industrial accident, it proposes measures to prevent its recurrence

and in the case of an immediate and serious risk, it calls on the management to take the

necessary measures, including the shutdown of the machine/plant/production process.

Between the Management, the representatives of the EARC and the Internal Protection &

Prevention of EYDAP SA (ESYPP), tripartite meetings are held every three months, in the

presence of a Safety Technician - Occupational Physician. .

The Company encourages open consultation between Management and employees on Health

and Safety issues, recognizing that their participation in the process is a fundamental human

right, in accordance with the relevant Human Rights Policy.

Direct employees of EYDAP SA who consider that their work poses a risk to their safety, address

their elected body for this purpose, where, among other things, anonymity is respected, in

order to avoid retaliation.

127

Experience of the Board of Directors in terms of sectors, products and geographical locations

GOV-1_04 & GOV-1_16

In accordance with the current Nomination Policy, the composition of the Board must reflect

the knowledge, skills and experience required for the exercise of its responsibilities. This

includes the requirement for the Board as a whole to have an adequate understanding of the

areas for which the members are collectively responsible and to have the necessary skills to

exercise the management and supervision of EYDAP SA, in particular with regard to :

● its business activity and the key risks associated with it,

● the utilities sector,

● the water supply and water resources management, sanitation and wastewater

management sector,

● strategic planning and innovation,

● auditing or accounting and financial management,

● the financial and non-financial reports,

● the sciences of all engineering disciplines,

● compliance with the legislative and regulatory framework,

● understanding of corporate governance issues,

● the ability to identify and manage risks,

● the impact of digital technology and information systems on its activity,

● adequate gender representation,

● understanding of issues related to the environment, social responsibility and

governance (ESG); and

● the understanding of corporate governance issues related to the Internal Audit

System.

The cognitive field of the current Board members is characterised by diversity (engineering

sciences, finance, business administration, law, etc.) while all members have professional

experience, either from their activities in the free market (private and multinational

companies, banking sector) or from positions related to the provision of advisory services in

the public sector.

According to the results of the individual and collective suitability of the Board of Directors,

conducted during the reporting period by an external independent evaluator, the current

composition of the Board of Directors of EYDAP SA combines a broad and relevant set of skills

as well as experience in areas related to technical, financial and legal issues. The Board

adequately combines public and private sector knowledge, instilling in the public sector the

mentality, entrepreneurial orientation and innovative thinking of the private sector. In

addition, the independent members contribute valuable experience in strategic and

128

operational operations, while the Chairman of the Board contributes valuable technical

expertise. Many Board members have significant management experience due to their

membership of other Boards, while also managing effectively the requirements of the five (5)

Board Committees, which cover the areas of audit, risk management, innovation and

sustainable development, remuneration and suitability of Board members and regulatory

compliance. The Remuneration and Nomination Committee monitors on an ongoing basis the

individual and collective suitability of Board members. The Board annually evaluates its

effectiveness, the fulfilment of its duties and the performance of its Committees through a

process chaired by the Chairman of the Board in collaboration with the Remuneration and

Nomination Committee. The evaluation, at least every three years, shall be carried out by an

external consultant. The Remuneration and Nomination Committee shall preside over the

evaluation of the Chairman of the Board of Directors in relation to the performance of his/her

duties.

The programme of continuous training of the members of the Board of Directors is decided on

an annual or biennial basis, depending on the needs of the Company, the needs of the Board

of Directors as a whole or of individual members and the developments in the markets and

the legislative framework, as well as the findings of the reports of the Board of Directors'

evaluations.

The Company's Remuneration and Nomination Committee is responsible for the preparation

of this training programme. The training is divided into introductory and continuous training.

The scope of the training may be varied and/or adapted according to the needs of the trainees,

taking into account, inter alia, the results of the Board of Directors' evaluation.

The relevant information is set out in the Annual Corporate Governance Statement included

in the Annual Report for 2024.

129

Diversity in the composition of the Board of Directors

GOV-1_05 & GOV-1_06

The Company through the Diversity Policy (Board Resolution. 20961/2021) recognizes the

importance of promoting the principle of Diversity in the composition of its Board of Directors,

its senior management, as well as in all its employees, with the key parameters including

gender, age, experience, skills and knowledge, and ensures that there is no exclusion on the

basis of discrimination based on gender, race, colour, ethnic or social origin, religion or belief,

property, disability, age or sexual orientation. The Company recognises that promoting

diversity in its administrative, management and supervisory bodies is important for its further

business development as it can multiply opportunities to access a greater variety of solutions

to issues related to its business.

On 31/12/2024 , 32.72% of the regular staff are women (715). Of the 282 employees holding

positions of responsibility, 56.38% are women (159) and 43.62% are men (123). Of the 1,903

employees who do not hold positions of responsibility, 29.22% are women (556) and 70.78%

are men (1,347). Of the 148 employees who hold managerial positions (* i.e. positions of

responsibility other than Supervisors and Controllers B) 56.09% are women (83) and 43.91%

are men (65).

The percentage of female Board members is 30.77%, which is considered an acceptable level

of adequate gender representation and in line with the provision of article 3A of Law

4706/2020 due to the rounding to the nearest whole number.

GOV-1_07

Table1 . Details of Board Members for the years 2023 and 2024

Details of Board Members.

2024

2023

Number of executive members of the

Board of Directors.

Number of non-executive members of

the Board of Directors

Percentage of female members of the

Board of Directors.

30,77%

Percentage of independent members of

the Board of Directors

30,77%

The relevant information is set out in the Annual Corporate Governance Statement included

in the Annual Report for 2024.

GOV-1_08 -09 &14 IRO-1_11

According to Article 21 of the Statutes, the Board of Directors may delegate some of its powers

or duties to the Executive Committee (ECC) which shall be established by decision of the Board

of Directors.

130

In application of the above statutory provision, by decision of the Board of Directors, an

Executive Committee was established and operates, consisting of the CEO, the General

Managers and the Directors of Finance and Supply Chain Operations (until the position of the

General Manager of Finance and Supply Chain Operations is filled). The Chief Executive Officer

has been appointed as Chairman of the CSRP. In fulfilling its duties, the CSRP takes into account

the decisions of the Board of Directors delegating to it defined powers or responsibilities of

the Board of Directors, the legal and regulatory framework, the financial situation, the

business strategy, the long-term interests and sustainability of the Company, as well as other

parameters at its discretion. The CSR is primarily an administrative and management body with

certain supervisory activities as described in its Rules of Procedure.

The ESRP monitors, inter alia, the implementation of the KPIs of corporate transformation and

the adoption of ESG criteria.

A key component of the Internal Control System developed and implemented by the company

is the Risk Management Department, whose main role is to support the Management of

EYDAP SA and the Board of Directors in managing risks in order to achieve its business

objectives. It operates according to COSO standards, regarding the Internal Control System and

ISO 31000 for the risk management system.

Based on the requirements of the legislative provisions on corporate governance

• the Board of Directors is responsible for ensuring the adequate and effective operation

of the company's internal control system

• a Risk Management Committee has been established in accordance with best practice

standards, consisting of members of the Board of Directors and governed by an

Operating Regulation, which is posted on the corporate website

The purpose of the Risk Management Committee is to assist the Board of Directors in the

performance of its responsibilities regarding the management of operational risks. It oversees,

evaluates and monitors the design and implementation of the all risk management framework

taking into account the scope of the front line activities and its critical infrastructure.

• the Audit Committee assures the Board that there is systematic and adequate

monitoring of the effective functioning of the internal control, quality assurance and

risk management systems and the sustainability reporting process.

Further information regarding the Risk Management Committee and the Audit Committee is

included in the Management Report of the Board of Directors in the section "Board

Committees - Composition - Competencies - Remuneration of members - Evaluation of

effectiveness".

A plethora of control mechanisms have been identified, which are monitored, which under the

responsibility of the risk managers mitigate risks and act positively towards achieving business

objectives By monitoring the inherent and residual risk profile, risks are assessed and

categorized into three risk levels of high, medium and low risks. For more information on the

control mechanism reporting system refer to GOV-1-11.

In addition, by Board Decision 20853/05.04.2021, a Strategy and Innovation Committee was

established, consisting exclusively of members of the Board of Directors of EYDAP SA. By virtue

of Board Decision No. 21270/22.3.2023, the Board's Strategy and Innovation Committee was

renamed Strategy, Innovation and Sustainable Development Committee and its Operating

Regulations were amended accordingly. This Committee informs, analyses, evaluates and

advises the Company's Management and the Board of Directors on issues related to the

131

Company's overall strategy and specifically on sustainability, strategy in new technologies and

innovation, including the Company's digital transformation and cybersecurity. The ultimate

goal of the Committee is to achieve sustainable growth and optimize the value of the Company.

Specifically in the context of Sustainable Development, the Committee informs, evaluates,

advises and gives its opinion on:

● domestic, European and international Sustainable Development trends and best

practices that may have a significant impact on the Company's business activities and

performance,

● the Company's Sustainable Development Strategy and sets the objectives (short and

long term) in line with the guidelines and objectives set by the Board of Directors

through the application of technology and innovative solutions,

● the implementation of the Sustainable Development Policy, in accordance with the

Company's relevant strategy

● the Company's performance on material environmental, social and governance (ESG)

issues, informing the Board of Directors and proposing any corrective actions.

More information on the responsibilities and functioning of the Committee is included in the

Management Report of the Board of Directors in the section "Board Committees - Composition

- Responsibilities - Compensation of members - Evaluation of effectiveness".

GOV-1_10

The Board of Directors ensures the supervision and management of the Company's

Sustainable Development issues, within the framework of the Company's strategic planning.

During its meetings, it discusses the objectives related to sustainable development issues.

Within the framework of the Sustainability Policy, the Board of Directors identifies in the

Annual Management Report the non-financial issues that are deemed essential for the

implementation of its vision and strategy, taking into account the requirements of its

stakeholders. The Report shall include a reference to the way they are managed and the

evaluation of these actions based on recognised international standards.

The Board of Directors is assisted in all the above responsibilities by the Audit Committee, the

Strategy, Innovation and Sustainability Committee and the Risk Management Committee.

The Board of Directors of the Company defines and oversees the implementation of the

corporate governance system and ensures the adequate and effective operation of all internal

control mechanisms and procedures, including risk management and regulatory compliance,

thus ensuring the safe and efficient operation of the Company.

Reports are prepared at least annually either to the regulator or in workshops organised

internally with the participation of the Strategy & Strategy Directorate. Innovation, where the

political, economic and wider social environment in which EYDAP SA operates is analysed, with

particular emphasis on risks and opportunities. At the same time the impacts, opportunities

and risks are taken into account for the prioritization of the Company's strategic priorities.

GOV-1_11

132

The Board of Directors is informed of the key risks of EYDAP SA and retains ultimate

responsibility for the implementation of an effective risk management framework.

The Risk Management Committee supports the Board of Directors in fulfilling its

responsibilities for the management of the risk management system

The Risk Management Division is responsible, inter alia, for the development and

implementation of the Risk Management Framework

The Company has an adequate and effective Internal Control System (ICS) in order to

effectively manage the operational risks that arise in the course of its activities,

The reporting model of the SAI includes the control environment, risk management, control

mechanisms and safeguards, information, communication and monitoring system of the SAI,

through a set of Principles, Regulations, Policies, Procedures, Safeguards and organisational

structures, designed to provide reasonable assurance as to the accuracy and reliability of

accounting and operational data. The design of the structure and monitoring of the SAI is

based on the adoption of the Three Lines Model, defining roles and responsibilities in different

areas and the relationship between them.

GOV-1_12

One of the management bodies of the Company is the Strategy, Innovation & Sustainable

Development. The Committee informs, analyses, evaluates and advises the Company's

Management and its Board of Directors (BoD) on matters relating to the Company's overall

strategy, but also specifically on strategic sustainable development and ESG issues. Among

other things, it informs, evaluates, advises and expresses its opinion on the progress towards

achieving the Company's carbon dioxide (CO2) emission reduction targets and the Company's

performance on other material environmental, social and governance (ESG) issues, and

informs the BoD, and proposes any corrective actions. It is assisted in its work by the Strategy

& Innovation, which reports on the Company's performance and individual strategy issues,

and proposes strategic prioritisation and the Company's annual and long-term target setting.

GOV-1_13

One pillar of the Internal Control System that the company has developed and implements is

the Risk Management Department, whose main role is to support the Management of EYDAP

SA and the Board of Directors in the management of risks in order to achieve its business

objectives. It operates according to COSO standards, regarding the Internal Control System and

ISO 31000 for the risk management system.

GOV-1_15 &

The current Nomination Policy for the Members of the Board of Directors was approved by the

decision of the General Meeting of the Company's Shareholders on 11-7-2024. The individual

suitability of the Board members is assessed according to the knowledge, skills and experience

required to perform their duties within their respective roles and positions. Account shall be

133

taken of the level and type of education (field of study and specialisation.) Experience shall

cover both practical and professional experience and theoretical knowledge acquired. A Board

member shall be presumed to be of good repute, integrity and honesty, unless there are

objective and demonstrable reasons to the contrary. For more information on the knowledge,

skills and experience of the Board, please see GOV GOV .

134

Experience of the Board of Directors in terms of sectors, products and geographical locations

GOV-1_04 & GOV-1_16

The Remuneration and Nomination Committee monitors on an ongoing basis the individual

and collective suitability of the members of the Board of Directors.

Executives and partners of the Strategy & Strategy Division Innovation are regularly trained on

ESG issues by obtaining certifications, participating in information workshops and monitoring

developments in the relevant regulatory framework. Several managers and partners of the

Strategy & Innovation Directorate are involved in training and learning from the latest

developments in the field. Innovation are regularly trained on ESG issues by obtaining

certifications, participating in information workshops and following developments in the

regulatory framework.

135

[GOV-2] Information received and sustainability issues considered by the company's

administrative, management and supervisory bodies

GOV-2_01

EYDAP SA, within the framework of the provisions on Corporate Governance and with the aim

of corporate transparency and the protection of the interests of all stakeholders, established

the Internal Audit Department (Board of Directors' Decision 12160/15.09.1999), which

became operational on 1 November 1999. The purpose of the Internal Audit Department is to

monitor and make recommendations for the improvement of the Company's operations and

policies with regard to its Internal Control System, thus supporting the Board of Directors and

the Company's Management in enhancing corporate value, achieving corporate objectives,

protecting the Company's financial resources, reputation and viability. The Internal Audit

Division implements the above responsibilities by conducting audits and reporting to the

Company's audited units on any findings, the risks arising from them and any

recommendations for improvement. The final reports, upon completion, are submitted

immediately to the Company's Management (CEO, Chairman of the Board), the Audit

Committee and the audited units and at least quarterly to the Board of Directors.

The Internal Audit Department shall submit reports to the Audit Committee at least every

three (3) months, including the most important issues and its recommendations, on the audits

it has carried out, which the Audit Committee shall present and submit together with its

comments to the Board of Directors.

The company has also established the Risk Management Committee. The purpose of the Risk

Management Committee is to assist the Board of Directors in carrying out its responsibilities

with respect to the management of operational risks and impacts. The Committee regularly

reviews and monitors the risk management and crisis and disaster response framework (e.g.

governance, policy, procedures, implementation, results) and makes recommendations on

changes to the Risk Management Division, the CEO and the Board of Directors. Regularly

informs the Board of Directors on the development of the Company's material risks and

impacts and the adequacy and effectiveness of the risk management framework through the

Chairman.

The Board of Directors of EYDAP SA is informed every quarter on the performance of the

company through reports on relevant indicators. The system of performance indicators

responds to the needs of executive monitoring both by the Board of Directors of the company,

as well as by the Ministry, the independent regulatory authority and the Securities and

Exchange Commission. It complies with recent European legislation on ESG reporting and also

serves the Company's participation in the European Benchmarking Cooperation data exchange

network.

In order to formulate the annual target setting, the Directorate for Strategy & Innovation takes

into account the social, economic and political environment as well as available risk analysis

combined with opportunity identification. All of these factors are analysed and evaluated,

giving a considered prioritisation of strategic priorities and, by extension, the objectives

recommended to be pursued for the sustainability of the Company.

136

The relevant information is set out in the Annual Corporate Governance Statement included

in the Annual Report for 2024.

GOV-2_02

The Internal Audit Division reports operationally to the Audit Committee and administratively

to the Chief Executive Officer. The Board of Directors is responsible for ensuring that the

Directorate is adequately empowered by approving the Operating Rules, the audit plan and its

resources. Management should provide adequate staffing and resources to the internal

auditors and be informed at least quarterly of the progress and findings of the audit. The

Director of Internal Audit has direct access to the Board of Directors and management must

provide all information necessary for the proper functioning of the audit. Board members

should cooperate with the internal auditors and facilitate their work by informing the Audit

Committee of any restrictions on the exercise of the audit. In addition, the Innovation and

Sustainability Strategy Committee shall inform, evaluate, advise and give its opinion on the

strategy regarding new technologies, innovation and transformation of the Company.

The Board of Directors also regularly reviews the impacts, opportunities and risks in relation

to the defined strategy and the relevant measures taken to address them. It shall ensure that

the risk management, internal control and compliance functions are independent of the

business areas they control and that they have the appropriate financial and human resources

and authority to operate effectively, as required by their role. Understand the Company's risks

and the nature of those risks and determine the extent of the Company's exposure to the risks

it intends to take in the context of its long-term strategic objectives.

The Strategy and Innovation Directorate prepares regular reports for the information of the

administrative, management and supervisory bodies including their committees, such as the

Executive Committee, the Strategy, Innovation and Sustainability Committee and the

Remuneration Committee. These reports include, but are not limited to, indicator

performance, proposed target setting, analysis of the investment plan in relation to the

Strategy and issues of immediate interest with an analysis of impacts, risks and opportunities.

GOV-2_03

The Risk Management Division records in the Risk Register all risks arising from legislation, its

operation and its overall activities. EYDAP SA's Risk Register is structured under 4 types of risks

(Operational, Compliance, Financial, Strategic) and includes 27 categories of operational risks.

identify the risks that affect them and assess them based on the impact, likelihood and control

scales established by the Risk Management Division.

The table of significant impacts, risks and opportunities is presented in SBM-3_12.

137

[GOV-3] Integrating sustainability-related performance into incentive schemes

GOV-3_01 GOV-3_02 & GOV-3_03 & GOV-3_04 & GOV-3_05 & E1.GOV-3_01

For 2024, according to the decision of the Management Board, one of the objectives, which

were qualified and linked to the payment of additional incentives, was the reduction of

unpriced water. This decision reflects the Administration's firm intention to adapt to climate

change and to safeguard the precious resource of water by steadily reducing losses throughout

the treatment and distribution facilities. The reduction of untreated water will also bring a

reduction in CO2 emissions resulting from the treatment carried out in order to meet the

required quality levels.

At the same time, a large proportion of the investment plan is related to reducing emissions,

including circular economy and environmental protection projects. In the aforementioned

resolution, it is envisaged to pay additional remuneration in case of completion of a significant

degree of such investments as well, thus seeking to strengthen efforts to achieve goals directly

related to the Company's sustainability.

EYDAP SA is closely monitoring the upcoming regulatory developments with discussions on

the integration of other DEYAs and the takeover of additional areas. This has resulted in a lack

of operational visibility in the short term in order to set long-term targets with relative

certainty. Efforts will be made to make such a distinction between short, medium and long

term targets within 2025, once the regulatory framework, which is still under development, is

defined. Within 2024, the Directorate General for Transformation has set a long-term target

for green energy. Increasing greenery in the city to reduce the urban heat island and improve

the microclimate is a parameter of the integrated strategies being developed by EYDAP SA

such as the utilisation of the Adrian Aqueduct and Wastewater Reuse. Both in the context of

these strategies and in the context of pilot actions of cyclicality implemented in the framework

of Research and Development, EYDAP SA is establishing a course of close cooperation with the

Local Authorities so that the management of the urban water cycle is linked to the

improvement of the microclimate in Athens.

Among the objectives of the current Remuneration Policy of the Board of Directors are the

promotion of the interests, the creation of long-term value and the sustainable development

of the Company as well as serving its strategic objectives. In its formulation, the principle of

paying remuneration based on the principle of reasonable and fair measure to the persons

selected as the most suitable and best performing, taking into account the needs and nature

of each position or functional role as well as the Company's well-being, the long-term

enhancement of its value and sustainable growth.

Since the Company's immediate objective is to improve its performance and results, the

Company grants additional incentives for the positions of Executive Board members in the

form of variable remuneration linked to short-term and/or medium-term corporate objectives.

The Remuneration and Nomination Committee annually recommends to the Board of

Directors for final decision the establishment and revision (when required) of Performance

Measurement Indicators (KPIs), the targets to be achieved and the percentage of variable

remuneration in case of their achievement (the amount of variable remuneration granted

138

should not exceed 20% of the fixed remuneration of the Executive Directors). The objectives

must be consistent with the Company's investment and strategic plan.

In addition to the annual targets, the possibility is given to set additional long-term targets,

which will be evaluated over time, e.g. 3 years. Variable remuneration is paid once a year after

the publication of the Annual Financial Results, subject to the achievement of the targets set

for the KPIs. In principle, a time limit of 3 months is set for target setting after the Board of

Directors approves the Company's budget. In the event that, after the publication of the

financial results of the previous financial year, there is a material change on the above KPIs,

the targets may be adjusted within 2 months after the date of publication of the financial

statements of the previous financial year.In addition, by decision of the Board of Directors,

additional extraordinary variable remuneration may be paid to the Executive Board members

linked to the achievement/completion of a strategic objective (e.g. e.g. improvement of ESG

scoring), the amount of which shall not exceed the gross The target linked to the additional

one-off variable remuneration is a recommendation of the Remuneration and Nomination

Committee and approved by the Board of Directors. The additional extraordinary

extraordinary variable remuneration and the timing of its payment are proposed by the

Remuneration and Nomination Committee, approved by the Board of Directors and are an

update in the Annual Remuneration Report to the General Meeting of Shareholders. In

accordance with the resolution of the Annual General Meeting of Shareholders of 11.7.2024:

Given that the immediate objective for the financial years is to improve the Company's

performance and results, the payment of an additional incentive to the CEO in the form of

variable gross remuneration linked to short-term targets (bonuses). The bonus is defined as

20% of remuneration (5% for each target), plus employer contributions. If any of the

aforementioned targets are achieved for 3 consecutive financial years, the corresponding

bonus becomes 40% for these years and is paid retroactively (10% for each target). The above

variable gross remuneration will be paid after the publication of the Annual Financial Results

and subject to the achievement of the above specific quantitative targets (KPIs) and linked to

the annual Regular Budget and the Company's Financial Results approved by the Board of

Directors. The specification of the targets and the determination of the method of calculation

of the above variable remuneration will be reflected in a new, subsequent, Recommendation

of the Remuneration and Nomination Committee to the Board of Directors.

The Regulations of the Remuneration and Nominations Committee specify the principles,

responsibilities and issues of its operation and procedures, in accordance with the current

regulatory framework, the Corporate Governance Code, and the Company's Operating

Regulations. The Committee assists in a transparent manner the Board of Directors of the

Company in matters relating to the remuneration of the Board members, the composition of

the Board and the identification of suitable Board members, in accordance with the applicable

regulatory framework, the Company's policies and these Operating Regulations. Among its

responsibilities is the review and submission of proposals to the Board (and through it to the

General Meeting of Shareholders) regarding the total amount of annual incentive-based

variable remuneration e.g. bonuses, stock grant plans and stock option plans for the

Company's executives for whom variable remuneration has been determined.

139

E1.GOV-3_02-03

In 2024, i.e. for the fiscal year 2023, no variable remuneration was paid to the executive

members of the Board of Directors.

140

[GOV-4] Declaration on due diligence

GOV-4_01 according to ESRS 2 par. 30;32

Table 2. Due diligence process

Key elements of Due

Diligence

Paragraphs in the Sustainability Statement

α) Integrating due

diligence into the

governance, strategy and

business model

ESRS 2-

Information received and viability issues considered by the administrative,

management and supervisory bodies of the undertaking

ESRS 2-GOV-3

Integrating sustainability-related performance into incentive schemes

ESRS 2-SBM-3

Significant impacts, risks and opportunities and their interaction with the strategy

and business model

(b) Engaging with affected

stakeholders at all key

stages of due diligence

ESRS 2- GOV-2

Information received and viability issues considered by the administrative,

management and supervisory bodies of the undertaking

ESRS 2- SBM-2

Interests and views of interested parties

ESRS 2-IRO-1

Description of procedures for identifying and assessing significant impacts, risks and

Policies on climate change mitigation and adaptation

E1-4

Objectives on climate change mitigation and adaptation

E3-1

Policies related to water and marine resources

E3-3

Objectives on water and marine resources

S1-1

Policies related to the workforce concerned

S2-1

Policies related to workers in the value chain

S3-1

Policies relevant to the affected communities

S4-1

Policies related to consumers and end-users

assessment of adverse

effects

ESRS 2-IRO-1

Description of the procedures for identifying and assessing significant impacts, risks

and opportunities

ESRS 2-SBM-3

Significant impacts, risks and opportunities and their interaction with the strategy

and business model

(d) Taking measures to

address these adverse

effects

E1-2

Policies on climate change mitigation and adaptation

E1-4

Objectives on climate change mitigation and adaptation

E3-1

Policies related to water and marine resources

E3-3

Objectives on water and marine resources

S1-1

Policies related to the workforce concerned

S1-5

Objectives related to promoting positive impacts and managing significant risks

141

S2-1

Policies related to workers in the value chain

S2-5

Objectives related to promoting positive impacts

S3-1

Policies relevant to the affected communities

S3-5

Objectives related to promoting positive impacts and managing significant risks

S4-1

Policies related to consumers and end-users

S4-5

Objectives related to promoting positive impacts and managing significant risks

(e) Monitoring and

communicating the

effectiveness of these

efforts;

E1-4

Objectives on climate change mitigation and adaptation

E3-3

Objectives on water and marine resources

S1-5

Objectives related to promoting positive impacts and managing significant risks

S2-5

Objectives related to promoting positive impacts

S3-5

Objectives related to promoting positive impacts and managing significant risks

S4-5

Objectives related to promoting positive impacts and managing significant risks

142

[GOV-5] Risk management and internal controls on sustainability reporting

GOV-5_01

The Company has an adequate and effective Risk Management Framework in order to

effectively manage the operational risks arising from the conduct of its activities, as well as

from changes in the regulatory and legal framework governing its operations, which may lead

to legal sanctions and fines for non-compliance.

The Internal Control System (ICS) reporting model includes the control environment, risk

management, control mechanisms and safeguards, information, communication and

monitoring system of the ICS, through a set of Principles, Regulations, Policies, Procedures,

procedures, safeguards and organisational structures, designed to provide reasonable

assurance regarding the accuracy and reliability of accounting and operational data. The

design of the structure and monitoring of the SAI is based on the adoption of the Three Lines

Model, defining roles and responsibilities in different areas and the relationship between

them.

A detailed description of the SIF is given in the Financial Results Report.

GOV-5_02

Initially, the Risk Register of EYDAP SA is used for the risk assessment. Then the likelihood,

impact and control mechanisms of the risks in the Company's Risk Register are assessed.

GOV-5_03

Key risks in the preparation of the sustainability report include potential inconsistencies in data

collection, problems in the availability of data along the value chain, and misrepresentation of

sustainability achievements, which may lead to mistrust by stakeholders. To address these

risks, EIF SA implements mitigation strategies such as improving data collection and

verification processes, enhancing transparency and communication with stakeholders, and

developing internal controls to ensure the accuracy and reliability of sustainability information.

GOV-5_04 & IRO-1_13

Our approach to the Risk Management system includes the following stages:

● Examination of the internal & external environment of the Company

● Identification of potential significant risks that may affect the achievement of the

Company's business objectives

● Updating the risk register at least annually

● Cooperation between the Risk Management Division and the heads of organisational

units

143

● Risk management based on the approved Risk Allocation Framework.

The Risk Management Division analyses the results of risk identification and assessment of the

competent organisational units and formulates the Company's risk profile. It monitors and

assesses the degree of completion of relevant high risk mitigation actions and the degree of

consistency with the approved Risk Disposition Framework.

GOV-5_05

The Risk Management Division monitors the impact of extraordinary events and initiates

actions to reassess the risks associated with them, identifies emerging risks and monitors their

evolution to facilitate timely corrective actions and mitigation of their impact by the

responsible parties.

The Risk Management Division informs the CEO and the Risk Management Committee on all

issues of the Risk Management Framework to ensure that risk mitigation actions are properly

supported and decisions are taken by the Management.

144

Strategy

[SBM-1] Strategy, business model and value chain

SBM-1_01

The Company is active in the refining and supply of water and the provision of sewerage and

wastewater treatment services in the Attica region. According to its Articles of Association,

EYDAP SA is responsible for the design, construction, installation, operation, operation,

maintenance, development and modernisation/renovation of water supply and sewerage

facilities and networks within its area of responsibility. In addition to the activities of EYDAP

SA, the ability to use the water supply and sewerage networks has been added for the

development of telecommunication and energy activities, the provision of water meter

maintenance services, camera inspection of third party sewerage networks, undertaking third

party water quality control programmes.

EYDAP SA adopts and implements a Sustainable Development Policy, approved by its Board of

Directors. The Policy is fully aligned with its business strategy, vision and values and is the

effective implementation of its Strategic Priorities. The pillars and commitments it has set

integrate sustainability into its business operations and development, creating Value for the

Environment, Society and Corporate Governance. The Policy refers to equal access to excellent

quality drinking water at an affordable price, support to the local community through actions

to contribute to local development in projects with social and environmental implications. The

Policy is posted on the corporate website eydap.gr. The Senior Managers support the

formulation of the corporate strategy and coordinate, direct and control the work of their

organisational units of responsibility.

The main impacts of the company on Sustainable Development are the following:

● Sustainable management of natural resources and water sources

● Protection of ecosystems

● Reducing the carbon footprint

● Adoption of circular economy principles

EYDAP's strategy is based on Sustainable Development, Digital Transition and EYDAP's

Resilience to economic, environmental and social factors.

The main points of its strategy are the following important points, to which particular attention

and diligence is paid by all employees, in order to achieve the objectives set for these points

by its Management.

- Water Resources Management: improving efficiency and reducing water losses

through investment in modern technologies and control systems.

- Climate Adaptation & Energy Efficiency.

- Digital transformation: developing data management systems and adopting

digital tools to enhance performance and transparency.

145

-Corporate Governance & Transparency: complying with ESG standards and enhancing

transparency at all levels of operation.

Also, with regard to the link between Strategy and Value Chain, it is noted that:

-EYDAP's strategy affects all stages of the value chain, from water pumping and distribution to

customer service and wastewater management.

-Investments in modern technologies for monitoring and efficient management of water

resources are planned and implemented.

-Develop processes and actions to improve the relationship with consumers through

innovative services and awareness programmes.

EYDAP SA's sustainable development strategy reflects the Company's commitments on

environmental, social and governance issues.

Environment

In the environmental pillar, EYDAP SA applies policies and implements projects aimed at its

protection, energy neutrality and the promotion of the circular economy.

The exploitation of the water of the Adrianaios Aqueduct is one of the most important projects

of EYDAP SA, with a total cost of €11.5 million. It is a multi-stakeholder project, in which

municipalities, European and non-European institutions cooperate and finance. The project

aims at exploiting underground water flows, which until now have remained untapped, for the

irrigation of parks and gardens. In this way, it contributes to reducing the urban heat island

effect, enhancing the sustainability and resilience of urban areas.

At the same time, the Strategic Reuse Plan that has already been implemented in East Attica

and is being extended to the rest of the basin, as well as the first related projects developed

by EYDAP SA - such as the innovative sewer mining project - or which are in the planning phase,

are essential steps towards a more sustainable and responsible management of water

resources.

At the same time, EYDAP SA is upgrading the energy efficiency of the pumping stations and

the KELs, utilising biogas, with projects worth a total of approximately €23 million. Electric

charging points for the fleet, which is gradually being converted into an electrically powered

fleet, are being added to the buildings. In addition, photovoltaic stations are under

construction at the Acharnon and Polydendriou MESs, while the Company has entered, as of

August 2024, into a new electricity supply contract, with 50% green energy participation. It is

important to mention that, the upgrades of the small hydroelectric plants and the construction

of new ones are planned, which will ensure even lower emissions and more energy self-

sufficiency. Within 2024, the operational upgrading of the Mavrosouvala borehole also

proceeded.

On the environmental issues for 2024, the Company's effort to design and start implementing

the water scarcity response plan, examining alternative scenarios and conducting cost-benefit

studies, took the lead. In cooperation with the State, the best solutions are being sought to

ensure an uninterrupted water supply in its area of activity. The solutions under consideration

146

include access to additional surface and groundwater resources, desalination and wastewater

reuse.

Society

In the area of Society, the strategic priorities of EYDAP SA are the following:

- Ensuring water quality along the entire transport and distribution system

- the Safety, Health and Welfare of workers

- customer satisfaction

- Efficient demand management and reduction of leakages

- the development of new activities and the expansion of the customer base

- the Attraction and Development of Human Resources and

- the Support of Society

- More specifically, EYDAP SA ensures that consumers receive quality water at a

fair price. To this end, it is launching the supply and installation of multi-sensors of water

quality along the Mornos aqueduct. At the same time, the sewerage projects in the areas of

Rafina, Pikermio, Spata and Artemis, as well as Nea Makri, Marathon and Oropos are

progressing, thus satisfying the need of the residents of East Attica for availability, accessibility

and quality of sewerage services. The development projects provide employment and

sustainable wages for a significant size of the population, creating direct, indirect and induced

employment, and are considered necessary to safeguard public health.

- Among the other benefits, it is important to mention that the strategy for the

exploitation of the Adrianaios Aqueduct of EYDAP SA includes its protection and exploitation

as a special cultural resource for the benefit of society, unique of its kind in Europe, which is

the responsibility of the Ministry of Culture. Promotional actions by EYDAP SA, the local

government and civil society are already being implemented in the framework of consortia

funded by European Programmes such as the competitive Urban Innovative Actions that funds

the action "CULTURAL HIDRANT" which was completed in 2024 with the participation of EYDAP

SA. Furthermore, the support of society is achieved through the long-standing introduction of

the tiered and social tariff to meet the needs of socially vulnerable groups, while the

Company's services are designed in a way that does not exclude people with mobility, visual

or hearing impairments.

- In matters related to the health and safety of employees, procedures are

followed and ISO standards such as 45001:2018 are applied, which ensure the appropriate

working conditions, while the whole effort is accompanied by the appropriate team of

Technicians and Occupational Physicians.

- It is important to note that EYDAP SA invests in its human resources with targeted

and continuous training programmes, in order to provide them with the appropriate skills and

competencies required by the ever-increasing demands of their work. It also ensures that

147

other benefits such as insurance schemes, family life support programmes and gifts for

employees' children are available.

Corporate Governance

The strategic priorities in the Corporate Governance pillar are as follows:

- Regulatory compliance and adherence to standards

- Operational Resilience

- Business Transformation - Leveraging technology

- Optimal Financial Management

EYDAP SA continuously monitors changes in the regulatory framework and updates its policies

and procedures accordingly. The Company provides training to its Board members and

employees to ensure that they understand and apply the regulatory requirements. The

Internal Audit Department of EYDAP SA conducts regular audits to ensure compliance with

internal regulations and policies. Regulatory compliance is vital for EYDAP SA, as it ensures the

proper functioning of the company and the protection of the interests of its consumers and

shareholders.

In the area of Operational Resilience, it launches projects to repair its water supply and

sewerage networks, as well as its reservoirs and pumping stations, in order to shield its

infrastructure. The shielding investment plan extends over a 10-year period, will require a

significant capital commitment and is necessary to meet the challenges of climate change.

At the same time, the digital and operational transformation of the company is progressing,

with the procurement of new ERP software that will be closer to its needs. In 2024, the SCADA

data transfer system development project also progressed. Finally, an operational upgrade of

the Mavrosouvala drilling facilities is being carried out.

Finally, the development of the reuse of the water resulting from the treatment of wastewater

especially in the wastewater treatment plants of East Attica and beyond, as well as the further

development of sewer mining technology in parks in Athens. Great emphasis is also placed by

the Administration on the prevalence of e-bill for reasons of environmental protection and

saving resources in general.

SBM-1_02

The main categories of the company's customers are:

● Industries

● Individuals

● Private enterprises

● Public bodies

● OTA.

148

Key Effects on Social Sustainability:

● Implementation of services & projects to improve the quality of life of citizens

● Ensuring an affordable tariff

● Adoption of policies to reduce inequalities

● Strengthening local communities with a holistic approach

● Protecting the health & safety of workers & consumers

● Employee development

● Ensuring equal opportunities & the right to diversity

SBM-1_03 &

EYDAP SA owns and staffs facilities (regional centres, technical sectors, refineries, aqueducts,

wastewater centres, etc.), throughout the Attica basin and in the regional units of Boeotia,

Fokidos and Aitoloakarnania.

For the categorisation of revenue by business segment, see the section of the Financial Results

Report.

The total number of employees and their geographical distribution are presented in section

S1-6_08-10.

149

SBM-1_21- 22

The Company's objectives are categorized according to the ESG framework. A table with the

objectives classified under the three pillars (Environment, Society, Governance) is provided

below.

ADMINISTRATION

SOCIETY

ENVIRONMENT

C1-Number of confirmed

non-compliances with

regulations

C3-Percentage of drinking

water quality controls

within legal limits

>99,5%

C10-Percentage

of energy

consumption

from RES

>66,3%

C2-Strategic absorption

indicator of the Investment

Plan for Operational

Resilience

>73%

C4-Confirmed quality

complaints

(Number/thousandths of

meters)

<0,025

C11-Gas emission

intensity EYDAP

<522

D3-Development indicator

in relation to the

investment plan

>72%

C5-Lost Time Injury

Frequency Rate

<0,5

C12-Total volume

of reusable water

>Χ

>17.800.000

C7-Direct economic

benefit from DG

Transformation projects

>4%

e-bill

C6-Satisfaction of EYDAP

SA staff

>78,5%

C8-Number of water

meters replaced due to

obsolescence per year

>6.000

C9-Customer satisfaction

>75%

C15-Group profitability

ratio in relation to group's

past due receivables [6

months to 2 years past due

receivables out of

settlement / Turnover]

<6,9%

D4-Efficiency index

including environmental

management in relation to

unpriced water

<22,75%

C16-Group Business Cycle /

[Cost of IAS Staff Fees +

cost of third party support

services]

>2,35

C17-Total water meters,

sewerage connections and

unconventional source

connections

>2.635.0

C13-EBT (group prices)

>24.000

C21-Strategic Investment

Plan Absorption Index for

the Development of New

Activities and Expansion of

the Clientele & Business

Transformation

>74%

C14-Circulating liquidity

(company prices)

2-6,06

150

D1-Efficiency ratio in

relation to receivables

overdue

<65%

D2-Efficiency ratio in

relation to operating

expenditure

<73%

C18-Percentage of posts

filled on the basis of

declared needs in human

resources management

>23%

C19-Average hours of

employee training

>8,5%

C20-Economic

contribution of EYDAP SA

to society

>9.200.0

Board Decision 21876

EYDAP SA has a matrix of sustainable objectives, spanning all ESG pillars. On corporate

governance issues, it seeks to comply with the regulatory framework and enhance resilience.

It promotes business transformation and optimal financial management. In matters relating to

society, its employees and customers, it sets objectives related to their satisfaction, the

expansion of its area of activity and the services offered. It sets targets for the reduction of

complaints regarding the quality of its services and accidents at work. On environmental

issues, it seeks to reduce gas emissions, promote energy self-sufficiency and renewable energy

sources, and promote circular economy practices. With regard to the major products in all the

CCLs, the pollutant removal rate, in terms of organic load, is over 95%. EYDAP SA ensures the

adequacy and quality of the water supplied, in accordance with the requirements of the

legislation on drinking water. The amount of water, from the treated effluent used within the

KEL facilities, to serve needs, amounts to 4,611,681m

for 2024.

SBM-1_23

Within the framework of the Sustainability Policy, the Board of Directors of EYDAP SA identifies

in the Annual Management Report the non-financial issues that are deemed essential for the

implementation of its vision and strategy, taking into account the requirements of its

stakeholders. The Report makes reference to the way they are managed and the evaluation of

these actions based on recognised international standards. The Board of Directors is assisted

by the Strategy, Innovation and Sustainability Committee in all the above responsibilities. The

Committee formulates the Company's strategy by setting its strategic priorities and objectives

in the context of Sustainable Development.

Its actions are aligned with the National and European Framework, while ESG KPIs contribute

to Management Decisions by assessing the relative performance in achieving the targets set.

The challenges ahead are summarised in the following points:

151

- Managing water resources by reducing losses and reusing water.

- Energy efficiency and increasing the use of renewable energy sources (with a

view to an integrated transition to them).

- Continuous alignment and adaptation to regulatory requirements, with the

integration of ESG criteria.

The dual materiality analysis highlighted the areas that the Company's Strategy consistently

focused on in 2024. Climate change and adaptation to it was addressed by all organizational

units, both for addressing the short-term challenges and for long-term planning. The issue of

water scarcity was particularly addressed, following consecutive years of high temperatures

and declining stocks, and optimal solutions were sought in terms of infrastructure projects that

would significantly mitigate any future challenges.

With regard to water and marine resources, it is a strategic decision of EYDAP SA to continue

to provide one of the highest quality waters in Europe, with high ratings and reduce

unnecessary consumption.It is its commitment to comply with the current regulatory

framework and its programme to implement the measures that involve it in the National River

Basin Management Plans. The sewerage projects in East Attica will rehabilitate all of the

region's water and marine resources, addressing a long-standing need of its nearly 400,000

inhabitants.

On workforce issues, the signing of the collective agreement met the demands of workers in a

context where health, safety, training and privacy issues are already high on the agenda.

However, the challenges that the Company has to face do not allow for complacency;

continuous training in new technologies and meeting the needs for qualified personnel in

technical and administrative positions are needed.

In 2024, projects and actions to strengthen the Company's operational resilience and

transformation continued unabated. The Operational Resource Management software

upgrade project was initiated and the majority of the budgeted projects in Water and

Wastewater infrastructure were implemented. One of the Company's challenges is to be able

to carry out all the required projects and expenditures while consistently maintaining

satisfactory profit margins that will ensure sustainability.

SBM-1_25

The company describes in detail the group profile, business model, and value chain in the

annual Sustainability Report.

EYDAP SA (Water Supply and Sewerage Company of Protopitousis) seeks the best possible

quality of life for the residents of the capital and all the areas it serves, by providing drinking

water and sewerage services. Major partnerships include public agencies, educational and

research institutions, and local government. The company serves industries, individuals,

private businesses and public organizations, with a focus on high service and a customer-

centric philosophy.

152

Communication with customers is done through corporate events, telephone communication,

website, social media and online requests. Revenues are derived from water supply, sewer

services, sale of electricity and stock.

Competitive advantages include excellent drinking water quality, reliable sanitation services,

smart metering, 24-hour telephone service and certified laboratories. The main activities

include water refining and supply, sewerage services, wastewater treatment and training.

Key resources include untreated water, pipeline networks, water treatment plants, wastewater

treatment plants and hydropower plants. The cost structure includes staff salaries, network

maintenance and untreated water costs.

A framework for action has been developed for the whole value chain, and specifically for

climate change and water scarcity.

EYDAP SA, as an organisation that provides critical water supply and wastewater services,

seeks the health and the best possible quality of life of its residents by offering the most

important commodity: drinking water. Its mission includes caring for the uninterrupted supply

of drinking water and sanitation services, ensuring that people's lives and business operations

are conducted in optimal conditions.

EYDAP SA collaborates with key stakeholders, such as public organisations, educational and

research institutions, as well as local authorities, in order to enhance the production of value

and utility. Its clientele includes industries, individuals, private companies, public

organizations, and local authorities, aiming to provide a high level of service through a

customer-centric philosophy.

EYDAP SA has created a special Customer Management and Customer Experience

Department, which manages issues in the direction of maintaining the customer experience

at a high level and ensures the improvement of the services provided to customers with

emphasis on electronic services.Communication with customers is carried out through

telephone communication (24/7), the corporate website, social media, the "EydApp"

application and electronic requests in eEYDAP, as well as through 12 regional customer service

centres.

The revenue structure of EYDAP SA is derived from the supply of water and related services,

sewerage services, sale of electricity and sale of stocks. Its competitive advantages include

excellent drinking water quality, continuous and reliable sewerage services, an intelligent

network with information and communication technologies for accurate metering of flows,

24-hour telephone service, an extensive pipeline network and network monitoring with a

remote control system.

The main activities of EYDAP SA include water refining and supply, sewerage services,

wastewater treatment, construction and operation of water supply and sewerage networks,

as well as education and research services. Its key resources include pipeline networks, water

treatment plants, wastewater treatment plants, hydroelectric and photovoltaic plants, as well

as chemical and microbiological laboratories.

153

Finally, the cost structure of EYDAP SA includes staff salaries, network maintenance,

construction of facilities, undiluted water costs and consumption of materials, ensuring the

sustainability and efficiency of its services.

Information related to the business model can be found in SBM 1_27.

SBM-1_28

As shown in the table below, EYDAP SA is located in the middle of the value chain, with the

main supplier upstream being EYDAP's main supplier and the main customers downstream

being industries, public entities, businesses and households.

The value chain of EYDAP SA is formed by the following critical elements:

- Infrastructure & Operations: Investing in sustainable water and sanitation

infrastructure.

- Innovation & Technology.

- Social Impact: contributing to the quality of life of citizens by ensuring access to

clean water.

Table2 . Value Chain

Ananti

Same Function

(Activity of EYDAP SA)

Downstream

Consultants and technical staff

(Legal, IT, Financial, Scientific,

etc.)

Construction

companies/contractors

Personnel supply companies

(labour, administrative)

Capital goods (e.g. equipment)

Financial institutions (banking,

insurance, mutual funds)

Municipal waste management

Energy (oil, electricity, gas)

Land transport (including tanker

transport of waste water to

treatment plants)

Sea transport

Water supply resources

(Marathon, Yliki, Mornos, Evinos

reservoirs, boreholes) [Etairia

PAGION EYDAP N.P.D.D.

(manager EYDAP SA)]

Administration offices

Customer service centres

Centre for Research and

Development (CEREFYT)

Industrial waste and wastewater

quality control service

Warehouses

Wastewater treatment plants

(Psyttaleia, Metamorfosi,

Thriasio, Megara, Koropi -

Peania)

Water treatment plants (Galati,

Acharnes, Polydendri and

Aspropyrgos)

Dams

Water extraction projects

(groundwater reserves)

Water transport aqueducts

(Mornos, Yliki, Marathon-Galati,

Distomo)

Industry

Public bodies

Businesses (such as hotels

etc.)

Households

Discharge of treated

wastewater by

customers/Reuse of

treated wastewater by

customers (e.g.

municipal)/Use of sludge

by customers (energy

recovery from cement

industry, fertilizers, etc.)

154

Chemicals for water and waste

water treatment

Landfill of sludge (ash, sand)

Equipment and consumables for

wastewater and water

treatment plants

Drinking water supply network,

including pumping stations

Network of pipelines, including

pumping stations, for the

transport of waste water from

producers to waste water

treatment plants

Production of electricity and

thermal energy from renewable

energy sources (photovoltaic,

hydroelectric, biogas)

Transport (business travel,

commuting)

Fleet of vehicles of the water

supply division, sewerage

division

155

SBM-1_26

The main inputs for the company are raw water, urban wastewater and wastewater of non-

standard urban composition. Overall, inputs for EYDAP SA are physical, financial, human, as

well as inputs from suppliers.

The Greek State, with the new Contract concluded between the Greek State, the Etairia

PAGION EYDAP NΠΔΔD and EYDAP SA, undertakes the obligation, throughout the duration of

the Contract, to supply EYDAP SA with raw water of sufficient quantity to cover the needs of

its consumers and quality in accordance with the requirements of the legislation.

SBM-1_27

The Company recognizes the following expected benefits that have been defined as strategic

priorities of the Company:

● Environment

1. Energy neutrality policy

2. Environmental protection and circular economy

● Society

1. Ensuring water quality along the entire transmission and distribution system

2. Safety, health and well-being of employees

3. Customer satisfaction

4. Efficient demand management and reduction of leakages

5. Development of new activities and expansion of customer base

6. Supporting society

7. Attracting and developing human resources

● Governance

1. Operational resilience

2. 2. Regulatory compliance and adherence to standards

3. Optimal financial management

4. Business transformation - Leveraging technology

EYDAP's business model reflects its commitment to sustainable water resources management,

ensuring quality water supply and wastewater services, its resilience to climate challenges and

the value it creates for customers, partners and society through innovation, responsible

governance and environmental protection.

The following is a detailed report of the Business Model of EYDAP SA.

Key Partners:

156

● Greek State (main shareholder & regulator)

● Municipalities and Regions

● Regulatory Authority for Waste Energy and Water (RAWEA)

● Environmental organisations

● Universities & Research Institutions

● Private suppliers and contractors

● International Organisations and Investors

● Local Societies

● Suppliers of equipment and services

Main Activities:

● Water management and treatment

● Operation, maintenance and development of water supply and sewerage

infrastructure

● Developing innovative solutions for sustainable water management.

● Water quality monitoring and control

● Monitoring and protection of water stocks

● Implementing a climate adaptation strategy

● Implementation of operational resilience programmes

● Compliance with the CSRD regulatory framework and ESG requirements

● Customer management and service

● Development of innovative solutions and technologies

Key Resources:

● Water resources and infrastructure

● Sewerage infrastructure

● Human resources and expertise

● Regulatory and legal framework

● Capital and financial resources

● Technological innovations (digital meters, smart water management)

● Water consumption data and analyses

157

Customer Categories:

● Residential consumers

● Industrial and professional customers

● Municipalities and Public Organisations

● Rural and environmental bodies

Relations with customers:

● Service through physical and digital channels (web site, mobile app)

● 24-hour telephone service (1022)

● Feedback and service improvement

● Information and education programmes on environmental issues

● Participation in consultations and open discussions with social stakeholders

● Consumer and contract management

Distribution Channels & Communication:

● Physical customer service points

● Corporate website and online services

● Mobile applications and online account management

● Telephone service centres

● Social media, information campaigns & advertising campaigns

● Cooperation with public and private bodies

Value & Innovation to Customers:

● Excellent drinking water quality

● Reliable and affordable water & sewerage services

● Commitment to sustainable development and environmental protection

● Transparency, social responsibility and service innovation

● Environmental responsibility and sustainable management of water resources

● ISO 17025 certified chemical and microbiological laboratories

● Extensive water distribution network (about 14,000 km) covering 4,400,000

inhabitants

158

● Management of four Water Treatment Plants with a total capacity of 1.8 million cubic

metres of water per day

● 24-hour network monitoring with remote control - remote control system (SCADA)

● Continuous technological upgrading and innovation

● High quality customer service

● Smart grid with information and communication technologies for accurate metering

of benefits

Cost structure:

● Infrastructure development, operation and maintenance costs

● Water quality management and control costs

● Research, innovation and sustainable development costs

● Costs of compliance with regulations & ESG

● Human resources and education

● Regulatory and regulatory compliance

● Investing in climate resilience and sustainability

Revenue streams:

● Pricing of water and sewerage services

● Sale of Electricity

● Service contracts with public & private entities

● European and national funding programmes

159

[SBM-2] Interests and views of stakeholders

SBM-2_01 & SBM-2_05 & SBM-2_06 & SBM-2_07

EYDAP SA recognises as affected stakeholders: individuals or groups whose interests are or

could be affected - positively or negatively - by the company's activities and its direct and

indirect business relationships throughout its value chain. Stakeholders include its employees.

Stakeholder identification refers to the entities and individuals with whom it maintains contact

and interacts by developing and enhancing a structured dialogue. The Company is in constant

communication with its stakeholders in order to strengthen the relationship of trust with

them.

Within the framework of the Sustainability Policy, the Board of Directors of the company

identifies in the Annual Management Report the non-financial issues that are deemed

essential for the implementation of its vision and strategy, taking into account the

requirements of its stakeholders. The Report makes reference to the way they are managed

and the evaluation of these actions based on recognised international standards.

SBM-2_02

The key stakeholders based on their position in the value chain are:

Up the value chain:

1. Suppliers and Service Providers: These provide the materials and services necessary

for the operation of EYDAP SA.

2. Tier 1 Supplier Employees: These employees work directly with EYDAP SA and

contribute to the implementation of projects.

3. Society: Includes Non-Governmental Organizations (NGOs), local communities and

ecological organizations that cooperate with EYDAP SA for the sustainability and

protection of water resources.

4. Water users in water abstraction areas: These are the consumers who depend on the

supply of drinking water and sanitation services.

5. Governments in key supplier countries: These governments influence the operation

of EYDAP SA through regulation and supplier support.

6. EUDAP'S FIXED ASSETS

Same Function:

1. Employees: The employees of EYDAP SA who work directly for the provision of

services.

2. Subcontractor workers: these workers fall into two categories:

● Those who work in EYDAP SA facilities.

160

● Those who work off-site, such as on damage repair and network maintenance

projects.

3. Investment Community: It includes shareholders and investors who financially

support EYDAP SA.

4. Financial Institutions: Banks, insurance companies and financial institutions that

provide financial support to EYDAP SA.

5. Society: Includes Non-Governmental Organizations (NGOs), local communities and

ecological organizations that cooperate with EYDAP SA to promote sustainable

practices.

6. State: Ministries and authorities with regulatory responsibilities, such as the Ministry

of Environment and the Ministry of Finance, which influence the operation of EYDAP

SA through regulations.

7. RAEAY: The regulatory body that oversees the operation of EYDAP SA.

8. EUROPE ISLANDS DEVELOPMENT COMPANY

Downstream Value Chain:

1. O.T.A (Local Authorities): these include the local authorities within the area of

responsibility of EYDAP SA, excluding the local authorities of East Attica.

2. O.T.A of Eastern Attica: The local authorities located in East Attica and cooperating

with EYDAP SA.

3. Local authorities and municipal water supply and wastewater utilities outside the

EYDAP SA Area of Responsibility: these local authorities and municipal water supply

and wastewater utilities, to which EYDAP SA already provides or may provide services.

4. Public bodies: These entities act as consumers of the services of EYDAP SA.

5. Large Customers: Customers who for operational reasons require special

management and use the services of EYDAP SA.

6. Customers: General consumers of water supply and sewerage services of EYDAP SA.

7. Society: Includes Non-Governmental Organizations (NGOs), local communities and

ecological organizations that cooperate with EYDAP SA to promote sustainable

practices.

8. State: Ministries and authorities with regulatory responsibilities, such as the Ministry

of Environment and the Ministry of Finance, which influence the operation of EYDAP

SA through regulations.

161

SBM-2_03

The Company is in constant communication with its stakeholders in order to strengthen the

relationship of trust with them. The frequency of communication with stakeholders is shaped

based on the specifics and needs of each group.

For the description of the parts concerned please refer to SBM-2_04 & SBM-2_06.

SBM-2_04 & SBM-2_06

During the Double Materiality analysis, the impacts and their assessments were presented to

stakeholder representatives to take their opinion into account in the final formulation.

● Employees

In EYDAP SA, communication and training are carried out through daily interactions,

emails and inspections. Employees are updated through the Intranet (thalassa) and

participate in training sessions and annual workshops. The weekly electronic magazine

"OUR SOURCE" provides important information and employees participate in

volunteer activities. The Annual Sustainability Report and participation in an Annual

Workshop highlight the company's commitment to sustainable practices.

● Customers

EYDAP SA offers a variety of ways of communication and service for its customers.

Customers can have personal contact at the Regional Centres or communicate via

email. The company provides 24-hour telephone service through the number 1022,

and is also active on social media and its corporate website.

For free service, customers can use the Click2Call and call back service. In addition,

online processing of requests is available through the eEYDAP and EydApp platforms.

EYDAP SA also conducts customer satisfaction surveys and customers participate in

the prioritization process of Material Issues, ensuring that their needs are taken into

account.

● Large Customers and Public Sector Entities

EYDAP SA provides many ways of communication and service for its customers and

public authorities. Customers can communicate in all the aforementioned ways.

162

● Suppliers / Service Providers to EYDAP SA

EYDAP SA ensures effective communication with its Suppliers/Service Providers

through personal contacts and email communication. In addition, on-site visits are

carried out to better serve them, and the company is continuously launching tenders

for projects, enhancing transparency and competitiveness. In addition,

communication is carried out through the ESIDES platform.

● Local authorities and public utilities outside the Area of Responsibility of EYDAP SA

(to which EYDAP SA already provides or may provide services)

EYDAP SA cooperates with local authorities and public utilities outside its area of

responsibility, to which it already provides or can provide services. The communication

with these entities is done through personal contacts, email and telephone calls.

● O.T.A. (within the Area of Responsibility of EYDAP SA, excluding O.T.A. East Attica)

EYDAP SA cooperates with local authorities within its area of responsibility, excluding

local authorities. East Attica. The communication with these entities is carried out

through personal contacts, email and telephone calls. Information and services are

also available through the corporate website of EYDAP SA. The local authorities are

involved in the prioritisation process of the Essential Issues, ensuring that their needs

are taken into account.

● O.T.A. of Eastern Attica

EYDAP SA maintains continuous personal and email communication with the local

authorities. East Attica for the effectiveness of the projects. It has created a special

website entitled "Clean Water of East Attica" to inform citizens. In addition,

information events are organised with the presence of local government

representatives and open discussions with the public.

● State (Ministry of Environment, Ministry of Finance, Region of Attica) / Authorities

with Regulatory Responsibilities

EYDAP SA maintains personal and email communication with the State, including the

Ministries of Environment and Energy (Ministry of Environment and Energy), Finance

(Ministry of Finance) and the Region of Attica, as well as with other authorities with

regulatory responsibilities. EYDAP SA executives participate in legislative committees,

contributing to the formulation of policies and regulations. Information and services

are available through the corporate website of EYDAP SA. In addition, the authorities

are involved in the prioritisation process of Material Issues, ensuring that their needs

are taken into account.

● RAAEY

EYDAP SA maintains personal and email communication with the Waste Energy and

Water Regulatory Authority (Waste Energy and Water Regulatory Authority). In

addition, EYDAP SA participates in the Essential Issues prioritization process, ensuring

that the needs and priorities of the Waste Energy and Water Regulatory Authority are

taken into account.

163

● Investment Community

EYDAP SA maintains personal and email communication with the investment

community, including shareholders and investors. It organises extraordinary and

regular shareholders' meetings on an annual basis, where financial results are

presented on an annual and half-yearly basis. Non-financial information is also

provided and current business developments are communicated through press

releases.

● Financial Institutions

EYDAP SA maintains personal and email communication with financial institutions,

such as banks, insurance companies and financing institutions.

● Business/industry bodies and networks

EYDAP SA maintains personal and email communication with business and industry

bodies and networks. These stakeholders are involved in the prioritisation process of

Material Issues, ensuring that their needs and priorities are taken into account.

● Society (NGOs, local communities, ecological organisations)

EYDAP SA maintains communication with the society, including Non-Governmental

Organizations (NGOs), local communities and ecological organizations, through the

corporate website and email.

● Mass media

EYDAP SA maintains communication with the media through press releases and press

briefings. Information is also available through the corporate website and social

media.

The Strategy focuses on Safety, Efficiency and Growth and has not been differentiated, as it is

a long-term strategy that serves the Vision and Mission of EYDAP SA. However, in 2024 even

more emphasis was placed on operational resilience and climate change adaptation issues.

The Company's Strategy is aligned with the interests and views of its stakeholders, always

guided by the ESG criteria.

The Company is considering alternative water supply scenarios for the coming years. One of

the options activated is pumping from Yliki and reopening the Mavrosouvala wells. In the

medium term, the integration of new reservoirs and the enrichment of the underground

aquifer with recycled water from the KELs are being considered. Other options include

desalination, a solution widely used in other countries, as well as water transport by

waterways. EYDAP SA, aware of the new challenges, is adapting its strategy accordingly and

preparing for the implementation of the best solutions. In this context, it has also amended its

statutes in order to have the necessary flexibility for the implementation of the above. These

measures are expected to strengthen the confidence and positive opinion of EYDAP's

stakeholders towards it.

164

SBM-2_12

The list of identified stakeholders was updated and approved by the Senior Management

(CEO). The frequency and manner of communication with our stakeholders follows specific

procedures.

Communication with stakeholders may be structured (e.g. analysts and stock market

representatives are informed about the Company's performance twice a year with the

announcement of the half-yearly and annual financial results) or unstructured (e.g. the

response to a specific consumer request regarding a specific issue).

With regard to internal procedures, regular and periodic meetings are held between the CEO

and the General Managers and Independent Directors directly reporting to him, as well as with

the respective General Management and Independent Directorates, in which the

Management has the opportunity to be informed, inter alia, on issues related to the different

stakeholders, risk and opportunity assessment and decision making through the appropriate

communication channels. The heads of the organisational units, through their

recommendations to senior management, propose actions to solve the problems that arise

and make use of the corresponding opportunities.

S1.SBM-2_01

In the Company's Strategy, the essential issues include the health, safety and development of

employees and ensuring respect for human rights, which are ensured through relevant

regulations and policies.

The company systematically interacts with employees by:

● Daily personal and email updates

● Inspections

● Internal website "Aqua portal"

● Trainings

● Participation in annual workshops

● Weekly electronic magazine "OUR SOURCE"

● Participation in the prioritisation process of Substantive Issues

● Voluntary actions

● Annual Sustainable Development Report

● Participation in Annual

Furthermore, EYDAP SA has established the Internal Protection and Prevention Service which

communicates openly and transparently with all stakeholders in order to identify and address,

as soon as possible, any potential risks. In accordance with the legislation in force (Presidential

Decree 17/1996, Law 3850/2010), an Employee Health and Safety Committee (EHS

165

Committee) has been established by the employees, an advisory body composed of elected

employee representatives, with the power to identify occupational hazards.

S2.SBM-2_01

In November 2022, EYDAP SA adopted a Human Rights Policy which also binds the Company's

partners (contractors, suppliers, service providers, etc.). To the extent permissible under the

national legal framework on Public Procurement, EYDAP SA has incorporated and faithfully

applies in its supply chain contracting procedures, the terms of compliance of

Suppliers/Service Providers with the Principles of the UN Global Compact in the areas of

Human Rights, Labour, Environment and Corruption, ensuring that all Suppliers/Suppliers of

Supply Chain Services implement practices that promote respect for human rights and are in

line with the Company's policies on social, labour and environmental issues. In addition to the

contractual obligation to comply with the provisions of environmental, social security and

labour legislation, established by Union law, national law, collective agreements or

international provisions of environmental, social and labour law, which are listed in Annex XIV

of Appendix B of Law No. 4412/2016 and depending on the scope, the contractors shall

provide evidence such as certifications for quality, environmental, labour, energy management

(ISO 90001, FCS, ISO 14001, 45001, 50001).

S3.SBM-2_01

EYDAP SA in accordance with its three strategic axes -safety, efficiency and growth- aligned

with ESG criteria, especially in the area of society and attempting to create increased social

value, has an active contribution to the environmental awakening of citizens, the

strengthening of society and the cultivation of environmental culture.

EYDAP SA follows a sustainable development strategy and has defined key strategic priorities

that correspond to the three ESG pillars - Environment, Society, Governance - and are directly

related to the corporate strategic pillars of Safety, Efficiency and Growth.

The Company faithfully serves the sustainable development strategy it has adopted,

monitoring the results of its active contribution to the environmental awareness of citizens,

the strengthening of society and the development of environmental culture, creating

increased social value.

More specifically:

In terms of environmental impact (E), EYDAP SA focuses on the sustainable management of

natural resources and water sources, the protection of ecosystems and the reduction of its

carbon footprint, adopting the principles of the circular economy.

In terms of social impact (S), it provides services and implements projects that improve the

quality of life of citizens while ensuring affordable tariffs and social policies that mitigate

inequalities. It strengthens local communities by taking a leading role in integrated local

166

development approaches. Essential issues are health, safety of workers and consumers and

the development of workers, while ensuring equal opportunities and the right to diversity.

In terms of corporate governance (G), the key strategic issues of EYDAP SA are the composition

of the Board of Directors in accordance with the principles of sustainable development, the

fight against corruption, financial performance and operational resilience, effective supply

chain management and the protection of personal data.

S4.SBM-2_01

The Company conducts, as part of its strategy, on a regular basis, customer satisfaction surveys

and analyses the results obtained, taking measures for improvement and setting new targets.

The Human Rights Policy and the Charter of Obligations to the Consumer form the framework

for the operation of its organisational units.

167

[SBM-3] Significant impacts, risks and opportunities and their interaction with the strategy and

business model

SBM-3_01

EYDAP S.A., as the exclusive provider of water supply and wastewater services in the Attica

basin, recognizes the environmental impacts of its activities, such as water consumption, and

is committed to managing water resources responsibly and sustainably. At the same time, it

ensures citizens' access to clean water and sanitation, enhancing public health and quality of

life.

In addition, EYDAP S.A. actively contributes to society by promoting access to a living wage,

creating employment opportunities, developing infrastructure and preserving cultural

heritage. Its contribution strengthens the social and economic development of the areas

where it operates. The impact of its activities is mainly in its core operations, but also at all

stages of the value chain, affecting suppliers, customers and the wider community.

SBM-3_02

For the risks and opportunities identified as significant in the relevant assessment, the table

below summarises their descriptions and the point in the value chain where they arise:

Table3 . Significant Risks and Opportunities and interconnection with the value chain

Financially significant sustainability risks and

opportunities

Value Chain

N/A

The use of alternative fuels, renewable energy sources

and on-site electricity generation can affect both the

cost and reliability of energy supply.

Ananti

Opportunity

Ineffective measures to protect the Company's facilities,

the non-use of Personal Protective Equipment (PPE) by

employees in designated areas and the creation of

conditions that do not ensure health and safety in all

EYDAP SA facilities may result in fines, increased

workers' compensation, higher insurance premiums,

reduced productivity and possible damage to the

Company's reputation.

Same Function

Danger

Inefficient operation of a signal reception centre due to

the non-use of electronic surveillance systems (CCTV),

or due to the use of old technology alarms, resulting in

inaccurate fault detection due to extreme weather

events that are increasing in the context of climate

change may lead to economic impacts

Same Function

Danger

Risk of a Personal Data Breach that may lead to

reputational risk and fines

Same Operation

/ Downstream

Danger

Difficulty recovering and continuing operations in the

event of cyber-attacks can lead to significant financial

losses and reputational risk.

Downstream

Danger

Unsafe water supply of Attica due to failure of the EWS

due to climate change (drought/snowfall/floods) may

lead to economic impacts.

Same Function

Danger

168

Water scarcity due to drought and lack of rainfall may

result in inadequate supplies or mandatory water

restrictions that affect the entity's value financially

through reduced revenues

Same Operation/

Downstream

Danger

As the likelihood of extreme weather events increases,

entities that address these risks through strategic

planning can keep water quality intact and serve

customers consistently.

Downstream

Opportunity

SBM-3_03 & SBM-3_04

EYDAP SA recognised and assessed the risk of unsafe alternative water supply to Attica due to

the failure of the EHS unified aqueduct, which is owned by the State. In the framework of an

Agreement with the Greek State, the execution of specific projects is being promoted that will

shield the secure water supply against very high risks of failure of the union aqueduct. At the

same time, the necessary control mechanisms have been identified and are under discussion

with all stakeholders to ensure the uninterrupted supply of quality water to EYDAP SA during

extreme weather events along the entire length and facilities of the EIS.

EYDAP SA has set as a priority the shielding of the company through an organised cybersecurity

framework, always in line with the current legislative provisions. In the year 2023, immediate

response services were ensured in case of detection of a cybersecurity incident, by

participating in the funded Cybersecurity Support Services Action of ENISA (European Union

Agency for Cybersecurity) through the National Cybersecurity Authority for Member States'

NSAs.

The Adrianaios Aqueduct project in Halandri, which was completed in June 2024 under the

European Cultural H.ID.RA.N.T. - UIA project, has significant impacts on both the business

model and the environment. This project led to the creation of the first urban non-potable

water network in Greece, 4 km long. The water from the Adrian Aqueduct, after proper

treatment, is distributed through modern underground tanks and pumping stations and used

for irrigation, purification and other non-potable uses, benefiting all residents of Halandri.

Material impacts and opportunities arising from the project include enhancing resilience to

water scarcity by providing an alternative water source. In addition, it helps to address urban

warming by supporting green spaces, and promotes adaptation to climate change. The project

protects natural drinking water resources by reducing dependence on drinking water for non-

potable uses, and promotes rational water management. EYDAP SA's strategy for sustainable

development and the principles of the circular economy are confirmed through this project.

The new network offers savings in drinking water, energy costs and well maintenance costs, as

well as cost savings from high drinking water tariffs.

In addition, it ensures a constant quantity and quality of non-potable water at a low price. The

project also has a significant impact on people and the environment. Positive impacts include

saving drinking water for essential uses, informing and educating the community about

sustainable water use, and highlighting the historical significance of the aqueduct. The project

contributes to the protection of natural water resources. However, there are negative impacts,

169

such as temporary disruptions during construction and maintenance requirements to ensure

system efficiency.

Water Consumption

EYDAP SA recognizes that water consumption is a significant challenge for its business model,

directly affecting its value chain, strategy and decision-making processes. The climate crisis has

led to a 35% decline in water reserves over the last two years, with reserves falling from 1,100

million cubic meters in October 2022 to below 700 million cubic meters today.

In response, EYDAP SA has developed a comprehensive action plan that includes:

● Short-term measures: Activation of drilling in Mavrosovala and Yliki with the aim of

recovering about 75 million cubic metres of water per year.

● Medium-term measures: Implementation of a €2.16 billion investment programme,

including optimisation of the water supply network, replacement of old pipelines and

installation of smart meters.

● Long-term measures: Consideration is being given to enhancing the Evinos reservoir

from rivers feeding the Lake of Kremasta, and the use of recycled water from Psyttalia,

Thriasio and Koropi-Peania for industrial use and irrigation. At the same time, the

company promotes information campaigns to raise public awareness on water

conservation, encouraging the adoption of responsible consumption habits. Through

these initiatives, EYDAP SA is adapting its strategy and business model, aiming at

sustainable management of water resources and ensuring the uninterrupted provision

of high quality water supply and wastewater services.

In addition, EYDAP SA, in the context of its commitment to sustainable development and social

well-being, implements a series of actions that have positive impacts of high importance to

both the economy and society.

Accessibility to a living wage

The company provides for the welfare of its employees through special benefits that support

their families. These include the provision of wedding gifts, coverage of nursery costs, as well

as financial support for foreign language learning and children's participation in camps and

summer camps. These benefits enhance the quality of life of employees and their families by

ensuring a supportive working environment.

Contribution to employment

The operation and development of EYDAP SA's projects has a direct positive contribution to

the local economy, creating new jobs and offering opportunities for professional development.

The company is the largest purchaser of specialized water supply and sewerage products and

services in Greece, maintaining jobs with its suppliers. In addition, the expansion of the Koropi

Wastewater Treatment Plant is expected to further boost employment and create new

economic benefits for the local community.

Infrastructure development

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The investment in the development of water supply and sewerage infrastructure in the

prefecture of Attica is estimated to have a significant positive impact on the local community.

The construction and operation of these infrastructures contributes to improving the living

standards of residents, boosts the local economy and leads to an increase in land value due to

the improvement of the quality of life and accessibility of the area.

New urban wastewater collection and treatment infrastructure plays a crucial role in public

health and in improving living conditions in the settlements served. Proper treatment of

wastewater protects the environment and reduces the risks of pollution. At the same time,

this infrastructure enhances the development of man-made activities, contributing to

sustainable development and increasing the attractiveness of the area for permanent

residence.

Access to sewerage

EYDAP SA ensures public health and hygiene by collecting wastewater through its sewerage

network and treating it at the Wastewater Treatment Centres. EYDAP SA maintains, repairs,

supervises and upgrades the operation and infrastructure of the sewerage system. In this way

it protects the environment and reduces the risks of pollution, thus contributing to sustainable

development.

Access, participation and safeguarding of cultural heritage

Through the initiative for the revival of the Adrianio Aqueduct, EYDAP SA supports the

preservation and promotion of cultural heritage, not only in the local community of the

Municipality of Halandri, but also in the wider region. This action connects history with the

present, highlighting the value of cultural heritage through modern water resource

management.

An important initiative of the Society for the preservation of cultural heritage is the

establishment and preservation of its Historical Archive.

The establishment of a Corporate Historical Archive Management Policy in 2018 reflects the

Company's commitment to the uniform management of its important cultural heritage, with

the ultimate goal of preserving, promoting and utilizing historical documents. The Historical

Archive of EYDAP SA consists of documents that record the history of the Company and the

People that make up the Company, namely photographic material, audiovisual material, paper

material - documents and objects.

Access to water

EYDAP SA ensures the adequacy and quality of the water supplied, in accordance with the

requirements of the legislation on drinking water. At the same time, it applies social tariffs for

vulnerable social groups, such as large families and senior citizens, offering reductions in water

bills. In this way, it contributes to social cohesion, solidarity and sustainable development.

The detailed assessment of the double materiality analysis highlights the different nature of

our impacts in different segments. We identified the impacts we create on the environment

and people through our business model and value chain activities, as well as our business

171

relationships with our stakeholders. All of our impacts are linked to ESRS themes, sub-themes

and sub-sub-themes.

We identified a significant negative impact which is referred to as 'Water' and relates to both

abstraction and consumption of water, which is covered in detail under ESRS E3 and as a

positive impact which is referred to as 'accessibility to living wage', 'contribution to

employment', 'infrastructure development', 'access to sanitation', 'safeguarding cultural

heritage' and 'access to water', which are covered in more detail under local ESRS S1, S2, S3,

S4.

SBM-3_05

EYDAP SA, as the main provider of water supply and wastewater services in Attica, recognizes

that water consumption is a central element of its business model and strategy. Increased

demand for water, combined with the effects of climate change, directly affects the availability

of water resources, which may lead to a reduction in reserves and affect the company's ability

to provide its services without interruption.

To address these challenges, EYDAP SA has incorporated a ten-year investment plan in its

strategy. In 2024, the project investment plan absorption amounted to EUR 60.7 million, an

increase of 27% compared to the absorption in 2023. 24% of the 2024 absorption was paid by

the EU.

The absorption is divided into :

● major projects in East Attica (€34.6 million)

● water supply network projects (€14 million). The projects include the Adrianio project

with an absorption of €0.7 million. €.

● sewerage projects (€11.2 million)

● building, digital governance and transformation projects (€0.9 million)

In addition, the Company promotes information campaigns to raise public awareness on water

conservation, encouraging the adoption of responsible consumption habits. In the summer of

2024, a public information & awareness campaign was launched to avoid wasting water

entitled "Do you want water? Turn off the tap!" It was an invitation to citizens to make the

right choices for proper water management by changing simple, everyday habits. The ways of

disseminating the information were through Press Release, Radio spot, Display (Banners &

Advertorials), Hybrid TV, Rich Media (Mobile Interactive/Animation), Interview & Statements

to Media, Direct Mail, Letter to OTAs, Recorded message for 1022, EYDAP Social Media.

Through these initiatives, EYDAP SA is adapting its business model and strategy, aiming at the

sustainable management of water resources and ensuring the continuous provision of high

quality water supply and wastewater services.

SBM-3_06

172

The time horizon of the impacts covers both the current situation (2024) and the future (2025-

2030 & beyond 2030).

SBM-3_07

EYDAP S.A., as the main provider of water supply and wastewater services in Attica, recognises

that its main environmental impacts arise from its activities. These include the pumping,

treatment and distribution of water, as well as the collection and treatment of wastewater,

which directly affect water resources and the natural environment.

In addition, EYDAP S.A. cooperates closely with suppliers and contractors for the construction,

maintenance and upgrading of its infrastructure. Through these partnerships, spill-over effects

may arise concerning waste management and rational use of resources.

The company is committed to minimising the environmental impact of its activities by adopting

policies and procedures that promote the sustainable management of water resources and

the preservation of the environment, ensuring a long-term positive impact on its areas of

operation.

SBM-3_08

The assessment of the identified risks and opportunities (ERs) did not identify any significant

ERs for the current period.

SBM-3_10

The Board of Directors ensures the supervision and management of the Company's

Sustainable Development issues, within the framework of the Company's strategic planning.

During its meetings, it discusses objectives related to sustainable development issues.

In the context of the Sustainable Development Policy, the Board of Directors identifies in the

Annual Management Report the non-financial issues that are deemed essential for the

implementation of its vision and strategy, taking into account the requirements of its

stakeholders.

The Board of Directors is assisted by the Strategy, Innovation and Sustainable Development

Committee in all the above responsibilities.

The Committee shapes the Company's strategy by setting its strategic priorities and objectives

in the context of Sustainable Development.

It informs, analyses, evaluates and advises the Company's Management and the Board of

Directors on issues of the Company's general strategy and specifically on issues of strategy for

new technologies and innovation, digital transformation, cybersecurity and sustainability,

using innovative technologies.

EYDAP SA manages its operational risks through procedures to identify, assess, mitigate and

monitor potential risk events or occurrences in order to support the achievement of its

business objectives in accordance with the requirements of the COSO ERM Framework (COSO

173

ERM Framework). Operational risk management is an integral part of the implementation of

the corporate strategy approved by the Board of Directors and implemented by management

and staff.

The Risk Management Division is not a substitute for the Company's executive functions in

terms of their responsibility for implementing an effective framework of controls.

The Risk Management Division manages, monitors and improves the Risk Management

Framework on an ongoing basis in order to support the Company in achieving its objectives.

The category of ESG risks has been included in the Operational Risk Register.

ESG risks have been added to the approved Risk Allocation Framework which lists 4

types/categories of risks (operational, financial, compliance, strategic). ESG risks have been

classified under each of the above mentioned risk types.

SBM-3_12

All impacts of EIF activities as well as associated risks & opportunities are linked to ESRS

Themes, Sub-Themes and Sub-Sub-Themes.

174

Table4 . Impacts, risks and opportunities and their linkage with the ESRS Themes

Impacts, risks and opportunities (IROs

ESRS issues

ESRS Subjects

ESRS Sub-stocks

Climate Change

E1 Climate Change

Climate change mitigation

The use of alternative fuels, renewable energy sources and on-site electricity generation can affect

both the cost and reliability of energy supply.

E1 Climate Change

Energy

Inefficient operation of a signal reception centre due to the non-use of electronic surveillance

systems (CCTV), or due to the use of old technology alarms, resulting in inaccurate fault detection

due to extreme weather events that are increasing in the context of climate change may lead to

economic impacts

E1 Climate Change

Adapting to climate change

Unsafe water supply of Attica due to failure of the EWS due to climate change

(drought/snowfall/floods) may lead to economic impacts.

E1 Climate Change

Adapting to climate change

As the likelihood of extreme weather events increases, entities that address these risks through

strategic planning can keep water quality intact and serve customers consistently.

E1 Climate Change

Adapting to climate change

Water use

E3 Water and marine resources

Water

Water consumption

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Water scarcity due to drought and lack of rainfall may result in inadequate supplies or mandatory

water restrictions that affect the entity's value financially through reduced revenues

E3 Water and marine resources

Water

Water pumping

Ineffective measures to protect the Company's facilities, the non-use of Personal Protective

Equipment (PPE) by employees in designated areas and the creation of conditions that do not ensure

health and safety in all EYDAP SA facilities may result in fines, increased workers' compensation,

higher insurance premiums, reduced productivity and possible damage to the Company's reputation.

S1 Domestic labour force

Working conditions

Health and safety

Loss of life, injuries and illnesses

S1 Domestic labour force

Working conditions

Health and safety

Risk of a Personal Data Breach that may lead to reputational risk and fines

S1 Domestic labour force

Other labour rights

Privacy

Accessibility to a living wage

S1 Domestic labour force

Working conditions

Adequate wages

Contribution to employment (direct/indirect)

S1 Domestic labour force

S2 Workers in the value chain

Working conditions

Secure jobs

Development of infrastructure

S3 Affected communities

Social rights of communities

Clean water and sanitation

Access to sewerage

S3 Affected communities

Social rights of communities

Clean water and sanitation

Access, participation and safeguarding of cultural heritage

S3 Affected communities

Rights of indigenous

communities

Cultural rights

Water scarcity due to increased drought and lack of rainfall may result in mandatory water

restrictions that financially impact the value of the entity through reduced revenues

S3 Affected communities

Economic, social and cultural

rights of communities

Economic, social and cultural

rights of communities: clean

water and sanitation

176

Difficulty recovering and continuing operations in the event of cyber-attacks can lead to significant

financial losses and reputational risk.

S4 Consumers and end-users

Impacts related to information

for consumers and/or end-users

Privacy

Access to water

S4 Consumers and end-users

Social inclusion of consumers

and/or end-users

Access to products and services

Risk of a Personal Data Breach that may lead to reputational risk and fines

S4 Consumers and end-users

Personal safety of consumers

and/or end-users

Health and safety, Privacy

177

Memo

Positive impact on the environment

Negative impact on the environment

Positive impact on society

Negative impact on society

Risk

Opportunities

178

Impact, risk and opportunity management

Notifications on the materiality assessment process

[IRO-1] Description of procedures for identifying and assessing significant impacts, risks and

opportunities

IRO-1_01_07_08

In 2024, we conducted a double materiality analysis based on the requirements of the European

Sustainability Reporting Standards (ESRS). We regularly assess our impacts on people and the

environment as part of our day-to-day operations, working with relevant stakeholders and experts.

These ongoing steps allow us to actively identify and manage our impacts, risks and opportunities as

we evolve and as new ones arise. At the same time, we have developed a robust risk management

process that incorporates the risks and opportunities arising from sustainability issues.

We followed a top-down approach at the Group level to identify, assess and prioritise impacts, risks

and opportunities (IROs) for both the environment and society.

Specifically, for impacts on the environment, in order to determine the appropriate scope to be used

to identify impacts in the context of a commonly established impact classification, we used the nature

change impact guides within the Taskforce on Nature-related Financial Disclosures (TNFD).

Similarly, to identify impacts on people within an appropriate scope with a commonly established

impact classification (for social and socio-economic impacts - which are absent from the ESRS), we

used the UNEP Impact Radar (impacts on the environment within the UNEPFI were not used as the

TNFD impact guide categorisation was used).

However, it should be clarified that all actions taken to mitigate any negative impacts are not

considered positive impacts, but mitigation actions. Therefore, their mapping is considered

complementary to the identification of negative impacts and is intended to facilitate the prioritisation

of impacts, risks and opportunities, based on existing sustainability objectives.

In assessing the significance of both actual and potential impacts, we categorise the severity of

current impacts into three dimensions: scale, extent and remediability. For potential impacts, we

assess them based on severity and likelihood. Current impacts are identified by examining the

interface between activities and nature. Similarly, potential impacts are identified using the ENCORE

platform, which provides us with scientific information on the pollution impacts of our sector and our

value chain.

Identifying and assessing financial risks and opportunities related to sustainability is a critical step in

developing a sustainable development strategy. During the process of identifying risks and

opportunities (RIs), EYDAP SA took into account its existing Risk Register while also considering RIs

that may arise from its positive and negative impacts on the environment and people, as well as RIs

arising from dependencies along its value chain, using the ENCORE tool for their identification.

Each CC that has been identified has also been associated with the part of the value chain where it is

created, and is classified as an environmental, social or governance CC.

IRO-1_02

179

The process encompasses all parts of our value chain, including upstream, own operations and

downstream. To enable the identification and assessment of impacts, both internal and external

sources were used to understand the causes of the various impacts. Impacts were rated on a scale of

1 to 5 based on quantitative and qualitative criteria and categorized according to the topic of the

impact they affect.

IRO-1_03

The aspects of the business model that were analysed at Group level included:

● Main activities of the business model, including water supply and sewerage and the

distribution of water to consumers, as well as secondary activities such as energy production

and raw material for the cement industry.

● Main inputs of the business model (including raw materials (flocculants, chlorinators, etc.)

and other supplies)

● Main outputs of the business model (including main products)

● Main externalities (e.g. greenhouse gas emissions, waste, etc.)

IRO-1_04_05

The identification and assessment of impacts were carried out throughout the value chain (upstream,

own activities, downstream), and the assessment of their significance was carried out through the

process of double materiality analysis which was carried out in accordance with the requirements of

Directive (EU) 2023/2772. As part of the identification and assessment of existing and potential

impacts, communication with affected stakeholders (employee representative, Ministry of

Environment and Energy) was carried out.

IRO-1_06

Existing adverse effects on humans and the environment have been assessed on the basis of the

severity of the effects in terms of scale, scope and irreparability, in accordance with the ESRS 1

guidelines. The actual positive effects on the environment and humans were assessed on the basis of

the significance of the effects in terms of scale and extent. In terms of potential negative and positive

impacts on the environment, we also considered the likelihood of impacts. With regard to the

assessment of potential effects on humans, their severity outweighs their likelihood, as defined by

ESRS 1.

IRO-1_07

Any JI that falls into the environmental or social JI categories is also classified according to the TCFD

categorisation. The magnitude of the financial impacts is then assessed over four time horizons. The

current year (2024), the short term horizon (2025), the medium term horizon (2030) and the long

term horizon (>2030). For all future horizons the scoring of CCs is based on a combination of the

180

magnitude of the financial horizon and the probability of occurrence. Both of these sizes are assessed

based on the scales presented previously resulting in the intrinsic risk score heat map.

IRO-1_09

For the identification of risks, the already recognized risk register of EYDAP SA, the ENCORE tool (in

order to identify risks and opportunities (CE) arising from environmental dependencies) and the SASB

standards were used as sources. The resulting list of CDs was then evaluated for each CD by all

individual relevant Directorates and the final score was derived as the highest score given by the

Directorates. The score is derived from the quantitative scale below, which the individual Directorates

use to carry out a qualitative analysis of the financial impact of the JUs:

Table5 . Financial Impact Assessment Scale

Size of Financial Impact

Ranking

Score

> EUR 5,000,000

Very High

EUR 500,000 - 5,000,000

High

100,000 - 500,000 euros

Medium

10,000 - 100,000 euros

Low

<10,000 euros

Very Low

At the same time, the probability of occurrence was assessed for the potential CCs according to the

following scale:

Table6 . Probability Ranking Table

Probability

Ranking

Score

Monthly

Very Possible

2 times a year

Possible

Annually

Medium Probability

Every 2-5 years

Minimal Possible

Every 5 years or more

Not at all likely

Based on the above scales, the significance thresholds for the current time horizon were set at above

4, corresponding to a high and very high financial impact magnitude, and for potential JI at above 15,

corresponding to high risk, based on the heat map below:

Table7 . Heat map of financial impact magnitude and likelihood

Size of Financial

Impact

Average

High

Average

High

Low

Average

High

Low

Average

Low

Average

181

Probability

IRO-1_10

EYDAP SA, taking into account the direct and indirect impacts of global conditions due to climate

change as well as the short/long-term instabilities in local and international markets (such as the

recent energy crisis), examines the potential operational risks it faces, mainly financial, operational

and reputational, adopts and applies sustainable practices and an integrated approach to their

identification, assessment and minimization through appropriate control mechanisms, in order to

address the risks to the company's business and its reputation.

IRO-1_12

The Risk Management Division monitors the impact of extraordinary events and initiates actions to

reassess the risks associated with them identifies emerging risks and monitors their evolution to

facilitate timely corrective actions and mitigation of their impact.

It should be noted that the Risk Management Division is not a substitute for the Company's executive

functions in terms of their responsibility for implementing an effective framework of controls.

IRO-1_14

A variety of external and internal data sources were used to identify the impact of risks and

opportunities. Indicatively, the following are mentioned below:

● ENCORE

● TCF

● TNFD

● SASB

● Risk Register

● CDP assessments for water and climate

● sustainability report

● Environmental Impact Studies

IRO-1_15

For the current reporting period, the process has changed, compared to the previous reporting

period, as a dual materiality analysis is followed, based on the requirements of ESRS, looking at the

company's impact on the environment and people as well as the risks and opportunities arising from

the environment and people in the company.

182

E1.IRO-1_01

EYDAP SA, recognising the importance of climate change and its impacts on its business activities, has

developed a systematic process to identify and assess climate-related impacts, risks and

opportunities, focusing in particular on the greenhouse gas (GHG) emissions resulting from its main

activities. The process is related to the calculation of GHG emissions, which is carried out in

accordance with the following:

1. ISO 14064-1:2018 Greenhouse gases - Part 1: Specification with guidance at the organization

level for quantification and reporting of green-house gas emissions and removals.

2. Greenhouse Gas Protocol, WRI (GHG Protocol Corporate Accounting and Reporting Standard,

Revised Edition).

At the same time, following the calculation of emissions, EYDAP SA, through the double materiality

analysis, examines the existing and potential impacts of climate change on the company, as well as

its impacts on the climate. The materiality of the impacts is based on the severity and significance of

the impacts, which are related to the following factors:

a) the scale,

(b) the extent and

Specifically, the gases that have been measured are:

● Carbon dioxide CO

● Methane CH

● Nitric oxide N

● HFCs

The infrastructure of EYDAP SA that are counted in the carbon footprint measurement include:

● 4 Water Treatment Units

● 5 Waste water treatment centres

● Water supply network

● Sewerage network

● Drilling Mavrosouvalas

● Small Hydroelectric Power Plants (SHPs)

● CCI of Thebes & 4 accompanying pumping stations of the RES of Thebes

● Owned and rented buildings

● Fleet of owned vehicles and machinery

E1.IRO-1_02 & 06-08 & 11 & 15 & 17-18

183

The resilience analysis of the strategy and business model of EYDAP SA started in 2023 with the

intrinsic and residual assessment of the identified business risks in order to prioritize them in terms

of their importance for further mitigation.

The identification, assessment and management of potential risks are very critical and important

factors that the Company manages with great care and invests resources and personnel to properly

assess them. By extension, as part of strengthening the resilience of the Company's strategy and

business model in relation to climate change, the Company is in the process of assessing climate risks

taking into account the most up-to-date scientific data and climate scenarios, and will be periodically

updated to ensure continued adaptation to changing climate conditions.

The analysis will use three climate scenarios to assess the risks and opportunities and their impacts

on EYDAP SA. These scenarios are common sets of assumptions derived from the discrete

combination of two widely used climate pathway scenarios, namely representative concentration

pathways (RCPs) and common socio-economic pathways (SSPs). Until the IPCC's 5th Assessment

Report (AR5, 2014), RCPs were the basis for climate scenario analysis, while combined scenario

modelling of SSPs and RCPs was first carried out by the IPCC in the 6th Assessment Report, which was

issued in 2023. Based on this methodology, anthropogenic CO

emissions appear to be slightly

different from those of RCP scenarios only, and thus climate and weather events are also expected to

show small differences. In view of the above, the assessment of the likelihood of a natural climate

risk occurring will be based on the RCP modelling assumptions in line with the IPCC 5th Assessment

Report. The climate scenarios that will be used for the assessment of risks and opportunities and their

impacts in the EIA are RCP4.5 and RCP8.5 for the natural hazards analysis and the RCP1.9 scenario

that is in alignment with the IEA NZE, as presented in more detail below:

Table8 . Description of climate scenarios

MISSION NZE / RCP1.9

Zero balance emissions scenario

RCP4.5

Moderate emissions scenario

RCP8.5

Uncontrolled emissions scenario

RCP1.9 is the IPCC's lowest

emissions pathway that focuses

on limiting warming to below

1.5°C by the end of the century,

which is the intended target of

the Paris Agreement and is in full

alignment with the IEA NZE. It

signals the increased and

ambitious efforts needed, even

compared to the previous 2

target. In this scenario, carbon

dioxide emissions are drastically

reduced already from 2020 and

by 2050 are already close to zero

or even negative. This scenario

provides details on the energy

transition and socio-economic

assumptions for achieving a zero

emissions balance by 2050. The

rapid development of clean

energy technologies and

improved energy efficiency,

combined with rapid and

RCP4.5 is described by the IPCC as a

moderate emissions scenario.

Emissions in RCP4.5 peak around 2040

and then decline, while the global

average temperature increases

between 1.1 and 2.6℃ by 2100.

According to resource experts, the

IPCC emission scenarios are biased

towards the over-availability of fossil

fuel reserves. RCP4.5 is the most likely

baseline scenario (without climate

policies), given the finite nature of

non-renewable fuels. Energy use in

the RCP4.5 scenario shows a

downward trend and fossil fuel use

decreases. In addition, nuclear power

and renewable energy will have

significant growth and there will be

extensive use of carbon capture and

storage (CCS) technology.

The RCP8.5 pathway results from

little effort to reduce emissions and

represents the failure to limit

warming by 2100. It represents the

worst case scenario with the highest

GHG emissions in the 21st century,

where energy demand is met mainly

by fossil fuels and there is low

penetration of renewables in the

energy mix. In addition, there are

insufficient technological

developments towards reducing the

carbon intensity of energy. Finally,

under the RCP8.5 scenario, without

climate policy, average temperatures

are expected to rise between 3.5 and

4.5

C by 2100.

184

significant reductions in

emissions from hydrocarbon

combustion and global

cooperation, are at the core of

the zero emissions transition.

As part of the ongoing climate risk analysis, the results of the future climate scenarios RCP4.5 and 8.5

are used for the analysis of physical risks. The methodological approach proposed and followed so far

assesses the potential impacts from each climate parameter for specific indicators related (as

presented in the following table. Part of the existing analysis for 2024 includes the parameters of

flooding, sea level rise, extreme wind and forest fire, for which the economic impacts for the

Company's facilities were assessed by evaluating part of the Company's exposure analysis for these

parameters, and the Company's vulnerability assessment to identify the material climate risks for

specific types of facilities at each location.

In order to assess the projected financial impact on assets based on their level of exposure, relative

vulnerability curves were examined, linking the rate of loss to the value of the assets and then the

results were linked to the five-point scale of financial impact that exists within the existing business

plan (ERM).

In this phase of the analysis, the exposure to material climate hazards was considered in terms of the

structural characteristics of each facility as a whole and no significant physical hazards were identified.

The next stage of the analysis will specialise both on the impacts that climate change may have on

equipment, transport, supply networks and staff health and safety. This exercise is already underway

so that the company will be in a position to disclose it in its next sustainability report.

E1.IRO-1_03

All identified risks are assessed in terms of their significance at three potential horizons. However, the

risks "Inefficient operation of a signal reception centre due to non-use of electronic surveillance

systems (CCTV), or due to the use of old technology alarms, resulting in ineffective fault detection

due to extreme weather events increasing in the context of climate change may lead to economic

impacts" and "Unsafe water supply to Attica due to failure of the EWS due to climate change

(drought/snowfall/floods) may lead to economic impacts" and "Unsafe water supply to Attica due to

failure of the EWS due to climate change (drought/snowfall/floods) may lead to economic impacts".

E1.IRO-1_04

EYDAP SA, taking into account the direct and indirect impacts of global conditions due to climate

change, examines the potential risks it faces in order to address chain reactions due to any prolonged

adverse conditions along the value chain.

The logistics network of EYDAP SA that is being examined concerns the processes of: 1. Procurement,

storage, ensuring the adequacy, handling and disposal of materials 2. Transport management with

the management, planning and maintenance of vehicles and machinery 3. Receiving the required

services.

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E1.IRO-1_05

Risks and opportunities are assessed for specific time horizons to align with the development of the

strategy, the expected life of its assets and financial planning. More specifically, the time horizons

taken into account are:

- Current: 2024

- Short term: 2025

- Medium term: 2030

- Long term: > 2030

E1.IRO-1_09-10& 12-13&15&19-20

Climate-related risks and opportunities were examined across the entire value chain and risks related

to both the operation of the business itself and upstream and downstream activities were identified

as important.

In a time of intense economic and geopolitical crisis, the cost of energy as a key regulator of industrial

processes has created an unfavourable cost condition along the supply chain, with an impact on

environmental and economic sustainability. The current energy crisis and its associated risks require

a holistic approach to the issue.

The Company is already in the process of assessing the climate transition risks according to the

IEA/NZE scenario. The drivers are related to elements such as regulatory changes, market trends,

energy prices, primary energy sources, sectoral energy transition changes and many other elements

towards the transition to a low-carbon economy.

This IEA report is one of the most recent publications to discuss the overall transition of the energy

sector and how this transition will be reflected in and affect various industries around the world. In

addition to the IEA scenarios, complementary regulations and directives at European and national

level, such as the EU Green Deal, are taken into account to narrate the scenarios and assess the

likelihood of risks and opportunities of the transition, European directives, the EU ETS, the UK

Transition Plan and the 2030 Roadmap for a zero carbon footprint in the water sector (UK Transition

Plan Taskforce, Water UK - NZ 2030 Routemap), and the National Climate Act.

Based on the analyses to date, the categories of transition risks and opportunities identified and

under assessment are presented in the tables below based on TCFD risk categorization and risk type:

Table 10. Summary of the climate transition risks considered

Risk category

Type of risk (TCFD)

Type of risk (ERM EYDAP SA)

Policies and legislation /

Regulatory framework

Increase in the price of coal

Compliance risk

Increased emissions reporting

obligations

Regulatory framework on existing

products and services

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Technology

Transition costs to lower emission

technology

Corporate reputation

Increased stakeholder concern

Strategic risk

Governance

Table 11: Summary of the climate opportunities considered

Category of opportunity

Type of opportunity (TCFD)

Durability

Resource substitutes and diversification

Products and services

Developing climate change adaptation solutions

Shopping

Access to new markets

Efficiency of resource use

Implementation Recycling

Energy sources

Adoption of low-emission energy sources

For the required actions and procedures to mitigate negative impacts on the one hand and for the

planned actions and initiatives related to climate on the other hand, the cross-directorial cooperation

is required, especially between the Directorates of Risk Management, Strategy & Innovation and the

Directorate General for Transformation.

E1.IRO-1_14&16

EYDAP SA is in the process of assessing the climate transition risks and the results are still in progress.

E2.IRO-1_01 & E3.IRO-1_01 & E4.IRO-1_01 & E4.IRO-1_02 & E4.IRO-1_03 & E4.IRO-1_04 & E5.IRO-1_01

An analytical and systematic process is applied to identify and assess the material impacts, risks and

opportunities related to pollution, biodiversity, water and the circular economy. Specifically, through

the double materiality analysis, EYDAP SA examines the existing and potential impacts related to

these issues for the whole value chain. To identify impacts, both internal (e.g. annual sustainability

report for 2023, CDP assessments, GRI index, etc.) and external sources (e.g. ENCORE database,

external literature review) were used to understand the causes of the different impacts. In addition,

we worked with experts as an additional source to identify impacts and understand how our business

activities, including through the value chain, impact the environment and people. To facilitate the

impact assessment, existing reports assessing impacts on the natural environment and society, such

as ERM, were also taken into account.

In particular, the significance of impacts was based on the severity and significance of impacts, which

are related to the following factors: a) scale, b) extent and c) mitigation potential. The scale was

assessed based on the magnitude of the impact. Scope was evaluated according to the level of

geographic occurrence of the facilities with which the relevant impacts are noted, and for the

mitigation potential, we assessed the expected time required for physical recovery. The likelihood of

187

potential impacts is assessed taking into account best practices, business model and mitigation

measures in place.

The identification and assessment of the JI related to pollution, biodiversity, water and the circular

economy has been carried out along the entire value chain, taking into account all EYDAP's facilities

and business activities. The assessment is based on the magnitude of financial impacts for the current

year and the combination of expected magnitude of financial impacts and probability of occurrence

for potential time horizons.

E2.IRO-1_03

Pollution in terms of own function relates to the company's impact on soil pollution through the

generation of waste from both its production processes and its administrative functions. All EYDAP

SA's facilities comply with the provisions of environmental legislation, while the facilities that are

environmentally licensed comply with the respective environmental conditions, resulting in

appropriate measures being taken to avoid pollution. In a broader context, an environmental

management system is to be implemented and the company will be certified according to ISO 14001

standards.

Pollution upstream in the value chain, in terms of the atmosphere, can mainly come from the burning

of fossil fuels for energy production and the emission of particulate matter during construction work

by contractors. In terms of soil pollution, it is mainly attributed to the generation of waste during

construction activities by its contractors. With regard to water, it is also attributed to the generation

of waste during construction activities and to the potential pollution of the water reservoirs used by

EYDAP SA. Pollution downstream in the value chain is linked to the escape of pollutants into

groundwater aquifers.

E2.IRO-1_02 & E3.IRO-1_02 & E4.IRO-1_05 & E4.IRO-1_07 & E5.IRO-1_02

The company, as part of a Dual Materiality Analysis, after identifying the significant impacts, risks and

opportunities, presented the identified impacts, along with their assessment and prioritization, to

stakeholder representatives (RACS representative, employee representative, MES representative) to

be considered in the final formulation, in accordance with the requirements of the ESRS.

E4.IRO-1_08

EYDAP SA, through the following measures and actions, ensures that negative impacts on biodiversity

are addressed:

● Ecological supply in reservoirs

● Control of projects and activities in the protection zones of reservoir basins

● High level treatment of urban waste water and disposal of the treated effluent to surface

water bodies

● Systematic monitoring of the Saronic Gulf and the Gulf of Elefsina by ELKEΘE

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● In the Schinias National Park as a protected wetland, within Natura 2000 areas, EYDAP carried

out Special Ecological Assessment (SEA) studies in the framework of the Environmental

Impact Study of the drainage projects, aiming to maintain the ecological integrity of the areas

and achieve the protection objectives (SSCO) of their species and habitats.

● The Hellenic Centre for Marine Research (HCMR) has completed, under the contract between

HCMR and EYDAP, the inventory of the marine ecosystem of the South Evian Gulf to

document the existing situation and to assess the impact of the KEL of East Attica. ELKEΘE

will continue to monitor the marine ecosystem during the operation of the new CCS in East

Attica in accordance with the obligations of the national and European legislation and the

AEPs.

● Compliance with the environmental conditions of licensed projects.

E4.IRO-1_14

In the context of sustainable management of water resources, biodiversity conservation is a key

parameter.

EYDAP SA, through the management of the hydrological cycle, protects the aquatic ecosystems in the

areas where it operates.

As human activities are tightly regulated, the lakes are evolving into important wetland ecosystems

that support protected bird species, interesting fish fauna and unique riparian vegetation. The main

role of the reservoirs is to store water for the capital's water supply, but they are also important

wetlands:

● Natural lake Yliki: Source of water for the capital's water supply system. It is an area of the

Natura 2000 Nature Protection Network.

● Artificial lake of Marathon: The first reservoir of the Attica water supply system and an

important wetland

● Mornos Reservoir and Euin Reservoir: They are important wetland ecosystems.

E4.IRO-1_15

In order to maintain the continuity of wetland ecosystems, EYDAP SA explored the possibility of

maintaining "ecological flow" in the river ecosystems downstream of the dams. Maintaining this

minimum required flow is necessary in accordance with legislation, environmental conditions and

current international trends in the environmental management of reservoirs. In this context, EYDAP

SA prepared a Technical Environmental Study (TEPEM) for the Mornos and Marathon dams. According

to the TEPEM for the Marathon dam, it was estimated that a flow rate of 25 l/sec downstream of the

dam was required to achieve the above mentioned purpose, which was implemented. The river

ecosystem downstream of the Mornos dam is in good condition due to the continuous flow of surface

water in the riverbed. EYDAP SA completed the systematic monitoring of the ecological and chemical

status of the river ecosystem, implementing a three-year programme of hydromorphological,

physicochemical, biological and chemical measurements, in accordance with the specifications of the

Water Framework Directive 2000/60/EU and the Water Management Plan YD04 provided for in the

189

Technical and Environmental Study (TEPEM) of the Mornos Dam. The monitoring showed that the

river ecosystem downstream of the Mornos dam is in good ecological and chemical condition. An

'ecological flow' of 1 m3/second has been provided for the River Evinos, the newest reservoir.

Consequently, the riparian ecosystems downstream of the dam retain their physiognomy and their

important biodiversity.

The collection and treatment of urban wastewater from settlements is an environmental

infrastructure project that protects surface and coastal water ecosystems. Particularly in areas of

protected wetlands of Natura 2000 sites, such as the Schinias National Park, Special Ecological

Assessment (SEA) studies are carried out as part of the Environmental Impact Assessments of

sewerage projects, with the aim of maintaining the ecological integrity of the areas and achieving the

protection objectives (SSCO) of their species and habitats. The Special Ecological Assessment Study

(SEA) for the Marathon project concerning the Schinias National Park has been completed.

E4.IRO-1_06 & E4.IRO-1_16

In the context of the environmental permitting (in accordance with the provisions of Directive

2011/92/EU) of the individual projects of EYDAP SA, the mitigation measures regarding the impacts

on biodiversity have been identified in the context of the Environmental Impact Studies that have

been prepared. For the installations located within Natura 2000 sites, the measures have been

identified in the respective Special Ecological Assessments (SEAs). The facility for which an EIA has

been prepared is the KEL Marathon.

G1.IRO-1

EYDAP SA has zero tolerance for actions and practices that undermine the integrity of corporate

governance and violate business ethics standards and applies an analytical process to identify and

assess material impacts, risks and opportunities related to transparency and business ethics. This

process includes:

● Location: An assessment of the geographic areas where the Company operates and the

associated impacts.

● Activity: Analysis of the company's main activities, such as water supply, sewerage, energy

and raw materials production.

● Sector: Examination of the sector in which the company operates and the specific challenges

it faces.

● Transaction structure: Evaluation of the transaction structure and the procedures followed to

ensure transparency and ethical conduct.

EYDAP SA recognizes that corruption and bribery undermine the ethical environment of any business

and constitute a complex problem with economic, social, environmental and political implications. By

adopting an Anti-Corruption and Bribery Policy, the Company is committed to conducting all its

activities with transparency, ethics, integrity and respect for society and the environment.

190

The Anti-Corruption and Bribery Policy encourages disclosure of matters or suspicions of wrongdoing

and protects against acts of retaliation. Control mechanisms include a system of policies, procedures

and practices to manage risks, reduce exposure to operational risks and enhance transparency.

The Company also adopts a Conflict of Interest Policy for the prevention, identification and

management of conflicts of interest, as well as a Sponsorship Policy that defines the principles of

sponsorship activity. In addition, it implements a Fund Operating Regulation to ensure security of

transactions and enhances transparency through information disclosure procedures and publication

of financial statements.

The Code of Ethics and Professional Conduct is also a valuable reference point, contributing

substantially to the protection of the interests of employees, customers and shareholders based on

the documented governance structures, while maintaining and strengthening the Company's

credibility, solvency and reputation.

191

[IRO-2] Disclosure requirements in ESRS covered by the entity's viability statement

IRO-2_01

Table of Data Points from the list of Disclosure Requirements in Annex 1.

IRO-2_02

Table of Data Points from other EU legislation in Annex 2.

IRO-2_13

The entity identified the material information based on the dual materiality analysis, which is fully

aligned with ESRS standards. The criteria for dual materiality are discussed in the individual ESRS

topics.

192

Environmental Information

EU Classification Regulation.

The EU Classification Regulation (Regulation 2020/852) is one of the tools established under the

European Green Deal, which aims to transform Europe, in a fair way, into a modern, efficient and

competitive economy with zero net carbon emissions by 2050.

The Regulation sets out the technical criteria on the basis of which an economic activity can be

considered environmentally sustainable. It therefore creates a common frame of reference that

investors can use when seeking to invest in economic activities that have a significant positive impact

on the climate, the environment and society. For an economic activity to qualify as environmentally

sustainable, or otherwise aligned with the Regulation, it must meet all of the following conditions:

● Be an eligible economic activity, i.e. included in the delegated regulations of the European

Taxonomy with the relevant technical criteria

● Make a significant contribution to one or more of the six (6) environmental objectives of the

Regulation

● Not cause significant harm to the other five (5) environmental objectives

● Comply with the minimum social

● Comply with the technical criteria for control adopted by the

The environmental objectives of the EU Classification Regulation are:

● Mitigating climate change

● Adapting to climate change

● Sustainable use and protection of water and marine resources

● The transition to a circular economy

● Pollution prevention and control

● Protecting and restoring biodiversity and ecosystems

Under the Delegated Regulations 2021/2139, 2022/1214, 2023/2485 and 2023/2486 technical

control criteria have been established for all 6 of the above objectives.

Publication requirements of the EU Classification Regulation.

In accordance with Article 8(1) of Regulation 2020/852/EU, firms subject to the obligation to publish

non-financial information (in accordance with Articles 19a and 29a of Directive 2013/34/EU) shall

disclose in the annual management report, information on the extent to which their activities (a) are

covered by the EU Taxonomy (eligible for the Taxonomy) and (b) comply with the technical criteria

control criteria set out in the Delegated Regulations of the Taxonomy (aligned with the Taxonomy).

The content and presentation of the required information are set out in Delegated Regulation (EU)

2021/2178, as amended.

193

More specifically, for disclosures published during 2025, relating to the financial year 2024, non-

financial firms will be required to disclose the following key performance indicators:

● The percentage of turnover (Turnover), capital expenditure (CapEx) and operating

expenditure (OpEx) derived from products or services related to eligible and non-eligible

economic activities for the Taxonomy and for the 6 environmental objectives.

● The percentage of Turnover, Capital Expenditure (CapEx) and Operating Expenditure (OpEx)

derived from products or services related to eligible and taxonomy-aligned economic

activities for the environmental objectives of climate change mitigation and adaptation.

Report on the EU taxonomy.

The following methodology was used to determine the key performance indicators (KPIs) of EYDAP

SA:

● Identification of eligible economic activities

● Assessment of the alignment of eligible economic activities, based on the following:

o Significant contribution to one or more of the six (6) environmental objectives of the

Regulation

o Non-induced significant damage (DNSH) to the remaining targets

o Compliance with minimum social safeguards

● Calculation of key performance indicators

The methodology applied was based on Regulation 2020/852, its delegated regulations and

additional guidance published:

● Delegated Regulations 2021/2139, 2022/1214, 2023/2485 and 20233/2486: These

Regulations establish the eligible activities and the technical criteria for determining the

conditions under which an economic activity meets the criteria of significant contribution and

no significant damage for all six environmental objectives.

● Delegated Regulation 2021/2178: This Regulation sets out the content and presentation of

the information to be disclosed on environmentally sustainable economic activities.

● Final Report on Minimum Safeguards: this report of the Platform on Sustainable Finance

provides guidance on the implementation of minimum social safeguards.

1. Identification of eligible economic activities

The identification of the eligible economic activities of EYDAP was carried out on the basis of the

description of its activities under the Regulation for the financial year 2024. An identification of the

economic activities was also carried out as to whether they are classified as favourable or transitional.

The economic activities of EYDAP SA for the financial year 2024 identified as eligible are the following:

194

Economic

Activity

Description

Environmental

Classification

Objective

Electricity

generation

using solar

photovoltaic

technology

Construction or operation of power generation facilities

that produce electricity using photovoltaic solar

technology (PV).

EYDAP SA has installed and produces electricity from a

1.97 MW photovoltaic power plant in the Acharnon mine

This activity generates revenue.

Climate Change

Mitigation - (CCM 4.1)

/ Climate Change

Adaptation (CCA 4.1)

Production of

electricity from

hydropower

Construction or operation of power generation

installations producing electricity from hydroelectric

power.

Along the external aqueducts that transport water from

the reservoirs to the refineries there are Small

Hydroelectric Projects/Systems (SHPs). In particular, it

has the following SHPs:

1. 650 kW helicopter

2. 820 kW of power

3. Kithairon 1200 kW power

4. 760 kW kirtle power

5. Manderas 630 power

This activity generates revenue.

Climate Change

Mitigation - (CCM 4.5)

/ Climate Change

Adaptation - (CCA

4.5)

Construction,

extension and

operation of

water

collection,

treatment and

supply systems

Construction, extension and operation of water

collection, treatment and supply systems.

EYDAP SA has installed and operates four Water

Treatment Plants with a total refining capacity of

1,800,000 m3/day in the regions: , Acharnon,

Polydendriou and Aspropyrgos.

The water supply network consists of about 14,500 km

of supply and distribution pipelines.

In addition, EYDAP AE operates ten rapid refineries with a

capacity range of 4 m3/hr - 360m3/hr

This activity generates revenue.

Climate Change

Mitigation - (CCM 5.1)

/ Climate Change

Adaptation (CCA 5.1)

195

Economic

Activity

Description

Environmental

Classification

Objective

Water supply

Construction, extension, operation and renewal of

systems for the collection, treatment and supply of

water intended for human consumption based on the

abstraction of natural water resources from surface or

groundwater sources.

The water supply facilities of EYDAP SA are those

mentioned in activity 5.1 above

This activity generates revenue.

Sustainable use and

protection of

water and marine

resources; (WTR 2.1)

Construction,

extension and

operation of

wastewater

collection and

treatment

systems

Construction, extension and operation of centralised

wastewater systems, including collection (sewerage) and

treatment.

EYDAP SA has 5 existing Wastewater Treatment Centres

in Psyttalia (KELPS), Thriasio (KELTH), Metamorphosis

(KELM), the KEL of the Municipality of Kropia and the

KEL of the Municipality of Megara in particular:

The KELPS has a wastewater treatment capacity of

1,000,000 m3/d and an average daily influent flow of

650,000 m3/d.

The WWTP has a wastewater treatment capacity of

44,000 m3/d and an average daily flow of 16,900 m3/d

of incoming wastewater and 9,800 m3/d of sewage.

The WWTP has a wastewater treatment capacity of

21,000 m3/d and an average daily influent flow of 6,700

m3/d.

The KEL of the Municipality of Kropias has a wastewater

treatment capacity of 18,000 m3/d and an average daily

flow of 1750 m3/d.

at the KEL of the Municipality of Megara, has a

treatment capacity of 8,000 m3/d and an average daily

flow of 1990 m3/d

In addition, it is noted that there are under

2 Wastewater Treatment Centres

The KEL of the Municipalities of Rafina - Pikermio &

Artemida - Spata, with a treatment capacity of 23,646

m3/d and

Climate Change

Mitigation - (CCM 5.3)

/ Climate Change

Adaptation - (CCA

5.3)

196

Economic

Activity

Description

Environmental

Classification

Objective

The KEL of the Municipality of Marathon, with a

treatment capacity of 9.885 m3/d.

This activity generates revenue.

Treatment of

urban waste

water

Construction, extension, upgrading, operation and

renewal of urban wastewater infrastructure, including

treatment plants, sewerage networks, connections to

wastewater infrastructure and outfall devices for treated

wastewater.

The urban wastewater treatment facilities of EYDAP SA

are those mentioned in activity 5.3 above

This activity generates revenue.

Sustainable use and

protection of

water and marine

resources - (WTR 2.2)

Transport by

motorcycles,

passenger cars

and light

commercial

vehicles

Purchase, financing, rental, leasing and operation of

vehicles.

EYDAP SA owns and leases vehicles for use by employees.

The company had costs related to the economic activity

eligible for the Classification (CapEx category c).

Climate Change

Mitigation - (CCM 6.5

Transitional) /

Adaptation to Climate

Change - (CCA 6.5)

Acquisition and

ownership of

buildings

Purchase of real estate and exercise of ownership of

such real estate.

EYDAP SA owns and exercises the ownership of a total of

47 properties that serve as offices and house the

administrative services.

The company had costs related to the economic activity

eligible for the Classification.

Climate Change

Mitigation (CCM 7.7)

/ Adaptation to

Climate Change -

(CCA 7.7)

In addition to the above activities, part of the energy needs of EYDAP SA at the wastewater treatment

centres (KEL of Psyttalia and KEL of Metamorphosis) is covered by the energy recovery of biogas

produced from the anaerobic digestion of sewage sludge. As this activity is considered as part of the

operation of the 2 WWTPs, and since no revenue is generated, it is not reflected above as a separate

economic activity. The capital expenditure as well as the operating costs of this activity are included

in the corresponding indicators of economic activity 5.3 'Construction, extension and operation of

wastewater collection and treatment systems'. At this point it is worth mentioning that the activities

have been identified as eligible under the new environmental objectives as follows:

● Production of alternative water resources for purposes other than human consumption

197

(Transition to a circular economy - CE 2.2) as in the WWTPs of Psyttalia, Metamorphosis and

Thriassio part of the treated effluent is recovered for on-site use

● Use of concrete in civil engineering projects (Transition to a circular economy - CE 3.5) as

during the construction of pumping stations, sewerage pipelines, etc., concrete is used as

specified by the activity.

The capital expenditures related to these economic activities are incorporated in the corresponding

key performance indicator (CapEx) of activity 5.3 "Construction, extension and operation of

wastewater collection and treatment systems", as there is currently no possibility of their allocation.

For this reason they are not reflected as separate economic activities in the tables of key performance

indicators.

At the same time, it is noted that as far as activity 2.1 WTR and the water supply facilities of EYDAP

SA are concerned, they are those reported in activity 5.1 CCM. In this context and in order to avoid

double counting, the respective amounts relating to the Turnover, Capital and Operating Expenditure

are recorded once and relate to both activities, 2.1 WTR and 5.1 CCM (see Key Performance Indicator

Tables). The same methodology was followed for the 5.3 CCM and 2.3 WTR activities.

2. Assessment of alignment with technical control criteria

EYDAP SA proceeded with the assessment of its existing and under development facilities related to

eligible economic activities, in relation to:

● The technical screening criteria relating to the significant contribution to mitigation and

adaptation to climate change

● The technical control criteria relating to the absence of significant damage

The objective of the assessment was to identify the degree of alignment of the eligible economic

activities of EYDAP SA with the criteria and requirements of the Classification Regulation and the

identification of any deviations, so that the company can draw up a specific action plan to achieve the

alignment of its eligible economic activities with the Regulation in the coming years.

In more detail, the results of the alignment assessment against the technical screening criteria of

significant contribution and no significant harm for each eligible economic activity are presented

below.

Electricity generation using solar photovoltaic technology (4.1)

EYDAP SA has installed and produces electricity from a 1.97 MW photovoltaic power plant in the

Acharnon mine.

Significant contribution to climate change mitigation

The activity is by definition aligned with the criteria of a significant contribution, as it produces

electricity using solar photovoltaic technology.

Significant contribution to adaptation to climate change

The natural climate risk assessment study required by the Regulation has not been carried out for the

photovoltaic plant in order to classify the activity as aligned. In addition, the activity is not classified

198

as favourable. Consequently, it is not eligible for the climate change adaptation objective and no

further assessment is required in relation to this objective.

No Significant Harm (DNSH)

The assessment was based on the No Significant Harm (DNSH) criteria described in activity 4.1 and

related to:

● The assessment of natural climate risks

● The use of equipment and components of high durability and recyclability

● The completion of the Environmental Impact Assessment (EIA) and the implementation of

the required mitigation and compensation measures for the protection of the environment

No Significant Harm (DNSH) in climate change adaptation

It is not in line with this criterion, as above.

No Significant Harm (DNSH) in the transition to a circular economy

Most of the photovoltaic panels are made of recyclable materials and the equipment has a lifespan

of at least 10 years. It is intended to follow the best market practices for recycling the equipment,

where technically feasible and in accordance with the relevant legislation. The activity therefore

complies with the technical control criteria related to the transition to a circular economy.

No Significant Harm (DNSH) in the protection and restoration of biodiversity and ecosystems

During the operation of the plant, the required mitigation measures for the protection of biodiversity

and associated ecosystems proposed in the respective Environmental Impact Assessment (EIA) and

the project's AEP are applied. Therefore, the activity complies with the technical control criteria

related to the restoration of biodiversity and ecosystems.

Based on the above, the PV plant is not fully aligned with all technical verification criteria.

Hydroelectric power generation (4.5)

Along the external aqueducts that transport water from the reservoirs to the refineries, small

hydroelectric power plants operate, whose energy is sold by EYDAP AE. The water from the aqueducts

is diverted to a side canal, where, with the operation of a hydro turbine, the hydraulic energy is

converted into mechanical energy and then, through a generator, into electricity. The water is then

reintroduced into the main aqueduct, where it continues to flow.

Specifically, the operating NIS are:

● MYES Elikona with a power of 650 kW and a projected annual energy production of 5.000.000

kWh

● MYES Evinos with a power of 820 kW and a projected annual energy production of 4.000.000

kWh

● Kithairon MES with a power of 1200 kW and a projected annual energy production of

5.730.000 kWh

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● MYES Kirfi with a power of 760 kW and a projected annual energy production of 5.860.000

kWh

● MANDRAS MES of 630 kW power and a projected annual energy production of 4.900.000

kWh

Finally, it is worth mentioning that in Psyttaleia there is a small hydroelectric power plant installed in

the outfall pipeline, which has been operating since 2015 and the energy produced is consumed by

the company. For the year 2024 the produced energy amounts to 2.155,00 kWh. This plant does not

generate any revenue for the company.

Significant contribution to climate change mitigation

The assessment on the significant contribution to climate change mitigation was based on compliance

with one of the following criteria:

● The power plant is a natural flow plant and has no artificial reservoir

● The power density of the power plant exceeds 5 W/m2;

● Life cycle greenhouse gas emissions from hydroelectric power generation are less than 100g

CO2e/kWh.

For the Small Hydropower Plants (SHPs), the assessment concluded that all of them are in line with

the first technical criterion for significant contribution to climate change mitigation, as they are

natural flow units and do not have an artificial reservoir.

Significant contribution to adaptation to climate change

The natural climate risk assessment studies required by the Regulation have not been carried out for

hydropower plants in order to classify the activity as aligned. In addition, the activity is not classified

as favourable. Consequently, the activity is not eligible for the climate change adaptation objective

and no further assessment is required in relation to this objective.

No Significant Harm (DNSH)

The assessment was based on the No Significant Harm (DNSH) criteria described in activity 4.5 (for

the Climate Change Mitigation objective) related to the assessment of natural climate risks, the

assessment of impacts on water, in accordance with the requirements of Directive 2000/60/EU and

the relevant river basin management plans, and the adoption of specific mitigation measures, where

required, and their monitoring, the completion of the Environmental Impact Assessment (EIA) and

the implementation of the required measures.

No Significant Harm (DNSH) in climate change adaptation

It is not in line with this criterion, as above.

No Significant Harm (DNSH) to the sustainable use and protection of water and marine resources

All hydropower plants are installed in aqueducts and therefore no assessment is carried out in

accordance with Directive 2000/60/EC. The activity therefore complies with the technical control

criteria related to the sustainable use and protection of water and marine resources.

No Significant Harm (DNSH) in the protection and restoration of biodiversity and ecosystems

200

Environmental Impact Studies have been prepared and approved for all hydroelectric power plants.

During their operation, the required mitigation measures for the protection of biodiversity and the

corresponding ecosystems proposed in the respective Environmental Impact Assessment (EIA) and

the EIA of the plants are implemented. The activity therefore complies with the technical control

criteria related to the restoration of biodiversity and ecosystems.

Based on the above, hydropower plants are not fully aligned with all technical control criteria.

Construction, extension and operation of water collection, treatment and supply systems (5.1 &

2.1)

EYDAP SA has installed and operates four Water Treatment Plants with a total refining capacity of

1,800,000 m3/day in the areas of Galatsiou, Acharnon, Polydendriou and Aspropyrgos. In addition,

EYDAP AE operates ten refineries, which are the following:

● Thiva tachydilic refinery with a total refining capacity of 360 m3/hr supplying water to the

areas of Erythres-Plateyes-Oinoi-Villias-Prophiti Ilias

● Tachydilic refinery of Kapreli with a total refining capacity of 100 m3/hr supplying the areas

of Kaparelli - Melissochori - Loutoufi - Agios Vasilios

● Lefktron tachydisintegrator with a total refining capacity of 70 m3/hr supplying water to the

Lefktron area

● Ellipia tachydistillery with a total refining capacity of 35 m3/hr supplying water to the areas

of Ellipia - Xeronomi

● Dombraeon tachydistillery with a total refining capacity of 35 m3/hr supplying water to the

areas of Dombraeon - Thisvi

● Tachydilite refinery in Prodromos with a total refining capacity of 45 m3/hr supplying the

areas of Saranti - Prodromos Beach

● Panagia Kalamiotissa refinery with a total refining capacity of 22 m3/hr supplying water to

the settlement of Karachalios

● Tarsos - Karyotis refinery with a total refining capacity of 4 m3/hr supplying the areas of Tarsos

- Karyotis

● Kyriaki refinery with a total refining capacity of 35 m3/hr supplying water to the Kyriaki area

● Distomos tachydistillery with a total refining capacity of 70 m3/hr supplying water to the area

of Distomos

In addition, EYDAP's activities include the water supply network, which consists of approximately

14,500 km of supply pipelines and distribution network.

Significant contribution to climate change mitigation (5.1

The assessment on the significant contribution to climate change mitigation was based on the

compliance of the water supply system with one of the following criteria:

(a) the net average energy consumption for pumping and treatment is no more than 0,5 kWh per

cubic metre of water flow produced.

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(b) the leakage level is calculated either by using the Infrastructure Leakage Index (ILI) (205)

assessment method, and the limit value is at most 1,5, or by using another appropriate method, and

the limit value is determined in accordance with Article 4 of Directive (EU) 2020/2184 of the European

Parliament and of the Council.

For all Water Treatment Plants and the water supply network, the net average energy consumption

for pumping and treatment is below 0.5 kWh per cubic meter of produced water. The activity is

therefore in line with the first criterion for significant contribution to climate change mitigation.

Significant contribution to the sustainable use and protection of water and marine resources (2.1

WTR)

The assessment on the significant contribution to the sustainable use and protection of water and

marine resources was based on the compliance of the water supply system with the following criteria:

● Compliance with Directive (EU) 2020/2184

● The leakage level of the system

● Whether the water supply system includes metering at the consumer level and whether a

plan is drawn up

● Individual criteria relating to the abstraction of water from underground aquifers

The IEDs and the water supply network comply with Directive (EU) 2020/2184.

The water supply system complies with Directive (EU) 2020/2184, Commission Implementing

Decision (EU) 2022/679 and the delegated and implementing acts adopted pursuant to that Directive.

The assessment of the alignment with the Infrastructure Leakage Index (ILI) threshold for the existing

system, the extension system or the renewed system is not feasible, as the European Commission will

adopt a act on the threshold based on Article 4 of Directive 2020/2184 by 12/01/2028.

As EYDAP SA has established a quarterly metering plan for residential consumers and a monthly plan

for special consumers, it meets the relevant criterion.

EYDAP AE is engaged in water abstraction activities from underground aquifers, however, due to the

lack of available information, it was not possible to verify the alignment of the activity with this

criterion.

Significant contribution to adaptation to climate change (5.1

The natural climate risk assessment study required by the Regulation has not been carried out for the

water treatment centres and the distribution network in order to classify the activity as aligned. In

addition, the activity is not classified as favourable. Consequently, it is not eligible for the climate

change adaptation objective and no further assessment is required in relation to this objective.

No Significant Harm (DNSH)

The assessment was based on the No Significant Harm (DNSH) criteria described in activity 5.1 (for

the Climate Change Mitigation objective) and related to:

The assessment of natural climate risks

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The assessment of the impacts on water, in accordance with Directive 2000/60/EU, and its treatment

The completion of the Environmental Impact Assessment (EIA) and the implementation of the

required mitigation and compensation measures for the protection of the environment.

No Significant Harm (DNSH) to climate change adaptation (common criterion with WTR activity 2.1)

It is not in line with this criterion, as above.

No Significant Harm (DNSH) to the sustainable use and protection of water and marine resources

Environmental Impact Assessments have been prepared for all water treatment plants, which include

an assessment of the impact on water in accordance with Directive 2000/60/EC. As regards the

implementation of the required water protection measures, all water treatment plants are subject to

the mitigation measures proposed in the respective EIAs, both during construction and operation.

The activity therefore complies with the technical control criteria related to the sustainable use and

protection of water and marine resources.

No Significant Damage (DNSH) to the protection and restoration of biodiversity and ecosystems

(common criterion with WTR activity 2.1)

Environmental Impact Studies have been prepared and approved for all water treatment plants.

During their operation, the required mitigation measures for the protection of biodiversity and their

respective ecosystems as set out in the respective approved Environmental Impact Assessments

(EIAs) are implemented in the respective approved Environmental Impact Assessments (EIAs).

Therefore, the activity complies with the technical control criteria related to the restoration of

biodiversity and ecosystems.

Based on the above, the water treatment plants and the network are not fully aligned with all

technical control criteria.

Construction, extension and operation of wastewater collection and treatment systems (5.3).

EYDAP SA operates five Wastewater Treatment Centres for the treatment of wastewater from the

areas under its jurisdiction:

● on the island of Psyttaleia (KELPS) with a capacity of 1,000,000 m3/day and an average daily

influent flow of 650,000 m3/day

● in Metamorfosi (KELM) with a capacity of 44,000 m3/day and an average daily flow of 16,900

m3/day of incoming wastewater and 9,800 m3/day of sewage

● in the Thriasio Field (KELTH) with a capacity of 21,000 m3/day and an average daily influent

flow of 6,700 m3/day

● at the KEL of the Municipality of Koropi - Peania with a treatment capacity of 18.000 m3/d

and an average incoming wastewater flow of 1750 m3/day

● at the KEL of the Municipality of Megara, with a treatment capacity of 8.000 m3/d and an

average incoming wastewater flow of 1990 m3/day.

At the same time, EYDAP SA is proceeding with the development of two Wastewater Treatment

Centres for wastewater treatment projects in Eastern Attica, which are:

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● The KEL of the Municipalities of Rafina - Pikermio & Artemida - Spata with a treatment

capacity of 23,646 m3/d

● The Marathon Municipality's treatment plant with a capacity of 9.885 m3/d

Significant contribution to climate change mitigation (5.3)

The assessment on the significant contribution to climate change mitigation was based on the

following criteria:

1. The net energy consumption of the wastewater treatment plant is at most:

(a) 35 kWh per population equivalent (PE) per year for a treatment plant capacity of less than

10 000 PE;

(b) 25 kWh per population equivalent (PE) per year for a treatment plant capacity of between

10,000 and 100,000 PE;

than 100,000 PE;

2. For the construction and expansion of a wastewater treatment plant or wastewater

treatment plant with a collection system that replaces more GHG-intensive treatment

systems (such as septic tanks, anaerobic ponds), an assessment of direct GHG emissions shall

be carried out. The results shall be made available to investors and customers upon request.

The evaluation concluded:

Existing waste water treatment plants

For two of the five plants (Psyttalia and Metamorphosis Wastewater Treatment Centres with a

treatment capacity of more than 100,000 IP each), the net average energy consumption for treatment

is below 20 kWh per year per population equivalent (PE). Therefore, two of the five WWTPs are in

line with the criterion for significant contribution to climate change mitigation.

Waste water treatment plants under construction

Due to unavailability of information on the plants under construction, it was not possible to verify the

alignment of the activity with the above criteria.

Significant contribution to the sustainable use and protection of water and marine resources (2.2

WTR)

The assessment on the significant contribution to the sustainable use and protection of water and

marine resources was based on the compliance of CRLs with one of the following criteria:

● The assessment of impacts on water, in accordance with Directive 2000/60/EU and

addressing

● The waste water treatment system meets the discharge requirements set by the competent

local

● Compliance with Directive 2008/56/EC

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● Compliance with Directive 91/271/EEC

● Where the sludge is treated by anaerobic digestion or a technology with the same or lower

net energy demand (taking into account both production and consumption of energy), to

stabilise the sludge

Existing and under construction wastewater treatment plants (WWTPs) meet the criteria for meeting

the relevant discharge requirements set out in Directive 91/271/EEC and an assessment and

remediation of any impacts has been carried out. In addition, for WWTPs with a capacity of more

than 100 000 population equivalent (p.e.), sludge treatment such as anaerobic digestion is already

implemented or planned to be implemented.

Significant contribution to adaptation to climate change (5.3)

EYDAP SA has implemented a natural climate risk assessment study for one of the seven CCLs in

accordance with the requirements of the Regulation. More specifically, the study was carried out for

the Koropi-Paenian CCS based on the EU Communication on "Technical guidance on enhancing the

resilience of infrastructure to climate change in the period 2021-2027" (2021/C 373/01) and the IPCC

RCP 4.5/8.5 scenarios were used.

The climate risk analysis concluded that the climate risks for the Koropi-Peania CDC range from low

to moderate. EYDAP AE already takes into account the potential impacts of these risks and is already

implementing (by design) measures and actions to address the risks and reduce the magnitude of the

impacts. According to the European Commission's Communication entitled Technical Guidance on

Infrastructure Sustainability Impact Assessment for the period 2021-2027 and in Appendix A of

Regulation 2021/2139, targeted adaptation measures are only required for each significant risk

identified. The climate risk analysis concluded that there are no significant climate risks for the

activities assessed.

Therefore, the KEL Koropi - Peania is aligned with the criterion of significant contribution to climate

change adaptation.

No Significant Harm (DNSH)

The assessment was based on the No Significant Harm (DNSH) criteria described in WTR activities 5.3

and 2.2 and related to:

● The assessment of direct greenhouse gas emissions from the central wastewater system,

including collection (sewerage) and treatment

● The implementation of a monitoring plan for methane leakage in the plant (in the case of

anaerobic digestion)

● The assessment of natural climate risks

● The assessment of the impact on water, in accordance with Directive 2000/60/EC, and the

treatment of wastewater and, where wastewater is treated to a level suitable for reuse in

agricultural irrigation, the necessary risk management measures to avoid negative

environmental impacts are defined and implemented

205

● Discharges to receiving waters meet the requirements of Directive 91/271/EC and measures

are in place to prevent and mitigate stormwater overflows. Sludge shall be used in accordance

with Council Directive 86/278/EEC or as required by national legislation

● The completion of the Environmental Impact Assessment (EIA) and the implementation of

the required mitigation and compensation measures for the protection of the environment

No Significant Harm (DNSH) in climate mitigation

All existing CERs are aligned with this criterion as an assessment of direct GHG emissions has been

carried out.

No Significant Harm (DNSH) in climate change adaptation

The physical climate risk study for the Koropi - Peania wastewater treatment centre also meets the

criteria of no significant harm.

No Significant Harm (DNSH) to the sustainable use and protection of water and marine resources

Environmental Impact Assessments have been prepared and approved for all wastewater treatment

centres. During their construction and operation, the required mitigation measures for the protection

of biodiversity and their respective ecosystems proposed in the respective Environmental Impact

Assessments (EIAs) are implemented. Therefore, the activity complies with the technical control

criteria.

No Significant Harm (DNSH) in Pollution Prevention and Control

The assessment concluded that for the existing and new WWTPs, the discharges to receiving waters

meet the requirements of Directive 91/271/EC and measures are in place to prevent and control

stormwater overflows to receiving waters, so the activity complies with the criterion related to

pollution prevention and control.

As dried sludge is not used in agriculture, this criterion of Directive 86/278/EEC does not apply.

No Significant Harm (DNSH) in the protection and restoration of biodiversity and ecosystems

Environmental Impact Assessments have been prepared and approved for all wastewater treatment

centres. During their construction and operation, the required mitigation measures for the protection

of biodiversity and their respective ecosystems proposed in the respective Environmental Impact

Assessment (EIA) and the EIA of the plants are implemented. The activity therefore complies with the

technical control criteria related to the restoration of biodiversity and ecosystems.

Based on the above, economic activity is not aligned with the objectives of mitigation and adaptation

to climate change, and sustainable use and protection of water and marine resources.

Transport by motorcycles, passenger cars and light commercial vehicles (6.5)

EYDAP SA owns and leases vehicles for use by employees.

Significant contribution to climate change mitigation

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This activity contributes significantly to climate change mitigation to the extent that M1 and N1

vehicles have CO2 emissions of less than 50 gCO2/km and for L vehicles to have zero emissions.

"Significant contribution to climate change mitigation

Vehicles of category M1/N1/L

The alignment assessment on emissions from M1,N1,L vehicles is ongoing.

Significant contribution to adaptation to climate change

The activity is not aligned as the natural climate risk assessment studies required by the Regulation

have not been carried out for this activity. In addition, the activity is not classified as favourable.

Consequently, the activity is not eligible for the climate change adaptation objective and no further

assessment is required in relation to this objective.

As this activity does not meet the criteria of a significant contribution, it was not assessed under the

criteria of not causing material injury.

Acquisition and ownership of buildings (7.7)

EYDAP SA owns and exercises ownership of 47 offices housing the administrative services.

Significant contribution to climate change mitigation

The activity has been assessed against the criteria of significant contribution related to the energy

efficiency of buildings and the monitoring and evaluation of their energy performance. As the

buildings do not have an Energy Performance Certificate Class A, the activity was considered not to

be in line with the criterion of significant contribution.

Significant contribution to adaptation to climate change

The natural climate risk assessment studies required by the Regulation have not been carried out for

the buildings in order to classify the activity as aligned. In addition, the activity is not classified as

favourable. Consequently, the activity is not eligible for the climate change adaptation objective and

no further assessment is required in relation to this objective.

As this activity does not meet the criteria of a significant contribution, it was not assessed under the

criteria of not causing material injury.

3. Minimum social safeguards

An assessment of EYDAP SA was carried out, with regard to the requirements of the minimum social

safeguards, which have been established in accordance with Article 18 of EU Regulation 2020/852.

Essentially these are derived from a set of defined guidelines of the UN, EU and other international

organizations, as follows:

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● OECD Guidelines for Multinational Enterprises (OECD Guidelines for Multinational

Enterprises)

● United Nations Guiding Principles on Business and Human Rights (UN Guiding Principles on

Business and Human Rights-UNGP)

● Declaration of the International Labour Organization on Fundamental Principles and Rights

at Work

● International Bill of Human Rights

According to the Final Report on Minimum Safeguards of the Platform for Sustainable Finance, the

minimum social safeguards relate to the following areas:

● Human rights, including labour rights

● Corruption and Bribery

● Taxation

● Fair competition

All human rights included in the ILO Fundamental Conventions and the International Bill of Human

Rights are taken into account in the United Nations Guiding Principles on Business and Human Rights.

Therefore, the assessment on minimum social safeguards was mainly based on the OECD Guidelines

for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.

Human rights

EYDAP SA has zero tolerance for behaviour and situations that violate human rights, and avoids

cooperation with persons who have been proven to be involved in cases of human rights violations.

In this direction, EYDAP SA has been implementing, since 2022, a Human Rights Policy approved by

the Board of Directors, which has as its primary purpose to enhance awareness and ensure the

commitment of all those employed by the Company, whether in the form of dependent employment

or not, partners, suppliers or subsidiaries to the Company. The Policy applies to the Company and any

existing or future subsidiary.

EYDAP AE is fully compliant with the requirements of Greek and EU legislation and human rights

standards. In particular, the Policy is based on the following:

● Fundamental principles of the Greek Constitution

● Principles of the United Nations Universal Declaration of Human Rights

● European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR)

● Charter of Fundamental Rights of the European Union (2000/C 364/01)

● Council of Europe Convention 108 and its update

● United Nations Guiding Principles on Business and Human Rights

● United Nations Global Compact (UNGC)

● OECD Guidelines for Multinational Enterprises

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● Declaration on Fundamental Principles and Rights at Work of the International Labour

Organisation

● International Standard Social Accountability 8000 (SA 8000)

The main pillars of the Policy are labour rights and social human rights. More information on the

"Human Rights Policy" of EYDAP AE in section "D2. DIVERSITY & EQUAL OPPORTUNITIES" in the same

Report.

Protection of consumer rights

EYDAP SA places primary emphasis on protecting the rights of its consumers.

Consumers can be informed about the pricing of water services and the application of general pricing

rules on the Agency's website (https://www.eydap.gr/CustomerSupport/normalrates/). In addition,

for citizens covered by the Social Income Solidarity Programme, EYDAP SA, recognizing the necessity

of water as a survival good, provides the possibility of granting an Extraordinary Special Tariff with

more favorable pricing.

In the context of customer education, EYDAP SA offers informative articles and videos, through its

website and social media, such as the "Learn how to..." which covers topics on how to read the EYDAP

SA bill easily and quickly, how to register in the online shop, how to locate the water meter and read

its readings, as well as how to check for possible leaks. Furthermore, EYDAP SA is a member of the

Association of Advertisers of Greece, which acts to defend and promote the rights of advertisers and

consumers.

In addition, with regard to human rights actions, in an effort to ensure equal access to its services,

since 2017, specially designed universal accessibility services for visually impaired people have been

implemented, providing for the sending of bills in larger fonts or in Braille or even by text or email.

In order to deal with situations that may arise in relation to consumers, EYDAP SA provides three

communication channels for the submission of requests and complaints: a) through a physical store,

b) through the telephone line 1022 and c) by e-mail at1022@eydap.gr . EYDAP SA is committed

through the Consumer Charter of Obligations to respond to requests/complaints within a time frame

of 15 to 30 working days depending on the specifications of the complaint.

Corruption & Briber

Integrity is a fundamental principle for EYDAP SA. To this end, it has developed the Code of Conduct

& Professional Conduct Code of Conduct which defines acceptable behaviours of personal and

professional integrity. This Code sets out the Company's acceptable framework for offering and

accepting gifts and other benefits from employees to third parties and vice versa.

In particular, EYDAP SA has adopted the Anti-Corruption and Anti-Bribery Policy in line with the

European Policy and the Greek Anti-Corruption Action Plan and through this Policy, EYDAP SA is

committed to conducting its activities with transparency, ethics, integrity and respect for society and

the environment. Covered persons are the members of the Board of Directors, senior and top

management and all employees of the Company regardless of the type of employment relationship.

209

Relevant trainings are organised for employees (e.g. completion, execution and implementation of

Public Contracts) in order to inform and raise awareness of bribery and corruption issues.

In addition, EYDAP SA has established and applies a Sponsorship Policy, which defines the basic

principles of its sponsorship activity, as derived from its Strategy and its priorities, the characteristics

that should govern the sponsored actions and the beneficiaries, as well as the procedure that should

be followed until the final stage of their implementation.

EYDAP SA has a Whistleblowing Policy, under which its employees and/or third parties are

encouraged and encouraged to report anonymously or anonymously any malfunctions, irregularities,

omissions or criminal acts that have come to their attention, as well as to express any concerns,

concerns or complaints regarding any violations of the Company's policies or the legislative-

regulatory framework governing its operation. Reporting can be achieved by sending the report to

156 Oropou 156, 111 46 GALATSI, EYDAP, by email towhistleblowing@eydap.gr or by using the online

form on the organisation's website

(https://www.eydap.gr/Investors/CorporateGovernance/WhistleblowingApp/). Information on the

management of complaints/claims for 2024 is available in the section "Management of

customer/employee complaints/claims" of the same Report.

Taxation

With regard to tax issues, EYDAP SA ensures compliance with accounting and tax laws, legislative and

other regulatory requirements for itself and all its subsidiaries. Compliance with tax legislation is also

ensured through the issuance of a "Tax Compliance Certificate" as well as the "Tax Audit Certificate".

The Company's Management and Finance Department is responsible for ensuring compliance with

the tax legislative framework.

In addition, the Company's management makes provisions in the financial statements for tax risks as

reflected in the financial report. The Risk Management Department monitors and applies similar

practices for all the Company's risks reporting to the Risk Management Committee of the Board of

Directors of EYDAP SA.

Fair competition

EYDAP SA is not subject to the national and EU competition legislation as, pursuant to the specific

legislative provision of Article 114 of Law 4812/2021 (and prior to its entry into force pursuant to the

provision of Article 2 of Law 2744/1999), it provides monopoly water supply and sewerage services

in its area of activity, i.e. in the major area of Attica. Moreover, the pricing policy of EYDAP SA is

exercised through the application of the general rules for the costing and pricing of water services,

which are established by ministerial decision in accordance with the provisions of Article 12 of Law

No. 3199/2003, while the tariffs for water services for the various categories of consumers and users

are approved by decision of the independent Waste, Energy and Water Regulatory Authority (Waste,

Energy and Water Regulatory Authority) in accordance with Article 12A of Law 4001/2011.

Furthermore, in the context of awarding and executing contracts for works, services, supplies, etc.,

EYDAP SA operates on an equal footing with the economic operators in terms of transparency and

210

protection of competition. In particular in the context of the implementation and compliance with

the principles of Article 253 of Law 4412/2016, EYDAP SA takes all necessary measures to ensure

equal treatment of tenderers in all phases of the contract award procedure, promoting the

development of healthy and effective competition. In this direction, it has adopted and applies the

Regulation on the Award and Execution of Contracts for Works, Designs and Provision of Technical

and Other Related Scientific Services as well as the Regulation on Procurement and General Services.

Information on EYDAP SA's compliance with the procedure for conducting competitive tendering

procedures for supplies and services is available in the "REGULATORY COMPLIANCE" section of the

same Report.

In the context of fair competition, EYDAP SA always provides in a timely and complete manner any

data and information requested by the Competition Commission and responds promptly to any

request of the Independent Authority, respecting the deadlines and conditions set by Law 3959/2011,

as in force.

With regard to the information and training of employees on competition issues, EYDAP SA includes

in the training programme that it prepares on a semi-annual basis for its employees, the application

of the legislation on public procurement, including its amendments, as well as the application of the

Regulations it has adopted for the award and execution of contracts, aiming, among other things, at

promoting the principle of non-discrimination, objectivity, impartiality and the protection of the

rights of employees and the protection of the environment.

4. Calculation of key performance indicators (KPIs)

4.1 Key performance indicator related to turnover (Turnover Key Performance Indicator)

The percentage of turnover referred to in Article 8(2)(a) of Regulation (EU) 2020/852 shall be

calculated as the part of net turnover derived from goods or services, including intangibles, linked to

economic activities aligned with the EU classification (numerator) divided by the net amount of

turnover (denominator) as defined in Article 2(5) of Directive 2013/34/EU. Turnover covers revenue

recognised in accordance with International Accounting Standard (IAS) 1(82)(a) as adopted by

Commission Regulation (EC) No 1126/2008 . .

The BGE referred to in the first subparagraph shall exclude from its numerator the part of the net

turnover derived from goods and services related to economic activities that are adapted to climate

change in accordance with Article 11(1)(a) of Regulation (EU) 2020/852 and in accordance with Annex

II to Delegated Regulation (EU) 2021/2139 unless those activities:

(a) can qualify as favourable activities in accordance with Article 11(1)(b) of Regulation

2020/852; or

b) are themselves eligible and aligned with the taxonomy.

To avoid double counting when allocating to the numerator of turnover between economic activities,

the data used have eliminated intra-company transactions (see section "1. Identification of eligible

Commission Regulation (EC) No 1126/2008 of 3 November 2008 adopting certain international accounting standards in

accordance with Regulation (EC) No 1606/2002 of the European Parliament and of the Council (OJ L 320, 29.11.2008, p. 1).

211

economic activities").

4.2 Key performance indicator related to capital expenditure (BTE CapEx)

The percentage of capital expenditure referred to in Article 8(2)(b) of Regulation (EU) 2020/852 shall

be calculated as the numerator divided by the denominator as defined in points 1.1.2.1 and 1.1.2.2.2

of Annex I to Regulation (EU) 2021/2178, as amended.

Denominator

The denominator shall cover additions to tangible and intangible assets during the financial year

under review before depreciation and any remeasurements, including those resulting from

revaluations and impairments, for the financial year concerned and excluding changes in fair value.

For non-financial corporations applying International Financial Reporting Standards (IFRS), as adopted

by Regulation (EC) No 1126/2008, capital expenditure covers expenditure accounted for on a basis:

(a) IAS 16 Property, Plant and Equipment, paragraph 73(e)(i) and (iii);

(b) IAS 38 Intangible assets, paragraph 118(e)(i);

Leases that do not result in the recognition of a right to use the asset shall not be accounted for as

capital expenditure.

Numerator

The numerator is equal to the part of the capital expenditure included in the denominator and is any

of the following:

(a) relating to assets or processes associated with economic activities aligned with the EU

classification

(b) part of a project aimed at expanding economic activities aligned with the EU taxonomy or

enabling the alignment of economic activities eligible for the taxonomy ('capital expenditure

project') under the conditions set out in the second subparagraph of this point

taxonomy and individual measures that enable the targeted activities to become low-carbon

or lead to reductions in greenhouse gas emissions, in particular the activities listed in points

7.3 to 7.6 of Annex I to the delegated act on climate, as well as other economic activities

included in the delegated acts adopted pursuant to Article 10(2); and (c) relating to the

purchase of products from the EU taxonomy and individual measures that enable the

targeted activities to become low-carbon or lead to reductions in greenhouse gas emissions,

in particular the activities listed in points 7.3 to 7.6 of Annex I to the delegated act on climate,

as well as other economic activities included in the delegated acts adopted pursuant to Article

10(2).

The numerator includes the part of the capital expenditure (CapEx) referred to in the first paragraph

of this point that contributes substantially to any of the environmental objectives. The numerator

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shall include a breakdown of the proportion of capital expenditure allocated to the substantial

contribution to each environmental objective.

To avoid double counting when allocating to the numerator of CapEx between economic activities,

the data have eliminated intercompany transactions (see section "1. Identification of eligible

economic activities").

4.3 Key performance indicator related to operating expenditure (BPI OpEx)

The percentage of operating expenditure referred to in Article 8(2)(b) of Regulation (EU) 2020/852

shall be calculated as the numerator divided by the denominator as defined in points 1.1.3.1 and

1.1.3.2 of Annex I to Regulation (EU) 2021/2178, as amended.

Denominator

The denominator covers direct non-capitalised expenditure relating to research and development,

building renovation measures, short-term leasing, maintenance and repair, and any other direct

expenditure relating to the day-to-day maintenance of tangible fixed assets by the enterprise or a

third party to whom the activities necessary to ensure the continued and efficient operation of these

assets are outsourced.

Numerator

The numerator is equal to the part of the operating costs included in the denominator and is any of

the following:

(a) related to assets or processes associated with economic activities aligned with the EU taxonomy,

including training and other human resource adjustment needs, and direct non-capitalised

expenditure representing research and development;

(b) relating to the purchase of products from economic activities aligned with the EU taxonomy and

to individual measures enabling the targeted activities to become low-carbon or leading to reductions

in greenhouse gas emissions, as well as to individual measures for the renovation of buildings as

specified in delegated acts adopted pursuant to Article 10(3), Article 11(3), Article 12(2), Article 13(2),

Article 14(2) or Article 15(2); Where the operating costs are not material to the business model of

non-financial undertakings, those undertakings:

(a) are excluded from the calculation of the numerator of the BREF of operating expenditure

in accordance with point 1.1.3.2 of Annex I of Delegated Regulation (EU) 2021/2178 and

declare that the numerator is zero

(b) disclose the total value of the denominator of operating costs calculated as follows

The numerator shall include the part of the operating costs (OpEx) referred to in the first paragraph

of this point that contributes substantially to any of the environmental objectives. The numerator

shall provide a breakdown of the part of the operating costs allocated to the substantial contribution

to each environmental objective.

To avoid double counting when allocating to the numerator of OpEx between economic activities, the

data have eliminated intercompany transactions (see section "1. Identification of eligible economic

213

activities'.

5. Key Performance Indicators - FY 2024

The tables below present the percentages of turnover, CapEx and OpEx associated with aligned, non-

aligned and non-eligible economic activities under the Classification Regulation for the financial year

2024, according to the result of the alignment assessment of the economic activities of EYDAP SA.

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Table 12. Percentage of turnover from activities linked to taxonomy-aligned economic activities - disclosure covering the financial year

Financial Year

2024

Criteria for a significant contribution

DNSH (No Significant Harm) criteria

Financial Activities

Code

Business cycle

Percentage of turnover for the

financial year 2024

Climate Change Mitigation

Adaptation to Climate Change

Water Resources

Circular Economy

Pollution

Biodiversity and Ecos

ystems

Climate Change Mitigation

Adaptation to Climate Change

Water Resources

Circular Economy

Pollution

Biodiversity and Ecosystems

Minimum Social Security

Percentage of turnover aligned (A.1)

with or eligible (A.2) for the EU

taxonomy for the financial y

ear 2023

Category

- (favourable activity)

Category

- (transition activity)

€'000

N, O,

M/E-P

N, O,

M/E-P

N, O,

M/E-P

N, O,

M/E-P

N, O,

M/E-P

N, O,

M/E-P

N/O

A. ACTIVITIES ELIGIBLE FOR CLASSIFICATION

A.1 Environmentally sustainable activities (aligned with the taxonomy)

Turnover of

environmentally

sustainable

activities (aligned

with the taxonomy)

(A.1)

Of which favourable activities

0,00%

Of which transition activities

A.2 Activities eligible for the taxonomy but not environmentally sustainable (activities not aligned with the taxonomy)

Electricity

generation using

solar photovoltaic

technology

CCM 4.1

220,00

0,06%

M/EP

0,06%

215

Production of

electricity from

hydropower

CCM 4.5

1.734,00

0,46%

M/EP

0,49%

Construction,

extension and

operation of water

collection,

treatment and

supply systems

CCM 5.1

WTR 2.1/

264.226,00

70,70%

M/EP

70,52%

Construction,

extension and

operation of

wastewater

collection and

treatment systems

CCM 5.3 /

WTR 2.2

106.656,00

28,54%

M/EP

28,90%

Transport by

motorcycles,

passenger cars and

light commercial

vehicles

CCM 6.5

M/EP

0,00%

Acquisition and

ownership of

buildings

CCM 7.7

M/EP

0,00%

Turnover from Unallocated

Activities (A.2)

372.836,00

99,77%

99,97%

Α. Turnover from Eligible

Activities (A1+A2)

372.836,00

99,77%

99,97%

B. ACTIVITIES NOT ELIGIBLE FOR CLASSIFICATION

216

Turnover of activities not

eligible for the classification of

activities (B)

867,00

0,23%

Total Operating Cycle (A+B)

373.703,00

100%

N - Yes, activity eligible for the Taxonomy and aligned with the Taxonomy for the relevant environmental objective

O - No, activity eligible for the Taxonomy but not aligned with the Taxonomy for the relevant environmental objective

OP - Activity eligible for the Classification for the relevant objective

N/A - Activity not eligible for the Classification for the relevant environmental objective

217

Percentage of turnover/total turnover

Aligned with the

taxonomy by objective

Eligible by the taxonomy

by objective

CCM

99,77%

CCA

WTR

99,25%

PPC

BIO

218

Table 13. Percentage of CapEx

from activities related to taxonomy-aligned economic activities - disclosure covering fiscal year 2024

Financial Year

2024

Criteria for a significant contribution

DNSH (No Significant Harm) criteria

Financial Activities

Code

CapEx

Percentage of CapEx for fiscal year

2024

Climate Change Mitigation

Adaptation to Climate Change

Water Resources

Circular Economy

Pollution

Biodiversity and Ecosystems

Climate Change Mitigation

Adaptation to Climate Change

Water Resources

Circular Economy

Pollution

Biodiversity and Ecosystems

Minimum Social Security

Percentage of CapEx aligned (A.1) wit

or eligible (A.2) for the EU taxonomy

for fiscal year 2023

Category

- (favourable activity)

Category

- (transition activity)

€'000

N, O,

M/E-

N, O,

M/E-P

N, O,

M/E-P

N, O,

M/E-P

N, O,

M/E-P

N, O,

M/E-P

N/O

A. ACTIVITIES ELIGIBLE FOR CLASSIFICATION

A.1 Environmentally sustainable activities (aligned with the taxonomy)

CapEx of environmentally

sustainable activities

(aligned with the

taxonomy) (A.1)

Of which favourable activities

Of which transition activities

A.2 Activities eligible for the taxonomy but not environmentally sustainable (activities not aligned with the taxonomy)

For the amounts for Water and Sewerage furniture of EUR 1,475 thousand and EUR 430 thousand respectively, and the amounts of EUR 1,003 thousand and EUR 253 thousand for Water and Sewerage respectively, there

is no detailed information on where they have been placed. For this reason, EYDAP SA has proceeded to a proportional apportionment of these funds for Water Supply and Sewerage, based on the amount charged to each

facility, in relation to the total Water Supply or Sewerage respectively, from outside expenditure.

219

Electricity generation

using solar photovoltaic

technology

CCM 4.1

2,00

0,00%

M/EP

0,00%

Production of electricity

from hydropower

CCM 4.5

2,00

0,00%

M/EP

0,00%

Construction, extension

and operation of water

collection, treatment and

supply systems

CCM 5.1 /

WTR 2.1

16.462,00

24,65%

M/EP

32,54%

Construction, extension

and operation of

wastewater collection

and treatment systems

CCM 5.3 /

WTR 2.2

46.555,00

69,72%

M/EP

65,42%

Transport by

motorcycles, passenger

cars and light commercial

vehicles

CCM 6.5

16,00

0,02%

M/EP

0,02%

Acquisition and

ownership of buildings

CCM 7.7

36,00

0,05%

M/EP

0,03%

CapEx from Unallocated Activities

(A.2)

63.071,00

94,46%

98,1%

CapEx from Eligible Activities

(A1+A2)

63.071,00

94,46%

98,1%

B. ACTIVITIES NOT ELIGIBLE FOR CLASSIFICATION

CapEx not eligible for classification

Activities (B)

3.699,00

5,54%

Total CapEx (A+B)

66.770,00

100%

220

N - Yes, activity eligible for the Taxonomy and aligned with the Taxonomy for the relevant environmental objective

O - No, activity eligible for the Taxonomy but not aligned with the Taxonomy for the relevant environmental objective

OP - Activity eligible for the Classification for the relevant objective

N/A - Activity not eligible for the Classification for the relevant environmental objective

221

CapEx ratio / Total CapEx

Aligned with the

taxonomy by objective

Eligible by the taxonomy

by objective

CCM

94,46%

CCA

WTR

94,38%

PPC

BIO

222

Table 14. Percentage of OpEx

from activities related to taxonomy-aligned economic activities - disclosure covering fiscal year 2024

Financial Year

2024

Criteria for a significant contribution

DNSH (No Significant Harm) criteria

Financial

Activities

Code

OpEx

Percentage of OpEx for the financial

year 2024

Climate Change Mitigation

Adaptation to Climate Change

Water Resources

Circular Economy

Pollution

Biodiversity and Ecosystems

Climate Change Mitigation

Adaptation to Climate Change

Water Resources

Circular Economy

Pollution

Biodiversity and Ecosystems

Minimum Social Security

Percentage of OpEx aligned (A.1) with

or eligible (A.2) for the EU t

axonomy

for the financial year 2023

Category (favourable activity)

Category (transition activity)

€'000

N, O,

M/E-P

N, O,

M/E-

N, O,

M/E-P

N, O,

M/E-P

N, O,

M/E-P

N, O,

M/E-P

N/O

A. ACTIVITIES ELIGIBLE FOR CLASSIFICATION

A.1 Environmentally sustainable activities (aligned with the taxonomy)

OpEx of

environmentally

sustainable

activities

(aligned with

For the Taxonomy KPIs 2024 OpEx table the following procedure was followed: First, the Accounting accounts were selected that relate to direct non-

capitalized costs associated with the taxonomy-eligible activities. Then, exclusively for these Accounting Accounts, only the direct costs registered in the

company's ERP were collected. The resulting amount was the denominator of the relevant indicator. Then specific water and wastewater activities were

selected, combined with cost centres, direct costs were obtained directly and only direct costs were obtained from the company's ERP and for the above

Accounting Accounts in order to extract costs for specific areas of activities required by the taxonomy. The individual category-by-category amounts are also

the individual category-by-category Numerator of the relevant indicator

*The OPEX 2023 rates were calculated on a different basis and are therefore not fully comparable with those of 2024.

223

the taxonomy)

(A.1)

Of which favourable

activities

Of which transition activities

A.2 Activities eligible for the taxonomy but not environmentally sustainable (activities not aligned with the taxonomy)

Electricity

generation using

solar

photovoltaic

technology

CCM 4.1

20,00

0,03%

M/EP

0,10%

Production of

electricity from

hydropower

CCM 4.5

151,00

0,23%

M/EP

0,38%

Construction,

extension and

operation of

water collection,

treatment and

supply systems

CCM 5.1/

WTR 2.1

17.787,00

26.99%

M/EP

55,14%

Construction,

extension and

operation of

wastewater

collection and

treatment

systems

CCM 5.3/

WTR 2.2

27.634,00

41,93%

M/E

M/EP

39,45%

Transport by

motorcycles,

passenger cars

CCM 6.5

2.726,00

4,14%

M/E

M/EP

1,91%

224

and light

commercial

vehicles

Acquisition and

ownership of

buildings

CCM 7.7

1.729,00

2,62%

M/E

M/EP

3,01%

OpEx from Unallocated

Activities (A.2)

50.047,00

75,94%

100%

OpEx from Eligible Activities

(A1+A2)

50.047,00

75,94%

100%

B. ACTIVITIES NOT ELIGIBLE FOR CLASSIFICATION

OpEx ineligible for

classification

Activities (B)

15.856,00

24,06%

Total OpEx (A+B)

65.903,00

100,0%

N - Yes, activity eligible for the Taxonomy and aligned with the Taxonomy for the relevant environmental objective

O - No, activity eligible for the Taxonomy but not aligned with the Taxonomy for the relevant environmental objective

OP - Activity eligible for the Classification for the relevant objective

N/A - Activity not eligible for the Classification for the relevant environmental objective

225

Percentage OpEx / Total OpEx

Aligned with the

taxonomy by objective

Eligible by the taxonomy

by objective

CCM

75,94%

CCA

WTR

68,92%

PPC

BIO

226

Table1 5. Notifications for activities related to nuclear energy and fossil gases

Activities related to nuclear energy and fossil

Activities related to nuclear energy

The company conducts, finances or has openings in the research, development,

demonstration and exploitation of innovative power generation facilities that

produce energy from nuclear processes with minimal waste from the fuel cycle.

The undertaking shall undertake, finance or have openings for the construction

and safe operation of new nuclear installations for the production of electricity or

industrial heat, including for district heating purposes or for industrial processes

such as hydrogen production, as well as safety upgrades, using the best available

technologies.

The undertaking shall undertake, finance or have openings in the safe operation

of existing nuclear installations producing electricity or industrial heat, including

for district heating purposes or for industrial processes such as the production of

hydrogen from nuclear energy, as well as safety upgrades.

Activities related to mineral gases

The enterprise undertakes, finances or has exposure to the construction or

operation of power generation facilities that produce electricity using fossil

gaseous fuels.

The company undertakes, finances or is open to the construction, renovation and

operation of combined heat/cooling and electricity generation plants using fossil

gaseous fuels.

The company undertakes, finances or has openings in the construction,

renovation and operation of heat generation facilities that produce heat/cooling

using fossil gaseous fuels.

227

ESRS E1 - Climate Change

● Strategy

[ESRS E1-1] Transition plan for achieving climate neutrality

E1- 1_16

The Company, at this time, does not have a comprehensive and formally approved transition

plan as defined by the ESRS. However, the importance of formulating such a plan to

progressively align its operations with the objectives of climate neutrality and green transition

is recognized. For this reason, a process has been initiated to develop and adopt the plan

within the next reporting period as part of the company's broader sustainability strategy.

228

[ESRS 2 SBM-3] Significant impacts, risks and opportunities and their interaction with the

strategy and business model

E1.SBM-3_01

To assess the risks and opportunities, the magnitude of the financial impact was considered

for both current and potential risks. For potential risks, the probability of their occurrence was

also considered in combination. The magnitude of the financial impact was assessed

qualitatively using a financial scale, depending on the nature and availability of the data.

Climate-related risks and opportunities were examined across the entire value chain and risks

related to both the operation of the business itself and upstream and downstream activities

were identified as important.

Regarding the categorisation of risks and opportunities, the risks are classified as material risks

which arise from natural climate hazards and were not qualified as significant transition risks.

More specifically, the following were qualified as significant climate-related risks:

Table 16. Significant material risks arising from natural hazards

Significant material risks arising from natural hazards

Existing Financial

Consequences

Potential Financial

Consequences

Description of risk

2025

2026-

2030

>2030

√

ANANTI & CATANTI

Unsafe water supply of Attica due to

failure of the EWS due to climate change

(drought/snowfall/floods) may lead to

economic impacts.

√

SAME FUNCTION

Inefficient operation of a signal reception

centre due to the non-use of electronic

surveillance systems (CCTV), or due to the

use of old technology alarms, resulting in

inaccurate fault detection due to extreme

weather events that are increasing in the

context of climate change can lead to

economic impacts.

The Company is already in the process of assessing climate risks according to the most up-to-

date climate models. At the same time, a calculation of the probability of occurrence of

significant climate risks that are able to affect facilities and economic activities and an

assessment of their impact is being carried out, while proposals are being developed for the

adoption of adaptation measures in cases where the level of risk is assessed as high.

229

According to the analyses carried out so far for the RCP 8.5 scenario and for the time horizon

2050, high exposure to drought and water stress is predicted for all EYDAP SA facilities.

For the time horizon 2050, high exposure to forest fire is expected for the Galatsiou MEC,

Acharnon MEC, the Photovoltaic Station of Acharnon MEC, the Metamorphosis MEC, and the

Koropi MEC.

Regarding the climate risk of flooding for the RCP 8 scenario.5 and for the time horizon 2050,

high exposure is predicted in Marathon Reservoir, Yliki Reservoir, Euinos Reservoir, Euinos

WWTP, Mornos Reservoir, Kithairona WWTP, Leuctra/Ellopia Pumping Station and in Megara

WWTP, Psyttalia WWTP, Metamorphosis WWTP, Acharnon WWTP, Acharnon PV Station,

Thebes WWTP Pumping Station.

Finally, for the RCP 8.5 scenario and for the 2050 time horizon, high exposure to soil erosion is

predicted at the Euinos EIS, Elikonas EIS, Euinos and Mornos Reservoirs, and at the Prodromos

and Panagia Kalamiotissa Post Refineries.

Water scarcity is one of the most important climate risks, with increasing impacts on the

accessibility and availability of water resources. Recognising the importance of adapting to this

risk, EYDAP SA has developed strategies and is planning projects that will enhance its resilience

to the impacts of climate change.

EYDAP SA is working with the Ministry of Environment, studying a range of solutions including

access to additional surface and groundwater resources, desalination and wastewater reuse.

Projects are underway to reinforce the existing external aqueduct system of Attica, including

the reactivation of its boreholes.

In this context, projects and actions are being planned and launched to address water scarcity,

including:

● Water resources interconnection projects, such as the planned interconnection of the

Krikeliotis and Karpenisiotis rivers with the Evinos reservoir, aiming at enhancing water

supplies.

● Hydrogeological studies for the exploitation of groundwater systems.

● Infrastructure projects for the possibility of emergency reinforcement of the water

supply system with water from the river Acheloos.

● Study for the construction of seawater desalination plants as an alternative source.

● Studies and projects for wastewater reuse and utilisation of the Adrian Aqueduct.

In 2024, EYDAP SA started its participation in the EU HORIZON THESEUS programme, in the

framework of which it is implementing a strategic reuse study for Attica, completing the study

completed in 2024 for Eastern Attica. At the same time, in 2024, funded projects and pilot

projects for decentralised water reuse from the sewer mining network were launched and are

ongoing in the Municipalities of Markopoulou (EU HORIZON IMPETUS research project) and

Athens (Cooling Havens project). Also, in 2024, the major part of the green water supply

project in Halandri, from the Adrianio Aqueduct, was implemented.

230

Informing consumers, local authorities and industry about the potential for reducing water

consumption and replacing drinking water with non-potable (untreated or recycled) water for

all uses other than human consumption and hygiene is also an integral part of the adaptation

strategy.

Finally, EYDAP SA is launching water network projects to reduce losses and install smart

meters, further enhancing sustainable water management.

Sustainable Water Resources Management

EYDAP SA implements strategic projects and actions aimed at the sustainable management of

water resources and the reduction of the risk of water scarcity. The main interventions include:

● Installation and operation of green decentralised reuse plants (sewer mining) and use

of the Roman Adrian Aqueduct for green water supply and increasing green spaces.

● Public awareness initiatives, such as the "Do you want water? Turn off the tap", aimed

at reducing consumption and raising awareness.

● Installation of smart meters in two municipalities of Attica and more general water

supply network projects and water treatment facilities to reduce leakages.

● Studies on the exploitation of the brackish water sources of Kirra, Mylon and Kalamos

in Attica, including assessment of reserves, water quality, required desalination

projects and interconnection with aqueducts.

These actions constitute a key pillar of EYDAP's ESG strategy, contributing both to the

sustainable management of water resources and to the strengthening of the resilience of the

Agency against climate change.

E1.SBM-3_02_03

EYDAP SA's business model reflects the range of the Company's activities and incorporates

important factors such as the direct response to market trends, the maintenance of excellent

relations with its partners, the application of technological innovations, as well as all those

elements that ensure its successful course to date.

EYDAP's business model and strategy is based on the principles of sustainable development,

enabling it to proactively manage risks - and exploit opportunities - in order achieve its short,

medium and long-term objectives. One of the most important risks to the resilience of EYDAP

SA in the long term is climate change. By managing climate risk through its business strategy

and investments, EYDAP SA is also exploiting important opportunities, such as reducing its

carbon footprint through energy efficiency projects at its plants, the development of

photovoltaic projects, the electrification of the fleet, and increasing biogas production from

wastewater treatment.

Much of the indicators for monitoring the strategy and business model are aligned with

modern ESG standards. In addition, the company has a reward system in place to coordinate

efforts and participate in achieving a collective result.

In addition, the Strategy and Innovation Directorate in conjunction with the Board Committee

on Strategy, Innovation and Sustainable Development ensures that the strategy design takes

231

into account, in addition to the important issues arising from the dual materiality analysis,

European and national trends and policies and technological developments. To this end,

EYDAP SA actively participates in the major relevant European networks and in European and

international consultations.

In the context of sustainable development and strengthening resilience to climate change,

EYDAP SA implements climate neutrality and circular economy policies. It aims at constant

improvement of its processes and makes investments such as upgrading its Water Treatment

Plants to reduce water consumption and enhancing the energy efficiency of its facilities. In

addition, a significant part of the investment plan concerns maintenance and repairs of water

supply and sewerage networks to reduce leaks and blockages.

In order to reduce its carbon footprint, EYDAP SA is making an energy transition to renewable

energy sources through hydroelectric projects and photovoltaic stations, gradually replacing

its fleet with electric vehicles and strengthening its infrastructure. Particularly critical for 2024

are the plans to tackle water scarcity, with urgent projects to reinforce the Mornos-Euinus

water intake system. At the same time, EYDAP SA is examining different scenarios to meet

future water needs, opting for solutions that will put less strain on reservoirs and have the

best cost-benefit ratio.

E1.SBM-3_04

The resilience analysis of the strategy and business model of EYDAP SA started in 2023 with

the intrinsic and residual assessment of the identified business risks in order to prioritize them

in terms of their importance for further mitigation.

The identification, assessment and management of potential risks are very critical and

important factors that the Company manages with great care and invests resources and

personnel to assess them. By extension, in the context of strengthening the resilience of the

Company's strategy and business model in relation to climate change, the Company is in the

process of assessing climate risks (current and future), taking into account existing analyses

and the most up-to-date scientific data and climate scenarios, and will be periodically updated

to ensure continuous adaptation to changing climate conditions.

The analysis will be used to assess the risks and opportunities and their impacts on EYDAP SA

in two climate scenarios for natural risks and one for transient/events. These scenarios are

common sets of assumptions derived from the discrete combination of two widely used

climate pathway scenarios, namely representative concentration pathways (RCPs) and

common socio-economic pathways (SSPs). Until the IPCC's 5th Assessment Report (AR5, 2014),

RCPs were the basis for climate scenario analysis, while combined scenario modelling of SSPs

and RCPs was first carried out by the IPCC in the 6th Assessment Report, which was issued in

2023. Based on this methodology, anthropogenic CO

emissions appear to be slightly different

from those of RCP scenarios only, and thus climate and weather events are also expected to

show small differences. In view of the above, the assessment of the likelihood of a natural

climate risk occurring will be based on the RCP modelling assumptions in line with the IPCC

5th Assessment Report. The climate scenarios that will be used for the assessment of risks and

opportunities and their impacts in the EIA are RCP4.5 and RCP8.5 for the natural hazards

analysis and the RCP1.9 scenario that is in alignment with the IEA NZE as presented in more

232

detail in the table below. Also, the assessment of the climate analyses for natural hazards has

so far been based on statistical time series analysis for a number of climate indicators for

different time periods. The datasets and climate indicators used are fed from the CMIP6

platforms corresponding to the latest IPCC AR6 report, but also from CMIP5, data which have

been downscaled with the help of the EURO-CORDEX experiments to a horizontal spatial

resolution of 11 km (EURO-CORDEX). More information on the analysis of transient hazards is

discussed in E1.IRO-1_09-10& 12-13&15&19-20.

233

E1.SBM-3_05

EYDAP SA has adopted the following time horizons in alignment with the CSRD:

● Short Term Time Horizon (2025): set at one year after the evaluation

● Medium-term time horizon (2030): set at 2-5 years after the evaluation

● Long-term time horizon (>2030): defined as at least 6 years after the assessment year,

further extended, where appropriate, to align with the type of climate risk being

assessed and the timeframe within which it can be reliably addressed

E1.SBM-3_06

As part of the resilience analysis, and the ongoing exercise on climate risk analysis, the results

of the future climate scenarios RCP4.5 and 8.5 are used to analyse natural hazards which

contain inherent uncertainties. As the exercise is ongoing, the uncertainty areas of the

resilience analysis have not yet been confirmed. The methodological approach proposed and

followed so far assesses the potential impacts from each climate parameter for specific

relevant indicators. Part of the existing analysis for 2024 includes the parameters of flood, sea

level rise, extreme wind and forest fire, for which the economic impacts for the Company's

facilities were assessed by evaluating part of the Company's exposure analysis for these

parameters, and the Company's vulnerability assessment to determine the material climate

risks for specific types of facilities at each location. In terms of flood risk, the Ministry of

Environment and Energy's Potentially High Flood Risk Zone (HPFZ) maps were also considered

for existing conditions.

To assess the projected financial impact on assets based on their level of exposure, relative

vulnerability curves were examined, linking the percentage of loss to the value of the assets

and then the results were linked to a five-point scale of financial impact that exists within the

existing business plan (ERM).

In this phase of the analysis, the exposure to material climate hazards was examined in terms

of the operational characteristics of the CCL and the LWR, taking into account the vulnerability

curves for each facility. The analysis, as presented in more detail below, highlights the presence

of significant physical risk for the facilities of Acharnon, Aspropyrgos, Polydendriou, and KELs

of Thriasio and Megara, following relevant analyses based on existing analyses and climate

model analyses. In the next stage the analysis will be specialised both on the impacts that

climate change may have on equipment, transport, catering networks and staff hygiene and

safety. This exercise is already underway so that the company will be in a position to disclose

it in its next sustainability report

E1.SBM-3_07

EYDAP SA, recognising the impacts of climate change, has developed a comprehensive

adaptation plan covering the short, medium and long term horizon.

234

● In the short term, the company focuses on risk management through the optimisation

of existing infrastructure and the implementation of technologies to detect and

reduce leaks in the water supply network. In addition, it maintains a strong financial

position, with access to borrowing and financial instruments, ensuring an affordable

cost of capital to support immediate adaptation actions.

● In the medium term, EYDAP's strategy includes the upgrading of existing

infrastructure, such as refineries and sewerage networks, in order to be resilient to

extreme weather events and changes in hydrological conditions. At the same time, the

company is investing in alternative sources of water supply, such as water reuse and

desalination technologies, while adapting its business model to new regulatory

requirements and environmental ESG criteria, ensuring continued access to

sustainable financing.

● In the long term, EYDAP SA aims to create a fully resilient and sustainable water

resources management system, incorporating innovative practices and smart

technologies, such as the digitalisation of water supply and the use of artificial

intelligence data to improve network performance. In addition, its strategy includes

redeploying and upgrading assets, as well as re-skilling its workforce to meet the

demands of the green transition.

With this integrated approach, EYDAP SA ensures that it can respond effectively to the

challenges of climate change, while maintaining the sustainability of its business and the

continuous provision of high quality services to citizens.

235

● Managing impacts, risks and opportunities

[E1-2] Policies on climate change mitigation and adaptation

E1.MDR-P_01-06 & Ε1-2_01

EYDAP SA through its Environmental Policy is committed to protecting the environment, to the

transition to a low-carbon economy, to addressing the challenges of Climate Change and to

contributing to the achievement of the Global Development Goals. In addition, it is committed

to adapting to climate change by operating in an environmentally responsible manner, aiming

to reduce its carbon footprint. It is also committed to continuously reviewing the rational use

of energy in the light of new technological developments. Furthermore, the company's policy

covers the entire value chain and all EYDAP SA activities in Greece. Therefore, it is observed

that the policy contributes to climate change adaptation as well as to the production of energy

from RES.

The environmental policy of EYDAP SA covers the whole range of its operations. The policy is

implemented by all employees of the company and therefore the highest level of the company

is the position of the CEO. In addition, the policy contributes to the United Nations Goal 13.

Stakeholder groups that are affected and benefit directly or indirectly from the policy include:

● Local communities

● National and local regulatory authorities

● Educational and voluntary communities

● Suppliers

The policy is posted on the company's website where all interested parties can access it, here.

In addition, although the company does not currently have a material impact on climate

change, the Environmental Policy is aligned with the company's intention to contribute to

climate change mitigation.

236

[E1-3] Actions and resources related to climate change policies

E1.MDR-Α_01_02_03_05 - E1-3_03

The Company, with environmental responsibility, incorporates transformation actions in its

operations, aiming to reduce its carbon footprint. A strategy has been drawn up to improve

energy efficiency and reduce its carbon footprint by 2030 through 3 axes of actions:

● Energy saving during the production process

● Production of energy from RES (PV, CHP) at the company's facilities

● Electricity supply contracts

The organisation is committed to climate change mitigation actions through its policy. Briefly,

the actions relate to the following:

● Upgrading the fleet with electric vehicles

● Installation of PV devices

● Completion of energy upgrading of pumping stations and facilities

● Green electricity supply contracts

● Pilot application of an innovative material, the Environmental Fuel Additive

● Energy savings

This is the context for the emission reductions observed between 2023-2024 (see following

graph):

● Scope 2: The decrease is due to the new electricity supply contract that came into

force from 01.08.2024, under which 50% of the energy we supply is with guarantees

of origin (energy from RES).

In addition, the following changes have occurred:

● Scope 1: The increase is mainly due to the receipt of the water supply and sewerage

network of Megareon, as well as the receipt of two additional WWTPs (Megara &

Koropi), resulting in an increase in mainly fugitive emissions (ESD - Category 1.4)

● Scope 3: The increase is due to the high electricity consumption of the facilities of

EYDAP NPO (EYS) from 07.2024 due to water scarcity.

237

238

Table 18. Key actions (existing & planned) in relation to climate change policies

Actions

Time horizon

for start-up

Time

horizon for

completion

Expected Results

Correlation with relevant

policy objectives

Scope of application

Progress of actions notified in

previous periods

Activities

Value chain

Geographical

limits

Affected stakeholders/

Internal stakeholders

Quantitative and qualitative

information

MDR-A_01

MDR-A_03

MDR-A_01

MDR-A_02

MDR-A_05

Implementation of a programme to cover

more than 80% of the General Directorate of

Water Supply's electrified units in the event

of a power cut to ensure the security of

water supply

2024

2025

Increasing the energy autonomy

of the water supply facilities of

EYDAP SA, enhancing resilience

to power outages,

Rational use of energy,

Adaptation to climate change,

Reduction of carbon footprint

Energy production

Same function

Attica

Society

Existence of a THALES plan for heavy rainfall

(alert graduation) and its updating

The

Directorate-

General for

Drainage

(activates an

action plan

(THALES) in

case of

flooding in the

drainage

network

After the

end of the

phenomeno

Adaptation to severe weather

events in order to ensure

business continuity

Climate change adaptation,

Natural disaster risk

management

Facilities

Ananti

Same Function

Downstream

Attica

Local communities,

National and local

regulatory authorities

Not activated in 2024

Participation in the implementation of the

XENOCRATES project, when the need arises

In the

implementatio

n of the

Xenocrates

Plan, EYDAP

S.A. assists

with

personnel,

means and

resources (e.g.

with

obstruction

vehicles to

transport

water to

support the

work of the

Fire Service)

upon request

At the end

of each

danger -

disaster.

With the

elimination

of each

danger.

Rapid response and coordinated

management of natural

disasters (e.g. floods, heavy

rainfall)

Climate change adaptation,

Natural disaster risk

management

Facilities

Ananti

Same Function

Downstream

Attica

Local communities,

National and local

regulatory authorities

In the fire season of 2024, EYDAP

S.A. contributed with blocking

vehicles supporting the work of

the Fire Service by transferring

water to fill the fire trucks.

239

Actions

Time horizon

for start-up

Time

horizon for

completion

Expected Results

Correlation with relevant

policy objectives

Scope of application

Progress of actions notified in

previous periods

Activities

Value chain

Geographical

limits

Affected stakeholders/

Internal stakeholders

Quantitative and qualitative

information

MDR-A_01

MDR-A_03

MDR-A_01

MDR-A_02

MDR-A_05

from the

Ministry and if

possible after

approval by

the

Administration

Existence of a disaster recovery plan

By the

individual

operators of

each

installation

After every

disaster

Ensuring business continuity

after natural disasters,

minimising impacts on water &

wastewater infrastructure, rapid

recovery of critical operations

Climate change adaptation,

Natural disaster risk

management

Crisis response

and damage

restoration

Same

function,

Downstream

Attica

Local communities,

National and local

regulatory authorities

Energy optimization of the KEL Psitallia - 5-

year operation & maintenance contract

2022

2027

In total, in the 5th contract year,

an overall reduction of 34.78%

(minimum) in the energy

consumption of the KELPS is

foreseen.

Rational use of energy

Adapting to climate change

Reducing its carbon footprint

Waste water

treatment

Same Function

Attica

Directorate for Waste

Water Treatment

Centres

During the 2nd contract year,

(April 2023 - April 2024) the

percentage reduction in annual

energy supply was 26.65%

compared to the target of 18.07%

projected by the overall reduction

in energy consumption of KELPS

Upgrading of existing hydroelectric plants

(Kirfi, Helicon, Kithairona and Mandra)

2024

2025

With regard to the MYES, they

are going to:

● 1,06MW MYES installed at the

Mornos dam

● upgrading the existing Kirfi

NPP to 1.22MW and Helicon

NPP to 1.22MW.

Regarding PV:

● a tender is expected to be

launched in 2025 for the

supply of 7 PV plants with a

total capacity of 9.7 MW (the

applications for the

Climate neutrality

Electricity

generation

Same Function

Central Greece,

Attica, Attica

Water Directorate

240

Actions

Time horizon

for start-up

Time

horizon for

completion

Expected Results

Correlation with relevant

policy objectives

Scope of application

Progress of actions notified in

previous periods

Activities

Value chain

Geographical

limits

Affected stakeholders/

Internal stakeholders

Quantitative and qualitative

information

MDR-A_01

MDR-A_03

MDR-A_01

MDR-A_02

MDR-A_05

connection of the new PV

plants have been completed)

● 2 new on-ground PV stations

are to be installed at the

Acharnon and Polydendri

NPPs with a total capacity of 2

MW with net-metering, for

which there is an active

contract with the Contractor

for their supply and

installation. Their expected

completion is 2025.

Energy utilization of biogas at the KEL

Metamorphosis with the installation of a

combined heat and power plant (CHP) have

been included in the investment program

Adapting to climate change

Reducing its carbon footprint

Waste water

treatment

Same Function

Attica

Directorate for Waste

Water Treatment

Centres

Energy upgrading and construction of new

pumping stations of the Polydendri MES

2025

2028

Replacement of pumps with

new modern high efficiency

pumps and low loss motors.

Construction of a new building

for a refined water pumping

station.

Replacement of MT substations

with low-loss transformers.

Installation of a modern

distribution network and motor

drive systems.

Adapting to climate change

Reducing its carbon footprint

Water treatment

plants (WTPs)

Same Function

Attica

EMEN

The continuous actions in the

WTPs have brought, in addition to

the operational upgrades, a 23%

reduction in electricity in the last 4

years, which consists of an energy

consumption from 14.70

kwh/1000m3 in 2020 to 11.10

kwh/1000m3 in 2024, despite the

fact that the new Elyos

Management Units in the four

WTPs have been gradually put into

operation from 2021-2024,

through which approximately

5,000,000 cubic meters of water

are saved on an annual basis.

Replacement of 66 low energy consumption

electric servo motors to replace the

pneumatic valves of the refining filters of the

New Unit of the Acharnon NPP

2023

2024

Reduce CO2 emissions and

electricity supply, increase the

resilience of the water

treatment system

Rational use of energy,

Reduction of carbon footprint

Water treatment

plants (WTPs)

Same Function

Attica

EMEN

241

Actions

Time horizon

for start-up

Time

horizon for

completion

Expected Results

Correlation with relevant

policy objectives

Scope of application

Progress of actions notified in

previous periods

Activities

Value chain

Geographical

limits

Affected stakeholders/

Internal stakeholders

Quantitative and qualitative

information

MDR-A_01

MDR-A_03

MDR-A_01

MDR-A_02

MDR-A_05

Supply of 30 new low energy consumption

dosing pumps for sodium hypochlorite,

polyelectrolyte and liquid sulphuric clay at all

4 Water Treatment Plants

2024

Reduction of CO2 emissions and

electricity supply

Rational use of energy,

Reduction of carbon footprint

Water treatment

plants (WTPs)

Same Function

Attica

EMEN

The ongoing actions outlined

above are expected to further

reduce energy consumption by

2.5-4 % compared to 2024.

Supply of new modern vertical pump units of

high efficiency and low energy consumption

for the Recovery Unit of the Aspropyrgos

MES

2024

Reduction of CO2 emissions and

electricity supply

Rational use of energy,

Reduction of carbon footprint

Water treatment

plants (WTPs)

Same Function

Attica

EMEN

Replacement of 100 new low energy

consumption electric servo motors for the

full automation of all the processes of the

final stage of the water treatment of the

water of the MES

2025

2027

Reduction of CO2 emissions and

electricity supply

Rational use of energy,

Reduction of carbon footprint

Water treatment

plants (WTPs)

Same Function

Attica

EMEN

Supply of 12 new modern low energy

consumption air compressors for all 4 ICUs

2024

2025

Reduction of CO2 emissions and

electricity supply

Rational use of energy,

Reduction of carbon footprint

Water treatment

plants (WTPs)

Same Function

Attica

EMEN

Supply of new three-phase gensets with new,

high efficiency and low energy consumption

gensets in all 4 Water Treatment Plants

2024

2026

Reduction of CO2 emissions and

electricity supply

Rational use of energy,

Reduction of carbon footprint

Water treatment

plants (WTPs)

Same Function

Attica

EMEN

Supply of 16 new high performance and low

energy consumption electric gates to the

Polydendri NICU

2025

2027

Reduction of CO2 emissions and

electricity supply

Rational use of energy,

Reduction of carbon footprint

Water treatment

plants (WTPs)

Same Function

Attica

EMEN

Replacement of 9 modern low energy

consumption blowers

2024

2025

Reduction of CO2 emissions and

electricity supply

Rational use of energy,

Reduction of carbon footprint

Water treatment

plants (WTPs)

Same Function

Attica

EMEN

Replacement of all the high efficiency and

low energy consumption washing pumps for

the 4 Water Treatment Plants and the high

efficiency and low energy consumption

reclaimed water.

2025

2027

Reduction of CO2 emissions and

electricity supply

Rational use of energy,

Reduction of carbon footprint

Water treatment

plants (WTPs)

Same Function

Attica

Water Directorate

The tender for the supply and installation of

2 photovoltaic plants on the ground at the

Acharnon and Polydendri NPPs with a total

capacity of 2 MW with net-metering was

completed.

2025

Reduction of CO2 emissions and

electricity supply

European Green Deal

Water treatment

plants (WTPs)

Same Function

Attica

Water Directorate

Submission of connection applications for

the development of new photovoltaic power

2027

Reduction of CO2 emissions and

electricity supply

European Green Deal

Water treatment

plants (WTPs)

Same Function

Attica

Water Directorate

242

Actions

Time horizon

for start-up

Time

horizon for

completion

Expected Results

Correlation with relevant

policy objectives

Scope of application

Progress of actions notified in

previous periods

Activities

Value chain

Geographical

limits

Affected stakeholders/

Internal stakeholders

Quantitative and qualitative

information

MDR-A_01

MDR-A_03

MDR-A_01

MDR-A_02

MDR-A_05

plants at EYDAP SA facilities, with a total

capacity of 11.6MW

Approval to replace 69 vehicles and 16 two-

wheelers with electric vehicles and

installation of the network for their charging

2025

Total estimated carbon footprint

reduction : 348 tCO2e in 4 years

of use (if cars are charged from

existing facilities) and 470 tCO2e

for 50% charging from "green"

energy

European Green Deal

Movement of staff

Same Function

Attica

Local community

Approval of the open tender for the

preliminary designs and the tender

documents for the construction of a new

bioclimatic building complex for the

company's services at its privately owned

land in Galati, which will be implemented on

the basis of the 1st prize of the Architectural

Ideas Competition completed by EYDAP SA.

2029

It cannot be

estimated.

The

competition

for the

preliminary

designs has

been

announced

but is not

opened (we

keep giving

time

extensions)

due to a pre-

litigation

appeal by

the

company

that won the

A prize in

the

Architectural

Ideas

Competition

. With the

20/2025

EADESY

Decision,

Realisation of the real estate

assets of EYDAP SA

Saving resources

Reduction of operating costs

European Green Deal

Housing of EYDAP

SA services

Same Function

Attica

Employees

243

Actions

Time horizon

for start-up

Time

horizon for

completion

Expected Results

Correlation with relevant

policy objectives

Scope of application

Progress of actions notified in

previous periods

Activities

Value chain

Geographical

limits

Affected stakeholders/

Internal stakeholders

Quantitative and qualitative

information

MDR-A_01

MDR-A_03

MDR-A_01

MDR-A_02

MDR-A_05

EYDAP SA

won the pre-

trial appeal,

but the

company

appealed

the Decision

to the

Administrati

ve Court of

Appeal and

the hearing

is set for

Monday

07/04/2025

Preparation of reconnaissance studies for the

identification and exploitation of any escaped

hydrodynamics at the sites of the

hydropower projects located along the

Mornos waterway.

The market is

being

investigated to

find

companies

that can

undertake the

reconnaissanc

e studies

The upgrade

of the MHYS

is estimated

to be

completed

in 2030

Total estimated increase in RES

production from the

rationalization/upgrade of all

existing RES (Kirfi, Elikonas,

Kithairona and Mandra) : 17

GWh / year, and estimated

energy production from the

development of new PV in

EVDAP SA owned sites : 41.5

GWh / year.

Increasing energy production

from RES, reducing carbon

footprint

Energy production

& management

from RES

Same function

Central Greece

Water Directorate

There are no

Signing of the contract (01.08.2024) for the

tender for the supply of electricity to the

facilities of EYDAP SA, with the requirement

that 50% of it be with guarantees of origin

from RES.

2024

Reducing the carbon footprint of

EYDAP SA, enhancing the use of

clean energy, increasing the

sustainability of energy supply

Increasing energy production

from RES, reducing carbon

footprint

Energy supply &

facilities

management

Anandi,

Same function

Attica

Regulatory authorities,

Energy suppliers

Redesign of the Transport Operating Model

(Target Operating Model-TOM)

Development of Fleet Management

specifications

Strategic Allocation Design (Strategic

Allocation Design)

2021

2030-

Optimising transport fleet

management, reducing

operating costs, increasing

efficiency and reducing the

environmental footprint

Reduction of carbon footprint

Transport &

Logistics

Same function

Attica

Procurement

Directorate

Study completed.

The update of the Technical

Specifications is urgent.

A GPS installation is in progress in

the fleet of EVDAP SA's leased

vehicles.

244

Actions

Time horizon

for start-up

Time

horizon for

completion

Expected Results

Correlation with relevant

policy objectives

Scope of application

Progress of actions notified in

previous periods

Activities

Value chain

Geographical

limits

Affected stakeholders/

Internal stakeholders

Quantitative and qualitative

information

MDR-A_01

MDR-A_03

MDR-A_01

MDR-A_02

MDR-A_05

Pilot application of an innovative material,

the environmental fuel additive (AdBlue

Additive)

In 2024,

EYDAP SA

purchased a

quantity of

3600 Litres of

additional

AdBlue for the

entire

compatible

fleet of

vehicles

The supply

of the

additive now

covers all

compatible

vehicles

(100%) and

is expected

to remain

stable for

the

foreseeable

future

Reducing the carbon footprint

from internal combustion

engines. In particular, it

drastically reduces black carbon

(PM, CO, HC), the second largest

anthropogenic contributor to

Climate Change, which accounts

for two thirds of the climate

impact of CO2. It also reduces

the consumption of liquid fossil

fuels and in the same

percentage the emissions of

carbon dioxide (CO2) and

nitrogen oxides (NOx). It also

reduces fuel consumption,

resulting in further percentage

reduction of pollutants,

including CO2 (Carbon Dioxide)

and NOx (Nitrogen Oxides),

without increasing the

concentration (ppm) in the

volume of residual combustion

products and without creating

new ones.

From the result of the pilot

implementation, it was found:

improvement of pollutants and

exhaust emissions by 60%,

reduction of fuel by 15% and

reduction of operating costs.

CARBON DIOXIDE REDUCTION

MEASURES & ENERGY

FOOTPRINT

Transport optimisation:

Reducing energy consumption

in transport.

Transfer of EYDAP

SA staff and

materials

Same Function

Attica

Employees

Pilot application of an innovative material,

the environmental fuel additive (Marbel

Additive) (voluntary action)

In 2024,

EYDAP SA

purchased a

quantity of

545 litres of

MARBEL

additive for

The supply

of the

additive now

covers all

compatible

vehicles

(100%) and

EYDAP SA has been using the

additive for the last few years

and it is estimated to bring a

mid-standard fuel reduction of

up to 15%, depending on the

technology, fuel, age and driving

conditions of the vehicle.

CARBON DIOXIDE REDUCTION

MEASURES & ENERGY

FOOTPRINT

Transport optimisation:

Reducing energy consumption

in transport.

Transfer of EYDAP

SA staff and

materials

Same Function

ATTIKI: Area of

responsibility of

EYDAP SA

Employees of EYDAP SA

Residents of Attica

245

Actions

Time horizon

for start-up

Time

horizon for

completion

Expected Results

Correlation with relevant

policy objectives

Scope of application

Progress of actions notified in

previous periods

Activities

Value chain

Geographical

limits

Affected stakeholders/

Internal stakeholders

Quantitative and qualitative

information

MDR-A_01

MDR-A_03

MDR-A_01

MDR-A_02

MDR-A_05

the entire

compatible

fleet of

vehicles

is expected

to remain

stable for

the

foreseeable

future

The TRINEFLEX research project is shaping an

integrated service to manage the energy

consumption of large installations and their

transition to a more flexible and sustainable

operation. The project is implemented at the

Wastewater Treatment Centre of

Metamorphosis.

Improvement of process energy

efficiency by >7%, reduction of

energy costs by >12%, reduction

of CO₂ emissions by >20%

through the development of a

digital twin & energy

management model

Reduction of energy

consumption & carbon

footprint

Wastewater

treatment &

energy

management

Same Function

Attica

Directorate for Waste

Water Treatment

Centres

The project is estimated to be

60% complete. The specifications

have been set, most of the

equipment has been installed.

Some systems are still to be

installed and modelling

completed.

European programme "Urban Innovative

Action" (UIA) 05-255 CULTURAL HID.R.A.N.T.

2024

EYDAP SA, in cooperation with

the Municipality of Halandri,

completed in 2024 the

CULTURAL HID.R.A.N.T

programme, utilising the water

from the Adrianio aqueduct for

the green regeneration of public

spaces in Halandri. This pilot

project formed the basis for the

formulation of an integrated

spatial investment strategy (ISI)

along the Adrianaio Aqueduct in

the basin.

Adapting to climate change by

operating with environmental

responsibility and aiming to

reduce its carbon footprint.

EYDAP SA

Same Function

Attica

Municipality and local

community

The project is 98% complete and

will start its trial operation in June

Energy upgrading of KEREFYT

2024

2025

Installation of thermo-

photovoltaic panels (ATPV

System) with a self-production

capacity of 9.75 kWp for

cogeneration of electrical and

thermal energy, photovoltaic

panels (PV) with a total installed

capacity of 36 kWp, heat pump

20 kW, and replacement of old

lamps with LED technology and

Adapting to climate change by

operating with environmental

responsibility and aiming to

reduce its carbon footprint.

EYDAP SA

Same Function

Attica

Employees

The project is 100% completed

and we are in the trial operation

phase

246

Actions

Time horizon

for start-up

Time

horizon for

completion

Expected Results

Correlation with relevant

policy objectives

Scope of application

Progress of actions notified in

previous periods

Activities

Value chain

Geographical

limits

Affected stakeholders/

Internal stakeholders

Quantitative and qualitative

information

MDR-A_01

MDR-A_03

MDR-A_01

MDR-A_02

MDR-A_05

replaced the fan- coil. It is

expected to have annual self-

generation to amount to 72.8

MWh.

Transport Management Optimisation

2024

The project to optimise the

transport management of

EYDAP SA was completed in

2024. It included the redesign of

the operational model of

transport services, the

development of fleet

management specifications and

the strategic planning of

transport service needs. The

renewal of the privately owned

fleet with environmentally

friendly vehicles, including

electric vehicles, was completed

in September 2024, reducing

emissions by 25%.

Adapting to climate change by

operating with environmental

responsibility and aiming to

reduce its carbon footprint.

EYDAP SA

Same Function

Attica

Employees

ELECTRIFICATION OF VEHICLES

In 2024, 20

electric

vehicles were

received to

reinforce/repla

ce the vehicle

fleet

The supply

of the

additive now

covers all

compatible

vehicles

(100%) and

is expected

to remain

stable for

the

foreseeable

future

Reducing fossil fuel use in

transport and greenhouse gas

emissions in the Urban Web.

CARBON DIOXIDE REDUCTION

MEASURES & ENERGY

FOOTPRINT

Transport optimisation:

Transfer of EYDAP

SA staff and

materials

Same Function

ATTIKI: Area of

responsibility of

EYDAP SA

Employees of EYDAP SA

Residents of Attica

247

E1.MDR-Α_04

For 2024, there was no incident of damage from impacts related to the operation of EYDAP.The

reduction in rainfall in 2024, combined with the high temperatures that prevailed for several

months, resulted in a further reduction of water reserves in the reservoirs of EYDAP SA. In

order to continue the uninterrupted water supply of the capital, water had to be pumped from

Lake Yliki and from wells operating in reserve, resulting in a significant increase in electricity

consumption and the corresponding operating costs of pumping the undistilled water. The

action to limit the operating costs of the External Water Supply System on the part of the

General Directorate of Transformation is the provision for additional supply of electricity at a

fixed price in the new tendering process during the respective periods of emergency. In

addition, the action concerning Lake Yliki has a deterrent role so as to avoid any possible

significant impact that may be caused to end consumers due to the drought phenomenon.

E1.MDR-Α_06_07_09-12 & E1-3_05 -08

EYDAP SA had in 2024 significant capital expenditure of 8.055.648€ for the implementation of

the relevant thematic actions.

248

● Measurement indicators and targets

[E1-4] Objectives on climate change mitigation and adaptation

E1.MDR-T_14

EYDAP SA is committed to the continuous improvement of operational resilience and

sustainable development. Through strategic investments and innovative solutions, it ensures

long-term sustainability and adaptation to climate and regulatory challenges. Its performance

on critical indicators, such as energy efficiency, demonstrates the company's significant

progress towards sustainable development. In addition, the Company monitors impacts, risks

and opportunities related to climate change through ongoing compliance with legislation,

especially alignment with the National Climate Change Act and the submission of an annual

carbon footprint report and its management systems. As part of an integrated strategic

planning, EYDAP SA implements actions including:

● Strengthening strategic planning to address water scarcity.

● Implementation of an integrated water reuse plan.

● Utilisation of the Adrianian Aqueduct as a source of water supply.

● Development and implementation of a desalination master plan.

● Conducting water consumption forecasting studies.

● Cooperation with international bodies to adopt best practices and promote innovative

technologies.

● Monitoring of critical indicators on a quarterly basis.

● Implement water saving programmes, aiming to reduce consumption by 10% per year.

Taking all the above into account, EYDAP SA is committed to setting clear and time-bound

targets for adaptation and mitigation to climate change.

249

[E1-5] Energy consumption and energy mix

E1.MDR-M_01

EYDAP SA applies a targeted energy management strategy, focused on energy saving,

optimizing consumption and thus reducing its environmental footprint.

An important pillar of this strategy is the energy optimization of the KEL of Psyttaleia,

incorporating innovative practices. At the same time, the company monitors critical energy

indicators, such as:

● Energy consumption for wastewater transport and treatment

● The percentage share of renewable energy in total consumption

To enhance resilience and adapt to climate change, EYDAP SA is committed to increasing

energy production from RES, such as photovoltaics and small hydro. At the same time, it has

completed a tender for the supply of electricity with 50% guaranteed origin from RES, further

enhancing its sustainable operation.

With these actions, EYDAP SA ensures the optimisation of its energy resources, reduces the

use of non-renewable sources and promotes environmental responsibility.

E1-5_01-15

Table 19. Energy consumption and energy mix

Energy consumption and energy mix

2024

1) Fuel consumption of coal and coal

products (Mwh)

2) Fuel consumption from crude oil

and petroleum products (MWh)

6.977,67

3) Gas fuel consumption (MWh)

524,44

4) Fuel consumption from other fossil

sources (MWh)

5) Consumption of electricity, heat,

steam and cooling purchased or

obtained from fossil sources (MWh)

117.414,77

6) Total energy consumption from

fossil sources (MWh)

(calculated as the sum of lines 1 to 5)

124.916,87

Share of fossil sources in total energy

consumption (%)

38,95%

8) Consumption of fuel from

renewable sources, including biomass

(which also includes industrial and

municipal waste of biological origin,

biogas, hydrogen from renewable

sources, etc.) (MWh)

161.600,10

9) Consumption of electricity, heat,

steam and cooling purchased or

31.997,04

250

acquired from renewable sources

(MWh)

10) Consumption of self-produced

energy from renewable sources not as

fuel (MWh)

2.208,05

11) Total consumption of energy from

renewable sources (MWh) (calculated

as the sum of lines 8 to 10)

195.805,19

Share of renewable energy sources in

total energy consumption (%)

61,05%

Total energy consumption (MWh)

(calculated as the sum of lines 6 and

11)

320.722,06

E1.MDR-M_02_03

● Consumption of fuel from crude oil and petroleum products (MWh): the Directorate

General of Transformation receives the relevant data on request from the Department

of Reserves Management, the Department of Transport and Vehicles, the Department

of Electricity/Mechanical Engineering of the PSO, the Department of

Electricity/Mechanical Engineering of the PSO and the Department of Vehicles and

Sewerage Machinery. The data is then appropriately processed to derive the specific

indicator.

● Gas fuel consumption (MWh): the Directorate General of Transformation receives the

relevant data upon request from the Ministry of Costs Settlement and the Ministry of

Energy on the basis of the monthly printed gas bills.

● Consumption of electricity, heat, steam and cooling purchased or acquired from fossil

sources (MWh): every month the Multiple Account of the electricity provider is sent

to the General Directorate of Transformation and after appropriate processing it is

integrated into a reporting platform and the specific indicator is extracted. The index

is obtained after deducting the electricity purchased with guarantees of origin (50% of

the total).

● Consumption of fuel from renewable sources, including biomass (which also includes

industrial and municipal waste of biological origin, biogas, hydrogen from renewable

sources, etc.) (MWh) (MWh).

● Consumption of electricity, heat, steam and cooling purchased or acquired from

renewable sources (MWh): every month the Multiple Account of the electricity

provider is sent to the General Transformation Directorate and after appropriate

processing it is integrated into a reference platform and the specific indicator is

extracted, which refers to the electricity purchased with guarantees of origin and is

applicable from 01.08.2024.

● Consumption of self-produced energy from renewable sources not as fuel (MWh): our

Directorate General for Transformation receives the relevant data upon request from

the Ministry of Energy and Climate Change

251

Indicators 2 to 6 and indicator 9 are verified by a certified body on an annual basis, as part of

the verification of the data used for the calculation of the Carbon Footprint of EYDAP SA.

Indicators 8, 10 and 11 are ensured by a certified verification body based on the annual EU-

ETS emission report of the Pistalaia CCL.

E1-5_16_17

Energy production from non-renewable sources (MWh): 7.98

Energy production from renewable sources (MWh): 186.809,27

E1-5_18-21

Total energy consumption (taking into account that all energy is in a high climate impact sector)

per net revenue (MWh/euro): 320,722.06/373,703,000 = 0.000858

252

[E1-6] Gross emissions of scopes 1, 2, 3 and total greenhouse gas emissions

E1.MDR-M_01_02_03 & E1-6_15

The infrastructure of EYDAP SA includes:

● 4 Water Treatment Plants (Acharnon, Galatsiou, Aspropyrgos and Polydendri

Monasteries)

● 5 Wastewater Treatment Centres (KEL Psyttaleia, KEL Metamorphosis and KEL

Thriasio Field, KEL Megara and KEL Koropi)

● The Water Supply Network

● The Sewerage Network

● Drilling Mavrosouvalas

● Small Hydroelectric Power Stations (SHPPs) along the External Water Supply System

(EWS)

● CCI of Thebes & the 4 accompanying pumping stations of the CCI of Thebes

● Owned and rented buildings, as well as a fleet of privately owned vehicles and

machinery

EYDAP SA under the current Contract is responsible for the operation and maintenance of the

External Water Supply System (EWS) on behalf of the EYDAP PAGIOS COMPANY

The dams, reservoirs, external aqueducts and pumping stations as well as other facilities that

ensure the safe transport of water until it enters the facilities of EYDAP SA, where it is

processed for the conversion of water into drinking water, belong to the ownership of the

EVDAP PAGE COMPANY.

Carbon footprint calculation

The gases that have been measured are: a) carbon dioxide (CO

), b) methane (CH

) and c)

nitrous oxide (N

O), which are the main greenhouse gases and account for most of the

emissions produced. In addition, HFCs are also measured, which are among the ozone

depleting substances (ODS). The other measurable greenhouse gases listed in the Kyoto

Protocol (NOx, SOx, PM) are not counted because according to the initial carbon footprint

reports (years 2019-2020) they represent a very small percentage based on the Company's

field of activity and in the official platform of the Ministry of Environment, notified to us in

October 2023, their calculation is not required.

The values used for the Global Warming Potentials (GWPs) for carbon dioxide (CO

), methane

(CH

) and nitrous oxide (N

O) are 1, 28 and 265 respectively (IPCC Fifth Assessment Report

(AR5)).

The methodology followed for the calculation of the carbon footprint of EYDAP SA is based on:

1. ISO 14064-1:2018 Greenhouse gases - Part 1: Specification with guidance at the

organization level for quantification and reporting of greenhouse gas emissions and

removals.

253

2. Greenhouse Gas Protocol, WRI (GHG Protocol Corporate Accounting and Reporting

Standard, Revised Edition).

EYDAP SA from May 2023, in order to better reflect the carbon footprint data, changed the

calculation boundaries and proceeded to recalculate SCOPE 1, 2, 3 with its own calculation

tool, classifying in the indirect emissions of EYDAP SA (Scope 3) the processes that take place

in E.W.S. (External Water Supply System), thus recording a deviation from the published data

in the Financial Report 2022. Subsequently, in October 2023, a calculation tool was posted by

the Ministry of Environmental Protection, based on which EYDAP SA recalculated the CO2

emissions for the year 2022. The verification of the 2022 Carbon Footprint Report was

performed by an external verifier and the agreed level of assurance was set as reasonable.

Given the above, the reference year for the calculation of the carbon footprint of EYDAP SA is

2022, as defined in the Climate Law 4936/2022 as the year of obligation to submit a verified

report to a platform of the Ministry of Environment and Natural Resources. It is noted that

from the 2022 Report onwards, the emissions of methane (CH4) and nitrous oxide (N

O) from

the use of biogas within the facilities of EYDAP SA are included.

E1-6_01_03_07_08_09_10_11_12_13_17_18_19_20_21_22_24_25_28

Table 21. Gross emissions 1, 2, 3 and total greenhouse gas emissions

Mixed emissions

2024

Scope greenhouse gas emissions 1

1 gross greenhouse gas emissions (tCO2eq)

165.321,049

Percentage of scope 1 greenhouse gas emissions from

regulated emissions trading schemes

4,65% (7.695)

(Non-biogenic emissions

Biogenic CO2 emissions from the combustion or

biodegradation of biomass separate from scope 1 greenhouse

gas emissions, but including emissions of other greenhouse

gases (in particular CH4 and N2O)

48.837,52

Scope greenhouse gas emissions 2

Gross greenhouse gas emissions of 2 based on location

(tCO2eq)

74.646,41

Market-based gross greenhouse gas emissions of scope 2

scope 2 (tCO2eq)

42.745,65

% of the scope 2 of greenhouse gases covered by conventional

means (PPAs/GOs)

21,

Biogenic CO2 emissions from the combustion or

biodegradation of biomass (include emissions of other types

of greenhouse gases (in particular CH4 and N2O))*

Significant greenhouse gas emissions scope 3

Gross greenhouse gas emissions for each major category

(scope 3) (tCO2eq)

28.530,69

% of emissions calculated using primary data obtained from

suppliers or other partners in the value chain.

28,51%

Biogenic CO2 emissions from the combustion or

biodegradation of biomass upstream of the value chain

254

(include emissions of other types of greenhouse gases (in

particular CH4 and N2O))*

Biogenic CO2 emissions from the combustion or

biodegradation of biomass downstream of the value chain

(include emissions of other types of greenhouse gases (in

particular CH4 and N2O))*

Total greenhouse gas emissions

Total greenhouse gas emissions (based on location) (tCO2eq)

268.498,15

Total greenhouse gas emissions (market-based) (tCO2eq)

236.597,39

* In case the applied emission factors do not distinguish the percentage of biomass or biogenic CO2, the company

shall disclose this fact. Where emissions of greenhouse gases other than CO2 (in particular CH4 and N2O) are not

available or are excluded from the measurement by site-based grid average emission factors or from the market-

based information, the undertaking shall disclose this fact.

E1-6_03-06

Table 22. Mixed emissions 1, 2, 3

Categories of emissions

Emissions (tCO

e) 2024

Greenhouse gas emissions from activities (Total scope 1)

e from energy used in installations (scope 1)

7.640,74

e from fuels used in company vehicles

1.651,32

e from fugitive emissions from the release of GHGs into

anthropogenic systems

156.028,99

Indirect greenhouse gas emissions related to energy production (market-based scope 2)

e from the electricity used in the plants (market-based scope 2)

42.745,65

e from electricity used in the plants (scope 2 based on location)

74.646,41

e from supplied heating and cooling (scope 2)

Total emissions Scope 2 market-based emissions

42.745,65

Total scope 2 emissions by location

74.646,41

Total emissions (market-based scope 1 and 2)

208.066,70

Total emissions (scope 1 and 2 based on location)

239.967,46

Other indirect greenhouse gas emissions (scope 3)

1 Purchases of goods and services

9.837,10

3 Fuel and energy related activities (not included in scope 1 or scope 2)

8.324,09

5 Waste generated from activities

7.809,53

7 Employee travel

2.559,97

Total greenhouse gas emissions (scope 1, 2 and 3 - market-based

scope 2)

236.597,39

255

Total greenhouse gas emissions (scope 1, 2 and 3 - scope 2 based on

location)

268.498,15

E1-6_ 23

Under the new electricity supply contract with effect from 01.08.2024, EYDAP SA will supply

50% of its electricity with Guarantees of Origin (GOs). The total CO2e equivalent emissions for

scope 2 (market basis) are obtained after deducting the 50% of electricity supply with

guarantees of origin (GOs).

256

E1-6_26_27

As not all the categories of scope 3 have currently been calculated, EYDAP SA for the current

reporting period will disclose the following carbon footprint categories:

Table 24. Scope categories 3

Scope categories 3

1. Goods and services purchased

3. Fuel and energy related activities

5. Waste generated during operation

7. Employee travel

Excludes scope 3 emissions for category 6 Business travel as these emissions are not assessed.

In particular, there is no detailed record of the above data as in some cases it may be difficult

to collect data for all sources. Furthermore, according to national legislation (Law 4936/2022:

National Climate Law), the calculation of scope 3 emissions is not mandatory.

Scope 3 emissions are excluded for categories 1, 2, 4, 6, 8, 9, 10 as in some cases it may be

difficult to collect data for all sources. Furthermore, according to national legislation (Law

4936/2022: National Climate Law), the calculation of scope 3 emissions is not mandatory.

E1-6_29

The methodology followed for the calculation of the carbon footprint for the scope 3

categories is based on:

1. ISO 14064-1:2018 Greenhouse gases - Part 1: Specification with guidance at the

organization level for quantification and reporting of greenhouse gas emissions and removals.

2. Greenhouse Gas Protocol, WRI (GHG Protocol Corporate Accounting and

Reporting Standard, Revised Edition).

E1-6_30-31

Table 25. Intensity of domestic greenhouse gas emissions (total greenhouse gas emissions per net

revenue

Intensity of domestic greenhouse gas emissions (total greenhouse gas emissions per net

revenue)

On the basis of location

On the basis of the market

2024

268,498.15 t CO2e/ 370,703,000€ = 0.0007

236,597.39 t CO2e/ 370,703,000€ = 0.0006

257

E1-6_32-35

Table 26. Net revenues for the calculation of greenhouse gas intensity

Net revenues used to calculate greenhouse gas intensity

370.703.000€

Total net revenue (in the financial statements)

370.703.000€

258

[E1-9] Projected financial impacts of significant material and transition risks and potential

climate-related opportunities

As part of the assessment of the projected financial consequences of significant material risks,

EYDAP SA conducted an assessment of the exposure of its individual facilities to specific

climate risks. The facilities examined are the Water Treatment Plants (Galatsiou, Acharnon,

Aspropyrgos, Polydendriou), the Photovoltaic Station of the Municipal Water Treatment Plant

of Acharnon, the WWTPs (Psyttalia, Metamorfosi, Thriasio, Megara) and the WWTPs (Elikona,

Evinou, Kithirona, Kirfi, Mandra).

First, the relevant risks that are significant for the company's financial activity during the

expected life of the specific facilities were identified. The analysis is ongoing and covers the

time horizons of 2025, 2030 and 2050, with the aim of providing information on the potential

medium-term impacts in terms of facility lifetime and economic planning.

The assessment of climate change impacts was carried out taking into account climate change

under the IPCC's most extreme climate scenario (RCP8.5). The RCP8 scenario.5 is one of the

four main scenarios used to project future greenhouse gas concentrations in the atmosphere

and represents a scenario in which emissions and concentrations of greenhouse gases increase

significantly over time, leading to a radiative forcing of 8.5 W/m² by the end of the century and

is therefore the most extreme scenario with respect to the change in climate characteristics

and extremes.

Climate indicators were assessed for those risks identified through the corresponding mapping

for the selected locations where the facilities are located and for the corresponding time

period, for historical/existing and future periods, in alignment with the results and

assumptions of the RCP 8.5 scenario.

The result of the analysis so far has included the following climate risks:

● Sea level rise

● Flood

● Forest fire

● Cyclone/Tornado/Typhoon (maximum wind speed gusts)

In addition, in order to assess the projected financial impact on assets based on their level of

exposure, relative vulnerability curves linking the percentage of loss to the value of the asset

were examined. To assess the projected financial impact on assets based on their level of

exposure, relative vulnerability curves were examined, linking the percentage of loss to the

value of the assets, and then the results were linked to the 5-point scale of financial impact

that exists within the existing business plan (ERM). According to the existing 5-point scale, a

physical risk is assessed as significant when its expected impact is p

In this phase of the analysis, the exposure to material climate risks was examined in terms of

the structural characteristics of the whole of each facility and it was concluded that there is a

significant material risk, specifically for flood risk which is an acute material climate risk. As

part of the assessment, in addition to the results of the climate analysis for the flood risk

exposure of the facilities under study, the Ministry of Environment and Energy's Potentially

259

High Flood Risk Zone (HPFZ) maps were also taken into account. Thus, combining the data, the

results of the assessment show that for East Attica, a significant flood risk is identified at the

Acharnon and the Polydendriou WWTP for the 3 time horizons. The Acharnon ICU is located

within the ZWFZ, while for the facilities of the Polydendriou ICU half of the facility is located

within the zone and the remaining half is located outside the zone. For West Attica, a

significant flood risk is identified at the KEL Thriassio and KEL Megara in all 3 time horizons,

which are also within the ZFD. In addition, according to the climate analysis and the Ministry's

flood risk maps which show the spatial distribution of maximum flood depth for the 100-year

return period, in the Acharnon, Polyendriou and Thriassio and Megara KELs, exposure to flood

water levels is expected which may cause a significant risk to EYDAP SA. According to the

Ministry's analyses and the climate model, the same probability of exposure to flood risk is

expected to occur for all 3 reference periods.

Then, taking into account the value of each facility, and dividing it by the value of all EYDAP's

facilities, the percentage of each facility at significant material risk per NUTS3 was calculated.

The results are presented in the table below.

Table 27. Assets at significant material risk prior to consideration of climate change mitigation actions

2025

Installation

€

% of the asset

NUTS 3 with assets at significant material risk (East Attica)

Intensive Care Unit of

Acharnon

50.298.609,44

19,57

ICU of Polydendri

13.841.149,14

5,38

NUTS 3 with assets at significant material risk (West Attica)

KEL Thriasio

42.467.501,81

16,52

KEL of Megara

3.750.000

1,46

The next stage of the analysis will focus on both the impacts that climate change may have on

equipment, transport, supply networks and staff health and safety. In addition, the next stage

of the analysis will look at the proportion of assets at significant material risk that are already

being addressed by climate change adaptation actions. This exercise is already underway so

that the company will be in a position to disclose it in its next sustainability report

E1-9_08-09

Water scarcity is one of the most important climate risks, with increasing impacts on the

accessibility and availability of water resources. Recognizing the importance of adapting to this

risk, EYDAP SA has initiated, as part of its climate analyses, an assessment of the impact of the

climate indicator of drought in order to identify and assess the trend of a climate indicator

linked to water scarcity, since drought can contribute to water scarcity by reducing the amount

of available water.

According to the analysis, the business activity considered to be at significant material risk is

the Water Supply Economic Activity in water scarcity.

260

ESRS E3 - Water and marine resources

● Managing impacts, risks and opportunities

[E3-1] Policies related to water and marine resources

E3.MDR-P_01-06 & E3-1_01-06_11

Attica, which is exclusively supplied with water by EYDAP SA - a non-transferable right - faces a significant

water risk due to its geographical location in the Mediterranean Basin, an area particularly vulnerable to

the effects of climate change, with an emphasis on water scarcity.

The Greek State, in accordance with the Convention of Law 4812/2021 between the Hellenic State, EYDAP

N.P.D.A. and EYDAP SA, valid until 31 December 2040, undertakes the obligation, throughout the duration

of the Contract, to ensure the supply of a sufficient quantity of Raw Water, which meets the Raw Water

Characteristics, at the Connection Points, at least in the quantities necessary to enable EYDAP SA as the

beneficiary to meet the minimum water consumption needs of its consumers.

Pursuant to the Law and the terms of this Agreement and subject to its conditions, the State renews the

exclusive right of the Beneficiary to perform the Water Services and the Sewer Services in the Activity Area

in accordance with the terms and conditions of this Agreement.

Activity Area means the geographical areas of the Beneficiary's activity as defined in Article 8 par. 1 of Law

No. 2744/1999 (A222), as in force, and as may be extended in accordance with the Law.

In this context, EYDAP SA formulates and implements policies that commit the company to the sustainable

management of water resources, emphasizing the continuous development of infrastructure and

equipment with emphasis on the use of cutting-edge technology, the enhancement of public awareness

and information, as well as the implementation of projects related to water reuse and the utilization of

treated effluents.

According to the Aqueduct Water Risk Atlas, EYDAP SA operates in areas of high water risk, both upstream

of its activity (water abstraction) and downstream (population/customers served), due to its geographical

location within the Mediterranean Basin it faces significant water risk, making it a region particularly

vulnerable to the impacts of climate change, with an emphasis on water scarcity.

In this context, through its policies, EYDAP SA is committed to adapting to climate change, operating with

environmental responsibility. In this way, emphasis is placed on the risk of water scarcity, which may affect

its smooth operation.

Specifically, in order to ensure the rational management of water resources, there are policies governing

the operation of EYDAP SA. In particular, EYDAP SA, through its Environmental Policy and Sustainable

Development Policy, declares that the management of the valuable resource of water is carried out with

responsibility and sensitivity, in a way that ensures the sustainability of reservoirs and springs, as well as

the return of clean water to nature - adopting the principles of circular economy, protecting the

underground aquifer, as well as the marine environment.

Thus, the company is committed to implementing sustainable practices for water conservation through

systematic awareness raising, water reuse and the utilization of treated effluents (e.g. for irrigation

purposes).

261

In addition, through awareness-raising activities, it informs employees, suppliers and society about the

importance of preventing water pollution. At the same time, it incorporates responsible and sustainable

practices in its processes, promotes digital transformation, ensuring the distribution of sufficient

quantities of drinking water of excellent quality through a reliable water supply network. It returns treated

wastewater cleanly to the environment after its responsible, efficient and uninterrupted collection.

Constantly plans new projects to expand its operations and upgrade its facilities using state-of-the-art

technology.

The stakeholder groups that are affected and benefit directly or indirectly from the policies are:

● Local communities

● National and local regulatory authorities

● Educational and voluntary communities

● Suppliers

The Environmental Policy of EYDAP SA demonstrates the company's commitment to take into account the

interests of its key stakeholders when defining its policy. In particular, EYDAP SA is committed to:

● To comply with current Greek and European environmental legislation, adopting approved

international practices and standards in environmental management, and to strive to meet

higher standards than those imposed by legislation, cooperating with the competent bodies

for the improvement of legislative requirements.

● To inform its suppliers and contractors working with it of the adoption of its Environmental

Policy and ensure that they comply with it.

● Aim to create and maintain an open and creative relationship of trust with the local

community and other stakeholders.

These commitments underline the attention that EYDAP SA pays to the interests of its key stakeholders

and to the adoption of international standards and practices in setting its environmental policy.

The policies are in line with the UN Sustainable Development Goals and cover the full range of activities

of the operation including the downstream value chain. The policies are implemented by all employees of

the company and the highest level responsible for implementation is the position of CEO.

The policies are communicated to its employees and stakeholders, reviewed and revised as appropriate,

and approved by its Board of Directors. The policies are communicated to employees through training and

updates. As part of ensuring that employees are aware of important Policies, a written statement

("Personal Commitment") is requested that they have been made aware of them. In addition, they are

posted on the Company's website, where all interested parties have access to them. In addition, the Policy

applies in areas where there is an impact of Company operations. The assessment of these is made taking

into account the impact thresholds.

262

[E3-2] Actions and resources related to water and marine resources

E3.MDR-A_01-03_05 & E3-2_03

The main axis of sustainable development of EYDAP SA is the sustainable management of the hydrological

cycle. EYDAP SA, as a provider of high expertise in water resources management, with continuous

integration of new technologies in its actions, ensures their rational management, i.e. the exploitation of

natural resources without burdening the environment but taking care of it and protecting it. The actions

of EYDAP SA are implemented in the Company's area of activity and cover the entire value chain.

Taking into account the high water risk and the high water stress in the areas where the Company operates,

the Company takes continuous measures for the sustainable use of water resources.

The main axis of sustainable development of EYDAP SA is the holistic and sustainable management of the

urban water cycle, with emphasis on adaptation to climate change and resilience of water resources. As a

provider of high expertise in water resources management, EYDAP SA integrates modern technologies

such as smart grids, digital twins and advanced monitoring and forecasting techniques, ensuring their

rational management. Its objective is the sustainable exploitation of natural resources while protecting

the environment and biodiversity. Its actions are mainly implemented in Attica, covering the whole range

of its value chain, from water abstraction to water reuse. In this context and in 2024, EYDAP SA carried out

loss reduction projects which are increasing over the next 3 years, alongside actions to optimise the

operation of the water supply network and water meter replacements. All the above are expected to

gradually reduce water losses. The ongoing projects in Eastern Attica are also expected to improve the

water table as domestic waste will no longer be disposed of in domestic cesspools, which until now have

led to environmental degradation. Integrated waste water management is also expected to improve the

surrounding marine resource.

The large sewerage projects in Eastern Attica, which are currently underway, are also expected to clean up

the aquifer as domestic waste will no longer be disposed of in domestic cesspools, which until now have

led to environmental degradation. Integrated waste water management is also expected to rehabilitate

the surrounding marine resource. Sustainable management is a main parameter of the strategy of

increasing the water resources of the capital city, by EYDAP SA. It has already started the implementation

of circular economy projects, such as decentralised wastewater reuse through innovative technologies

(sewer-mining) and the integrated exploitation of the Roman underground Adrian Aqueduct of Attica,

which within 2025 will provide water for green water supply and increase green spaces in Halandri. The

network projects and treatment facilities to reduce losses, the installation of smart meters in 2

municipalities complete the implemented actions of EYDAP SA in the framework of sustainable water

resources management.

EYDAP SA is working with the Ministry of Environment and Natural Resources, studying a range of solutions

including access to additional surface and groundwater resources, desalination and wastewater reuse.

EYDAP SA, on the basis of article 8.1.4 of the Contract of Law No. 4812/2021 between the Hellenic State,

EYDAP S.A. and EYDAP SA, prepares Water Resources Management Plans for Athens in cooperation with

the National Technical University of Athens, based on which it implements the appropriate water

withdrawal policy from the Euinos, Mornos and Marathon Reservoirs. This management also includes the

activation of back-up water sources such as Lake Yliki and the Mavrosouvala boreholes, where

circumstances require it.

263

The management of the country's water compartments is carried out by the State in accordance with the

River Basin Management Plans for each of the water compartments, which include Drought Management

Plans.

Furthermore, EYDAP SA, as an advisor and partner of the Ministry of Environment, in the effort to find

new water resources, in order to manage the risk of water scarcity and following the order no.

YPEN/D18/117253/524/29.10.2024 Decision of the Minister of Environment and Energy, pursuant to the

provisions of article 18 of Law 5106/01.05.2024, initiates the construction of the following projects.

As part of the immediate actions, it was assigned:

1. Restoration of the functionality and reintegration into the EIS, of the drilling wells of Middle Ru Boeotiko

Kifissos (implementation in two stages), as follows:

Stage 1: Through PTLEY, the assessment of the water potential of the Vasilika and Parori water wells of the

Middle Roo Boeotian Kifissos is carried out.

Stage 2: According to the results of Stage 1, the operational rehabilitation of the electrical and mechanical

equipment of the above mentioned boreholes as well as the three water transfer pumping stations from

the Vasilika - Parorios boreholes to the Mornos Aqueduct via the Unitary Distomo Aqueduct will be

planned.

In terms of long-term planning, alternatives such as desalination, the use of recycled water, the connection

of the Evinos reservoir with other water sources, and the transfer of water from the Acheloos River to the

Mornos Aqueduct are already under consideration, with the launch of the following projects:

2. Project study for the reinforcement of the Euinos - Mornos water supply system from basins of the

eastern Acheloos.

2.1: Pendulum study - Krikeliotis - Karpenisiotis

2.2 Sea transport of raw water from Acheloos to the Mornos Aqueduct downstream of Siphon Kalogerikos.

To this end, the relevant preliminary study will be prepared for:

● Construction of a water intake and water transfer project from the Acheloos canal in the location

of Pentalofos in the P.E. of Etoloakarnania, in the area of Astakos of the same P.E.

● Construction of a water transfer project, from the area of Asproi Sites Distomo of Boeotia, to the

head of the Kyriakiou tunnel of the Mornos aqueduct of the same region.

● Construction of a port project for the loading and transfer of water from the area of Astakos in the

region of Aitoloakarnania (Region of Western Greece) to the area of Aspra Houses in the region of

Boeotia.

3. Project study for the installation of desalination plants, including possible desalination of brackish water.

3.1 Project study for the installation of brackish water desalination plants: a preliminary study will be

carried out:

● For the construction of a project for the collection of brackish water, its desalination and transfer

from the sources of the North Corinthian Sea to the Mornos aqueduct in Fokida P.E.

264

● For the construction of a project for the collection of brackish water, its desalination and its

transfer from the sources of Kalamos Oropou and Drillings Phyllis to the aqueducts of Yliki and

Mornos, respectively, in the Region of Attica

In addition, the study entitled "Vulnerability Study of the E.Y.S." which will highlight its shortcomings and

weaknesses against climate risks.

1. Sustainable reservoir management

EYDAP SA ensures the protection of the reservoirs with:

● Compliance with strict legislation (Health Decree A5/2280/1983 as in force) "for the protection of

waters used for the water supply of the capital region from pollution and contamination" and PD

51/2007 on the definition of measures and procedures for integrated water protection and

management in compliance with the provisions of Directive 2000/60/EC.

● The supervision of the expropriated areas with regard to the provisions of the current sanitary

provisions (A5 EHS), and informing the EYDAP PAGIOS COMPANY for further actions that there will

be indications of infringement or non-compliance with the sanitary provisions (A5 EHS), in

accordance with the contract for the operation and maintenance of the EHS

● The control of projects and activities in the protection zones of reservoir basins.

● Random measurements of reservoir water quality.

The applied methods of water resources management are characterised by:

● Scientifically based rationality

● Efficiency

● Sustainability, in that they do not create a problem of depleting water resources in the future by

meeting the needs of today.

The time horizon for the implementation of this action is as long as the water is pumped from the

reservoirs.

2. Maintaining the "ecological flow" in the Euinos, Mornos and Marathon reservoirs.

In order to maintain the continuity of wetland ecosystems, EYDAP SA explored the possibility of

maintaining "ecological flow" in the river ecosystems downstream of the dams. Maintaining this minimum

required flow is necessary in accordance with legislation, environmental conditions and current

international trends in the environmental management of reservoirs. Thus,

● According to the TEPEM (Technical Environmental Study) for the Marathon dam, it was estimated

that a flow rate of 25 l/sec downstream of the dam was required to achieve the above-mentioned

purpose, which was implemented.

● The river ecosystem downstream of the Mornos dam is in good condition, due to the continuous

flow of surface water in the riverbed. EYDAP SA has completed the systematic monitoring of the

ecological and chemical status of the river ecosystem, applying a three-year programme of

hydromorphological, physicochemical, biological and chemical measurements, in accordance with

265

the specifications of the Water Framework Directive 2000/60/EU and the Water Management

Plan YD04 provided by the Technical and Environmental Study (TEPEM) of the Mornos Dam. The

monitoring showed that the river ecosystem downstream of the Mornos dam is in good ecological

and chemical condition.oThe river Evinos, the newest reservoir, has a predicted "ecological flow"

of 1 m3/sec. Consequently, the riparian ecosystems downstream of the dam retain their

physiognomy and their important biodiversity.

Time horizon for implementation: as long as water is being pumped from the reservoirs.

3. Actions and resources in relation to areas at water risk, including areas of high water stress.

The main reservoirs and boreholes and the respective regional units from which EYDAP SA draws water

are:

● Mornu reservoir: Regional Unit of Fokida

● Ylikis reservoir: Regional Unit of Boeotia

● Marathon Reservoir: Regional Unit of Eastern Attica

● Euinus reservoir: Regional Unit of Etoloakarnania.

● Drilling: Approximately 100 wells have been developed for back-up purposes: The Region of Attica

and the Regional Unit of Boeotia.

More information is available on the company's website.

In this context, it is taking actions to manage the risk of water scarcity, such as implementing control

mechanisms to ensure adequate supply of raw water to the Water Treatment Plants, in case the routed

inputs will be put under insufficient flow. The aforementioned action will be carried out in accordance

with the updated water resources management plan for the water supply of Athens, prepared by the Civil

Engineering Department of the National Technical University of Athens, in cooperation with EYDAP SA.

In addition, pumping will take place from the Yliki branch, with the operation of the Mavrosouvala wells

and the pumping stations of the Yliki branch.

In the medium term, an increase in the pumping of the Yliki branch and the activation of the Middle Roo

Boeotian Kifissos wells, which, through the Unitiko Distomos Aqueduct, feed the Mornos Aqueduct, are

foreseen.

In terms of long-term planning, alternatives such as desalination, enrichment of the underground aquifer

with recycled water, and connection to other water reservoirs are already under consideration.

The time horizon for the implementation of this action is as long as the water is pumped from the

reservoirs.

4. Ensuring the rational operation of the External Water Supply System (EWS)

In order to ensure the security of the capital's water supply, the implementation of five (5) important

critical projects in the EWS has been planned and launched, on the one hand for the support - safeguarding

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of the existing critical infrastructure of the EWS and, by extension, their fuller operation, and on the other

hand for the possibility of alternative water supply of the entire basin from Lake Yliki, as follows:

With the Addendum signed on 21.06.2023 to the Annex of the Contract signed on 2.2.2022 of N4812/2021

between the Greek State, the Etairia PAGION EYDAP (NΠΔD) and EYDAP SA, EYDAP SA was awarded the

construction of a project as follows:

1. "Construction of Rehabilitation Works of the Unitary Aqueduct of Mornos - Marathon. Section: Klidi -

Dafnoula" with contract code E-907, for which the tender procedure has been completed and the

signing of the contract is expected".

By means of the Commission's Decision no. YPEN/D18/117253/524/29.10.2024 Decision of the Minister

of Environment and Energy, pursuant to the provisions of article 18 of Law 5106/01.05.2024, the

construction of the following works was awarded to E.Y.D.A.P. S.A:

2. Stabilisation and sealing project in the Kithero Canal in the Kokkini area.

3. Project for the completion of the Construction of the Supplementary Aqueduct of cross-section F2000

of the Mornos Ananti Kokkinio Aqueduct to the Acharnon Water Treatment Plant (Section II).

4. Project for the protection of the Mornos Aqueduct from rock falls in the Kithairon Canal.

5. Intervention Completion Project in the Thibon Canal of the Mornos Aqueduct.

Projects 2, 4 and 5 are expected to be put out to tender in 2025. For project No. 3, the approval of the

final design of the project is expected. In parallel, reforestation removal and land expropriation is required.

By the 02.02.2022 signed Contract for the contracting of Operation and Maintenance Services of the

External Water Supply System of the Capital Region, between the Greek State, the Etairia PAGION EYDAP

NΠΔΔD and EYDAP SAEYDAP SA undertook to prepare and submit for approval to the Ministry of

Infrastructure and Transport, a proposal for the design of an integrated system for the installation of

cutting-edge technologies for the safety and monitoring of the operation of the EIS (SCADA, Geographical

Information System, Hydraulic Model, security cameras, fibre optics, etc.).).

EYDAP SA completed the design of the above project in 2024, which consists of:

I. Proprietary Telecommunications Network based on optical fibres

II. Monitoring and Control System of the EES

III. Hydraulic Model and Automatic Operation

IV. Integrated IT system for the supervision and control of the EIS

The Design Proposal was presented and submitted for approval, to the Directorate of Water Supply,

Sewerage & Sewerage Projects Wastewater Treatment (D18) of the Ministry of Environment and Energy,

in accordance with the provisions of Article 5.2 of the Operation & Maintenance of the EWS of EYDAP SA,

with the Greek State. The project is expected to be put out to tender within 2025.

5. Rational Water System Management and Leakage Reduction

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The actions related to the Rational Management of the Water Supply System and Leakage Reduction are:

● Application of modern advanced pressure management technologies in the water supply network

(advanced pressure management), which results in avoiding unnecessary stress on the pipelines,

with significant economic benefits. Creation of pressure zones for better control of the pressure

in the pipelines, i.e. territorial areas at 30 to 40 metres of altitude difference, with a specific

pressure. The pressure range within the hydraulic zones is in the vast majority of cases between 4

and 6 atm. The water supply network is monitored on a 24-hour basis by a remote control system

- discrete remote control (SCADA).

● Proactive network maintenance, through reliable data collection.

● 5-year Investment Programme for the massive replacement of networks and water supplies of

properties in identified water supply hydraulic zones

● Targeted programme of documented priority water supply network replacement

● Decision Support System, which is used on a daily operational basis by EYDAP SA for the

supervision and management of the water supply system and includes the following components

(subsystems):

o Geographic information system for the visualization and monitoring of the water supply

system.

o System for measuring the water resources of Athens' water supply

o Assessment and forecasting system of the water resources of Athens' water supply

o System to support the management of the water resources of Athens' water supply

● Immediate restoration of pipeline damage and breakages

● "Smart Grid".

● The Company is in the process of developing a "smart grid", a strategic project for the business

transformation of EYDAP SA with multiple benefits both for the infrastructure and operational

optimization of the networks, as well as for consumers and the environment. The smart grid will

achieve real-time data delivery, optimisation of network design and efficiency, immediate and

accurate information for decision making, and improved customer experience. In terms of the

environment and resource management, it contributes to water savings through the ability to

monitor water balances and reduce losses, as well as the use of digital tools for water resource

management.

As this is a large investment of more than €300 million, the technological solutions, the financing

possibilities of the investment, the procurement strategy and the plan for the installation of smart

meters over a 10-year horizon are being explored.

● Development of a Pilot Program "Multiutility" in order to explore the provision of advanced

metering infrastructure services by DEDDEO to EYDAP SA, through the DEDDEO telemetry

network. In the context of upgrading the electricity meters with new smart electricity meters,

BEDDEO is evaluating the provision of additional services to third parties. Similarly, EYDAP SA is

also exploring the possibilities of further exploiting the potential of the smart meters it has already

installed, in order to increase the benefits of this technology, to optimise the service to consumers

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and to achieve active monitoring of water balances in water supply zones of the water supply

network.

The "Multiutility" pilot project is currently underway. In addition, by the end of 2025, the tender

documents for the supply and installation of smart meters will be completed and the contract with the

consultant will be finalised.

6. Water supply for new areas and reinforcement of existing areas

For the few areas that are not supplied with water by EYDAP SA but by hydrogeothermal wells, mainly in

Western Attica, EYDAP SA has launched a series of interventions and actions, in cooperation with the local

authorities, so that in a short period of time they will be included in the total number of areas that will

receive water from EYDAP SA. In this context, the following projects will be implemented:

● Water supply for the settlement of Kinetta of Megara - Phase A

The implementation of the project "Water supply of Kinetta Settlement of Megara - Phase A: 1) External

water supply pipeline, 2) Central tank" was scheduled, which includes the construction of a new steel

supply pipeline Φ500, about 15km long, as well as a water tank, through which the area of Kinetta will be

supplied with water, which is not supplied with water by EYDAP SA.

In October 2023, the Board approved the launch of a new public electronic tender entitled "Completion

of the remaining works for the water supply of the settlement of Kinetta Megara Phase A: 1) External water

supply pipeline, 2) Central tank". The tender procedure is currently underway.

● Feeding pipeline of Perama tanks from Schistou Avenue

The implementation of the project "Feeding Pipeline of Perama Tanks from Schistos Avenue" is

proceeding, for the construction of a new steel feeding pipeline, cross-section Φ300-Φ600 and a length of

approximately 4km, which will feed the existing tanks of the Municipality of Perama, without the help of

the boosters that are currently used for the water supply of the area, thus reducing to a minimum the

current consumption of electricity. The project is currently underway and is expected to be completed

within the 2nd quarter of 2025.

● Reinforcement of the central water supply network of EYDAP SA in West Attica - Construction of a

new supply pipeline of cross-section Φ1000

In October 2023, the Board of Directors approved the launch of a new public electronic tender for the

implementation of the project "Reinforcement of the central water supply network of EYDAP SA in West

Attica - Construction of a new supply pipeline of cross-section F1000", in order to meet the increasing

demand requirements of the wider area in West Attica and the islands of Salamis and Aegina, with a total

length of 15,440m. The tender procedure is currently underway.

● Replacement of water supply pipeline cross-section Φ1300: Section Kiourka - Pumping Station

Agios Stefanos

In July 2023 it was approved by the Board. the holding of a new public electronic tender for the

implementation of the project "Replacement of water supply pipeline of cross-section Φ1300: Section

Kourka - Pumping Station of Agios Stefanos", for the replacement of the existing depressed pipeline of

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prestressed concrete, diameter Φ1300, with a new steel pipeline of the same diameter, in an area of

3120m between the pumping stations of Polydendri and Agios Stefanos. The tender procedure is currently

underway.

● Projects for the reinforcement of the central water supply network of EYDAP SA, in P.E. South

Sector of Athens.

In the framework of the approved investment program of the General Directorate of Water Supply of

EYDAP SA, the project "Projects to strengthen the central water supply network of EYDAP SA, in the South

Sector of Athens" was launched, which was deemed necessary to meet the increased demand

requirements, with the inclusion of the new metropolitan pole Elliniko-Ag. Kosmas, in the supply network

of EYDAP SA. The final design and tender documents for the project are expected to be completed and

approved within the second quarter of 2025, so that the construction of the project can then be launched.

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7. R&D actions in the context of ensuring the quality of drinking water

Ensuring water quality is a strategic priority of EYDAP SA. In the field of innovation, EYDAP SA participates

in European and national research programmes, testing advanced water treatment, monitoring and reuse

methods.

Specifically, the ToDrinQ project is currently underway and is expected to deliver to the Polydendri Water

Treatment Plant an integrated pilot system for the control of quality parameters that could not be

controlled by conventional means. In addition, it will provide an interoperable decision making tool that

will act as an advisory tool to the operators and designers of the Water Treatment Plants.

The TESTUDO project, which is also underway, aims at a holistic and autonomous security approach to

protect critical infrastructure. Using advanced unmanned vehicles, new sensors, advanced software and

existing equipment, an integrated platform will be developed for continuous monitoring, even in

challenging environments.

More specifically, the project will focus on the security of the Marathon Dam and a Water Treatment Plant,

preventing malicious actions in physical and cyber space. The following will be used:

More specifically, the project will focus on the security of the Marathon Dam and a Water Treatment Plant,

preventing malicious actions in physical and cyber space. The following will be used:

● Tools for detecting cyber-attacks on MEN's systems.

● Autonomous or semi-autonomous unmanned air and ground vehicles at the Marathon facility.

● AI algorithms for action, people and object recognition.

● A user-friendly platform for monitoring and using the above tools.

After the successful completion of the European project INTCATCH, EYDAP SA has two autonomous robotic

vessels that enhance the monitoring and protection of water quality. For the fourth consecutive year,

EYDAP SA carried out continuous monitoring of the reservoirs and prepared scientific monitoring reports.

The vessels are equipped with sensors for physico-chemical parameters (chlorophyll, conductivity, pH,

dissolved oxygen) and a sampling system for hard-to-reach areas of the lake.

The use of robotic vessels has shown that they can contribute to a more comprehensive and better quality

control of the reservoir, since in case of possible pollution from anthropogenic activities or natural

processes, the vessels can be operationally deployed in a very short time across the entire lake, locating

the point of inflow of the pollutant in time.

8. Management of water resources in Wastewater Treatment Centres (WWTPs)

The reuse of the treated effluents of the East Attica WWTP is a strategic choice for EYDAP SA in the design

and implementation of its projects, with a significant impact on the purification and enrichment of the

underground aquifer and the saving of the valuable resource of water.

Part of the treated effluent (disinfected water and non-disinfected industrial water) from the Psyttalia

WWTP and disinfected water from the Metamorphosis WWTP and the Thriassio WWTP, and the Koropi-

Peania WWTP is used within the facilities of the WWTP, to serve the needs of water use (e.g. irrigation,

equipment cooling, washing and other uses), thus reducing the need for water consumption from the

water supply network for these uses.

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The construction of additional treatment works (ultrafiltration) of the effluent of the Thriassio WWTP is

also planned for reuse off-site for irrigation and industrial use.

At the same time, a Sustainability Study for the operational activity of reusing the treated effluents of the

WWTPs is in progress (the Sustainability Study also concerns the existing WWTPs).

EYDAP SA, in cooperation with the Agricultural University of Athens (GAU), developed a pilot application

of irrigation with treated effluents in an experimental field of GAU in the area of Mesogeia and continues

to assess possible changes in the chemical and microbiological characteristics of the soils and the

evaluation of the nutritional status of the plants.

In addition, EYDAP SA is in the process of implementing the new pilot application for the reuse of treated

effluents of equivalent qualitative characteristics to the treated effluents of the Marathon WWTP in

vegetable growing soils in Eastern Attica.

Finally, with the operation of the new CCS projects, a drastic reduction in the use of cesspools will be

achieved, most of which are absorptive and have so far been a significant pollutant load to groundwater.

A reduction will also be achieved in pumping from the underground aquifer, thus reducing the risk of

groundwater contamination.

These projects are a strategic choice for EYDAP SA, with a significant impact on the purification and

enrichment of the underground aquifer and the saving of the valuable resource of water.

WWTPs, through the collection and treatment of urban wastewater, are key environmental infrastructure

for the protection of marine receptors. The treated effluent from the WWTPs is discharged into the sea

free of its pollutant load at a minimum rate of 95%.

The total treated wastewater in 2024 for all WWTPs is in the order of 250,000,000 m3, noting that the

inflow is almost identical to the outflow.

The time horizon for the implementation of the East Attica treated effluent reuse projects is foreseen to

be implemented after the maturity of the projects (completion of connections and required supplies)

after about a decade.

9. East Attica projects (in progress)

EYDAP SA has taken substantial action to solve the problem of non-integrated wastewater management,

which for many years has led to environmental degradation, to the non-optimal management of the

valuable resource of water and to the imposition of fines, due to non-compliance with the European

Directive 91/271 EEC for the treatment of urban wastewater.

In this context, in East Attica, the construction of new KELs and the construction of a sewerage network is

underway. These important projects of EYDAP SA have been designed to operate with cutting-edge

technology, ensuring the possibility of reuse of treated effluents, in full compliance with the current

institutional framework for reuse.

Finally, with the operation of the new CCS projects, a drastic reduction in the use of cesspools will be

achieved, most of which are absorptive and have so far been a significant pollutant load to groundwater.

A reduction will also be achieved in pumping from the underground aquifer, thus reducing the risk of

waterlogging of the groundwater system. According to the design, around 400,000 inhabitants of East

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Attica will be connected to the sewerage network.

● The Wastewater Treatment Centres (WWTP) to be operated by EYDAP SA in East Attica (KEL

Rafina-Pikermio & Artemida-Spata, Marathon WWTP, Koropi - Peania WWTP) will have a capacity

to produce approximately 48,000 m3/day of reclaimed water.

● In the future, this capacity can be increased in 20 years (2040) with the construction of the

necessary expansion works of the KEL to 75,000 m3/day.

● The annual reclaimed water production capacity for the irrigation period (April-September) will

be 8,800,000 m3/year for the construction phase of the projects, while for the 20-year period

(2040) the corresponding capacity may be increased to 14,000,000 m3/year.

● Assuming that the annual irrigation water needs in cultivated areas adjacent to the KELs are in

the range of 500-600 m3/acre per year - as recorded in the "General Plan for the reuse of the

treated effluents of the KELs of Eastern Attica" (EYDAP S.A., 2016) - the possibility of irrigation

✓ in the initial phase, approximately 16,000 hectares of arable land, and

✓ in 20 years (2040) about 25,000 acres.

Part of the treated effluent (disinfected water and non-disinfected industrial water) of the KEL Koropi -

Peania is used within the facilities of the KEL, to serve the needs of water use (e.g. irrigation, equipment

cooling, washing and other uses), thus reducing the need for water consumption from the water supply

network for these uses.

This action is particularly important, given that from the River Basin Management Plans (Directive 2000/60

) and from studies by EYDAP SA and other bodies, it has been established that the underground aquifers

in the Central Mediterranean region (area of the Koropi - Peania KEL), are locally under intensive

exploitation and exhibit a pronounced drop in water level (well water table), phenomena of water logging

and nitrate pollution. In this context, in addition to the operation of the existing ones, the construction of

new WWTPs and the construction of a sewerage network is under way. These important projects of EYDAP

SA are designed to operate with state-of-the-art technology, ensuring the possibility of reuse of treated

effluents, in full compliance with the current institutional framework for reuse. The reuse of the treated

effluents of the East Attica WWTP is a strategic choice for EYDAP SA in the design and implementation of

its projects, with a significant impact on the rehabilitation and enrichment of the underground aquifer and

the saving of the valuable resource of water. Project maturation activities continue for the reuse of the

reclaimed water of the KELs for irrigation and peri-urban use for the benefit of agricultural cooperatives

and local communities. In the summer of 2024, information and awareness-raising actions were

completed for farmers in the areas of Marathon and Koropi, as the main group of potential users of the

recovered water of the KELs of Eastern Attica. The 2 new WWTPs of East Attica are estimated to be

completed within the current programming period and are designed to operate with state-of-the-art

technology, ensuring the possibility of reuse of treated effluents, in full compliance with the current

institutional framework for reuse:

● the KEL Rafina-Pikermio & Artemis-Spata (under construction)

● the KEL Marathon (under construction)

● The treated effluent of the Koropi-Peania WWTP, whose management and operation was

transferred to EYDAP SA from mid-December 2023, is planned to be used for the irrigation of

crops, peri-urban greenery and the enrichment of the underground aquifer. This will be possible

after the construction of an ultrafiltration membrane (UF) plant

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At the same time, environmental awareness and education actions are being implemented, as well as

continuous communication with the local community through environmental awareness actions, and

awareness raising actions have already been launched for farmers in the area, as the main group of

potential users of the recycled water from the KEL.

At the same time, a Sustainability Study for the operational activity of reuse of the treated effluents of the

CCS is underway.

These projects are a strategic choice for EYDAP SA, with a significant impact on the purification and

enrichment of the underground aquifer and the saving of the valuable resource of water.

EYDAP SA has commissioned ELKEΘE to monitor the marine ecosystem of the South Evian Gulf in order to

document its current state and assess the impact of the Wastewater Treatment Centres. With the

operation of the East Attica projects, it is expected to achieve:

● the protection of the marine environment

● the protection of water quality; and

● the protection of bathing beaches.

Implementation horizon: end of 2029

10. Management of water resources in Water Treatment Plants (WWTPs)

The management of water resources in the context of the operation of AWRs includes:

● Reducing the consumption of water used for its treatment. The water used at all stages of water

treatment (emptying of the flocculation-settling tanks, cleaning and washing of these tanks,

reverse washing of filters) is not discharged but recycled and reintroduced into the production

process.

● The construction of sludge treatment projects in the WWTPs, for the reuse of the water

resulting from the centrifugation of the sludge resulting from the water digestion process. This

water is added to the quantities of water used for washing the filters of the refineries, all of

which is returned to the inlet of the STPs for re-treatment.

11. Marine ecosystem protection

In addition to the sustainable management of natural resources-water sources, EYDAP SA ensures the

protection of the marine ecosystem. The Company, in the context of its activities, takes all necessary

preventive measures to ensure its protection.

In addition, EYDAP SA has commissioned the public research organisation, the Hellenic Centre for Marine

Research (ELKEΘE), to systematically monitor the status of the ecosystem of the Inner Saronic Gulf and

the Gulf of Elefsina, which are "sensitive receptors", which shows improvement over time.

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At the same time, under a contract with EYDAP SA, the Hellenic Centre for Marine Research (ELKEΘE)

undertook the monitoring of the marine ecosystem of the South Evian Gulf in order to record and

document the existing situation and to assess the impact of the

the new Wastewater Treatment Centres (WWTPs) in East Attica.

Specifically, with the operation of the East Attica projects, it is expected to achieve:

● the protection of the marine environment

● the protection of water quality

● and the protection of bathing beaches.

ELKEΘE has completed the inventory of the current state of the marine ecosystem of the South Evian Gulf.

During the operation of the new Wastewater Treatment Centres (WWTPs) in East Attica, ELKEΘE will

continue to monitor the marine ecosystem in accordance with the obligations of national and European

legislation and the AEPs.

Implementation time horizon: continuous

12. The Adrianeio as a Water Resource

EYDAP SA is constructing a network for the utilization of the Adrianaios Aqueduct in Halandri, with the co-

financing of the EU (UIA Cultural HID.R.A.N.T. Programme). The object of the project is the construction of

the irrigation network for the transport and distribution of water to green irrigation areas within the

Municipality of Halandri, from the lights (wells) number 85, located in a common green area of Kodrou

Street and 102, located in a common green area of El Alamein Street, of the Adrianianian Aqueduct. The

project includes networks of pipelines for the transport and distribution of water, the electromechanical

equipment for pumping water from the wells and the electromechanical equipment for the suction tanks.

Sustainable Development & Benefits

This new infrastructure incorporates the principles of the circular economy and sustainable development

(ESG) of EYDAP SA, with the following objectives:

● Resilience to water scarcity

● Reducing urban overheating

● Protection of water resources

● Cost and energy savings for users

13. Strategic Reuse Plan

EYDAP SA is preparing a strategic reuse plan for the whole of Attica. Part of the plan is the utilisation of

decentralised wastewater treatment plants by direct extraction of wastewater from the sewerage network

(Sewer Mining). In this context, it is launching the operation of 4 plants in the first phase, in addition to 2

plants already existing at its Research Centre (KEREFYT) and at the Nursery of the Municipality of Athens.

The new units are :

1. In the Greek

2. In the Municipality of Markopoulou: This is the first green plant using solar energy, with a

capacity of 25 km/day. The project is a collaboration with the NTUA in the framework of the

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European research project IMPETUS. The plant will be commissioned in spring 2025. The plant

will also serve as an information centre for the circular economy.

3. In the Municipality of Athens: a 50 sqm/day green unit to be installed in Ilision Park in the

framework of the European Urban Innovation Programme Cooling Heavens to be completed

in 2028. The unit will also serve as an information centre for the circular economy.

In 2024, EYDAP SA participating with NTUA and other partners in the European funded research project

THESEUS secured the installation of another unit.

After the completion, in 2026, of the Strategic Plan for Wastewater Reuse implemented by EYDAP SA, the

next phase of projects for sustainable irrigation, water supply for urban greenery and non-human

consumption needs through wastewater reuse will be launched.

14. R&D actions in water resources management

EYDAP SA, as the leading company in the water supply and wastewater sector in Greece, invests in

Research and Development (R&D) activities for the sustainable management of water resources. In this

context, it follows the current trends in the implementation of Nature Based Solutions (NBS),

incorporating circular economy and water reuse practices. An example is the UPWATER project, which

develops tools and methods for monitoring water quality and quantity, enhancing the resilience of water

resources against climate change.

In addition, EYDAP SA collaborates with research institutions and other entities to develop and

demonstrate innovative technologies, such as the use of autonomous robotic vessels (USV) to monitor

water quality characteristics of reservoirs.

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E3.MDR-A_04

Sewer management was not linked in 2024 to losses from actual significant impacts. Any damage that

occurred to the sewerage network from blockages due to third parties dumping unsuitable materials into

the network or tree roots was repaired by EYDAP SA crews immediately, without there ever being any

interruption of wastewater collection or treatment services.

Due to unforeseen factors combined with the age of the water supply network of EYDAP SA, but also due

to third party projects and due to disasters resulting from natural phenomena, there may be a temporary

interruption of water supply, during which the company's specialized technical staff undertakes the

immediate resolution of the relevant problems, minimizing any direct or indirect impact on the final

consumers of Attica.

E3.MDR-A_06

In addition, there are actions for which EYDAP SA may allocate significant operational and/or capital

expenditure. As the company adopts the principles and objectives of sustainability, the following table

presents the existing and future actions of EYDAP SA in the framework of sustainable and green financing

as well as the financial instruments of each action.

Table 29. Existing and future actions and financial instruments of the action concerned

Existing action

Financial Tool

Adrianio Aqueduct:

Construction of a network for the utilisation of the Adrian Aqueduct

for irrigation of urban greenery and water saving

EU co-funding (UIA Cultural

HID.R.A.N.T. Programme).

Sewer Mining:

The "green" Sewer Mining technology is an innovative, flexible and

energy-autonomous circular economy solution developed by EYDAP

SA in collaboration with NTUA in the framework of the European

funded IMPETUS project, which extracts wastewater directly from

the local sewerage network, processes it in a portable unit and

produces high quality water at the point of demand suitable for

irrigation and industrial use.

European funded project

IMPETUS

E3.

EYDAP SA had in 2024 significant operating expenses of 259.152.000€ for the implementation of the

relevant thematic actions.

E3-2_02

EYDAP SA actively participates in collective action plans, in addition to the actions it carries out at company

level. Specifically, it participates in the consultations related to the Water Management Plan of the Attica

Water Region (EL06) and its relevant Revisions in the framework of the workshops organized by the Special

Secretariat for Water, of the Ministry of Environment and Energy.

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● Measurement indicators and targets

[E3-3] Targets on water and marine resources

E3.MDR-T_01 -07_09-11

For all activities of EYDAP SA, the objective is the efficient use of water resources, the optimal use of

infrastructure and the strengthening of networks, as well as the improvement of the level of water

supply and wastewater services. One of the main objectives is the development and implementation

of the Environmental Management System according to the ISO 14001: 2015 standard throughout the

Company. The implementation of the internationally recognized Environmental Management System

(EMS) throughout the Company confirms its strategy to systematically monitor, evaluate and improve

its environmental performance. The System will maintain the Company's track record of not having

been fined or otherwise sanctioned for incidents of non-compliance with environmental laws and

regulations related to water or wastewater activities.

For water supply, a target has been set to reduce the operating deficit of the STPs by reducing the

consumption of water used for treatment. The water used in all stages of water treatment (evacuation

of the flocculation-settling tanks, cleaning and cleaning of these tanks, reverse washing of filters). reuse

of the water resulting from the centrifugation of the sludge resulting from the water demineralisation

process. This water is added to the quantities of water used for washing the refinery filters, all of which

is returned to the inlet of the refineries for re-treatment. The target is to reduce the operating deficit

by 75% with a base value of 2,522,651.04 m

and a base year of 2024 with a 1-year duration. This target

required funds of EUR 8,710,091.90 which were allocated to the construction of a sludge treatment

plant and the accompanying works for the 4 WWTPs.

E3.MDR-T_08_10-13_ E3-3_01_03_08

EYDAP SA has not set interim targets or milestones for the environmental objectives identified, nor has

it clarified whether they are based on hard scientific evidence or whether they are derived from

legislative requirements or are voluntary. Furthermore, it has not clarified the involvement of

stakeholders in the target setting process, nor has it identified how the targets are linked to the

management of significant environmental impacts, risks and opportunities, in particular in areas of

water risk or increased stress on water resources, such as improving water quality or reducing

consumption. At the same time, EIA is in the process of recording its performance against the

objectives set, including information on the monitoring method, measurement indicators, and

whether progress is consistent with the original planning, while recording possible changes to the

objectives, methodologies, assumptions, constraints and data collection procedures within the

specified timeframe.

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[E3-4] Water consumption

E3-4_01-07_11

Table 30. Performance in water consumption

Parameters

Measurement

unit

2024

Total water consumption

415.360.783

Total water consumption in areas at water risk,

including areas with high water stress

Total water recycled and reused

17.103.240,5

Total water stored

Changes in storage

EYDAP SA supplies untreated water from both surface and underground water resources. In particular,

surface water resources are the property of the Greek State. The untreated water supplied by the

Greek State to EYDAP SA (at the entrance of the Water Treatment Plants) comes from surface water

resources of the Marathon, Yliki, Mornos and Evinos catchments. Of the reservoirs, only the Yliki

reservoir is natural (lake), while the others have been created by the construction of dams at

appropriate points in the bed of the rivers Haradros (Marathon dam), Evinos and Mornos.

As far as the underground water resources are concerned, they are owned by EYDAP SA and the Greek

State. The water of the groundwater resources can be exploited depending on their availability and

the policy of their use, by operation:

● 20 water wells of Mavrosouvala, owned by EYDAP SA, with a total annual pumping capacity

of approximately 41 million m

of water/year

● 68 water wells owned by the Greek State, with a total annual pumping capacity of

approximately 138 million m

of water/year

In addition, based on the current operating conditions, the water sources of EYDAP SA can be divided

into main water sources, which include Mornos and Evinos, and auxiliary water sources, which include

Marathon (for the supply of the Galatsion Municipal Hospital) and Yliki (in emergency cases). Finally,

there are also the standby waterways, which include underground water resources and water wells.

Reservoirs are managed with the main objective of ensuring the quantitative and qualitative

sustainability of the resource. By extension, EYDAP SA ensures the protection of the reservoirs by

complying with strict legislation on integrated water protection and management, monitoring of

projects and activities in the protection zones of the reservoir basins and sampling of reservoir water

quality.

In particular, EYDAP SA closely monitors the water quality of the four reservoirs (Mornos, Evinos,

Marathon and Ylikis) at least eight times a year by carrying out site visits, sampling measurements for

the water quality of the reservoirs, as well as relevant analyses. In addition, complex systems for online

monitoring of critical quality parameters in raw water have been installed at 12 selected points in the

279

external aqueducts, which send real-time results with telemetry and timely alerts in case of extreme

values.

For water quality control, EYDAP SA has laboratories accredited according to ELOT ISO 17025, in Galatzi

and Acharnes, where the most modern analytical methods are applied in order to achieve high

sensitivity, accuracy and repeatability of measurement. At the same time, the laboratories are

constantly upgraded with state-of-the-art analytical equipment.

EYDAP's water laboratories are accredited for more than 110 types of tests/parameters for drinking

and surface water, as well as for sampling.

In order to comply with the obligations of the new Contract of Law 4812/2021 between the Greek

State, the Etairia PAGION EYDAP NΠΔD and EYDAP SA, the raw water quality data as well as the data

on the quality of water for human consumption are now systematically sent to the Ministry of

Environment. The results of the analyses certify that the quality of the drinking water of EYDAP SA

meets the legislative requirements of KYA D1 (d)/GP οικ. 27829/15-5-2023 (Government Gazette

3525/B/25-5-2023), concerning the "Quality of water for human consumption in compliance with the

provisions of Directive (EU) 2020/2184".

Quality of treated effluent from the WWTPs

As mentioned above, apart from the water pumping that EYDAP SA carries out in order to meet the

needs of consumers with sufficient water, within the scope of its activities is the collection and

treatment of urban wastewater through the WWTPs. The WWTPs are basic environmental

infrastructures for the protection of marine receptors. The treated effluent of the WWTPs is discharged

into the sea free of its pollutant load at a rate of about 95 %. In particular, the final recipient of the

effluent from the Metamorphosis WWTP is the Pyrna stream, which flows into the Kifissos River. The

treated wastewater from the KEL of Psyttalia is discharged directly into the Saronic Gulf. Treated waste

water from the Thriassio WWTP is discharged directly into the Gulf of Elefsina. The 3 WWTPs of EYDAP

SA, as well as the 2 newly acquired WWTPs, Megara and Koropi-Peania, discharge treated wastewater

95% free of pollutants into marine and surface waters.

EYDAP SA ensures the protection of the reservoirs by complying with strict legislation on integrated

water protection and management, monitoring of projects and activities in the protection zones of the

reservoir basins and sampling measurements of reservoir water quality.

In particular, EYDAP SA closely monitors the quality of untreated water all the way from the reservoirs

to the treatment plants, as well as drinking water from the water supply network throughout the area

of EYDAP SA's responsibility.

The water quality monitoring program has been established to monitor and document the excellent

quality and to address in a timely manner any problem that may arise, exceeding legislative

requirements and includes:

● monitoring the water quality of the four reservoirs, Mornos, Evinos, Marathon and Yliki, with on-

site measurements, sampling and analyses at least eight (8) times/year,

● daily sampling and analysis of samples of untreated water entering the ICUs

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● daily sampling and analysis of drinking water samples from the drinking water supply network

and the water supply network

● 20 quality stations for on-line monitoring of critical quality parameters, installed at key locations

of the untreated water transfer aqueducts to the treatment plants, sending real-time results with

telemetry and timely alerts in case of extreme values

● 2 quality stations for on-line monitoring of critical quality parameters, installed at selected

locations in the drinking water network

● on-line monitoring of residual chlorine in water supply network tanks, with real-time telemetric

transmission of results and timely alerts in cases of extreme values. In total, by 2025, residual

chlorine will be monitored in all the tanks of the water supply network, i.e. in 53 locations of the

network under the responsibility of EYDAP SA.

The checks carried out, particularly on drinking water, exceed the frequencies required by law.

The number of drinking water samples tested for microbiological parameters exceeds 9,000 per year

compared to the 3,300 required by legislation.

For water quality control, EYDAP SA has laboratories accredited according to ELOT ISO 17025, in Galatzi

and Acharnes, where the most modern analytical methods are applied in order to achieve high

sensitivity, accuracy and repeatability of measurement. At the same time, the laboratories are

constantly upgraded with state-of-the-art analytical equipment.

EYDAP SA's water laboratories are accredited for over 140 total tests/parameters for drinking and

surface water, as well as for sampling and the list of substances monitored is continuously enriched,

in line with international trends in regulatory issues.

Data on the quality of water for human consumption as well as data on the quality of untreated water

are systematically sent to the Ministry of Health and the Ministry of Environment. The results of the

analyses certify that the quality of the drinking water of EYDAP AE meets the legislative requirements

of the KYA D1 (d)/GP οικ. 27829/15-5-2023 (Government Gazette 3525/B/25-5-2023), concerning the

"Quality of water for human consumption in compliance with the provisions of Directive (EU)

2020/2184".

In the annual international assessment of water supply companies issued in 2024 by the European

Benchmarking Co-operation, the water quality of EYDAP SA was rated 99.7%, higher than the average

rating achieved by the European companies that participated. Water quality is ranked 1st among

180 countries worldwide, with a score of 100%, according to the Environmental Performance Index

(EPI) of Yale University.

Regarding the way of collecting data on water consumption, there are water meters installed.

E3-4_08

281

The water consumption intensity for EYDAP SA is calculated as follows: 415,360,783 m3 / EUR 373.703

million = 1,111,473 m3/euro.

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[E3-5] Projected financial consequences of impacts, risks and opportunities related to aquatic and

marine resources

E3-5_01-03

The projected financial consequences of risks and opportunities related to water resources are

considered separately for both water and sanitation.

Water supply

To assess the risks and opportunities, the magnitude of the financial impact was considered for both

current and potential risks. For potential risks, the probability of their occurrence was also considered

in combination. The magnitude of the financial impact was assessed qualitatively using a financial

scale, depending on the nature and availability of the data.

The risks and opportunities related to water resources were examined across the entire value chain

and risks that may have an impact on consumers and the company's profitability were identified as

significant.

These concern the following:

● The unsafe supply of Attica with water due to the failure of the External Water Supply System

EYDAP SA recognised and assessed the risk of unsafe water supply to Attica due to the failure of the

external water supply system. To this end, in the framework of an agreement with the Greek State, the

execution of specific projects is being promoted that will shield the secure water supply against very

high risks. For this purpose, the construction of 5 projects as indicated in E3.MDR-A_01 has been

launched. At the same time, the necessary control mechanisms have been identified and are under

discussion with all stakeholders to ensure the uninterrupted supply of quality water to EYDAP SA

during extreme weather events along the entire length and facilities of the EWS.

● The risk of water scarcity due to climate change

EYDAP SA is obliged, according to article 8.1.4 of the Contract of Law 4812/2021 between the Greek

State, the EVDAP S.A. and EYDAP SA, to prepare Water Resources Management Plans for Athens, based

on which the appropriate water withdrawal policy from the Evinos, Mornos and Marathon Reservoirs,

as well as from Lake Yliki of the External Water Supply System (EWS) of the Capital Region is

implemented. At the same time, in the medium term, the possibility of using brackish water from

exploitable deposits in the wider area of the Mornos aqueduct (e.g. the areas of Kirras, Mylons,

Kalamos Oropou, Phyllis), as well as the possibility of exploiting seawater through desalination plants,

is being investigated. Studies are being launched for all these actions). In the longer term, and with a

view to maintaining an adequate supply of water to the Athens Basin, projects are being planned and

launched to interconnect the Krikeliotis and Karpenisiotis rivers with the Evinos reservoir, ensuring

water sufficiency even in extreme conditions).

EYDAP SA for the optimal management of the water supply network includes in its 2025-2034

investment programme of €165.2 million for the reduction of leaks in the EYDAP SA network.

Sanitation

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Risks related to sewerage issues were not assessed as significant in the Financial Significance exercise,

as they did not exceed the materiality threshold when assessed in the current situation and future

horizons (up to and beyond 2030). Below is a brief summary of the main risks related to sanitation

issues:

● Environmental degradation in areas where there is no sewerage network

● Wastewater inflow into real estate or escape of wastewater into the environment (roads,

streams) due to overflows or blockages of pipelines

● Problems in the operation of the CCW treatment plants due to the discharge of untreated

wastewater into the network

● Impact on the marine ecosystem in case of inadequate treatment of waste water

● Impact of climate change (extreme weather events, fires, etc.)

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Information on social issues

ESRS S1 Domestic labour force

Strategy

[SBM-3] Significant impacts and risks and their interaction with the strategy and business model

S1.SBM-3_01 _02_03_04_05_06_11_12

EYDAP SA discloses that all employees - irrespective of their employment relationship - who could be

significantly affected by the company are included in the scope of disclosure in accordance with ESRS

2. This includes impacts arising from its operations, its value chain, its products and services, and its

business relationships.

In particular, EYDAP SA on the one hand takes into account the important impacts related to job

security, adequate wages and health and safety, ensuring that employees enjoy appropriate working

conditions and remuneration, while on the other hand it takes into account the risks related to the

health and safety and privacy of employees

Description of the types of salaried and non-salaried workers:

Employed workers

• Employees with an indefinite contract: These are the Company's regular staff, who have concluded

an employment contract of indefinite duration with EYDAP SA, covered by the Personnel

Regulation of EYDAP SA, the Operational Employment Contracts (ESSE), the decisions of the Board

of Directors and the circulars.

• Part-time cleaning contractors and 8-month contract workers .

Non-salaried workers

• Employees with a service voucher such as: Lawyers, doctors, engineers

• Employees who work in the facilities of EYDAP SA and their work is controlled by EYDAP SA but

their direct employer is a contractor (external partner).

Negative impact

EYDAP SA has no widespread or systemic significant negative impacts on the employees of its relevant

workforce in the areas where it operates. Despite the high health and safety standards it requires of

its employees, it continues to report isolated lost time accidents. All health and safety incidents are

investigated locally by dedicated teams and steps are taken to prevent similar incidents in the future,

thus ensuring the protection and welfare of employees.

A brief description of the activities resulting in positive impacts:

Secure jobs

For 2024, although the categories "Part-time contract cleaning workers" and "8-month

contract workers" exist, the number of employees in these categories was zero.

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On the social axis, the Company's concern is to ensure access to quality and affordable water for all.

At the same time, emphasis is placed on the protection of labour and human rights, in a framework of

meritocracy and transparency, where equality and safe working conditions are promoted.

The Company has established a number of benefits, such as Health Service, private insurance for

employees and children, pension insurance, as well as other benefits that contribute to the welfare of

employees.

In addition, a Regular Staff Benefits Policy (not publicly available) has been established to support

employees.

EYDAP SA applies all the requirements set by the labour legislation for the health and safety of its

employees, with the only violations recorded in 2024 being the lack of good working condition

inspection certificates for certain cranes and forklifts used in the Company and the lack of a stop

terminal on a sliding gate of a facility so that it does not come off its track. It is noted that all corrective

actions required by the Labor Inspection reports were completed promptly.

Adequate wages

Employees shall receive information in paper or electronic form of their payroll receipts, as well as any

clarifications regarding their pay and shall have the right to request and receive clarifications regarding

their pay.

All employees belonging to the Company's regular staff, irrespective of gender, are paid the same

salary, varying only according to their qualifications, marital status, years of service, job scope and

position of responsibility, if any.

The salaries of EYDAP SA's employees with employment relationship of indefinite duration (regular

staff) are derived from the Operational Collective Labour Agreements as well as from Board Decisions,

in which a uniform salary policy is followed for all these staff.

There is no gender or age differentiation in terms of basic salary and allowances, which are determined

by collective agreement.

The grade and salary promotion of permanent employees is done through their annual appraisal,

which is carried out with the use of Crisis Sheets, as provided by the Personnel Regulation of EYDAP

SA.

Finally, in the context of remuneration, a lump sum is provided for, which is taken upon the employee's

retirement from the company.

Significant risks arising from impacts and dependencies on the concerned

Health and Safety risk:

The ineffective protection measures of the Company's facilities, the non-use of Personal Protective

Equipment by employees in designated areas and the creation of conditions that do not ensure health

The information provided on adequate salaries refers to the relevant workforce

(employees with an indefinite contract) of EYDAP SA and does not include the

remuneration of the Board of Directors (BoD).

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and safety in all EYDAP SA's facilities may lead to fines, increased workers' compensation, higher

insurance premiums, reduced productivity and possible damage to the Company's reputation.

Management recognises as a key objective the continuous identification of occupational hazards, the

assessment of their risk and the implementation of the necessary control, protection and prevention

measures for a safe working environment.

Privacy Risk:

Risk of a personal data breach that may lead to reputational risk and fines and may be caused by:

● Ineffective management of network vulnerabilities.

● Inadequate training of the Company's staff on data protection issues.

● Insufficient level of information security from third parties managing corporate data.

● Insufficient physical security of facilities where critical information is stored or processed.

● Inadequate measures to protect the personal data of the organisation's employees.

● Lack of insurance coverage of the Company for personal data issues.

● Delayed reaction or failure to detect a potential cyber-attack on information systems.

● Delayed and/or insufficient installation of security updates to applications, Inadequate

management of access to the Company's information systems.

● Lack of security software to prevent cyber-attacks, viruses, etc.

● Inefficient system for data storage, back-up and recovery of critical data.

● Extensive use of individual files (e.g. Excel) to record and process data.

● Poor modification process in IT applications.

● Increased IT security management requirements due to remote working.

● Absence of classification of information and appropriate retention and processing of

information based on its criticality.

Significant impacts caused by the company's plans and actions to reduce carbon emissions in

accordance with international agreements

The company's carbon reduction actions do not create risks of job losses. A need may arise for a

number of employees to change their job description in relation to green development and

technology. It is important to note that these changes may have negative impacts on the health and

safety of employees if appropriate support and training measures are not taken. The Company should

ensure that employees have access to retraining and support programmes to adapt to new

requirements, thereby minimising the risks to growth and development.

Workforce at increased risk of harm and significant risks for specific groups:

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The Company recognizes that its workforce may be at increased risk of harm due to the diversity and

the specificities and scope of its workplaces, which include administrative services, field crews,

construction sites, refineries, water treatment plants (WWTPs), wastewater treatment centers

(WWTPs), etc. These hazards arise from the use of various machinery and tools for a wide range of

technical work, as well as from unforeseen situations such as extreme weather events, natural

disasters (e.g. fires, pandemics, etc.).

Particular attention is paid to personnel working in particularly unfavourable and unhealthy conditions

such as working in manholes and pipelines with the release of gases hazardous to health, etc. Such

personnel shall receive systematic and regular training in order to enable them to perform their duties

in the safest and best possible way. The use of personal protective equipment is also compulsory.

In addition, safety technicians and direct employees of EYDAP SA, who consider that their work

involves a risk to their safety, have the possibility to address the elected body representing them. In

this context, the anonymity of the reports is respected in order to avoid retaliation.

As mentioned above, sanitation workers are considered to belong to one of the groups with the highest

occupational risk and, for this reason, they are constantly trained and receive an unhealthy work

allowance in various percentages, in accordance with the Collective Agreement and the decisions of

the Board of Directors and circulars. Similarly, the same applies to the workers in the ICUs, who also

belong to a high-risk group, as they are constantly under the risk of chlorine gas leakage.

288

Impact and risk management

[S1-1] Policies related to the workforce concerned

S1.MDR-P_01-06 _01_02_03_04_05_06

The Company has adopted and implements the following Policies for the management of significant

impacts and risks in its workforce:

● Code of Conduct and Professional Behaviour

● Health and Safety Policy

● Employee Privacy Policy & Employee Data Protection Policy Insured

● Human Rights Policy

● Operational Collective Labour Agreements

CODE OF ETHICS AND PROFESSIONAL CONDUCT

Basic content (general objectives, major impacts and risks, monitoring process)

The Code of Ethics and Professional Conduct (hereinafter referred to as the Code), is the guide for the

daily professional conduct of EYDAP SA's employees and other partners. It clearly sets out the ethical

principles and values, as well as internal rules of ethics and ethical conduct that must be observed by

all those who have an employment or cooperation relationship with EYDAP SA. Compliance and

adherence to the above is both an individual and collective responsibility of all of us.

The main contents of the Code include:

● Mission and Vision of the Company

● Purpose and scope of the Code

● Our principles and values

● Corporate Governance and Compliance

● Standards of Behaviour

● Personal and professional integrity

● Information and data management

● Protection and use of the Company's assets

● Health and Safety

● Crisis management

● Environmental responsibility

● Infringements and reports

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● Approvals and dispute resolution

● Monitoring, revision, validity and posting of the Code

The heads of the Company's organisational units are responsible for the implementation of the Code,

who ensure through personal commitment that all employees of their organisational units and

external partners have fully understood the Code and behave in accordance with it.

The violation of this Code, the relevant legislation and corporate Directives/Policies/Regulations may

have significant consequences not only for the individuals who commit it but also for EYDAP SA, as

many of the specific standards of conduct included in this Code constitute disciplinary and criminal

offences.

The Company takes all reports of potential misconduct seriously, ensuring in each case that the

confidentiality of the report is guaranteed and that a relevant investigation is carried out in order to

establish any violation. For each violation, the required corrective measures and related sanctions are

taken, which are determined in accordance with the nature of the violation, the applicable law and

the employment/cooperation agreements.

Scope of

Based on the Code, which is applicable in all geographical areas of the Company's activity, the way of

exercising the duties of all EYDAP SA personnel, who are employed by the Company with a dependent

or non-dependent employment contract, is regulated and will also be addressed to all its partners

(contractors, suppliers, service providers, etc.)

There is no exception to the scope of this Policy.

Highest level in the organisation of the enterprise responsible for implementation

The Compliance Directorate is the reporting address for questions or doubts about compliance with

the Code.

Commitment to respect third party standards or initiatives

The Code is based on international standards and best practice methodologies and aligned with

relevant regulatory/legal requirements.

Attention paid to the interests of key stakeholders in the definition of policy

The Code is updated and the views of the workforce concerned are taken into account. Their

suggestions and comments are carefully assessed when defining and revising the Code to ensure that

their needs and interests are fully integrated.

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in

its implementation

290

The Code was communicated to employees with an obligation to provide written proof that they were

aware of it and is posted on the Company's website.

HEALTH AND SAFETY POLICY AT WORK

Basic content (general objectives, major impacts and risks, monitoring process)

EYDAP SA has adopted and applies an Occupational Health and Safety Policy, which applies to all its

employees without exception, as well as to any third person, who, for any reason, is in its premises.

It also sets specific targets, to which it commits itself to making every effort to achieve them. One of

the main objectives of the policy is to achieve full compliance with the regulatory framework and, in

addition to the laws and regulations, EYDAP SA also creates and implements its own guidelines, such

as the general and specific work guidelines which are posted on the ESYP website.

In order to achieve this goal, regular visits are made by Safety Technicians and Occupational Physicians

to all workplaces, in order to identify and quantify the risk of each job.

The main aim of workplace inspections is to provide advice on safety at work and to identify unsafe

conditions. Inspections serve as a tool for investigating occupational or near-occupational accidents,

as well as for measuring harmful factors such as noise, humidity, temperature and radiation, using

appropriately calibrated instruments, etc.

At the same time, EYDAP SA complies with all applicable laws and regulations, implementing programs

and procedures that ensure such compliance. To this end, the training of employees on H&S issues is

continuous and uninterrupted, and is carried out either remotely (e.g. through targeted emails) or

through face-to-face seminars, which take place on an annual basis, as a rule. The ESRP's training

material is also available in electronic format, and in 2024 it was further enriched by the use of artificial

intelligence applications.

Management recognises as a key objective the continuous identification of occupational hazards, the

assessment of their risk and the implementation of the necessary control, protection and prevention

measures in order to ensure a safe working environment. For this reason, it encourages

communication with employees on H&S issues, and, at regular intervals, it also convenes tripartite

meetings with the H&S Department, and employee representatives, as required by law.

More generally, the Management recognises that the Health and Safety of employees is its primary

responsibility, and for this reason, it is committed to ensuring that it has all the necessary resources

and authorisations for the most effective operation of the Occupational Health and Safety system.

Finally, it believes that each employee should also make every effort to fulfil his or her own

responsibilities and obligations in response to this commitment of the Management.

Scope of

The Occupational Health and Safety Policy applies to all employees of EYDAP SA, regardless of the type

of their contract (permanent, water engineers, part-time cleaning contractors and 8-month contract

employees), as well as to any third person who, for any reason, is on its premises.

291

Highest level in the organisation of the enterprise responsible for implementation

In accordance with the current legislation (Law 3850/2010), EYDAP SA has established an Internal

Prevention and Protection Service (ESYPP), consisting of the Technical and Scientific Officers (and their

scientific managers), with the main responsibility for the identification and labelling of occupational

hazards, ensuring the best possible prevention of occupational hazards. Based also on the current legal

framework, the ESRP - a purely advisory body on employee health & safety issues - is organisationally

directly subordinated to the person legally responsible for the Company (i.e. the CEO), without any

involvement in the implementation of any policy.

Commitment to respect third party standards or initiatives

In order to fulfil its service role, ESYPF, among other things, applies a single management system that

meets the requirements of ISO 9001:2015 and ISO 45001:2018.

Attention paid to the interests of key stakeholders when defining the Policy

As explicitly stated in the H&S Policy, the Management is committed to seeking communication with

employees on any relevant issue, while, at regular intervals, it also convenes tripartite meetings with

the ESYPP and the Employees' Health and Safety Committee (EHS Committee), in accordance with the

provisions of Law 3850/2010. The EHRC is an elected body of employees to which complaints may be

submitted anonymously, in accordance with the legislation in force.

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in

its implementation

The Health and Safety Policy of EYDAP SA is posted on the corporate website www.eydap.gr in the

section "The Company/Regulatory Framework".

EMPLOYEE DATA PROTECTION POLICY

Basic content (general objectives, major impacts and risks, monitoring process)

EYDAP SA, based on the provisions of Regulation (EU) 2016/679, through its Employee Data Protection

Policy, informs its employees about the processing of their data by the Company and, where

applicable, they are invited to sign individual forms-declarations to ensure their information.

In addition, through this Policy, it informs its employees about the type of personal data it collects in

the context of the employment relationship, the purpose of processing, way of processing (collection,

storage, use, transfer), the means of protection and the rights that users have against this processing,

which in any case is carried out in a reliable and transparent manner.

The employees themselves, at the beginning of their employment relationship and thereafter,

whenever the need arises due to a change in their work duties, sign relevant confidentiality circulars

and compliance with the Company's procedures regarding the protection of personal data, generally

within the Company, both for consumers and employees themselves.

The Company ensures the protection of employees' personal data, showing absolute respect for their

individual freedoms and rights. In the context of highlighting respect for privacy in the workplace and

292

protecting the right of informational self-determination of each employee, clear procedures and

privacy policies have been established to ensure the safe exercise of such complaints.

Personal data of human resources are protected by taking the necessary technical and organisational

security measures in the facilities and systems where the data are kept.

Staff shall be facilitated in the exercise of any relevant rights by establishing simple and clear

procedures for the exercise, processing, evaluation and satisfaction of requests.

Scope of

EYDAP SA, through its Employee Data Protection Policy, informs its employees about the processing of

their data by the Company.

At the same time, and through the Code, EYDAP SA is committed that the personal data of its

employees is important and protects it with great care and responsibility.

The company, as a critical infrastructure in the field of cybersecurity, applies a holistic information

security management strategy consisting of a series of technical actions and measures to protect,

prevent and address risks and threats in order to enhance the resilience of its information systems and

networks, armor them and ensure compliance with regulatory, legal and contractual requirements.

EYDAP SA in the context of compliance with the national and international regulatory and legal

framework of cybersecurity (NIS2, ISO27001, NIST CSF, CIS Controls, GDPR) formulates an Integrated

Security Management Framework based on these and taking into account the protection of personal

data, as it is only one aspect of overall information security. It also formulates an Integrated

Cybersecurity Risk Management Framework through threat occurrence identification assessments and

operational impact mitigation assessments on the Organization's activities and operations. In addition,

in the area of Threat Management and Incident Response, the company organizes and implements

regular penetration testing, discovery and management of critical vulnerabilities in corporate systems

(Vulnerability Assessment & Penetration Testing). Implements Cyber Threat Intelligence solution, to

monitor and collect critical to the Company's security from Deep and Dark Web and develops business

continuity management policy, disaster recovery and incident response plans.

Highest level in the organisation of the enterprise responsible for implementation

In order to ensure continuous and secure compliance with the General Data Protection Regulation, a

Data Protection Officer's Office has been established, staffed by individuals with expertise and

knowledge of internal Company procedures. However, the responsibility for the implementation of the

Policy, as well as other policies related to the protection and compliance with the GDPR, lies with the

respective "data controller".

Commitment to respect third party standards or initiatives

EYDAP SA manages the issue of Personal Data Protection with a view to the continuous compliance of

the Company in the light of the provisions of the General Data Protection Regulation EU2016/679 and

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the current legislative framework (Law 4624/2019, Law 3471/2006), the Guidelines of the Working

Party No. 29 (WP29), the European Data Protection Board (EDPS), the European Commission, the

relevant Directives, Decisions, Opinions of the Data Protection Authority.

Attention paid to the interests of key stakeholders when defining the Policy

The Employees' Personal Data Protection Policy aims to inform employees about the Personal Data

collected by EYDAP SA in the context of the employment relationship, how they are processed, the

means of protection it receives for their protection and the rights that employees have against this

processing, which in any case is carried out in a transparent and reliable manner.

The Employee Privacy Policy is not the result of an understanding of employees' concerns and their

suggestions but is a statement informing employees about the data collected in the context of the

employment relationship, how it is processed, the means of protection it receives to protect it and the

rights employees have against such processing, which in any case is carried out in a transparent and

reliable manner.

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in

its implementation

The Policy is widely known and communicated to interested parties such as shareholders and

consumers by posting it on the Company's website and to employees by announcing it to all and

posting it on the internal website (portal).

HUMAN RIGHTS POLICY

Basic content (general objectives, major impacts and risks, monitoring process)

EYDAP SA is committed to the protection of human rights, taking preventive actions in order to avoid

acts and/or omissions that may be detrimental to human rights.

The primary purpose of this Policy is to raise awareness and ensure the commitment of all those

employed by the Company, whether as employees, partners, suppliers or subsidiaries.

The main contents of the Policy include:

● Respect and protection of labour & social human rights

o Labour Rights

o Social Human Rights

● Final provisions

o Monitoring and evaluation of the implementation of the Policy

o Report of policy violations

o Adoption and review of the Policy

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The Company ensures the timely detection and prevention of situations that endanger human rights,

by informing and training all its staff and other associates.

The Company's Policy must be strictly observed by everyone without exception. No violation will be

tolerated and in case of violation of its principles, the procedure for the imposition of legal sanctions

will be activated.

Scope of

The EYDAP SA HUMAN RIGHTS POLICY applies to all the Company's geographical areas of operation,

as well as to any existing or future subsidiary.

More specifically, the following are bound by the content of this Policy:

1. The personnel employed by the Company under a dependent employment contract

2. Personnel who provide services to the Company under a service contract or otherwise

independently.

3. The Company's other partners (contractors, suppliers, service providers, etc.)

There is no exception to the scope of this Policy.

Highest level in the organisation of the enterprise responsible for policy implementation

Please see below under Availability of the policy to potentially affected parties, as well as to

stakeholders who should assist in its implementation.

Commitment to respect third party standards or initiatives

The Company complies fully with the requirements of Greek and EU legislation and human rights

standards. In particular, this Policy is based on the following:

● Fundamental principles of the Greek Constitution

● Principles of the United Nations Universal Declaration of Human Rights

● European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR)

● Charter of Fundamental Rights of the European Union (2000/C 364/01)

● Council of Europe Convention 108 and its update

● United Nations Guiding Principles on Business and Human Rights 4

● United Nations Global Compact (UNGC)

● OECD Guidelines for Multinational Enterprises

● Declaration on Fundamental Principles and Rights at Work of the International Labour

Organisation

295

● International Standard Social Accountability 8000 (SA 8000)

Attention paid to the interests of key stakeholders when defining the Policy

EYDAP SA recognises the importance of protecting human rights and pays particular attention to the

interests of key stakeholders when defining the Policy.

In case of violation of any principle related to human rights or if there is a reasonable suspicion such

violation, then the corresponding report/complaint should be submitted to the Company. This

procedure is governed by the Whistleblowing Policy, the Policy on Preventing and Combating Violence

and Harassment at Work and this Policy.

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist

in its implementation

The Human Rights Policy, under the responsibility of the General Directorate of Human Resources, is

communicated to the Company's employees and posted on the Company's website www.eydap.gr.

The Policy is approved by the Board of Directors and reviewed annually by the Compliance Department

and revised if and when required. The Compliance Division is responsible for preparing and proposing

the revision for approval.

OPERATIONAL COLLECTIVE LABOUR AGREEMENTS

Basic content (general objectives, major impacts and risks, monitoring process)

All employees, belonging to the regular staff of EYDAP SA, regardless of gender, are remunerated with

the same salaries, varying only according to their qualifications, marital status, years of service, job

scope and position of responsibility, if held, as mentioned above in S1.SBM-

3_01_02_02_04_05_06_11_12.

The salaries of EYDAP SA's employees result from the application of both the Operational Collective

Labour Agreements (EWCs), but also from circulars and decisions of the Board of Directors, which

follow a uniform salary policy for all regular staff, depending on their qualifications, without separation

or discrimination.

The Company, in addition to the statutory benefits to employees, has also instituted indicative

measures for the protection of the family, through Board decisions and ESSEs and in accordance with

the Personnel Regulation:

● 9-month parental leave, instead of the reduced working hours provided by law. In 2024 and in

the context of family protection and in application of Law 4342/23-12-2015, such leave was

granted to 19 employees of the Company (8 Men and 11 Women). 100% of the employees

who were granted such leave and whose leave expired in 2024 returned to work after its

expiration.

296

● 8 days of leave/year, instead of the 5 required by law, due to illness of their child, aged up to

16 years old and not up to 12 years old as required by law. After exhausting their statutory

maternity leave, take parental leave with half pay until their child is two (2) years old

● 4 days off for each child to inform working parents about their child's progress at school, a

benefit for children aged 5-18 years.

● 6 workers (3 men and 3 women) took unpaid leave of more than 3 months for family or study

reasons

● The right for the children of employees to participate in summer camps. In 2024, 211

employee children participated in the camp program.

● Use of the Daycare coverage benefit by 78 employees for 93 children.

● Use of the Foreign Language Tuition Fee Coverage benefit by 451 employees for 709 children.

● Health Service, which provides primary health care services to workers and their insured family

members and manages their medical and pharmaceutical coverage

● Private insurance for employees and children

● Pension insurance for doctors, engineers and lawyers (upon request)

● Ownership of shares

● Provision of expenditure for children's camps, for undergraduate or postgraduate studies for

employees, etc.

● Educational cash prizes for excellence for those who succeed in Higher Education Institutions,

children of employees

● A lump-sum amount is provided under the remuneration framework, which is received upon

retirement from the company.

● Amount to cover the cost of creative activity (summer camp) for a child during the summer

months.

● A lump-sum benefit to one of the two employees of the Company, regardless of gender, for

the birth of each child.

The NAPs and Policies promote transparency of procedures, enhance employee confidence and

safeguard safe workplaces while reducing the risks of privacy violations and improving working

conditions on a daily basis, creating a harmonious working environment. After the expiration of the

current ESCA, negotiations and signing of a new contract will follow based on the needs of the

employees.

Scope of

297

The company's Collective Labour Agreements cover the company's regular staff, regardless of the

geographical area they work in.

Highest level in the organisation of the enterprise responsible for policy implementation

The Directorate General for Human Resources is responsible for implementing the terms of the

Operational Collective Labour Agreements.

298

Commitment to respect third party standards or initiatives

Right to trade unionism: The constitutional right to trade unionism is exercised by the Federation of

Employees of EYDAP SA, which was founded in 1979, is a Secondary Trade Union Organization and

represents the employees of the Company. Its composition is formed proportionally by elected

representatives of the 9 Primary Unions.

The purpose of OME - EYDAP SA is the study, protection and promotion of the trade union, economic,

professional, ethical, insurance and social interests of its members, the protection of the environment,

the realisation of the principle of gender equality and the safeguarding of corporate responsibility.

The aim is to claim the improvement of employees' working conditions by using dialogue and

cooperation with the Company's Management, always within the framework of corporate social

responsibility rules. The objective is to claim the improvement of the working conditions of the

employees by using dialogue and cooperation with the Company's Management, always within the

framework of the rules of corporate social responsibility and the Trade Union Law 1264/1982.

The Collective Labour Agreements are the result of negotiations between the parties, the CEO of the

Company and the President and Secretary of the Federation of Employees of EYDAP SA (OME-E.YD.A.P.)

Attention paid to the interests of key stakeholders when defining the Policy

EYDAP SA maintains an open dialogue with its staff in order to solve any cooperation problems, within

the framework of the applicable labour and insurance legislation and the relevant Collective Labour

Agreements.

Employees receive information in paper or electronic form of their payroll receipts and have the right

to request and receive clarification on their pay.

Workers' concerns and proposals are expressed through the Federation, during the negotiations for

the formulation of the NDAs

The total number of workers registered with the Federation amount to 2.101 percentage: 96,02%.

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in

its implementation

The Company Collective Labour Agreements (CECAs) are made known to the employees upon

notification by the Company's Employees' Federation.

299

S1-1_01

Impact and risk management policies for all or specific groups of the workforce.

Please see requirement S1.MDR-P_01-06_01_02_03_04_05_06 (Scope of Policies).

All of the above Policies cover the entire workforce of EYDAP SA

S1-1_03_04_05_06_07 & S1.

Commitments on Human Rights Policy

Commitments & respect for human rights - Procedures and mechanisms for monitoring compliance -

Alignment with internationally recognised instruments

In November 2022, by decision of the Board of Directors, the EYDAP SA HUMAN RIGHTS POLICY came

into force, which is based on the fundamental principles of the Greek Constitution, the Principles of

the United Nations Universal Declaration of Human Rights, as well as on a number of other

International Conventions clearly described in the Policy (see. requirement S1.MDR-P_01-

06_01_02_03_04_05_06 in the HUMAN RIGHTS POLICY ). The Company, is committed to upholding

human rights, taking proactive steps to avoid acts and/or omissions.

In addition, an assessment of EYDAP SA and its subsidiaries was carried out with regard to the

requirements of the minimum social safeguards, which have been established in accordance with

Article 18 of EU Regulation 2020/852. These safeguards are derived from a set of defined guidelines

of the UN, the EU and other international organisations, as follows:

● OECD Guidelines for Multinational Enterprises (OECD Guidelines for Multinational Enterprises)

● United Nations Guiding Principles on Business and Human Rights (UN Guiding Principles on

Business and Human Rights-UNGP)

● Declaration of the International Labour Organization on Fundamental Principles and Rights at

Work

● International Bill of Human Rights

According to the Final Report on Minimum Safeguards of the Platform for Sustainable Finance, the

minimum social safeguards relate to the following areas:

● Human rights, including labour rights

● Corruption and Bribery

● Taxation

● Fair competition

300

The Policy applies to the Company and any existing or future subsidiary. Its content binds staff with a

dependent employment contract, staff with a contract or service project relationship, as well as

members of the Company's Board of Directors and other partners (contractors, suppliers, service

providers, etc.).

CODE OF ETHICS AND PROFESSIONAL CONDUCT

Please see also requirement S1.MDR-P_01-06 _01_02_03_04_05_06 Commitment to respect the

standards or initiatives of third parties to the Code.

HUMAN RIGHTS POLICY

EYDAP SA shows zero tolerance to behaviours and situations that violate human rights, while avoiding

cooperation with persons who have been proven to be involved in cases of human rights violations. In

this direction, EYDAP SA has been implementing, since 2022, a Human Rights Policy approved by the

Board of Directors, which has as its primary purpose to raise awareness and ensure the commitment

of all those employed by the Company, whether in the form of dependent employment or non-

affiliates, suppliers or subsidiaries to the Company. Please also see requirement S1.MDR-P_01-06

_01_02_03_04_05_06 Commitment to respect the standards or third party initiatives of this Policy.

HEALTH AND SAFETY POLICY AT WORK

Please see also requirement S1.MDR-P_01-06 _01_02_03_04_05_06 Commitment to respect the

standards or third party initiatives of this Policy.

EMPLOYEE DATA PROTECTION POLICY

Please see also requirement S1.MDR-P_01-06 _01_02_03_04_05_06 Commitment to respect the

standards or third party initiatives of this Policy.

OPERATIONAL COLLECTIVE LABOUR AGREEMENTS

Company Collective Labour Agreements are negotiated with the Employees' Federation (OME) and

contain terms in accordance with labour legislation. Please see also requirement S1.MDR-P_01-06

_01_02_03_04_05_06 Commitment to respect third party standards or initiatives for ESCAs.

Respect for the human rights, including labour rights, of those in its own workforce in relation to the

important issues

Please see requirement S1.MDR-P_01-06 _01_02_03_04_05_06 of the Human Rights Policy.

301

Health and Safety

The Company provides access to drinking and clean water, sanitary and catering facilities, as well as

special changing rooms, depending on the nature of the staff's work. The Company's primary objective

is to ensure that work is carried out with the minimum risk of accident, injury or exposure to health

hazards. To this end, all measures are observed to avoid and minimise these.

Privacy

The Company complying with the provisions of the applicable legislation on the protection of personal

data of natural persons, takes care to comply with the appropriate technical and organizational

measures and guarantees, in order to ensure that:

● Privacy: By default, the privacy of natural persons is respected and only the personal data

necessary for the purpose of the processing is processed.

● Processing Principles: All processing is governed by the principles set out in Article 5 of the

General Data Protection Regulation (EU) 2016/679, which include the principle of legality,

objectivity and transparency, purpose limitation, the principle of proportionality (data

minimisation), data accuracy, the determination of the duration of processing, integrity and

confidentiality, as well as the principle of accountability of the Company.

● Rights of natural persons: the possibility and procedures for exercising the rights of natural

persons, such as information, access, opposition, deletion, restriction, portability.

● Data security: every effort is made to prevent any form of external or internal action that could

in the alteration, loss, destruction of personal data, as well as unauthorized access by third

parties.

Please see also the requirement S1.MDR-P_01-06_01_02_03_04_05_06 of the HUMAN RIGHTS

POLICY.

Job security and adequate wages

Please see requirement S1.MDR-P_01-06 _01_02_03_04_05_06. Working with individuals in its own

workforce

Health and Safety

The Internal Prevention and Protection Service (IPSPS) of EYDAP SA provides all possible information,

to all its external partners, on the risks and the measures that should be taken. However, compliance

with safety measures is not up to the company itself, but to the respective employer of these

employees, who, among other things, should have their own TA and IE to supervise their staff, by law.

Security guarantees are provided for workers with respect for their privacy and dignity.

Privacy

Please see above: privacy (2

bulletpoint).

Job security and adequate wages

302

Please see requirement S1.MDR-P_01-06 _01_02_03_04_05_06.

Measures that provide and/or enable remediation of human rights impacts.

The Company's HUMAN RIGHTS POLICY must be strictly observed by everyone without exception. No

violation will be accepted and, in fact, in case of violation of its principles, the procedure for the

imposition of legal sanctions will be activated, as indicated in S1.MDR-P_01-06 _01_02_03_04_05_06

of this Policy.

In the event that a human rights principle is violated or there is a reasonable suspicion of such a

violation, then the corresponding report or complaint should be submitted to the Company, in

accordance with the

Whistleblowing Policy or the POLICY FOR THE PREVENTION OF VIOLENCE AND MALICIDE AT WORK, as

applicable.

Health and Safety

For the Company, defending and ensuring the health and safety of its employees and third parties

(contractors and their employees, service providers, etc.) is a paramount obligation. To this end, it

establishes policies and adopts in the workplaces, high standards of health and safety in the workplace,

proceeding to regular assessment of these and management of the relevant risks and updating, if

necessary.

Privacy

Please see above: privacy (3

bullet).

Secure jobs

The Company provides its employees and executives with working conditions that are compatible with

its operation and related to the respective duties of each employee.

Furthermore, the Company fully respects and complies with the entire legal framework concerning

the right of association and collective bargaining.

Adequate wages

Please see requirement S1.MDR-P_01-06 _01_02_03_04_05_06.

303

S1-1_09

Prevention policy or management system for accidents at work

EYDAP SA has adopted and applies the Health and Safety Policy, which is posted on the corporate

website www.eydap.gr in the section "The Company/Regulatory Framework". This policy applies to all

employees of EYDAP SA's facilities without exception, regardless of the employment relationship under

which they are employed.

Within the framework of the Health and Safety Policy of EYDAP SA, a specific number of visits per

facility, by the Occupational Physicians (O.E./Safety Technicians (TA), depending on the number of

employees employed in the facility, is foreseen. The observations of the IOs/TAs are initially submitted

in handwritten form, in books certified by the SEPE, which are kept at the premises of EYDAP SA, for

this purpose, as provided for by the legislation in force.

The reports/reports of the IOs/TAs are also sent in aggregate to the Management, at the end of each

month, in the form of electronic files, with embedded photographic material, if deemed appropriate.

The evaluation of the reports of the PI/TAs is also carried out by their scientific supervisors in the ESRP,

who also have the possibility to carry out ad hoc inspections of the workplaces. Furthermore, an

annual report summarising the main findings of the IC/TAs is prepared by the ESRP at the end of each

year and sent to the Management.

Visits to workplaces are also carried out by the Employee Health and Safety Committee (EHSC), a

statutory collective body of employee representatives, which also meets periodically together with the

Management and the ESYPP, and may also propose measures to remove unsafe conditions.

In the event of an industrial accident, the ESYP immediately applies the prescribed procedure, which

includes, among other things:

• an autopsy at the site where the incident took place

• interviews with the parties involved

• preparation of a report by the competent Safety Technician, analysing the causes of the accident

• a proposal for measures to avoid the incident in the future

• sending the written report to the Administration

The work accident report is also communicated to EYAE in order to contribute with its views to avoid

similar incidents in the future.

Please also see requirement S1.MDR-P_01-06_01_02_03_04_05_06 regarding the Employee Health

and Safety Committee in the Occupational Health and Safety Policy.

304

S1-1_10 _11_12_13

Policies aimed at eliminating discrimination including harassment and promoting other ways to

enhance diversity and inclusion

The Company has adopted and applies:

● Policy on prevention, combating violence and harassment at work available on the corporate

website eydap.gr.

● Diversity Policy available on the corporate website eydap.gr.

Discrimination coverage in the 's policy

The Company, through its Diversity Policy (Board Resolution 20961/2021), recognizes the importance

of promoting the Diversity Principle in the composition of its Board of Directors, its senior management

and all its employees. This Policy focuses on key parameters such as gender, age, experience, skills and

knowledge. In addition, it ensures that there is no exclusion on the grounds of discrimination related

to gender, race, colour, ethnic or social origin, religion or belief, property, disability, age or sexual

orientation.

Commitments on inclusion or affirmative action for people from vulnerable groups within its own

workforce

Measures and management practices to prevent and control the risks of violence and harassment

include actions to raise awareness among employees of healthy patterns of behaviour (e.g. avoidance

of addictions), but also issues relating to vulnerable categories of employees. The actions involve the

existence of a liaison "reporting person" in the Company, the immediate receipt and investigation of

reports - complaints submitted and their resolution within the Company's framework and in a very

short time.

Please see also requirement S1-2_10

Implement specific procedures for preventing, mitigating and acting on discrimination and promoting

diversity and inclusion

● Compliance with legislation: The Company complies with all measures and obligations set

forth in Law 4808/2021 for the prevention and response to all forms of violence and

harassment.

● Awareness and protection: The Company shall ensure the awareness and protection of

employees and the strengthening of confidence in the working environment.

● Maintaining a positive climate: The Company encourages the maintenance of a work climate

where respect for human dignity, cooperation and mutual assistance are core values.

● Management of reports: The Company is to implement procedures within 2025 to manage

reports and complaints from the Complaints Review Committee on Violence and Harassment

at Work.

305

The Company protects any person who is subjected to bullying or harassment by encouraging him/her

to make a complaint and by informing the competent authorities and the competent departments of

the Company on his/her own initiative.

Also, in the context of promoting respect for privacy in the workplace and protecting the right to

informational self-determination of each employee, clear procedures and privacy policies have been

established for the safe exercise of complaints. These complaints are either part of the Whistleblowing

complaints system or relate to the prevention and combating of violence and harassment at work.

S1-1_14

Forms of policy communication - Tools and channels - ensuring policy accessibility and understanding

of its impact by the workforce concerned

All Policies are communicated to interested parties initially by posting them on the official company

website and on the internal portal website. They are communicated to the entire workforce through

email to all users and by posting them on notice boards at workplaces in hard copy and with a signed

declaration that they have taken note of the respective Policy. At the same time, seminars are held by

the Human Resources Training Department on the relevant topics, where employees are trained on

the Policies and thus possible obstacles to their dissemination are removed.

CODE OF ETHICS AND PROFESSIONAL CONDUCT

Please see requirement S1.MDR-P_01-06 _01_02_03_04_05_06 of the Code.

HUMAN RIGHTS POLICY

Under the responsibility of the General Directorate of Human Resources, the Policy is communicated

to the Company's employees and posted on the Company's website. The Policy is approved by the

Board of Directors, reviewed annually by the Compliance Department and revised if and when

required. The Compliance Division is responsible for preparing and proposing the revision for approval.

Please see also requirement S1.MDR-P_01-06_01_02_03_04_05_06 of this Policy.

HEALTH AND SAFETY POLICY AT WORK

EYDAP SA's H&S Policy is posted on the Company's website and in all its facilities, in the form of

information boards.

Please see also requirement S1.MDR-P_01-06_01_02_03_04_05_06 of this Policy.

EMPLOYEE DATA PROTECTION POLICY

The Employee Privacy Policy is posted on the internal website Aqua Portal of EYDAP SA.Please see also

the requirement S1.MDR-P_01-06 _01_02_03_04_05_06 of this Policy

OPERATIONAL COLLECTIVE LABOUR AGREEMENTS

Please see also requirement S1.MDR-P_01-06_01_02_03_04_05_06 of this Policy.

306

S1-1_15

Policies and procedures that make qualifications, skills and experience the basis for recruitment,

placement, training and development - Supporting those who find it most difficult to acquire such

qualifications, skills and experience.

Factors for attracting new talent & managing existing valuable staff:

• Recruitment process with clear identification of formal & substantive qualifications through the

AESEP

In an era of rapid economic and technological change, it is imperative to equip human resources with

the necessary knowledge, skills and competencies to respond effectively to job requirements, to

enhance the diffusion of knowledge and to ensure corporate continuity.

In the IT sector in particular, the low starting salary compared to market salaries is a barrier to

attracting new talent. The high complexity and high demands of the subject make it more difficult to

attract skilled professionals, who often prefer more competitive salaries in the private sector. The

internal procedure applied to staffing the Company's organisational structure provides for the internal

advertisement of each vacancy (Responsibility Position) that arises. All employees of the Company

with a contract of indefinite duration who meet the conditions set out in each Call for Applications are

eligible to participate. The process involves candidates completing a psychometric test followed by a

skills exploration stage conducted by a team of trained internal interviewers. Employees who

participate in the process are placed on the Executive Register to fill vacancies for positions of

responsibility in the organisation chart.

In parallel with this work and in order for all the Company's executives to be included in the Register

of Executives, the same internal skills screening process is also carried out for the Heads of all the

General Directorates and Independent Services, who have not participated as candidates in any of the

internal calls.

In 2024, a total of 12 Service level responsibility posts and 1 Directorate level post were advertised

internally.

After the internal procedures were implemented, the 11 posts of Head and the post of Director were

filled by staff members who either took over from a previous position of responsibility or took over for

the first time.

EYDAP SA, in line with its corporate strategy and business objectives, invests in continuous training and

the development of employees' skills as a tool for upgrading and deepening skills, without

discrimination, both at professional and personal level, as they are its most valuable asset, either by

implementing training programs or by encouraging participation in seminars/conferences outside the

Company.

Please also see requirement S1.MDR-P_01-06_01_02_03_04_05_06 (All employees, regardless of

gender discrimination).

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S1-1_17

Every semester seminars are held by the Human Resources Training Department on policies, with

emphasis on those related to combating violence & harassment at work, diversity, human rights, etc.

All the Company's workforce and, of course, middle and senior managers have the opportunity to

participate in these in order to raise awareness, address in a timely manner and resolve any

discrimination that may arise.

S1-1_18

In order to ensure the health and safety of employees, customers and other visitors with disabilities,

ramps for disabled persons and wheelchairs are provided, in accordance with existing legislation, so

that they can move in a safe manner throughout most of the company's premises. Special parking

spaces, lifts and sanitary facilities are also provided to facilitate safe movement for all.

S1-1_20

The records of permanent workers are updated frequently and whenever the workers themselves

submit new information concerning themselves and their family (e.g. change of identity or residence

address, obtaining a degree or postgraduate qualification, etc.). Also, for any change in the employee's

grade & salary status, promotion, change in position or job scope, change in type of insurance, etc.,

both the employee's physical and electronic file is updated on . Thus, there is detailed monitoring and

complete transparency in the changes in the employee's job profile.

S1-1_21

Procedures for reporting incidents of discrimination and vigilance about formal structures and informal

cultural issues that may prevent workers from raising concerns and complaints

Under the Whistleblowing Policy, the internal reporting mechanism concerns violations of the

Company's Policies and/or the legislative and regulatory framework governing its operation.

The reports are evaluated by the Report Evaluation Committee headed by the Director of Compliance,

who is also responsible for the whole process of the internal reporting system.

Complaints are dealt with in accordance with the procedures for their resolution, within the

framework of the services of the respective Directorates. The Company ensures that these procedures

are accessible and understandable to all employees.

In addition, in addition to written and electronic information for employees, training seminars have

been provided.

308

S1-1_22

Programmes to promote access to skills development

Please see also requirement S1-1_15 (In a time of rapid change... ensuring corporate continuity)

EYDAP SA, in line with its corporate strategy and business objectives, invests in the training and

development of employees' skills both at professional and personal level, as they are its most valuable

asset, either by implementing training programmes or by encouraging participation in

seminars/conferences outside the Company.

In addition, the training programme of the HR Training Department is aligned with the strategic

priorities of the Company.

The Company provides Health & Safety Education & Health & Safety at Work as well as Training on all

Company Policies.

It is noted that in 2024, the percentage of workers trained reached 10.04%.

In 2024, the average number of training hours per employee was 10.05%, while a total of 83 training

items were implemented in the thematic modules, with 132 seminars, with significant employee

participation.

Training topics:

• Organization, Management & Economy: Seminars 44 I Trainees 675 I Training hours 6.496.

• Research, Sustainable Development & Innovation: Seminars 6 I Trainees 113 I Training hours 1.227.

• Information Technology & Control Systems: Seminars 20 I Trainees 215 I Training hours 4.000.

• Foreign Languages: Seminars 12 I Trainees 116 I Training hours 4.135.

• Compliance and Policies: Seminars 19 I Trainees 408 I Training hours 2.294.

• Health & Safety at Work: seminars 31 I Trainees 599 I Training hours 5.049.

For 2025, the Company plans to develop an asynchronous training platform, offering flexibility of

access to various subjects, focusing on the Company's Policies related to regulatory compliance.

EYDAP SA continues to invest in training and development, ensuring the long-term sustainability of its

strategy and the empowerment of its human resources.

309

[S1-2] Procedures for engaging with the relevant workforce and employee representatives on impacts

S1-2_01

The views of the Company's workforce are taken into account in decisions and activities relating to the

management of actual and potential impacts on work. The views of employees are taken into account

through:

● Communication with employees: "Our Source" is an internal communication channel, sending

out weekly newsletters with informative content on Company news.

● Executive workshops: Annual workshops are organised covering all areas of the Company's

business, including strategy, corporate governance, innovation and digital transformation.

● Information Workshops: Throughout the year, information workshops are organised for all

staff, focusing on labour, health and social issues, on the occasion of World Days.

● Social Responsibility actions: The Company organizes actions that strengthen the culture of

belonging and teamwork, such as tree plantings in cooperation with We4All and beach clean-

ups in East Attica.

● Running Team EYDAP: A team of employee runners was created to participate in running

events, promoting health and wellness.

● HR strategy: As part of the strategic monitoring and planning of human resources needs, an

application (workforce planning) has been developed to record data and staffing needs, with

the aim of automatically updating annual and needs up to 2031.

● Questionnaires when employees leave for retirement: A questionnaire is provided to staff

coming to the Company to receive the necessary documents for retirement and submit them

for retirement to record job satisfaction and suggestions for improving the operation of EYDAP

SA.

● Social Responsibility actions: In the context of strengthening a unified corporate culture, the

Family Day was organized for the first time at the Marathon Dam, where employees and their

families met and enjoyed a rich program of environmental activities and games, aiming to

strengthen environmental awareness and cultivate team spirit. In the same direction, the

collaboration with the Goulandris National Museum of Natural History offered the employees'

families the opportunity to visit the Museum's exhibits and participate in its activities.

Please see also requirement S1-1_21.

S1-2_02 _04_05

EYDAP SA has established various channels of communication, either directly with employees or with

their representatives, such as direct internal communication channels with the company that are

available to all employees, e.g. all users announcements, but also meetings and communication

between the employee unions of EYDAP SA (Federation of Employees of EYDAP SA) and the

management, staff appraisal and employee surveys.

310

Please see also requirement S1.MDR-P_01-06 _01_02_03_04_05_06 Commitment to respect third

party standards or initiatives for the ESS.

In order to achieve its objectives, the Federation negotiates to solve the problems of its members with

any competent body or person and ensures the drawing up of the Operational Collective Labour

Agreements. The Federation shall also participate actively in the Staff Councils, Disciplinary Councils

and any other body or body represented.

Finally, the Federation is represented by 2 members, who have voting rights, on the Board of Directors

of the Company.

The Company encourages open consultation between Management and employees on Health and

Safety issues, recognizing that their participation in the process is a fundamental human right, in

accordance with the relevant Human Rights Policy. Please see also requirement S1.SBM-

3_01_02_04_05_06_11_12 (Health and Safety)

EYDAP SA ensures cooperation with employee representatives also on human rights related issues,

allowing it to gain valuable insights into the views of the workforce. The agreement facilitates open

dialogue and cooperation, ensuring that employees' views and concerns are heard and taken into

account in decision-making processes.

Also, the obligations of the Head of each organisational unit, regardless of his/her position of

responsibility, include maintaining open channels of communication with the employees of his/her

organisational unit, creating a favourable environment for the development of dialogue. It is important

to have constant feedback and communication between colleagues and the Head of the organisational

unit concerned, so that we do not feel isolated from our physical working environment.

The General Directorate of Human Resources is responsible for informing employees and

implementing the Company's policies and practices regarding human resources. It ensures, through

the Facilities Division, that facilities are kept full, that employees' personal data is protected, that

secure employment is supported and that fair and adequate wages are guaranteed in accordance with

collective bargaining agreements.

In addition, the Corporate Culture & Internal Communication is also responsible for conducting the

employee survey, contributing to the recording of the views and needs of the Company's human

resources.

Finally, the responsibilities of the Corporate Culture & Internal Communication, is the development of

different internal communication channels, e.g. intranet, social media, print, digital signage screens,

e-mails, as the appropriate means of communication with employees, depending on the nature and

content of different circumstances and messages. "Our Source" is an internal channel of

communication with employees. On a weekly basis, it is sent in the form of a newsletter to the emails

of all employees, with informative content on Company news, existing policies, actions organized and

entertainment content. The work carried out by the Directorates and the employees is also presented

through articles and photographic material.

311

S1-2_03

Stages at which cooperation takes place, type of cooperation and frequency of cooperation

Table 31: Stages at which cooperation takes place, type of cooperation and frequency of cooperation

Type of cooperation

Stages

Frequency

Daily personal and email

updates

Communication and information

Daily

Inspections

Risk assessment and identification

Where appropriate

Via Intranet (thalassa)

Provision of information and

communications

Regularly

Trainings

Education and awareness raising

Where appropriate

and per semester

Participation in annual

workshops

Presentation and discussion of

issues

Annual

Weekly electronic magazine

"OUR SOURCE"

Information and dissemination of

information

Weekly

Participation in the

prioritisation process

Consultation and decision-making

Where appropriate

Voluntary actions

Involving and supporting local

communities

Where appropriate

Annual Sustainable

Development Report

Presentation of achievements and

objectives

Annual

Participation in Annual

Workshop

Discussion and information on

strategies and policies

Annual

S1-2_06

Evaluating the effectiveness of working with its own workforce

So far, there has been no mention or recording of specific procedures or practices that EYDAP SA

applies for the evaluation of its cooperation with its workforce. This may suggest that such procedures

are not currently in place or have not been notified for this context.

S1-2_07

Measures to obtain the views of people who may be particularly vulnerable to impacts and/or

marginalised

For people in its workforce who may be particularly vulnerable to impacts and/or marginalised, such

as women, migrants, people with disabilities, etc, appropriate measures are taken e.g. grievance

mechanism, reporting/complaints procedure to the Disciplinary Board Secretariat and initiation of

312

further disciplinary proceedings, reporting through the Liaison Reporting Person on incidents of

violence & harassment at work to the Review Committee on such incidents, satisfaction surveys etc.

The company provides accessibility to its services through the corporate website for visually impaired

people through specially designed services. It is also working on the possibility of serving the hearing

impaired (deaf/hard of hearing) through remote interpretation. Finally, it has proceeded with the

creation of audio files

of the Sustainable Development Report, ensuring equal access to information

for visually impaired and totally blind people.

The cultivation and establishment of a stable, modern and healthy corporate environment that will

promote the work of EYDAP SA and will be characterized by the principles of integrity, honesty and

regulatory compliance, is an obligation of all and a basic prerequisite for healthy business activity and

social cohesion and progress.

S1-2_10

Information on diversity and how to work with people at risk or in vulnerable situations

EYDAP SA in the context of inclusion implements pioneering actions:

1. Barrier-free accessibility for disabled people and people with disabilities. To facilitate and

protect people with disabilities are provided in accordance with existing legislation so that

they can move in a safe way:

- ramps for people and wheelchairs in 66% of the buildings

- parking spaces

- special lifts in 22% of the buildings

- sanitary facilities.

2. Working on the possibility of serving the hearing impaired

3. Accessibility to our services for visually impaired people through specially designed services

In the same consistent manner, our goal is to further improve the existing infrastructure and create

new ones, so that the building facilities become as disabled-friendly (employee-friendly) as possible,

in compliance with the existing provisions of the legislation.

S1-2_12

The company provides understandable and accessible information to its workforce through

appropriate communication channels.

The files are available on the corporate website eydap.gr in the section EYDAP-

SUSTAINABLE DEVELOPMENT EVIDENCE FOR WASTE.

313

The notification of circulars, benefits and procedures concerning the relevant workforce and mainly

the regular staff, such as the updating of the data of insured persons and beneficiaries of family

allowance and health care, the submission of applications for the provision of day care centres etc., is

done through announcements to all with clear and detailed instructions, through mail to all users and

by posting on the Company's internal portal.

S1-2_13

Settlement of conflicting workforce interests

EYDAP SA recognises that the concept of conflicts of interest refers to the differences that may arise

between employees due to diversity. However, so far, no such conflicts have arisen that affect the

Company's operations.

[S1-3] Procedures for the remediation of negative impacts and channels for raising concerns by the

workers concerned

S1-3_01

General approach and procedures for providing or contributing to remediation in cases of serious

adverse impacts and ways of assessing the effectiveness of the remediation provided.

EYDAP SA recognises the importance of the health and safety of its employees and is committed to

addressing any negative impacts that may arise. The Company's general approach includes the

systematic assessment of working conditions and safety procedures in order to identify and correct

any problems that may affect the health and safety of the workforce.

In cases where serious negative impacts arise, EYDAP SA is ready to provide remedies, which may

include medical support, rehabilitation and retraining programmes, as well as measures to improve

working conditions. The effectiveness of the remedies provided shall be evaluated through regular

employee satisfaction surveys and feedback, as well as through the monitoring of relevant health and

safety indicators.

EYDAP SA is committed to ensuring that its Policies remain flexible and adaptable to meet the needs

of employees and minimise negative impacts on their health and safety.

S1-3_02_05_06_07_08

Procedures and channels for raising concerns or needs and addressing them - Establishment of

channels by the company itself and/or through participation in third party mechanisms

Please see the requirements:

● S1-1_09,

314

● S1-1_10 _11_12_13 (Implementation of special procedures...and integration),

● S1-1_21

The Company takes all necessary measures through the Whistleblowing Policy to encourage

employees to express themselves freely, to react to reprehensible behaviour, to report without fear of

retaliation and to comply with the Company's policies. To this end, newsletters, e-mail, intranet,

training, website posting, meetings of the manager of the grievance system with staff are used.

The Training Directorate organises systematic training of staff on the internal mechanism for raising

concerns, while making it clear that no employee is subject to retaliation, discrimination or disciplinary

action for reporting reprehensible behaviour.

EYDAP SA also assesses the knowledge and confidence of employees in the reporting structures

through periodic surveys conducted by the Internal Audit Department. These surveys focus on

employees' perception of 'the ethical climate' and their knowledge of the framework of the concern

raising mechanism. In addition, data is collected on the satisfaction of employees who have used these

channels to ensure that the processes are effective and reliable.

The Compliance Division ensures that the human resources of EYDAP SA, regardless of their position

or status, are aware of the Reporting and Complaints Management Policy and the possibilities it

provides, through relevant training programmes.

Employee Complaints Management:

● The prescribed procedures for their resolution are followed, within the framework of the

Services of the Directorates.

● The submission of reports can be achieved by sending the report to the address 156 Oroposou,

111 46 Galati, EYDAP SA, by email to whistleblowing@eydap.gr or by using the online form on

the website of the organisation.

● In addition to written and electronic information for employees, training seminars have also

been provided.

Health Complaints Management & Health & Safety Complaints Management Employee Safety:

● Employees who consider that their work poses a risk to their safety may address both the ESRP

and their elected body, the Employee Health and Safety Committee, which is elected for this

purpose, and which respects, inter alia, anonymity, in order to avoid retaliation.

The Company ensures that the complaints procedure is accessible and understandable for all

employees. Reports are managed by the Compliance Department, which is responsible for the

implementation of the policy and the operation of the Reporting Mechanism.

Upon receipt of the report, the Compliance Directorate immediately contacts the person who

submitted the report, informing him/her that the report has been received, provided that it was

315

submitted in his/her name. Reports shall be assessed by a special committee with due diligence,

confidentiality and objectivity.

S1-3_09

The protection of individuals from retaliation including workers' representatives

Any discriminatory act against an employee who raises concerns or against an employee who assists

in the investigation or any act that may discourage other employees from raising concerns is not

tolerated by EYDAP SA and will result in disciplinary action, in accordance with the provisions of the

Company's Personnel Regulation. Specifically, through the Whistleblowing Policy, Whistleblowers who

selflessly and "in good faith" made a report - complaint, are entitled to protection if at the time of

reporting they had reasonable grounds to believe that the information regarding the reported

violations is true and falls within the scope of the said Policy. The protection applies to natural persons

of any status who are likely to make a report.

Protection is still provided:

● to persons who assisted in the investigation of the disclosure because they were required to

do so by virtue of their authority and position or in the performance of their duties.

● persons whose employment relationship has ended and candidates for employment or other

forms of cooperation who have obtained information about violations during their

employment or during the recruitment process, and who could be subject to retaliation, for

example in the form of negative professional recommendations, blacklisting or boycotting

companies.

In addition, EYDAP SA, in the framework of the Policy for the prevention and combating of violence

and harassment at work, is committed to:

● all persons who make an internal complaint or facilitate its investigation will not be subject to

retaliation (including intimidation, threats, unfair treatment, demotion or deprivation of

promotion, marginalisation, diversion of functions).

● the termination or termination in any way of the legal relationship on which the employment

is based and any other adverse treatment of the person concerned shall be prohibited and

shall be null and void if it constitutes retaliatory behaviour or a countermeasure for incidents

of violence and harassment.

316

[S1-4] Taking action on significant impacts on the relevant workforce and approaches to manage

significant risks in relation to the relevant workforce and the effectiveness of these actions

S1.MDR-A_01-12

The summary description of the action plans and resources to manage the significant impacts and risks

associated with the EYDAP SA workforce is as follows:

Health & Employee Safety

EYDAP SA makes every effort to ensure the physical and mental health of its staff, through its Health

and Safety Policy, which has been implemented since 2014. Prevention (ES.Y.P.P.), which is a direct

advisor to the Management on health and safety issues. The tasks and responsibilities of the ESHEP

include, among others:

● Compliance with legislative requirements, standards and internal guidelines.

● Transparent communication with all stakeholders to identify and address potential risks as

soon as possible

● Continuous efforts to strengthen the culture of health and safety at work, through messaging,

continuous and targeted training of all employees.

● The preparation of a Written Occupational Risk Assessment for each job performed.

● The measurement of harmful factors in the workplace.

● The drafting of specifications for Personal Protective Equipment (PPE) & Personal Protective

Equipment (PPE).

● The recording and investigation of accidents at work, as well as near misses, with a view to

taking preventive action

● The issue by the Occupational Physicians of a Certificate of Fitness to each worker depending

on the job.

● The development of a vaccination programme for employees.

● Continuous training of employees on health & safety issues

Privacy

● EYDAP SA protects the personal data of its employees with technical and organisational

security measures.

● There are clear procedures for informing employees about the processing of their data.

● EYDAP SA is in the process of obtaining an insurance policy to cover itself against a cyber

security incident, which is expected to be completed within 2025. EYDAP SA has obtained

PCI/DSS certification for the protection of payment card holder data (such as credit and debit

cards).

317

● Training of employees on the Policies related to the protection of personal data.

Secure Employment Jobs

● EYDAP SA applies what is defined by labour legislation and works systematically to meet every

requirement

● In 2024, there were no complaints of any violation of the Labour Law and no incidents were

recorded concerning the non-payment of required overtime, or the non-payment of statutory

wages or inconsistency in the observance of the required insurance coverage.

● Please see requirement S1.SBM-3_01 _02_04_05_06_11_12 - Secure Employment - ("EYDAP

SA applies what is defined by the labour legislation ... of the Labour Inspectorate were

completed immediately").

Adequate Wages

● All employees are paid equally, varying only according to qualifications, years of service, job

scope and position of responsibility, if held; with pay resulting from the Operational Collective

Agreements.

Employees receive information in paper or electronic form through their pay slips and have

the right to request and receive clarification on their pay.

S1.MDR-A_01 & S1-4_02

Health and Safety

Key Actions

Compliance with the Health and Safety policy is ensured through a single management system, which

is implemented by ESYPP, in accordance with the ISO 9001:2015 "Quality Management System" and

ISO 45001:2018 "Occupational Health and Safety" standards.

During the reporting year, specific actions have been taken, such as training employees to identify and

prevent risks, providing protective equipment and conducting regular safety checks. For the future,

additional actions are planned, such as upgrading safety procedures and strengthening communication

on H&S issues, to ensure continuous improvement of employee safety and health.

Please see also requirement S1.MDR-P_01-06 _01_02_03_04_05_06.

Expected Results

During 2024, the ESYPF once again successfully obtained the relevant certification for its management

system from an accredited body.

EYDAP SA's Health and Safety initiatives aim to reduce accidents and injuries. This is achieved by

improving safety procedures, investigating the causes of accidents, implementing corrective actions

and disseminating good practices across all units.

318

How the implementation of the actions contributes to the achievement of the objectives and aims of

the policy

During 2024, there was a slight decrease in the number of occupational accidents and no fatal

occupational accidents, but the desired goal of zero occupational accidents was not achieved.

Furthermore, there has been an increased, in general, interest on the part of employees in issues

related to H&S, as shown by the participation rates in the annual training seminars organised by ESYPF.

Privacy

Key Actions

EYDAP SA, through its Employee Data Protection Policy, informs its employees about the processing

of their data by the Company.

Please see the requirements:

● S1.SBM-3_01 _02_04_05_06_11_12

● S1.MDR-P_01-06 _01_02_03_04_05_06

EYDAP SA in the context of compliance with the national and international regulatory and legal

cybersecurity framework (NIS2, ISO27001, NIST CSF, CIS Controls, GDPR) forms an Integrated Security

Management Framework based on these and taking into account the protection of personal data, as

it is only one aspect of the overall information security

In addition, the insurance policy against a cyber security incident, which is expected to be completed

within 2025, covers all personal data stored within the digital databases of EYDAP SA.Under the above

policy, only the digital data stored in the information systems of EYDAP SA are protected. The insurance

contract does not apply in the event that someone from the General Customer Directorate discloses

in writing or orally personal data of a customer or if in any way in the context of an action EYDAP SA

does not comply with the provisions of GDPR.

Finally, EYDAP SA has received PCI/DSS certification for the protection of payment card holders' data

(such as credit and debit cards).

Expected Results

In order to maintain the continuous compliance of EYDAP SA with Regulation (EU) 2016/679, the

employees themselves, at the beginning of their employment relationship and thereafter, whenever

the need arises due to a change in their job duties, will sign relevant confidentiality circulars and

compliance with the Company's procedures regarding the protection of personal data, in general,

within the Company, both consumers and employees.

Through the procedures the following should be observed:

319

● Prevent unauthorised persons from gaining access to the data processing systems through

which personal data are processed or used (physical access control).

● Ensure that data processing systems cannot be used by unauthorised persons (access denial

control).

● Ensure that persons authorised to use the data processing systems have access only to the

data for which they have been authorised and that personal data cannot, during processing or

use or after their recording, be read, copied, changed or moved by unauthorised persons (data

access control).

● Ensure that, during the electronic transmission or during the transfer or recording of data,

personal data cannot be read, copied, changed or moved by an unauthorised person, and that

it will be possible to examine and verify whether personal data have been transmitted by

means of data transmission equipment.

● Ensure that it is possible to retrospectively examine and verify whether and by whom personal

data were entered into the data processing systems, and whether they have been changed or

moved.

● Ensure that personal data processed by subcontractors are only processed in accordance with

the employer's instructions (subcontractor control).

● Ensure that personal data is protected against accidental destruction or loss (availability

check).

By reading the policy/information statement, the employee has become aware of the processing that

is in accordance with Regulation 2016/679 and its recitals, exclusively for the purposes mentioned

above and for purposes compatible with them. Finally, through the insurance policy, EYDAP SA aims to

enhance data security and minimize legal and regulatory sanctions, but also through PCI/DSS

certification to ensure the improvement of operational processes and the implementation of strict

security standards.

How the implementation of the actions contributes to the achievement of the objectives and aims of

the policy

EYDAP SA takes measures to protect personal data and comply with the GDPR Regulation and other

security standards. With access controls and staff training, it enhances data security. In addition,

PCI/DSS certification and cybersecurity insurance help reduce the risk of a breach. This achieves the

objectives of the above Policy, ensuring confidentiality and compliance.

Secure jobs

Key Actions

EYDAP SA provides its employees and its executives with working conditions that are consistent with

its operation and related to the respective duties of each employee.

Please see also requirement: S1-1_03_04_05_06_07 & S1.MDR-P_04 (Measures that provide and/or

enable remediation of human rights impacts).

The recruitment process is based on a clear definition of formal & substantive qualifications and

objective criteria through the Supreme Personnel Selection Board (SSC). New employees of the

320

Company are hired on a contract of indefinite duration and receive the remuneration and all benefits

provided for by the legislation, the Personnel Regulation of EYDAP SA (P.R./EYDAP SA), the decisions

of the Board of Directors (BoD) and circulars.

Expected Results

EYDAP SA applies what is defined by the labour legislation and there was no complaint for violation of

the Labour Law in 2024.

Compliance with the laws and actions to comply with labour legislation help to create a safe and fair

working environment, enhancing employee confidence and the company's credibility, thus

strengthening the sense of commitment and loyalty to the company.

Please see also the requirement: S1.SBM-3_01 02_04_05_06_11_12 & S1.MDR-A_01-12 - Secure

Employment.

How the implementation of the actions contributes to the achievement of the objectives and aims of

the policy

Please see requirement S1.MDR-A_01-12 - Secure Employment ("In 2024, there were no complaints

of violations of Labor Law ... insurance coverage").

Please see requirement S1.SBM-3_01_02_04_04_05_06_11_12 - Secure Employment - ("EYDAP SA

applies all the provisions of the labour legislation for the health and safety of employees with only

violations recorded in 2024 ... of the Labour Inspectorate were completed immediately").

The implementation of EYDAP SA's actions contributes to the achievement of the objectives by

ensuring a safe and fair working environment. The lack of complaints for violations of labour legislation

shows that compliance procedures are working well, providing safety to employees. Transparency and

the possibility to file complaints through whistleblowing channels enhance trust and a sense of

fairness. All of these actions help maintain employee satisfaction and engagement in the business.

Adequate wages

Key Actions and how the implementation of the actions contributes to the achievement of the

objectives and aims of the policy

Employees receive information in paper or electronic form of their payroll receipts and have the right

to request and receive clarification on their pay.

Please see the requirements:

● S1.MDR-P_01-06 _01_02_03_04_05_06

● S1.SBM-3_01 _02_04_05_06_11_12.

Expected Results

The uniform salary policy applied in the company has positive results, such as:

• Employees' satisfaction with their pay

321

• No difference in pay between permanent workers, regardless of gender.

• Transparency in the payroll process.

• Strengthening employee commitment to the company.

322

S1.MDR-A_02

Health and Safety

Scope of

Please see requirement S1.MDR-P_01-06_01_02_03_04_05_06 for the Health and Safety Policy.

Privacy

Scope of

EYDAP SA is committed to protecting the personal data of its employees and customers by

implementing policies that comply with the GDPR. These include all data processing activities and

affect employees, consumers and partners.

Secure jobs

Scope of

EYDAP SA implements actions to ensure safe working conditions, covering all employees in all facilities.

The actions include training, safety procedures and equipment to protect workers.

Adequate wages

Scope of

EYDAP SA ensures the provision of adequate salaries in accordance with the applicable legislation and

contracts. This commitment covers all employees, with the aim of maintaining their sustainability and

supporting their well-being.

S1.MDR-A_03

Health and Safety - Privacy - Secure jobs

Time horizon of key actions

Actions to achieve the objectives are carried out on a continuous basis as corrective actions, upgrades

of facilities and applications, related training, implementation of the requirements set out in these

Policies and others are regularly and continuously carried out.

Adequate wages

Time horizon of key actions

Any new legislative framework or amendment of the existing one concerning the remuneration of

employees to ensure that they are paid adequate wages is implemented immediately and adhered to

on an ongoing basis.

S1.MDR-A_04

323

EYDAP SA is committed to implementing policies that ensure the welfare and safety of its employees.

In the context of the implementation of strategies to achieve environmental objectives, some negative

impacts on the health and safety of the workforce have arisen. The company recognises these impacts

and is actively working to anticipate and address them through the implementation of enhanced

preventive actions, measures and upgrading of safety procedures. In cases where the health and safety

of employees have been affected, EYDAP SA will take appropriate remedial actions, offering support

and redress for affected employees in accordance with internal policies and international agreements.

S1.MDR-A_05

Progress of actions or action plans notified in previous periods

Health and Safety

Mission 2025

EYDAP SA monitors its progress towards the targets set for employee safety, such as reducing

occupational accidents and ensuring zero fatalities.

Two key performance indicators (KPIs) are primarily used to assess progress in terms of worker health

and safety by the ESSP, (a) the impact indicator, which is defined as the ratio of the number of accidents

at work to the total number of declared working hours in the company, and (b) the severity indicator,

which is defined as the ratio of the total number of days of absence of workers to the total number of

accidents at work to which these absences are attributable.

Key Performance Indicators (KPIs) are used to monitor progress

Target 2025

2022

(base year)

2023

2024

2025 target

Impact indicator

0,656

0,57

0,53

Severity indicator

24,68

59,14

46.92

Privacy

EYDAP SA conducts updates and trainings on personal data protection, focusing on compliance with

the GDPR Regulation and ensuring data security for all stakeholders.

No key performance indicator (KPI) is used to monitor progress.

Please see also requirement S1.MDR-A_01 & S1-4_02.

Secure jobs

EYDAP SA aims to improve working conditions and reduce dangerous incidents.

No key performance indicator (KPI) is used to monitor progress.

324

Please see also requirement S1.MDR-A_01 & S1-4_02.

Adequate wages

EYDAP SA ensures that there are no differences in remuneration due to gender discrimination.

No key performance indicator (KPI) is used to monitor progress towards the target.

Please see the requirements:

● S1.MDR-P_01-06 _01_02_03_04_05_06

● S1.SBM-3_01 _02_04_05_06_11_12

● S1.MDR-A_01 & S1-4_02.

S1.MDR-A_06 _07_09_10_11_12

Financial resources and implementation of action plans.

EYDAP SA takes into account the importance of adequate resources for the successful implementation

of its action plans. In this context, it is in the process of allocating and planning both existing and future

financial and other resources required. Capital (CapEx) and operating (OpEx) expenditures are directly

linked to the significant amounts presented in the company's financial statements, and financial

instruments such as green and social bonds are also being considered. Implementation of actions may

be contingent on specific conditions, such as developments in public policy or securing financial

support, ensuring the sustainability and effectiveness of the Company's initiatives.

S1-4_01_05

Actions to prevent and mitigate impacts on the workforce.

Some of the company's procedures regarding health and safety, safe workplaces, adequate wages and

employee privacy are:

● Compliance with labour legislation and the Company's Collective Labour Agreements on pay

and benefits for the employees covered by them

● The staffing of the Health Care Service with doctors of many specialties e.g. psychiatrist,

general practitioner, pathologists, orthopedist etc.

● The protection of the personal data of all employees by adhering to Policies and in particular

those who make a complaint/report on issues about which they wish to express a complaint

or rights violation or issues of harassment and violence at work.

● The Company's regular staff enjoys the security of their employment as they have an

employment contract for an indefinite period of time and their selection was made through

the procedures of the Supreme Personnel Selection Council (ASEP).

325

Actions to achieve a positive impact on the workforce.

A satisfaction survey is carried out with the completion of questionnaires by employees leaving for

retirement. In addition, monitoring of the KPIs set for employees is carried out, concerning the

reduction of accidents at work and lost working time due to them, increasing the hours of training for

all employees on issues related to health and safety at work, information on compliance with policies

and procedures, on technical issues and on issues related to personal development that contribute to

the well-being of employees.

S1-4_06

Actions to mitigate significant risks from the workforce

Please see the requirements:

● S1.SBM-3_01 _02_04_05_06_11_12

● S1.MDR-A_01

EYDAP SA takes care of:

● Strengthening Employee Support Policies such as the Policy on Combating Violence &

Harassment at Work

● Creation of Opportunities for Development and Innovation such as the system of internal

advertisements for the staffing of positions of responsibility in the Company's Organization

Chart

● Annual monitoring and Performance Evaluation of regular staff through the Crisis Sheets

● Health and Safety by adhering to a specific Policy whose effectiveness is monitored in practice,

through a single management system implemented by ESYPP, in compliance with ISO

9001:2015 (Quality Management System) and ISO 45001:2018 (Occupational Health and

Safety).

● EYDAP SA plans to implement a project for the creation of an Integrated Information System

for the governance and utilization of its corporate data in order to support decision making

and value creation from them. This integrated system will be centred on the Enterprise Data

Lakehouse (EDLH). The EDLH will support the provision, to any interested corporate user, of

data whose quality will be expressed and assessed in terms of validity, accuracy, availability,

completeness and democratisation of data across all addresses.

S1-4_07

Actions to exploit significant opportunities from the workforce.

326

The company implements a comprehensive cybersecurity risk management framework through threat

identification assessments and mitigation of operational impacts on the organization's activities and

operations.

At the same time, the Cybersecurity Directorate has implemented staff training programmes to

promote a cybersecurity culture. Finally, partnerships with cybersecurity bodies (NSAs, CSIRT, ENISA)

are being promoted to exchange critical security information related to incidents.

It also takes appropriate technical protection measures, such as:

• Network Intrusion Detection and Prevention Systems (IDS/IPS) for monitoring and analysing

network traffic.

• Use of firewalls with corresponding network and application level access control settings (Web

Application Firewall - WAF).

• System of uninterrupted surveillance and incident and breach detection (SOC/SIEM) for

continuous surveillance and automatic notification in case of detection of threats and/or breaches.

• Implementation of an EDR (Endpoint Detection & Response) and IT resource management (ITAM)

solution.

S1-4_08

Tension management and mitigation

The ESRP ensures medical confidentiality, as well as other personal data of employees that comes to

its attention (e.g. for the issuance of fitness certificates, following the procedures foreseen by its single

management system.

S1-4_09

Resources to manage significant impacts.

The financial and technological resources used are salaries, allowances, amounts paid for employee

insurance, amounts paid for software and tools, the management of salaries & allowances and training

programmes.

Human resources refer to the organisational teams, administrative bodies involved in the management

of the subject.

Time resources: training hours.

S1-4_16

The role of workforce and representatives in decisions to design and implement processes.

327

The Collective Labour Agreements, the Policies applied in the Company and their revision result either

from negotiation or from the elaboration and submission of proposals and opinions by the collective

body of the employees, the Employees' Federation

Please see also requirement S1-2_02 _04_05 for the Employee Federation.

S1-4_17

Information on positive results of labour procedures

The achieved positive results of these procedures are:

● industrial peace

● security in relation to jobs

● employee satisfaction with their pay.

S1-4_19

Measures to manage the negative impact on the workforce

1. Staff training and retraining [Job security]

o EYDAP SA can offer training programmes on new water management technologies,

such as smart grids, leak detection with artificial intelligence and energy efficient

installations.

o In addition, training programmes could cover environmental management, renewable

energy and sustainable waste management practices.

2. Employment guarantees and alternative placements

o In case of restructuring of operations due to digitalisation or automation, EYDAP SA

may implement a plan to reallocate employees to new positions, such as in green

infrastructure maintenance and energy resource management.

o Developing internal internal mobility programmes to deploy staff in new roles.

Compliance with regulatory frameworks

EYDAP SA complies with various regulatory frameworks and strategies to ensure sustainability and

environmental responsibility such as

● European Green Deal: adopts measures to reduce greenhouse gas emissions and promote

climate neutrality by 2050.

● ESRS (European Sustainability Reporting Standards): follows European sustainability

reporting standards to ensure transparency and accuracy in its reporting.

328

● CSRD (Corporate Sustainability Reporting Directive): complies with the Corporate

Sustainability Reporting Directive by providing detailed information on its environmental and

social performance.

The Office of Strategy and Regulatory Affairs (OSRTH), in cooperation with the Regulatory Compliance

Directorate, maintains a website with the current regulatory framework, while the OSRTH also

maintains an advocacy calendar.

These actions help EYDAP SA to ensure sustainability and environmental responsibility in its business

activities.

External Developments

1. New Environmental Legislation: stricter legislation is being imposed and adopted at European

and international level to control and ensure the quality and management of water and

wastewater, reduce CO₂ emissions and protect water resources.

2. Technological changes: the development of smart water networks and automated water

quality control systems continues at a rapid pace, requiring skilled technological staff and

investment in new technologies.

3. Change in Consumer Requirements: Growing demand for environmentally friendly water

supply, recycling and reuse solutions is on the rise, with consumers demanding sustainable

and efficient solutions.

Potential Risks

1. Regulatory Risks: The continuous evolution of environmental regulations increases

compliance requirements and will impose additional costs.

2. Technological Risks: Technological changes may bring risks, such as cyber-attacks and an

urgent need for continuous training and technological expertise of employees.

3. Financial Risks: Changes in economic conditions and market uncertainty can affect the

financing possibilities and sustainability of investments.

329

Measurement indicators and targets

[S1-5] Objectives related to managing significant negative impacts, promoting positive impacts and

managing significant risks

S1-5_01

Goal setting process and working with the workforce.

Health and Safety

EYDAP SA cooperates with the representatives of the employees and the relevant trade unions to:

● Defining and updating safety protocols, in particular for workers in sewerage, water treatment

plants, pumping stations and mobile crews carrying out maintenance-repair work on

networks.

● Continuous education and training on safe working practices, accident prevention and

emergency management.

● Preventing occupational diseases by carrying out regular medical checks and implementing

measures to reduce exposure to chemical or physical hazards.

Employee participation:

● Through the Employee Health and Safety Committee (EHSC), employees can make suggestions

and evaluate existing policies.

● Regular consultations are also held with the unions to strengthen safety protocols.

Secure jobs

The company develops social initiatives to support employees and their families, such as:

● Benefits for parents: Maternity/paternity leave, flexible working hours and support for

employees with family responsibilities.

● Psychological support and well-being: Access to mental health counselling and wellness

programmes.

● Social responsibility programmes: Support for employees facing financial difficulties or

emergencies.

Employee participation:

● Dialogue with workers' representatives on the extension of social benefits.

● Collecting suggestions through internal surveys to improve social care programmes.

330

Adequate Wages

EYDAP SA ensures that the remuneration of its employees:

● They are in line with the minimum thresholds for decent living standards, as defined by

national and European standards.

● They shall be revised on the basis of inflation and the cost of living to reflect the real needs of

workers.

● They include additional benefits such as insurance coverage and allowances.

Employee participation:

● Collective bargaining with unions to ensure fair pay.

● Consultation with staff committees on the review of salary policy.

Privacy

The company has put in place strict protocols to protect the personal data of employees:

● Compliance with GDPR (General Data Protection Regulation) for the management of sensitive

information.

● Restrict access to personal data to authorised personnel only.

● Staff training on cybersecurity and data protection.

Employee participation:

● Organising seminars on privacy rights at work.

● Collaboration with staff committees to monitor the implementation of data protection

policies.

S1-5_02

Goal setting process and performance monitoring with the workforce

Please see also requirement S1.MDR-P_01-06_01_02_03_04_05_06.

In order to achieve the desired goal of zero accidents at work, meetings are held at regular intervals,

at the initiative of the Management, in which, apart from the NSYPP, the Health and Safety Committee

(HSSC), the elected body set up by law by the employees for this purpose, also participates.

331

S1-5_03

Process of setting goals and identifying lessons or improvements from performance.

Please see also requirement S1-1_09.

In the event of an accident at work, the Employees' Health and Safety Committee (EHSC) also

contributes with its views in order to prevent similar incidents from happening again.

S1-5_04

The company's desired goal, in terms of Health & Safety of employees is zero number of accidents at

work.

S1.MDR-T_14-19

Setting objectives

Based on the strategy of EYDAP SA, the priorities for the Company are:

● Ensuring a fair and dynamic working environment / working conditions

● The creation of new jobs/ Contribution to employment

● Improving the level of the services we offer

● Access to a living wage

● Data privacy

Furthermore, EYDAP SA recognises that managing health and safety impacts requires continuous

monitoring and adjustment of our strategies. The Company will continue to assess employee needs

and adapt its policies to ensure that employees have the support and resources they need to address

the challenges that arise.

α) Intention to set targets & timetable

The company aims to set measurable targets in the coming years, through cooperation with

employees, trade unions and other stakeholders. The aim is to develop a comprehensive monitoring

and evaluation framework on key labour policy issues. However, to monitor the effectiveness of

policies and actions, the Company has not currently set a precise measurable target, nor a specific key

indicator to monitor it.

Indicative timetable:

● 2024: Analysis of existing policies and consultation of workers

● 2025: Set measurable targets and implement monitoring mechanisms

● 2026: First annual progress assessment

332

b) Monitoring the effectiveness of policies & actions

1. Health & Safety

The company implements monitoring mechanisms to reduce accidents and promote safe work.

● Regular checks for compliance with safety standards

● Collection of reports on accidents and dangerous occurrences

● Training programmes for occupational risk prevention

2. Secure jobs

The company promotes initiatives to support employees and their families with:

● Employee satisfaction surveys

● Feedback through social policy committees

● Evaluation of the use of social benefits

3. Adequate Wages

The company shall ensure that remuneration meets the standards of decent living by:

● Comparative analysis of wages against the average cost of living

● Consultations with trade unions

● Recording of workers' requests for salary adjustments

4. Privacy

The company protects the personal data of employees by:

● Regular compliance checks

● Training programmes on GDPR and cybersecurity

● Data breach logging mechanisms

In 2024, there were 2 notifications of violations to the APA, one of which was closed. The Company

has not received any fines to date.

333

[S1-6] Characteristics of the company's employees

S1-6_01-06

Disclosure of total number of employees and breakdowns by gender and country.

Table 34. Template for the presentation of information on the number of employees by gender

Sex

Number of employees (total number of employees)

2024

2023

2022

Men

1.743

1.583

1.654

Women

751

768

Total employees

2.848

2.422

2.334

The year 2024 includes permanent workers, outsourced workers and workers with a service voucher.

Table9 5. Template for the 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.

Sex

Number of employees (total number of employees)

2024

2023

2022

Greece

2.848

2.422

2.334

The year 2024 includes permanent workers, outsourced workers and workers with a service voucher.

334

S1-6_07 _18

Table 36. Template for the presentation of information on employees by type of contract, broken down by gender (total staff or FTE) - (reporting on full-time and part-time

employees is optional)

2024

2023

2022

Men

Women

Othe

Not

disclosed

Total

Men

Wome

Othe

Not

disclos

Total

Men

Women

Other

Not

disclose

Total

Greece

Number of

employees (total

employees/FTE)

1.743

1.105

2.848

1.583

751

2.334

1.654

768

2.442

Number of

permanent

employees (total

employees/FTE)

1.470

715

2.185

1.558

730

2.288

1.604

724

2.328

Number of

temporary agents

(total

employees/FTE)

Number of full-time

employees (total

employees/FTE)

1.743

1.105

2.848

1583

751

2334

The number of employees was calculated at 31.12.2024 , applying the "headcount" methodology.

335

The year 2024 includes permanent workers, outsourced workers and workers with a service voucher.

336

S1-6_08-10 _18

Table10 7. Template for the presentation of information on employees by type of contract, broken down by region (total staff or

FTE) (reporting on full-time and part-time employees is optional)

1) In the year 2024 the number of employees includes regular staff (2,185), outsourced employees for administrative

support of services (553) and rationed employees (110).

2) In 2024 there were no temporary workers.

S1-6_11-12

There is an increase in the number of departures of regular staff as, as provided for in the 2024-2027 NPSA in force

from May 2024, those who reach the age of 67 and are entitled to receive a full main pension, the Company has the

right to terminate their dependent employment contracts.

Table 38. Number of employees who left the Company and percentage of turnover

2024

2023

2022

2024

2023

2022

Attica

Fokida,

Boeotia &

Aitoloaka

rnania

Total

Attica

Fokida,

Boeotia &

Aitoloakarn

ania

Total

Attica

Fokida,

Boeotia &

Aitoloakarn

ania

Total

Number of

employees (total

employees/FTE)

2.724

124

2.848

2.222

112

2.334

2.306

116

2.422

Number of

permanent

employees (total

employees/FTE)

2.066

119

2.185

2.176

112

2.288

2.212

116

2.328

Number of

temporary agents

(total

employees/FTE)

551

553

Number of

employees with

non-guaranteed

working hours

(total

employees/FTE)

Number of full-

time employees

(total

employees/FTE)

2.724

124

2.848

2.222

112

2.334

2.306

116

2.422

Number of part-

time employees

(total

employees/FTE)

337

Number of employees

who left

160

Employee mobility rate

7,32%

4,23%

2,83%

S1-6_13-15

The assumptions used relate to the type of employees for which figures are given. Specifically, for 2024, permanent

employees, outsourced employees and employees with a service voucher are included. The headcount method was

used and the data refer to 31/12/2024.

S1-6_16

Comparative figures are given in relation to previous years e.g. Table 34, 35. There is no data on the variation in the

number of employees during the reporting period as the headcount method has been used as at 31/12/2024

S1-6_17

Linking Information to Financial Statements

The same reference will be made in the financial statements.

[S1-7] Characteristics of non-salaried employees in the workforce of the enterprise itself

S1-7_01-03

Number of non-salaried employees in the Company.

Table 39. Number of non-salaried employees in the labour force of the enterprise Number of employees/FTE

2024

2023

Number of non-salaried

workers

Men

Women

Total

Men

Women

Total

110

Number of employees

provided by enterprises

principally engaged in

'employment activities'

(NACE N78)

230

323

553

202

294

496

S1-7_05

Types of non-salaried employees and their relationship with the Company and the type of work they perform

The most common types of non-employees employed by the company are self-employed persons and persons supplied

by companies that are primarily engaged in employment activities and the type of work they do is mainly administrative

support and research positions e.g. R&D.

338

S1-7_06-08

Explanation of methodologies and assumptions for non-salaried employees

The number of non-salaried employees is reported as total employees or full-time equivalent, the headcount method

was used and the data refer to 31/12/2024.

S1-7_09

Wider Framework Information for Non-Employed Workers

There is no data on the variation in the number of non-salaried employees during the reporting period as the headcount

method has been used as at 31/12/2024.

[S1-9] Diversity measurement indicators

S1-9_01-02

Table 40 Distribution of top management by gender

2024

Men

Women

Senior

management

S1-9_03-05

Table 41 Distribution of employees by age group

2024

<30

30-50

>50

Number of

employees (#)

501

1681

Percentage of

employees (%)

0,14

22,93

76,93

339

[S1-10] Adequate wages

S1-10_01

Notification of adequate employee salary.

The salaries of EYDAP SA employees are derived from the Operational Collective Labour Agreements, as well as from

circulars and decisions of the Board of Directors. Employees are remunerated equally without any segregation or

discrimination, with remuneration varying only according to their qualifications, years of service, job scope and position

of responsibility, if held.

In 2024, a new three-year Collective Operating Agreement was concluded between the Company and the trade unions

of its employees, with which additional salary regulations and benefits came into force.

[S1-11] Social protection

S1-11_01-05 & 07-10

Employee social protection notification and coverage of major life events.

EYDAP SA initiative for permanent staff on family protection.

Please see requirement S1.MDR-P_01-06_01_02_03_04_05_06 (BUSINESS COLLECTIVE EMPLOYMENT CONTRACTS).

Benefits for permanent employees

The smooth and modern operation of the Company requires personnel of high educational level and specialized

training. The Company, in addition to the statutory employee benefits, has also established:

● Health Service, which provides primary health care services to workers and their insured family members and

manages their medical and pharmaceutical coverage.

● 9 months' paid parental leave instead of the reduced working hours provided by law.

● Private insurance for employees and children.

● In the event of an accident at work, the worker receives his/her remuneration for the entire period of absence.

● Pension insurance for doctors, engineers and lawyers (upon request).

● A lump sum is provided for under the remuneration scheme, which is taken upon the employee's retirement

from the company.

[S1-14] Health and safety measurement indicators

S1-14_01

2024

2023

2022

Employees**

Unpaid

workers

Employees**

Unpaid

workers

Employees**

Unpaid

workers

Number of

employees**

and non-

employees of

the Company

covered by a

health and

safety system

2.185

2.291

2.333

340

Table 42.11

Percentage of

persons covered

by a health and

safety

management

system based on

legal

requirements and/or recognised standards or guidelines

**Non-employed employees (employees through an external partner) and "self-employed" i.e. employees with service

vouchers are not covered by the Group's Health System. The figures refer only to regular staff.

The Health and Safety Policy of EYDAP SA applies to all employees of EYDAP SA's facilities without exception, regardless

of the employment relationship under which they are employed.

S1-14_02-03_04-05

Table 43. Number of deaths of employees and non-employees of the Company due to work-related injuries and health problems

2024

2023

2022

Employees

Unpaid

workers

Employees

Unpaid

workers

Employees

Unpaid

workers

Number of deaths of

employees and non-

employees of the

Company due to work-

related injuries and

health problems

n/a

The results of the table refer to all employees (permanent employees, part-time cleaning contractors and 8-month

contract employees) with an employment contract, in which EYDAP SA is designated as the employer.

Accidents involving contractor personnel are excluded from the count, as they are counted against employers with

whom these workers have contracts attached.

Percentage of

employees**

and non-

employees of

the Company

covered by a

health and

safety system

100%

2024

2023

2022

Employees

Unpaid

workers

Employees

Unpaid

workers

Employees

Unpaid workers

Number of recorded

occupational

accidents of

employees and non-

employees of the

Group (#)

n/a

Percentage of

recorded

occupational

accidents of

employees and non-

n/a

341

Table 44.

Number and percentage of recorded accidents at work

S1-14_06

Table 45. Number of cases of recorded work-related diseases subject to legal restrictions on data collection

2024

2023

2022

Employees

Unpaid

workers

Employees

Unpaid

workers

Employees

Unpaid

workers

Number of cases of

recorded work-related

health problems

(employees)

n/a

S1-14_07

Table 46. Number of days lost due to occupational injuries and deaths from accidents at work

2024

2023

2022

Employees

Unpaid

workers

Employees

Unpaid

workers

Employees

Unpaid

workers

Number of working days

lost due to injuries and

deaths from accidents

at work (employees)

610

n/a

1.343

n/a

430

n/a

S1-14_08-09

Table 47. Number of cases of recorded work-related health problems, subject to legal restrictions on data collection & Number of

working days lost due to injuries and deaths from work-related accidents, work-related health problems and deaths due to health

problems

Employees

Unpaid workers

2024

2023

2022

2024

2023

2022

Number of

cases of

recorded work-

related health

problems,

subject to legal

restrictions on

data collection

(#)

n/a

employees of the

Group (%)

342

Number of

working days

lost due to

injuries and

deaths from

work-related

injuries and

deaths from

work-related

accidents,

work-related

health

problems and

deaths due to

health

problems (#)

610

n/a

S1-14_10

Table 48. Percentage of its employees covered by a health and safety management system based on legal requirements and/or

recognised standards or guidelines and which has been audited internally and/or audited or certified by an external body

Employees

2024

2023

2022

The percentage of its

employees covered by a

health and safety

management system

based on legal

requirements and/or

recognised standards or

guidelines. (%)

100%

The percentage of its

employees covered by a

health and safety

management system

based on legal

requirements and/or

recognised standards or

guidelines that has

been internally audited

and/or reviewed (%)

100%

The percentage of its

employees covered by a

health and safety

management system

based on legal

requirements and/or

recognised standards or

guidelines and which

has been audited

internally and/or

100%

343

audited or certified by

an external body (%)

S1-14_11

Notification of health and safety management system audit and certification.

Compliance with the H&S policy is ensured through a single management system, which is implemented by ESYPP, in

accordance with ISO 9001:2015 as well as ISO 45001:2018 "Occupational Health and Safety - Quality Management

System". The management system of ESYPF is subject to both internal audit and external inspection by an accredited

body at regular intervals.

Please see requirement S1.MDR-A_01.

S1-14_12

Disclosure of work-related health problems identified during the reporting period among persons formerly in the

enterprise's workforce.

So far, there is no occupational disease confirmed by the NHS.

344

[S1-16] Compensation measurement indicators (wage gap and total compensation)

S1-16_01

Table 49. Wage gap by gender

2024

2023

2022

Men

Women

Men

Women

Men

Women

Percentage

pay gap by

gender

Employees are paid equally without distinction or discrimination, with pay differentiated only according to

qualifications, years of service, job description and position of responsibility, if held, and no gender or age

differentiation in basic pay and allowances.

The salaries of the regular staff of EYDAP SA are clearly defined through the Operational Collective Labour Agreements

between the Company's Management and the relevant trade union representatives.

There is no question of wage inequality or discrimination between men and women in the ESS and consequently. The

gender pay gap rate is zero (0%).

S1-16_02

Table 50. Annual total remuneration index

2024

2023

2022

Annual total remuneration

index (%)

3,308

3,0809

3,9685

The ratio of the annual total compensation for the highest paid person to the median annual total compensation for

all employees for the year 2024, for the purposes of the Sustainability Statement, is 156,800/47,395.85=3.308.

S1-16_03 .

The information has been collected on the basis of the Operational Collective Labour Agreements and is fully

documented. The data are calculated on a non-discriminatory basis, based on clearly defined methodologies that

remain unchanged over the period considered.

345

[S1-17] Incidents, complaints and serious human rights impacts

S1-17_01-02

Table 51. Total number of incidents of introduction of discrimination, including harassment during the reporting period

2024

2023

2022

Total number of incidents of introduction of discrimination, including

harassment

In the year 2024, no serious incidents of discrimination, abuse and/or violation of human rights related to the

Company's relevant workforce were reported in all of the Company's operations.

Furthermore, in the years 2023 and 2024, no incidents of discrimination have been recorded or reported to all EYDAP

SA staff and no complaints have been filed by employees or third parties for incidents of discrimination.

Through the Whistleblowing channels, one (1) anonymous complaint of workplace harassment was submitted in 2024,

which is under investigation and its validity has not been confirmed.

For the 1 incident recorded in 2022, a penalty was imposed on the complainant by the Company's Disciplinary Board.

S1-17_03-04 .

No whistleblowing complaints related to the issues in paragraph 2 of this Standard (working conditions, equal

treatment and equal opportunities for all and other labour rights) have been submitted .

Overall, the total number of complaints submitted through whistleblowing channels are:

● 2024: 234

● 2023: 146

● 2022: 44

It should be noted that the matters referred to in par. 2 of this standard.

From them:

● 2024: Only 13 concerned the field of whistleblowing. The rest were customer complaints about water

supply/sewerage or were not related to EYDAP SA at all and were therefore filed.

● 2023: Only 8 concerned the field of whistleblowing. The rest were customer complaints or not related to EYDAP

SA and were archived.

● 2022: Only 6 concerned the field of whistleblowing. The rest were customer complaints or not related to EYDAP

SA and were archived.

S1-17_05-06

No fines, penalties and compensation have been imposed during the current reporting period.

S1-17_07

346

No data collection is carried out for this information. EYDAP SA is considering the possibility of collecting and

documenting this data in the future, for a more complete understanding of the processes and results.

S1-17_08-10

In the year 2024, no serious incidents of discrimination, abuse and/or violation of human rights related to the

Company's relevant workforce were reported in all of the Company's activities

S1-17_11-12

There have been no serious incidents of human rights violations related to the Company's relevant workforce.

347

ESRS S2 - Workers in the value chain

Strategy

[SBM-3] Significant impacts and their interaction with strategy and business model

S2.SBM-3_01 _02_06

EYDAP SA discloses that all employees in its upstream value chain function, including EYDAP SA's suppliers/service

providers and Tier 1 employees of suppliers, who could be significantly affected by the business, are included in the

scope of the disclosure, in accordance with ESRS 2. This includes impacts arising from the upstream operation of the

value chain

In particular, EYDAP SA takes into account the significant impacts related to job security, ensuring that employees

upstream in its value chain enjoy appropriate working conditions with respect to the social protection rights of

employees.

Description of the types of workers in the upstream function of the value chain:

● Suppliers / Service Providers to EYDAP SA

● Tier 1 Workers

S2.SBM-3_03

Employees in the upstream value chain include mainly employees who work in the facilities and on behalf of EYDAP

SA, but are not part of its own workforce, i.e. they are not self-employed or employees provided by third party

companies that are mainly engaged in employment activities. Examples include workers on maintenance and repair

projects of water supply and sewerage networks, technicians working for partner companies for the installation and

maintenance of equipment, workers in security and security services of EYDAP SA's facilities.

Significant impacts on different types of employees upstream in the value chain function, which are linked to the

activities and value chain of the firm

To the extent that the National Legal Framework on Public Procurement allows, EYDAP SA has incorporated, and

faithfully applies in its supply chain contracting procedures, the terms of compliance of Suppliers/Service Providers

with the principles of the UN Global Compact in the areas of Human Rights, Labour, Environment and Corruption,

ensuring that all Suppliers/Suppliers of Supply Chain Services implement practices that promote respect for human

rights and are consistent with the Company's policies on social, labour and environmental issues.

In addition to the contractual obligation to comply with the provisions of environmental, social security and labour

legislation, established by Union law, national law, collective agreements or international provisions of environmental,

social and labour law, which are listed in Annex XIV of Appendix B of L. 4412/2016 and depending on the scope, the

contractors shall provide evidence such as certifications for quality, environmental, labour, energy management (ISO

90001, FCS, ISO 14001, 45001, 50001).

A brief description of the activities resulting in positive impacts:

Secure jobs

EYDAP SA is committed to upholding human rights and enhancing the awareness of all those employed by the Company,

including suppliers and employees of outsourced services.

1) Regulatory framework - Implementation of National and Community Procurement Legislation

348

By the Board of Directors' Decision 21721/06.12.23, the Regulation on the Award and Execution of Contracts for

Projects, Studies and the Provision of Technical and Other Related Scientific Services was approved, with an effective

date of January 1, 2024.

2) Tender procedure - Attracting new economic operators

The terms of the contracts are publicly accessible elements of the notices through public postings both Nationally

(Regionally) on digital networks such as:

• the Electronic Online Repository of Administrative Acts (DIAYGEIA),

• the Central Electronic Register of Public Contracts (C.E.M.M.D.S.),

• the National Electronic Public Procurement System (E.S.H.E.D.S.),

and European:

• the Publication Annex of the Official Journal of the European Union and on the website of EYDAP SA

3) Integrating sustainability principles - Human Rights Protection

In November 2022, EYDAP SA adopted a Human Rights Policy which also binds the Company's partners (contractors,

suppliers, service providers, etc.)

4) Ongoing supply chain optimisation projects

Optimization projects involve the overall redesign of the supply chain in terms of organization, operations, warehouse

network, transport and inventory optimization, optimization of operating costs, increase of efficiency and acceleration

of processes.

5) Long-term agreements

As regards long-term agreements, it is noted that they are compatible with the principles of free competition, subject

to the following conditions:

- have been concluded following competitive tendering procedures

- the technical specifications of the products or services are clear and detailed

- be governed by mutual obligations and rights of the parties to the contract

- be periodically checked to ensure that they remain competitive

6) Tender procedures of high importance

In tendering procedures of high importance and with a high economic scope, EYDAP SA conducts tenders published at

European level, in order to ensure the participation of major suppliers, active in both the domestic and the European

business scene, thus ensuring the development of healthy competition.

In 2024, there were no cases of non-compliance by EYDAP SA, as the contracting entity, during the procedure of

tendering for supplies and services.

S2.SBM-3_08

Workers in the value chain who may be at greater risk of harm

Employees providing services to EYDAP SA, such as technicians working in water supply and sewerage facilities, are

subject to strict health and safety related risk assessment procedures. In particular, we recognise hazardous work, such

as working in underground facilities, network maintenance and working on construction sites and industrial facilities.

349

In addition, we pay particular attention to vulnerable groups, such as people with disabilities, to ensure that their

needs are taken into account.

Based on these assessments and health and safety guidelines, we have developed specific measures to prevent

accidents and protect our employees. These measures include training, provision of protective equipment and regular

safety checks.

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Impact management

[S2-1] Policies related to workers in the value chain

S2.MDR-P_01-06 _01_02_03_04_05_06

The Company has adopted and implemented the following Policies to manage the significant impacts related to job

security and employee-related impacts upstream in the value chain. These policies cover all types of employees in the

value chain mentioned in the previous section.

● Code of Conduct and Professional Behaviour

● Human Rights Policy

● Privacy Policy for the Award and Performance of Public Contracts (applies exclusively to contractors

themselves, not to their employees)

● Sustainable Development Policy

The Code of Conduct and Human Rights Policy is addressed to all the Company's partners (e.g. contractors, suppliers,

service providers), including obviously their staff.

The Data Protection Policy for the Award and Performance of Public Contracts covers tenderers, economic operators,

contractors of public contracts that it invites and/or awards and/or supervises, as well as any third parties involved in

the contract, namely, indicatively, subcontractors and third economic operators on whose capacity the contractors

rely.

"Tenderers" or "contractors" for the purposes of the Personal Data Protection Policy are defined as all economic

operators who submit a tender or to whom a contract for a project, design, technical and other scientific services,

supply or general services is awarded, as these terms are defined in Law No. 4412/2016 on public works, supply and

service contracts (A' 147).

The Procurement Directorate, in its contracts with suppliers, includes specific provisions that do not constitute Policies

but serve the same purposes.

CODE OF ETHICS AND PROFESSIONAL CONDUCT

Basic content (general objectives, major impacts and risks, monitoring process)

Please see also S1.MDR-P_01-06_01_02_03_04_05_06, where it has been covered for the Code.

Scope of

Based on the Code, the way of exercising the duties of all EYDAP SA staff, who are employed by the Company with a

dependent or non-dependent employment contract and will also be addressed to all its partners (contractors,

suppliers, service providers, etc.)

Please see also S1.MDR-P_01-06_01_02_03_04_05_06, where it has been covered for the Code.

Highest level in the organisation of the enterprise responsible for implementation

Please see also S1.MDR-P_01-06_01_02_03_04_05_06, where it has been covered for the Code.

Commitment to respect third party standards or initiatives

The Code sets out the basic principles and guidelines of ethical conduct and integrity and aims to enhance

transparency, open communication and meritocracy. Its content is directly linked to the Company's main Policies and

Regulations and at the same time is in line with the Company's Compliance Management Policy and System.

Please see also S1.MDR-P_01-06_01_02_03_04_05_06, where it has been covered for the Code.

351

Attention paid to the interests of key stakeholders in the definition of policy

Following the cooperation of the Internal Audit Department and the Compliance Department, in February 2024, a

questionnaire (anonymous with optional completion of an e-mail address) was sent to all employees and those

employed by EYDAP SA in any employment relationship regarding the consolidation of the principles of the Code of

Conduct and satisfaction with its application. Responses to the above questionnaire have been taken into account in

the context of the ongoing revision of the Code of Conduct and Professional Behaviour.

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in its

implementation

The Code is communicated through the General Directorate of Human Resources to all employees of the Company

including persons or personnel placed at the disposal and under the control of the Company or its subsidiary. All the

aforementioned persons are requested to sign a personal commitment to comply with the principles, standards and

rules set. The Code is also posted on the Company's internal website and is available to all interested parties on the

Company's website www.eydap.gr.

Please see also S1.MDR-P_01-06_01_02_03_04_05_06, where it has been covered for the Code.

HUMAN RIGHTS POLICY

Please also see S1.MDR-P_01 -06_01_02_03_04_05_06, where it has been covered for the same Policy.

Scope of

EYDAP's HUMAN RIGHTS POLICY applies to the Company and any existing or future subsidiary.

More specifically, the following are bound by the content of this Policy:

● The personnel employed by the Company under a dependent employment contract

● Personnel who provide services to the Company under a service contract or otherwise independently.

● The Company's other partners (contractors, suppliers, service providers, etc.)

Please see also S1.MDR-P_01-06_01_02_03_04_05_06, where it has been covered for the same Policy.

Highest level in the organisation of the enterprise responsible for policy implementation

Please see requirement S1.MDR-P_01-06_01_02_03_04_05_06, where it has been covered for the same Policy.

Commitment to respect third party standards or initiatives

Please see requirement S1.MDR-P_01-06_01_02_03_04_05_06, where it has been covered for the same Policy.

Attention paid to the interests of key stakeholders when defining the Policy

In the event that a human rights principle is indeed violated or there is a reasonable suspicion of a violation, then the

relevant report/complaint should be submitted to the Company, in accordance with the Whistleblowing Policy, the

Policy for the Prevention and Combating of Violence and Harassment at Work and this Policy.

Please see requirement S1.MDR-P_01-06_01_02_03_04_05_06, where it has been covered for the same Policy.

This Policy was established with the aim of defending the social and labour rights of all and ensuring equality for all

employees of EYDAP SA, regardless of whether they are regular employees or not.

352

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in its

implementation

The Human Rights Policy, under the responsibility of the General Directorate of Human Resources, is communicated to

the Company's employees and posted on the Company's website www.eydap.gr.

Please see requirement S1.MDR-P_01-06_01_02_03_04_05_06, where it has been covered for the same Policy.

The Human Rights Policy, under the responsibility of the General Directorate of Human Resources, is communicated to

all employees of the Company, including persons or personnel placed at the disposal and under the control of the

Company or its subsidiary. The Policy is also posted on the Company's internal website and is available to all interested

parties on the Company's website www.eydap.gr.

PERSONAL DATA PROTECTION POLICY FOR THE AWARD AND PERFORMANCE OF PUBLIC PROCUREMENT CONTRACTS

(applies only to contractors themselves, not to their employees)

Basic content (general objectives, major impacts, monitoring process)

The purpose of this Privacy Policy of EYDAP SA is to describe the framework for the processing of personal data of

tenderers, contractors and any third parties involved in the contract. The Policy provides information on the types of

data collected, how they are processed (collection, recording, storage, use, transmission, etc.), the means of protection

of personal data and the rights of the data subjects (tenderers, economic operators, contractors and other persons

involved in the contract) in relation to this processing, which is in any case carried out in a reliable and transparent

manner.

EYDAP SA has the right as a data controller to process the necessary personal data of the economic operators bidding,

the contractors with whom it contracts and any third parties involved in the contract, such as subcontractors or lenders

of expertise.

The processor is obliged, upon request of the controller, to provide all information required by the controller in order

to demonstrate compliance with the obligations arising from the public contract and applicable law.

Personal data is processed exclusively for evaluation purposes in the context of procedures for the award, performance

and support of public contracts, as well as for the fulfilment of obligations arising from them or by law, in accordance

with national and EU legislation.

Scope of

For the purposes of this PRIVACY POLICY FOR THE PROCUREMENT AND PERFORMANCE OF PUBLIC CONTRACTS ,

"tenderers" or "contractors" are defined as all economic operators who submit a tender or who are awarded a contract

for work, design, technical and other scientific services, supplies or general services as these terms are defined in Law

4412/2016 on public contracts.

Highest level in the organisation of the enterprise responsible for policy implementation

In order to ensure continuous and secure compliance, a Data Protection Officer's Office has been established, staffed

by individuals with knowledge and experience in the internal procedures of EYDAP SA. Marianna Alboura

(dpo@eydap.gr ) has been appointed as the Data Protection Officer of EYDAP SA.

However, for the implementation of the Policy, as for other policies relating to protection and compliance with the

GDPR, the responsibility lies with the "controller" concerned.

353

Commitment to respect third party standards or initiatives

EYDAP SA, acting as "controller", is committed to comply with the provisions of Regulation (EU) 2016/679 ["On the

protection of individuals with regard to the processing of personal data and on the free movement of such data and

repealing Directive 95/46/EC (General Data Protection Regulation)"]. This commitment extends to the economic

operators making a bid, to the contractors of the public contracts it invites and/or awards and/or supervises, as well

as to any third parties involved in the contract, such as subcontractors and third economic operators on whom the

contractors rely. EYDAP SA respects their privacy and is vigilant in ensuring the confidentiality and security of their

personal data.

Attention paid to the interests of key stakeholders when defining the Code

The Regulation recognises and safeguards the following rights of economic operators, contractors and third parties

involved in the contract, as defined in Articles 12-22 of the General Data Protection Regulation:

● The right to transparent, comprehensible and easily accessible information

● Right of access to personal data

● Right to rectification

● Right to erasure

● Right to ensure the restriction of processing

● Right to object to processing

● Right to withdraw consent already given

● Right to complain to the competent supervisory authority

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in its

implementation

The Policy is available to all potentially affected parties, as well as to stakeholders who contribute to its implementation.

By participating in an award procedure of EYDAP SA and by signing the public contract, the data subjects are deemed

to have knowledge of and consent to the processing of their personal data.

In addition, the Policy is posted on the Company's website www.eydap.gr.

At the same time, in the body of the contract signed with the contractor who will be the processor there is a relevant

article in the general conditions, namely article 19, which states that: "EYDAP SA has the right to process the personal

data of the Service Provider, in case it is a natural person, and/or of the personnel it employs, in case it is either a

natural person or a legal entity, and/or of its management staff, in case it is a legal entity, exclusively for the purposes

of implementing and supporting this contract, as well as for the purposes of contractual and legal obligations arising

from the applicable legislation (e.g. labour, social and social security, etc.).

Also, access to the above personal data, in certain cases, may have third companies with which EYDAP SA is in

cooperation, e.g. administrative support companies. In the context of the above processing, EYDAP SA is obliged to

take the necessary technical and organisational measures deemed necessary to safeguard and protect the personal

data of its contractor and / or the staff it employs and / or its management staff. The Service Provider has read and

unconditionally accepts the Data Protection Policy for the Award and Execution of Public Contracts, which is posted

on the website of EYDAP SA, at http://www.eydap.gr, in the section Tenders - Procurement Notices.

The obligations of the Service Provider in relation to the protection of personal data are described in ANNEX I, which

forms an integral part of the contract. In case of transmission/disclosure to EYDAP SA of personal data of employees

of the Service Provider, the latter expressly and unconditionally declares that it has duly informed the natural persons

354

concerned of such transmission/disclosure, as well as of the terms of the aforementioned Policy and the respective

obligations under the relevant Confidentiality Clause, as mentioned in the contract.

In the context of the execution of the contract and in order to facilitate the relevant communication, cooperation and

exchange of information between EYDAP SA and the Service Provider, in the context of fulfilling the scope of the

contract, the contracting parties shall make available to each other the necessary personal data of their employees,

collaborators and/or personal data of third companies with which the contracting parties may contract.

SUSTAINABLE POLICY

Basic content (general objectives, major impacts and risks, monitoring process)

Please see the disclosure requirement S3.MDR-P_01_02_03_04_05_06 "EYDAP SA adopts and implements a

Sustainable Development Policy, approved by its Board of Directors. The Policy is fully aligned with its business

strategy, vision and values and is the effective implementation of its Strategic Priorities. The pillars and commitments

it has set integrate sustainability into its business operations and development, creating Value for the Environment,

Society and Corporate Governance".

In addition, EYDAP SA invests in the know-how and continuous development of the skills of its people. It operates

according to criteria of meritocracy and transparency. It integrates the Principles of Sustainable Development into its

business plan, promoting respect for diversity and the protection of human and labour rights. It shall encourage open

dialogue and effective communication.

Scope of

The Sustainable Development Policy is applied in all the Company's geographical areas of operation.

Please see disclosure requirement S2.MDR-P_01 "In addition, EYDAP SA invests in the expertise and continuous

development of the skills of its people. It operates according to criteria of meritocracy and transparency. It integrates

the Principles of Sustainable Development into its business plan, promoting respect for diversity and the protection of

human and labour rights. It encourages open dialogue and effective communication.

Top level in the organisation of the company responsible for policy implementation.

Responsible for the implementation of the Policy is the Company's top management, which ensures its compliance

through the relevant Directorates, based on their respective responsibilities

Commitment to respect third party standards or initiatives

The Company declares its commitment to the adoption and implementation of the principles contained in the

Sustainable Development Policy, operating with respect to internationally recognized standards and third party

initiatives that promote sustainability and sustainable development.

Attention paid to the interests of key stakeholders in the definition of policy

The Company, within the framework of the Sustainable Development Policy, takes into account the interests of key

stakeholders, such as employees, partners and local communities, ensuring transparency and enhancing cooperation

in the definition and implementation of the policy.

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in its

implementation

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The Policy is available to all potentially affected parties, as well as to stakeholders who contribute to its implementation.

In addition, the Policy is posted on the Company's website www.eydap.gr.

S2-1_01 _02_03_04_06

Commitments on Human Rights Policy

Commitments & respect for human rights - Procedures and mechanisms for monitoring compliance - Alignment with

internationally recognised instruments

Please see requirement S1-1_03_04_05_06_07 & S1.MDR-P_04 where it has been covered for the Human Rights

Policy.

EYDAP SA is committed to ensuring that employees upstream in the value chain comply with the principles set out in

the Human Rights Policy. This Policy is applied to all its partners, ensuring that working conditions are fair and that the

human rights of employees are protected.

EYDAP SA monitors suppliers' compliance with UN, ILO and OECD guidelines, ensuring that they enjoy their rights and

that their working conditions are safe and fair. Through cooperation with suppliers and the provision of appropriate

training, EYDAP SA aims to continuously improve working practices

For the Company, defending and ensuring the health and safety of its employees and third parties (contractors and

their employees, service providers, etc.) is a paramount obligation. To this end, it establishes policies, adopts and

implements high standards of health and safety in the workplace, regularly evaluating them and managing the risks

involved. The Company provides access to drinking and clean water, sanitary and catering facilities and dedicated

changing rooms, depending on the nature of the work of the staff.

The Company's primary objective is to provide work with the minimum risk of accident or injury or exposure to health

hazards. To this end, all measures are observed to avoid and minimise these. To ensure the above, systematic

information and awareness is provided to the Company's employees, its contractors and their employees regarding the

protective measures applicable in the Company, such as Personal and Group Protection Means (PPE & PPE) etc. At the

same time, the Company acknowledges its responsibility to remain aware of any relevant risk within its operations

Respect for human rights, including the labour rights of those working in the value chain in relation to the important

issues

Secure jobs

Please see requirement S2.SBM-3_03 (To the extent that the National Legal Framework... environmental issues).

Working with employees in the value chain _

EYDAP SA's communication with its suppliers, contractors or external partners is based on trust and honesty. In

particular, the Company in its relationship with the aforementioned, adopts and complies with general principles which

aim to ensure:

• transparency

• the prohibition of discrimination

• their recognition and management as equivalent to domestic economic operators, where their services are

provided by another Member State but fulfil in an equivalent way the objectives pursued through them

• objectivity and impartiality

• the reasons for decisions where necessary measures are taken against them

356

EYDAP SA promotes cooperation with employees in the value chain and encourages the submission of complaints

through the relevant directorates. Our aim is to ensure that the concerns of these employees are also heard and taken

seriously.

Please see requirement S2.MDR-P_01-06 _01_02_03_04_05_06 for the Human Rights Policy.

Measures that provide and/or enable remediation of human rights impacts

EYDAP SA ensures that employees in the value chain have access to reporting and support mechanisms to raise

concerns about human rights violations and seek redress.

Please see the requirements:

● S2.SBM-3_03 (To the extent that the National Legal Framework... environmental issues)

● S2.MDR-P_01-06 _01_02_03_04_05_06 (If indeed...and this Policy)

Availability of a code of conduct

The company has set a goal for 2024 to create a Supplier Policy, which will include guidelines and principles that

promote transparency, ethical conduct and compliance with applicable laws. While we do not currently have a specific

Supplier Code of Conduct, the Supplier Policy will ensure that our suppliers operate in accordance with the values and

principles of our business.

However, the Code of Conduct and Professional Behaviour must be observed by all those who have an employment or

cooperation relationship with EYDAP SA.

S2-1_07

Both during the invitation and selection of the contractors, and during the implementation of the contract, the

communication procedures with the contractors provided for by the legislation on public procurement and the terms

of the respective contract are followed and they are checked for compliance with the terms by committees competent

for the subject of the contract, both during their selection on the basis of submitted evidence (certificates or quality

and environmental management declarations), and during the execution of the contracts for the

S2-1_08

Alignment of EYDAP's policies with internationally recognised standards for employees in the value chain.

EYDAP SA ensures that its Policies, as mentioned in the previous section on employees in the value chain, are aligned

with internationally recognised standards, such as the United Nations Guiding Principles on Business and Human Rights.

Please see requirement S2.SBM-3_03 (To the extent that the National Legal Framework... environmental issues).

S2-1_09

Cases of non-compliance with the UN Guiding Principles, the ILO Declaration or the OECD Guidelines concerning

workers up the value chain

In 2024, EYDAP SA did not observe any cases of non-compliance with the United Nations Guiding Principles on Business

and Human Rights, the ILO Declaration or the OECD Guidelines on Workers in the Value Chain.

357

In 2024, with regard to compliance with public law by suppliers/service providers, four (4) incidents of non-compliance

with the terms of the contract due to failure to perform the contractual obligations in good faith were identified. The

performance bonds were forfeited.

During the same year, the audit of the respective committees did not reveal any cases of violation of the provisions

concerning:

● child labour,

● forced labour,

● participation in a criminal organisation,

● bribery and corruption,

● fraud,

● the commission of terrorist offences or, more generally, the commission of offences linked to terrorist

organisations,

● environmental legislation and climate change

● money laundering from illegal activities by suppliers

S2-1_10

By the Board of Directors' Decision 21721/06.12.23, the Regulation on the Award and Execution of Contracts for

Projects, Studies and the Provision of Technical and Other Related Scientific Services was approved, with an effective

date of January 1, 2024.

S2-1_11

Forms of policy communication - Tools and channels - ensuring policy accessibility and understanding of its impact by

workers in the value chain - the workforce

Please see the requirements:

● S1-1_14

● S2.MDR-P_01-06 _01_02_03_04_05_06

The communication of the policies is done through multiple channels, on the internal website www.eydap.gr, in public

areas, in physical form, digitally, on billboards, etc.

The Compliance Department prepares on a semi-annual basis a training program on the principles contained in all

compliance policies including the Human Rights Policy and the Code of Ethics and Professional Conduct, as well as

ensures that the policies are accessible to the staff through their posting in a special section on the Company's internal

website. On the Company's website all Policies are also translated into English. Plans are already underway to

disseminate the Policies in a more accessible and interactive way in cooperation with the Communication and

Corporate Relations Department.

The Directorate of Communication & Corporate Relations formulates a comprehensive internal communication

program aimed at fostering a culture of regulatory compliance and policy adoption by all employees. The programming

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includes actions covering all levels of the hierarchy using both educational methods and the use of audiovisual and

other media.

[S2-2] Procedures for engaging with employees in the value chain in relation to impacts

S2-2_01

Impact of employees' views on the value chain on the Company's decisions or activities related to impact management

To manage the impacts related to the safe employment of its suppliers' employees, it has adopted the following

mechanisms:

● All suppliers of EYDAP SA are required to comply with Law 3850/2010, according to which specific safety

protocols must be applied, such as the use of Personal Protective Equipment (PPE), training for work in

confined spaces (e.g. manholes) and compliance with safe excavation rules.

● EYDAP SA may maintain an anonymous hotline, through which suppliers' employees can complain about

unsafe working conditions, such as lack of protective equipment or excessive working hours. In such cases, it

may demand immediate improvements or even terminate cooperation with non-compliant suppliers.

● Pilot Programmes for Safer Working Conditions: The Company may work with outside agencies and their

employee unions to implement best practices, such as new indoor gas detection technologies or advanced

safe excavation methods.

S2-2_02

Cooperation with elected representatives

The competent body for the consultation of employees with the management on health and safety issues is the

Employee Health and Safety Committee (EHS Committee), which consists of elected employee representatives (Law

3850/2010).

Explanation of the stages, type and frequency of cooperation

Table 52. Stages at which collaboration takes place, the type of collaboration and the frequency of collaboration with value chain

workers

Type of cooperation

Stages

Frequency

Personal and email

communication

Communication and information

Daily

On-site visits

Evaluation and monitoring of

procedures

Where appropriate

Constant calls for tenders for

projects

Procedure for the award and

execution of projects

Where appropriate

S2-2_04

The highest level with operational responsibility for ensuring cooperation with employees in the value chain

In April 2023, EYDAP SA adopted the Environmental Policy by Board Decision 21295/26.04.23). The Policy is posted on

the official corporate website eydap.gr, according to which the Directorate of Procurement and Projects Management,

in the context of its activities, is committed to inform suppliers and contractors that cooperate with it on the adoption

of the Environmental Policy and to ensure their compliance with it.

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S2-2_05

Universal framework agreements or agreements concluded by the enterprise with global trade union federations on

respect for the human rights of workers in the value chain

Please see requirement S1.MDR-P_01-06 _01_02_03_04_05_06 Commitment to respect third-party standards or

initiatives for the ESMPs and requirement S1-2_02 _04_05 for the Employee Federation.

EYDAP SA respects the rights of employees to participate in trade unions. Through the agreements it has concluded

with trade union federations, it ensures that the views of employees in the value chain are heard and taken into

account. EYDAP SA promotes an open dialogue with employee representatives, thus enabling an understanding of their

needs and concerns.

S2-2_06

How to evaluate the effectiveness of the cooperation with employees in the value chain - Agreements or subsequent

results

Please see requirement S2-1_01_02_02_03_04_06 (the communication of EYDAP SA with suppliers...necessary

measures against them.)

S2-2_07

Measures to obtain the views of people who may be particularly vulnerable to impacts and/or

Employees in the value chain have access to a complaints mechanism, satisfaction surveys, etc.

The cultivation and establishment of a stable, modern and healthy corporate environment that will promote the work

of EYDAP SA and will be characterized by the principles of integrity, honesty and regulatory compliance, is an obligation

of all and a basic prerequisite for healthy business activity and social cohesion and progress.

Please see requirement S2-1_01_02_03_04_06 (By implementing the Whistleblowing Policy ...improper activity).

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[S2-3] Channels for employees to raise concerns in the value chain

S2-3_01 _02_03_04_05_06

General approach and procedures for providing or contributing to remediation in cases of serious adverse impacts and

ways of assessing the effectiveness of the remediation provided

EYDAP SA ensures that no significant negative impacts on employees in the value chain have been identified through

the implementation of policies that promote their safety and well-being. The company promotes cooperation with

suppliers and service providers, ensuring that working conditions comply with applicable laws and the principles of the

UN Global Compact. In addition, EYDAP SA monitors and evaluates its processes to ensure that its practices promote

the welfare of its employees and do not lead to negative impacts. Should issues arise, the Company stands ready to

consider and implement appropriate remedies.

Procedures and channels for raising concerns or needs and addressing them - Establishment of channels by the

company itself and/or through participation in third party mechanisms

Please see requirement S2-1_01_02_03_04_06 (By implementing the Whistleblowing Policy ...improper activity).

The submission of reports can be achieved by sending the report to the address 156 Oroposou, 111 46 Galati, EYDAP

SA, by e-mail to whistleblowing@eydap.gr or by using the online form on the website of the organization

https://www.eydap.gr/Investors/CorporateGovernance/Whistle-blowingApp/ .

Communication channels for reporting incidents of misconduct

This Policy is posted on the Company's official website "www.eydap.gr". You may report incidents involving violations

of Company policies and procedures and applicable laws and incidents of alleged misconduct using the contact

channels below:

● by e-mail (whistleblowing@eydap.gr). Reports can be submitted via either the corporate or personal email

address.

● postal account: EYDAP AE - Regulatory Compliance Service

Availability of workplace channels for employees in the value chain

The system for raising concerns is also accessible to persons outside the company (suppliers, customers) and any third

party associated with the company.

EYDAP SA encourages any person working, providing services, cooperating with EYDAP SA and any third party related

to the Company to report any violations that have come to their attention as well as to express any concerns, concerns

or complaints regarding any violations of the Company's policies or the legislative-regulatory framework governing its

operation. For this reason, the system for raising concerns is accessible to all, in particular through the specially

designed platform on the Company's website

(https://www.eydap.gr/Investors/CorporateGovernance/WhistleblowingApp/).

Identifying and monitoring issues

The Company makes available to the Interested Parties communication channels that enable them to submit reports

on incidents falling under the provisions of the Whistleblowing Policy. Incident reports must be submitted within a

reasonable time from the time the facts came to the attention of the Reporting Party, be clear, definite and well-

founded, and be made either by e-mail or by post to the Compliance Department or through the dedicated platform

on the Company's website (https://www.eydap.gr/Investors/CorporateGovernance/WhistleblowingApp/). The

relevant channels of communication are listed at the end of this document and are posted on the Company's website.

If a report falling within the scope of this policy is sent to another service unit of the Company, the latter must forward

it to the Compliance Department.

361

The Compliance Directorate is responsible for the management of the internal reporting system. Its role is to ensure

the implementation of the policy and the operation of the Company's Reporting Mechanism. The Compliance Division

manages the reporting-complaints with due diligence, confidentially, impartially and objectively. Upon receipt of the

report, the Compliance Division shall file the report in hard copy and electronically in a separate protocol and shall be

maintained in a manner that ensures confidentiality. It will also immediately, and in any case no later than three

working days, contact the person who submitted the report to inform him/her that the report has been received,

provided that it was submitted in a signed and signed form. The Compliance Directorate will then forward the reports

to the Reports Evaluation Committee.

Ensuring channel efficiency

The implementation of the Whistleblowing Policy as part of the Company's internal control system is periodically

evaluated as to its effectiveness by the Internal Audit Department. The Policy is updated by decision of the Board of

Directors upon recommendation of the Compliance Committee and proposal of the Compliance Division.

All Company Personnel and Executives should provide all possible cooperation in the investigation of reports and

actively support the mechanism for raising concerns. The Company's General Managers and Directorates should

promptly and accurately provide all information and facilities required for the effective investigation of reports. The

following have been taken into consideration in the preparation of this Policy:

● Directive (EU) 2019/1937 of the European Parliament and of the Council.

● Public Interest Whistleblower Protection Guidelines for Companies in Greece OECD.

● A Best Practice Guide for Whistleblowing Legislation, Transparency International

● The United Nations Convention against Corruption Resource Guide on Good Practices in the Protection of

Reporting Persons

● Special whistleblowing platform on the Company's website.

Assessment of the knowledge and confidence of these structures or processes as a way of reporting their concerns

or needs and having them addressed by employees in the value chain

EYDAP SA encourages the free expression of employee or third party reports in order to enhance confidence in its

proper operation and efficiency and to reduce corruption. Cultivating a climate of open communication with the

Company is crucial to address incidents of illegal or irregular behaviour. In this context, this document constitutes a

Policy and Procedure aimed at preventing, combating and managing illegal acts or omissions, in order to ensure the

above principles, including the fight against corruption

Policies on the protection of individuals against retaliation

Through the Whistleblowing Policy, EYDAP SA is committed to protecting all employees, including those in the value

chain, who make reports or participate in the investigation process. are entitled to protection from retaliation as long

as their reports are well-intentioned and based on valid reasons.

The protection extends to family members of the petitioners who may have an employment or professional

relationship with the Company.

Please see requirement S1-3_09.

S2-3_11 .

Please see requirement S2-3_01_02_03_04_05_06 (Issue identification and tracking).

The basic and inviolable principles of the Policy for the Management of Reports - Complaints are the protection of

anonymity and the principle of confidentiality of the information of the Petitioners. Reports are handled with due

diligence, impartially and objectively and all reports are treated equally, with absolute confidentiality and discretion.

362

The investigation and satisfaction of a subject's request always takes into account confidentiality, which is one of the

basic principles of the triangle safeguarded by the Data Protection Officer (CIA: Confidentiality, Integrity, Availability).

Loss of any one of the three implies a breach of Data Protection.

S2-3_12

The Company, through the communication channels it establishes, gives the opportunity to the petitioners to submit

their report either anonymously or anonymously. However, the Company encourages anonymous reports as this

better achieves an assessment of the credibility of the report-complaint and the Petitioner's intentions, and facilitates

communication both for further clarification and to keep the Petitioner informed of the progress of the report.

For complaints involving Personal Data, the email address isdpo@eydap.gr . Due to the nature of the incidents being

investigated, identification is requested.

363

[S2-4] Taking action on the significant impacts on employees in the value chain and the effectiveness of these actions

S2.MDR-A_01-12

Summary description of action plans and resources to manage significant impacts

The summary description of the action plans and resources to manage the significant impacts related to employees in

the value chain of EYDAP SA is as follows:

Secure jobs

● Compliance with the legislation on minimum requirements for public procurement of suppliers/service

providers, equal treatment of suppliers/service providers.

● Tendering procedure - Attracting new economic operators

o Both during the invitation and selection of the contractors and during the implementation of the

contract, the communication procedures with the contractors provided for by the legislation on public

procurement and the terms of the respective contract are observed and they are checked for

compliance with the terms by committees competent for the subject matter of the contract.

● Integrating sustainability principles - Protection of Human Rights

o In November 2022, EYDAP SA adopted a Human Rights Policy which also binds the Company's partners

(contractors, suppliers, service providers, etc.)

● Ongoing supply chain optimisation projects

o Optimization projects involve the overall redesign of the supply chain in terms of organization,

operations, warehouse network, transport and inventory optimization, optimization of operating costs,

increase of efficiency and acceleration of processes.

● Long-term agreements

o As regards long-term agreements, it is noted that they are compatible with the principles of free

competition and are periodically monitored.

● Compliance by suppliers with their obligations

o Implementation of the Whistleblowing Policy which includes a system of raising concerns ensures

operation in a professional manner, and prevention even of any suspected unfair practices or

corruption or circumstances of improper activity.

S2.MDR-A_01

Secure employment places

Key actions

Human Rights Policy

Please see requirement S2.MDR-A_01-12.

Please see requirement S2.SBM-3_03 (To the extent that the National Legal Framework... environmental

issues...45001, 50001).

Whistleblowing Policy (Whistleblowing Policy

Please see requirement S2.MDR-A_01-12 (Compliance by suppliers).

Expected Results

The implementation of the actions is expected to strengthen the Company's commitment to ensuring safe workplaces,

respecting human rights and promoting a healthy and cooperative work culture.

How the implementation of the actions contributes to the achievement of the objectives and aims of the policy

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These actions promote the basic principles of the Company's policies, such as compliance with the applicable

regulatory framework, transparency and accountability, while being in line with the sustainability and corporate

governance policies

S2.MDR-A_02

Secure employment places

Scope of

Human Rights Policy

Please see requirement S2.MDR-A_01-12 (Integrating sustainability principles - Human Rights Protection)

Whistleblowing Policy

The Policy applies to all organizational units of the Group and is addressed to and concerns any person working,

providing services, cooperating with EYDAP SA and any third party related to the Company and in particular:

● Employees (permanent, seasonal, temporary, with a service voucher, through an external partner, trainees)

● The members of the Board of Directors

● All executives

● Contractors and subcontractors

● Suppliers

● Consultants, Special Partners and anyone providing services to the Company

● Candidates for jobs or other forms of cooperation

● Customers

● Shareholders

● third parties who have relevant information about any illegal actions concerning the Company.

S2.MDR-A_03

Secure jobs

Time horizon of key actions

Please see requirement S1.MDR-A_03

S2.MDR-A_05

Progress of actions or action plans notified in previous periods.

Secure jobs

Mission 2025

EYDAP SA will continue to monitor the progress of its actions aimed at ensuring the safety and rights of employees in

the value chain. Actions include improving working conditions and strengthening cooperation with suppliers to comply

with health and safety standards, contributing to the overall sustainability of the value chain

S2.MDR-A_06_07_09_10_11_12

Please see requirement S1.MDR-A_06_06_07_09_10_11_12

365

S2-4_03

Additional actions or processes to achieve positive impacts for employees in the value chain.

Please see the notification requirement S2.MDR-A_01-12.

There are no additional actions or processes that the company implements to achieve positive impacts for

employees in the value chain.

S2-4_04

Evaluation of the effectiveness of actions for employees in the value chain.

EYDAP SA systematically monitors the overall progress and the actions implemented, evaluating their effectiveness

through qualitative and quantitative indicators. Although there are no specific mechanisms for employees in the value

chain, the development of appropriate procedures to enhance transparency and monitoring of impacts in the future

is being considered

S2-4_12

Resources to manage significant impacts.

EYDAP SA does not currently disclose resources allocated to manage significant impacts on employees in the value

chain. The possibility of collecting and providing this information in the future is being considered in order to enhance

transparency and understanding of its processes

Measurement indicators and targets

[S2-5] Objectives related to promoting positive impacts

EYDAP SA does not currently have procedures for the disclosure of objectives relating to employees in the value chain.

However, it emphasizes positive impacts, such as ensuring safe jobs, which are consistently monitored through relevant

actions. The company is considering the possibility of developing target setting processes for employees in the value

chain to enhance overall transparency and efficiency.

S2.MDR-T_16

No measurable, results-oriented and time-bound targets have been set with regard to safe jobs for workers up the

value chain.

However, the dynamic triptych of Safety at Work - Operational Efficiency - Growth for Society is what defines the

Company's strategic priorities for:

● Ensuring a fair and dynamic working environment.

● Creating new jobs.

● Improving the level of services we offer

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In addition, among the Corporate Governance Objectives is the establishment of a Supplier Policy. This Policy has been

drafted by the Compliance Department, but it is an initial draft and the consultation and approval process has not yet

been completed.

At the same time, EYDAP SA monitors the effectiveness of its policies and actions related to safe workplaces through

performance indicators and regular assessments.

S2.MDR-T_17

Effectiveness is monitored using qualitative and quantitative indicators, such as the frequency of complaints about

safety conditions and the implementation of corrective actions.

S2.MDR-T_18

There are no specific targets, but progress is monitored through the prevention of recorded safety incidents and the

steady improvement of working conditions.

S2.MDR-T_19

Monitoring is based on qualitative and quantitative indicators relating to secure jobs, without specifying a specific

baseline period, as a steady improvement is sought.

367

ESRS S3 - Affected communities

Strategy

[SBM-3] Significant impacts and risks and their interaction with the strategy and business model

S3.SBM-3_01 _02_05_06

EYDAP SA discloses that all affected communities upstream, own and downstream in its value chain, including NGOs,

local communities and scientific institutions, which could be significantly affected by the operation, are included in the

scope of disclosure in accordance with ESRS 2. This includes impacts arising from upstream, own and downstream value

chain functions.

In particular, EYDAP SA takes into account the significant impacts related to clean water and sanitation, as well as

cultural rights, ensuring that the affected communities upstream, upstream and downstream of its value chain enjoy

the provision of clean drinking water, access to sanitation, while at the same time the company supports with its actions

the access, participation and preservation of the cultural heritage of these communities. At the same time, EYDAP SA

also takes into account the risk of water scarcity for the affected communities in the upstream, same and downstream

operations of the value chain due to increased drought and lack of rainfall.

Description of the types of communities subject to significant impacts

Clean water and sanitation

● NGOs active in the field of environmental protection and human rights protection may be affected by decisions

or practices of EYDAP SA, especially in cases related to the quality of drinking water, the access of vulnerable

social groups to clean water or the reduction of the environmental burden due to the effective treatment of

wastewater.

● Local communities that are directly affected by the management of water and sanitation networks. The

uninterrupted supply of high quality drinking water and wastewater collection and treatment services and the

adequacy of infrastructure are important factors shaping the daily lives of the inhabitants.

For 2024 we are referring to a total of 2,269,207 water supplies. The estimate for 2025 is approximately 2,280,000

water supplies

The benefits in "Water - Sewerage" for 2024 are: 2.095.283. The benefits for "Water supply" alone are: 128,307. The

benefits for 'Sewerage' alone are: 45,617.

The benefits with a household tariff for 2024 are: 2,215,089 (not including professional, large families, EL, EL, elderly,

charity, ship supply, network aid, public and local authorities).

● Scientific bodies that closely monitor the environmental impacts of water and sanitation activities, with an

emphasis on monitoring water ecosystems and sustainable use of natural resources.

Cultural rights:

● NGOs active in the protection of cultural heritage can benefit from the initiatives of EYDAP SA for the

preservation and promotion of historical sites during infrastructure projects. Through partnerships with

cultural institutions and archaeological services, the Company can contribute to the discovery, protection and

preservation of cultural monuments, enhancing the cultural identity of the areas.

● Local communities that benefit from projects that enhance the urban landscape can highlight historic areas

and raise the cultural profile of local communities.

● Scientific bodies that can, in cooperation with EYDAP SA, promote the sustainable management of water

resources in culturally important areas. Through landscape restoration and wetland protection projects, the

368

Company can contribute to the preservation of natural and cultural monuments, while enhancing public

environmental awareness.

Please see requirement S3.MDR-P_01 _02_03_04_05_06, which only applies to the sponsorship framework:

("1.Education structures: EYDAP SA supports education structures...and development and prosperity").

Brief description of the activities resulting in positive impacts

Clean water and sanitation

● EYDAP SA has the exclusive right to provide water supply and sewerage services in the capital city area, a non-

transferable responsibility and right. The Greek State, with the new Contract, lasting until 2040, which it has

concluded with the Etairia PAGION EYDAP N.P.D.D. and EYDAP SA, undertakes the obligation throughout the

duration of the Contract to supply EYDAP SA with raw water of sufficient quantity to meet the needs of its

consumers and quality, in accordance with the requirements of the legislation. The right of EYDAP SA includes

the treatment of water, its distribution, as well as the operation and maintenance of the privately owned water

supply network, in order to cover the water supply needs of all consumers, irrespective of their origin, in the

capital area.

● EYDAP SA is responsible for the construction, operation and maintenance of the sewerage network and

Wastewater Treatment Centres in its area of responsibility. The result of integrated wastewater management

is the return to the environment of treated water, free of pollutant load (> 95%).

● CLEAN WATER OF ANATOLIKI ATTIKIS: A major project of EYDAP SA, aiming at the integrated management of

wastewater in East Attica and the utilization of the recycled water produced by to ensure maximum benefit

for people, society and the environment.

● Environmental Permitting of East Attica Projects 2024: The major environmental infrastructure projects are

implemented after the preparation of the necessary Environmental Impact Studies and the relevant approval

of Environmental Conditions. In the course of the implementation of the projects, the Technical Environmental

Studies required by law are prepared

● According to the Company's information systems, for the reporting period (1/1/2024 - 31/12/2024), no fines

or other non-monetary sanctions were imposed on EYDAP SA for non-compliance with environmental

legislation and environmental regulations, related to the management and disposal of liquid and solid waste.

However, it should be mentioned that with the Audit Report No. 111686/6078/2024 of the Environmental

Inspection Department, 3 violations of medium importance (Unauthorized storage of hazardous waste -

Hazardous waste open air and on land, unauthorized storage of non-hazardous solid waste - HAZW, inadequate

monitoring of hazardous solid waste) were confirmed for which corrective actions are required (corrective

action plan). Consequently, no fine was imposed, but a corrective action plan was defined in accordance with

the above infringements and a timetable for their implementation was established.

● At the core of EYDAP's strategy is the uninterrupted provision of high quality water supply and sewerage

services in Athens and the rest of Greece. Its mission is to provide quality and cheap drinking water to more

and more citizens, giving it back to the environment in a clean way with social sensitivity and with a view to its

contribution to social welfare. Providing clean and safe water contributes to the health and well-being of the

community. By investing in modern sanitation infrastructure, risks of contamination are reduced and quality

of life is improved. Over time and even more so in the coming years, investments are being launched to build

resilient water supply infrastructure to address climate risks

Cultural rights

● Sponsorship Program EYDAP SA: EYDAP SA by decision of its Board of Directors established in 2020 a Corporate

Sponsorship Policy by decision of its Board of Directors, which defines the basic principles of sponsorships, as

derived from the Strategy and priorities of the Company. The sponsorship programme supports actions in

areas directly linked to a substantial contribution to social welfare.

369

● EYDAP SA, in cooperation with the Municipality of Halandri and 6 other specialized partners, participated in

the project CULTURAL H.ID.RA.N.T. - UIA, which was completed in June 2024. EYDAP SA actively participated

in all the actions of the project, contributing and raising awareness in water management and in the promotion

of the Adrianion Aqueduct, through its Cultural Network.

● Strategically, EYDAP SA chooses to support society with projects that have an impact on the preservation of

historic water infrastructure, encourage citizen participation and promote the development of green oases

within the urban landscape.

● At the same time, the Company takes into account the cultural and social impacts of its projects, ensuring that

the cultural heritage and the rights of local communities are not negatively affected. The Adrian Aqueduct

project is a prime example of preserving historic water infrastructure for future generations, with citizen

participation and multiple positive impacts on the local communities it passes through.

Please see also requirement S3.MDR-A_01 for the Adrian Aqueduct as a Heritage Site.

● EYDAP SA, in the context of corporate responsibility, preserves and exploits its historical documents. In 2018,

it established a Historical Archive Management Policy for the uniform management of this important heritage

and its opening to the public and the scientific community.

Significant risks arising from impacts and dependencies on affected communities

Risk of water scarcity

● Due to increased drought and lack of rainfall there is a risk of water scarcity, which may lead to mandatory

water restrictions. The identified risk is projected to have a long-term financial impact on the entity's value

through reduced revenues and on communities due to water restrictions.

● To manage the risk of water scarcity, control mechanisms are applied to ensure adequate supply of raw water

to the Water Treatment Units (WTPs), in cases where the routed inputs will be under the impossibility of

sufficient flow, according to the updated water resources management plan for the water supply of Athens,

prepared by the Civil Engineering Department of the National Technical University of Athens in cooperation

with EYDAP SA.

● EYDAP SA is implementing a fairly extensive investment plan with the development and maintenance of

networks, construction of Wastewater Treatment Centres and infrastructure projects in general. Local

communities are affected during the implementation of the projects in various ways, as there is temporary

acoustic pollution from machinery activity, temporary effects on air pollution due to dust and other pollutants,

as well as traffic delays. For all of the above disturbances, EADAP is taking all foreseen mitigation and safety

measures.

S3.SBM-3_03

Clean water and sanitation

The activities of EYDAP SA have significant impacts on the local communities of the urban and interurban centres of

Attica, in the downstream parts of the value chain, which are located both around the premises and operation of the

company, and in areas of treated wastewater outflow and are recipients of drinking water and sewerage services.

More specifically, EYDAP SA, through maintaining "ecological supply" in its reservoirs, impacts local communities by

ensuring the continuity of wetland systems around its operations, factories, facilities or other physical activities.

At the same time, the reliable and uninterrupted provision of sewerage services contributes to the protection of both

the underground aquifer and the marine environment, benefiting the local communities under the influence of the

Wastewater Treatment Centres, since the treated effluent of the WWTPs is returned to the marine environment free

of their pollutant load by at least 95%.

It is possible that in the future communities located in the adjacent area of the water bodies from which the drainage

is made may also be affected.

370

S3.SBM-3_07

Clean water and sanitation

The existence of an affordable tariff reflects the support of society, ensures the mitigation of social inequalities and

protects vulnerable groups of the population from being deprived of the basic social good, water.

The tiered tariff acts as a deterrent to the waste of the natural resource and raises consumer awareness of its rational

use.

EYDAP SA, in recognition of the need to support vulnerable social groups, has undertaken important initiatives, beyond

those defined by the relevant Regulatory Framework, through its Tariff Policy.

● Support of socially vulnerable groups through institutionalized decisions of the Company's Board of Directors.

Discount on bills is provided: Special Special Tariff (SST), Large Families of Elderly Customers.

● Charity Tariff which is provided not only to foundations and associations within the meaning of Law 1111 of

8/11.2.72 and Law 4182/2013, but by decision of the Board of Directors and other institutions - bodies that carry

out charitable - public benefit work.

● Providing discounts on increased bills taking into account social and income criteria, through procedures

established by the company.

● Accessibility to our services for visually/hearing impaired people

o Send special bills in Braille, large fonts, SMS and email

o Version of the Sustainable Development Report in audio file format

o Corporate video subtitling

The Company's efforts are continuous in order to ensure uninterrupted access to the Water Supply / Sewerage Services

in order to provide the necessary goods to the customer and ensure the Company's business resilience. The existence

of a tiered tariff helps to limit the wasteful use of water and safeguard the resource in order to ensure the

uninterrupted operation of our business. It also helps to reduce our environmental footprint. The Company's tariff

policy through tiered tariffs, special tariffs, customer debt management aim, on the one hand, to largely meet the

actual needs of households and businesses and, on the other hand, to ensure the resilience and financial stability of

EYDAP SA.

Cultural rights

Communities with specific characteristics or those working in specific contexts or those undertaking specific activities

are not affected by cultural rights-related impacts.

S3.SBM-3_08

Risk of water scarcity

The risk of water scarcity is not associated with specific groups of affected communities

371

Impact and risk management

[S3-1] Policies related to the affected communities

S3.MDR-P_01-06

The Company has adopted and implemented the following Policies to manage the significant impacts related to clean

water and sanitation and cultural rights and the risk of water scarcity in its upstream, downstream and own operations

with respect to the affected communities:

● Sustainable Development Policy

● Sponsorship Policy

● Historical Archive Management Policy

● Human Rights Policy

S3.MDR-P_01 _02_03_04_05_06

Access to drinking water

SUSTAINABLE DEVELOPMENT POLICY

Basic content (general objectives, major impacts and risks, monitoring process)

EYDAP SA adopts and implements a Sustainable Development Policy, approved by its Board of Directors. The Policy is

fully aligned with its business strategy, vision and values and is the effective implementation of its Strategic Priorities.

The pillars and commitments it has set integrate sustainability into its business operations and development, creating

Value for the Environment, Society and Corporate Governance. The Policy refers to equal access to excellent quality

drinking water at an affordable price, support to the local community through actions to contribute to local

development in projects with social and environmental implications.

Creating Value for Society: the Company ensures equal access to high quality drinking water to an increasing number

of citizens at an affordable price. It designs its operations with customer service at its core, continuously upgrading the

scope and quality of its services. It integrates new digital applications across the entire range of our operations, making

quick decisions. It operates in full compliance with the Regulatory Framework, based on the non-negotiable principle

of complying with the requirements of the law and the commitments it has voluntarily adopted. Challenges at the

social level are opportunities for EYDAP SA. It supports local communities, creates synergies and actions to contribute

to local development in projects with social and environmental implications.

Scope of

The Sustainable Development Policy is applied throughout the entire area of activity of EYDAP SA.

Highest level in the organisation of the enterprise responsible for policy implementation - Commitment to respect

third party standards or initiatives - Attention paid to the interests of key stakeholders when setting policy

Within the framework of the Sustainability Policy, the Board of Directors identifies in the Annual Management

Report the non-financial issues that are deemed essential for the realisation of its vision and strategy, taking into

account the requirements of its stakeholders. The Board of Directors shall be assisted by the Strategy, Innovation and

Sustainability Committee in all of the above responsibilities.

The Report refers to the way these actions are managed and the evaluation of these actions based on the recognised

international GRI and SASB standards for water companies.

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in its

implementation

The Sustainable Development Policy of EYDAP SA is posted on the corporate website www.eydap.gr.

372

Human Rights Policy

Please see requirement S1.MDR-P_01-06 _01_02_03_04_05_06.

Cultural Rights

SPONSORSHIP POLICY

Basic content (general objectives, major impacts and risks, monitoring process)

The Company accepts the definition of sponsorship according to Law 3525/2007 as amended and in force until today:

"sponsorship means the financial or other form of financial provision in kind, in intangible goods or services by natural

or legal persons, domestic or foreign, for the support of specific cultural activities or purposes of the recipient of the

sponsorship, with a compensation for the promotion of the social person and the welfare of the sponsor".

Specifically for EYDAP SA, the definition of sponsorship may include the support of knowledge dissemination activities,

through conferences, workshops, forums and other related events, always under the condition of reciprocal benefits

for the Company.

All Company sponsorships are subject to the operation of this Policy. This Policy merges financial aid and aid of a social

and non-contributory nature for the Company.

The Company's sponsorship program promotes, among others, the values of education, culture, sports, environment

and public health, making EYDAP SA an important supporter of actions that contribute to the Greek society and have

a positive impact on the quality of life of its citizens, as they have a direct social, cultural and environmental impact.

In addition, based on the Policy, a minimum of two scholarships are established annually, in cooperation with the State

Scholarships Foundation (IKY), which are addressed to students at doctoral level, who are carrying out their PhD thesis

in universities in Greece, in subjects related to water and wastewater management.

Scope of

Within the framework of the Sponsorship Policy, the Company contributes to the social cohesion and well-being of the

communities where it operates, supporting social and development and prosperity. In addition has established two (2)

Scholarships annually to PhD candidates of Greek Universities.

Please see within the same disclosure requirement S3.MDR-P_01 _02_03_04_05_06: "..the definition of sponsorship

may include support for knowledge dissemination activities, through conferences, workshops, fora and other related

events".

Sponsorship Framework (Sponsoring Bodies/Organisations)

1. Education structures

EYDAP SA supports educational structures that promote research, excellence, innovation and fair play.

2. Bodies promoting culture

EYDAP SA may sponsor cultural bodies/organizations with the aim of promoting culture and the qualitative upgrading

of the society.

3. Sports clubs, sports events

Applications concerning the sports sector are evaluated based on the strategic and promotional objectives of EYDAP

SA.

4. Conferences/meetings

373

EYDAP SA examines the possibility of financial support for conferences/meetings, in cases that relate to the scope of

action of EYDAP SA and/or serve the achievement of the business objectives only, as described in this form.

5. Local Societies

The Company contributes to the social cohesion and well-being of the societies where it operates by supporting social

and economic development and prosperity.

All Institutions / Organizations that are active in the fields of culture, environment, education, sports and health are

entitled to participate in the Company's sponsorship program. Priority is given to civil non-profit companies, local

government organizations, voluntary organizations, academic research institutions, educational centers affiliated with

universities and TEI, postgraduate programs of universities and TEI, sports federations, associations and clubs

(excluding associations responsible for the organization of professional championships and professional sports and

sports entertainment companies, such as football clubs, clubs, etc.), as well as the NΠΔΔ and NΠID active in the field

of culture, education, science. NGOs are excluded from the sponsored bodies/organisations.

SCHOLARSHIPS EUDAP EA

A minimum of two scholarships were established annually, in cooperation with the State Scholarship Foundation (IKY),

for students at doctoral level, who are pursuing their PhD thesis at universities in Greece, in subjects related to water

and wastewater management.

Top level in the organisation of the company responsible for policy implementation.

The Board of Directors of the Company exercises the Sponsorship Policy, approves the annual budget on these within

the framework of the Company's budget. The Chief Executive Officer of the Company approves any sponsorship

request within the approved sponsorship budget upon the recommendation of the Committee and reports back to the

Board on an annual basis on its major decisions. For any sponsorship decision that exceeds the budget, the CEO shall

seek prior approval from the Board.

Commitment to respect third party standards or initiatives

This Policy makes reference to Law no. 3525/2007 regarding third party standards or initiatives that the Merchant

commits to respect through the implementation of the Policy.

In addition, basic principles such as:

● Transparency: all the Company's sponsorships are disclosed through an entry on the Company's website. In

particular, the details of the recipient, the subject of the approved action and the amount of the sponsorship

are made public.

● Independence: The Sponsorship Policy of EYDAP SA is independent of the individual interests of customers,

shareholders or third parties. In relation to scholarships, they are given in cooperation with the State

Scholarships Foundation (IKY), following all legal procedures and applying criteria of objectivity and

transparency.

Attention paid to the interests of key stakeholders in the definition of policy

EYDAP SA, the largest company in Greece in water cycle management, does not have a process through which it

understands the concerns and suggestions of affected communities and incorporates their views in the formulation of

the Policy. However, it remains firmly committed to the principles of Sustainable Development and, as part of its

corporate responsibility, it implements a Sponsorship Programme aimed at promoting, among other things, the values

of education, culture, sports, the environment and public health, making EYDAP SA an important supporter of actions

that contribute to Greek society at every level.

374

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in its

implementation

The Sponsorship Policy of EYDAP SA is posted on the corporate website www.eydap.gr.

Also, regarding the scholarships of EYDAP SA, after the publication of the relevant Ministerial Decision (Government

Gazette 3983/B/27-7-2022), the announcement of the launch of the ICY-EYDAP SA Scholarship Programme was made

by the State Scholarship Foundation to the Rectors and Vice Rectors, as well as to the Secretariats of the Departments

of Higher Education Institutions. The annual notice is posted on the website of the State Scholarship Foundation - IKY

and EYDAP SA.

POLITICS OF THE HISTORICAL ARCHIVE

Basic content (general objectives, major impacts and risks, monitoring process).

EYDAP SA has been providing uninterrupted water supply and sewerage services to the residents of the Attica basin

for almost a century, creating emblematic projects that highlight the Company's significant role in the shaping and

development of Attica.

In the context of the need to save, preserve and manage the Corporate Historical Archive, in 2018 EYDAP SA established

a Historical Archive Policy, defining the procedures for the uniform constitution and management of its corporate

material of historical importance. The Corporate Archive is defined as all documents, copies or originals, regardless of

their type or substrate, related to the activities of the Company, which were produced organically or accumulated and

used by a legal or natural person during their activities and functions.

The aim is the preservation, organization, management and promotion of the Historical Archive Material of EYDAP SA,

and in detail:

a) informing the Company's employees about the importance of preserving the Historical Archive and encouraging the

preservation of the Archive

b) the organization of the process of recording the inactive file by thematic section and its duration, with the aim of

characterizing part of it as inactive-historical with the agreement of the competent General Directorate / independent

Directorate and the Legal Service of EYDAP SA

c) the collection, recording and documentation of historical archival material based on international standards.

d) the creation of appropriate conditions for the preservation and conservation of the original physical form of the

documents of historical importance.

e) the digitisation of historical archival material on the basis of international standards, seeking the maximum possible

preservation and conservation of physical and digitised material of historical importance, as well as ensuring its

subsequent access and exploitation. The digitisation of the material includes the use of appropriate technology, the

complete processing of the primary digital files (cleaning of dust and physical marks, tonal and colour processing),

digital archiving and digital documentation.

Scope of

The Corporate Responsibility & Corporate Responsibility Service Historical Archive of EYDAP SA, in order to utilize and

promote its historical archival material for research, educational and cultural purposes, develops various actions for

third party access to its historical archival material. These actions include:

● Thematic Exhibitions

● Book/album publications

● Educational Programmes

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● Posting some of the material on the internet and other digital media.

Top level in the organisation of the company responsible for policy implementation.

The Historical Archives Policy is approved by the Board of Directors of the Company and its implementation is carried

out by the Historical Archives Service and supervised by the Senior Management.

Commitment to respect third party standards or initiatives

This Policy makes no reference to third party standards or initiatives that the company commits to respect through

the implementation of the policy.

Attention paid to the interests of key stakeholders in the definition of policy

The rescue, preservation and management of the company's archival material of historical importance is an investment

on the part of the Management, which contributes to the preservation of the history of the Company and our cultural

heritage in general.

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in its

implementation

On the Company's website, in the section Sustainable Development - Historical Archive of EYDAP SA, an extract of the

Historical Archive Policy is posted regarding the procedure for interested parties to obtain material from the Historical

Archive for research, scientific purposes, etc. The Historical Archive Policy relates to internal procedures between

departments describing how the archive is collected and acquired and the annex only describes how external

stakeholders such as researchers can access the archive for a specific purpose. The annex is posted on the corporate

website. The full text of the policy is not available potentially affected parties via the corporate website or internally.

376

S3-1_02 _03_04

Commitments on Human Policy

Commitments & respect for human rights - Procedures and mechanisms for monitoring compliance - Alignment with

internationally recognised instruments

EYDAP's commitment to the affected communities is undeniable. The Company takes all necessary measures to

protect the environment and avoids actions that could endanger both the environment and the local communities. It

encourages the development and dissemination of environmentally friendly technologies while promoting

environmental responsibility. The Company develops and promotes activities and executes projects with respect for

local communities. In this context, dialogue and consultation with representatives of local communities is encouraged,

when necessary, in order to achieve cooperation in the formulation of actions, investments and decisions that can

affect their economic and social progress.

Respect for the human rights of communities in relation to important issues

The Company takes care to identify and prevent situations that endanger human rights by informing and training all

its personnel. To this end, the Compliance Department draws up a training programme on a semi-annual basis on the

principles contained in the Human Rights Policy and ensures that staff have access to it. Since the scope of the above

Policy covers a wide field of labour and social rights, each organizational unit involved in the Company is required to

strictly adhere to the principles of the Human Rights Policy by taking appropriate measures to effectively resolve any

complaint.

The Company intends to establish a Complaints Policy in order to adopt a common culture of receiving and managing

complaints in a uniform manner, and to achieve continuous improvement of the services provided through the

feedback received. The completion of the establishment of a Complaints Policy is a 2025 plan and is expected to be

approved by the Board by the end of the year.

In the event that a human rights principle is indeed violated or there is a reasonable suspicion of it, the Company

encourages the submission of a report/complaint in accordance with the Whistleblowing Policy through the availability

and accessibility that members of the affected communities can have to the Whistleblowing platform, which is located

on the Company's website

Finally, the Compliance Directorate monitors the effectiveness of the Human Rights Policy and evaluates its

effectiveness.

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Focus on the important issues

EYDAP SA focuses on critical human rights issues that affect communities:

● Clean water and sanitation: ensuring access for all citizens to safe and affordable water and efficient

management of sanitation systems to protect public health.

● Cultural rights: Respect and protection of cultural heritage in EYDAP SA's areas of activity, ensuring that

infrastructure and interventions do not adversely affect the cultural monuments and traditions of local

communities.

General approach to respect for human rights

EYDAP SA actively promotes respect for human rights through:

● Educate and raise awareness among its staff about international guiding principles and the importance of

protecting human rights.

● Partnerships with NGOs, scientific bodies and local communities to develop and implement sustainable

practices

● Transparency and accountability, providing regular reports on the progress and effectiveness of policies and

compliance mechanisms.

S3-1_05

Measures that provide and/or enable remediation of human rights impacts

Please see requirement S3-1_02_03 on the "General approach to respect for human rights".

EYDAP SA focuses on clean water and sanitation and cultural rights as well as its overall approach to measures that

provide and/or enable remediation of human rights impacts on affected communities through its Whistleblowing

Policy

Please see also the requirement S1-1_03_04_05_06_07 & S1.MDR-P_04.

S3-1_06

Please see requirement S1-1_03_04_05_06_07 & S1.MDR-P_04.

S3-1_07

In the reporting period, there were no incidents of non-compliance with the UN Guiding Principles on Business and

Human Rights, the ILO Declaration on fundamental principles and rights at work or the OECD Guidelines for

Multinational Enterprises Involving Affected Communities, in the context of the company's operations or upstream

and downstream parts of the value chain.

S3-1_09

Example of the ways in which its policies are communicated to the individuals, group of individuals or entities to which

they are addressed

Please see the notification requirements S2-1_11, S1-1_14 & S3.MDR-P_01 _02_03_04_05_06.

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[S3-2] Procedures for engaging with affected communities in relation to impacts

S3-2_01_02_03_04_05_06_08

Impact of the views of affected communities on the Company's decisions or activities related to community impact

management

Considering society (NGOs, local communities, scientific bodies) as one of its Key Identified Stakeholder Groups, EYDAP

SA has established specific ways of direct communication with the Company, so that the views of the affected

communities contribute to the formulation of its decisions or activities aimed at managing actual and potential impacts

on communities. Modes of communication include:

• Corporate Website

• Email

Additional ways of incorporating the views of the Communities used by EYDAP SA:

1. Public Consultations and Environmental Studies:

o Public consultations are carried out during the Environmental Authorisation phase of large

infrastructure projects (such as Waste Water Treatment Centres and sewerage projects). Local

communities have the opportunity to express their views through open hearings or written

submissions.

o The views of citizens and local stakeholders are assessed and incorporated into the project design and

approved through the Environmental Conditions Approval Decision in the final environmental impact

studies.

2. Cooperation with Local Bodies and Municipalities:

o EYDAP SA cooperates closely with local authorities, Regions, Municipalities and representatives of

communities for the management of water supply and sewerage issues. Through these partnerships,

it develops and adapts its projects according to the needs and concerns of the residents.

EYDAP SA has established various communication channels, either directly with the affected communities (corporate

website, email, public consultations) or with their representatives (Regions, Municipalities, Community

Representatives).

Explanation of the stages, type and frequency of cooperation

Table 53. Stages at which cooperation takes place, type of cooperation and frequency of cooperation with affected communities

Type of cooperation

Stages

Frequency

Corporate Website

Communication and information

Daily

Communication and information

Daily

There is no specific position and role at the top level within the Company to which operational responsibility is assigned

for ensuring cooperation with affected communities and for taking into account the results in the EYDAP SA approach.

Evaluation of the effectiveness of the Partnership

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● Continuous Monitoring and Feedback: EYDAP SA has mechanisms in place to continuously monitor its

engagement with communities, recording concerns and suggestions arising from consultations.

● Satisfaction Surveys: citizen satisfaction surveys are conducted to assess the company's response to the needs

of the affected communities. The results of these surveys influence the formulation of future policies and

actions.

● Accounts and Reports: The results of consultations and actions taken based on community partnerships are

made public in Annual Sustainable Development Reports. The reports also describe the effectiveness of the

partnership through KPIs related to the social acceptability of the projects.

● Consequential Results: In cases where long-term partnerships are required, EYDAP SA enters into agreements

with municipalities or local authorities for the execution of public utility projects, ensuring the participation of

communities in the management of the projects.

The Company does not take specific steps to obtain information about the views of affected communities that may be

particularly vulnerable to impacts and/or marginalized, as well as the views of specific groups within affected

communities, such as women and girls.

Please see requirement S3-2_01, which also applies to the specific community groups.

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[S3-3] Channels for raising concerns from affected communities

S3-3_11 _12_13_14_15

Procedures and channels for raising concerns or needs and addressing them - Establishment of channels by the

company itself and/or through participation in third party mechanisms

Clean Water and Sanitation

Complaint calls 2024

o Water mains: internal leakage, work on the supply, bazaar removal, pavement-asphalt restoration,

third party works, manhole covers, water in basement, water in street, water in meter well, water

quality, pressure and water intake deprivation.

o Sewer network: drain blocking, manhole covers and pavement/asphalt rehabilitation.

o Line 1022 (24/7)

Please see the requirement S1-3_02_05_06_07_08.

● In-person submission of concerns from affected communities to the Regional Centres for large bills from

leakages, debt settlements, etc.

● Through the corporate website, all customers can view and pay their bill, make appointments, change the

details of their supply, find out about the conditions for reducing an exorbitant bill, find out about water supply

interruptions in the network, find out about sewerage in East Attica and request click to call or call back calls.

● All customers can also find out how to read their bill, read their property's water meter and check for possible

leaks in their property.

● Identified customers, through the website, can also request a reduction of an excessive bill, request settlement

of their debts, apply for a Social Tariff, cancel the printed bill, declare any business use benefits,

● Also, through the corporate website, registered users can remove the printed bill, register their meter reading,

perform virtual billing, request the granting or renewal of a luxury, business, charity and senior citizen invoice.

They can also apply for a test of their meter and for the restoration of their water supply after a cut-off due to

debt. Registered users can and do keep track of all the requests they have made as well as bills issued and

payments made.

Availability of channels from the Company's business relationships

The availability of communication channels is easy through the 1022 Line 24/7 and through our website EYDAP SA-

CONNECT WITH US.

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Identifying and monitoring issues

Please see also requirement S1-3_02_05_06_07_08.

The Company makes available to the Petitioners communication channels that enable them to submit reports

regarding incidents falling under the provisions of this Policy. Incident reporting must be submitted within a reasonable

time from the time the facts came to the attention of the Reporting Party, must be clear, definite and substantiated,

and must be made either by e-mail or postal mail to the Compliance Department or through the dedicated platform

on the Company's website (https://www.eydap.gr/Investors/CorporateGovernance/WhistleblowingApp/). The

relevant communication channels and are posted on the Company's website. If a report falling within the scope of the

whistleblowing policy is sent to another service unit of the Company, the latter must forward it to the Compliance

Department.

The Compliance Directorate is responsible for the management of the internal reporting system. Its role is to ensure

the implementation of the policy and the operation of the Company's Reporting Mechanism. The Compliance Division

manages the reporting-complaints with due diligence, confidentially, impartially and objectively. Upon receipt of the

report, the Compliance Division files it in hard copy and electronically in a separate protocol in a manner that ensures

confidentiality. It shall also immediately, and in any event no later than three working days, contact the person who

submitted the report to inform him or her that the report has been received, provided that the report was submitted

in a signed and signed form. The Compliance Directorate will then forward the reports to the Reports Evaluation

Committee.

However, issues relating to the Company's normal operation do not fall within the scope of the Whistleblowing Policy,

and are therefore forwarded directly to the Company's competent units for resolution.

Ensuring channel efficiency

The implementation of the Whistleblowing Policy as part of the Company's internal control system is periodically

evaluated as to its effectiveness by the Internal Audit Department. The Policy is updated by decision of the Board of

Directors upon recommendation of the Compliance Committee and proposal of the Compliance Division.

All Company Personnel and Executives should provide all possible cooperation in the investigation of reports and

actively support the mechanism for raising concerns. The Company's General Managers and Directorates must

promptly and accurately provide all information and facilities required for the effective investigation of reports. The

following have been taken into consideration in the preparation of this Policy:

● Directive (EU) 2019/1937 of the European Parliament and of the Council.

● Public Interest Whistleblower Protection Guidelines for Companies in Greece OECD.

● A Best Practice Guide for Whistleblowing Legislation, Transparency International.

● The United Nations Convention against Corruption Resource Guide on Good Practices in the Protection of

Reporting Persons.

Assessing the knowledge and confidence of these structures or processes as a way of reporting their concerns or needs

and having them addressed by the affected communities

EYDAP SA encourages the free expression of employee or third party reports in order to enhance confidence in its

proper functioning and effectiveness and to limit corruption. Cultivating a climate of open communication with the

Company is crucial to address incidents of illegal or irregular behaviour. In this regard, a Policy and Procedure has been

established herein for the purpose of preventing, combating and managing illegal acts or omissions to ensure the

above principles, including the fight against corruption.

Policies on the protection of individuals against retaliation

Through the Whistleblowing Policy Whistleblowers ,who selflessly and in "good faith" made a report - complaint are

entitled to protection if at the time of reporting they had reasonable grounds to believe that the information regarding

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the reported violations is true and falls within the scope of this Policy. Therefore, they are not protected in the case of

a malicious complaint, i.e. where it is proven that the employee knowingly made a false allegation, or provided false

or misleading information, obstructed work during an investigation, or acted in bad faith in any way.

The Company also protects persons who, through error or ignorance, are believed to have made a report and are

subject to retaliation as a result. Protection is even afforded to persons who assisted in the investigation of the

disclosure because they were required to do so by virtue of their authority and position or in the performance of their

duties.

The protection applies to natural persons of any status who fall within the scope of this Policy (section 4) and may

make reports as set out herein.

Protection is also provided to persons whose employment relationship has ended and to candidates for employment

or other forms of cooperation who have obtained information about violations during their employment or during the

recruitment process, and who could be subject to retaliation, for example in the form of negative professional

references, blacklisting or boycotting companies.

The protection extends to family members of the petitioners who may have an employment or professional

relationship with the Company.

Please see requirement S1-3_09.

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[S3-4] Taking action on significant impacts on affected communities and approaches to manage significant risks in

relation to affected communities and the effectiveness of these actions

S3.MDR-A_01-12

Summary description of action plans and resources to manage significant impacts

Clean water and sanitation

In 2024, a further expansion of the sewerage network in areas lacking sewerage was achieved and significant progress

was made in the implementation of sewerage projects in all areas under the responsibility of EYDAP SA, including East

Attica.

The modernisation of equipment that contributes to more efficient wastewater management (integrated quality

control system for all urban and industrial sewage discharged to the WWTP, the tender for the installation of on-line

instruments for monitoring waste in the network was completed, and the delivery of new tankers was carried out).

In cases of impossibility of construction by the Municipalities of the secondary sewage pipes, EYDAP SA undertakes

their construction as well as the construction of the connections of the properties, after signing a programmatic

contract with the respective Municipality.

EYDAP SA is in constant communication with the local community through environmental awareness actions.

Cultural Rights

EYDAP SA, in the framework of corporate social responsibility, seeks to raise awareness of society on issues concerning

the preservation and exploitation of cultural heritage, through its activities in the field of culture.

● Historical archive of EYDAP SA

● Cultural Network of EYDAP SA

● Granting of historical material 2024

● Adrianion Aqueduct as a Cultural Heritage monument

S3.MDR-A_01_02_03 &

Clean water and sanitation

Key Actions

In 2024, significant progress was made in the implementation of the sewage projects in East Attica. Specifically and

per project, the most important progress milestones are presented.

Among the main actions of the Sewerage Services for the collection and treatment of wastewater are:

● Acceptance of the Wastewater Treatment Centre of Koropi - Peania by EYDAP SA and start of operation of the

WWTP by EYDAP SA.

● Completion of the tender for the supply of thirteen (23) online wastewater monitoring systems.

● Completion of the tender for the provision of services for the qualitative recording of wastewater and

detection of potential pollution hot spots in selected areas of the Sewerage Network through continuous

monitoring and sampling in the Sewerage Network of EYDAP SA.

● Completion of the tender for the quality control of the sewage sludge disposed at the Metamorphosis

Wastewater Treatment Centre

● Rehabilitation / upgrading of the old central pantorrhic network with NO DIG Technology, i.e. applying an

innovative method that allows the repair of the pipelines without nuisance, i.e. digging, breaking, unnecessary

damage, noise, dust etc., in a sensitive area such as the centre of Athens.

Regarding the main actions for the supply of clean water, EYDAP SA ensures:

384

1. Ensuring drinking water coverage, which is provided by all the water supply network facilities. Specifically:

o The water supply network consists of about 14,600 km of supply and distribution pipelines. The main

supply network (primary network) is approximately 1 300 km long and consists of pipelines with

diameters ranging from Φ300 mm to Φ2000 mm.

o The distribution network has a length of approximately 13,350 km, consisting of the secondary and

tertiary networks, which have a total length of approximately 9,000 km for the secondary network and

approximately 4,350 km for the tertiary network, respectively. The distribution network consists of

pipelines with a diameter of less than F300 mm, which transport drinking water to consumers.

o There are 53 reservoirs, 82 pumping stations, 619 pressure reducing valves from Φ80 to Φ600 & about

90,000 isolation valves scattered in the area of responsibility.

2. Monitoring and improving the operation of the water supply network (demand monitoring, pressure

monitoring, pressure zone modifications, etc.)

Attica is characterised by an intense terrain. EYDAP SA provides water in areas with ground elevations from 0 to 600

meters above sea level. In order to better control the pressure of the pipelines, pressure zones were created, i.e.

ground areas with a specific pressure every 30 to 40 metres of altitude difference. The range of pressures within the

hydraulic zones varies from 2 to 12 atm with the vast majority ranging from 4 to 6 atm. The water supply network is

monitored on a 24-hour basis by a remote control - remote management system (SCADA).

In 2024, in order to achieve better network management, EYDAP SA replaced existing problematic and installed new

flow meters, so that the total number of these flow meters will reach approximately 200 flow meters in network

feeders and 80 telemetry stations in addition to the existing ones, bringing the total number of telemetry stations to

1590 and the number of SCADA stations to 108.

3. The extension, replacement and rehabilitation of existing network pipelines and water supply systems for

properties.

The existing network of EYDAP SA consists of pipelines of different cross-sections and different materials, which have

been installed over the years to serve the increased water supply needs of the residents of Attica.

Many of these pipelines have been in operation for many years, and due to the original conditions of their installation

and due to the development of the city and the successive reconfigurations of roads and other public spaces, combined

with other nuisances (vehicle traffic, other external factors), they have been subjected to significant stresses leading

to frequent breakages.

Similarly, the water supplies of the properties, which are watered by these pipelines are characterized by the same

age and show similar stresses as the pipelines. The operating conditions of these pipelines are assessed by EYDAP and

then programmes are defined and implemented to replace them with new pipelines and water mains made of the

most modern materials.

In 2024, EYDAP SA replaced, installed new and relocated a total of 49,031.02 m of pipelines. In detail, the following

were carried out:

o Replacement of existing pipelines: 43.901,02 mm of pipelines of cross-section Φ63, Φ90, Φ110, Φ160, Φ200,

Φ250, Φ300, Φ315

o Laying of new pipelines: 4.472,15 m of pipelines

o Pipeline displacements: 657,5 m of pipelines

and at the same time replaced/remediated approximately 7,981 water supply properties.

4. Settlements - Displacements of pipelines from third-party projects

In the context of works carried out by third parties, EYDAP is invited to intervene in its network to facilitate the

execution of new works taking place on the city's roads. In this context, 657.50 m of pipelines were laid in 2024, either

to replace existing ones (438.50 m) or to cover new water supply needs arising from the interventions of third parties

in the city (219 m) (indicatively, METRO, ERGOSE, etc.).

385

In order to ensure the good quality of the water supplied to the consumer, EYDAP SA carries out periodic cleaning of

the water storage tanks every three years. Based on this planning, 7 water storage tanks in the water supply network

were cleaned in 2024.

Water supply projects for new areas and reinforcement of existing areas

Please see requirement E3.MDR-A_01: "for the water supply of new areas and to enhance the water supply of existing

areas, the following projects will be implemented...In October 2023, the Board approved the launch of a new public

electronic tender with the project title "Completion of the remaining works for the water supply of the settlement of

Kinetta Megara, Phase A: 1) External water supply pipeline, 2) Central reservoir". The tender procedure is currently

underway. It is expected to be completed within the 1st quarter of 2025".

Expected results

Multiple benefits from the implementation of the projects (East Attica):

By applying cutting-edge technology and high know-how, the projects in East Attica will ensure sustainable water

management, the protection of the marine environment and the aquifer, as well as safeguarding the health of more

than 400,000 residents who will benefit from modern sewerage and wastewater treatment infrastructure.

● Environmental value: the marine environment is protected, underground aquifers are enriched and significant

quantities of valuable water resources are saved

● Value to society: the projects protect public health and will improve the quality of life of residents. It also

increases property values and eliminates the cost of emptying septic tanks.

● Support to Farmers: In seasons with significant irrigation water needs , it is possible to irrigate farmland through

the reuse of recycled, high quality water, enhancing sustainable agricultural production and reducing

dependence on natural water resources.

Expected results - Clean water

For EYDAP SA, ensuring throughout the entire water supply system sufficient quantities of high quality drinking water

at acceptable pressure conditions, while protecting the natural resource, is a main priority, as:

● More efficient operation of the water supply network is achieved with a consistent, reliable and uninterrupted

water supply and a significant amount of the valuable natural resource of water is saved (further reduction of

NRW).

● It ensures an adequate supply of high quality drinking water, protects public health, enhances the quality of

life of residents and improves the level of service to consumers.

Time horizon for key actions - Clean water

● Extension, replacement and rehabilitation of existing network pipelines and water supplies to properties

In 2024, EYDAP SA replaced existing pipelines with pipelines of cross-section Φ110 and rehabilitated water outlets in

the framework of the project "Works of extensions, improvements and replacements of pipelines of the Water Supply

Network in areas of responsibility of the Heraklion Sector of E.YDAP SA".

In addition, in 2024 EYDAP SA installed new pipelines (pipeline extensions resulting from the general planning of new

pipelines of the General Directorate of Water Supply for the reinforcement of water supply of existing areas) of cross-

sections Φ160, Φ300, Φ400 and Φ600 in the framework of the project "Supply Pipeline of Perama Tanks from Schistos

Avenue".

o The project "Works of extensions, improvements and replacements of pipelines of the Water Supply

Network in areas under the jurisdiction of the Heraklion Sector of E.YD.A.P. S.A." was completed within

2024.

o The project "Perama Tank Supply Pipeline from Schistos Avenue" is underway and is expected to be

completed within the first quarter of 2025, as already mentioned in the key action "Projects for water

supply to new areas and reinforcement of water supply to existing areas".

386

● Receipt of new networks: The receipt of new networks has no specific time horizon for implementation.

Cultural Rights

Key Actions

1) Historical Archive of EYDAP SA: The Historical Archive of EYDAP SA consists of documents that record the

history of the Company and the people who make up the Company. Some of the subjects that make up the

archive material of historical importance come from the Adrianion Aqueduct, the construction projects of the

water supply system of Athens-Piraeus and Surroundings (of the period 1925-1931), and the construction

projects of the Yliki and Mornos projects.

Expected results

In the framework of corporate social responsibility, EYDAP SA seeks to raise awareness of society on issues related to

the preservation and exploitation of cultural heritage.

The establishment of a Corporate Historical Archive Management Policy in 2018 reflects the Company's commitment

to the uniform management of this important heritage, with the ultimate goal of preserving, promoting and utilizing

historical documents.

2) Cultural Network of EYDAP SA: The Network, through the adoption and development of a single policy,

implements the following actions.

Specifically, in 2024, EYDAP SA:

o Organized a tour of the Marathon Dam Museum

o He participated with a speech and presented the experience of setting up the Historical Archive

o Organised an internal corporate event to honour employees who contributed to the preservation of the

Historical Archive's material

o Completed most of the compilation of an archive of oral testimonies from employees and executives of the

Company

o Enrich the historical archive with digitizations and file editing

o Completed most of phase B of the project for the unified management of the historical archive

o Digitize in High Definition and 2K resolution the audiovisual archive

3) Provision of historical material 2024: In 2024, historical archival material was provided for various uses, such

as documentation of courses at an educational institution and development of an educational programme,

inclusion in articles in print and electronic publications, use in anniversary publications and printed tourism

promotion material.

Expected result

The expected result of the actions related to the Cultural Network of EYDAP SA and the Donation of historical material

is the promotion of the Company's cultural contribution.

4) Adrianio Aqueduct as a Cultural Heritage Monument: in the framework of the European project Cultural

H.ID.RA.N.T. - UIA, which was completed in June 2024, the first urban non-potable water network in Greece, 4

km long, was constructed in Halandri by EYDAP SA.

EYDAP SA, as a key partner in the project, presented the new "Adrianio" water network, which makes the water of the

aqueduct usable for irrigation and other non-potable uses and organized targeted meetings-presentations to

important and influential stakeholders in the region.

387

In September 2023, EYDAP SA participated in a documentary entitled "Our Planet Earth - Urban Desert", which was

broadcast the British national broadcaster "BBC Earth" in autumn 2024.

In 2024 they were carried out by EYDAP SA:

● two large guided tours along the entire length of the Adriatic Aqueduct, to representatives of the Embassy of

Switzerland (16.10.2024) and to the partners of the European Water4all project (8.11.2024)

● multiple guided tours and activities throughout the year in schools, both in the new network in Halandri and in

the iconic Kolonaki Tank

● guided tours and distribution of scientific material to researchers and students.

Expected results

The "Adrianio" water network confirms the Sustainable Development Strategy (ESG) of EYDAP SA and the principles of

the circular economy with the objectives of :

● enhancing resilience to water scarcity

● shielding against the phenomenon of urban overheating

● adaptation to climate change

● protection of natural drinking water resources

● rational water management

and with the benefit for the user of Adrianaios water the savings of drinking water, the energy costs of maintenance

of the wells, the costs of the high tariff scales of quantitative water, as well as the guaranteed quantity and quality of

non-potable water with a constant low price

How their implementation contributes to the achievement of policy objectives and targets

The implementation of these actions not only enhances public health and environmental sustainability through

improved wastewater management and the preservation of cultural heritage, but also contributes to the achievement

of its objectives and policies by promoting the well-being of the community, promoting the responsible use of

resources and ensuring the protection of cultural assets for future generations. At the same time it develops

environmental awareness and highlights the importance of the precious resource of water.

388

S3.MDR-A_05

Clean water and sanitation

Mission 2025

● Zero cases of out-of-limit analyses in the outputs of the ELVs (exceeding the Environmental Authorisation

Decisions)

● Increased Sewerage connections

Key Performance Indicators (KPIs) are used to monitor progress

Target 2025

2022

(base year)

2023

2024

2025 target

Cases of out-of-

limit analyses in

the outputs of

the ELVs

(exceeding the

Environmental

Authorisation

Decisions)

Sewerage

connections

469.859

476.229

476.944

There is no defined measurable target for sewer connections for 2025.

Cultural rights

Mission 2025

Please see requirement S3.MDR-A_01 regarding Cultural Rights.

S3.MDR-A_06 _07_09_10_11_12

EYDAP SA implements its investment plan in constant search for sustainability and in this context seeks to receive

grants and financial support, either from European or state funds.

EYDAP SA had in 2024 capital expenditure of 38.001.900€ for the implementation of the relevant thematic actions.

Please see also the disclosure requirement S1.MDR-A_06_07_09_10_11_12.

S3-4_04 _12

How to monitor and evaluate the effectiveness of actions and initiatives in relation to the achievement of the intended

results

Clean water and sanitation

Drinking water supply and wastewater collection

● Systematic water checks: EYDAP SA carries out more than 180,000 laboratory tests annually to ensure the

quality of drinking water, checking parameters such as microbiological and chemical composition.

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● Sufficiency and loss ratios: Water supply adequacy and network losses (e.g. leakage rate) are monitored to

assess the efficiency of water supply networks.

● Environmental impact assessment: in large projects (such as East Attica), environmental impact studies are

carried out and after the implementation of the projects, the effects on the environment and the local

community are monitored.

o EYDAP SA ensures environmental compliance in all its areas of responsibility, including the AEPs for

water supply and wastewater projects throughout Attica. Actions include monitoring and assessment

of environmental impacts, compliance with applicable environmental legislation and implementation

of best practices for the management of natural resources

o The effective operation of the Wastewater Treatment Centres is systematically monitored and

controlled, both with on-line instruments and laboratory analyses, at the intermediate stages of

treatment and at discharge. The results of the monitoring are available to all interested parties through

the National Database for Monitoring the Operation of Wastewater Treatment Plants of the Ministry

of Environment & Environment. Energy (http://astikalimata.ypeka.gr/). During the reporting period,

the Company has not identified any non-compliance with environmental laws and/or regulations.

o Under a contract with EYDAP SA, the Hellenic Centre for Marine Research (HCMR) undertook the

monitoring of the marine ecosystem of the South Evian Gulf in order to record and document the

existing situation and to assess the impact of the CCS, as has been done for years in the Saronic Gulf

where the positive impact of the operation of the Psyttaleia CCS on the improvement of the marine

ecosystem has been documented. ELKEΘE has completed the inventory of the existing situation in the

South Evian Gulf and will continue to monitor the marine ecosystem during the operation of the new

CCLs in East Attica, in accordance with the obligations of national and European legislation and the

AEPs.

o Tests are carried out on samples in the accredited laboratories EYDAP SA on samples of waste water -

waste and sludge, coming from the WWTPs, from the pipelines of the sewerage network, from

companies-industries connected to the network, from tankers that transport sludge to the

Metamorphosis WWTP, from properties where damage occurs and from the Environmental Inspectors

on issues of their competence, regarding pollution of the aquatic environment. In 2025, the number

of samples analysed by the laboratories of the Sewerage Laboratory Analysis Service amounts to

12,330 with the corresponding analyses reaching 71,140.

Cultural Rights:

● Citizen satisfaction surveys: Periodic surveys are conducted in the affected communities to assess satisfaction

with water and sanitation services and cultural activities.

● Evaluation of social programmes: cultural programmes and CSR actions are evaluated on the basis of

participation, positive feedback and social impact (e.g. increased cultural participation).

S3-4_08 _09

Risk of water scarcity

WATER RESOURCES MANAGEMENT AND WATER SCARCITY MANAGEMENT

The main axis of sustainable development of EYDAP SA is the sustainable management of water resources with

continuous integration of new technologies in its actions, in order to ensure their rational management, i.e. the

exploitation of natural resources without harming the environment.

EYDAP SA supplies the untreated water:

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● from surface water resources owned by the Greek State. (Mornos, Evinos, Marathon and Lake Yliki reservoirs)

● from underground water resources owned by EYDAP SA and the Greek State.

In order to ensure the water supply of Attica, under the new conditions formed due to the climate crisis and the

repeated and prolonged drought in the catchment areas of the Mornos, Evinos and Lake Ylikis reservoirs, EYDAP SA,

in cooperation with the Ministry of Environment, has launched an ambitious but necessary plan to ensure the water

sufficiency of Athens. The plan includes immediate, medium-term and long-term interventions, with the aim of

enhancing water reserves through the use of alternative water sources. As part of the immediate actions, the Yliki

pumping stations and the Mavrosovala boreholes have already been put into operation from July 2024. At the same

time, the restoration of the functionality and the reintegration into the EIS of the Middle Roo Kifissos boreholes is

under consideration, in order to further strengthen the water reserves of the EIS through the Mornos aqueduct.

● In a longer term perspective, and with the aim of maintaining adequate supply to the Athens Basin, projects

are being planned and launched:

- interconnection of the Krikeliotis and Karpenisiotis rivers with the Euinos reservoir, ensuring water

sufficiency even in extreme conditions,

- installation of desalination plants, including possible desalination of brackish water.

- sea water transport by tankers from the river Acheloos to the Mornos aqueduct

The distribution of withdrawals (in hm3) of water resources allocated to cover all water supply needs (EYDAP, OTAs,

Organizations etc.) for the year 2024 is analysed as follows:

INVESTMENT IN INFRASTRUCTURE AND SMART METERS

EYDAP SA has included in its five-year investment programme the implementation of a targeted programme, with

documented priority for the replacement of water supply network pipelines, which includes projects of extensions,

improvements and replacements of water supply network pipelines in EYDAP SA's Sectors, which include the

replacement of approximately 380km of secondary and tertiary network pipelines.

Through the above-mentioned interventions, EYDAP SA has initiated the annual replacement of measures of the Water

Supply Network, which corresponds to approximately 1.5% of the total length of the network, following and complying

with global best practices.

In order to achieve the sustainability of the resource, along with the modernization and optimization of network and

asset management, the Company is in the process of developing a "Smart Grid".

In this context, EYDAP SA until 31/12/24:

✓ has replaced 1140 (22 new ones within 2024) old mechanical water meters of special flow rates of 2-inch to

6-inch cross-sections, with the installation of corresponding electronic water meters of modern technology

(smart meters) with the same number of dataloggers.

✓ has already implemented (years 2017-2018) two pilot applications with the installation of 83,500 electronic

household water meters in the Municipalities of Halandri & P. Faliro, at the Varvakeio Market and the

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surrounding streets.

Since December 2023, E.Y.D.A.P. S.A. in cooperation - which remains in force for the current reporting period - with

DEDIE, has launched a pilot project "Multiutility" in order to exploit the infrastructure of new smart electronic meters

of DEDIE for the implementation of a wireless communications network for the purpose of receiving data from meters

of other operators, including EYDAP SA.

EYDAP SA has included in its investment program the installation of new smart meters to replace existing older

technology in order to transition to the smart water network and modern technologies.

NETWORK MAINTENANCE - PREVENTIVE AND EMERGENCY (maintenance of pumping stations, fire hydrants, cleaning

of tanks, repairs of leaking pipelines - supplies, etc.)

The preventive maintenance of pipelines is mainly based on the statistical analysis of the failures. Similar actions are

launched by EYDAP SA for the maintenance of the water supply network feeders through specific modern intervention

methods, as well as for all other supporting infrastructure of the Water Supply Network (pumping stations, tanks,

special water supply wells and large cranes, fire hydrants, etc.).

In addition to the above, the resulting daily failures of the water supply network that cause leaks or breakages in the

network, are collected at the telephone center for faults - complaints of EYDAP SA (1022) and the portal of Water

Supply and are routed for repair to the competent technicians of the Water Supply Sectors. The repair is implemented

immediately, by the ongoing contracting of the General Directorate of Water Supply and the corporate staff, so as to

minimize the nuisance caused to consumers - customers and to restore the smooth water supply of areas where the

network is damaged.

In 2024, the total number of leaks - breakages of both pipelines and valves in all the networks handled by EYDAP SA

amounted to approximately 6,696. These leaks were repaired in their entirety immediately by the Services of the

General Directorate of Water Supply.

S3-4_11

For the reporting period, the Company has not identified any serious human rights issues and incidents related to the

affected communities.

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Measurement indicators and targets

[S3-5] Objectives related to promoting positive impacts and managing significant risks

S3.MDR-T_01-13 _02

Summary of objectives for the affected communities

The dynamic triptych of Safety at Work - Operational Efficiency - Growth for Society is what defines the Company's

strategic priorities.

Clean water and sanitation

● (C3) Percentage of drinking water quality controls within legal limits: >99.5%. Refers to the percentage of

drinking water quality tests found to be within legislative limits, which is set as a target for 2024 to be greater

than 99.5%.

● (C4) Confirmed quality complaints (Number/thousand counters): <0.025. Refers to confirmed quality

complaints per thousand meters, which for 2024 is set as a target of less than 0.025.

Cultural rights

Regarding cultural rights there is no objective with direct relevance. The indicator relating to the Economic contribution

of EYDAP SA to society (C20) with an achievement target of> 9.200.000€, reflects the influence on society through the

contribution route, namely through the social tariff, sponsorships and discounts in general to vulnerable social groups.

S3.MDR-T_01

Clean water and sanitation

The integrated management of wastewater in Eastern Attica is a strategic objective of EYDAP SA. The planning includes

the reuse of treated effluents, using state-of-the-art technology and in full compliance with the current institutional

framework for reuse.

The targets of indicators C3 - Percentage of drinking water quality controls within legal limits > 99.5% and C4 -

Confirmed quality complaints (Number/thousand meters) <0.025, are related to the Key Strategic Priority of EYDAP SA

to ensure water quality along the entire transmission and distribution system. This Strategy is directly related to the

Company's mission, which is to provide quality water and cheap drinking water to more and more citizens and return

it back to the environment clean, through efficient waste management, with social sensitivity and with a view to

contributing to social welfare.

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Cultural Rights

The objectives of EYDAP SA:

● Completion of the 2nd phase of the organisation and management of the Historical Archives, which includes

the classification of the archival material and their archival description.

● Electronic management of archival description data through appropriate software.

● Completion of the oral testimonies of the Company's executives and employees and incorporation into the

historical archive of both the audiovisual material and the material provided by the participants in the

programme.

● Inventory and valuation of the historical mechanical equipment located in the premises of EYDAP SA.

The target of indicator C20 - Economic contribution of EYDAP SA to society is in direct relation to the Strategic Priority

"Supporting Society", also in direct relation to the Company's Vision and Mission. EYDAP, as a provider and agent for

the preservation of the precious commodity of water, through its sponsorship programs ensures the strengthening of

the Company's strategic direction and helps to achieve its objectives. All Agencies/Organizations actively engaged in

the fields of culture, environment, education, sports and health are eligible to participate in the Company's sponsorship

program.

Please see also requirement S3.MDR-T_01-13.

S3.MDR-T_03_04_05_06_07_08_09_10_13

Targets are assessed on a quarterly basis and their value is the annual performance. Please see also requirement

S3.MDR-T_01-13

The targets relate to the downstream value chain, while the geographical boundaries refer to the entire area of the

Company's activity. There is no base value; each update to management reflects the Index's performance against the

target and against previous periods and years, where data is available.

There are no milestones or intermediate targets for 2024. Targets are set based on the preceding assessment of the

importance of strategic priorities and after taking into account important parameters such as the risks and

opportunities of the period, the investment plan, the regulatory framework and the Company's assessment against

ESG criteria. The target setting is then jointly agreed between the Strategy & Innovation and the relevant General or

Independent Directorates.

S3.MDR-T_11

EYDAP SA ensures that sustainability objectives are formulated through transparent processes with stakeholders. The

involvement of NGOs, local communities, public authorities and scientific stakeholders is crucial for the formulation of

realistic and effective strategies.

Please see the disclosure requirements in section "[S3-2] Procedures for engaging with affected communities in relation

to impacts"

S3.MDR-T_ 12

EYDAP SA maintains transparent procedures for the assessment and revision of sustainability objectives, taking into

account new methodologies, scientific developments and changes in the regulatory framework. To this end, it shall

adapt the targets and the corresponding measurement indicators to underlying measurement methodologies,

important assumptions, constraints, sources and procedures for data collection approved within the specified time

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horizon. Any changes made to this basis shall be accompanied by an explanation of the rationale for such changes and

their impact on comparability.

S3-5_01 _02_03

Work with affected communities, their legal representatives or their trusted proxies to set these targets, monitor the

performance of the business and identify any lessons learned or improvements

Please see the disclosure requirements in section "[S3-2] Procedures for engaging with affected communities in relation

to impacts"

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ESRS S4 - Consumers and end users

Strategy

[SBM-3] Significant impacts, risks and their interaction with strategy and business model

S4.SBM-3_01_02

EYDAP SA discloses that all consumers in its downstream value chain, including small and/or large customers, as well

as public sector entities that are customers of EYDAP SA and that may be significantly affected by the company's

activities, are included in the scope of disclosure in accordance with ESRS 2. This section includes the impacts arising

from the upstream, same function and downstream value chain.

In particular, EYDAP SA takes into account the significant impacts and risks related to water supply and sanitation, in

particular the adequacy of water supplies, the protection of the environment, the uninterrupted operation of water

supply and sanitation networks, pricing and quality of services, ensuring that its consumers enjoy the supply of drinking

water, the management of their wastewater and have access to the water supply and sanitation network

Description of the types of consumers and/or end-users

The types of consumers and/or end-users of water and wastewater services are divided into the following categories:

● Industries

● Households

● Private enterprises

● Public bodies

● O.T.A.

In the context of the Dual Meaning Analysis, the categories related to end-use are:

● Disposal of treated wastewater by customers (e.g. industries)

● Use of sludge with energy recovery from the cement industry)

● Discharge of urban waste water by customers

● Disposal of sewage by customers

S4.SBM-3_

Please see requirement S3.SBM-3_01_02_05_06: Description of the types of communities subject to significant

impacts - Clean water and sanitation ("For 2024 we refer to... public and OTAs").

The following categories of consumers are considered to be significantly affected by the company's activities:

● Industries/ Professionals

● Foundations and Associations that carry out charitable - public benefit work

● Areas outside the Plan

● Islands of the South Aegean Region

● Ship supply

● Large families

● Elderly Customers

● People with disabilities

● Beneficiaries of the Social Solidarity Income

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EYDAP SA ensures that consumers and end-users have access to accurate and accessible information on water quality,

charges and service procedures. This includes providing information through e.g. the website, in order to avoid

potentially harmful use of the product or service.

Please see also requirement S4-2_01, regarding communication with customers.

S4.SBM-3_04

During the reporting period, no incidents of non-compliance with regulations concerning the quality of water supply

water and the quality of effluents from the Wastewater Treatment Centres and with negative impacts on the health

and safety of consumers were identified

Please see requirement S3.SBM-3_01_02_05_06 ("Based on the data kept in the information system

"Lysias"...according to the above violations and a timetable for their implementation was established").

EYDAP SA operates in compliance with environmental legislation:

o Complies with the approved environmental conditions for all its installations (Wastewater Treatment

Centres, Water Treatment Units, External Water Supply System, etc.)

o The relevant environmental permitting procedure shall be followed for any new project or

modification of existing ones, if required.

o Environmental Permit Approval Decisions (EEPOs) have been issued for all facilities, where required,

as well as for each Wastewater Treatment Centre (WWTP) and Water Treatment Plant (WWTP) with

their associated projects. The same applies to all Facilities of the External Water Supply System.

o The PV Station of the Acharnon Municipal Health Care Centre has an Environmental Conditions

Approval Permit (AEO).

o For all of the Company's projects and activities, there are valid decisions on the approval of

environmental conditions, or requests for renewal or modification have been submitted in due time.

In 2024, there was no incident of a consumer request not being satisfied, nor an incident of a fine or compensation for

water quality issues.

In 2024 no incidents of non-compliance with regulations related to water quality and negative impacts on the HEALTH

and SAFETY of CONSUMERS were identified.

S4.SBM-3_05

The activities of EYDAP SA that create positive impacts on consumers relate to:

Receipt of water supply networks: EYDAP SA takes over municipal water supply networks which are currently mainly

focused on East and West Attica and is a strategic objective of the company. The takeover is carried out exclusively

after a positive decision of the Municipal Council of the municipality.

Receipt of Sewerage Networks: EYDAP S.A. receives Raw Water Networks of the city of Megara and Nea Peramos, thus,

our network extends from Agios Stefanos to Salamina and from Varkiza to Megara and Nea Peramos.

Extension of the sewerage network: In order to extend the sewerage network in areas under its jurisdiction, EYDAP S.A.

cooperates with the Municipalities and proceeds with the design and study of the required sewerage projects.

397

Pricing of Services: The Company's pricing policy through tiered tariffs, special tariffs, customer debt management aim,

on the one hand, to largely meet the actual needs of households and businesses and, on the other hand, to ensure the

resilience and financial stability of EYDAP SA. The existence of an affordable tariff reflects in practice the support of

EYDAP SA to the society, ensures the mitigation of social inequalities and protects vulnerable groups of the population

from the deprivation of the basic social good, water. Currently the following Special Tariffs exist: Industrial/Vocational

Tariff, Public - Municipal - Community Tariff, Charity Tariff, Tariff for Strengthening Networks of Municipalities and

Communities - Island Water Supply, Tariff for Ship Supply, Tariff for Fire Services and Tariff for Undistilled Water.

Customer Service: Digital services, modern and easy-to-use digital services through multiple channels of

communication with customers. Digital service is available for all customer requests. These include, electronic updates

to identified citizens, complaint calls and their management, bill payments and debt settlements.

Accessibility for people with disabilities: accessibility to our services for visually impaired people through specially

designed services. Since 2017, it enables the sending of special readable bills (in Braille, large fonts, sending sms, e-

mail), summary of the Sustainable Development Report 2021 and 2022 in audio file format, subtitling of corporate

videos posted on the corporate website and concerning consumers, processing of the possibility of serving the hearing

impaired (deaf/hard of hearing) with remote interpretation. Finally, the degree of accessibility of the corporate website

to the visually impaired was determined to be 76/100 using the Lighthouse v.100.0.0.0 accessibility testing tool for the

Google Chrome browser. The corporate website development team is working to improve accessibility and is

committed to adopting the tool's key recommendations to the extent possible. The EYDAP SA website uses the userway

add-on specifically for users with disabilities. There is a posted Accessibility Statement on the corporate website.

Support of vulnerable groups:Support of socially vulnerable groups through statutory decisions of the Board of

Directors of the Company, a discount is provided on the accounts of the beneficiaries of the Social Solidarity Income,

Large Families and Senior Citizens. In addition, the Company, taking into account social and income criteria and

applying institutionalized procedures, provides discounts on increased consumption bills and also on water poaching

bills.

S4.SBM-3_06

Significant risks arising from impacts and dependencies on consumers and/or

Privacy

Cybersecurity

EYDAP SA has set as a priority the shielding of the company through an organised cyber security framework, always in

line with the current legislative provisions.

In this context

● It proceeded to the mapping of risk and maturity profiles, based on international standards and methodologies

for the study of an integrated plan for the implementation of security actions aimed at upgrading measures

● An information security management framework (ISMS) has been established in accordance with the

principles governing cybersecurity and the national and international regulatory and legal framework for

cybersecurity (NIS2, ISO27001, NIST CSF, CIS Controls, GDPR).

● Developed a business continuity and cybersecurity risk remediation plan for the Company's information

systems from a potential disaster, through threat occurrence assessments and mitigation of operational

impacts on the Company's activities and operations.

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● Created the necessary framework of cooperation for the productive exploitation of the identified

vulnerabilities on the recorded activities, where personal data processing is identified, on the one hand, and

for the targeted creation of clear procedures and a Consumer Data Protection Policy in case a breach is

identified.

In this way, the required framework for detecting and responding to incidents of information systems and

personal data breaches was created as an aspect of information security for compliance with the Company's

contractual and regulatory obligations.

● The control mechanisms available to the Company to detect such risks/incidents include tools for

cybersecurity training and awareness of all personnel, network intrusion detection and prevention systems for

monitoring and analyzing network traffic, network access control settings at the network and application level,

as well as a system for intrusive surveillance and detection of events and breaches from external sources at

different levels of the Web and response to cyber security incidents.

The Company, as a critical infrastructure in the field of cybersecurity, applies a holistic information security

management strategy consisting of a series of technical actions and measures for protection, prevention and response

to risks and threats in order to enhance the resilience of its information systems and networks, armour its information

systems and networks and ensure compliance with regulatory, legal and contractual requirements.

1. Cybersecurity Governance Framework

● Establishment of an Information Security Management System (ISMS) framework in accordance with the

principles governing cybersecurity and the national and international regulatory and legal framework of

cybersecurity (NIS2, ISO27001, NIST CSF, CIS Controls, GDPR), as well as obtaining the necessary Certifications

(PCI-DSS).

● An integrated cybersecurity risk management framework through threat identification assessments and

operational impact mitigation for the Organization's activities and operations.

● Implement staff training programmes to promote a cybersecurity culture.

Cooperation with cybersecurity bodies (NSAs, CSIRT, ENISA) to share critical security information related to incidents.

2. Technical Protection Measures

● Network Intrusion Detection and Prevention Systems (IDS/IPS) for monitoring and analysing network traffic.

● Use of firewalls with corresponding network and application level access control settings (Web Application

Firewall - WAF).

● System of uninterrupted surveillance and incident and breach detection (SOC/SIEM) for continuous

surveillance and automatic notification in case of detection of threats and/or breaches.

● Implementation of an EDR (Endpoint Detection & Response) and IT resource management (ITAM) solution.

3. Threat Management and Incident Response

● Regular penetration testing, finding and managing critical vulnerabilities in corporate systems (Vulnerability

Assessment & Penetration Testing).

● Implementation of a Cyber Threat Intelligence solution to monitor and collect security critical information from

the Deep and Dark Web.

399

● Develop business continuity management policy, disaster recovery and incident response plans.

Access to Water

The Greek State, according to the contract of Law 4812/2021, has the obligation to supply EYDAP SA with raw water

of sufficient quantity to cover the needs of its consumers and of sufficient quality in accordance with the requirements

of the legislation.

For EYDAP SA, the continuation of providing high quality water supply and sewerage services at an affordable price for

consumers, customer service through structured and digital processes, is part of business continuity and growth. The

risks that arise are related to customer arrears, customer affordability, reduction of available resource due to climate

change, loss of resource due to network failures, along with loss of customer confidence.

Access to Sanitation and Management

The Sustainable Development of Attica is firmly linked to the responsible and effective management of wastewater.

Today, EYDAP SA, as the largest company in Greece active in the water cycle, takes care of the collection and treatment

of wastewater and returns to the environment treated water free of pollutant load, applying the most modern

international practices.

The integrated management of the wastewater of the areas under the jurisdiction of EYDAP SA is a strategic objective

of the company. The company's commitment is the continuous and dynamic presence in this sector, through its

undisputed high level of expertise and with the main objective of protecting natural resources, the use of modern

methods of circular economy and the continuous improvement of the quality of life of citizens.

The maintenance of the good environmental status of the marine ecosystem is a key concern of EYDAP SA. The

Company, in the context of its activities, takes all necessary preventive measures to ensure its protection. Please see

also S3-4_04 _12, regarding the environmental impact assessment for the marine ecosystem

The operation of EYDAP SA and especially the disposal and treatment of wastewater from residences, institutions,

factories or other facilities is based on the regulatory provisions of Greek and European legislation and corporate

initiatives.

Personal Data Protection

EYDAP SA, as a Data Controller, places particular emphasis on the protection of its customers' personal data both

during collection - and this applies to all physical or electronic sources - and during processing and maintenance. It

takes particular care to implement the technical and organisational measures provided for by the current legislative

framework and invests in the appropriate training of its human resources by area of specialisation. EYDAP SA, in order

to inform consumers on Personal Data Protection issues, updates and updates the Consumer Privacy Policy, through

the account (printed or electronic form), the official corporate website eydap.gr, app applications and directly when a

request is made. In cases of use of electronic applications of EYDAP SA or the electronic services provided through its

website as well as in face-to-face transactions, further special information is provided to the user through simple and

clear terms of use and special updates - Privacy Policies regarding the processing of his/her data.

All personal data subject to processing by EYDAP SA have been brought to its knowledge by the Subject or a person

authorised by the Subject or result from manifestly disclosed data or Public Authorities to which the Company has legal

access and is limited in the context of servicing the water supply contract and informing the consumer. Where

applicable and in the context of serving the Company's legal obligations, the data may be disclosed to public authorities

(e.g. the AADE, judicial or investigative authorities), which process the data as third party and independent Data

Processors for a specific and sole purpose, as determined by the legal framework. In case of the necessity to issue

statistical data and for the general optimization of the services provided by the Company, the competent Services of

400

the Company take care of procedures for the anonymization of personal data, ensuring the prior notification of the

Subjects. EYDAP SA evaluates, examines, responds and, in some cases, satisfies every query submitted to it, with a

particular sense of responsibility and respect towards the consumer, in compliance with the relevant Policies and

Procedures, which it applies within the timeframes defined by the regulatory framework.

S4.SBM-3_07 _08

Access to Water

The Company's pricing policy through tiered tariffs, special tariffs, management of customer debts aim, on the one

hand, to respond to a large extent to the actual needs of households and businesses and, on the other hand, to ensure

the resilience and financial stability of EYDAP SA.The existence of an affordable tariff reflects in practice the support

of society, ensures the mitigation of social inequalities and protects vulnerable groups of the population from

deprivation of basic social goods. EYDAP SA undertakes important initiatives within the framework of its tariff policy

to support vulnerable social groups, recognizing the difficult economic situation experienced by the Greek society.

Support of socially vulnerable groups: through institutionalized decisions of the Board of Directors of the Company, a

discount is provided on their bills: Groups covered by the EET, Large Families, and Elderly Customers. In addition, the

Company, taking into account social and income criteria and applying institutionalized procedures, provides discounts

on increased consumption bills and also on water poaching bills.

Privacy

The company has not identified consumers/end users with particular characteristics, as well as those working in

specific contexts or those using specific products or services who may be at greater risk of harm.

401

Impact and risk management

[S4-1] Policies related to consumers and end-users

S4.MDR-P_01-06_01_02_03_04_05_06

The Company has adopted and applies the following Policies to manage the significant impacts and risks to all

consumers and/or end users:

● Charter of Obligations to the Consumer

● Accessibility Statement

● Consumer Privacy Policy.

The policies cover all consumers.

MAP OF OBLIGATIONS TO THE CONSUMER

Key content (overall objectives, significant impacts and risks, monitoring process) and attention given to the interests

of key stakeholders in the policy definition

The Charter outlines all the obligations of EYDAP SA towards its consumers, and includes provisions related to the

management of:

● Consumers' Requests and Undertaken Obligations of EYDAP SA for their resolution

● Other liabilities of EYDAP SA

● Consumer Compensation

● Dispute Resolution Procedure

● Exceptions

EYDAP SA is obliged to inform the Consumer Protection Committee on the implementation of the provisions of the

Charter of Consumer Obligations, as well as any amendments to this Code, in order to serve the consumer and improve

its services. The Charter is directly related to the risk of lack of access to water.

Scope of application

The Consumer Commitments Map includes all consumers throughout the geographical scope of the company's

operations.

Top level in the organisation of the company responsible for policy implementation.

The highest level responsible for consumer obligations is the General Directorate for Customers.

Reference to the standards or initiatives of third parties that the undertaking undertakes to

Government Gazette No. 60/2-2-1998 published Government Gazette No. D16ig/015/38G/28 -2 1998, according to

which the Charter of Obligations of EYDAP SA to consumers was approved.

By means of Decision No. Z1-647/2-6-2006 of the General Secretariat of Consumer Affairs of the Ministry of

Development and after the application of Law 3429/05 and especially article 7 par. 3 on "Public Enterprises and Public

Utilities Organizations" Government Gazette 314/A , every Public Enterprise that offers products or services to

consumers is required to have drawn up a Charter of Obligations to Consumers that defines the statutory obligations,

the conditions under which the Public Enterprise provides its products or services to consumers and the procedure for

compensation to consumers in case of non-compliance with the above obligations and conditions.

The Board of Directors' Decision 15858/4-4-2007 approved the reformed Charter of Obligations to Consumers (C.O.C.)

of E.Y.D.A.P. S.A., which is still in force today.

402

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in its

implementation

The map is available on the company's website. The customer can go to any of the Company's services that deal with

the public and submit the relevant complaint, by recording it in the "Contact Form" provided and established by EYDAP

SA. Also, the Company must inform the Consumer Protection Committee, regarding the implementation of the

implementation of the stated in the Charter of Consumer Obligations, as well as any amendments to this Charter , in

order to serve the consumer and improve the services provided by the Company.

ACCESSIBILITY STATEMENT

Basic content (general objectives, major impacts and risks, monitoring process)

EYDAPP SA commits to make the relevant website https://www.eydap.gr and the EYDAPP mobile application

accessible, in accordance with the provisions of Law No. 4727/2020 (Government Gazette 184 A' 23-09-2020), as in

force.

This Accessibility Statement is made to assess the compliance of the Company's website and its implementation with

the requirements of Directive (EU) 2016/2102 and WCAG 2.1 (Level A and Level AA).The Digital Experience Design

Service ensures the continuous improvement of the accessibility of the website, always with a view to ensuring equal

and seamless use by everyone, regardless of their physical abilities or technology.

In an ongoing effort to continuously improve and remedy any accessibility issues, we regularly scan the relevant

website with UserWay's accessibility scanner to identify and fix any potential accessibility barriers on the website.

Despite our efforts to make all pages and content on the website and app fully accessible, some content may not yet

be fully adapted to the stricter accessibility standards.

In particular, the UserWay website accessibility widget has been integrated into the website and app, powered by a

dedicated accessibility server (offering a range of functions for use by people with disabilities - including those with

visual, hearing, cognitive and motor impairments). With this Widget, most accessibility issues are resolved for Level

AA of WCAG 2.1. The Statement is directly related to Cybersecurity Risks.

Scope of application

Please see requirement S4.MDR-P_01-06_01_02_03_04_05_06.

The Accessibility Statement includes all users of the corporate website regardless of their geographical location or

status.

The accessibility statement includes all consumers across the geographic scope of the company's operations.

Top level in the organisation of the company responsible for policy implementation.

The Service responsible for accessibility issues and for the processing of related requests is the Digital Experience

Design Service (e-mail: y_sepse@eydap.gr)

Reference to the standards or initiatives of third parties that the undertaking undertakes to

EYDAPP SA commits to make the relevant website https://www.eydap.gr and the EYDAPP mobile application

accessible, in accordance with the provisions of Law No. 4727/2020 (Government Gazette 184 A' 23-09-2020), as in

force. The company's website partially complies with the accessibility requirements of Article 39 of Law No. 4727/2020

and partially with the WCAG 2.1 (Level AA) standard.

Attention paid to the interests of key stakeholders in the definition of policy

403

The Digital Experience Design Service is committed to the continuous improvement of the accessibility of the website,

always with a view to ensuring equal and seamless use by everyone, regardless of their physical abilities or technology.

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in its

implementation

The Declaration is available on the company's website. In accordance with the provisions of paragraph b. 4 of Art. 42

and para. 1 Art. 45 ν. 4727/2020 (Government Gazette 184 A' 23-09-2020), any interested party has the right to submit

comments or a request for information regarding the compliance status or a request for missing information. The

communication with EYDAP SA regarding the improvement of the accessibility of the content and the identification of

possible accessibility problems can be made by email at y_sepse@eydap.gr , as well as in writing to the postal address

156 Oropou, Galatssi, T.K. 111 46, Athens.

CONSUMER DATA PROTECTION POLICY

Basic content (general objectives, major impacts and risks, monitoring process)

The purpose of this privacy policy is to inform you about the type of personal data collected by the company, the way

they are processed (collection, storage, use, transfer), the means of their protection and the rights that users have

against this processing, which in any case is carried out in a reliable and transparent manner. In order to make

transparent the way personal data are collected, used and exchanged and to disclose the purpose and means of

processing, the company provides its consumers with the following information:

- What information we collect and in which cases

- What is the legal basis of the processing?

- Disclosure to third parties

- Retention of data

- Consumer rights and their exercise

- Technical and organisational measures to safeguard both technological and physical security

In order to safeguard privacy, it applies best practices to secure consumers' personal data through the implementation

of the necessary technical and organisational measures set out in the GDPR. Data is safeguarded against the loss of

availability, integrity and confidentiality of information.

- What happens in the event of a breach of consumer data: The Policy is directly related to Cybersecurity and Privacy

risks.

Scope of application

Please see requirement S4.MDR-P_01-06_01_02_03_04_05_06.

The Consumer Privacy Policy includes all consumers across the geographic scope of the company's operations.

In cases of use of electronic applications of EYDAP SA or the electronic services provided through its website, further

special information is provided to the user through simple and clear terms of use and special updates - Privacy Policies

regarding the processing of data."

Therefore, if the consumer uses online services, e.g. is an identified user, he/she enjoys services related to the water

contract through a website where there are specific policies, statements and terms of use

404

Highest level in the organisation of the company responsible for policy implementation

The role of the DPO is advisory, his/her duties are defined in Article 39 of the GDPR and he/she is not personally liable

for non-compliance with the GDPR. Responsible for ensuring and demonstrating that the DPO's processing operations

are in compliance with the GDPR and those referred to in the policy currently under discussion is the i.e. the executive

body authorised by the Board of Directors and has the accountability responsibility.

Reference to the standards or initiatives of third parties that the undertaking undertakes to

EYDAP SA is in continuous harmonization and compliance with the terms of the General Regulation (EU) 2016/679 on

the protection of natural persons with regard to the processing of personal data and on the free movement of data

and makes every effort to comply with it.

Finally, the company applies to its interactive Websites, the secure communication protocol SSL (Secure Sockets Layer)

with strong 128-bit encryption, which ensures the confidentiality and inviolability of transactions and your personal

data.

It is drawn up in accordance with the requirements of the GDPR, the relevant WP quidelines, decisions and opinions

of the independent data protection authorities, the European Supervisor, and other competent bodies

Attention paid to the interests of key stakeholders in the definition of policy

Please see the notification requirement S4.MDR-P_01_02_02_03_04_05_06. "As part of the Sustainability Policy, the

Board identifies in the Annual Management Report the non-financial issues that are deemed essential to the realization

of its vision and strategy, taking into account the requirements of its stakeholders."

Availability of the policy to potentially affected parties, as well as to stakeholders who should assist in its

implementation

The Consumer Data Protection Policy of EYDAP SA is posted on the corporate website EYDAP SA-

CONSUMERFRAMEWORK PRIVACY .

S4-1_02 _03_04_06_07

Commitments on Human Rights Policy

Commitments & respect for human rights - Procedures and mechanisms for monitoring compliance - Alignment with

internationally recognised instruments

Consumers do not fall within the scope of the Human Rights Policy.

However, in accordance with the notifications related to Article 8 of the EU Taxonomy Regulation on minimum social

safeguards, an assessment of EYDAP SA and its subsidiaries has been carried out with regard to the requirements of

minimum social safeguards, which have been established in accordance with Article 18 of EU Regulation 2020/852.

Essentially, these are derived from a set of defined guidelines of the UN, the EU and other international organizations,

as follows:

● OECD Guidelines for Multinational Enterprises (OECD Guidelines for Multinational Enterprises)

● United Nations Guiding Principles on Business and Human Rights (UN Guiding Principles on Business and

Human Rights-UNGP)

● Declaration of the International Labour Organization on Fundamental Principles and Rights at Work

405

● International Bill of Human Rights

According to the Final Report on Minimum Safeguards of the Platform for Sustainable Finance, the minimum social

safeguards relate to the following areas:

● Human rights, including labour rights

● Corruption and Bribery

● Taxation

● Fair competition

All human rights included in the ILO Fundamental Conventions and the International Bill of Human Rights are taken

into account in the United Nations Guiding Principles on Business and Human Rights. Therefore, the assessment on

minimum social safeguards was mainly based on the OECD Guidelines for Multinational Enterprises and the UN Guiding

Principles on Business and Human Rights.

406

S4-1_05

Measures that provide and/or enable remediation of human rights impacts

The Company's Human Rights Policy must be strictly observed by all those who fall within its scope, such as the

Company's relevant workforce, directly affecting consumers, for whom it is not explicitly applicable. In this context, no

violation will be accepted - and indeed in the event of a violation of human rights - the procedure for the imposition

of legal sanctions will be activated. In the event that a human rights-related principle is indeed violated or there is a

reasonable suspicion of such a violation, then the relevant report/complaint should be submitted to the Company, in

accordance with the Whistleblowing Policy.

S4-1_08

The Compliance Division has drafted a Complaints Policy, which is expected to be approved by the Board of Directors

by the end of 2025, and has completed the update of the Complaints Management Policy and the Code of Ethics and

Professional Conduct, but they still need to be approved by the Compliance Committee and the Board of Directors.

Discussions have also been held with the General Directorate for Customers and the Legal Services Directorate to

update the Consumer Charter.

S4-1_09

Notification and availability of policies

Charter of Obligations to the Consumer

The Charter is available on the company's website in the Regulatory Framework section.

Accessibility Statement

The Accessibility Statement is available on the company's website under Regulatory Framework - Accessibility.

Consumer Privacy Policy Consumer Data Protection Policy

The Policy is posted on the company's website, sent by mail (with the account form) and through the applications. It

is also available in public places and is available together with relevant information statements. Per category of

personal data processing there may be a relevant statement/policy e.g. shareholders.

The Directorate of Education shall carry out relevant training programmes.

407

[S4-2] Procedures for engaging with consumers and end-users on impacts

S4-2_01

Impact of consumer and end-user views on the Company's decisions or activities related to impact management

The company develops multi-level communication with consumers and end-users of its services:

Contact with Customers

• Personal contact (Regional Centres) - email

• 24-hour telephone service 1022

• social media

• Corporate website

• Click2Call- Callback: for toll-free service

• EHRC & EydApp: for electronic processing of requests and useful updates and information

• Customer satisfaction survey

• Participation in the prioritisation process of Substantive Issues

Contact with Large Customers

EYDAP SA maintains communication channels to ensure effective interaction with all stakeholders. According to

indicators SBM-2_04 and SBM-2_06, the company takes into account the views and interests of stakeholders through

the due diligence process and the assessment of material issues. Communication channels include:

• Personal and email communication

• 24-hour telephone service 1022

• Click2Call- Callback: for toll-free service

• EHRC & EydApp: for electronic processing of requests for useful updates and information

• Participation in the prioritisation process of Substantive Issues

Communication with Public Authorities as consumers of EYDAP SA

• Personal and email communication

• 24-hour telephone service 1022

• Click2Call- Callback: for toll-free service

• EHRC & EydApp: for electronic processing of requests for useful updates and information

• Participation in the prioritisation process of Substantive Issues

408

S4-2_02

Please see requirement S4-2_01.

EYDAP SA communicates directly with the affected consumers and/or end users or their legal representatives or with

reliable proxies who are aware of their situation by phone, email and sms depending on the request they have

submitted.

In case the consumer is a registered user, he has a complete overview of all his requests concerning his supply and

their status.

S4-2_03

Explanation of the stages, type and frequency of cooperation.

The frequency of cooperation depends on the consumer, i.e. when they request something, when they have a problem

or want some information either in person, online or by telephone

Table 54. Stages at which cooperation takes place, type of cooperation and frequency of cooperation with consumers and end-

users

Type of cooperation

Stages

Frequency

Personal and email

communication

Communication and information

Where appropriate

Corporate website

Communication and information

Where appropriate

24-hour telephone service 1022

Communication and information

Where appropriate

Participation in the

prioritisation process

Identification of material issues for

suppliers

Where appropriate

S4-2_04

The highest level with operational responsibility for ensuring cooperation with consumers and end-users

The Company recognizes that its cooperation with end users and consumers is ensured through the possibility of

expressing the latter's views on important issues, and that it is important for its executives to assume operational

responsibility in order to make every effort to manage them. For this reason, management is informed in various ways

about consumer activities and takes decisions accordingly.

S4-2_05

How to assess the effectiveness of cooperation with consumers and/or end-users - Agreements or results of

cooperation

Management, informed by statistical reports, evaluates the effectiveness of its cooperation with consumers and takes

appropriate decisions.

S4-2_06

Measures to obtain the views of people who may be particularly vulnerable to impacts and/or marginalised

409

The Digital Experience Design Service is committed to the continuous improvement of the accessibility of the website,

always with a view to ensuring equal and seamless use by everyone, regardless of their physical abilities or technology.

410

[S4-3] Channels for consumers and end-users to raise concerns

S4-3_02 _03_04_05_06

Procedures and channels for raising concerns or needs and addressing them - Establishment of channels by the

company itself and/or through participation in mechanisms

The company has developed a number of channels to receive complaints from consumers. In particular:

● Managing complaints through distinct contact channels,

● the Regional Centres of EYDAP SA,

● line 1022,

● the company's email eydap.gr (24/7)1022@eydap.gr , and

● the eydap.gr click2call-callBack.

For 2024, 162,604 complaint calls were made about problems with water and sewerage networks. On line 1022

complaints about water quality are made.

Availability of channels to consumers and/or end-users

The business requires the availability of channels for the purpose of reporting consumer concerns or needs if it is a

Public Benefit Corporation under its Articles of Incorporation.

Identifying and monitoring issues

The Company has a Policy for the Management of Reports - Complaints regarding issues of the Privacy Regulation. The

Policy is posted on the corporate website eydap.gr and on the internal corporate website (portal).

The Company makes available to the Petitioners communication channels that enable them to submit reports

regarding incidents falling under the provisions of this Policy. Incident reports must be submitted within a reasonable

time after the facts came to the attention of the Reporting Party, be clear, definite and substantiated, and be made

either by e-mail or by mail. The relevant channels of communication are listed at the end of this document and are

posted on the Company's website.

If a report that falls within the scope of this policy is sent to another unit of the Company, the latter must forward it.

During the reporting period (2024) there were only a few requests-complaints from the customers of EYDAP SA, the

management of which was immediate and satisfactory with positive comments from some of the customers regarding

the management of these. In addition, two incidents of violation were notified to the EAPC, one of which ended with

a recommendation.

The temporary technical malfunction in the recorded call records kept by the Cosmote e-value Contractor since

December 2023, which was assessed as a breach incident due to the unavailability of part of the recorded calls, is still

open at the beginning.

It should be noted that with the decision 10/2024 of the Hellenic Data Protection Authority, the pending case of the

2022 breach of customers' Personal Data by a third-party External Partner, namely by ELTA, was closed favourably for

EYDAP.

Ensuring channel efficiency

Requests submitted under the GDPR to the email of the Data Protection Officer are determined by a specific legal

framework set out in the GDPR. Because of this and the nature of the GDPR there is a trust and a duty of legitimacy.

Policies on the protection of individuals against retaliation

411

The Policy for the Management of Reports-Complaints provides for the operation of a mechanism for the submission

of reports and the procedure for their management, based on the principle of confidentiality and ensuring non-

retaliation. The Policy describes how to submit a complaint (by e-mail (whistleblowing@eydap.gr), or by post to EYDAP

SA - Regulatory Compliance Service) and the procedure for receiving and evaluating them by the Committee for the

Evaluation of Reports.

Retaliation: Any direct or indirect action or threat of action or omission against the reporting party that occurs because

of the report and takes place in a work-related context and causes or may cause undue harm to the reporting party,

including harassment, discrimination, negative evaluations and retaliation (detailed in the relevant section 10 of this

document). Confidentiality / Confidentiality of identity: In cases where the report is anonymous, the identity of the

reporting party shall be kept confidential by the recipient of the information vis-à-vis the person(s) who may be

involved in the serious irregularity reported and shall only be used in cases where absolutely necessary. Anonymity:

The situation in which the identity of the source of the information is not known to the recipient.

S4-3_09

Accessibility to channels at the enterprise level

All consumers who may be affected can access channels at the enterprise level. In person, by telephone and

electronically.

S4-3_11

Protecting people who use the mechanisms against

EYDAP SA has a Whistleblowing Policy, under which its employees and/or third parties are encouraged and encouraged

to report anonymously or anonymously any malfunctions, irregularities, omissions or criminal acts that have come to

their attention, as well as to express any concerns, concerns or complaints regarding any violations of the Company's

policies or the legislative-regulatory framework governing its operation.

Reporting can be achieved by sending the report to 156 Oropou 156, 111 46 Galati, EYDAP SA, by email to

whistleblowing@eydap.gr or by using the online form on the organisation's website

(https://www.eydap.gr/Investors/CorporateGovernance/Whistle blowingApp/).

S4-3_12

Anonymity - Confidentiality. The Company, through the communication channels it establishes, gives the opportunity

to the petitioners to submit their report either anonymously or anonymously. However, the Company encourages

anonymous reports as this better achieves an assessment of the credibility of the report-complaint and the Petitioner's

intentions, and facilitates communication both for further clarification and to keep the Petitioner informed of the

progress of the report.

In the case of anonymous reports falling within the scope of paragraph 5.2, the Company undertakes to maintain the

anonymity of the complainant and not to take any action that may result in the disclosure of his/her identity. In the

event that a named report does not fall within the scope of paragraph 5.2 (e.g. routine management of customer

complaints), then the report will be forwarded as such to the competent services of the Company for further

management, in which case the anonymity of the complainant will not be preserved, given that for the examination

of the customer's request, the Company's services will have to know the complainant's details. Therefore, the attention

is drawn to the complainants not to submit reports, if their request concerns routine water supply, sewerage, damage,

illegal water intakes, debts and other related issues, but to contact the Company's Customer Service Units (1022,

Regional Centers, etc.) for their convenience. It is noted that the disclosure of the identity of the complainant may be

412

required in the context of any judicial investigation of the case or other legal proceedings. In this case, the anonymity

of any other persons involved in the report will be preserved, subject to the above restrictions.

S4-3_13

In 2024, a telephone customer satisfaction survey was carried out using a structured questionnaire in the Region of

Attica. 603 customers participated in the survey, based on a random selection of telephone numbers. The survey was

conducted by a market research company, member of the Greek and European Association of Market Research

Companies (SEDEA) and the World Association of Public Opinion Research Companies (WAPOR). 74% o EVDAP

satisfaction index at levels similar to 2013 (75%) +33 the Net Promoter Score (NPS) of the Company significantly

positive at almost 1 in 2 are promoters of the company.

413

[S4-4] Taking action on significant impacts on consumers and end-users and approaches to manage significant risks in

relation to consumers and end-users and the effectiveness of such actions

S4.MDR-A_01-12 & S4-4_03 _09

Summary description of action plans and resources to manage significant impacts

Access to Products and Services

Support to Society

The company applies a discount policy and takes precautionary measures to avoid the accumulation of debts and

applies debt repayment facilities through procedures approved by the Board of Directors, as specified in the Revenue

and Customer Receivables Management Policy of EYDAP SA (Board Decision 21010/2022). Main preventive actions of

the Company to minimize, as far as possible, the debts.

● Registered customers are immediately informed about the issuance of their account, choosing the way they

wish to be informed (sms, e-mail).

● Customers who have settled their debt are digitally informed for timely repayment of overdue instalments

● Digital information of identified consumers on issues of overdue instalments-increased consumption-

imminent water supply interruption.

● Sending an email to identified customers for credit cancellation, notification of increased consumption and also

by pasting a special form at the entrance of the property for all customers during their metering

● Written consumer information on debt issues

● The Company, taking into account social and income criteria and applying institutionalized procedures,

provides discounts on increased consumption bills and on water extraction bills.

● Through statutory decisions of the Board of Directors of the Company, a discount is provided on bills for the

support of socially vulnerable groups such as beneficiaries of the Social Tariff, large families and senior citizens.

Pricing Policy

The existence of an affordable tariff reflects the support of society, ensures the mitigation of social inequalities and

protects vulnerable groups of the population from being deprived of the basic social good, water.

Personal Data Protection

EYDAP SA, as a Data Controller, places particular emphasis on the protection of its customers' personal data both

during collection - and this applies to all physical or electronic sources - and during processing and maintenance. It

takes particular care to implement the technical and organisational measures provided for by the current legislative

framework and invests in the appropriate training of its human resources by area of specialisation.

EYDAP SA, in order to inform consumers on Personal Data Protection issues, updates and publishes the Consumer

applications and directly when a request is made. In cases of use of electronic applications of EYDAP SA or the

electronic services provided through its website, further specific information is provided to the user through simple

and clear terms of use and specific updates - Privacy Policies regarding the processing of data.

All personal data subject to processing by EYDAP SA have been brought to its knowledge by the Subject or a person

authorised by him/her or result from obviously disclosed data or Public Authorities to which the Company has legal

access and is limited in the context of servicing the water supply contract and informing the consumer. Where

applicable and in the context of serving the Company's legal obligations, the data may be disclosed to public authorities

414

(e.g. the AADE, judicial or investigative authorities), which process the data as third party and independent Data

Controllers for a specific and sole purpose, as defined by the legal framework. In case of the necessity to issue statistical

data and for the general optimization of the services provided by the Company, the competent Services of the

Company take care of procedures for the anonymization of personal data, ensuring the prior notification of the

Subjects.

EYDAP SA evaluates, examines and responds and, where appropriate, satisfies any query submitted to it with a

particular sense of responsibility and respect towards the consumer, in compliance with the relevant Policies and

Procedures, which in principle it applies within the legal timeframes set by the regulatory framework. For matters

relating to the protection of personal data, there is a contact email dpo@eydap.gr where anyone who wishes to make

a request concerning matters relating to personal data may contact.

Please see requirement S1.MDR-A_01-1 (Privacy)

EYDAP SA is in the process of obtaining an insurance policy to cover itself against a cybersecurity incident, which is

expected to be completed within 2025.EYDAP SA has received PCI/DSS certification for the protection of payment card

holders' data (such as credit and debit cards).

415

S4.MDR-A_01

Access to Products and Services - Support to Society & Pricing Policy

Key actions, expected results and how the implementation of actions contributes to the achievement of the objectives

and aims of the policy

The implementation of actions related to Access to Products and Services contributes to the achievement of the

objectives and aims of the Consumer Charter and the Accessibility Statement. Please see also requirements S4.MDR-

A_01-12 the paragraphs "Support to the Community" and "Pricing Policy" and S4.MDR-P_01-06_01_02_03_04_05_06.

Health and Safety - Personal Data Protection

Key actions, expected results and how the implementation of actions contributes to the achievement of the objectives

and aims of the policy

Please see requirement S4.MDR-A_01-12 in the "Privacy" section regarding key actions.

The implementation of actions related to the protection of personal data contributes to the achievement of the

objectives and purposes of the Consumer Data Protection Policy. Please see also requirement Please see also

requirement S4.MDR-P_01-06_01_02_03_04_05_06.

Privacy - Cybersecurity

Key actions, expected results and how the implementation of actions contributes to the achievement of the objectives

and aims of the policy

Please see the S1.MDR-A_01 (Privacy) disclosure requirement regarding the cybersecurity incident insurance policy

and PCI/DSS certification for the protection of payment cardholder data

S4.MDR-A_02_03

Access to products and services

Support to Society & Pricing policy

Scope of application

The Company's pricing policy through tiered tariffs, special tariffs, management of customer debts aim, on the one

hand, to respond to a large extent to the actual needs of households and businesses and, on the other hand, to ensure

the resilience and financial stability of EYDAP SA.

● Household Tariff (granted to the majority of consumers): 2.215.089

● Special Tariffs: 3.485 Connections

● Escalating tariff

Please see the notification requirement E3.MDR-A_01 according to ESRS2 para. 68a.

The tiered tariff acts as a deterrent to waste of the natural resource and raises awareness among consumers to adopt

a rational use of the resource.

Time horizon of key actions

Please see requirement S4.MDR-A_01-12 the sections "Support to Society" and "Pricing Policy".

Health and Safety - Personal Data Protection

Scope of application & Time horizon of key

416

Please see requirement S4.MDR-A_01-12 in the section "Privacy".

Privacy - Cybersecurity

Scope of application & Time horizon of key actions

Please see the S1.MDR-A_01 (Privacy) disclosure requirement regarding the cybersecurity incident insurance policy

and PCI/DSS certification for the protection of payment cardholder data.

S4.MDR-A_05

Access to products and services

Social inclusion of consumers and/or end-users

Mission 2025

Supporting society by providing affordable services and tariff facilities

Health and Safety

Protection of personal data of consumers and/or end users

Mission 2025

The company has conducted training on Data Protection issues.

Privacy

Protecting against the effects of cyber-attacks involving consumer and/or end-user data

Mission 2025

Actions on Cybersecurity Issues:

● Establishment of an Information Security Management System (ISMS) framework in accordance with the

principles governing cybersecurity and the national and international regulatory and legal cybersecurity

framework (NIS2, ISO27001, NIST CSF, CIS Controls, GDPR).

● An integrated cybersecurity risk management framework through threat identification assessments and

operational impact mitigation for the Organization's activities and operations.

● Implement staff training programmes to promote a cybersecurity culture.

S4.MDR-A_06 _07_08_09_11_12

Please see the disclosure requirement S1.MDR-A_06_07_09_10_11_12.

S4-4_04

Please see disclosure requirement S4-3_13.

S4-4_08

Please see the notification requirement S3-4_08_09.

417

S4-4_11

Serious human rights issues and incidents involving consumers and/or end-users

Please see requirement S4-3_02_03_04_05_06 - Identifying and tracking issues.

S4-4_12

EYDAP SA, in order to evaluate the effectiveness of its corporate policies and actions, governed by the Sustainable

Development Strategy and Regulatory Compliance, has defined clear objectives and performance indicators (KPIs).

These indicators are monitored regularly (quarterly), allowing the timely identification of areas for improvement and

the development and implementation of actions aimed at enhancing transparency, accountability and responsibility

at all hierarchical levels of the company.

Please see also the requirements S4.MDR-P_01-06_01_02_03_04_05_06, S4.MDR-A_01-12 and S4.MDR-T_01-13.

418

Measurement indicators and targets

[S4-5] Objectives related to promoting positive impacts and managing significant risks

S4.MDR-T_01-13

The summary description of the objectives for the management of significant impacts, risks

With responsibility, specialised expertise and a consistent people-centred approach, EYDAP SA has been managing the

water cycle effectively for decades. It ensures the supply of clean water to all citizens of Attica without discrimination,

while at the same time it is committed to returning water back to the environment in excellent quality, contributing to

sustainable development and the protection of natural resources.

The Company's main objectives related to consumers and/or end users:

The objectives relate to

1. cybersecurity

EYDAP SA, recognizing that its activities and services are increasingly dependent on digital technologies, invests in

ensuring the protection of consumer data. It provides continuous training for its employees to ensure resilience to new

threats.

A direct indicator measuring cybersecurity issues has not been defined.

Two indirect indicators have been defined:

● Indicator C1: Number of confirmed non-compliances with targeted regulations (each year) zero [0]

● Indicator C2: Strategic absorption rate of the Investment Plan for operational resilience with targeting - for

2024 - >73%

2. consumer access to drinking water

EYDAP SA is committed to ensuring the uninterrupted supply of clean and safe drinking water to all citizens. It has set

targets to reduce water supply interruptions and improve water quality in accordance with the most stringent

international standards.

A direct indicator, and thus a target measuring access to drinking water from the perspective of consumers [DG

Customer] has not been defined.

● Two indirect indicators have been defined indicator C3: Percentage of drinking water quality controls within

legal limits with a target for 2024 > 99.5%

● Indicator C9: Customer satisfaction with a target of > 75%

3. the protection of consumers' personal data

EYDAP SA applies policies for the protection of consumers' personal data in accordance with the standards of GDPR. It

has set a goal of full compliance with regulatory requirements and continuous improvement of transparency in data

management.

A direct indicator measuring privacy issues has not been defined. Indirect indicator C1: Number of confirmed non-

compliances with targeted regulations (each year) zero [0] also covers this issue.

S4.MDR-T_08

419

There are no milestones and intermediate targets for 2024.

S4.MDR-T_12

No changes have been made to the objectives and corresponding measurement indicators or underlying measurement

methodologies, major assumptions, limitations, sources and procedures for data collection.

S4-5_01 _02_03

EYDAP SA has not currently established procedures for the setting of targets through direct cooperation with consumers

and/or end-users or their legal representatives, as well as for the communication of targets to consumers and end-

users.

However, it emphasises the positive impacts, such as access to products and services, but also the risks, such as privacy

and consumer health and safety, which are consistently monitored through relevant actions. The Company is

considering the possibility of developing target setting processes for consumers and end users to enhance overall

transparency and efficiency

These objectives are fully correlated with the objectives of the Sustainable Development Policy. Please see also

requirement S4.MDR-P_01-06 _01_02_03_04_05_06.

Access to drinking water (products and services)

Access to drinking water for consumers is directly related to the policy objectives of Consumer Health and Safety, and

Drinking Water Quality. The aim is to provide equitable access to excellent quality drinking water at an affordable price

for consumers. EYDAP's mission is to provide quality and cheap drinking water to more and more citizens and to return

it back to the environment in a clean way, through the efficient management of all available resources, with social

sensitivity and with a view to contributing to social welfare.

Protection of consumers' personal data

This is part of the Customer Service with Safety policy objective. EYDAP SA, as a Data Controller, places particular

emphasis on the protection of its customers' personal data both during collection - and this applies to all physical or

electronic sources - and during processing and maintenance. It takes particular care to implement the technical and

organisational measures provided for by the current legislative framework and invests in the appropriate training of its

human resources by area of specialisation.

Cybersecurity

Cybersecurity is part of the Digital Transformation policy objective. EYDAP SA has made it a priority to shield itself

through an organised cybersecurity framework, always in line with current legislation. Taking into account the

Community and national legislative provisions, EYDAP SA has set as a priority to ensure the uninterrupted and

uninterrupted operation of its information and network systems, in the context of shielding the digital ecosystem and

strengthening the digital transformation. EYDAP SA has ensured immediate response services in case of detection of a

cybersecurity incident, by participating in the funded Cybersecurity Support Services Action of ENISA (European Union

Agency for Cybersecurity) through the National Cybersecurity Authority for the FIS of the EU Member States

420

Annex 1

Data points from the list of Notification Requirements (IRO-2_01)

Disclosure requirement

Location in the sustainability

statement (page/paragraph)

[BP-1] General basis for the preparation of the sustainability statement

Page. 121

[BP-2] Disclosures in relation to special circumstances

Page. 123

[GOV-1] The role of the administrative, management and supervisory bodies

Page. 126

[GOV-2] Information received and sustainability issues considered by the

company's administrative, management and supervisory bodies

Page. 135

[GOV-3] Integrating sustainability-related performance into incentive schemes

Page. 137

[GOV-4] Declaration on due diligence

Page. 140

[GOV-5] Risk management and internal controls on sustainability reporting

Page. 142

[SBM-1] Strategy, business model and value chain

Page. 144

[SBM-2] Interests and views of stakeholders

Page. 159

[SBM-3] Significant impacts, risks and opportunities and their interaction with

the strategy and business model

Page. 167

[IRO-1] Description of procedures for identifying and assessing significant

impacts, risks and opportunities

Page. 178

[IRO-2] Disclosure requirements in ESRS covered by the viability statement of

the entity

Page. 191

[ESRS 2 SBM-3] Significant impacts, risks and opportunities and their

interaction with the strategy and business model

Page. 228

[E1-2] Policies on climate change mitigation and adaptation

Page. 235

[E1-3] Actions and resources related to climate change policies

Page. 236

[E1-4] Objectives on climate change mitigation and adaptation

Page. 248

[E1-5] Energy consumption and energy mix

Page. 249

[E1-6] Gross emissions of scopes 1, 2, 3 and total greenhouse gas emissions

Page. 252

[E1-9] Projected financial impacts of significant material and transition risks

and potential climate-related opportunities

Page. 258

[E3.MDR-P] Policies adopted to manage major sustainability issues

Page. 260

[E3-1] Policies related to water and marine resources

Page. 260

[E3.MDR-A] Actions and resources in relation to key sustainability issues

Page. 262

[E3-2] Actions and resources related to water and marine resources

Page. 262

[E3.MDR-T] Monitoring the effectiveness of policies and actions through

targets

Page. 277

[E3-3] Objectives on water and marine resources

Page. 277

[E3-4] Water consumption

Page. 278

[S1.SBM-3] Significant impacts, risks and opportunities and their interaction

with the strategy and business model

Page. 284

[S1.MDR-P] Policies adopted to manage major sustainability issues

Page. 288

[S1-1] Policies related to the workforce concerned

Page. 288

[S1-2] Procedures for engaging with the relevant workforce and employee

representatives on impacts

Page. 309

[S1-3] Procedures for the remediation of negative impacts and channels for

raising concerns by the workers concerned

Page. 313

[S1.MDR-A] Actions and resources in relation to important sustainability issues

Page. 316

[S1-4] Taking action on significant impacts on the relevant workforce and

approaches to manage significant risks and exploit significant opportunities in

relation to the relevant workforce and the effectiveness of these actions

Page. 316

[S1.MDR-T] Monitoring the effectiveness of policies and actions through

targets

Page. 331

421

[S1-5] Objectives related to managing significant negative impacts, promoting

positive impacts and managing significant risks and opportunities

Page. 329

[S1-6] Characteristics of the company's employees

Page. 333

[S1-7] Characteristics of non-salaried employees in the workforce of the

enterprise itself

Page. 337

[S1-10] Adequate wages

Page. 339

[S1-11] Social protection

Page. 339

[S1-14] Health and safety measurement indicators

Page. 339

[S1-16] Compensation measurement indicators (wage gap and total

compensation)

Page. 344

[S2.SBM-3] Significant impacts, risks and opportunities and their interaction

with the strategy and business model

Page. 347

[S2.MDR-P] Policies adopted to manage major sustainability issues

Page. 350

[S2-1] Policies related to workers in the value chain

Page. 350

[S2-2] Procedures for engaging with employees in the value chain in relation to

impacts

Page. 358

[S2-3] Procedures for remediation of negative impacts and channels for raising

concerns by workers in the value chain

Page. 360

[S2.MDR-A] Actions and resources in relation to important sustainability issues

Page. 363

[S2-4] Taking action on significant impacts on workers in the value chain and

approaches to manage significant risks in relation to workers in the value chain

and the effectiveness of these actions

Page. 363

[S2.MDR-T] Monitoring the effectiveness of policies and actions through

targets

Page. 365

[S2-5] Objectives related to managing significant negative impacts, promoting

positive impacts and managing significant risks and opportunities

Page. 365

[S3.SBM-3] Significant impacts, risks and opportunities and their interaction

with the strategy and business model

Page. 367

[S3.MDR-P] Policies adopted to manage major sustainability issues

Page. 371

[S3-1] Policies related to the affected communities

Page. 371

[S3-2] Procedures for engaging with affected communities in relation to

impacts

Page. 378

[S3-3] Procedures for remediation of negative impacts and channels for raising

concerns from affected communities

Page. 380

[S3.MDR-A] Actions and resources in relation to important sustainability issues

Page. 383

[S3-4] Taking action on significant impacts on affected communities and

approaches to manage significant risks and seize significant opportunities in

relation to affected communities and the effectiveness of these actions

Page. 383

[S3.MDR-T] Monitoring the effectiveness of policies and actions through

targets

Page. 392

[S3-5] Objectives related to managing significant negative impacts, promoting

positive impacts and managing significant risks and opportunities

Page. 392

[S4.SBM-3] Significant impacts, risks and opportunities and their interaction

with the strategy and business model

Page. 395

[S4.MDR-P] Policies adopted to manage major sustainability issues

Page. 401

[S4-1] Policies related to consumers and end users  

Page. 401

[S4-2] Procedures for engaging with consumers and end-users on impacts

Page. 407

[S4-3] Procedures for remediation of negative impacts and channels for raising

concerns from consumers and end-users

Page. 410

[S4.MDR-A] Actions and resources in relation to key sustainability issues

Page. 413

422

[S4-4] Taking action on significant impacts on consumers and end-users and

approaches to manage significant risks and exploit significant opportunities in

relation to consumers and end-users and the effectiveness of such actions

Page. 413

[S4.MDR-T] Monitoring the effectiveness of policies and actions through

targets

Page. 418

[S4-5] Objectives related to managing significant negative impacts, promoting

positive impacts and managing significant risks and opportunities

Page. 418

423

Annex 2

Data points from other EU legislation (IRO-2_02)

Disclosure

requirement and

relevant data point

Report

Reference to

the Regulation

Reference to

EU climate law

Location in

the

sustainability

statement

Importance of

information (Company

level)

ESRS 2 GOV-1

Gender diversity in

the Council paragraph

21 (d)

Indicator 13 of

Table #1 of Annex

Regulation (EU)

2020/1816,

Annex II

Page 129

Important at company

level

ESRS 2 GOV-1

Percentage of board

members who are

independent

paragraph 21 (e)

Regulation (EU)

2020/1816,

Annex II

Page 129

Important at company

level

ESRS 2 GOV-4

Declaration on due

diligence paragraph

Indicator 10 of

Table #3 of Annex

Page 140

Important at company

level

ESRS 2 SBM-1

Participation in

activities related to

the fossil fuel sector

paragraph 40(40)(d)(i)

Indicator 4 of

Table #1 of Annex

Regulation (EU)

2020/1816,

Annex II

Non applicable

Not significant at

company level

ESRS 2 SBM-1

Participation in

activities related to

the production of

chemicals paragraph

40(40)(d)(ii)

Indicator 9 of

Table #2 of Annex

Regulation (EU)

2020/1816,

Annex II

Non applicable

Not significant at

company level

ESRS 2 SBM-1

Involvement in

activities related to

controversial

weapons paragraph

40(40)(d)(iii)

Indicator 14 of

Table #1 of Annex

Regulation

2020/1818,

Article 12(1),

Regulation (EU)

2020/1816,

Annex II

Non applicable

Not significant at

company level

ESRS 2 SBM-1

Participation in

activities

linked to the

cultivation and

production

tobacco products

paragraph 40(d) iv

Regulation

2020/1818,

Article 12(1),

Regulation (EU)

2020/1816,

Annex II

Non applicable

Not significant at

company level

424

Galatsi, April 29, 2025

The members of the Board of Directors

Full Name

Capacity

George Stergiou

Chairman of the Board of Directors, non-Executive Member

Charalambos Sachinis

CEO, Executive Member

Antonios Giannikouris

Non-Executive Member

Christos Karaplis

Non-Executive Member

Eleni-Maria Kaymenaki

Non-Executive Member

Marika Lambrou

Independent Non-Executive Member

Anastasia Martseki

Independent Non-Executive Member

Marina Mavrommati

Independent Non-Executive Member

Efthymios Sfikas

Independent Non-Executive Member

Christos Mistriotis

Non-Executive Member

Panagiotis Skoularikis

Non-Executive Member

Emmanuel Angelakis

Non-Executive Member

Georgios Alexandrakis

Non-Executive Member

Exact Copy from No.1498

Minutes of the Board of Directors of April 29, 2025 "Approval of Individual and Consolidated Annual Financial Statements of EYDAP

S.A. in accordance with the InternationalAccounting Standards and the International Financial Reporting Standards (IFRS) of the

2023 Corporate Year and the Management Report of the Board of Directors of EYDAP SA."

The CEO

Charalampos Sahinis

425

Limited Assurance Report of the Statutory Auditor on the Sustainability

Report of the Water Supply and Sewerage Company of Protoprotousis

S.A.

To the Shareholders of the Company for Water Supply and Sewerage of the Capital Region S.A.

We have performed limited assurance work in respect of the consolidated Sustainability Report of the Water Supply and Sewerage

Company of Capital City S.A. (the "Company"), which is included in the "SUSTAINABILITY REPORT" section of the consolidated

Management Report of the Board of Directors (the "Sustainability Report"), for the period from 1 January 2024 to 31 December 2024.

Conclusion of limited assurance

Based on our work performed, as described below in the paragraph "Scope of Work Performed", and the evidence obtained, nothing has

come to our attention that causes us to believe that:

● the Sustainability Report was not prepared in all material respects, in accordance with article 154 of Law 4548/2018 as amended

and in force with Law 5164/2024, which transposed article 29(a) of Directive 2013/34/EU into Greek law

● the Sustainability Report does not comply with the European Sustainability Reporting Standards (hereinafter "ESRP"), in

accordance with Commission Regulation (EU) 2023/2772 of 31 July 2023 and Directive (EU) 2022/2464 of the European

Parliament and of the Council of 14 December 2022

● the process followed by the Company to identify and assess significant risks and opportunities (the "Process"), as set out in

section "[IRO-1] Description of Processes for Identifying and Assessing Significant Impacts, Risks and Opportunities" of the

Sustainability Report, does not comply with "Requirement IRO-1-Description of Processes for Identifying and Assessing

Significant Impacts, Risks and Opportunities" of EIAB 2 "General Disclosures"

● the disclosures in the "EU Classification Regulation" section of the Sustainability Report do not comply with Article 8 of EU

Regulation 2020/852

This assurance report does not extend to information on prior periods.

Basis for the conclusion

The limited assurance work was performed in accordance with the International Standard on Assurance Engagements 3000 (Revised),

"Assurance Engagements Other Than an Audit or Review of Historical Financial Information" (hereafter "ISA 3000").

In the context of a limited assurance engagement, the procedures to be carried out differ in nature and timing and are of a smaller scope

than in a reasonable assurance engagement. Consequently, the level of assurance obtained from such an assignment is significantly lower

than the level of assurance that would have been obtained if a reasonable assurance assignment had been carried out.

Our responsibilities are further described in the "Auditor's Responsibilities" section.

426

Professional Ethics and Quality Management

We have been independent of Company throughout this work and have complied with the requirements of the Code of Ethics for

Professional Accountants of the Council of International Standards on Auditing Ethics (ISA Code), the ethics 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 Audit Firms Performing Audits

or Reviews of Financial Statements and Other Assurance or Related Services Engagements" and therefore 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 obtained is sufficient and appropriate to provide a basis for our conclusion.

Responsibilities of the Company's Management for the Sustainability Report

The Company's management is responsible for designing and implementing an appropriate process for determining the required

information to be included in the Sustainability Report in accordance with the EIFS, as well as for disclosing the Process in the section

"[GOV-2] Information received and sustainability issues considered by the Company's governing, management and supervisory bodies"

in the Sustainability Report

More specifically, this responsibility includes:

● Understanding the context in which the Company's activities and business relationships take place, as well as understanding

their affected stakeholders

● The identification of actual and potential impacts (both negative and positive) related to sustainability issues, as well as the risks

and opportunities that affect, or are reasonably expected to affect, the economic position, financial performance and financial

position of the company.

● the Company's performance, cash flow, access to finance or cost of capital over the short, medium or long term

● Assessing the significance of identified impacts, risks and opportunities related to sustainability issues through the selection and

application of appropriate thresholds and

● The formulation of assumptions that are reasonable in the current circumstances

The Management of the Company is also responsible for the preparation of the Sustainability Report, in accordance with article 154 of

Law 4548/2018, as amended and in force by Law 5164/2024, which incorporated article 29(a) of Directive 2013/34 into Greek law.

In this context, the Company's Management is responsible for:

● Compliance of the Sustainability Report with the EIAB

● Preparation of notifications in the "EU Classification Regulation" module of the Sustainability Report, in compliance with the

provisions of Article 8 of EU Regulation 2020/852

● Such internal control as management determines is necessary to ensure that the Sustainability Report is free from material

misstatement, whether due to fraud or error; and

● Selection and application of appropriate reporting methods, including assumptions and estimates about individual disclosures

in the Sustainability Report that have been assessed as reasonable in the circumstances

The Company's Audit Committee is responsible for overseeing the process of preparing the Company's Sustainability Report.

427

Intrinsic limitations in the preparation of the Sustainability Report

As stated in the sections in the Sustainability Report "[BP-2] Disclosures in relation to specific circumstances" , "[IRO-1] Description of

procedures for identifying and assessing significant impacts, risks and opportunities", "ESRS 2 SBM-3 Significant impacts, risks and

opportunities and their interaction with the strategy and business model" and "EU Classification Regulation" the information incorporated

in the relevant disclosures is based on, among other things, significant estimates and assumptions, particularly in areas such as Scope 3

emissions, climate transition risks, risks from emerging natural hazards, assumptions for calculating BREs, and which are subject to

inherent uncertainty regarding the likelihood, timing or impact of future impacts due to limitations in available data and measurement

methods.

In disclosing forward-looking information under the SIFRS, the Company's management is required to prepare forward-looking

information based on disclosed assumptions about events that may occur in the future and possible future actions of the Company. The

actual outcome of these actions may be different, as anticipated events often do not occur as expected.

Our work covered the items listed in the "Scope of Work Performed" section to obtain limited assurance based on the procedures included

in the Program. Our work is not an audit or review of historical financial information in accordance with applicable International Standards

on Auditing or International Standards on Assurance Engagements, and therefore we do not express any assurance other than that set

out in the "Scope of Work Performed" section.

Responsibilities of the Auditor

This limited assurance report has been prepared in accordance with the provisions of article 154C of Law 4548/2018 and article 32A of

Law 4449/2017.

Our responsibility is to plan and perform the limited assurance engagement to obtain limited assurance as to whether the Sustainability

Report is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our

conclusion. An error may arise from fraud or error and is considered material when, individually or in the aggregate, it could reasonably

be expected to affect the financial decisions of users made on the basis of the Sustainability Report taken as a whole.

In the context of a limited assurance engagement in accordance with FRA 3000 (Revised), we exercise professional judgment and maintain

our professional skepticism throughout the engagement.

Our responsibilities with respect to the Sustainability Report, in relation to the Process, include:

● Conducting risk assessment procedures, including an understanding of the relevant internal controls, to identify risks relating to

whether the Process followed by the Company to determine the information reported in the Sustainability Report does not meet

the applicable requirements of the SIPAs, but not for the purpose of providing an opinion on the effectiveness of the internal

controls over the Process; and

● Designing and conducting procedures to assess whether the Process for identifying the information reported in the Sustainability

Report is consistent with the description of the Process as disclosed in the section "[GOV-2 Information received and

sustainability issues considered by the undertaking's administrative, management and supervisory bodies" of that Report

Further we are responsible for:

● Performing risk assessment procedures, including an understanding of the relevant internal controls, to identify those

disclosures that are likely to be materially misstated, whether due to fraud or error, but not for the purpose of expressing an

opinion on the effectiveness of the Company's internal controls

● Planning and performing procedures for those disclosures in the Sustainability Report where a material error is likely to occur.

The risk of not detecting a material misstatement resulting from fraud is higher than that resulting from error, as fraud may

involve collusion, forgery, intentional omissions, misrepresentation or the circumvention of internal controls

428

Scope of Work Performed

Our work involves performing procedures and obtaining audit evidence for the purpose of forming a conclusion on limited assurance and

covers only the limited assurance procedures set out in the limited assurance programme issued by the 22.01.2025 decision of the

National Bank of Greece (hereinafter referred to as the "Programme"), as formulated for the purpose of issuing a limited assurance report

on the Company's Sustainability Report.

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, 29 April 2025

The Auditor

Athena Moustaki

A.M.SOEL 28871

429

1. ANNUAL FINANCIAL STATEMENTS

FOR THE FY 1 JANUARY 2024 TO 31 DECEMBER 2024

IN ACCORDANCE WITH THE INTERNATIONAL FINANCIAL REPORTING STANDARDS (IFRS)

OF THE GROUP AND EYDAP SA (THE COMPANY)

HEADQUARTERS: 156 OROPOU ST. – GALATSI,

SOC. ANON. REG. NO. 44724/06/Β/99/52

GEMI NO. 121578960000

430

The present Financial Statements of the Company, pages 429 - 490, were approved by the Board of Directors on 29 April, 2025, are subject to

the approval of the Annual Regular Meeting of Shareholders and were signed on mandate by the Board of Directors, by the following persons:

Athens, 29 April 2025

The Chairman of the Board of

Directors

The Chief Executive Officer

The Director of Financial

Services

The Head of Accounting

Department

Georgios Stergiou

ID No. ΑΕ 525749

Charalambos Georg. Sahinis

ID No. ΑΟ 568292

Lemonia Mark. Skylaki

ID No. ΑΟ 010837

Economic Chamber of Greece

Accounting License Reg. No.

Α/17806

Dimitra Vas. Zarkadoula

ID No. ΑΒ 253061

Economic Chamber of Greece

Accounting License Reg. No.

Α/112285

CONTENTS

● General Information about the Company

● Income Statement for the Financial Years ended on 31

December 2024 & 2023

● Statement of Total Comprehensive Income for the Financial Years ended on 31

December 2024 & 2023

● Statement of Financial Position as of 31

December 2024 & 2023

● Statement of Changes in Equity as of 1

January – 31

December 2024 & 2023

● Statements of Cash Flows as of 1

January – 31

December 2024 & 2023

● Notes to the Annual Financial Statements for the period ended on 31

December 2024

431

GENERAL INFORMATION ABOUT THE COMPANY

Company Title:

Athens Water Supply and Sewerage Company S.A.

Distinctive Title:

EYDAP S.A.

Headquarters:

156 Oropou St. – Galatsi

Date of Establishment:

25.10.1999

Company Duration:

100 years

Main Activity:

Water Supply – Sewerage

G.E.MI. (Greece’s General Electronic Commercial

Registry) Number:

121578960000

Pertinent Ministry:

Environment and Energy

Tax Registration Number:

094079101

Members of the Board of Directors:

G. Stergiou, Ch. Sahinis, Euth. Sfikas, An. Martski,

M. Mavrommati, M. Lambrou, E. Kaimenaki, A. Yiannikouris,

Chr. Karaplis, Chr. Mistriotis, P. Skoularikis, Em. Aggelakis,

G. Alexandrakis

Ending Date of the Current Period:

31 December 2024

Duration:

12 months

Type of Financial Statements (which have been the basis

in compiling the condensed financial information):

Annual

Date of Approval of Financial Statements (which have

been the basis in compiling the condensed financial

information):

29 April 2025

Chartered Auditors Accountants:

Panagiotis Christopoulos SOEL Reg. No. 28481

Auditing Firm:

“Grant Thornton” S.A.

SOEL REG. NUMBER 127

Independent Auditor’s Report on the Annual Financial

Statements:

Unqualified Opinion

Internet address where the Financial Statements are

posted:

www.eydap.gr

The Notes on pages 432 – 490 form an integral part of these Financial Statements

436

NOTES TO THE ANNUAL FINANCIAL STATEMENTS AS OF 31

DECEMBER 2024

1. ESTABLISHMENT, BUSINESS ACTIVITY AND LEGAL FRAMEWORK OF THE COMPANY

LEGAL FRAMEWORK

The company “Athens Water Supply and Sewerage Company S.A.” under the distinctive title “EYDAP SA” (“EYDAP”, or the

“Company”) was established under Law 1068/80 following the merger between the Hellenic Water Company of the cities of Athens

– Piraeus and peripheral areas, and the Sewerage Organization of Athens as the exclusive provider of water supply and sewerage

services in the cities of Athens - Piraeus and the surrounding municipalities in the legal form of a societe anonyme under the full

control of the Greek State.

Furthermore, Law 2744/1999 re-regulated EYDAP’s legal status and the Company established its current form with listing all its

shares on Athens Stock Exchange under the supervision of the Minister of Infrastructure and Transport.

EYDAP's exclusive right to provide water supply and sewerage services, the terms of which were established by the Contract of

2.2.2022 between the Greek State, EYDAP Fixed Assets, and EYDAP, was extended by Law 4812/2021 until 31.12.2040. Under the

same Law, EYDAP was also entrusted with the operation and maintenance of the External Water Supply System (EWSS) based on

the Contract of 2.2.2022 between the same parties, with an initial three-year term and a potential six-month extension. The

extension of this EWSS operation and maintenance contract until 31 December 2025 under the same terms is expected according

to Article 18 of Law 5106/2024.

Pursuant to Law 5037/2023, the supervision of EYDAP was transferred to the Ministry of Environment and Energy and the

supervision of water services and urban waste management was assigned to the Waste, Energy and Water Regulatory Authority

(RAWEW).

EYDAP's pricing policy adheres to the general rules of costing and pricing for water services. These rules are established by a joint

decision of the Ministers of Environment and Energy, Finance, Interior, and Rural Development and Food, as provided for by Article

12 of Law 3199/2003 (replaced by Article 34 of Law 5037/2023). This same decision also outlines the procedures and methods for

recovering the cost of water services across different uses. Furthermore, tariffs for water services, categorized by consumer and

user type, are approved every five years by a decision of the RAWEW (Waste, Energy and Water Regulatory Authority), in

accordance with Article 12A of Law 4001/2011 (introduced by Article 11 of Law 5037/2023). In application of these provisions, the

Ministerial Decision under reference number Ministry of Environment and Natural Resources/GRGFPY/103755/2994/2024

(Government Gazette 5438/B/27.9.2024), titled 'Determination of general rules for costing and pricing of water services, measures

for their improvement. Procedures and method of recovery of costs of water services in its various uses', was issued on 27.9.2024.

It is important to note that Article 19 of Law 5106/2024 allowed the Minister of Environment and Energy to approve EYDAP's tariffs

until the staffing of RAWEW was completed.

Pursuant to Law 5045/2023, the Greek State acquired the majority of the EYDAP share capital (due to the transfer of the shares

owned by Growthfund) and the exercise of the relevant rights of the State was provided for by the Ministers of Finance and

Environment and Energy (jointly). Today, the total percentage of voting rights (direct and indirect) controlled by the Greek State

in EYDAP amounts to 65,319,740 (61.33%), of which the direct voting rights pertain to 53,250,001 common nominal shares (50%

+1 share) and the indirect voting rights pertain to 12,069,739 (11.33%).

From a corporate law perspective, EYDAP is currently governed by the provisions of the Law on Public Limited Companies

4548/2018, the Law on Corporate Governance 4706/2020, as well as by the stock exchange legislation (Regulation (EU) 596/2014,

Law 4443/2016, Law 3556/2007, etc.) and the decisions and instructions of the Hellenic Capital Market Commission, by which it is

supervised.

OPERATIONS

The Company's objectives include refining and supplying water, providing sewerage and wastewater treatment services in the

Attica region

, and the design, construction, installation, operation, maintenance, development, and modernization/renovation of

The Notes on pages 432 – 490 form an integral part of these Financial Statements

437

related facilities and networks within its operational area. Additionally, its statutes allow for the development of activities such as

water meter maintenance, camera inspection of third-party sewerage networks, and the strengthening of research and

development, potentially through a cross-sectoral research center for innovative solutions.

"EYDAP NISON S.A." is a wholly-owned subsidiary of EYDAP, with EYDAP holding 100% of its share capital.

Law 5106/2024 expanded EYDAP's objectives to include using the water supply and sewerage system for telecommunications and

energy activities, specifically supporting renewable energy production and facilitating water reuse. This Law also allowed for

entrusting the stormwater network's responsibility to EYDAP via a public service contract with the Greek State to improve its

extension and maintenance.

EYDAP's geographical activity covers the municipalities of the Attica Region as defined in subparagraph i' of par. 3 of Article 3 of

Law 3852/2010, excluding the municipalities of Aegina, Troizinia, Kythira, Agistri, Spetses, Hydra, and Poros in the Islands Regional

Unit of Attica. Furthermore, according to Article 1 par. 6 of Law 2744/1999 (as amended by Law 5106/2024), EYDAP can undertake

activities outside this area through PPPs, programmatic contracts with subsidiaries, or other specific cases mentioned in that

provision.

EYDAP's water supply network currently comprises approximately 14,300 km of pipelines, serving a population of 4,400,000

inhabitants. The Company also operates four Water Treatment Plants with a total daily capacity of 1.8 million cubic meters.

The sewerage network extends for about 8,716 km and serves a population of 3,695,500 inhabitants. The system is separate

(sewage and stormwater pipes) except in central Athens, where it is a combined system. Wastewater is collected in the secondary

sewerage system via mandatory connections for property owners within six (6) months of written notification by EYDAP.

With regard to the waste management, EYDAP SA possesses 5 waste management centers (WMC):

● The WMC of Psitalia has a processing capacity (average design flow) of 1,000,000 m3 / day of waste water (currently the

average flow of incoming waste is of 650,000 m3 / day)

● The WMC of Metamorphosis has a processing capacity of 44,000 m3 / day of waste water (20,000 m3 / day urban waste

water and 24,000 m3 / day urban sewage). (Today the average supply of incoming sewage is at the level of 16,900 m3 /

day and its sewage of 9,800 m 3 / day); and

● The WMC of Thriasio has a processing capacity (average design flow) of 21,000 m3 / day of sewage (currently, the

average intake of incoming sewage is at the level of 6,700 m3 / day).

● The WMC of Megara undertaken from the Municipality of Megara in September 2023 has a processing capacity

(average design flow) of 1,990 m3 / day of sewage and the capacity of the constructed facility is 43,330.

● The WMC of Paiania-Koropi undertaken from the Prefecture of Attica in December 2023 has a capacity to treat (average

design flow) wastewater of a population equivalent of 18.000 m3 / day of sewage (today-2024, average design flow of

sewage is approximately 1.750 m3 / day .

The Waste Management Center (WMC) in Psitalia also operates three Electrical and Thermal Energy Co-production units (ETEC).

The one ETEC unit operates with the combustion of natural gas of electrical power 12.9 MWe and thermal power of 17.3 MWth

respectively. The other two ETEC units operate with the combustion of biogas of total electrical power of 11.4 MWe (7.14 MWe &

4.25 ΜWe) and thermal power of 17.2 MWth, as well as a small-scale hydroelectric station of 489 KW capacity for the recovery of

the contained energy in the wave of processed outflows prior to their disposition in Saronikos Gulf. Through the operation of the

Waste Management Center (WMC) in Psitalia, EYDAP has been incorporated in the EU System of Greenhouse Gas Emission

Allowance Trading, applying the relative EU and national legislation.

In addition, EYDAP manages the sewerage projects of Eastern Attica for the collection and treatment of urban waste water and

the re-use-disposal of treated effluents. In 2023, significant progress was made in the implementation of sewage projects in

Eastern Attica. The design of construction and operation of integrated wastewater management systems in Eastern Attica includes

projects in areas of the Municipalities of Rafina-Pikermi, Spata-Artemida, Marathon, Pallini, Paiania, Saronic and Kropia. EYDAP

The Notes on pages 432 – 490 form an integral part of these Financial Statements

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launched the special website katharonero.eydap.gr to continuously inform citizens about significant sewage projects in Eastern

Attica and the respective environmental benefits.

In the context of optimizing its energy balance and utilizing renewable energy sources, EYDAP: (a) has installed and operates five

small hydroelectric power stations in the locations of Kirfi, Eliconas, Kithaironas, Mandra of the Mandra of Mornos Aqueduct, and

the small hydroelectric power station in Evinos; and (b) has installed a photovoltaic station (PV), power 1.9712 MW, in its facilities

in the Municipality of Acharnes, in order to proceed with disposal of the produced electricity.

2. NEW STANDARDS, INTERPRETATIONS AND AMENDMENTS TO EXISTING STANDARDS

2.1 New Standards, Interpretations, Revisions and Amendments to existing Standards that are effective and have been adopted

by the European Union

The following new Standards, Interpretations and amendments of IFRSs have been issued by the International Accounting

Standards Board (IASB), are adopted by the European Union, and their application is mandatory from or after 01/01/2024.

Amendments to IFRS 16 “Leases: Lease Liability in a Sale and Leaseback” (effective for annual periods

starting on or after 01/01/2024)

In September 2022, the IASB issued narrow-scope amendments to IFRS 16 “Leases” which add to requirements explaining

how a company accounts for a sale and leaseback after the date of the transaction. A sale and leaseback is a transaction for

which a company sells an asset and leases that same asset back for a period of time from the new owner. IFRS 16 includes

requirements on how to account for a sale and leaseback at the date the transaction takes place. However, IFRS 16 includes

no specific subsequent measurement requirements for the transaction, specifically where some or all the lease payments are

variable lease payments that do not depend on an index or rate. The issued amendments add to the sale and leaseback

requirements in IFRS 16, thereby supporting the consistent application of the Accounting Standard. These amendments will

not change the accounting for leases other than those arising in a sale and leaseback transaction. The amendments do not

affect the consolidated Financial Statements. The above have been adopted by the European Union with effective date of

01/01/2024.

Amendments to IAS 1 “Classification of Liabilities as Current or Non-current” (effective for annual periods

starting on or after 01/01/2024)

Τhe amendments clarify the principles of IAS 1 for the classification of liabilities as either current or non‐current. The

amendments clarify that an entity’s right to defer settlement must exist at the end of the reporting period. The classification

is not affected by management’s intentions or the counterparty’s option to settle the liability by transfer of the entity’s own

equity instruments. Also, the amendments clarify that only covenants with which an entity must comply on or before the

reporting date will affect a liability’s classification. The amendments require a company to disclose information about these

covenants in the notes to the financial statements. The amendments are effective for annual reporting periods beginning on

or after 1 January 2024, with early adoption permitted. The amendments do not affect the consolidated Financial Statements.

The above have been adopted by the European Union with effective date of 01/01/2024.

Amendments to IAS 7 “Statement of Cash Flows” and IFRS 7 “Financial Instruments: Disclosures”: Supplier

Finance Arrangements (effective for annual periods starting on or after 01/01/2024)

In May 2023, the International Accounting Standards Board (IASB) issued Supplier Finance Arrangements, which amended

IAS 7 Statement of Cash Flows and IFRS 7 Financial Instruments: Disclosures. The new amendments require an entity to

provide additional disclosures about its supplier finance arrangements. The amendments require additional disclosures that

complement the existing disclosures in these two standards. They require entities to provide users of financial statements

with information that enable them a) to assess how supplier finance arrangements affect an entity’s liabilities and cash flows

and b) to understand the effect of supplier finance arrangements on an entity’s exposure to liquidity risk and how the entity

might be affected if the arrangements were no longer available to it. The amendments to IAS 7 and IFRS 7 are effective for

The Notes on pages 432 – 490 form an integral part of these Financial Statements

439

accounting periods on or after 1 January 2024. The amendments do not affect the consolidated Financial Statements. The

above have been adopted by the European Union with effective date of 01/01/2024.

2.2 New Standards, Interpretations, Revisions and Amendments to existing Standards that have not been applied yet or have

not been adopted by the European Union

The following new Standards, Interpretations and amendments of IFRSs have been issued by the International Accounting

Standards Board (IASB), but their application has not started yet or they have not been adopted by the European Union.

Amendments to IAS 21 “The Effects of Changes in Foreign Exchange Rates: Lack of Exchangeability”

(effective for annual periods starting on or after 01/01/2025)

In August 2023, the International Accounting Standards Board (IASB) issued amendments to IAS 21. The Effects of Changes in

Foreign Exchange Rates that require entities to provide more useful information in their financial statements when a currency

cannot be exchanged into another currency. The amendments introduce a definition of currency exchangeability and the process

by which an entity should assess this exchangeability. In addition, the amendments provide guidance on how an entity should

estimate a spot exchange rate in cases where a currency is not exchangeable and require additional disclosures in cases where an

entity has estimated a spot exchange rate due to a lack of exchangeability. The amendments to IAS 21 are effective for accounting

periods on or after 1 January 2025. The Group will examine the impact of the above on its Financial Statements, though it is not

expected to have any. The above have been adopted by the European Union with effective date of 01/01/2025.

IFRS 9 & IFRS 7 “Amendments to the Classification and Measurement of Financial Instruments” (effective

for annual periods starting on or after 01/01/2026)

In May 2024, the International Accounting Standards Board (IASB) issued amendments to the Classification and Measurement of

Financial Instruments which amended IFRS 9 “Financial Instruments” and IFRS 7 “Financial Instruments: Disclosures”. Specifically,

the new amendments clarify when a financial liability should be derecognised when it is settled by electronic payment. Also, the

amendments provide additional guidance for assessing contractual cash flow characteristics to financial assets with features

related to ESG-linked features (environmental, social, and governance). IASB amended disclosure requirements relating to

investments in equity instruments designated at fair value through other comprehensive income and added disclosure

requirements for financial instruments with contingent features that do not relate directly to basic lending risks and costs. The

amendments are effective from annual reporting periods beginning on or after 1 January 2026. The Group will examine the impact

of the above on its Financial Statements, though it is not expected to have any. The above have not been adopted by the European

Union

Annual Improvements to IFRS Standards-Volume 11 (effective for annual periods starting on or after

01/01/2026)

In July 2024, the IASB issued the Annual Improvements to IFRS Accounting Standards-Volume 11 addressing minor amendments

to the following Standards: IFRS 1 ‘First-time Adoption of International Financial Reporting Standards’, IFRS 7 ‘Financial

Instruments: Disclosures’, IFRS 9 ‘Financial Instruments’: IFRS 10 ‘Consolidated Financial Statements’, and IAS 7 ‘Statement of Cash

Flows’. The amendments are effective for accounting periods on or after 1 January 2026. The Group will examine the impact of

the above on its Financial Statements, though it is not expected to have any. The above have not been adopted by the European

Union.

Amendments to IFRS 9 and IFRS 7 “Contracts Referencing Nature-dependent Electricity” (effective for

annual periods starting on or after 01/01/2026)

On 18 December 2024 the International Accounting Standards Board (IASB) issued amendments to IFRS 9 “Financial Instruments”

and IFRS 7 “Financial Instruments: Disclosures” to help companies better report the financial effects of nature-dependent

electricity contracts, which are often structured as power purchase agreements (PPAs). Nature-dependent electricity contracts

help companies to secure their electricity supply from sources such as wind and solar power. The amount of electricity generated

under these contracts can vary based on uncontrollable factors such as weather conditions. The amendments allow companies

to better reflect these contracts in the financial statements, by a) clarifying the application of the ‘own-use’ requirements, b)

permitting hedge accounting if these contracts are used as hedging instruments and c) adding new disclosure requirements to

enable investors to understand the effect of these contracts on a company’s financial performance and cash flows. The

The Notes on pages 432 – 490 form an integral part of these Financial Statements

440

amendments are effective for accounting periods on or after 1 January 2026, with early application permitted. The Group will

examine the impact of the above on its Financial Statements, though it is not expected to have any. The above have not been

adopted by the European Union.

IFRS 18 “Presentation and Disclosure in Financial Statements” (effective for annual periods starting on or

after 01/01/2027)

In April 2024 the International Accounting Standards Board (IASB) issued a new standard, IFRS 18, which replaces IAS 1

‘Presentation of Financial Statements’. The objective of the Standard is to improve how information is communicated in an entity’s

financial statements, particularly in the statement of profit or loss and in its notes to the financial statements. Specifically, the

Standard will improve the quality of financial reporting due to a) the requirement of defined subtotals in the statement of profit

or loss, b) the requirement of the disclosure about management-defined performance measures and c) the new principles for

aggregation and disaggregation of information. The Group will examine the impact of the above on its Financial Statements,

though it is not expected to have any. The above have not been adopted by the European Union.

IFRS 19 “Subsidiaries without Public Accountability: Disclosures” (effective for annual periods starting on

or after 01/01/2027)

In May 2024 the International Accounting Standards Board issued a new standard, IFRS 19 “Subsidiaries without Public

Accountability: Disclosures”. The new standard allows eligible entities to elect to apply IFRS 19 reduced disclosure requirements

instead of the disclosure requirements set out in other IFRS. IFRS 19 works alongside other IFRS, with eligible subsidiaries applying

the measurement, recognition and presentation requirements set out in other IFRS and the reduced disclosures outlined in IFRS

19. This simplifies the preparation of IFRS financial statements for the subsidiaries that are in-scope of this standard while

maintaining at the same time the usefulness of those financial statements for their users. IFRS 19 is effective from annual reporting

periods beginning on or after 1 January 2027, with early adoption permitted. The Group will examine the impact of the above on

its Financial Statements, though it is not expected to have any. The above have not been adopted by the European Union.

3. SIGNIFICANT ACCOUNTING POLICIES

Statement of Compliance

The financial statements have been prepared in accordance with the International Financial Reporting Standards (IFRS).

Basis for Consolidation

The Consolidated financial Statements of the current as well as of the previous period, include the parent company and its

subsidiary “NISON EYDAP DEVELOPMENT S.A.”.

The annual Financial Statements of the subsidiary company “ISLANDS’ EYDAP DEVELOPMENT S.A.”, audited by Certified Auditors

Accountants, are available on the Internet at the company’s website under the domain name www.eydapnison.gr.

Subsidiaries are all the companies which are managed and controlled directly or indirectly by the parent Company - either through

the majority holding of the companies’ shares to which the investment has been made or through their dependence on the know-

how, which is provided to them by the Group. Subsidiaries’ financial statements are included in the consolidated financial

statements from the date of control accession until the date that the control ceases to exist.

During the acquisition of the subsidiary the respective receivables, liabilities as well as any potential liabilities are assessed at their

fair value. In case that the cost value is greater than the fair value, the respective difference is recognized as goodwill.

In the opposite case, when the cost is lower than the fair value, the respective difference is credited to the financial results of the

acquisition year. Minority interests are displayed at the proportion of the minority at the fair value of the assets and liabilities at

which they have been recognized.

Subsidiaries’ acquisitions are recognized under the purchase method. The financial results of subsidiaries, either acquired or sold

during the fiscal year, are included in the respective consolidated statements respectively from their acquisition date or the date

of their disposal.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

441

When deemed necessary, subsidiaries’ financial statements are restated in order for the data to be homogeneous and comparable

with the respective data of the remaining companies of the Group. During the consolidation, all the intra-group transactions and

balances as well as losses and gains between the companies of the Group, are eliminated.

In the Company’s financial statements participations in subsidiaries and affiliates are displayed at their cost, less any impairment

of their value. The company examines - on an annual basis or whenever there is any indication of impairment - the accounting

value of the aforementioned participations compared to the retrieval value on the basis of the higher value between fair value

less cost to sell and the value in use.

Investments in associates

Associates are those companies on which the Group exercises significant influence but that do not meet the requirements to be

treated as subsidiaries. The consolidated financial statements include the Group's share in the profits and losses of the associates,

based on the equity consolidation method from the date that the Group obtains significant influence until the date that it ceases

to exist such influence. When the Group's share in the losses of an associate exceeds the displayed book value of the investment,

the carrying value of the investment is reduced to nil and the recognition of further losses stops, unless the Group has undertaken

liabilities or contingent liabilities of the associate, beyond that arising from its shareholder state. The results stemming from

transactions between the companies of the Group and the associates are eliminated to the extent of the investment of the Group

in the associates.

In the separate financial statements of the Company, associates are carried at cost and are subject to impairment test annually or

in interim periods, when there are serious indications of impairment.

Goodwill

Goodwill, arising from the acquisition of a subsidiary or a jointly controlled entity or other business activity, represents the

difference between the acquisition cost and the participation of the Company in the net fair value of the identified assets, liabilities

and contingent liabilities of the subsidiary or that of the jointly controlled entity or other business activity recognized at the date

of acquisition.

Goodwill is initially recognized as an asset at cost and is subsequently measured at cost less any accumulated impairment losses.

For the purpose of impairment test, goodwill is allocated to every cash-generating unit of the company. Cash-generating units, to

which goodwill has been allocated, are aurally tested for impairment, or more frequently when there is an indication that the unit

may be impaired. If the recoverable amount of the cash-generating unit is less than the carrying amount of the unit, the impairment

loss is allocated first to reduce the carrying amount of any goodwill allocated to the unit and then to the other assets of the unit

proportional based on the carrying amount of the unit’s assets. An impairment loss recognized for goodwill is not reversed in a

subsequent period.

During the disposal of a subsidiary or a jointly controlled entity or other business activity the defined amount of goodwill is included

in the determination of the profit or loss that stems from disposal.

The Company’s policy for goodwill arising on the acquisition of an associate is described in the section ‘Investments in associates’

above.

Revenue recognition

The Group has the following major sources of revenue:

- Revenue from water supply and related services

- Revenue from sewerage and related services

- Revenue from electricity sale

- Revenue from sales of inventory

Also, the Company enters into construction contracts with customers. However, there were no construction contracts during the

current interim period and the comparative period.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

442

Revenue is measured based on the consideration specified in a contract with a customer and excludes amounts collected on behalf

of third parties. The Group recognizes revenue when it transfers control of a product or service to a customer.

The Group does not enter into any contracts where the period between the transfer of the promised goods or services to the

customer and the payment by the customer exceeds one year. As a consequence, the Group does not adjust any of the transaction

prices for the time value of money.

Revenue from water supply and sewerage services and related services

Water supply and sewerage services are the major sources of revenue for the Company and the Group and represent two separate

distinct performance obligations. Revenue for each of the above-mentioned two performance obligations is recognized over time,

since the customer simultaneously receives and consumes the benefits arising from both the water consumption and the

utilization of the sewerage network. Revenue is measured based on the quantities of water consumed and the effective price lists.

The Company invoices the customers for the water supply and sewerage services mainly on a quarterly basis based on relevant

measurements.

In cases where the Company has not performed the relevant measurements for consumed quantities up to the end of the reporting

period, it conducts estimates on the consumption based on historical data and recognizes the relevant revenue. The Company

recognizes a contractual asset for revenue accrued and not yet invoiced to customers.

In order to include accrued not invoiced revenue in the turnover of the reporting period of the financial statements, the Company

makes two categories of provisions:

● provision for invoiced revenue (the revenue has been counted and invoiced after the reporting date), and

● provision for not invoiced revenue (the revenue has been counted and invoiced until the reporting date

In essence, the above revenues concern provisions that largely depend on the quantities of water consumed. Based on the use of

estimates, the actual amounts ultimately invoiced might differ from those projected.

A receivable is recognized by the Company when the relevant invoice is issued, as this represents the point in time at which the

right to consideration becomes unconditional, as only the passage of time is required before payment is due. The usual credit

period for the settlement of accounts is approximately 30 days from the date of issuance of the relevant document. Also, the

Company adjusts the revenue recognized at each reporting period based on estimates for discounts/ refunds to customers for

various reasons. The relevant estimates are supported by historical data and the Company recognizes a corresponding refund

liability.

The Company’s customers are required to participate in the network connection cost (meters, distribution network, connections

pipes). In particular, customers are charged for water supply and sewerage services with one-off upfront fees that relate to the

construction of the connection network and the equipment (including any upgrades and extensions). Based on the Company's

assessment, the connection of each house to the water and sewerage network represents a distinct performance obligation since

the connection has a stand-alone value for the customer. In other words, a property will be more valuable if it possesses a

connection to the water and sewerage network than without the connection. Revenue from these one-off fees is recognized at a

point in time, and particularly at the time when the connection is established.

The Company recognizes a contractual liability when it receives advance payments from customers in exchange for goods or

services to be transferred to them.

Revenue from electricity sale

Sale of electric power represents a single performance obligation and revenue is recognized over time by measuring the progress

towards complete satisfaction of the performance obligation based on the kWh sold and the effective price lists. The Company

invoices monthly for the sale of electric power and recognizes a relevant receivable upon invoicing.

Revenue from sales of inventory

The Notes on pages 432 – 490 form an integral part of these Financial Statements

443

Sales of inventory relate to sales of scrap to customers. Relevant revenue is recognized at a point in time, when control of the

goods has been transferred to the customers. Since the terms in each contract may vary from each other, the Company assesses

on a contract by contract basis when control of the goods is transferred to the customers based on the criteria provided by IFRS

15, paragraph 38 (immediate right to payment, legal title, physical possession, significant risks and rewards of asset ownership,

acceptance of goods by the customer).

Leases

Accounting policies according to IFRS 16 since 1 January 2019

The Group as a lessee

The Group assesses whether a contact is or contains a lease, at inception of a contract. Accordingly, it recognizes a right-of-use

asset and a corresponding lease liability with respect to all lease agreements in which it is the lessee, except for short-term leases

(defined as leases with a lease term of 12 months or less) and leases of low value assets. For these leases, the Group recognizes

the lease payments as an operating expense on a straight-line basis over the term of the lease.

“Silent renewed” contracts of indefinite life are not enforceable, meaning that no relevant rights and liabilities emanate from the

above contracts. The Group recognizes the lease payments associated with those contracts as operating expenses in the income

statement.

The lease liability is initially measured at the present value of the lease payments that have not been paid at the commencement

date, which are being discounted by using the rate implicit in the leases. If this rate cannot be readily determined, the Group uses

its incremental borrowing rate. Lease payments included in the measurement of the lease liability comprise:

• fixed lease payments (including in-substance fixed payments), less any lease incentives;

• variable lease payments that depend on an index or rate, initially measured using the index or rate at the commencement date

of the lease period;

• the amount expected to be payable by the lessee under the residual value guarantees;

• the exercise price of purchase options, if the lessee is reasonably certain to exercise the options; and

• payments of penalties for terminating the lease, if the lease term reflects the exercise of an option to terminate the lease.

The lease liability is subsequently measured by increasing the carrying amount to reflect interest on the lease liability (using the

effective interest method) and by reducing the carrying amount to reflect the lease payments made. The Group re-measures the

lease liability (and makes a corresponding adjustment to the related right-of-use asset) whenever:

• the lease term has changed or there is a change in the assessment of exercise of a purchase option, in which case the lease

liability is remeasured by discounting the revised lease payments using a revised discount rate.

• the lease payments change due to changes in an index or rate or a change in expected payment under a guaranteed residual

value, in which cases the lease liability is measured by discounting the revised lease payments using the initial discount rate.

• a lease contract is modified and the lease modification is not accounted for as a separate lease, in which case, the lease liability

is remeasured by discounting the revised lease payments using a revised discount rate.

The lease liability is presented as a separate line in the consolidated statement of financial position.

The right-of-use asset comprises the initial measurement of the corresponding lease liability, lease payments made at or before

the commencement day and any initial direct costs. They are subsequently measured at cost less accumulated depreciation and

impairment losses. The Group applies IAS 36 to determine whether a right-of-use asset is impaired.

Whenever the Group incurs an obligation for costs to dismantle and remove a leased asset, restore the site on which it is located

or restore the underlying asset to the condition required by the terms and conditions of the lease, a provision is recognized and

measured under IAS 37. These costs are included in the related right-of-use asset. The Group did not incur any such costs during

the periods presented in the annual financial statements.

Right-of-use assets are depreciated over the shorter period between the lease term and useful life of the underlying asset. If a

lease ownership transfer of the underlying asset or the cost of the right-of-use asset reflects that the Group expects to exercise a

purchase option, then the related right-of-use asset is depreciated over the useful life of the underlying asset. The depreciation

starts at the lease commencement date.

The right-of-use assets are presented as a separate line in the consolidated statement of financial position.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

444

Variable leases that do not depend on an index or rate are not included in the measurement of the lease liability and the right-of-

use asset. The related payments are recognized as an expense in the period in which the event or condition that triggers those

payments occur.

As permitted by IFRS 16, the Group applied the practical expedient according to which a lessee is not required to separate non-

lease components, and as such, it accounts for any lease and associated non-lease components as a single arrangement.

The Group as a lessor

Leases, in which the Group is a lessor, are classified as finance or operating leases. Whenever the terms of the lease transfer

substantially all the risks and rewards of ownership to the lessee, the contract is classified as a finance lease. All other leases are

classified as operating leases. When the Group is an intermediate lessor, it accounts for the head lease and the sublease as two

separate contracts. The sublease is classified as a finance or operating lease by reference to the right-of-use asset arising from the

head lease.

Rental income from operating leases is recognized on a straight-line basis over the term of the relevant lease. Initial direct costs

incurred in negotiating and arranging an operating lease are added to the carrying amount of the leased asset and recognized on

a straight-line basis over the lease term.

Amounts due from lessees under finance leases are recognized as receivables at the amount of the Group’s net investment in the

leases. Finance lease income is allocated to reporting periods so as to reflect a constant periodic rate of return on the Group’s net

investment outstanding in respect of the leases.

When a contract includes lease and non-lease components, the Group applies IFRS 15 to allocate the consideration under the

contract to each component.

Foreign currencies

The financial statements of the Company are presented in the currency of the economic environment, in which the entity operates

(its functional currency), which is Euro. During the preparation of the Company’s financial statements, transactions in currencies

other than the entity’s functional currency (foreign currencies) are recorded at the rates of exchange prevailing at the dates of the

transactions. On every financial statements reporting date, monetary items denominated in foreign currencies are retranslated at

the rates prevailing on the financial statements reporting date. Non-monetary items which are estimated at fair value and

denominated in foreign currencies are retranslated at the rates prevailing at the date when the fair value was determined. Non-

monetary items, measured in terms of historical cost in a foreign currency, are not retranslated.

Exchange differences are recognized in the financial result of the period in which they arise except for:

● exchange differences, related to assets under construction for future use in the production, which are included in the cost of

those assets and they are regarded as an adjustment to the interest costs on foreign currency borrowings;

● exchange differences in hedging transactions of certain foreign currency risks and

● exchange differences on monetary items receivable from or payable to a foreign operation for which settlement is neither

planned nor likely to occur, which form part of the net investment in a foreign operation, and which are recognized in the

foreign currency translation reserve and recognized in profit or loss on disposal of the net investment.

Goodwill and fair value adjustments arising on the acquisition of a foreign operation are treated as assets and liabilities of the

foreign operation and translated at the closing rate.

Borrowing costs

The borrowing costs burden the financial results of the fiscal year when incurred.

Subsidies

Subsidies are not recognized until there is reasonable assurance that the Company will comply with the clauses that govern them

and that the subsidy will be received.

State subsidies, whose primary condition is the purchase or the construction, or by any other way the acquisition of non-current

assets, are recognized as deferred income in the balance sheet and transferred to the operating result on a systematic and rational

basis during the useful life of the related asset.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

445

Other subsidies are recorded on a systematic basis in the income of the respective periods, during which matching of these

subsidies with the respective costs has to be made. State subsidies, received as compensation for expenses or losses which have

already incurred or for the purpose of providing immediate financial support to the Company with no future related costs, are

recognized in the income statement for the period, during which they become receivable.

The Company receives subsidies from the European Union (E.U.) the Greek State and the Organization of Local Government for

financing of specific projects. Furthermore EYDAP’s customers are required to participate in the initial network connection cost

(supply, distribution network, connections pipes, etc.) or in the upgrade/expansion of the Company’s networks. Subsidies and

customers’ contributions are deferred and amortized into income, over the period necessary to match them with the related cost,

they are provided to compensate, at the amortization rate equal to the depreciation rate of the respective assets. The

aforementioned income is presented as a subtraction from the depreciation expense in the financial statements.

Government grants for staff retraining are recognized in the income statement during the periods required to meet the

corresponding related costs and are presented as a deduction.

Retirement benefit costs

Contributions to defined staff contribution plans are recognized as an expense when employees have provided services entitling

them to the contributions.

Regarding defined benefit retirement plans, the cost of providing benefits is determined using the Projected Unit Credit Method,

with actuarial valuation studies being carried out on each financial position statement’s date. Actuarial gains or losses are directly

recognized in the total comprehensive income for the period during which they occur, and are not transferred to the income

statement of a following period. Prior service cost is recognized immediately to the extent that the benefits are already vested,

otherwise are amortized on a straight-line basis over the average period until the benefits become vested.

The retirement benefit obligation recognized in the statement of financial position at the time of the indemnity represents the

present value of the defined benefit obligation after taking into account the adjustments for the unrecognized actuarial gains and

losses and unrecognized past work experience cost reduced by the fair value of scheme’s assets.

Any asset resulting from this calculation is limited to unrecognized actuarial losses and past working experience cost, plus the

present value of available refunds and reductions in future contributions to the plan.

Taxation

Income tax expense represents the sum of the current tax payable and the deferred tax.

Current tax

The current tax payable is based on taxable profit for the year. Taxable profit differs from profit as reported in the income

statement because it excludes items of income or expense that are taxable or deductible in other years and in addition it further

excludes items that are will never be taxed or exempted. The Company’s liability for the current tax is calculated using the effective

tax rates or those effective on the financial statements reporting date.

Deferred tax

Deferred tax is recognized on differences between the carrying amounts of assets and liabilities of the financial statements and

the corresponding tax bases, used for calculating taxable profit. Deferred tax is recorded by applying the balance sheet liability

method. Liabilities from deferred tax are generally recognized for all the taxable temporary differences and deferred tax assets

are generally recognized for all deductible temporary differences to the extent that it is probable that taxable profits will be

available against which those deductible temporary differences can be utilized. Such assets and liabilities are not recognized if the

temporary difference arises from goodwill or from the initial recognition (other than in a business combination) of other assets

and liabilities in a transaction that does not affects neither the taxable profit nor the accounting profit.

Deferred tax liabilities are recognized for all the taxable temporary differences associated which arise from investments in

subsidiaries and associates, and participations in joint ventures, with the exception of the cases where the Company is able to

control the reversal of the temporary difference and it is probable that the temporary difference will not be reversed in the

The Notes on pages 432 – 490 form an integral part of these Financial Statements

446

foreseeable future. Deferred tax assets arising from deductible temporary differences associated with such investments and

participations are only recognized to the extent that it is probable that there will be sufficient taxable profits against which they

could be utilized the benefits of the temporary differences and they are expected to be reversed in the foreseeable future.

The carrying amount of deferred tax assets is reviewed at each balance sheet date and is been reduced to the extent that it is no

longer probable that sufficient taxable profits will be available to allow all or part of the asset to be recovered.

Deferred tax assets and liabilities are measured according to the tax rates that are expected to be effective in the period at which

the asset will be liquidized or the liability will be settled, based on effective tax rates or are effective by the balance sheet date.

The measurement of deferred tax liabilities and assets reflects the tax results that will follow based on the way that the Company

expects, at the reporting date, to recover or settle the carrying amount of its assets and liabilities.

Deferred tax assets and liabilities are offset when there is a legally enforceable right to set off current tax assets against current

tax liabilities and when they are related to income taxes levied by the same taxation authority and furthermore the Company

intends to settle its current tax assets and liabilities through offsetting.

Current and deferred tax for the period

Current and deferred taxes are recognized as an expense or income in the financial results, except when they are related to items

credited or debited directly to equity, case where the tax is also recognized directly in equity, or where they arise from the initial

recognition of a business combination. In the case of a business combination, the tax effect is taken into account in calculating

goodwill or in determining the excess between the acquirer’s interest in the net fair value of the acquired business identifiable

assets, liabilities and contingent liabilities over cost of the Company.

Property, plant and equipment

Land and buildings held for use in the production or sale of goods or services, or for administrative purposes, are displayed on the

financial statement report at their acquisition cost less any subsequent accumulated depreciation and subsequent accumulated

impairment losses. Properties under construction for production, rental or administrative purposes, or for purposes not yet

determined, are carried at cost, less any recognized impairment loss. Cost includes the compensation of professionals.

Depreciation of these assets, on the same basis as other property assets, commences when the assets are ready for their intended

use. Land owned by the Company is not depreciated.

The water supply and sewerage networks as well as the antipollution projects, waste processing centers, fixtures and equipment

are stated at cost less accumulated depreciation and any accumulated impairment losses. Depreciation is charged against the

results so as to decrease the cost or the value of the assets, with the exception of the land and properties under construction, over

their estimated useful lives, using the straight-line method. The estimated useful lives, residual values and depreciation method

are reviewed at end of each year, with the effect of any changes on the estimates to be calculated on a prospective basis.

Assets held under finance leases are depreciated over their expected useful lives on the same basis as the owned assets or, based

on the term of the relevant lease term in case it is shorter.

The gain or loss arising from the disposal or the retirement of a property, plant and equipment item is determined as the difference

between the sales proceeds and the net book value of the asset and it is recognized in the income statement.

Intangible Assets

Intangible assets acquired separately

Intangible assets acquired separately are reported at cost less accumulated amortization and accumulated impairment losses.

Amortization is charged on a straight-line basis over their estimated useful lives of the tangible assets. The estimated useful life

and the amortization method are reviewed at the end of each annual reporting period, with the effect of any changes in estimates

being accounted on a future basis.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

447

Internally generated intangible assets – research and development expenses

Expenditure on research activities is recognized as an expense in the period in which it incurs.

An internally-generated intangible asset arising from development (or from the development phase of an internal project) is

recognized if, and only if, all of the following can be proven:

● the technical feasibility of completing the intangible asset so that it will be available for use or sale;

● the intention to complete the intangible asset and use or sell it;

● the ability to use or sell the intangible asset

● the intangible asset to be able to generate probable future economic benefits.

● the availability of adequate technical, financial and other resources for the completion of the development and the utilization

or sale of the intangible asset and

● the ability to measure reliably the expenditure attributable to the intangible asset during its development.

The amount initially recognized for internally-generated intangible assets is the sum of the expenditure which arises from the date

when the intangible asset first meets the recognition of the criteria listed above. Where it is not possible to recognize internally-

generated intangible asset, development expenditure is charged to the profit and loss statement in the period in which it incurs.

Subsequent to initial recognition, internally generated intangible assets are carried at cost less accumulated amortization and

accumulated impairment losses on the same basis as intangible assets acquired separately.

Intangible assets acquired in a business combination

Intangible assets acquired in a business combination are identified and disclosed separately from goodwill when they meet the

requirements of the definition of an intangible asset and their fair value can be measured reliably. The cost of such intangible

assets is their fair value at the date of acquisition.

Subsequent to initial measurement, intangible assets acquired in a business combination are carried at cost, less accumulated

amortization and accumulated impairment losses, on the same basis as intangible assets acquired separately.

Impairment of tangible and intangible assets excluding goodwill

On every financial statements reporting date, the Company reviews the carrying amounts of its tangible and intangible assets to

determine whether there is any indication that those assets have suffered an impairment loss. If any such indication exists, the

recoverable amount of the asset is estimated in order to determine the extent of the impairment loss (if any). When it is not

possible to estimate the recoverable amount of an individual asset, the Company estimates the recoverable amount of the cash

flow-generating unit, to which the asset belongs.

When a reasonable and consistent basis of allocation can be identified, corporate assets can also be allocated to separate cash

flow-generating units, or otherwise they are allocated to the smaller group of cash flow-generating units for which a reasonable

and consistent allocation basis can be identified.

Intangible assets with indefinite useful lives and intangible assets not yet available for use are tested for impairment annually, and

whenever there is an indication that the asset may be impaired.

Recoverable amount is the higher between the fair value deducted by the sale costs and the value in use. In assessing value in use

(of the asset), the estimated future cash flows are discounted to their present value using a pre-tax discount rate that reflects the

current market assessments of the time value of money and the risks related to the asset.

If the recoverable amount of an asset (or cash flow-generating unit) is estimated to be less than its carrying amount, the carrying

amount of the asset (cash flow-generating unit) is reduced to its recoverable amount. An impairment loss is recognized

immediately in the profit and loss account.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

448

When an impairment loss subsequently is reversed, the carrying amount of the asset (cash flow-generating unit) is increased to

the revised estimate of its recoverable amount, so as the increased carrying amount does not exceed the carrying amount that

would have been determined if there had not been recognized any impairment loss for the asset (or a cash flow-generating unit)

in prior years. A reversal of an impairment loss is directly recognized in the income statement.

Receivables ( Miscellaneous advances)

Mandatory expropriation complies with the procedure stated in Law 2882/2001 (Α΄17) "Mandatory Expropriation Code" - as

amended and effective, in particular with article 280 of Law 4364/2016 (Α΄13), adding the provision of article 7A of the above

code which concerns implementation of projects of general significance to the country's economy - in conjunction with Law

1068/1980 (article 28 Expropriations), which applies in addition to the provisions of Law 2744/1999, governing EYDAP SA

operations.

The unit price of the expropriation compensation is determined in accordance with article 7A, as well as the temporary and final

unit price is determined by the competent Court of Appeal, in accordance with Law 2882/01 on mandatory expropriations.

The amounts are awarded to the beneficiaries who will be recognized by a court decision (after the expropriation decision) and

until they are awarded to the beneficiaries, they will remain with the Deposits and Loans Fund.

Until the issuance of the Decision determining the final unit price of the expropriated area, the relevant funds remain in the

"miscellaneous advance payments" and upon its issuance, they are transferred to the project they concern.

It is noted that the Company implements water supply and sewerage projects in its areas of responsibility.

Inventory

Inventory is recorded at the lower value between acquisition cost and net liquidation value. The acquisition cost is calculated via

the weighted average cost method. The cost incorporates all respective materials and whenever is required it also includes direct

labor costs and the respective general industrial expenses incurred for the processing of inventories to their final condition. The

net realizable value represents the estimated selling price less the estimated costs necessary for the completion of the sale.

Provisions

Provisions are recognized when the Company has a present obligation (legal or constructive) as a result of a past event, it is

probable that the Company will be required to settle the obligation, and a reliable estimate can be made of the amount of the

obligation.

The amount recognized as a provision is the best estimate of the consideration required to settle the present obligation on the

financial statements reporting date, taking into account the risks and uncertainties surrounding the obligation. Where a provision

is measured using the cash flows estimated to settle the present obligation, its carrying amount is the present value of those cash

flows.

When part or all of the economic benefits required to settle a provision are expected to be recovered from a third party, the

receivable is recognized as an asset when it is practically certain that reimbursement will be received and the amount of the

receivable can be measured reliably.

Onerous contracts

Present obligations arising under onerous contracts are recognized and measured as a provision. An onerous contract is considered

to occur where the Company has a contract under which the unavoidable costs of meeting the obligations under the contract

exceed the economic benefits expected to be received under it.

Restructuring

A provision for costs of restructuring is recognized when the Company has developed a detailed formal plan for the restructuring

and has raised a valid expectation, to those been affected, that it will carry out the restructuring by starting the implementation

of the plan or announcing its main features to those been affected by it. The measurement of a restructuring provision includes

only the direct expenditures arising from the restructuring, which necessarily stem from the restructuring and simultaneously are

not associated with the ongoing activities of the entity.

Warranties

The Notes on pages 432 – 490 form an integral part of these Financial Statements

449

Provisions for warranty costs are recognized at the date of the sale of the relevant products, according to the Management’s best

estimates for the expenditure required to settle the Company’s obligation.

Financial instruments

The Group and the Company have selected to apply the limited exemption in IFRS 9 paragraph 7.2.15 relating to the transition for

classification, measurement and impairment of the financial assets, and accordingly have not restated the items in the comparative

periods in the initial application. As a consequence, any adjustments to the book value of the financial assets and the provisions

for impairment at the financial position were recognized retrospectively with the cumulative effect from the initial adoption

adjusting the opening balance of retained earnings on 1 January 2018, meaning that not restatement occurred in the items of the

equity in the comparative period.

Investments in financial assets are classified as either liability or equity investments in equity with reference to the requirements

for the issuer in IAS 32 “Financial Instruments”

(a) Impairment of Financial Assets

The categories of financial assets that are subject to IFRS 9 new expected credit loss model are the following:

● Trade and Other Receivables

● Cash and Cash Equivalents.

The Group and the Company revised their impairment measurement methodology under IFRS 9 for each of these assets categories.

Impairment

The Group and the Company apply the simplified approach for the estimation of the expected future credit losses in relation to

the “Trade Receivables” as it is required by IFRS 9, paragraph 5.5.15. The Group recognizes the provision for the expected credit

losses during the initial recognition with regard to the item “Trade Receivables”, classified and measured at amortized cost.

In the context of the requirements set by the IFRS 9 regarding the financial asset “Trade Receivables”, the Group has adopted the

simplified approach according to which it recognizes and classifies the financial asset “Trade Receivables” either in stage 2 or in

stage 3 based on the days of delay in the payment of the accounts as follows:

• Stage 2: 0-89 days of delay from the day of payment stated in the invoice. In stage 2, trade receivables are not impaired.

• Stage 3: 90 or more days of delay. Stage 3 includes trade receivables for whom a default event has occurred (they are

impaired).

For stages 2 and 3, the Company forms the Expected Credit Losses on the basis of risk parameters which are calculated according

to the historic data. The risk parameters are the estimated probability of default, the percentage of loss on the amount due given

that the customer has defaulted in the payment of this amount due, and the outstanding amount which the Company is exposed

to in case of the customer’s default.

As general rule, the assessment of the classification in stages is performed in each reporting period.

The Group recognizes the provision for expected credit losses during the initial recognition of the financial asset “Trade

Receivables”, classified and measured at the amortized cost.

Investments and Other Financial Assets

Classification

From the transition date of 1 January 2018, the Group and the Company classified their financial assets in the following categories

● Measured at fair value (either through other comprehensive income or through profit or loss),

● Measured at amortized cost

The classification depends on the entity’s business model for managing the financial assets and the contractual terms of the cash

flows.

For assets measured at fair value, gains and losses will either be recorded in profit or loss or in other comprehensive income. For

investments in equity instruments not held for sale, it will depend on whether the company has made an irrevocable election at

the time of initial recognition to account for the equity investment at fair value through other comprehensive income (FVOCI).

The Notes on pages 432 – 490 form an integral part of these Financial Statements

450

Measurement

At initial recognition, the Group and the Company measure a financial asset at its fair value plus transaction costs that are directly

attributable to the acquisition of the financial asset, provided that the Group and the Company do not recognize this asset in the

income statement, but in other comprehensive income. In case the asset is recognized in the income statement, potential costs

are expensed.

Investments in equity instruments

The investments available for sale were recognized at fair value through other comprehensive income, in particular:

Listed equity instruments have been reclassified at the transition date 1 January 2018 from the item "Investments Available for

Sale" to the item “Financial Instruments at Fair Value through Other Comprehensive Income”. This reclassification has been made

irrevocably for both the Group and the Company.

In compliance with IFRS 9, the Group and the Company consider that the cost of these equity instruments represents an

appropriate estimation of their fair value.

The equity investments are measured at fair value. Where the Group's and the Company’s management have elected to present

fair value gains and losses on equity investments in other comprehensive income (OCI), there is no subsequent reclassification of

fair value gains and losses into profit or loss following the de-recognition of the investment. Dividends from such investments

continue to be recognized in profit or loss as other income when the Group's and the Company’s right to receive cash flows is

established. Changes in the fair value of financial assets through profit and loss are recognized in other gains/(losses) in the

statement of profit or loss as applicable. Impairment losses (and reversal of impairment losses) on equity investments measured

at FVOCI are not reported separately from other changes in fair value.

Cash and cash equivalents

Cash and cash equivalents comprise of cash on hand and deposits, and other short-term highly liquid investments that are easily

converted to a known amount of cash and subject to an insignificant risk of changes in their value.

Operating segments

The key operations of the Company (water supply, sewerage services and others) are not subject to different risks and returns. As

a result the company did not present the disclosures with respect to the operating segments. It is clarified that the Company

operates in one geographical segment (Attiki Metropolitan area). The policy and the decision making is common for the operating

segments of the Company.

4. KEY ACCOUNTING TREATMENTS AND SIGNIFICANT SOURCES OF UNCERTAINTY

During the preparation of the financial statements in accordance with the accounting policies of the Group, as presented in Note

3, it is essential for the management to proceed with judgments, estimations and assumptions with regard to the book value of

the assets and the liabilities, which are not obvious from other sources of information.

The estimates and the relevant assumptions, are based on the past empirical evidence, estimates of specialized external advisors

as well as other related factors. The actual results may differ from these estimates.

The estimates and the subjective assumptions are reviewed on on-going basis. The revisions of accounting estimates are

recognized in the period of occurrence, if they affect only the particular period or in future periods as well.

The accounting judgments which have been made by the management during the application of the Group’s accounting policies

and which significantly affect the financial statements of the Company and the Group are the following:

1. Provision for contingent doubtful customer receivables (retail customers, Greek State, local authorities - OTA).

2. Provisions concerning four defined benefit plans for the personnel.

3. Provisions for pending judicial cases relating to labor issues.

4. Provisions for Other Receivables

The Notes on pages 432 – 490 form an integral part of these Financial Statements

451

5. Term of the lease

It is common practice in the Greek rental market of commercial real estate, for the tenant to continue to use the property even

after the expiration date of the lease agreement. The above-mentioned so-called "silently renewed" lease agreements become

indefinite after their expiration date and continue to create enforceable rights and obligations, provided that none of the

counterparties proceeds to terminate them. According to the Hellenic Civil Code, each of the counterparties has the right to

terminate the lease without the imposition of a penalty immediately after the end of the short notice period as defined in the

above code. Since both the lessee and the lessor have the right to terminate the lease without obtaining the relevant permission

of the counterparty and without requiring the payment of any amount as compensation, the Group assessed that the "silently

renewed" lease agreements do not create obligations after the expiration of their contractual date and therefore do not meet

the definition of the lease contract based on IFRS 16. Consequently, the Group concluded that the duration of the lease of

"silently renewed" contracts is their initial contractual duration. The Group therefore recognizes the rents associated with these

leases as operating expenses in the Income Statement.

6. Incremental Borrowing Rate

To determine the incremental borrowing rate, the Group used the yield curve of Greek government bonds as a reference interest

rate, which was adjusted to the Group's credit spread. In order to incorporate in the above incremental borrowing rate the fact

that the loan is secured, the difference in the yield spread between the covered bonds of the Greek Systemic Banks and the

bonds of the Greek State was utilized.

Furthermore the management annually reviews, in terms of assumptions and estimations, the following:

1. Useful life and recoverable amount of the depreciated tangible assets and the amortized intangible assets.

2. Income tax which incorporates the provision for the current income tax and the provision for additional taxes and incremental

charges for tax unaudited years.

3. Recoverability of deferred tax receivables.

5. REVENUE

Paragraph 4 of Article One Hundred and Fourteen (114) of Law 4812/2021 (A’110) provided the terms under which EYDAP is

obliged to maintain and operate the External Water Supply System (EYS) of the major Capital area for a three-year period, which

may be extended by agreement of the parties.

Following the contract dated 02.02.2022 between the Greek State, EYDAP Fixed Assets (EPEYDAP) and EYDAP SA (Company) with

a term of validity from 01.01.2021 to 31.12.2023 and the possibility of extension for an additional period of six (6) months, a

memorandum of understanding was signed on 27.04.2022 which clarified Article 10 of the Contract of L.4812 / 2021 ( Exclusive

Right Contract) as well as Article 9 of the contract under which EYDAP was assigned the operation and maintenance of the External

Water Supply System.

The agreement for the operation and maintenance of the EWSS (SLA) under decision No.17/8.8.2023 of EYDAP Fixed Assets

(EPEYDAP) Board of Directors was unilaterally extended with the same terms, for a period of six (6) months, i.e. until 30 June 2024.

It is noted that throughout the three-year term of the operation and maintenance agreement and until 30.06.2024, EPEYDAP paid

in cash to EYDAP this fixed fee for the first half of 2024 in the amount of Euro 12.5 million, whose receivable was offset against the

corresponding receivable of EPEYDAP.

For the period after 30.6.2024, a new agreement was signed for the operation and maintenance of the of the EWSS (SLA) between

EYDAP Fixed Assets (EPEYDAP), EYDAP SA, and the Greek State. This agreement extends the duration of the assignment under the

same terms for a period of eighteen (18) months, from July 1, 2024, to December 31, 2025.

EYDAP continues the operation and maintenance of the EWS and has recognized in its turnover an amount of €12,500 thousand

for the second half of 2024.

For the year 2024, the fee for the provision of maintenance and operation services for the External Water Supply System of Euro

25 million is included in the turnover.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

452

The Company's revenue is analyzed as follows:

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
REVENUE
Revenue from water supply and related services	239.269	222.918	239.226	222.918
Revenue from sewerage services	106.656	101.634	106.656	101.606
Revenue from electric power sale	1.954	1.931	1.954	1.931
Revenues from EWS Operation and Maintenance Contract	25.000	25.000	25.000	25.000
Inventory disposal	866	120	866	120
Turnover	373.746	351.602	373.703	351.574
Other Operating Revenues	10.290	3.159	10.290	3.155
Financial Income	20.036	17.816	20.022	17.806
Total Revenue	404.072	372.578	404.015	372.536

The change in turnover is mainly due to:

· the increase in consumption by 5.9% i.e. an increase in water and sewerage revenue by approximately Euro 19.6 million

· the increase in water and sewerage revenue of approximately Euro 1.7 million

· the increase in revenue from inventory disposal by approximately Euro 746 k from sale of electricity by approximately Euro

24 k.

The Company's financial income as of 31 December 2024 amounted to EUR 20,022 thousand from EUR 17,806 thousand in the

corresponding period of the previous year. This change of Euro 2.2 million is mainly due to the increase in interest income from

bank deposits amounted to Euro 1.9 million.

Other operating income include:

1. for the second half of 2024, income from EPEYDAP for electricity from water pumping under the agreement for the

operation and maintenance of the External Water Supply System amounting to Euro 6,998 k, which is an equal expense

paid by EYDAP SA for electricity consumption and is reflected in Other expenses

2. income from legal expenses, income from the deposit of letters of guarantee and other miscellaneous income

amounting to approximately Euro 3.3 million, which did not show a significant change.

amounted to Euro 10.3 million.

The Group segregates revenue from contracts with customers on the basis of the service transfer time, as the management

believes that this demonstrates better that the nature, quantity, timing and uncertainty of the Group's income and cash flows are

affected by economic factors.

	GROUP		COMPANY
Amounts in k Euro		31.12.2024
		In a particular point		In a particular
REVENUE	In the long run	in time	In the long run	point in time
Revenue from water supply and related services	230.045	9.224	230.045	9.181
Revenue from sewerage and related services	104.051	2.605	104.051	2.605
Revenue from electric power sale	1.954	0	1.954	0
Revenue from Operation and Maintenance Contract of the EYS	25.000	0	25.000	0
Inventory disposal	866	0	866	0
Total	361.917	11.829	361.917	11.786

The Notes on pages 432 – 490 form an integral part of these Financial Statements

453

	GROUP		COMPANY
Amounts in k Euro		31.12.2023
		In a particular point		In a particular
REVENUE	In the long run	in time	In the long run	point in time
Revenue from water supply and related services	215.410	7.536	215.410	7.508
Revenue from sewerage and related services	99.077	2.528	99.077	2.528
Revenue from electric power sale	1.931	-	1.931	-
Revenue from Operation and Maintenance Contract of the EYS	25.000	-	25.000	-
Inventory disposal	120	-	120	-
Total	341.538	10.064	341.538	10.036

6. ALLOCATION OF THE ITEMS OF THE INCOME STATEMENT PER CATEGORY OF EXPENSES

The expenses accounts (by nature) have been allocated into the cost of goods sold and administration and distribution operations

as follows:

GROUP

31.12.2024	Cost of Sales	Distribution	Administrative	Impairment of Financial Assets	Total
Amounts in k Euro		Expenses	Expenses
Third-party fees and expenses	93.675	4.757	20.410	-	118.843
Cost of Self-Constructed Assets	(51.767)	-	-	-	(51.767)
Total Α	41.908	4.757	20.410	-	67.075
Personnel Fees & Expenses (Note 8)	70.814	23.338	46.110	-	140.261
Utilities	37.507	5.163	14.328	-	56.997
Depreciation and amortization (Note 7)	35.229	540	6.221	-	41.990
Provision for costs of raw water (e)	29.133			-	29.133
Various Provisions (Notes 22, 23, 30)	(5.199)	-	-	6.501	1.301
Various Expenses	7.740	4.256	4.189	-	16.185
Raw materials and consumables	12.912	258	1.146	-	14.316
Cost of Self-Constructed Assets	(8.963)	-	-	-	(8.963)
Total Β	179.173	33.554	71.993	6.501	291.221
Total (Α + Β)	221.081	38.311	92.403	6.501	358.297

31.12.2023	Cost of Sales	Distribution	Administrative	Impairment of Financial Assets	Total
Amounts in k Euro		Expenses	Expenses
Third-party fees and expenses	74.938	5.121	15.299	-	95.358
Cost of Self-Constructed Assets	(37.319)	-	-	-	(37.319)
Total Α	37.619	5.121	15.299	-	58.039
Personnel Fees & Expenses (Note 8)	65.737	22.082	40.803	-	128.621
Utilities	39.817	4.530	11.573	-	55.920
Depreciation and amortization (Note 7)	34.472	625	4.210	-	39.307
Provision for costs of raw water (e)	27.785	-	-	-	27.785
Various Provisions (Notes 22, 23, 30)	1.784	-	-	(477)	1.307
Various Expenses	6.410	3.134	3.640	-	13.185
Raw materials and consumables	10.718	468	1.078	-	12.264
Cost of Self-Constructed Assets	(6.590)	-	-	-	(6.590)
Total Β	180.133	30.839	61.304	(477)	271.798
Total (Α + Β)	217.752	35.960	76.602	(477)	329.838

The Notes on pages 432 – 490 form an integral part of these Financial Statements

454

COMPANY

31.12.2024	Cost of Sales	Distribution	Administrativ	Impairment of Financial	Total
Amounts in k Euro		Expenses	e Expenses	Assets
Third-party fees and expenses	93.675	4.757	20.379	-	118.811
Cost of Self-Constructed Assets	(51.767)	-	-	-	(51.767)
Total Α	41.908	4.757	20.379	-	67.044
Personnel Fees & Expenses (Note 8)	70.814	23.338	46.107	-	140.259
Utilities	37.507	5.163	14.328	-	56.997
Depreciation and amortization (Note 7)	35.229	540	6.221	-	41.990
Provision for costs of raw water (e)	29.133			-	29.133
Various Provisions (Notes 22, 23, 30)	(5.199)	-	-	6.501	1.301
Various Expenses	7.740	4.256	4.179	-	16.175
Raw materials and consumables	12.912	258	1.146	-	14.316
Cost of Self-Constructed Assets	(8.963)	-	-	-	(8.963)
Total Β	179.173	33.554	71.980	6.501	291.209
Total (Α + Β)	221.081	38.312	92.359	6.501	358.253

31.12.2023	Cost of Sales	Distribution	Administrativ	Impairment of Financial	Total
Amounts in k Euro		Expenses	e Expenses	Assets
Third-party fees and expenses	74.930	5.121	15.277	-	95.329
Cost of Self-Constructed Assets	(37.319)	-	-	-	(37.319)
Total Α	37.611	5.121	15.277	-	58.010
Personnel Fees & Expenses (Note 8)	65.738	22.082	40.800	-	128.620
Utilities	39.817	4.530	11.572	-	55.919
Depreciation and amortization (Note 7)	34.472	625	4.210	-	39.307
Provision for costs of raw water (e)	27.785	-	-	-	27.785
Various Provisions (Notes 22, 23, 30)	1.784	-	-	(477)	1.307
Various Expenses	6.404	3.134	3.641	-	13.180
Raw materials and consumables	10.718	468	1.078	-	12.264
Cost of Self-Constructed Assets	(6.590)	-	-	-	(6.590)
Total Β	180.128	30.839	61.301	(477)	271.792
Total (Α + Β)	217.739	35.960	76.578	(477)	329.800

The fluctuation of expenses compared to the previous year is presented in the following tables:

a. UTILITIES (GROUP & COMPANY)

The account is analyzed as follows:

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Electric Power	29.059	32.873	29.059	32.873
Natural Gas	54	107	54	107
Expenses concerning short-term leases	8.193	7.694	8.193	7.694
Expenses concerning payments of variable leases which are not included in	126	124	126	124
the measurement of liabilities from leases
Expenses from leases concerning contracts that were “silently” renewed	778	914	778	914
Telecommunication – Postal Expenses	4.126	4.261	4.126	4.261
Repairs and maintenance	8.830	6.820	8.830	6.820
Other utilities	5.831	3.127	5.831	3.126
Total (Note 6)	56.997	55.920	56.997	55.919

The Notes on pages 432 – 490 form an integral part of these Financial Statements

455

b. MISCELLANEOUS EXPENSES (GROUP & COMPANY)

The account is analyzed as follows:

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Taxes - Duties	4.963	4.703	4.959	4.700
Materials for Immediate Consumption	3.738	3.130	3.738	3.130
Promotion and Advertising Expenses	1.843	1.125	1.843	1.125
Transport Expenses	1.060	1.045	1.060	1.045
Sponsoring Expenses - Grants	1.356	1.021	1.356	1.021
Other Expenses	3.227	2.160	3.220	2.158
Total (Note 6)	16.186	13.185	16.175	13.180

c. THIRD PARTY FEES & EXPENSES (GROUP & COMPANY)

The account, after the deduction of the cost of self-constructed assets (Total A), is analyzed as follows:

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Fees of Sub-contractors of Psitalia WTP	24.194	25.358	24.194	25.358
Fees of Sub-contractors of Mornos WTP	3.464	1.977	3.464	1.977
Fees of Water Supply Network Sub-contractors	5.198	4.736	5.198	4.736
Other Third Party Fees	34.219	25.968	34.188	25.939
Total (Note 6)	67.075	58.039	67.044	58.010

d. VARIOUS PROVISIONS (GROUP & COMPANY)

The account is analyzed as follows:

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Provisions for Impairment of Receivables	6.501	(477)	6.501	(477)
Provisions for Litigations Cases	(4.703)	1.992	(4.703)	1.992
Provisions for Obsolete Inventories	(496)	(208)	(496)	(208)
Total (Note 6)	1.301	1.307	1.301	1.307

e. RAW WATER COSTS (GROUP & COMPANY)

Law 4812/2021 (Government Gazette 110/A’/30-6-2021) renewed the exclusive right to provide water supply and sewerage

services granted to EYDAP SA until 31.12.2040 with par. 1 of Article 2 of Law 2744/1999 (A '222). On 02.02.2022, based on the

above provisions, the relevant contract of L.4812 / 2021 was signed between the Greek State, the Legal Entity of Public Law

EPEYDAP and EYDAP SA. The term of the Contract for Sale of Water and Exclusive Right stands at twenty years, for the period from

01.01.2021 to 31.12.2040. The consideration of water supplied by EYDAP SA is defined in the unit price per cubic meter, specifically

in the table of Article 10 of the contract which for the year 2024 amounted to Euro 29,133 k. In the corresponding period last year,

the cost for the Company amounted to Euro 27.785 k

The Notes on pages 432 – 490 form an integral part of these Financial Statements

456

7. DEPRECIATION EXPENSES

Depreciation expenses of fixed assets are recorded on the basis of fixed assets’ useful life, applying the straight line depreciation

method, as follows:

Ι.	WATER SUPPLY NETWORKS
Primary Water Supply Pipelines		25-35 years
Secondary Water Supply Pipelines		25-50 years
Distribution Networks, External and Internal Pumping Stations		10-50 years
Storage tanks – Water Treatment Plants		20-50 years
Ι.	SEWERAGE NETWORKS
Heavy Infrastructure and Primary Collection Units		25-50 years
Secondary Pipelines		25-50 years
External Branches		25-50 years
Electromechanical Installations		25-50 years
IΙΙ.	ANTI-POLLUTION PROJECTS AND WASTE WATER TREATMENT PLANTS
Waste Water Treatment R&D Centers		10-40 years
Waste Water Treatment Plants		10-40 years
IV.	OTHER
Furniture & Fixture		5 years
Computer Hardware		3-4 years
Vehicles		5-7 years
Machinery		6-10 years
Buildings		20 years

The amounts recorded in the financial statements are analyzed as follows:

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Depreciation of tangible assets	40.501	39.623	40.501	39.623
Amortization of intangible assets	2.426	710	2.426	710
Amortization of the exclusive right	4.375	4.375	4.375	4.375
Amortization of investment subsidies	(6.135)	(6.139)	(6.135)	(6.139)
Expenses related to the depreciation of right-of-use assets	822	738	822	738
Total (Note 6)	41.990	39.307	41.990	39.307

The Notes on pages 432 – 490 form an integral part of these Financial Statements

457

8. PERSONNEL FEES & EXPENSES (GROUP & COMPANY)

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Salaries and Wages	104.806	94.798	104.805	94.797
Social Security Contributions	23.577	22.045	23.577	22.045
Provision for staff indemnity Law 2112 (Note 29a)	1.283	1.303	1.283	1.303
Provision for Special One-Off Indemnity for employees	1.094	1.223	1.094	1.223
hired up to the date 25/10/1999 (Note 29.d)
Provision for Special One-Off Indemnity for employees	93	113	93	113
hired after the date 25/10/1999 (Note 29.c)
Provisions for Healthcare Beneficiaries (Note 29.b)	2.210	1.983	2.210	1.983
Other Provisions	7.199	7.156	7.199	7.156
Total (Note 6)	140.261	128.621	140.259	128.620

9. OTHER EXPENSES (GROUP & COMPANY)

Other expenses include

• charge from electricity consumption for water pumping according to the operation and maintenance agreement for the second

half of 2024, amounting to Euro 6,998 k, which constitutes an equal income of EYDAP SA from EPEYDAP and is reflected in the

item “Other operating income”

• accident-related compensations, inventory deficit differences, extraordinary losses totaling Euro 3,668 k for the current period

and Euro 3,413 k for the corresponding period last year. It is pointed out that in the current period, the item includes an amount

of approximately Euro 1.3 million, compared to Euro 0.4 million in the corresponding period last year, which concerns provision

for impairment of other receivables due to their non-recoverability (Note 24).

10. FINANCIAL INCOME (GROUP & COMPANY)

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Interest from Customers	8.815	8.495	8.815	8.495
Dividends	7	-	7	-
Interest earned on times deposits	10.776	8.881	10.763	8.871
Other Income	438	440	438	440
Total (Note 5)	20.036	17.816	20.022	17.806

The Company's financial income as of 31 December 2024 amounted to EUR 20,022 thousand from EUR 17,806 thousand in the

corresponding period of the previous year. This change of Euro 2.2 million is mainly due to the increase in interest income from

bank deposits amounted to Euro 1.9 million.

11. FINANCIAL EXPENSES (GROUP & COMPANY)

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Interest of leases – IFRS 16	95	88	95	88
Interest costs on the actuarial liability	8.049	9.381	8.049	9.381
Other expenses	1.896	1.866	1.896	1.866
Total	10.041	11.335	10.041	11.335

The Notes on pages 432 – 490 form an integral part of these Financial Statements

458

The Company's financial expenses as of 31 December 2024 amounted to Euro 10,041 k compared to Euro 11,335 k in the

corresponding period of the previous year. This change of Euro (1.3) million is due to the increase in interest from the change in

interest rates on the actuarial liability of the Company's defined benefit plans in accordance with IAS 19 (Note 29).

12. INCOME TAX

a. Income Tax in the Income Statement

The income tax of the current year represents the total amount of the current income tax, deferred tax, and tax provision for the

unaudited financial years as well as the tax audit differences, and is analyzed as follows:

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Corresponding Income Tax	5.139	8.556	5.139	8.556
Tax settlement differences	264	12	264	12
Deferred Taxation	5.014	(852)	5.014	(852)
Total	10.417	7.716	10.417	7.716

The following income tax has arisen for the current period:

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Earnings before tax	25.069	27.992	25.056	27.988
Income tax calculated with the tax rate in effect (22%)	5.512	6.158	5.512	6.158
Income tax settlement differences	264	12	264	12
Tax on permanent differences and non tax-deductible expenses	4.641	1.546	4.641	1.546
Total	10.417	7.716	10.417	7.716

The income tax has been calculated in accordance with the tax legislation based on the tax rate of 22% currently in effect.

b. Income Tax in the Statement of Financial Position

Current Tax Obligation

In 2024, the total tax obligation amounts to Euro 1,873 k and is analyzed as follows:

Amounts in k Euro
Current Income Tax of FY 2024	5.139
Withheld Taxes – Income tax advance – Obligation for Income Tax 2024	(3.266)
Total current tax obligations as at 31.12.2024	1.873

The tax obligations of the Company for the years from 2011 to 2024 have not been examined by the tax authorities.

Therefore, the tax results of the aforementioned years have not been finalized.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

459

For the fiscal years 2011 to 2023, the Company had been subject to the tax audit of the Certified Public Accountants according to

the provisions of paragraph (5) of article 82 of Law 2238/1994 (fiscal years 2011 up to 2013) and 65A of Law 4174/2013 (fiscal

years 2014 - 2023) as in force and Unqualified Conclusion Tax Compliance Reports were issued. The tax compliance reports for the

fiscal years 2016, 2017, 2018, 2019, 2020, 2021, 2022 and 2023 include Emphasis of Matter, which refers to the request to the

Independent Public Revenue Authority regarding the obligation to register property rights in the Company's Statement of Property

Inquiry (E9).

For the year 2024, the Company has been subject to the tax audit of the Certified Public Accountants in compliance with the

provisions of Article 65a of Law 4174/2013. This audit is in progress and the relevant tax certificate is due to be issued after the

publication of the financial statements for the year 2024.

It is noted that the Partial Tax Audit of the Company by the Independent Authority for Public Revenue (AADE) No. 109/26.03.2025

for the period 1.1.2019-31.12.2019 is in progress.

The financial statements include provisions for potential tax differences totaling Euro 2.4 million.

NISON EYDAP DEVELOPMENT SA has not been audited for tax purposes from the fiscal year 2011 and onwards and no relevant

provision has been made due to its limited business transactions.

13. EARNINGS PER SHARE

The basic earnings per share are calculated by dividing the net profit of the period attributable to ordinary shareholders with the

weighted average number of ordinary shares in issue during the period. Profits are defined as profits/losses from continuing

operations of the Group. It is noted that in the current year, as well as in the previous one, there were no discontinued operations.

There were no convertible bonds or other potentially dilutive convertible securities during the periods reported in the

accompanying financial statements, so there is no calculation of any diluted earnings per share.

An entity presents basic and diluted earnings per share, even if the disclosed amounts are negative (e.g. loss per share).

	GROUP		COMPANY
	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Earnings/(Losses) corresponding to the shareholders (in k	14.652	20.275	14.639	20.272
Euro)
Weighted average number of shares in circulation	106.500	106.500	106.500	106.500
Earnings/(Losses) per share – Basic in Euro	0,14	0,19	0,14	0,19

At its meeting held on 29.04.2025, the Company’s Board of Directors approved submitting a proposal to the Regular General

Meeting of Shareholders regarding distribution of a dividend, pursuant to Articles 159, 160 and 161 of Law 4548/2018, amounting

to seven cents (Euro 0.07) per share, ( total gross amount Euro 7.455 k ). The dividend is subject to the approval of the Regular

General Meeting of shareholders and is included in the balance of the "Retained earnings" item.

14. GOODWILL

The goodwill of Euro 3,357 k on 31 December 2024 concerns the amount paid in excess for the acquisition of Elefsina, Aspropyrgos

and Lykovrisi networks as compared to the networks’ net replacement cost, which was valued at the time of the acquisition.

The cash generating units and - consequently - the goodwill of the networks, are tested for potential impairment on annual basis,

or provided that the events or the changes of conditions indicate that such impairment could be effective. No impairment loss has

arisen from the impairment test, conducted by the Financial Analysis & Investors Relations Department of the Company in

December 2024.

In particular:

In order to settle its receivables from certain local government authorities (OTA), the Company signed contracts with three

municipalities (Aspropyrgos and Elefsina during the 2

half of 2003 and Likovrisi in the 2

half of 2006) for the transfer of

The Notes on pages 432 – 490 form an integral part of these Financial Statements

460

ownership of their water supply networks. In the context of the above contracts, water supply networks of 327 kilometers were

transferred to EYDAP. The networks service, via 26,786 connections, 65,000 inhabitants approximately of the particular

municipalities, which are now added to the Company’s customer base.

The acquisition of the network of Aspropyrgos Municipality accounted for Euro 2,749 k and was settled by offsetting an equal debt

to the Company. The appraisal of the network in replacement cost, which was performed by the Company’s technical department

and was in agreement with the corresponding estimates of the Municipality’s technical department, amounts to Euro 2,192 k.

The acquisition of the network of Elefsina Municipality accounted for Euro 1,800 k and was settled by offsetting a debt of Euro

1,500 k to the Company and via a payment of Euro 300 k from the Company to the municipality. The appraisal of the network in

replacement cost, which was performed by the Company’s technical department and was in agreement with the corresponding

estimates of the Municipality’s technical department, amounts to Euro 681 k.

The acquisition of the network of Likovrisi Municipality accounted for Euro 2,271 k and was settled by offsetting an equal debt to

the Company. The appraisal of the network in replacement cost, which was performed by the Company’s technical department

and was in agreement with the corresponding estimates of the Municipality’s technical department, amounts to Euro 590 k.

15. OTHER INTANGIBLE ASSETS (GROUP & COMPANY)

Acquisition Cost on 31st December 2023	124.116
Additions	2.853
Balance on 31st December 2024	126.969
DEPRECIATION
31st December 2023	(48.432)
Depreciation for the Year	(6.801)
Reductions / Transfers	0
Total Depreciation on 31st December 2024	(55.233)
Net Value
31st December 2023	75.684
31st December 2024	71.736

Other intangible assets concern expenses for the purchase of software and other intangible fixed assets, which are expected to

generate future benefits to the Company. These expenses are recorded as intangible assets. Software assets are mainly

depreciated over a three-year period whereas with regard to the other intangible fixed assets, the Company reviews their

economic life on a regular basis.

On 02/02/2022, pursuant to paragraphs 1, 2 and 4 of Article 114 of Law 4812/2021, the following contracts were signed between

the Greek State, the legal entity under public law EPEYDAP and EYDAP SA:

(1) the relevant contract under Law 4812/2021 (Exclusive Right Contract) following which, among other things, against

consideration the State - EPEYDAP grants the intangible and special right, provided by the Law, of the exclusive supply of raw water

to EYDAP and agrees on the annual supply of raw water for twenty years effective from 1.1.2021 to 31.12.2040, as specifically

defined in Article 10 of this contract

(2) the relevant contract of Article 4812/2021, following which EYDAP was assigned operation and maintenance of the EYS with

an initial term of three years with the possibility of extension for another six months.

As an implementation of the above legislative provision, under Article 10 of the Exclusive Right Contract, against consideration,

EYDAP SA receives the special intangible right of exclusive supply of Raw Water throughout the period provided by Law and in the

contract term (1.1.21 - 31.12.2040) and its Consideration (Raw Water) is agreed, determined on the basis of a price per cubic

meter that is valid for each reporting year according to a table included in the aforementioned Contract.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

461

On 27.04.2022 a memorandum of understanding was signed between the Greek State, EPEYDAP, and the consideration paid for

the intangible right of exclusive supply of raw water amounting to Euro 87,500 k was determined. The cost of acquiring the

intangible right is subject to amortization corresponding to the duration of the commitment, the contract, the supply of the raw

water. It is to be noted that the liability that had been incurred to EPEYDAP for the provision of the intangible right is offset against

the corresponding claim of the Company due to the provided network maintenance service during three and a half years and till

30.06.2024, according to the respective contract for maintenance and operation of the external water system. As at 31.12.2024

the book value of the intangible right stands at Euro 70.000 k.

16. TANGIBLE ASSETS

The Company, applying the provisions of IFRS 1 “First-time adoption of IFRS”, used the exception concerning recording and

valuation of property assets during the compilation of the Transitional Balance Sheet to the IFRS on 1 January 2004. In this context,

the Company considered the adjusted value of its property assets as deemed (implied) cost for the purposes of the compilation of

the Transitional Balance Sheet to the IFRS on 1 January 2004. Specifically for the transition to IFRS, the Company recorded the self-

utilized property assets at fair values based on studies performed by independent valuators. These fair values constituted the

deemed cost for the compilation of the Balance Sheet.

The changes in fixed assets of the Group and the Company for FYs 2024 and 2023 are presented in the table below as follows:

2024		Machinery &	Water Supply	Sewerage	Motor	Prepayments
	Land &	Mechanical	Network &	Networks &	Vehicles &	&	Total
	Buildings	Equipment	consumption	Biological	Furniture	Constructions
Amounts in k Euro			meters	Treatment		in Progress
Non-Depreciated Value on 1st January	251.081	2.449	200.527	258.315	15.056	56.331	783.758
2024
Additions	27	1.219	13.668	6.677	1.943	40.385	63.919
Reductions/Transfers	0	0	0	0	(192)	0	(192)
Deprecation Reverse Entry	0	0	0	0	192	0	192
Depreciation of the Year	(2.354)	(678)	(16.524)	(15.437)	(5.508)	0	(40.501)
Non-Depreciated Value on 31/12/2024	248.754	2.991	197.671	249.555	11.490	96.716	807.175
01.01.2024:	251.081	2.449	200.527	258.315	15.056	56.331	783.758
Cost	306.818	28.298	564.808	576.344	87.676	56.331	1.620.276
Accumulated Depreciation	(55.736)	(25.849)	(364.283)	(318.029)	(72.622)	0	(836.519)
Net Non-Depreciated Value	251.081	2.449	200.524	258.315	15.055	56.331	783.758
31.12.2024
Cost	306.845	29.517	578.475	583.022	89.427	96.717	1.684.003
Accumulated Depreciation	(58.090)	(26.526)	(380.807)	(333.467)	(77.938)	0	(876.828)
Net Non-Depreciated Value	248.755	2.991	197.668	249.555	11.489	96.717	807.175

The Notes on pages 432 – 490 form an integral part of these Financial Statements

462

2023		Machinery &	Water Supply	Sewerage	Motor	Prepayments
	Land &	Mechanical	Network &	Networks &	Vehicles &	&	Total
Amounts in k Euro	Buildings	Equipment	consumption	Biological	Furniture	Constructions
			meters	Treatment		in Progress
Non-Depreciated Value on 2023	253.197	2.082	207.755	266.346	18.930	30.673	778.980
Additions	378	915	8.882	7.133	1.608	25.658	44.574
Reductions/Transfers	0	0	0	0	(359)	0	(359)
Deprecation Reverse Entry	0	0	0	0	185	0	185
Depreciation of the Year	(2.493)	(548)	(16.110)	(15.163)	(5.309)	0	(39.623)
Non-Depreciated Value on 31.12.2023	251.081	2.449	200.527	258.315	15.054	56.331	783.758
01.01.2023:	253.197	2.082	207.755	266.346	18.930	30.673	778.980
Cost	306.440	27.383	555.929	569.211	86.428	30.673	1.576.061
Accumulated Depreciation	(53.243)	(25.301)	(348.174)	(302.866)	(67.497)	0	(797.081)
Net Non-Depreciated Value	253.197	2.082	207.755	266.346	18.930	30.673	778.980
31.12.2023
Cost	306.818	28.298	564.811	576.345	87.677	56.331	1.620.276
Accumulated Depreciation	(55.736)	(25.849)	(364.283)	(318.029)	(72.621)	0	(836.519)
Net Non-Depreciated Value	251.081	2.449	200.527	258.315	15.056	56.331	783.758

Additions standing at Euro 40.385 k. to the item "Prepayments & Constructions in Progress" for FY 2024 include:

● an amount of Euro 60.730 k. for constructions in progress,

● an amount of Euro (20.345) k. for consolidations of the year (Euro 13.668) k. for water supply network & consumption

meters and Euro (6.677) k for Sewerage Network - Biological treatment.

17. RIGHT-OF-USE ASSETS AND LIABILITIES FROM LEASES (GROUP & COMPANY)

The statement of Financial Position of the Company and the Group includes the following amounts in relation to the leases:

Right-of-use assets

(Amounts in k Euro)	BUILDINGS & MOTOR VEHICLES
Net book value 1st January 2024	2.949
Net book value 31st December 2024	2.819
Depreciation charges for the year ended on 31st December 2024	822

Additions of Euro 692 k were made to ROU assets in FY 2024 made for the Group and the Company due to the singing of a new

lease agreement for a building in Aspropyrgos, East Attica, due to readjustments to lease payments given the change in the

Consumer Price Index (CPI) as well as due to the signing of a new motor vehicle contract.

Lease liabilities
(Amounts in k Euro)	31.12.2024	31.12.2023
Long-term	2.137	2.237
Short-term	814	812
Total lease liabilities	2.951	3.049

The Group mainly leases land & buildings, in order to serve its administrative and operational needs. Lease terms are negotiated

on an individual basis and contain a wide range of different terms and conditions. The majority of those lease contracts contain

The Notes on pages 432 – 490 form an integral part of these Financial Statements

477

Cost of curtailment / settlements / service termination		-
Total expense in the account of results	138	181
Change in the present value of the liability
Present value of liability at the beginning of period	13.932	12.797
Cost of current employment	93	113
Interest cost	418	469
Employee contributions	970	809
Benefits paid from the plan	(497)	(36)
Benefits paid from the employer	-	-
Cost of curtailment / settlements / service termination	-	-
Cost of prior service at the period	-	-
Actuarial loss / (profit) – financial assumptions	(433)	28
Actuarial loss / (profit) – demographic assumptions	-	92
Actuarial loss / (profit) – evidence from the period	4.022	(339)
Present value of liability at the end of period	18.504	13.932
Change in the value of assets
Value of plan’s assets at beginning of period	11.685	10.548
Expected return on assets	373	400
Contributions from the employer	388	23
Contributions from employees	970	809
Benefits paid from the plan	(497)	(36)
Expenses	71	(60)
Asset adjustment (via Equity)	-	-
Actuarial (loss) / gain	-	-
Value of plan’s assets at the end of the period	12.990	11.685

It is to be noted that the fair value of the plan’s assets noted above, amounted to Euro 12,990 k and Euro 11,685 k on 31.12.2024

and 31.12.2023 respectively.

PERIOD	01.01 - 31.12.2024	01.01 - 31.12.2023
Adjustments
Adjustments in liabilities due to change of assumptions	433	(120)
Empirical adjustments in liabilities	(4.022)	339
Empirical adjustments in assets	71	(60)
Total actuarial gain / (loss) in the Equity	(3.517)	159

The Notes on pages 432 – 490 form an integral part of these Financial Statements

478

Changes in the Net Liability recognized in Balance Sheet
Net Liability at beginning of period	2.247	2.249
Contributions from Employer	(388)	(23)
Benefits paid by the employer	-	-
Total expenditure recognized in the results	138	181
Change in Equity	3.517	(159)
Net Liability at the end of year	5.514	2.247

The expected contributions from the plan over the following year are estimated at Euro 2,604 k.

The major actuarial assumptions applied under calculating the relevant provisions for the special lump sum account for employees

hired after 26.10.1999, are the following

Actuarial assumptions	2024	2023
Discount rate	3,09%	3,15%
Inflation	1,90%	2,10%
Future salary increases	1,90%	2,10%
Duration of obligations	8,36	8,44

d. Special lump sum account for employees hired until 25.10.1999

With the voting of article 45 of Law 4179/2013, which abolished the clauses of article 26 of Law 2939/2001 concerning the

mandatory coverage of the account’s deficit from the Greek State for employees hired until 25.10.1999, the Company’s

Management proceeded with an actuarial study in order to estimate the relevant provision for employees’ indemnity.

PERIOD	01.01 - 31.12.2024	01.01 - 31.12.2023
Amounts recognized in the balance sheet
Present value of liabilities	95.233	91.815
Fair value of the plan’s assets	(13.188)	(12.672)
Net liability recognized in the balance sheet	82.046	79.142
Amounts recognized in the results
Cost of current employment	1.094	1.223
Net interest on the liability / (asset)	2.115	3.077
Profit or Loss under settlement	-	-
Total administrative expenses recognized in the income statement	-	-
Ordinary expenses in the income statement	3.208	4.300
Precious service cost	-	-
Cost of curtailment / settlements / service termination	-	-
Total expense in the income statement	3.208	4.300
Change in the present value of the liability
Present value of liability at the beginning of period	91.815	96.535
Cost of current employment	1.094	1.223

The Notes on pages 432 – 490 form an integral part of these Financial Statements

479

Interest cost	2.489		3.143
Employee contributions	1.278		1.269
Benefits paid from the plan	(13.580)		(7.756)
Benefits paid from the employer	-		-
Cost of curtailment / settlements / service termination	-		-
Cost of prior service at the period	- -		-
Actuarial loss / (profit) – financial assumptions	(208)	221	221
Actuarial loss / (profit) – demographic assumptions	-		265
Actuarial loss / (profit) – evidence from the period	12.347		(3.086)
Present value of liability at the end of period	95.233		91.815

Change in the value of assets	01.01 - 31.12.2024	01.01 - 31.12.2023
Value of plan’s assets at beginning of period	12.672	11.732
Expected return on assets	374	65
Benefits from the employer	12.347	7.054
Contributions from employees	1.278	1.269
Benefits paid from the plan	(13.580)	(7.756)
Expense	-	-
Asset adjustment (via Equity)	-	-
Actuarial (loss) / gain	97	308
Value of plan’s assets at the end of the period	13.188	12.672

It is to be noted that the fair value of the plan’s assets recorded above, amounted to Euro 13,188 k. and Euro 12,672 k. on

31.12.2024 and 31.12.2023 respectively.

PERIOD	01.01 - 31.12.2024	01.01 - 31.12.2023
Adjustments
Adjustments in liabilities due to change of assumptions	208	(486)
Empirical adjustments in liabilities	(12.347)	3.086
Empirical adjustments in assets	97	308
Total actuarial gain / (loss) in the Equity	(12.042)	2.908
Сhanges in the Net Liability recognized in Balance Sheet
Net Liability at beginning of period	79.142	84.804
Contributions from Employer	(12.347)	(7.054)
Benefits paid by the employer	-	-
Total expenditure recognized in the results	3.208	4.300
Change in Equity	12.042	(2.908)
Net Liability at the end of year	82.046	79.142

The expected contributions from the plan over the following year are estimated at Euro 21,142 k.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

480

The major actuarial assumptions applied under calculating the relevant provisions for the special lump sum account for employees

hired until 25.10.1999, are the following:

Actuarial assumptions	2024	2023
Discount rate	3,09%	3,15%
Inflation	1,90%	2,10%
Future salary increases	1,90%	2,10%
Duration of obligations	4,05	5,09

Sensitivity analysis of the results:

The results of the valuation are dependent on the assumptions (financial and demographic) of the actuarial study. We have

calculated the actuarial Defined Benefit Obligation (DBO) on the valuation date for every plan and for the following sensitivity

scenarios:

DBO (in Euro)
Scenario	Law 2112/20	Special Account	Health Care	Special Provision
Discount rate +0.5%	36.339.021	17.786.635	153.252.420	93.391.510
Discount rate -0.5%	38.146.649	19.268.213	174.583.526	97.145.132
Inflation +0.5%	38.153.200	19.261.467	174.631.174	97.045.670
Inflation -0.5%	36.324.606	17.786.755	153.083.829	93.471.088
Remuneration increase +0.5%	37.251.722	19.564.380	-	97.644.235
Remuneration increase -0.5%	37.182.759	17.510.234	-	92.889.456
Life expectancy +1 year	37.242.797	18.499.444	170.291.028	95.319.254
Life expectancy -1 year	37.197.221	18.508.924	156.538.645	95.139.517
Incidence of a disease +0,5%	-	-	175.552.230	-
Incidence of a disease -0,5%	-	-	152.127.487	-

DBO (change)

Scenario	Law 2112/20	Special Account	Health Care	Special Provision
Discount rate +0.5%	-2,40%	-3,90%	-6,20%	-1,90%
Discount rate -0.5%	2,50%	4,10%	6,90%	2,00%
Inflation +0.5%	2,50%	4,10%	6,90%	1,90%
Inflation -0.5%	-2,40%	-3,90%	-6,30%	-1,90%
Remuneration increase +0.5%	0,10%	5,70%	Ν/Α	2,50%
Remuneration increase -0.5%	-0,10%	-5,40%	Ν/Α	-2,50%
Life expectancy +1 year	0,10%	0,00%	4,30%	0,10%
Life expectancy -1 year	-0,10%	0,00%	-4,20%	-0,10%
Incidence of a disease +0,5%	Ν/Α	Ν/Α	7,50%	Ν/Α
Incidence of a disease -0,5%	Ν/Α	Ν/Α	-6,90%	Ν/Α

The Notes on pages 432 – 490 form an integral part of these Financial Statements

481

30. PROVISIONS FOR PENDING LITIGATIONS (GROUP & COMPANY)

The account in analyzed as follows:

Amounts in k Euro	31.12.2024	31.12.2023
Provisions for pending litigations with employees - pensioners	14.526	23.154
Provisions for civil litigations	20.399	16.475
Total	34.925	39.628

As of 31.12.2024, lawsuits for civil cases against the Company accounted for approximately Euro 73,8 million. The lawsuits

concerned indemnities for damages from flooding (due to pipeline fractures or rainfalls), or cases involving various counterparty

suppliers and sub-contractors with regard to violation of contractual terms. Furthermore, there are pending legal cases for

employment differences of approximately Euro 100 million.

The total amount of the provisions that the Company has made accounts for approximately Euro 35 million at 31.12.2024 (an

amount of approximately Euro 39.6 million as at 31.12.2023).

Moreover, an amount of approximately Euro 2 million, , which concerns the balance of the compromise solution of labor disputes

under the decisions of the Board of Directors no. 19105/21.12.2016 and 19224/24.05.2017, is presented in the short-term

liabilities (same as last year).

The provision for disputed legal cases is based on management's estimates in conjunction with the Legal Services Division for the

amount that is likely to be disbursed.

31. INVESTMENT SUBSIDIES (GROUP & COMPANY)

The account in the financial statements is analyzed as follows::

Amounts in k Euro	31.12.2024	31.12.2023
Opening Value:
Investment Subsidies	297.459	282.876
Income from sewage network rights 22%	37.814	37.805
	335.273	320.681
Accumulated Depreciation
Investment Subsidies	(142.956)	(137.665)
Income from sewage network rights 22%	(19.129)	(18.187)
	(162.085)	(155.852)
Net (Non Depreciated) Value
Investment Subsidies	154.503	145.211
Income from sewage network rights 22%	18.685	19.618
	173.188	164.829

The Company receives subsidies from the European Union, through the Greek State, in order to finance certain projects.

Furthermore, the Company’s customers (including the public sector and the local government authorities) participate in the

financing scheme of the initial network development cost (meters, network connections, etc.) or its upgrade.

It should be noted that the process of transferring projects to the NSRF 2021-2027 by the competent public bodies has been

delayed, which has led to delays in approval decisions on the progress of projects and the temporary inability to pay the amount

The Notes on pages 432 – 490 form an integral part of these Financial Statements

482

corresponding to the European Union funding and the disbursement from EYDAP's own resources. For the financial year leading

up to 31.12.2024, the Company paid approximately an amount of Euro 13.6 million. Cumulatively, up to the date of approval of

the financial statements, the Company had paid approximately an amount of Euro 20.9 million from its own resources. The

amounts will be reimbursed from the NSRF to EYDAP upon completion of the project transfer process by the public sector

stakeholders.

The related one-off charges that were charged to customers before the 30th of June 2009 (i.e. earlier than the effective date of

IFRIC 18 which was not applied retrospectively) were accounted for by the Company as deferred income and recognized in income

over the useful life of the relevant fixed assets.

With the adoption of IFRS 15, the amount of € 33,259 k that was included as deferred income in the Statement of Financial Position

as at 1st January 2018 under the heading "Investment Subsidies and Customer Contributions" was recognized in retained earnings

of the Company and the Group.

The above subsidies and income from rights 22% are accounted for at the time of receipt and are recorded in the Statement of

Financial Position in the long-term liabilities. These amounts constitute deferred income and are depreciated on the basis of the

economic life of the relevant assets, at the time their operation commences. The amortization of subsidies and income from rights

22% are deducted from the depreciation of fixed assets in the income statement.

Apart from the above, the Company has also received other type of state subsidies such as the granting of a concession to Psitalia

island, which EYDAP utilizes for the operation of the waste treatment management.

32. CONSUMERS’ GUARANTEES

The amounts of Euro 19,542 k on 31.12.2024 and Euro 19,312 k. on 31.12.2023 concern customer guarantees for the use of the

water meter, paid at the time of water supply connection. The above guarantees are paid back (free of interest) upon request

from the customer for termination of the water supply connection. The above guarantees have been recorded in nominal value,

and not at fair value, initially, and in a following stage in their net (amortized) cost, since they can be claimed from the customers

at any time.

33. OPERATING & OTHER SHORT-TERM LIABILITIES

The account in the financial statements is analyzed as follows:

a. Operating Short-Term Liabilities

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Suppliers	80.164	64.389	80.164	64.389
Withheld Taxes Payable	7.490	6.948	7.490	6.948
Social Security Contributions and Other Items	2.548	2.286	2.548	2.286
Contractual Obligations	8.067	7.224	8.067	7.224
Dividends Payable	298	345	298	345
Operating Short-Term Liabilities	98.568	81.192	98.567	81.192

Operating short-term liabilities of the Company increased in the current period by Euro 17.4 million in relation to those recorded

on 31.12.2023 and amounted to approximately Euro 98.6 million on 31.12.2024. This change is mainly due to suppliers item.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

483

b. Other Short-term Liabilities

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Pending litigations with employees - pensioners	1.985	2.056	1.985	2.056
Checks Payable	149	158	149	158
Collections for Third Parties	1.012	1.012	1.012	1.012
Collective Labor Agreement Obligation	10.342	7.321	10.342	7.321
Personnel Compensation	2.797	643	2.797	643
Other Short-Term Liabilities	8.291	7.097	8.304	7.109
Short-Term Customer Guarantees	6.520	6.086	6.520	6.086
Other Short-Term Liabilities	31.096	24.373	31.108	24.385

In the item “Pending litigations with employees – pensioners” include the implementation of the decisions of the Board of

Directors No. 19105/21.12.2016 and 19224/24.5.2017.

Furthermore, the Company's Obligation to the employees in accordance with the Collective Labor Agreement regarding the

imminent conclusion of a defined contribution pension insurance plan is included in the item “Collective Labor Agreement

Obligation”. Until the conclusion of the relevant contract, the Company’s liability for 2024, stands at Euro 10.3 million.

34. COMMITMENTS AND CONTINGENT LIABILITIES - ASSETS

Contingent liabilities are not recorded in the financial statements but they are disclosed, provided that the possibility of an outflow

of resources incorporating financial benefits is minimal.

1. Commitments concerning Non-Executed Contracts

The Company’s commitments which concern expansions, improvements and maintenance of networks and installations, electrical

and thermal energy production unit installations, etc., accounted for Euro 269 million approximately on 31.12.2024 and for Euro

272 million approximately on 31.12.2023.

2. Letters of Guarantee

The Company has issued letters of guarantee for liability insurance of Euro 3,931 k. on 31.12.2024.

3. Pending Litigations

Pending litigations are analyzed as follows:

Amounts in k Euro	Amount Demanded	Provision	Contingent Liability
Labor Issues	99.696	16.511	83.185
Law of obligations	73.796	20.399	53.397
Total	173.492	36.910	136.582

The provision amount of Euro 36.9 million includes an obligation of Euro 2 million approximately, recorded in the item “Pending

litigations with employees - pensioners” in Other Short-term Liabilities.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

484

35. RELATED PARTY TRANSACTIONS (GROUP & COMPANY)

Α) Transactions with Members of the BoD

Amounts in k Euro		31.12.2024	31.12.2023
Short-term benefits:
-	Fees (Chairman & CEO, and Executive Directors)	203	273
-	Fees & attendance expenses of BoD members	352	274
-	Social insurance cost	92	84
Additional benefits		8	25
Total		654	656

Β) Transactions with Related Parties

Amounts in k Euro	31.12.2024	31.12.2023
Short-term benefits:
Related parties fees	610	551
Social insurance cost	99	90
Additional benefits	10	13
Actuarial obligation	51	63
Total	770	717

The Executive Committee was established following the BoD Decision Num. 21144/ 21.12.2022.

The members of the aforementioned Committee are the executives responsible for planning and reviewing the Company's

operations in accordance with IAS 24 and Company presents the amounts of the previous year as well for comparability purposes.

C) Transactions and amounts outstanding with the Greek State and the Municipalities (OTA)

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
1) Transactions
- Income	84.009	81.400	84.009	81.400
- Expenses	29.265	27.911	29.265	27.911
2) Outstanding amounts
- Long-term receivables (Projects for the Greek State)	6.701	3.652	6.701	3.652
- Trade receivables (Local authorities, Greek State)	75.027	52.743	75.027	52.743
- Receivables from NISON DEVELOPMENT SEWERAGE SOCIETY	9	-	9	-
ANONYME
- Other Receivables (from EPEYDAP from water pumping)	6.998	-	6.998	-
- Short-term Liabilities (provisions for raw water costs)	29.187	34.339	29.187	34.339

Transactions with the Greek State and Local Authorities (OTA) concern revenue from water supply, invoiced and accrued. In

particular, revenues include the amount of Euro 12,500 k invoiced by EYDAP SA in 2024 as well as accrued non-invoiced revenue

for the second half of 2024 for the provision of operation

and maintenance services in 2024. Expenses mainly include the provision for raw water supply of EPEYDAP in 2024, amounting

to Euro 29.1 million.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

485

D) Transactions and balances with other Related parties consolidated with HCAP SA

Amounts in k Euro	31.12.2024	31.12.2023
1) Transactions
Income	-	884
Expenses	-	20.709
Dividend payments	-	-
	31.12.2024	31.12.2023
2) Balances
Trade receivables	-	3.920
Liabilities towards suppliers	-	5.222

The above balances include a cumulative provision of the amount of Euro 2,4 million, mainly related to balances of receivables

formed in previous years by ETVA, Marina Zeas and HPP. Legal proceedings are in progress for these balances. According to article

64 of Law 5035/29.07.23, all shares of ownership of HCAP in EYDAP SA are transferred to the Greek State and therefore there are

no transactions and balances consolidated with HCAP SA from now on.

36. AUDITORS FEES

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Auditors remuneration for auditing the annual accounts	67	64	64	61
Auditors remuneration for the Tax Compliance Report	15	14	15	14
Other fees	60	46	60	46
Total fees	142	124	139	121

37. EYDAP FIXED ASSETS “EYDAP L.E.P.L.”

1. “EYDAP Fixed Assets Legal Entity of Public Law L.E.P.L.” was established at the time of the Company’s public listing (IPO) aiming

at transferring the ownership of the water dams and basins of Marathon, Mornos, Yliki and Evinos. Apart from the

constructions and the expansions of the facilities which are connected to the above dams and basins, the Greek State through

“EYDAP Fixed Assets L.E.P.L.” supplies the Company with raw water so that the Company is in position to fulfill its obligations

with regard to the provision of water supply services.

2. It is to be noted that:

● the Aqueduct of Yliki until the Viliza in Thiva was transferred to the competent Land Registry of Thiva and Oropos.

● The construction sites of Amfissa and Chrissos in Delphi have already been incorporated into the competent office of

Amfissa which operates as Land Registry.

3. The Board of Directors of “EYDAP S.A.” with the decision 18448/ 24.09.2014 approved the signing of an agreement

between “EYDAP Fixed Assets Legal Entity of Public Law L.E.P.L.” and “EYDAP S.A.” concerning the water supply and

invoicing, since 1/10/2014, of the local government authorities and other legal entities of public law from “EYDAP Fixed

Assets L.E.P.L.” along the External Water Supply System which concerns geographic areas beyond the jurisdiction of

“EYDAP S.A.”. Particularly, the above decision concerned the following Municipalities:

● Delfoi

● Leivadia (and of DEYAL)

● Thiva (and of DEYATH)

● Tanagra

The Notes on pages 432 – 490 form an integral part of these Financial Statements

486

● Chalkida (and of DEYACH)

● Distomo – Arachova

4. In compliance with the contract signed on 02.02.2022 of L.4812 / 2021 between the Greek State and EYDAP SA, EPEYDAP is

the exclusive provider of water services outside the area of activity, maintaining the exclusive right to supply water to

individuals along its external water supply system (Article 5.5.1). In this context, the procedure of subcontracting individuals'

contracts to EPEYDAP is carried out.

5. An Addendum was signed between EYDAP, the Greek State, and EYDAP Fixed Assets. In June 2023, the tripartite Addendum to

as of 2.2.2022 Agreement was signed between EYDAP, the Greek State, and EYDAP Fixed Assets. The agreement defines

performing works on the Aqueduct Mornos - Marathonas, Kleidi - Dafnoula Section. Under this agreement, the implementation

of an important project to upgrade the External Water Supply System of Attica is promoted.

6. In its letter no. 1170/08.08.2023, EPEYDAP informed EYDAP SA of the unilateral extension of the contract for the operation

and maintenance of the External Water Supply System (EWS) under the same terms, for an additional period of six (6) months,

until 30 June 2024.

7. For the period after 30.6.2024, a new agreement was signed for the operation and maintenance of the of the EWSS (SLA)

between EYDAP Fixed Assets (EPEYDAP), EYDAP SA, and the Greek State. This agreement extends the duration of the

assignment under the same terms for a period of eighteen (18) months, from July 1, 2024, to December 31, 2025.

38. CAPITAL MANAGEMENT

The Company manages its capital in such way in order to meet its objectives as these are mentioned in paragraph 4a of article 1

of Law 2744/99. In addition, according to paragraph 8 of the same article the placement of its fixed real estate assets used for

water supply and sewerage purposes as collateral is prohibited. It is noted that according to article 5 of the same law there is no

provision for compulsory administration of the assets of EYDAP used for water supply and sewerage purposes.

In the current period, the Company does not possess any bank liability either long-term or short-term. Following its listing on the

Athens Exchange in 2000 and until 2013, the Company held mainly short-term debt, in order to meet its operating needs due to

the fact that it had not collected payments for water supply bills from certain municipalities and other public entities.

The Company maintains sufficient capital in order to serve its business objectives and to apply the appropriate dividend policy.

Leverage ratio

	GROUP		COMPANY
Amounts in k Euro	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Borrowings	-	-	-	-
Cash and cash equivalents	(299.639)	(325.795)	(298.797)	(324.974)
Total Equity	827.528	847.259	827.827	847.571
Net Debt to Equity Ratio	-	-	-	-

39. FINANCIAL RISK MANAGEMENT

Risk management is processed by the Company’s pertinent Departments which operate under certain rules which have been

approved by the Board of Directors.

The Board of Directors sets the objectives, defines the policy, and selects the risk management framework, the implementation of

which is assigned to the Company's executives. The existence of a risk management framework is of central importance and the

monitoring process is structured, continuous and consistent.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

487

(a) Credit Risk

The Company’s exposure with respect to the credit risk is limited to the financial assets which at the reporting date of the Financial

Statements are analyzed as follows:

	GROUP		COMPANY
Financial Assets categories	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Financial assets at fair value through the other comprehensive income	853	907	853	907
Cash and cash equivalents	299.639	325.795	298.797	324.974
Trade and other receivables and contractual assets	203.864	181.786	203.807	181.720
Long-term receivables	22.793	15.418	22.793	15.418
Investments in subsidiaries	-	-	1.210	1.210
Total	527.150	523.906	527.460	524.229

Trade and other receivables are included in receivables from private clients for which there is a relative risk, which is limited by

measures and actions taken by the competent directorates. The actions concern the assumption of measures in order to deal with

the arrears of due liabilities and the provision of facilities for their repayment.

For the category of local government liabilities, the Company examines the possibility of collecting arrears through the signing of

contracts (network management or settlements) or through regulatory arrangements.

The Group and the Company use the methodology for measuring the impairment of financial assets in accordance with IFRS 9

Analysis of the Company’s receivables based on their maturity is displayed below as follows:

Amounts in k Euro
		TIME ANALYSIS OF OVERDUE RECEIVABLES
2024	Non overdue	0-1 month	1-6 months	6 months	-2	2 years	-5	> 5 years	Total
				years		years
PRIVATE	32.412	9.996	21.037	30.236		29.070		55.502	178.253
CUSTOMERS
STATE	2.330	809	2.057	3.915		2.888		10.155	22.154
LOCAL	6.110	1.808	7.007	17.327		8.034		3.690	43.976
GOVERNMENT
Total	40.852	12.613	30.101	51.478		39.992		69.347	244.383

2023	Non overdue	0-1 month	1-6 months	6 months -2	2 years -5	> 5 years	Total
				years	years
PRIVATE
CUSTOMERS	30.213	6.117	22.219	34.010	28.681	52.349	173.589
STATE	2.360	134	1.635	3.127	2.398	10.244	19.899
LOCAL
GOVERNMENT	5.644	331	9.267	11.216	3.723	3.340	33.521
Total	38.218	6.583	33.121	48.353	34.802	65.933	227.009

The Department of Revenue & Trade Receivables Management, as well as the Department of Special Customers Management,

continuously monitor the claims of the Company, either separately or based on groups (invoice codes, customer categories) and

incorporate this information into the credit risk control procedure.

With regard to credit risk management, the Department of Collection Enforcement of the Legal Services Division reviews on

constant basis and settles via judicial procedures (LD 356/1974 “Code for the Collection of Public Revenues”) overdue receivables

concerning water supply, utilization rights and property connection rights from retail customers and local government authorities

(OTA).

The Notes on pages 432 – 490 form an integral part of these Financial Statements

488

Cash and cash equivalents are subject to an impairment test in accordance with the requirements of IFRS 9 and the estimated

impairment loss is not judged as significant. Credit risk management is carried out by aggregating the largest part of the Company's

assets into the Bank of Greece (approximately 60%) and by limiting the exposure to other credit institutions (mainly systemic

banks).

None of the financial assets has been placed as collateral or in any other form of credit insurance.

Correspondingly, the Company has not assigned to third parties as a form of guarantee financial instruments through Assets.

(b) Liquidity Risk

The liquidity risk is addressed through preservation of sufficient cash available and by the assurance of bank credits for use. There

is no liquidity risk due to the existence of sufficient cash reserves which can cover the current operating and investment needs.

The following table analyses the Company’s financial liabilities which are classified in groups according to their expiration date

which are calculated according to the time balance from the balance sheet date until the contractual arrangement expiration date

at non-discounted values.

Amounts in k Euro
ANALYSIS OF MATURITY OF LIABILITIES
2024	0-1 Month	2-3 Months	3-6 Months	6-12 Months	1- 5 years	> 5 years	Total
Debt liabilities	-	-	-	-	-	-	-
Liabilities due to employee benefits	-	-	-	-	78.474	235.833	314.307
Provisions / Other long-term liabilities	-	-	-	-	-	54.467	54.467
Suppliers and other liabilities	36.825	52.024	7.802	5.764	-	-	102.415
Provision for raw water costs	-	-	29.133	-	-	-	29.133
Liabilities from leases	73	145	218	377	1.945	192	2.951
Total	36.898	52.169	37.153	6.142	80.419	290.493	503.273

2023	0-1 Month	2-3 Months	3-6 Months	6-12 Months	1- 5 years	> 5 years	Total
Debt liabilities	-	-	-	-	-	-	-
Liabilities due to employee benefits	-	-	-	-	71.764	221.623	293.387
Provisions / Other long-term liabilities	-	-	-	-	-	58.939	58.939
Suppliers and other liabilities	16.681	39.310	11.945	15.872	-	-	83.809
Provision for raw water costs	-	-	27.785	-	-	-	27.785
Liabilities from leases	69	139	209	394	1.715	523	3.049
Total	16.750	39.449	39.939	16.267	73.479	281.085	466.969

Market risk is related to the Company's equity portfolio, which is a long-term, strategic investment and as a result is limited to pre-

defined Position Limits).

(d) Risk of Climate Change

EYDAP addresses climate risks as an opportunity to transition to a more sustainable, low-carbon future and implements mitigation

measures:

The Notes on pages 432 – 490 form an integral part of these Financial Statements

489

● Formulation of a strategy to improve energy efficiency and reduce the carbon footprint

● Implementation of water demand management and leakage reduction programmes to ensure rational and sustainable

management of water resources. Replacing old water meters with new 'smart' water meters of state-of-the-art

technology. Network rehabilitation and replacement of old pipelines with new pipelines made of advanced materials

compatible with the natural environment.

● Circular economy practices, launching wastewater reuse projects at the East Attica Wastewater Treatment Plant for

irrigation of peri-urban green areas, industrial and municipal purposes.

● Use of technologies to improve the efficiency of water and wastewater treatment plants

● Alternative water resources for irrigation use such as exploitation and development of the Adrian Aqueduct

● Ensuring that every effort is made to save energy and resources in all its operations, actively contributing to the

reduction of greenhouse gas emissions

● Implementation of zero tolerance European and Greek regulations and standards, new and existing environmental

specifications in the design of water supply and sewerage projects

● Selecting materials and machinery with modern environmental standards. Monitoring and optimizing the cyclicality of

the materials used. Keeping products and materials (including raw materials) in the life cycle for as long as possible, and

treating waste as a secondary raw material that can be recycled for processing and reuse (circular economy).

● Electric vehicles – extending the potential to replace part of its fleet with electric vehicles to contribute to low

greenhouse gas emissions

● Upgrading and modernizing its buildings and facilities with new building materials and energy systems.

The Company ensures and plans contingency management scenarios that may arise due to climate risk. It recognizes the way each

of its organizational units operates, and has included in the risk register of the Risk Management Framework the risks against

which it must be shielded to effectively respond.

(h) EWS failure risk

EYDAP and all the other involved bodies had recognized and evaluated the risk of unsafe water supply in Attica due to failure of

the external water supply system in the unifying aqueduct, owned by the State.

It is estimated that potentially arising damage in this area will cause a temporary deficit of 30-40% of Athens water supply.

On August 4, 2022, the Ministry of Infrastructure and Transport sent a letter to EYDAP in which it is stated that EYDAP is expected

to be assigned immediate priority projects for the EWS, with a budget of Euro 78 million (including VAT) in accordance with Law

4412/16 and the terms of the contract signed as at February 2, 2022. However, the Ministry had not determined the way of

financing the projects, while the relevant contract with EYDAP has not been signed yet either.

In order to avoid the effects of this risk, in March 2023 EYDAP sent a request to the competent Ministries for the specification of

the financing method and the necessary conditions for the implementation of the necessary improvement projects.

In the letter, the Management sent in April 2023 to the supervising ministry, following a relevant meeting attended by the

representatives of EYDAP, EYDAP Fixed Assets, Ministry of Transport and Infrastructure, Ministry of Environment and Energy, it

was communicated that the fastest and most feasible solution to proceed as soon as possible with the implementation of the said

projects is to conclude a contract between EYDAP S.A. and EYDAP Fixed Assets. The relevant directions of the supervising ministry

are expected to be issued directly.

Under article 7 "Raw Water Supply Obligation", of the effective contract with the Greek State:

"The State is obliged throughout the term of the Contract to supply the Beneficiary with Raw Water in accordance with the terms

of this Contract and in any case based on the criteria set out in Articles 8 (Quantitative Characteristics) and 9 (Qualitative

Characteristics) of this Contract."

Consequently, in the event of failure to supply EYDAP with raw water, the financial loss falls in particular on the Greek State, which

has a contractual obligation to provide EYDAP with raw water. EYDAP's risk mainly concerns its corporate reputation. EYDAP's

assessment is that, if the above-mentioned implementation of the necessary projects starts as soon as possible, this risk will be

minimized.

The Notes on pages 432 – 490 form an integral part of these Financial Statements

490

40. FAIR VALUE DETERMINATION

The fair value of the financial assert, are traded in active markets (stock exchanges) (i.e. derivatives, stocks, bonds, mutual funds)

is determined based on their published price quotations, effective on the financial statements’ reporting date. Available for sale

financial assets are measured at fair value, which is their market price, and, therefore, are classified in Level 1, according to the

provisions of IFRS 7, par. 27B.

The fair value of financial assets, not traded in active markets, is determined, applying valuation techniques and

assumptions, based on market data on the Financial Statements reporting date.

It is estimated that the nominal value less provisions for impairment of trade receivables approximates their actual value. The

actual values of financial liabilities for presentation purposes in the financial statements are calculated based on the present

value of their future cash flows, applying the effective interest rate, available for the Company for using similar financial

instruments.

41. SIGNIFICANT EVENTS

Determination of the management adequacy of EYDAP by RAAEY

In March 2025, RAAEY, within the framework of its responsibilities as defined in the provisions of Articles 12A and 12B of

Law No. 4001/2011 (A' 179), and under No. ΥΠΕΝ/ΔΣΔΔΥ/53924/460/2023 (B' 3309), confirmed the management adequacy

of EYDAP S.A. for the provision of water services.

491

2 INDEPENDENT AUDITOR’S REPORT

This is a translation into English of the Statutory Auditors’ report issued originally in Greek and is provided for the convenience of

English speaking readers. This report includes information specifically required by European regulation and Greek law and should

be read in conjunction with, and construed in accordance with, Greek law and International Standards on Auditing (ISAs)

incorporated into the Greek Legislation.

INDEPENDENT AUDITOR’S REPORT

To the Shareholders of the Athens Water Supply and Sewerage Company (EYDAP S.A.)

Report on the Audit of the Separate and Consolidated Financial Statements

Opinion

We have audited the accompanying separate and consolidated financial statements of the Company EYDAP

S.A. (the Company) which comprise the separate and consolidated statement of financial position as at

December 31st, 2024, separate and consolidated statements of comprehensive income, changes in equity

and cash flows for the year then ended and a summary of significant accounting policies and other

explanatory information.

In our opinion, the accompanying separate and consolidated financial statements present fairly, in all material

respects, the financial position of the Company EYDAP S.A. and its subsidiary (the Group) as at December

31st, 2024, their financial performance and their cash flows for the year ended in accordance with

International Financial Reporting Standards that have been adopted by the European Union.

Basis for Opinion

We conducted our audit in accordance with International Standards on Auditing (ISAs) incorporated into the

Greek Legislation. Our responsibilities under those standards are described in the “Auditor’s Responsibilities

for the Audit of the Separate and Consolidated Financial Statements” section of our report. We are

independent of the Company and its consolidated subsidiary within our entire assignment in accordance with

the International Ethics Standards Board for Accountants’ Code of Ethics for Professional Accountants

(IESBA Code) incorporated into the Greek Legislation and ethical requirements relevant to the audit of

separate and consolidated financial statements in Greece and we have fulfilled our ethical responsibilities in

accordance with these requirements and the IESBA Code. We believe that the audit evidence we have

obtained is sufficient and appropriate to provide a basis for our opinion.

Key Audit Matters

Key audit matters are those matters that, in our professional judgement, were of most significance in our audit

of the separate and consolidated financial statements of the current period. These matters, as well as the

related risk of significant misstatements, were addressed in the context of our audit of the separate and

492

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

Audit Approach

Revenue recognition

The turnover of the Company and the Group

amounted for the year ended 31/12/2024 to €

373,7 mil., (€ 351,6 mil. for the year ended

31/12/2023).

Periodic counting and invoicing based on the

current consumption invoices of

approximately 2.2 mil. supplies are required

in order to recognize the company’s revenue.

Revenue recognition as well as updating the

accounting systems is performed

automatically through the company's

subsystems. The Company uses information

systems and internal controls in order to

ensure an integrated revenue recognition

framework.

Revenue recognition has been defined as a

key audit matter since it is a complex issue

associated with the high volume of

transactions, use of information systems in

order to update the prices and revenue

recognition, in line with the management’s

judgments and estimates.

The Company’s disclosures concerning the

accounting policies followed regarding

revenue recognition, are recorded in notes 3

and 5 to the financial statements.

Our audit approach included, among

others, the following procedures:

● Review of the IT systems environment,

including internal procedures and

related security controls.

● Review of correct data transfer from

individual information systems to the

general accounting trial balance.

● Discussion with the management and

assessment of the internal controls in

respect of the procedure of estimating

revenue for consumed and non-

invoiced amount of water and the

corresponding revenue from rendering

sewerage services.

● Review of mathematical accuracy of

the calculations and sound accounting

treatment of the amounts.

● The contribution of a Grant Thornton

expert was used regarding the

aforementioned procedures, when

deemed necessary.

● Assessment of adequacy and

suitability of the disclosures recorded

in the separate and consolidated

financial statements.

Recoverability of trade receivables

As at 31/12/2024 the trade receivables of the

Company and the Group amounted to €

187,5 mil. including accumulated impairment

loss allowance of € 105,6 mil. (€ 169,9 mil.

and € 99,1 mil. as at 31/12/2023).

The Company applies the simplified approach

under IFRS 9 "Financial Instruments" and

calculates the expected credit losses

throughout the entire life of their trade

receivables. In order to calculate the

expected credit losses, historical data are

used that reflect the expected impact of the

current data in the future.

Our audit approach included, among

others, the following procedures:

● Review of internal controls in place, in

respect of trade receivables

impairment test.

● Obtaining and reviewing the

calculation of trade receivables

impairment performed by the

management, assessing, inter alia,

completeness and accuracy of the

data used to determine the expected

credit losses as well as the

493

We have defined the procedure of trade

receivables impairment test as one of the key

audit matters given the amount of these

accounts in line with the significance of the

management’s assumptions and estimates

applied under this procedure.

The Company’s and the Group’s disclosures

regarding the accounting policy, judgments,

estimates and assumptions used under the

trade receivables impairment test are

recorded in notes 3 and 23 to the separate

and consolidated financial statements.

assumptions, on which the

Management based its estimates.

● Review of mathematical accuracy of

the calculations and sound accounting

treatment of the amounts.

● Assessment of adequacy and

suitability of the disclosures recorded

in the separate and consolidated

financial statements.

Employee benefits obligations

The Company is required to cover the

medical cost of employees, retired

employees and dependent members of their

families. It is also required to pay employee

lump sum retirement benefit and specific

lump sum retirement benefit, according to the

current labour law and the collective labour

agreement of the personnel.

These benefits are treated by the

Management as a defined benefit plan and

the estimate of the obligation is made

according to IAS 19. The Management used

independent actuaries in order to determine

the appropriate assumptions regarding the

variables, such as the level of inflation,

discount rate, future increases in salaries,

mortality rate and the preparation of the

relative study.

Given the size of € 314,3 mil. (2023: € 293,4

mil. approximately) and the sensitivity of the

liability amount to various parameters – the

assumptions mentioned above - we have

defined assessment of employee benefits as

one of the key audit matters.

The respective Management’s disclosures in

respect of employee benefits obligations

according to IAS 19 are recorded in Note 29

to the financial statements.

Our audit approach included, among

others, the following procedures:

● Review of the policy regarding

recognition of the relevant liability in

relation to the provisions of IAS 19

● Review and reconciliation of the data

and information provided by the

Company's Management to the

external actuaries, regarding the

Company's personnel.

● Evaluation, with the assistance of a

specialized technical actuarial

consultant, of the actuarial

assumptions and the calculations of

the actuarial study.

● Sample based review of the

calculation and accounting treatment

of the benefits paid to employees in

the year under audit.

● Assessment of adequacy of the

disclosures made by the

Management in compliance with IAS

19 in note 29 to the financial

statements.

494

Other Information

Management is responsible for the other information. The other information included in the Annual Financial

Report includes the Board of Director’s Report, the reference to which is made in the “Report on Other Legal

and Regulatory Requirements” section of our Report and Statements of the Members of the Board of

Directors, but does not include the separate and consolidated financial statements and our auditor’s report

thereon.

Our opinion on the separate and consolidated financial statements does not cover the other information and

we will not express any form of assurance conclusion thereon.

In connection with our audit of the separate and consolidated financial statements, our responsibility is to

read the other information and, in doing so, consider whether the other information is materially inconsistent

with the separate and consolidated financial statements or our knowledge obtained in the audit, or otherwise

appears to be materially misstated. If, based on our audit, we conclude that there is a material misstatement

therein, we are required to communicate that matter to those charged with governance.

No such issue has arisen.

Responsibilities of Management and Those Charged with Governance for the Separate and

Consolidated Financial Statements

Management is responsible for the preparation and fair presentation of the separate and consolidated

financial statements in accordance with International Financial Reporting Standards that have been adopted

by the European Union and for such internal control as management 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, management is responsible for assessing

the Company’s and the 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 the management’s intention

is to proceed with liquidating the Company and the Group or discontinuing their operations or unless the

management has no other realistic option but to proceed with those actions.

The Company’s Audit Committee (Article 44, Law 4449/2017) is responsible for overseeing the Company’s

and the Group’s financial reporting process.

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 an aggregate, 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, incorporated into the Greek Legislation, 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 affect 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, incorporated into the Greek Legislation, we exercise professional

judgment and maintain professional skepticism throughout the audit. We also:

495

● Identify and assess the risks of material misstatement of the separate and consolidated financial

statements, whether due to fraud or error, design and perform 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 that resulting from error,

as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of

internal control.

● 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 the Group’s internal control.

● Evaluate the appropriateness of accounting policies used and the reasonableness of accounting

estimates and related disclosures made by the management.

● Conclude on the appropriateness of management’s 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 the 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 the Group to cease to continue as a going concern.

● Evaluate the overall presentation, structure and content of the 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.

● Obtain sufficient appropriate audit evidence regarding financial information of entities or business

activities within the Group for the purpose of expressing an opinion on the separate and consociated

financial statements to be able to draw reasonable conclusions on which to base the auditor’s opinion.

Our responsibility is to design, supervise and perform the audit of the Company and its subsidiaries. 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 current period

and are therefore the key audit matters.

496

Report on Other Legal and Regulatory Requirements

1. Board of Directors’ Report

Taking into consideration that Management is responsible for the preparation of the Board of Directors’ Report

and the Corporate Governance Statement included in this report, according to the provisions of paragraph 1,

cases aa', ab' and b', of Article 154C of Law 4548/2018, which do not include the sustainability report and for

which we have issued a related limited assurance report dated 29.04.2025 in accordance with International

Standard on Assurance Engagements 3000 (Revised), we note the following:

a) The Board of Directors’ Report includes the corporate governance statement that provides the information

required by Article 152 of Law 4548/2018.

b) In our opinion, the Board of Directors’ Report has been prepared in accordance with the legal requirements

of articles 150 and 153 of Law 4548/2018 with the exception of the requirement to submit a sustainability

report under paragraph 5A of Article 150 of the same law and the content of the report is consistent with

the accompanying financial statements for the year ended 31.12.2024.

c) Based on the knowledge we acquired during our audit, we have not identified any material misstatements

in the Board of Directors’ Report in relation to the Company EYDAP S.A. and its environment.

2. Additional Report to the Audit Committee

Our opinion on the accompanying separate and consolidated financial statements is consistent with our

Additional Report to the Company Audit Committee, prepared in compliance with Article 11, Regulation (EU)

No 537/2014.

3. Provision of Non-Audit Services

We have not provided to the Company and its subsidiary any prohibited non-audit services referred to in

article 5 of Regulation (EU) 537/2014.

Non-prohibited non-audit services we rendered to the Company and its subsidiary within the year ended as

at December 31st 2024 are disclosed in Note 36 to the accompanying separate and consolidated financial

statements.

4. Auditor’s Appointment

We were first appointed the Company’s Chartered Accountants following as of 26/6/2019 Decision of the

Annual Regular General Meeting of the Shareholders. Since then, our appointment has been constantly

renewed for a total period of 6 years in compliance with the decisions of the annual regular general meetings

of shareholders.

5. Bylaws (Internal Regulations)

The Company has in effect Bylaws (Internal Regulations) in conformance with the provisions of article 14 of

Law 4706/2020.

497

6. Assurance Report on European Single Electronic Format

Subject Matter

We have undertaken a reasonable assurance engagement to review the digital records of EYDAP S.A.

(hereinafter “the Company and/or the Group), prepared in accordance with the European Single Electronic

Format (ESEF), which comprise the separate and consolidated financial statements of the Company and the

Group for the year ended December 31, 2024, in XHTML, as well as the provided XBRL

(213800SA1M6NZ4YSQU91-2024-12-31-en.zip) with the appropriate mark-up, on the aforementioned

consolidated financial statements including other explanatory information (Notes to financial statements)

(hereinafter (the "Subject Matter") in order to verify 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 prepared in accordance with

the Commission Delegated Regulation (EU) 2018/815 as amended by the Commission Delegated Regulation

(EU) 2020/1989 (hereinafter the ESEF Regulation) and the European Commission Interpretative

Communication 2020/C379/01 of November 10, 2020, in conformance with Law 3556/2007 and the relevant

announcements of the Hellenic Capital Market Commission and the Athens Stock Exchange (ESEF

Regulatory Framework). In summary, this framework includes, inter alia, the following requirements:

- All annual financial reports shall be prepared in XHTML format.

- For the consolidated financial statements in accordance with IFRS, financial information included in the

Statements of Comprehensive Income, Financial Position, Changes in Equity and Cash Flows, as well as

the financial information included in other explanatory information shall be marked-up with XBRL (XBRL

‘tags’ and “‘block tag”’), in accordance with the effective ESEF Taxonomy. ESEF technical specifications,

including the relevant taxonomy, 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 December 31, 2024, in accordance with the

Applicable Criteria, and for such internal control as management determines is necessary to enable the

preparation of digital records that are free from material misstatement, whether due to fraud or error.

Auditor’s Responsibilities

Our responsibility is to issue this Report in respect of the assessment of the Subject Matter, based on our

assurance engagement, as described below in the section "Scope of the Engagement”.

We conducted our work in accordance with the International Standard on Assurance Engagements 3000

“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 to evaluate the Subject

Matter in accordance with the Applicable Criteria. As part of the procedures performed, we assess the risk of

material misstatement of information related to the Subject Matter.

We consider that the evidence we have obtained is sufficient and appropriate and supports the conclusion

reached in this assurance report.

498

Professional ethics and quality management

We are independent of the Company and the Group during our entire assignment and we have complied with

the requirements of the International Ethics Standards Board for Accountants Code of Ethics for Professional

Accountants (IESBA Code) the ethical and independence requirements of Law 4449/2017 and Regulation

(EU) 537/2014.

Our auditing firm applies the International Standard on Quality Management (ISQM) 1 “Quality Management

for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services

Engagements” and accordingly, operates a comprehensive system of quality management including

documented policies and procedures regarding compliance with ethical requirements, professional standards

and applicable legal and regulatory requirements.

Scope of engagement

The assurance procedures we performed covers, in a limited way, the items included in the BoD Resolution

214/4/11-02-2022 of the Hellenic Accounting and Auditing Standards Oversight Board (HAASOB) and the

"Guidelines in relation to the work and assurance report of the Statutory Auditors on the European Single

Electronic Reporting Form (ESEF) of the issuers with securities listed on a regulated market in Greece", as

issued by the Institute of Certified Public Accountants of Greece (SOEL) 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 Engagement" section to obtain reasonable assurance

based on the procedures described. In this context, the work we performed could not provide absolute

assurance that all matters that could be considered material weaknesses would be disclosed.

Conclusion

Based on the procedures performed and the evidence obtained, we express the conclusion that the separate

and consolidated financial statements of the Company and the Group for the year ended December 31, 2024,

in XHTML format, as well as the provided XBRL file (213800SA1M6NZ4YSQU91-2024-12-31-en.zip) with

the appropriate mark-up on the above consolidated financial statements, including the Notes, have been

prepared, in all material respects, in accordance with the Applicable Criteria.

Athens, April 29, 2025

The Certified Public Accountant

Panagiotis Christopoulos

Registry Number SOEL 28481

Amounts in k Euro	GROUP		COMPANY
	31.12.2024	31.12.2023	31.12.2024	31.12.2023
Personnel Loans (Note 24)	4.308	5.332	4.308	5.332
Settlement of overdue amounts from Municipalities	5.333	2.740	5.333	2.740
Advances for compensation of expropriated lands	12.536	6.652	12.536	6.652
Guarantees (Public Power Corp., Real Estate)
	616	618	616	618
Other long term receivables	0	76	0	76
Total	22.793	15.418	22.793	15.418

Amounts in k Euro
					(Burden)/
	Closing	(Burden)/	Burden)/	Closing Balance	Benefit in the	Burden)/	Closing Balance
Description	Balance	Benefit in the	Benefit in		Income	Benefit in
	01.01.2023	Income	Equity		Statement	Equity
		Statement		31.12.2023			31.12.2024
Expensing of intangible assets	8	-	-	8	-	-	8
Inventory impairment	633	(46)	-	587	(109)	-	478
Obligation for employee benefits	37.106	(245)	2.339	39.200	(2.478)	6.680	43.402
Provision for doubtful receivables	6.570	438	-	7.008	1.392	-	8.400
Customer and municipalities	4.557	(41)	-	4.516	(105)	-	4.411
contributions
Amortization difference between	(10.693)	(1.886)	-	(12.579)	(1.916)	-	(14.495)
accounting and tax basis
Deferred tax in Tax Reserve due to	6.828	-	-	6.828	-	-	6.828
revaluation of real estate assets
Impairment of securities	4.398	-	-	4.398	1	-	4.399
Other deferred taxation items	16.440	2.631	-	19.071	(1.799)	-	17.272
Total	65.847	853	2.339	69.039	(5.014)	6.680	70.705

Amounts in k Euro
	31.12.2024	31.12.2023
Consumables and Spare Parts	23.211	23.024
Provision for Impairment	(2.174)	(2.670)
Total	21.037	20.354

Amounts in k Euro	31.12.2024	31.12.2023
Opening balance	2.670	2.879
Provision for the year	(496)	(209)
Closing balance	2.174	2.670

Amounts in k Euro	Group & Company
Provision for impairment of receivables on 01.01.2024	99.125
Provision for the year’s impairment of receivables on 31.12.2024	6.501
Provision for impairment of receivables on 31.12.2024	105.627

	Number of	Acquisition	Valuation on	Valuation on
Amounts in k Euro	Shares	Cost	31.12.2024	31.12.2023
Thessaloniki Water Supply & Sewerage Co. (EYATH)	264.880	485	853	901
Attica Bank SA	5	20.000	0	6
Total	264.885	20.485	853	907

Retail Customer Receivables – Non settled	Non-overdue	0-30	30-60	60-90	90+	Total
Expected credit losses (%)	7,27%	7,27%	7,27%	7,27%	61,77%	43,40%
Receivable prior to impairment	30.707	8.535	5.291	4.572	96.579	145.684
Provision for impairment	2.233	621	385	333	59.653	63.224

Retail Customer Receivables – Settled	Non-overdue	0-30	30-60	60-90	90+	Total
Expected credit losses (%)	0,6%	0,6%	0,6%	0,6%	14,0%	10,6%
Receivable prior to impairment	100	491	780	910	6.895	9.176
Provision for impairment	1	3	5	5	963	976

Retail Customer Receivables excluding water	Non-overdue
supply and sewerage services		0-30	30-60	60-90	90+	Total
Possibility of Default (%)	-	9,50%	9,50%	9,50%	83,00%	75,60%
Receivable prior to impairment	-	960	15	31	8.968	9.974
Provision for impairment	-	91	1	3	7.446	7.542

Municipalities (OTA), Greek State, Public	Non-overdue
Utilities (DEKO)		0-30	30-60	60-90	90+	Total
Expected credit losses (%)	6,20%	6,20%	6,20%	6,20%	51,50%	43,50%
Receivable prior to impairment	3.933	2.616	73	3.000	57.801	67.425
Provision for impairment	245	163	5	187	29.777	30.377

Contractual Assets	Non-overdue	0-30	30-60	60-90	90+	Total
Expected credit losses (%)	5,76%	-	-	-	-	5,76%
Receivable prior to impairment	60.882	-	-	-	-	60.882
Provision for impairment	3.508	-	-	-	-	3.508

Total Receivables from Customers and	Non-overdue
Contractual Assets		0-30	30-60	60-90	90+	Total
Receivable prior to impairment	95.623	12.602	6.159	8.513	170.243	293.140
Provision for impairment	5.987	878	395	528	97.839	105.627
Total						187.513

Municipalities (OTA), Greek State, Public Utilities	Non-overdue
(DEKO)		0-30	30-60	60-90	90+	Total
Expected credit losses (%)	7,3%	7,3%	7,3%	7,3%	51,2%	43,5%
Receivable prior to impairment	6.549	423	2.563	2.750	45.661	57.947
Provision for impairment	477	31	187	200	23.372	24.266

Total Receivables from Customers and Contractual	Non-overdue
Assets		0-30	30-60	60-90	90+	Total
Receivable prior to impairment	85.183	6.610	9.935	7.793	159.459	268.980
Provision for impairment	6.129	526	759	575	91.138	99.126
Total						169.854

Adjustments
Adjustments in liabilities due to change of assumptions	6.872	(14.969)
Empirical adjustments in liabilities	(21.289)	1.558
Empirical adjustments in assets	-	-
Total actuarial gain / (loss) in the Equity	(14.417)	(13.411)
Changes in the Net Liability recognized in Balance Sheet
Net Liability at beginning of period	149.185	135.060
Contributions from Employer	-	-
Benefits paid by the employer	(7.278)	(6.225)
Total expenditure recognized in the results	7.025	6.939
Change in Equity	14.417	13.411
Net Liability at the end of year	163.348	149.185