Sustainability Report 2012

Building the Future we want

CONTENTS

Page 2 1. MESSAGE FROM THE CHAIRMAN 4 2. SUSTAINABILITY REPORT PARAMETERS 4 2.1 Report Scope and Boundary 6 2.2 Report Methodology 8 3. MYTILINEOS GROUP PROFILE 8 3.1 Structure & Activity Sectors 11 3.2 Group Governance Structure 12 3.3 Business Milestones 14 3.4 Strategy & Key Figures 15 3.5 Impact of Climate Change on business activity 15 3.6 Collaborations with social partners and organisations 16 3.7 Awards and distinctions 17 4. APPROACH TO CORPORATE SOCIAL RESPONSIBILITY 18 4.1 ESG (Environmental, Social and Governance) Milestones 20 4.2 Corporate Social Responsibility – Fundamental Commitments 21 4.3 Governance of Corporate Social Responsibility 22 4.4 Stakeholder engagement 28 4.5 CSR Performance in 2012 & Targets for 2013 32 5. ECONOMIC PERFORMANCE 32 5.1 Key economic value data 34 5.2 New investments 35 6. EMPLOYMENT & LABOUR PRACTICES 36 6.1 Employment 41 6.2 Employee Education, Training and Development 45 6.3 Occupational Health & Safety 47 6.4 Benefits 49 7. PROTECTION OF HUMAN RIGHTS 49 7.1 Fundamental labour rights 51 7.2 Equal opportunities & diversity 52 7.3 Freedom of Association 53 7.4 Child Labour 54 7.5 Forced Labour 55 8. ENVIRONMENTAL PROTECTION 55 8.1 Environmental Footprint of MYTILINEOS Group 59 8.2 Management of raw & other materials 61 8.3 Energy consumption 64 8.4 Water consumption 65 8.5 Emissions 67 8.6 Significant spills 67 8.7 Waste management 70 8.8 Environmental expenditures 71 8.9 Biodiversity 73 8.10 Compliance with environmental laws and regulations 74 9. SOCIAL COHESION AND DEVELOPMENT 74 9.1 Social Footprint of MYTILINEOS Group 78 9.2 Participation in the development of local communities 80 9.3 Social expenditures 82 9.4 Actions to strengthen Transparency & combat corruption 83 10. FAIR MARKET PRACTICES 83 10.1 Product Quality & Safety 85 10.2 Management of Local Suppliers 86 10.3 Client satisfaction 86 10.4 Responsible Communication & Marketing 86 10.5 Protection of client privacy 87 10.6 Relations with the Competition & Regulatory Compliance 88 11. MYTILINEOS GROUP – AGGREGATE PERFORMANCE SUMMARY 88 11.1 GRI Disclosures and Indicators 94 11.2 Coverage of the Principles of the UN Global Compact 95 11.3 Coverage of the clauses of the ISO 26000 Social Responsibility Guidance Standard

1 1. MESSAGE FROM THE CHAIRMAN

n a country going through its fifth year of deep recession, formulating and adhering to a well-organised, visionary strategy is a sine qua non for mov- Iing forward, both in the short and in the long term. In MYTILINEOS Group we are taking carefully planned steps, seeking to grow every day while protecting the interests of the Company, of our people and of our shareholders. With a clearly focused strategy that relies on our strong exporting profile and on strict cost controls, we have laid the foundations that consolidate our position today and create positive prospects for the future. Our strategy, however, is also driven by an additional key element: our desire to create shared value for society and for the economy. We do not limit ourselves to a social responsibility policy, which has a marginal role within our business strategy, functioning merely as a mechanism for redistributing a part of our profits or for mitigating any unavoidable impacts of our business activity. We know very well that the sustainability and the progress of organisations are inextricably linked with the development of their environment and, therefore, prosperity for any enterprise is inextricably linked to the prosperity of the society in which it operates. The only way forward is to move forward together. Our priority to become a driver for social growth and for development, carrying forward with us the society and the economy, is at the core of our Group’s operation. And with a corporate and economic footprint that is the reflection of 2,500 employees, €1.454 billion in turnover and subsidiary companies which gain distinctions in Greece and abroad, our dynamism is commensurate with our size. This dynamism translates into a holistic philosophy of responsibility, contribution and progress that is part of our corporate DNA. MYTILINEOS Group does not rest on its achievements, but instead works tirelessly to improve its social and economic footprint and to achieve nothing less than excellence. In taking every step, we want to help the efforts to strengthen the Greek economy, we support society, we protect the environment and we promote a proper and balanced work environment. We are not trying to build our own image along these four key action pillars, but to achieve real business and build the future that we wish for ourselves and for our children. We are building this future through a consistent, long-term strategy that is directly linked to our business operations and remains aligned with international standards and requirements. It is this philosophy which, despite last years economic adversities, made us achieve once more remarkable results. We generated a “social product” with a value of €233 million, allocated to taxes, salaries and social, business and environmental investments. Indeed, the Group’s aggregate social product since 2009 has exceeded €1 billion, in spite of the domestic recession. With Greece’s social structures in ever-increasing need of support, the Group remained steadfast in its commitment to address relevant issues. During 2012 we contributed approximately €800,000 to the promotion of culture, sports

2 and entrepreneurship, and we also provided local communities with assistance for covering local infrastructure needs. Conscious of the fact that our people are the Group’s heart and soul and a

family for which we are responsible, we not only managed to safeguard the SUSTAINABILITY REPORT 2012 jobs that we provide, which now exceed 2,500, but we also hired 374 new employees. At the same time, we have created a work environment which offers to our people security, equality, stability and a high level of satisfaction, and drives their commitment and loyalty to our corporate values. In the Health & Safety domain in particular, in 2012 we improved our performance, as we achieved our target for “Zero Accidents and Zero Occupational Diseases” while keeping the rate of incidents at near-zero levels. Regarding the protection of the environment, the Group’s initiatives in this area exceed the boundaries of statutory obligations and duties, always seeking to minimise the impacts resulting from its activities. We invested more than €10 million in environmental projects for waste treatment and discharge, the treatment of air emissions and the installation of “greener” technology. Finally, we remained a driving force for the Greek market and economy, as during the year we not only carried out €92 million of total investments, but we also demonstrated – and continue to do so, that despite the adverse economic juncture – the talent and creativity of Greek entrepreneurship, can and must grow. Of course the combination of difficult conditions, negative economic climate, overtaxation and red tape create inevitably a climate of uncertainty that hits the business community and, consequently, all social responsibility initiatives. In MYTILINEOS Group, however, we do not make easy compromises and remain steadfast in the course we have set for ourselves – to create shared value for all. As additional proof of our success in following this course and of our compliance with international standards, we obtained for yet another year the certification of the Global Reporting Initiative (GRI), international assessment organisation for the compliance of our Sustainability Report with the GRI-G3.1 Ap- plication, Level B reporting requirements. We also participated for the first time in Bloomberg’s ESG (Environmental, Social and Governance) indicator, and were ranked No. 1 among all participating Greek enterprises in terms of overall performance. Of course, distinctions are not an end in themselves – it is the essence of what they stand for that counts. Thomas Edison once remarked that “If we did all the things we are capable of, we would literally astonish ourselves.” In MYTILINEOS Group, we wish to astonish ourselves in this way every day.

Evangelos G. Mytilineos Chairman of the Board & CEO MYTILINEOS Group of Companies

3 2. SUSTAINABILITY REPORT PARAMETERS

e welcome you to the 5th 2.1 Report Scope and Boundary annual Sustainability Re- This year’s Sustainability Report in- Wport of MYTILINEOS Group troduces substantial changes from (hereinafter “Sustainability Report” the structure of our previous Re- or simply “Report”). Our Sustain- ports, as its preparation has been ability Reports, which are released based for the first time on the and published annually, present a combination of a number of inter- summary of the challenges that we national standards and guidelines, face in the domain of Corporate So- such as: cial Responsibility and of our related efforts and performance, in line - The seven fundamental principles with our goal to achieve socially re- of social responsibility defined by sponsible and sustainable develop- the ISO 26000 Social Responsibil- ment, as defined by our corporate ity Guidance Standard, which cov- values. The present Report that er accountability, transparency, ethical behaviour, respect for Stakeholder interests, respect for the rule of law and for interna- The key purpose of the Sustainability Report is 8 tional norms of behaviour, and re- to provide all social groups and all natural and spect for Human Rights. legal persons which the Group recognises as its - The OECD Guidelines on Corpo- key Stakeholders (employees, shareholders, rate Social Responsibility, which we take into account in our efforts financial analysts, corporate clients, suppliers, to determine and apply our re- business partners, government officials, the Press sponsible business conduct. & Media, and the local communities where the - The Ten Principles of the UN Glob- Group deploys and develops its activities) with al Compact; and direct, reliable and transparent information about - The Guidelines of the Global Re- porting Initiative (GRI) interna- the Group’s efforts, performance and future tional organisation on the publi- commitments concerning the integration of cation of Sustainability Reports. Corporate Social Responsibility in its operations. The novel features introduced with our Report for 2012 refer to the concrete description of our Social and Environmental footprints and covers the period from 1st January the presentation of our performance to 31st December 2012, is a con- regarding the economic, social and tinuation of our previous Sustain- environmental dimensions of our ac- ability Report 2011 and comple- tivities. To this end, in the present ments the Group’s Annual Report Report we have done away with the 2012. individual company sections which

4 presented information on our sub- and labour practices and on the pro- in detail in the Group’s Annual Re- sidiaries and had served as the ba- tection of human rights and the en- port 2012, and because the CSR sis for our previous Reports. In- vironment, together with data con- section of the Group’s website now stead, we have chosen to high- cerning our contribution to the so- provides comprehensive coverage of light by means of suitable graphs or cial cohesion and development of the following subjects: textboxes the aspects of our sub- the local communities where we op- - The degree of compliance with the sidiaries’ performance, whether pos- erate. The results presented for the Corporate Governance Code and itive or negative, that play a signif- Group cover extensively the envi- any deviations from it.

icant part in establishing the over- ronmental and social initiatives and SUSTAINABILITY REPORT 2012 - The relationship between the earn- all picture for the Group in each ref- performance (sustainability frame- ings of management executives erence area. work) of MYTILINEOS HOLDINGS and the performance of the Group S.A. (Corporate Centre) and it's In putting together the Sustain- and the Group companies. wholly owned three subsidiaries ability Report 2012, our goal was to (ALUMINIUM S.A. with its subsidiary - Conflicts of interests. present its contents in a more con- DELPHI-DISTOMON S.A., and cise way, in order to make it more - The procedures for specifying the PROTERGIA S.A.) with reference to easily accessible to as many of our qualifications of the Board mem- Greece, as well as of METKA S.A., in Stakeholder groups as possible. To bers. which MYTILINEOS HOLDINGS S.A. achieve this, the information con- - The corporate policies and values is the majority shareholder and tained in the Report is comple- relating to the Group's econom- which – in addition to Greece – is al- mented by the new, dedicated sec- ic, environmental and social per- so active abroad, in Algeria, Turkey, tion on Corporate Social Responsi- formance. Syria, Iraq and Jordan. bility which is now available on the - Risk management. Group's website, as well as by rel- There are no significant changes evant references to our Annual Re- from the previous Report in terms of - The procedure for evaluating the port. the scope and boundaries of the performance of the Board with re- Sustainability Report 2012 and of spect to the Group’s economic, This year’s Report opens with the the calculation methods used to ob- environmental and social per- message from the Chairman of the tain the quantitative data present- formance. Group, which focuses on the key ised. However, specific revisions of the sues and the progress made in - The Group’s initiatives relating to Report’s contents compared to pre- 2012, introducing briefly the Re- the precautionary approach or vious Reports are as follows: port’s contents and the Group’s principle. new business goals for the coming (a) The policies and the systematic (c) Finally, the Report does not con- years. The next section describes the actions undertaken by the Group in tain any data on the Group’s new- Sustainability Report parameters, the Corporate Social Responsibility ly-established company “M&M GAS which define the Report’s scope domain were covered in detail in the Co S.A.”, established jointly with and boundary, and is followed by a Sustainability Report 2010, which MOTOR OIL to engage in the sup- brief presentation of the Group’s serves as reference for the on-going ply and trading of natural gas. The business profile. Of particular sig- mechanisms and directions in place investigation and assessment of nificance is the section that presents to guide the efforts of our sub- the possibility to include this com- our approach to the Governance of sidiaries towards sustainable devel- pany in the Sustainability Report Corporate Social Responsibility, the opment. The Sustainability Reports 2013 has been scheduled for this results of our third cycle of consul- published after 2010 only contain year. tation with our Stakeholders, our references to any changes or major performance against the targets revisions to these policies and sys- we had set ourselves in 2012, and tematic actions. This symbol is used to indicate a the new CSR targets we have set for (b) The contents of the section on reference to the MYTILINEOS Group Annual Report 2012. 2013. It is followed by a summary of “Corporate Governance” have been the Group’s key financial figures drastically reduced, because the (which are discussed in detail in the composition and responsibilities of This symbol is used to indicate a reference Annual Report 2012). The next sec- the Group’s Board of Directors and to the MYTILINEOS Group website, at: tions contain data on employment Board Committees are described www.mytilineos.gr.

5 2.2 Report Methodology MYTILINEOS HOLDINGS S.A., which PROTERGIA S.A. (expectations of represents the entire Group. The participants). The data and information presented present Report contains data ob- in the Report have been collected us- T The principles and values of the tained from direct measurements, ing the procedures and scientific cap- Group and its core commitments in while – to help comparisons – the cor- ture methods applied by each Group the framework of Corporate Social responding data for 2010 and 2011 subsidiary, as well as from the data- Responsibility. are also given, where available. Ad- bases kept in the respective corporate ditionally, the Report sections on car- T The introduction and application of systems. The data capture and the cal- bon dioxide emissions and the per- the procedure to determine the culation of the indicators referring to formance in the Health & Safety do- key issues pertaining to the Group’s the performance of MYTILINEOS main provide detailed descriptions Environmental and Social footprint, Group are checked and verified using of the calculations used to obtain the which, in addition to the individual the corporate SAP system, official values for the indicators developed to CSR Teams, also involves the Man- documents (e.g. financial statements), address these subjects. agement of all our subsidiaries. in-house calculation systems available in the respective departments of The procedure to determine the sub- T The results of the working meet- each individual Group company (e.g. ject areas (materiality) contained in the ings of the CSR Teams of the custom Excel worksheets created and Report and relating to the challenges Group companies and the collab- regularly updated for this specific that the Group faces in connection oration with the Heads of Depart- task), and internationally accepted cal- with Sustainable Development, was ments in the context of the data culation methods, such as those pro- based on the following: capture and evaluation tasks. In car- vided under the OHSAS 18001 – T The expectations on the part of rying out the data capture and ELOT 1801 Occupational Health & Stakeholders in connection with evaluation work regarding the in- Safety Management Systems and the CSR issues, after the conclusion of formation required for the Report, ISO 14001 Environmental Manage- the cycle of Dialogue Forums with the CSR Teams of the Group com- ment Standard. With regard to social Stakeholders, organised in 2012 panies used as guidance the prin- data, these cover the initiatives taken for the third year running by ciples of the GRI standard, to en- by each company individually as well ALUMINIUM S.A. and METKA S.A., sure the maximum possible com- as the actions carried out by and for the second year running by pleteness, comparability, accuracy,

6 clarity and reliability of the Report’s surance) by an external assurance ning for this procedure to be fully contents. provider has been postponed, due to adopted across all Group companies T The results of the Corporate Social the need for the CSR Teams of the (e.g. familiarisation with the special- Responsibility Mapping project, Group companies to become accus- purpose data capture forms, system- which involved the assessment of tomed to their duties and for the plan- atic filing of data capture forms and the significance of the issues per- related material, collaboration with taining to responsible entrepre- the individual Sections of Group com- neurship, which are renewed an- panies for obtaining the information required etc.). The external assur- nually by the Group companies and 8 SUSTAINABILITY REPORT 2012 form the basis of the Sustainability ance procedure is scheduled to be ap- MYTILINEOS Group Report for each year. plied starting with the Sustainability declares that its Report 2013. The establishment of the Report’s structure, the guidance on the data Sustainability Report Finally, as with the Group’s previous capture and checking activities, and 2012, which is published Reports, the Sustainability Report the authoring and editing of the Re- in accordance with the 2012 is published in both Greek and port texts were carried out with the Guidelines of the Global English and is also accessible in digi- tal form over the Internet from the scientific support of a specialist Reporting Initiative (GRI) provider, MEDA Communication S.A. Group’s website, so as to help inter- international organisation – Social Management, Development ested users who wish to make com- and Communication Company. regarding the publication parisons with previous Reports or of Sustainability Reports, forward their comments or sugges- The Report was checked by the Glob- tions. al Reporting Initiative (GRI), interna- meets the Application tional organisation for compliance Level B requirements T The terms “Corporate Centre”, with the Application Level B require- under the G3.1 reporting “Parent Company”, “MYTILINEOS Holdings” and the name ments, in accordance with the self-de- guidelines of the GRI level claration made by MYTILINEOS Group. “MYTILINEOS S.A.” refer to the structure. The procedure for third-party check- company under the business name ing and assessment of the Report (as- “MYTILINEOSHOLDINGSS.A.”. T The terms “Company”, “Business” and the names “MYTILINEOS S.A.”, “ALUMINIUMS.A.”,“DELPHI- DISTOMONS.A.”,“METKAS.A.” and “PROTERGIA S.A.” refer to each company that represents the respective business activity sector of the Group and to that company’s activities in Greece. T The terms “Group” and “MYTILINEOS Group” refer to MYTILINEOS HOLDINGS S.A. and to its subsidiaries, all of which together make up MYTILINEOS Group.

Your views, comments or sugges- tions are most welcome. Please address them to: Vivian Bouzali Group Communication Director Tel. +30 210 6877300, Fax:: +30 210 6877400

7 3. MYTILINEOS GROUP PROFILE

3.1 Structure & Activity Sectors MYTILINEOS Group has a strong ith vision, boldness and effi- markets, is ranked among the Top 10 international presence in the cient strategic planning, of the world’s largest EPC contractors EPC Projects and Metallurgy WMYTILINEOS Group is flexibly for energy projects and – through pi- sectors. The Group's activities to- deploying its resources across its three oneering investments in the Energy day are located in 29 countries key business activity sectors – EPC Proj- sector – has been firmly established as that span the markets of Eu- ects, Metallurgy & Mining, and Ener- Greece’s largest private electricity pro- rope, Turkey, the Middle East gy. It establishes the products of the ducer and the very first private natu- and Africa. Greek metallurgical industry as world- ral gas supplier. class products in the international

Geographical map of Activities

8 MYTILINEOS Group - Structure

ACTIVITY GROUP OWNERSHIP COMPANY SECTORS COMPANIES STAKE HEADQUARTERS

METALLURGY & ALUMINIUM S.A. 100.00% Athens, GREECE MINING DELPHI-DISTOMON S.A. 100.00% Athens, GREECE

PROTERGIA S.A. X 100.00% Athens, GREECE

ENERGY M&M GAS Co S.A. 50.00% Athens, GREECE SUSTAINABILITY REPORT 2012 KORINTHOS POWER S.A. 65.00% Athens, GREECE

EPC PROJECTS METKA S.A. 56.19% Athens, GREECE

Activity sectors

METALLURGY par with those of the world’s top met- turn-key projects from design and and MINING allurgical industries. In addition, 2012 procurement through to construction saw the launch of the company’s and commissioning. The Company “MELLON” competitiveness-improve- specialises in the construction of pow- ment programme, designed to safe- er plants (combined-cycle, conven- guard ALUMINIUM S.A. from the chal- tional thermal and hydropower) and lenges stemming from Greece’s deep has achieved significant penetration in Starting with the acquisition of recession and to improve the com- developing markets abroad, with proj- ALUMINIUM OF GREECE S.A. in 2005, petitiveness of the Group’s Metallur- ects currently under way in Europe, which marked a major turning point in gy Sector for the next twenty years. Turkey, the Middle East and North its evolution, the Group gave top pri- Africa. METKA S.A. competes on an ority to the efforts to develop and en- DELPHI-DISTOMON S.A. equal footing with global EPC giants, hance the competitiveness of its met- as it has been established as one of the allurgy branch, and has since evolved DELPHI-DISTOMON S.A. is the second strongest players in the market for EPC into one of the sector’s strongest largest bauxite producer in Greece and projects in Europe and beyond, as well players in SE Europe. ALUMINIUM S.A. in Europe, with an annual production as one of the leading Greek exporting and its subsidiary DELPHI- of 650,000 tons. The company’s mines, companies. The Company has been DISTOMON S.A. are today a key driv- which supply bauxite to ALUMINIUM listed on the Athens Exchange since ing force for the growth of the Greek S.A., are located in the Amfissa region 1973 and its share is today a con- economy and for the development of and employ around 100 people. stituent of the FTSE-ASE/25 Large the Greek periphery. From 1960 to this Cap index. In parallel, its strong in- day, ALUMINIUM S.A. remains a strong EPC PROJECTS dustrial production base allows it to pillar of Greek industry, with an annual manufacture custom mechanical parts production capacity that exceeds and to have a strong presence as a spe- 170,000 tons of aluminium and cialist contractor for Infrastructure 810,000 tons of alumina. The Com- and Defence projects. Finally, the 7th pany is today the largest vertically in- Class Contractor’s Certificate obtained tegrated alumina and aluminium pro- Established in 1962, METKA S.A. is to- by METKA S.A. has expanded the op- ducer in Europe, and its industrial day Greece’s top EPC (Engineering- portunities for its participation in a complex in Ag. Nikolaos (Viotia) applies Procurement-Construction) contrac- broad range of public works in the production and trading practices on a tor, undertaking implementation of Greek market.

9 Αctivity sectors

energy portfolio under the company’s full operation. As a result, the Group’s ENERGY management comprises 1200MW Energy Sector is on a par with its oth- from Gas-fired Combined Cycle Ther- er business activity sectors and repre- mal Power plants (CCGTs and CHP / sents the third pillar on which the High-Efficiency CHP) and 54 MW from Group’s prospects for improved fi- Renewable Energy Sources (RES), main- nancial performance rely. ly wind farms and photovoltaic parks, Over the last ten years, MYTILINEOS in operation. The strategic priorities of «M&M GAS Co. S.A.» Group has been established as the Protergia are the following: dominant independent energy pro- - To build and/or manage a dynamic ducer in Greece by carrying out €1 bil- M&M GAS Co S.A was established by and balanced portfolio of energy assets lion of energy investments in a market the MYTILINEOS and MOTOR OIL mainly from gas-fired thermal plants that opens up significant prospects for Groups in 2010 and is active in the (CCGTs) who successfully meet the the Greek economy and for Greek supply and trading of natural gas (liq- ever-changing environment of the businesses. Today, the Group has in uefied or non-liquefied). The Compa- Greek energy market and to the Eu- place a broad range of operations in ny seeks to meet the needs of its two ropean Union requirements. the energy sector, ranging from the founding Groups in natural gas under construction of power plants to the - To enter dynamically the wholesale competitive terms and to also market supply of natural gas and the injection and retail electricity markets and the natural gas to third parties. Its estab- of the electricity produced into the na- CO2 emissions trading market. lishment has paved the way for the lib- tional grid. - To expand in the future to neigh- eralisation of the domestic market PROTERGIA S.A. is the flagship com- boring countries with high energy for natural gas, as M&M GAS Co S.A. pany of MYTILINEOS Group in the en- demand. was the very first company in Greece ergy sector, bringing under the same Finally, 2012 was the first year during to import a private Liquefied Natural roof the management of all energy as- which all three thermal power plants Gas (LNG) cargo. sets and activities of the Group. The managed by PROTERGIA S.A. were in

10 3.2 Group Governance Structure In MYTILINEOS Group, we apply the shareholders and to the investing defines the boundaries of responsi- principles of Corporate Governance in public. Guided by the principles of bility, assisting and facilitating deci- accordance with the Greek laws in Corporate Governance, MYTILINEOS sion-making and implementation in force, in order to ensure transparen- HOLDINGS S.A. formulates the strat- line with the Group’s strategy. Its pur- cy and operate responsibly across all egy and lays down the general direc- pose is to establish the relationships our business activity sectors. Above all, tions, policies and principles that gov- and roles that guarantee the smooth we seek to safeguard the interests and ern the operation of all Group sub- operation of the Group, with SUSTAINABILITY REPORT 2012 the sustainability of our subsidiaries sidiaries. The organisational struc- MYTILINEOS HOLDINGS S.A. acting as and to maximise the benefits to our ture of MYTILINEOS HOLDINGS S.A. the coordination centre.

GROUP ORGANISATIONAL STRUCTURE

BOARD OF DIRECTORS

AUDIT REMUNERATIONS CSR COMMITTEE COMMITEE COMMITTEE

INTERNAL CHAIRMAN & AUDIT CHIEF EXECUTIVE OFFICER

Mergers & Acquisitions

CORPORATION CENTRE Group Legal & Group Group Group Regulatory Treasury Finance Administration Affairs Group Corporate Affairs

International Business Affairs

ΜΕΤΑLLURGY ENERGY EPC WORKS SECTORS Protergia ΑLUMINIUM OF ACTIVITY M&M GAS ΜΕΤΚΑ Delfi-Distomon Korinthos Power

In our Annual Report: On our Website: - Composition and responsibilities of the Group's Board of Directors - Information on the Group’s corporate - Responsibilities of the Group’s Chairman and Chief Executive Officer (CEO) governance - Composition and scope of work of the Group’s Board Committees

11 3.3 Business Milestones

1990 1995 1996 1998

Establishment MYTILINEOS S.A. Strategic agreements for 1. Acquisition of a majority of MYTILINEOS S.A. is listed on the commercial cooperation stake in METKA S.A., the Athens Exchange. with leading metallurgy largest metal constructions groups in the Balkan region. plant in Greece. 2. Acquisition of the zinc and lead processing metallurgy plant SOMETRA S.A. in Ro- mania.

2006 2007 2008 2009

Acquisition of SPRIDER 1. Strategic partnership with 1. Signature of a strategic 1. The MOTOR OIL and ENERGY S.A. and DELTA Endesa. Establishment of agreement with MOTOR MYTILINEOS Groups an- PROJECT S.A., active in the Endesa Hellas, which aims OIL in the energy sector for nounce the establishment development, construction to play a key part in the the construction and op- of a joint company for the and operation of hy- Greek energy market, eration of a commercial import and trading of dropower plants and wind along with its selective ex- power plant. Natural Gas in all its forms farms. pansion in SE Europe. 2. The High Efficiency Com- (LNG, CNG etc.). 2. Completion of the triple bined Heat and Power 2. First full scope EPC of merger by absorption of plant (CHP/High Efficiency the Group in Turkey, un- ALUMINIUM OF GREECE CHP) enters into commis- der METKA and its 100% S.A. and DELTA PROJECT sioning. The 334 MW plant Turkish subsidiary Power S.A. with the MYTILINEOS is the first thermal plant of Projects, for the consor- Group. the Group to be connect- tium "RWE & TURCAS ed to the Greek National Güney Elektrik Uretim Grid. A.S."

12 1999 2000 2002 2005

Acquisition of a 30% stake Acquisition of a 43% stake Establishment of MYTILINEOS Acquisition of 53% of in Hellenic Copper Mines in State-owned vehicle Power Generation and Sup- ALUMINIUMOFGREECE SUSTAINABILITY REPORT 2012 Ltd., a copper processing manufacturer ELVO S.A. ply S.A. & MYTILINEOS Hel- S.A., one the largest verti- metallurgy in Cyprus. through privatisation, also lenic Wind Power S.A. cally integrated alumina taking over the company’s and aluminium producers in management. Europe.

2010 2011 2012

1. Establishment and operation of M&M GAS Co S.A., 1. METKA S.A. wins 1. The 436 MW Gas-Fired Combined Cycle Ther- the joint company to result from the Group’s strate- the contract for mal Plant (CCGT) owned by KORINTHOS gic alliance with MOTOR OIL. It is the first private- the construction POWER S.A., enters into commercial operation. sector company to enter the market for trading and of a 1250 MW 2. METKA S.A. wins its first two EPC contracts for supply of natural gas in Greece, thus marking the ef- thermal power construction of a 143 MW power plant and a fective liberalisation of the market for natural gas. plant in Iraq. 146 MW wind turbine facility in Jordan. 2. Establishment of Power Projects, a subsidiary of 2. The 444 MW 3. METKA S.A. through its subsidiary in Turkey, METKA S.A. in Turkey. METKA S.A. wins the contract CCGT plant of Power Projects, wins the contract for con- for construction of Syria’s largest power plant, with Ag. Nikolaos (Vio- struction of an energy project in Algeria. a capacity of 724 MW. tia) enters into 4. 2nd EPC major project for METKA S.A., 3. MYTILINEOS Group concludes with Enel an agreement commercial operation. through Power Projects, in Algeria. The proj- for the acquisition of the 50.1% stake held by ENDESA ect concerns the engineering, procurement, in- SA in Endesa Hellas. With this agreement, MYTILINEOS stallation and commissioning of twenty-four Group becomes the sole shareholder of Endesa Hel- (24) gas turbine power generation units with las, which is renamed Protergia S.A., and strengthens a total output of 481,7 MW at site conditions. its position as the largest independent power producer in Greece. 5. METKA S.A. completed the construction of Ro- mania's largest power plant, a 860 MW 4. METKA S.A. and POWER PROJECTS reached an Combined-Cycle Power Plant in Ploesti, Ro- agreement with “BORASCO ELEKTRIK URETIM SANAYI mania. VE TICARET A.S.” for construction works as well as supply of most of the equipment for a 870 MW thermal power plant in Samsun, Turkey.

13 3.4 Strategy & Key Figures

With a disciplined, vision-driven strat- EPC Projects Sector, we achieve an sets of PROTERGIA S.A. and egy that relies on our strong export- unprecedented penetration in for- KORINTHOS POWER S.A., we main- ing profile and strict cost controls, and eign markets, with a signed backlog tain our position as the largest in- aware of our role as a large, respon- standing at nearly €1.7 billion. dependent energy producer in Greece and, through M&M GAS sible corporate citizen, in MYTILINEOS T Through a long-term investment Co S.A., as Greece’s largest private Group we are enhancing our position plan, we fortify the traditionally supplier of natural gas. in order to cope with the adverse en- strong Greek metallurgical industry vironment brought about by the eco- and secure the current and future Additionally, despite the suffocating economic conditions created by the cri- nomic crisis in Greece. operation of ALUMINIUM S.A. as the sis that prevails in Greece, we remain T Our consolidated turnover for 2012 largest vertically integrated alumina steadfast in our strategic commit- stood at €1,454 million. and aluminium producer in the EU. ments to: T Through METKA S.A., active in the T Leveraging the portfolio of energy as- T Promote Greece’s potential for growth across the globe, by deliver- ing products and services that gain international distinction. T Showcase the competitiveness of Greek businesses and the talent KEY FIGURES – 2012 and creativity that Greek entrepreneurship shows in dealing with the Turnover (in million €) 1,453.6 obstacles posed by the current ad- EBITDA (in million €) 170.1 verse economic environment. Net profits (in million €) 21.7 T Provide unwavering support to the Social product (in €) 233,290,213 Greek economy and society, secur- Activity sectors 3 ing more than 2,500 direct and indirect jobs and generating a “social Total number of subsidiaries 3 product” which for 2012 stood at Total number of countries where the Group is present 7 nearly €233 million. Total number of production plants 7 T Ensure that each one of our business Total workforce 1,836 activities is inextricably linked to our social and environmental footprint, Social expenditure (€) 741,607 guided by the principles of Sustain- Environmental expenditure (€) 10,722,197 able Development and Corporate Re- Average annual production of Bauxite (tons) 555,983 sponsibility and with respect for society, the environment, our people Average annual production of Alumina (tons) 757,517 and our shareholders. Average annual production of finished Aluminium (tons) 165,045 EPC signed backlog (in million €) 1,682.1

Portfolio of RES projects in various stages 1,285 of development (MW)*

Total number of shares – MYTILINEOS HOLDINGS S.A. 116,915,862 Share price – MYTILINEOS HOLDINGS S.A. 4.47 (as at 31-12-2012) (€) Total number of shares – METKA S.A. 51,950,600.00 Share price – METKA S.A. (as at 31-12-2012) (€) 9.79

* Installation Licenses: 62 MW; Production Licenses: 1080 MW; Applications for Production Licenses: 143MW.

14 3.5 Impact of Climate Change on business activity 3.6 Collaborations with social partners and Energy is a key raw material for the ac- gy, as a result of new regulatory institutions tivities of MYTILINEOS Group and is al- arrangements primarily in the EU, so expected to become a significant where the Group is active. The po- The application of Responsible Entre- source of income in the near future. In tential impact of the future legislation preneurship in practice relies on the collaboration with social partners and addition, our activities extend to the and of the regulatory framework on institutions, in order to jointly work out broader energy sector, through the climate change, as well as of the Eu- and promote solutions to important is- construction of turn-key energy proj- ropean and international conventions sues of concern at national level. To SUSTAINABILITY REPORT 2012 ects (EPC). According to a view that is and agreements, cannot be estimat- this end, MYTILINEOS Group is devel- rapidly gaining ground, the con- ed with any certainty, given the wide- oping initiatives and is participating as sumption of the energy produced by ranging purposes of these potential an active member in voluntary Greek mineral fuels is one of the key factors changes. In the future, our Group may and international organisations, seek- that contribute to global warming. An be forced to make substantial investing to promote CSR and the principles increasing number of Governments or ments, due to the requirement for of Sustainable Development, to ex- State bodies and committees have al- compliance with the amended legis- change views on CSR-related issues, to ready introduced or intend to intro- lation and the new arrangements. Fi- improve its social and environmental duce legislative and regulatory changes nally, as its management of CO2 emis- contribution and to develop respon- in response to the potential risks as- sion rights may post negative (deficit) sible practices in the broader business sociated with global warming. or positive (surplus) results, and as a community. The Group’s operating margins might consequence of its high energy con- The Group participates in, endorses or sumption (due primarily to the be affected by changes which may be supports voluntary initiatives, such as: made to production facilities of the Aluminium production process), the The UN Global Compact, which the Group with high greenhouse gas Group in the future may have to T Group has joined and co-signed emission levels and to Group facilities recognise significant expenditures or since 2008. with increased requirements in ener- revenues, respectively. T The Global Reporting Initiative (GRI) international organisation, whose reporting guidelines on the compila- tion of its Sustainability Reports it has adopted and applies since 2008. T The annual Environmental, Social and Governance (ESG) Survey of the Bloomberg international financial data service, in which the Group participated for the first time in 2012. T The Hellenic Network for Corporate Social Responsibility, in whose working groups and initiatives, aimed at promoting Corporate Social Re- sponsibility, it participates since 2006. T The Hellenic Federation of Enter- prises (SEV), in whose “Council for Sustainable Development” the Group has participated and whose Code of Principles it adopts. T The international standards on Qual- ity (ISO 9001), Environmental Man- agement (ISO 14001) and Occupa- tional Health & Safety (OHSAS

15 18001), which have been adopted the participation of PROTERGIA S.A. T The Hellenic-Arab Chamber of Com- by all Group Companies. in the Hellenic Association of Inde- merce and Development. In addition, we are actively contribut- pendent Power Producers (HAIPP). T The Hellenic-German Chamber of ing to significant developments relat- - We support the promotion of RES in- Commerce and Industry. ing to public policy in the energy sec- vestments in Greece, through the par- T The Hellenic-Chinese Chamber of tor and directly affecting our business ticipation of PROTERGIA S.A. in the Commerce and Industry. activities, such as: Greek Association of RES Electricity T The Hellenic-French Chamber of Producers (GAREP) and in the Hellenic - The promotion of RES investments Commerce and Industry. in Greece, which is a contractual ob- Wind Energy Association (HWEA). T The Hellenic-African Chamber of ligation of the country in line with - Through the participation of Commerce and Development. the EU target of a RES penetration PROTERGIA S.A. in the Institute of En- T The Aluminium Association of of 20% in final electricity consump- ergy for Southeast Europe (IENE), we Greece. tion by 2020. also contribute to the development of T The Hellenic Foundation for Euro- - The liberalisation of the domestic positions and recommendations and pean and Foreign Policy (ELIAMEP). electricity market, which is expect- to lobbying on energy-related issues ed to result in significant benefits for in the wider region of SE Europe. T The Pan-Hellenic Exporters’ Associ- the national economy, the environ- Finally, in addition to the abovemen- ation (PEA). ment and consumers. tioned bodies, MYTILINEOS Group is T The Viotia Chamber. Through our subsidiary PROTERGIA a member of, and works closely with, T The Association of Sociétés S.A. we participate actively in public the following industry associations Anonymes and Limited Liability consultations on specific Bills and on and other organisations: Companies. draft decisions and regulations which T The Greek Mining Enterprises As- T The ALBA Graduate Business School. concern the energy sector. sociation (SME). T The Association of Industries in In the context of our participation in T The Hellenic Management Associa- Thessaly and Central Greece (AITC). the above initiatives: tion (HMA). T The Hellenic Institute of Entrepre- - We promote the liberalisation of the T The Athens Chamber of Commerce neurship & Sustainable Develop- domestic electricity market, through and Industry (ACCI). ment (IEA).

3.7 Awards and distinctions During 2012, MYTILINEOS Group received the following awards and distinctions:

Awards T The Group’s Chairman & CEO was awarded with the 2nd Prize in the category “Visionary CEO in CSR” of the CEO & CSR Money Conference Awards 2012 organised by the “Money Conference” institution. T MYTILINEOS HOLDINGS S.A. was presented with the 3rd Prize in “Best FTSE-ASE/20 Company – 2012” category of the “MONEY – G. OUZOUNIS Business Awards 2012” institution T METKA S.A. was presented with the 3rd Prize in the “Best Company – 2012” category of the “MONEY – G. OUZOU- NIS Business Awards 2012” institution Distinctions T MYTILINEOS Group was presented with a special award by the “Together for Children” Association in recognition of its generous support of the Association's cause and activities. T METKA S.A. was presented with a special award by the Hellenic Equestrian Federation, in recognition of its long- standing support of the Equestrian sport.

16 4. APPROACH TO CORPORATE Our Vision SOCIALRESPONSIBILITY Our principle to ensure that the business excellence and growth of our Group are guided by the moral principles and the values that keep unbroken our alliance SUSTAINABILITY REPORT 2012 with society, with our people ur approach to Corporate So- ment of our CSR function (shown in and with the environment. cial Responsibility is a multi- the graph below). We developed a uni- Our duty Ofaceted and complex process form system for the governance of to create value for our clients, CSR and for its integration into our or- characterised by our conscious self- business partners and ganisational structure, taking into ac- commitment to continuous improve- shareholders. ment. It is directly linked to our busi- count the particular characteristics of Our goal ness operations and defines the way our business activity sectors. We in- to maintain our position in which we choose each time to move troduced a process of open dialogue as the dominant independent forward, taking steady steps towards with our Stakeholders, which we improve every year; we adopted inter- Energy producer in Greece achieving Continuous Responsible De- national standards and committed and a strong, competitive velopment, guided by our vision and ourselves to international initiatives European Heavy Industry Group values. that promote responsible entrepre- in the sectors of Energy, Starting with the definition of our fun- neurship; and we continue with our ef- Metallurgy and Construction. damental commitments regarding forts to set realistic targets and to en- Corporate Social Responsibility, we es- sure the proper disclosure of our per- tablished a more systematic manage- formance.

1. Assessment 2. Development Our values of the current of CSR Strategic situation Directions Human Business Society Capital Excellence & Environment

“Our Business “We are pursuing “We elevate our success is based on the continuous corporate social 6. Evaluation & CSR 3. Development our people” improvement of our responsibility to a Improvement of Management of CSR Policies in performance in daily practice” CSR Practices Team Process the individual order to achive & Actions Spirit Socially sectors optimal business Integrity responsible results” development Communication Financial Gaining the trust Professional soundness / High of the society attitude profitability 5. Μeasurements, 4. Implementation around us Reports & Health of CSR Policies High efficiency / Respect towards Communication & Safety (actions) Excellent result the environment at the Competitive Workplace Safety & advantage Environmental Continuous Conscience progress / Innovation High Safety & On our Website: Quality standards - Our CSR strategic directions - More details on our approach to CSR

17 4.1 ESG (Environmental, Social and Governance) Milestones

2000 2001 2002 2003

1.Pechiney award to 1. ELVO S.A. obtains ELOT EN ALUMINIUM OF GREECE ALUMINIUMOFGREECE ALUMINIUM OF GREECE ISO 9001:2000 certifica- S.A. wins European S.A. wins European S.A. for best safety results tion of its Quality Man- Aluminium Association Aluminium Association among all alumina and agement System. award for best Health & award for best Health & aluminium plants of the 2. ALUMINIUM OF GREECE Safety results among all Safety results among all alu- Pechiney Group. S.A. wins European aluminium processing mina processing plants in 2.METKA S.A. obtains ISO Aluminium Association plants in Europe. Europe. 9001:2008 certification of award for best Health & its Quality Management Safety results among all System (the first such certi- aluminium processing fication for METKA dates plants in Europe. back to 1997).

2007 2008 2009

MEKA S.A. obtains ISO 1. ALUMINIUM OF GREECE S.A. launches op- 1. Implementation of Corporate So- 14001:2004 certification of eration of its 2nd Filter Press for Bauxite cial Responsibility Mapping proj- its Environmental Manage- Residues Utilisation. ect in ALUMINIUM S.A., METKA ment System. 2. MYTILINEOS Group joins the United Na- S.A. and DELPHI-DISTOMON S.A. tions Global Compact on human rights, 2. DELPHI-DISTOMON obtains labour, environment and anti-corruption. OHSAS 18001: 2007 certifica- 3. Adoption of the G3 Level C reporting tion of its Occupational Health & guidelines of the Global Reporting Initia- Safety Management System. tive (GRI) for the publication of the Group’s Sustainability Report. 4. DELPHI-DISTOMON obtains ΕΝ ISO 14001:2004 certification of its Environ- mental Management System.

18 2004 2005 2006

1. ALUMINIUM OF GREECE S.A. is 1. ALUMINIUM OF GREECE 1. ALUMINIUM OF GREECE S.A. obtains ELOT ranked No 1 in the world (among all S.A. obtains ELOT ΕΝ ISO 9001:2000 certification of its Quality aluminium plants with 1-3 million 14001:2004 certification of Management System. SUSTAINABILITY REPORT 2012 working hours), on the basis of the its Environmental Manage- 2. MYTILINEOS Group joins the Hellenic results published annually by the In- ment System. Network for Corporate Social Responsibility. ternational Aluminium Institute (IAI). 2. METKA S.A. obtains OHSAS 3. ALUMINIUM OF GREECE S.A. launches op- 2. ALUMINIUM OF GEECE S.A. ob- 18001 Certification of its eration of its 1st Filter Press for Bauxite tains OHSAS 18001 – ELOT 1801 cer- Occupational Health & Safe- Residues Utilisation. tification if it’s Occupational Health & ty Management System. Safety Management System.

2010 2011 2012

1. Establishment of the Corporate 1. The Group's Sustainabili- 1. The Group’s Sustainability Report is upgraded to the Social Responsibility Committee ty Report is upgraded to ISO 26000 Social Responsibility Guidance Standard and at the level of the Group’s Board GRI-G3.1 Application Lev- the OECD Guidelines on Corporate Social Responsi- of Directors. el B and is officially certi- bility. 2. Establishment of Corporate So- fied by the GRI interna- 2. ALUMINIUM S.A. and METKA S.A. hold 3rd Dialogue cial Responsibility structures in all tional organisation for Forum with Stakeholders. PROTERGIA S.A. holds s 2nd Group companies. compliance with the re- Dialogue Forum with Stakeholders. spective requirements. 3. 1st Dialogue Forum with Stake- 3. 1st participation of MYTILINEOS Group in the annu- holders at the Group level and at 2. ALUMINIUM S.A. and al ESG (Environmental, Social and Governance) the level of individual companies METKA S.A. hold 2nd Di- Bloomberg Survey, where it is ranked No 1 among all (ALUMINIUM S.A. and METKA alogue Forum with Stake- participating Greek companies in terms of its overall S.A.). holders. PROTERGIA S.A. performance. holds 1st Dialogue Fo- 4. Establishment of the Climate rum with Stakeholders. 4. ALUMINIUM S.A. permanently discontinues the dis- Change Management Section posal of bauxite residues in the sea. under the Department for Group 5. PROTERGIA S.A. obtains ΕΝ ISO 14001:2004 certifi- Legal & Regulatory Affairs. cation of its Environmental Management System. 5. The Group's Sustainability Report 6. PROTERGIA S.A. obtains OHSAS 18001: 2007 Certi- is officially certified by the GRI in- fication of its Occupational Health & Safety Man- ternational organisation for compliance with the Application Lev- agement System. el B requirements of the GRI-G3 7. PROTERGIA S.A. obtains EN ISO 9001: 2008 certifi- level structure. cation of its Quality Management System.

19 4.2 Corporate Social Responsibility – Fundamental Commitments The sustainability of our Group is directly linked to our so- In this context, we seek to achieve the best possible un- cial and environmental footprint and is founded on the prin- derstanding of the implications of our business activities, ciples of Sustainable Development. Our sincere commitment which reinforces our efforts to adhere to our individual com- to CSR does not only affect our daily decisions and actions, mitments, which are presented below, and thus improve but also impacts on our relations with our Stakeholders. our overall maturity and competitiveness.

Human Resources Human Rights

Our commitment: Our commitment: To maintain labour peace by developing performance To strive in a continuous and concerted manner to es- reward & management systems, ensuring internal tablish procedures and methods that will define our ac- communication and evaluating individual peformance. tions, so that our commitments remain aligned with the To invest continuously in the improvement of labour re- principles of the United Nations Global Compact relations, showing confidence in our employees’ skills and garding labour rights. encouraging the development of their capabilities that help achieve individual, team and corporate results. Environment

Our commitment: Occupational Health & Safety To identify the sources and assume the responsibility for the unavoidable impacts of our operations on the nat- Our commitment: ural environment and to carry out concerted “green” To ensure that the target “Zero Accidents & Zero Oc- actions or programmes to mitigate these impacts, cou- cupational Diseases” is achieved in the workplaces of pled with systematic monitoring and application of the all our companies, by adopting modern methods, pro- Group’s Environmental Measures and Principles across moting constant alertness and providing appropriate all Group companies. education and training to employees of all levels in the procuction process across all Group companies. Corporate Governance

Our commitment: Anti-Corruption To focus on safeguarding the interests of our share- Our commitment: holders and on creating value for all our Stakeholders. To adhere to market rules, to participate in international To continously strengthen corporate culture by up- anti-corruption standards and to strengthen trans- holding integrity, ethical standards and transparency, parency through the dialogue with our Stakeholders and and by adopting internal practices over and above the their active participation in full alignment with our Val- statutory ones to ensure our full compliance with the ues and Principles. To abide by integrity practices and regulatory framework on corporate governance to the the corporate governance rules, in order to minimise highest possible standard. our exposure to corruption. Fair Market practices

Local communities Our commitment: To strengthen our efforts for strategic investments at the Our commitment: level of products and technologies, also taking into ac- To record local needs and help address them, so that count social and environmental needs and parameters. viable conditions for the development of the local com- To promote the gradual incorporation of CSR across our munities concerned are created, especially in regions supply chain and to maintain the ethical characteristics where the Group’s activities are of a higher visibility. of our communication policy.

20 4.3 Governance of Corporate Social Responsibility For MYTILINEOS Group, the design and (c) To balance the economic, social and Management and to the relevant Board application of the Corporate Social Re- environmental implications of the Committees on the above issues, to as- sponsibility structures – or CSR Gover- Group's business activities, while gen- sist in their implementation in a more nance system – is indicative of our ap- erating value for its shareholders and complete manner. proach to the concept of CSR. for all its other Stakeholder groups. During 2012, the CSR Committee held Our Group’s CSR Governance system In parallel, the Group’s Professional two meetings: consists of: (a) the CSR Committee, Ethics Code plays an important part in T On 24.04.2012, with the following SUSTAINABILITY REPORT 2012 which functions at the level of the ensuring the commitment of the entire items on the Agenda: (a) The Group’s Board of Directors and is re- Group to the requirements of Re- Aluminium History Museum in Aspra sponsible for monitoring and ensuring sponsible Entrepreneurship. The Code Spitia (Viotia); (b) the events organ- the correct application of Responsible covers the rules of acceptable conduct ised at the Athens Concert Hall; (c) Entrepreneurship; (b) the CSR Teams of regarding the Management’s conduct the update on the Group’s partici- our subsidiaries, which carry out specific towards its employees and the rules pation in the BLOOMBERG, GRI and tasks and have clearly defined obliga- that govern the conduct of our em- Carbon Disclosure Project organisations; and (c) the Group Communica- ployees between themselves and to- tions; (d) Volunteerism; and (e) the tion Department, involved in CSR ac- wards third parties, especially towards proposal regarding the appointment tivities in a crucial coordinating role. The our Stakeholder groups. of new members to the Committee. integration of the CSR Governance Sys- The Group’s Corporate Social Respon- T On 6.11.2012, with the following tem in the Group's organisational sibility Committee is composed of two items on the Agenda: (a) The structure relies on a uniform set of pro- Board members without executive au- Aluminium History Museum in Aspra cedures and on a specific reporting hi- thority within the company, with the Spitia (Viotia); (b) the events organ- erarchy, in order to overcome any ob- other Committee members being ex- ised at the Athens Concert Hall; (c) stacles which might result from the par- ecutives of MYTILINEOS HOLDINGS the Group’s financial assistance to the ticular characteristics of our individual S.A. Penteli Branch of the Patriotic Insti- business activity sectors. tute for Social Welfare and Aware- The CSR Committee is responsible to The aims of the Group’s CSR Gover- ness (PIKPA); (d) the update on the the Board of Directors for monitoring nance system are: Group’s participation in the and ensuring the correct application of BLOOMBERG and GRI organisations (a) To highlight the scope and depth of Corporate Social Responsibility in the and the setting of the Group’s next the relevant concepts, with the ultimate Group in terms of policies, goals/tar- objectives; (e) other matters regard- goal to prevent business, social and en- gets, actions and results, in connection ing the Group’s progress towards Re- vironmental risks. with environmental, social and ethical sponsible Entrepreneurship. (b) To identify and implement policies issues in the internal, as well as the ex- and initiatives that will substantially con- ternal environment of the Group com- On our Website: tribute to the achievement of Sustain- panies. The CSR Committee may also - The Group’s Professional Ethics Code - The Group’s CSR Governance structure able Development; and act as advisor to the Group’s Executive

CSR COMMITTEE Composition

CSR COMMITTEE Executive / Non- Independent Name Composition Executive Members Members

Chairman Christos Zerefos Non-Executive Independent

Member Christos Diamantopoulos Non-Executive Independent

Member Sofia Daskalaki-Mytilineou Non-Executive

Member Spyros Kasdas

Member Vivian Bouzali

Member Fotios Spyrakos

Member Lydia Tsapara

21 4.4 Stakeholder engagement

Our continuous efforts to apply Re- public bodies and voluntary organisa- adopting these procedures, we aim to sponsible Entrepreneurship in practice, tions. establish specific internal processes rely on our collaboration with our In 2010, in an effort to strengthen that will allow us to assess the pro- Stakeholder groups, in order to joint- even more the collaboration and en- posals and recommendations put for- ly work out and promote solutions to gagement of all our Stakeholders, ward by our Stakeholders and to in- issues of mutual concern. we organised for the first time dedi- corporate them in the formulation of In this context, transparency in com- cated consultation events (Dialogue our annual CSR strategic directions. munication and open dialogue are key Forums) to all our subsidiaries. This ini- These processes will also allow us to to fostering mutual trust and collab- tiative, which today has been estab- consolidate the application by our oration with all our Stakeholder groups lished as an institution within the subsidiaries of the precautionary prin- – employees, local communities, Group, is continuing with consisten- ciple regarding economic, environ- clients, suppliers, shareholders, the cy and is subject to self-evaluation and mental and social issues, thus ensur- Press & Media, business partners, self-improvement procedures. In ing their sustainable development.

Approaches to the engagement of the Group’s key Stakeholder groups

Stakeholder Groups Approaches to Stakeholder engagement & collaboration

- Regular and ad hoc meetings between the Management and representatives of employee unions. - Representation of employees in the BoD and in the General Meetings of the Shareholders. Employees - Participation of employees in the first- and second-degree evaluation boards. - Annual consultation (Dialogue Forum) on CSR-related issues. - Annual employee performance review.

Local communities - Annual consultation (Dialogue Forum) on CSR-related issues.

Associated Companies & Suppliers - Annual consultation (Dialogue Forum) on CSR-related issues.

Corporate Social Responsibility - Annual consultation (Dialogue Forum) on CSR-related issues. Organisations - Participation at events.

- Annual consultation (Dialogue Forum) on CSR-related issues. Local Authorities - Individual meetings. - Participation at events.

- Regular and Extraordinary Shareholders’ Meetings. Shareholders – Investors - Presentations of financial results. - Annual consultation (Dialogue Forum) on CSR-related issues.

- Annual consultation (Dialogue Forum) on CSR-related issues. Press & Media - Individual meetings. - Participation at events.

- Annual consultation (Dialogue Forum) on CSR-related issues. Church - Individual meetings.

- Requests to the company for support. Voluntary Organisations - Annual consultation (Dialogue Forum) on CSR-related issues.

22 Overview & key issues raised in the Consultations of the Group Companies with their key Stakeholder groups.

(The Dialogue Forum was organised on 11 December 2012 at the company's plant in Aspra Spitia, Viotia). The Dialogue Forum 2012 was the company’s best effort to-date in its interaction with its Stake- holders. The event was marked by interesting views and constant dialogue with the participants on almost all the issues raised. Emphasis was placed on the “MELLON” programme, designed to SUSTAINABILITY REPORT 2012 boost the company’s sustainability, thus communicating this difficult situation to its Stakehold- er groups.

(The Dialogue Forum was organised on 12 December 2012 at the company’s plant in Volos). The response to the Forum was very positive, serving as recognition of the efforts that the company and the Group made in order to hold this year's Forum locally. The views presented were very effective in terms of the issues raised, while and the comments made by the participants focused primarily on issues relating to the company’s business growth.

(The Dialogue Forum was held on 26 November 2012 at the company's headquarters in Athens). The Company’s presentation of its key CSR activities and of the CSR policies and actions it has adopted led to a particularly constructive dialogue with its Stakeholders. The Forum covered issues such as labour practices, the environment, management systems, health & safety, compliance with the laws and relations with local communities, thus providing participants with a complete picture of the company's activities.

All the representatives of the individual companies and of the Group responded to the comments made by the participants, offering relevant information where this was possible at that particular time. The presentations given and the views expressed, together with the response of the Group companies to the issues raised, which are listed below, will be published in the Group’s Sustainability Report 2013.

Key issues raised & expectations by Stakeholder group

1. LOCAL AUTHORITIES

T Concerns were expressed by the Municipality of Kyria- reduction of the amount allocated by the company in ki about the impact of Bauxite residues on the envi- 2012 for its social policy compared to previous years was ronment. The Company was asked to supply quantified discussed. information to certify the extent of this impact and to T Emphasis was given to the need for industrial compa- disclose information on the respective protection meas- nies of the size of MYTILINEOS Group to remain in ures. Greece. This particular Stakeholder group expressed its T The matter of adhering to the ratio for recruitment of concerns in connection with the risks to social cohesion employees from the local communities was raised – a from the exploding unemployment and the company request was made for the recruitment of more em- was asked to provide help for dealing with the problem, ployees from the Municipality of Kyriaki. by increasing its social product. The Regional Adminis- T The wish was expressed for a shift in the company’s so- tration stressed that it supports all company's activities cial policy to the immediate problems of the local com- to provide assistance and relief to vulnerable social munities, with participation from all Municipalities. The groups.

23 1. LOCAL AUTHORITIES

T Satisfaction was expressed about the fact that this year’s T Very positive comments were made about the Group’s Dialogue Forum was held in Volos, as the relevant re- CSR policy, focusing on the concept of Transparency. quest had been made during the Dialogue Forum 2011. Representatives of the Orchomenos and Karystos Mu- The subject of robust investments and collaborations as nicipalities confirmed the very good collaboration be- an answer to the financial crises was presented, and pri- tween the company and the respective Municipalities. ority was given to the allocation of the social product Additionally, regarding the request for more invest- of businesses. ments in the Municipality of Orchomenos, it was men- T References were made to the lack of a well-organised tioned that the Municipality is open to proposals for investment plan in Greece. The wish was expressed for collaboration and owns lands on which photovoltaic the company to remain in Volos area and to increase its systems can be installed. production output and employability in the local com- T The Mayor of Karystos stated his satisfaction with the munity. It was also mentioned that sustainable businesses way in which «PROTERGIA S.A.» responds to the needs also result in sustainable local communities. of the local community and spoke of the good col- T In connection with its collaboration with the Associa- laboration between the Municipality and the com- tion of Industries in Thessaly and in Central Greece, the pany’s executives. Regional Administration put a request to the company to assist financially the establishment by the Association of a centre for support and encouragement of young entrepreneurs. T Thanks were expressed to the company for its contribution in helping meet the social needs of the local community, as well as for its unreserved and discreet support to the Municipality, whenever this was requested. Mention was made of the synchronised swimming championships, the donation of school books, the support of local events and the provisioning of local grocer’s stores. Finally, satisfaction was expressed about the growth of the company’s investment in the local community, which during 2012 was increased, in response to the request made during the Dialogue Forum 2011.

2. EMPLOYEES

T No particular positions were presented, as negotiations T The employees expressed their overall appreciation of between employees and the company’s Manage- the company and their trust in it, together with their ment regarding their employment contracts are under hopes that this very good climate of collaboration will way. The employees expect that jobs will be maintained continue. Additionally, the company and the Group in during the particularly difficult period of the financial general were asked to remain closely in touch with the crisis. During the time since last year’s Dialogue Forum, employees and their problems, as they have done so namely in December 2012, the company’s Management far. The raise in employees’ earnings, which the com- and the Union of Company Employees signed a new pany decided despite the financial crisis, was mentioned agreement, under which the plant’s jobs and produc- with very positive comments. tion capacity are maintained, with substantial cost ra- tionalisations introduced on a sustainable and long-term basis.

24 3. BUSINESS PARTNERS 5. VOLUNTARY ORGANISATIONS AND PROFESSIONAL ASSOCIATIONS

T A proposal was made for participation of the com- T Special thanks were extended to the company for its pany’s shareholders in the Dialogue Forum 2013. The support of the local branch of the Hellenic Cancer wish for the company to continue investing in the Society. region was expressed.

T It was pointed out that the KORINTHOS POWER in- T Thanks were extended to the company for its support SUSTAINABILITY REPORT 2012 vestment could have been made in the Volos region, of the Hellenic Society for Disabled Children (ELEPAP) as initially planned. The facts which led to the change during the last ten years. Emphasis was placed on the in this decision were mentioned, emphasising the lo- “financial adoption" by METKA – the only one of all cal community’s lack of readiness to accept this par- the local industries to do so, as it was stressed – of ticular investment. one child without health insurance from the 12 chil- T Great significance was given to the fact that the com- dren which ELEPAP takes under its care every year. pany is located within the city and yet there are no T ELEPAP presented its plans for a new day-care, edu- complaints regarding environmental impacts or oth- cational and creative activity programme for pre-school er issues, such as noise. The wish was expressed for children, and invited the company to provide finan- the company’s development and for the continua- cial assistance for this programme during 2013, as it tion of the good collaboration between the em- has been delayed due to financial difficulties. ployees, the shareholders and the Management that promotes social stability. T The Company was asked to broaden its contacts with local labour unions. 6. CHURCH

4. PRESS & MEDIA T Thanks were extended to the company for its support of the local Diocese’s foundations, which carry out invaluable social work. The need for a more social pro- T Concerns were expressed about whether the company has in place a mechanism linking work with profile during these times was expressed, taking of course ductivity. An issue raised with some insistence was into consideration the difficulties that the company the absence of employees from Lidoriki. is facing. A proposal was made for devising a mechanism which T The concerns regarding the pollution to the envi- T ronment from the company’s activity were stressed, will help assistance to be directed to the social groups together with the need to rehabilitate any adverse or to the individuals who really need it. The regular effects to the environment. More specifically, the ap- recruitment of young people was also proposed, so pearance of tar in the Corinthian Gulf waters was that they may gain professional experience which will mentioned, and the company was asked to provide be useful to them in the future. clarifications. T Ideas were put forward for supporting educational coaching establishments in the region by provisioning T The Company’s support for the reforestation project in the broader region was requested. them with heating oil, and for the organisation of events to promote optimism and strengthen social cohesion.

7. ASSOCIATED COMPANIES

T It was stated that the company’s initiative to engage T Concerns were expressed about the continuing in- in dialogue with its Stakeholders creates a very posi- stallation of photovoltaic systems, especially on flat fer- tive image. tile land, when mountainous and arid land could be T It was asked whether the Group-via the company- in- used for the same purpose. The question was then tends to develop facilities for the use of biomass. raised about the existence of a specific land planning map regarding photovoltaic installations.

25 Response by the Group’s subsidiaries to the key issues raised in the Consultations held in 2011

This section provides a brief overview of the approach of our subsidiaries or of the initiatives that they have taken in response to the requests made by their Stakeholders during the consultations (Dialogue Forum events) held in 2011. Relevant details are for ALUMINIUM S.A. and METKA S.A., as in the case of PROTERGIA S.A. no requests were made requiring the company to respond with specific actions.

DIALOGUE FORUM 2011

Key Stakeholder expectations M Company Response M Stakeholder Groups: Local Communities

- The wish was expressed for the company to show greater trust to suppliers from the local com- T During 2012, the company continued to support its local sup- munities. pliers. - The Viotia Chamber of Commerce proposed a new meeting to be arranged with the company T The Company's financial assistance to social bodies and soci- for the presentation of its proposals under a systematic joint effort to address CSR-related issues. eties was maintained at 2011 levels. The exceptionally adverse - The representative of the Regional Administration expressed a demand for the company to in- economic conditions during 2012 did not allow the compa- crease its social product. ny to increase its social product. However, its financial support - The collaboration of the Region with the company was proposed, using as leverage the data which of vulnerable social groups through various foundations re- the former can supply and the latter can use in its initiatives to support and provide relief to vul- mained substantial. nerable social groups. Stakeholder Groups: Employees

- Expect the company to maintain jobs in the current difficult period of financial crisis. T During 2012, a three-year bilateral company-level agreement - The issue of the threats made by contractors about salary reductions was raised; it was point- was signed by the Management and the employees. ed out that the company can play a part in this, as contractors are its direct partners. T The jobs were maintained. - Particular emphasis was placed on the need for a more active contribution by the company T Facilities are improved through the necessary investments as well in helping address issues faced by employees (more help and increased sensitivity). as through adequate maintenance. A significant investment - The need was pointed out for more investments in the company’s facilities, because of their made involved the substitution of fuel oil with natural gas as age. combustion fuel. This investment has been fully completed in the Alumina processing plant, and its completion in the Aluminium plant is expected during 2013.

Stakeholder Groups: Press & Media

- The employees’ concern for the future of their jobs and for the well-being of their families was T The support of cultural activities was continued. ALUMINIUM stressed. S.A. was the exclusive sponsor of the publication of the two - It was stressed how important it is for the company to be willing to follow closely developments biannual issues of the literary magazine "Emvolimon" and of in the local communities where its operations are located. Particular emphasis was given to cul- the events held at the magazine's lounge. ture, with the expectation than the company will continue to support it. T The Company continued to support the local cultural societies and their events, by making available premises (halls), equipment and other materials, providing accommodation etc. Stakeholder Groups: Local Authorities

- Proposal for active participation of the Municipality in the company’s dialogue with its Stakeholders, T During the Dialogue Forum 2012, time was allocated for the with time requested for a more detailed presentation of local problems. presentation of local problems by the Municipalities, in response - Proposal for innovative actions to protect the environment, always combined with actions aimed to their request. at sensitising citizens, and invitation to participate in a dialogue on the environmental propos- T The Company remains open to dialogue and collaborations, als of the Municipality of Livadia. and will examine all proposals which could help further improve - It was observed that, despite the company’s significant activities in the CSR domain, no budget issues relating to the protection of the environment. was presented on its social contribution. T Data (both quantitative and qualitative) on the company’s so- - Complaints were relayed from agricultural cooperatives for dust deposits on cultivations. cial contribution are presented annually as part of the Group’s Sustainability Report.

On our Website : - Our approach to the dialogue with our basic Stakeholder Groups - The procedure for the definition of our key Stakeholder group - The issues raised during the consultation process with our key Stakeholder Groups

26 DIALOGUE FORUM 2011

Key Stakeholder expectations M Company Response M Stakeholder Groups: Associated Companies – Suppliers - The Company can play an important part in the ab- T During a very difficult year with high unemployment and underemployment rates, METKA S.A. managed to sorption of unemployment. maintain jobs, as the largest share of employee departures represents inter-Group transfers. - The need was expressed, for the second year in a T Committed to its strategic goal to strive to protect the natural environment and to promote consistency and row, for the systematic measurement of total car- transparency in CSR issues, in late 2012 the company launched the development of its Quality Management

bon dioxide emissions from the company’s activi- System regarding measurement and reporting of its greenhouse gas emissions (greenhouse gas inventory). SUSTAINABILITY REPORT 2012 ties, and details were requested on the subject. The procedures regarding the greenhouse gas inventory and the company-level measures regarding energy management and savings will be completed at the end of 2013 and the relevant results will be announced in early 2014. Stakeholder Groups: Non-Governmental Organisations (NGOs) - The Company was requested to continue to sup- T METKA continued to actively support NGOs, societies, associations and public benefit foundations, with em- port and provide financial assistance for their phasis on the support of children with disabilities and chronic diseases, through regular sponsorships to spe- work. cial groups such as the Volos Branch of the Hellenic Society for Disabled Children (ELEPAP), the Magnisia Branch of “FLOGA” (“FLAME” – The Association of Parents of Children with Neoplastic Diseases), and the Hellenic Therapeutic Riding Association. Stakeholder Groups: Business partners - It was proposed to the company to consider the Vo- T During 2012, SERVISTEEL S.A., a subsidiary of METKA S.A. located in Volos, invested in the production of los area as an area for its future investments. electricity through the installation of a 2.50 MWp photovoltaic station in the open grounds of its facilities. - The idea was proposed to adopt the institution of In parallel, as part of its efforts to modernise the installations of its Volos plant, METKA S.A. installed pho- scholarships to engineers with specialisations of in- tovoltaic panels at the roofs of the plant's buildings. These activities form part of the company’s overall plan terest to the company, and the possibility for fur- involving constant investments in its local facilities in the Volos area and the support of the local commu- ther collaboration with Tertiary Education Institu- nity. tions was pointed out. T In line with its commitment to closely collaborate with Tertiary Education Institutions, the company provided practical training opportunities to students of various disciplines, so that they can obtain work-related knowledge and experiences in its offices and construction sites. Although so far the company has no established schol- arship programme, during 2012 it covered the cost of studies in a foreign University for one student. Stakeholder Groups: Corporate Social Responsibility Organisations - Proposal for financial assistance to research insti- T Seeking to assist research institutions and support the dissemination of technological knowledge, during 2012 tutions to support the dissemination of techno- METKA S.A. participated actively in the research project of the National Technical University of Athens with logical knowledge. the title “Development of a System for Monitoring and Optimising the Operation and Maintenance of a Com- - Proposal for adopting the institution of scholarships bined-Cycle Power Plant”. The project is coordinated by the Laboratory of Thermal Turbo Machines of the of to engineers with specialisations of interest to the faculty of Mechanical Engineering, in collaboration with the Electric Energy Systems Laboratory of the facul- company. ty of Electrical and Computer Engineering. - Proposal for further collaboration with Tertiary Ed- T The issue of transparency and the method for the company’s certification with regard to the documentation ucation Institutions. of transparency will be investigated at Group level under a 3-year plan. - References were made to the Health & Safety of em- T A Health & Safety Committee functions at the Volos plant, composed of Company employees and Manage- ployees, and the company was asked to clarify ment executives, thus strengthening the dialogue between the employees and the Management on the rel- whether or not the Management is participating ac- evant issues. Regular and ad hoc meetings are held to evaluate work conditions, and measures to improve tively in the dialogue with employees on the rele- them are also proposed. The Management evaluates all proposals and provides responses to all Occupation- vant issues. al Health & Safety issues raised by its employees. T During 2012 the company, taking into account the financial crisis prevailing in Greece, gave priority to the needs of vulnerable social groups, increasing its financial assistance to social actions and its sponsorships and donations from 3% to 37% of its total social expenditure.

Stakeholder Groups: Press & Media - The employees’ concern for the future of their jobs T In a particularly adverse economic environment, the company managed to keep stable the number of its em- and for the well-being of their families was stressed. ployees and to maintain all benefits to them without cutting jobs or other financial benefits. Indeed, the com- - It was stressed how important it is for the compa- pany raised the earnings of its Volos plant employees, on the basis of the new collective employment con- ny to be willing to follow closely developments in tract signed during 2012. the local communities where its operations are lo- T In parallel, the company provided again financial support for Arts & Culture, investing 17% of its social ex- cated. Particular emphasis was given to culture, with penditure in related actions. the expectation than the company will continue to support it.

Stakeholder Groups: Local Authorities - The need was expressed for a shift of priorities by the T Maintaining close ties with its local communities, the company provided substantial financial support to in- company and in general by the Group to the infra- frastructure works in the Volos Swimming Centre, where the 2012 Junior Synchronised Swimming Cham- structure needs of the local communities, particularly pionships were hosted, and was the Event’s Exclusive Sponsor. It also supported extensively various educa- during the period of the current crisis. This was ac- tional institutions, such as the Aliveri Nursery and Upper Secondary School (Lykeio). companied by a request for the company to increase, to the extent that this is feasible, the share of 3% which the company presented as the level of its contribution to the local communities for 2011.

27 4.5 CSR Performance in 2012 & Targets for 2013

QUANTITATIVE TARGETS: PERFORMANCE IN 2012 & TARGETS FOR 2013 BY COMPANY

LABOUR PRACTICES Group Target Status of Target Target (description) Company for 2012 for 2012 for 2013

2.5 >3 Training hours per year and per employee – Executives. 70.0 70.0 3 >3 Training hours per year and per employee – Administrative employees. 34.0 35.0 2.0 >3 Training hours per year and per employee – Labour & Technical personnel. 50.0 50.0 1.5 >3 Average training hours per year and per employee (Men). 52.0 52.0 1.5 >3 Average training hours per year and per employee (Women). 35.0 35.0 0 0 0 0 Total work-related fatalities. 0 0 0 0 0 0 0 0 Total accidents. 0 0 0 0 0 0 0 0 Total incidents related to occupational diseases.. 0 0 0 0 80% 80% Percentage of employees receiving performance 100% 100% and career development reviews. 100% 100%

: Target achieved : Target not achieved

28 QUANTITATIVE TARGETS: PERFORMANCE IN 2012 & TARGETS FOR 2013 BY COMPANY

HUMAN RIGHTS Group Target Status of Target Target (description) Company for 2012 for 2012 for 2013

Percentage of inclusion of specific clauses on Human Rights in Company contracts with significant suppliers, 5% 5% contractors or other business partners. SUSTAINABILITY REPORT 2012

0 0 Total incidents of discrimination. 0 0 Total incidents of child labour. 0 0 Total incidents of forced labour. 0 0 Total incidents of employment of young contracted 0 0 personnel in hazardous work. Total incidents involving rights of indigenous people. 0 0 Percentage of security personnel directly employed by the company who have received formal training in 100% 100% Human Rights.

ENVIRONMENT Group Target Status of Target Target (description) Company for 2012 for 2012 for 2013 Fluoride emissions.. 1,5kg/t Al 1,5kg/t Al CF4 (Tetrafluoromethane) emissions. 0,03kg/t Al 0,03kg/t Al Recycling percentage of the filtrate from the 16% 100% treatment of bauxite residues (Filter Presses). Solid waste sorting. > 80% > 85% >50%/ 1000t Hazardous waste collection. >30 of gross product

< 20 t/basin Generation of unsorted basin waste. <20 t/cellAB ΑΒ equ < 10 kg/t AH Final waste disposal for the Alumina production line. <20 kg/t AH of waste < 14.500 Total abstraction of water (industrial use + potable). 14.560 m3/d m3/day Reduction of direct consumption of energy from By 5% primary sources by 5%.

Reduction of direct consumption of energy from By 5% non-renewable sources by 5%. Conservation of energy and/or increase of energy By 10% savings due to improvements and process reengineering.

Reduction of water consumption. By 10%

29 QUANTITATIVE TARGETS: PERFORMANCE IN 2012 & TARGETS FOR 2013 PER COMPANY

ENVIRONMENT Group Target Status of Target Target (description) Company for 2012 for 2012 for 2013

< 30 < 25 Total incidents involving significant spills. 0

To maintain and/or increase pollution prevention and By 10% environmental management costs.

Percentage of waste recycled. 100%

IΡΡ: regular maintenance of the plant to maintain its high efficiency, which results in the least possible 100% 100% burden to the environment.

SOCIETY Group Target Status of Target Target (description) Company for 2012 for 2012 for 2013 Outlays to local suppliers as a share of total 30% 30% purchases budget.

QUALITATIVE TARGETS: PERFORMANCE IN 2012 & TARGETS FOR 2013 PER COMPANY

LABOUR PRACTICES Group Status of Target Target (description) Company for 2012 for 2013

Certification of the company’s Occupational Health & Safety To maintain Management System in accordance with the OHSAS 18001 the International Standard. certification

Preparation of the procedure for the employees’ participation in the formulation and checking of Occupational Health & Safety Plans, with priority given to production facilities.

HUMAN RIGHTS Group Status of Target Target (description) Company for 2012 for 2013

Addition of specific framework clauses (“Code of Conduct”) on Human Rights as a condition for the conclusion of commercial agreement contracts.

: Target achieved : Target not achieved : Target for 2013

30 QUALITATIVE TARGETS: PERFORMANCE IN 2012 & TARGETS FOR 2013 PER COMPANY

ENVIRONMENT Group Status of Target Target (description) Company for 2012 for 2013 Control of the consumption of raw materials. Improvement of disposal costs for Bauxite Residues. Control of the consumption of energy. SUSTAINABILITY REPORT 2012 Monitoring of the percentage of the filtrate from the treatment of bauxite residues which is recycled in the production process, leading to reduced abstraction of water.

Control and, within our technological and financial capabilities, continuous reduction of solid and liquid waste and waste gas.

Installation of air duct for transporting hot air from the air compressors to the work rooms in the company’s subsidiary SERVISTEEL S.A.

Development of management system for greenhouse gas emissions. Lowest possible impact on biodiversity during the construction of RES projects. Full and strict compliance with the approved Environmental Terms of power plants (thermal and RES-based).

Operation of gas-fired power plants to remain within the high-efficiency end of the output curve. Adherence to the plants’ reliability and availability targets throughout the year.

SOCIETY Group Status of Target Target (description) Company for 2012 for 2013

Continuation of the collaboration and dialogue with Stakeholders and response to the fullest possible extent to their requirements, as these were expressed in the Dialogue Forums held in 2012. Maximisation of social dissemination of actions & programmes and focus on supporting vulnerable social groups in the current adverse economic juncture. Establishment and development of close, stable and long-term ties with social partners and other bodies and organisations.

: Target achieved : Target not achieved : Target for 2013

31 5. ECONOMIC PERFORMANCE

5.1 Key economic value data

riven by our desire for contin- formance in the coming years. Our consolidated turnover uous development and Our core development goal is “TO EX- progress and seeking to al- for 2012 stood at D PLOIT THE OPPORTUNITIES OPENING ways be at the forefront of develop- UPTHROUGHTHELIBERALISATION ments, as we have always done in €1,453 million. OFTHEENERGYMARKET” in the course of our long history, in Greece. The Group is currently hold- MYTILINEOS Group we consistently ing a dominant position in the Greek pursue our vision to become a strong and competitive European “heavy in- market, as it is the country’s largest dustry” group. In an constantly electricity producer after the PPC. The Group’s Business Investments With persistence and a clear focus on reached the amount of changing economic environment, maintaining high liquidity and miti- concrete targets, we carried out an €92 million. gating financial risk are key to en- energy investment plan in excess of suring the smooth continuation of €1 billion during the last few years, investments in all our activity sectors. managing to overcome business and Drawing on our highly qualified hu- regulatory difficulties in the process. man resources, significant assets and Today, these efforts are rewarded, as We generated a “social product” financial robustness, we aim to at the end of 2012 a substantial part with a total value of achieve a steady organic growth in the of our total turnover and operating wider region of Europe, Middle East profits came from our activities in the €233 million. and Αfrica, and we focus on consol- Energy sector. idating the significant synergies avail- In addition, the goals of “SEEKING able between our core activity sectors, NEW VERTICAL INTEGRATION PROJ- seeking in this way to ensure their bal- ECTS OR PROJECTS FOR EXPANDING anced development. At the same METALLURGY OPERATIONS” and of time, through our investment plan, we “INCREASINGCOMPETITIVENESS develop methods to curtail costs and we exploit the capabilities of sophis- THROUGH STRATEGIC INVEST- ticated risk-hedging tools and tech- MENTSANDRISK-HEDGINGMETH- niques to optimise our economic per- ODS” show the Group’s orientation in the Metallurgy sector, while the focus on “UTILISING THE SIGNIFICANT IN- DUSTRIALKNOW-HOWANDIN- FRASTRUCTURE” and on “MAIN- TAININGTHEGROUP’SLEADING ROLEINENERGYPROJECTSIN GREECEANDEXPANDINGITSOP- ERATIONS ABROAD” is indicative of the Group’s strategic priorities in the EPC Projects sector.

32 Economic Value Table 2010 2011 2012

Economic value created

Turnover (€) 1,001,351,000 1,570,998,231 1,453,635,665

Economic value distributed Operating costs (€) 850,470,000 1,394,182,732 1,355,008,786 Employee salaries and benefits (€) 87,290,000 92,019,145 82,131,707 SUSTAINABILITY REPORT 2012 Payment of income tax & other taxes (€) 38,566,000 67,666,347 32,942,394 Payments to capital providers (€) 6,154,000 30,208,942 54,263,639 Investments in local communities (€) 1,062,667 1,221,835 741,607 Total (€) 983,542,667 1,585,299,001 1,623,715,012

% of economic value which is distributed 98.2% 100.9% 111.7% % of economic value which is retained 1.8% -0.9% -11.7%

Significant financial assistance* received from Government 2010 2011 2012 Tax exemptions / credits (€) 133,398 115,200 0 Subsidies (€)* 282.201 4.816.149 436,841

Investment, research and technology subsidies 1.084.914 133.739 0 and other relevant types of subsidies (€)

* During the fiscal year 2012, ALUMINIUM S.A. and DELPHI-DISTOMON S.A. received €279,863 and €147,578 of subsidies, respectively, consisting in refunds of the Special Consumption Tax on fuel and of employer contributions paid to the Em- ployment and Vocational Training Account [LAEK] of the Manpower Employment Organisation [OAED].

33 5.2 New investments management and strict cost controls, its strategic goals – to globalise its busi- succeeded in posting financial results ness operations, to improve its com- The economic climate during 2012 re- that stood at levels comparable to its petitiveness and to build a balanced sulted in suffocating conditions for record-high ones of 2011. portfolio of industrial activities, thus lay- Greek businesses, characterised pri- ing solid foundations that allow it to marily by the uncertainty regarding the 2012 saw the completion of our sub- look to the future with optimism. progress of investment plans. In this stantial energy investment plan, despite negative juncture, MYTILINEOS Group, the particularly adverse conditions. In particular, developments during relying on its strong export orientation, The end of the year found the Group 2012 in the Group’s activity sectors consistent cash flow and liquidity in a strong position, as it has achieved were as follows:

Metallurgy EPC & Mining Projects Energy

We have given priority to the ap- Throughout last year, METKA S.A. was For MYTILINEOS Group, the plication of strict cost controls faced with the consequences of the commercial operation of the and to reducing operating costs volatile economic environment. The lack PROTERGIA S.A. plant in in ALUMINIUM S.A., in order to of confidence in Greece led to serious ob- Ag. Nikolaos and of the improve the company’s compet- stacles in the company’s international ac- KORINTHOS POWER plant, in itive position. The satisfactory tivity, making its efforts to secure new June 2011 and April 2012, re- progress of the “MELLON” com- projects all the more difficult. At the same spectively, signalled the comple- petitiveness improvement pro- time, the company had to address the is- tion of the first phase of the gramme was already reflected in sues and challenges caused by the esca- Group’s investment plan with the sector’s financial results for lating tension in Syria. With a strong installed thermal capacity 1,2GW. the second half of 2012, which sense of responsibility, the company’s Additionally, on 17/1/2013 the were markedly improved com- Management took all necessary measures Ministry of Environment, Energy pared to the first half of the year. to ensure the protection of its employ- and Climate Change issued the More specifically, the actions ees and facilities, working out alternative commercial operation licence for which ALUMINIUM S.A. had iden- ways in which work on its local project the High Efficiency Combined tified under the “MELLON” pro- could progress, so that the project could Heat and Power plant (CHP/High gramme by the end of 2012 ac- be completed as soon as possible. Despite Efficiency CHP) of ALUMINIUM count for more than 80% of the these obstacles, the company remained S.A. This plant was already in tri- programme’s final cost savings steadily on a positive course during al operation since 28/11/2012, as target. The full recognition of the 2012, rising to the challenges with a high the Electricity Market Operator in- benefits of these actions in the fi- level of professionalism and drawing on cluded it in the national grid nancial results posted by the credibility and reliability it had build configuration as a Distributed ALUMINIUM S.A. and by the for itself over the previous years. High-Efficiency CHP Plant in trial Group has already started during Remaining committed to its strategy of operation, following the conclu- 2012 and is expected to be grad- international orientation and continued sion of an agreement under ually completed during 2013. enhancement of its exporting profile; which the electricity produced by METKA continued to generate most of the plant and injected into the its revenues abroad and achieved a sub- national grid was measured and stantial expansion of its portfolio of in- priced accordingly. ternational projects.

34 6. EMPLOYMENT & LABOURPRACTICES SUSTAINABILITY REPORT 2012 or MYTILINEOS Group, the pro- held in all our subsidiaries to provide motion of dialogue and collabo- them with information on important F ration with its people on issues of corporate matters and on potential op- common interest is a daily concern. Our erational changes. With respect to the 100% of our business employees and their representatives are latter, all Group employees affected by units have in place Occupational encouraged to express their opinion on such changes are informed of them Health & Safety Management business, social and environmental is- within the time limits prescribed by the Systems certified in accordance sues through appropriate constructive applicable laws, which in several cases with the OHSAS 18001 international standard. channels such as, for example, their par- exceed the statutory ones. Finally, in all ticipation in the consultations with geographical locations of its operations our Stakeholders, in line with our com- abroad, our subsidiary METKA S.A. mitment to open and constructive complies with the applicable national communication that promotes the or regional laws and adheres to em- We hired public good as well as mutual interests, ployment and labour practice standards, as well as their participation in the reg- which are the same as those that ap- 374 ular and ad hoc meetings between the ply in Greece. new employees. Management and their collective Unions, in the annual employee per- On our Website: formance review procedures, etc. Ad- Our Management Approach regarding Labour Practices ditionally, meetings with employees are

85% of our employees come from our local communities.

We provided 54,029 training hours, increasing the average hours of training per year per employee to

34.2 h.

35 6.1 Employment the efforts of our people, whose sci- (2.7%) less than 2011 – a development entific qualifications; effectiveness attributed to the difficult economic A standing goal of MYTILINEOS Group and professional dependability help us conditions in Greece. Almost 89% of is to successfully attract competent meet our business targets in the con- our people are employed in mining ac- professionals and to support their stantly changing and difficult economic tivities, aluminium production and development, ensuring that their ca- EPC construction projects, while 8% conditions of the last years. reers evolve within our Group com- are employed in the Energy sector, a panies and contribute to our efforts for On 31.12.2012, MYTILINEOS Group share that is expected to increase economic, social and environmental employed a total of 1,965 people in- during 2013 driven by the entry of progress towards sustainable devel- cluding freelance professionals and PROTERGIA S.A. in the retail market opment. We recognise and appreciate subcontractor personnel, slightly for electricity.

Total workforce 2010 2011 2012 Contracted personnel 2010 2011 2012

Total 2,249 2,020 1,965 Total 410 397 384 Men 1,732 1,703 Men 315 315 Women 288 262 Women 82 69

In METKA S.A. the number of per- In late 2012 the Management of sonnel dropped by 15% from the ALUMINIUM S.A. and the Union of previous year, mainly due to: (a) A substantial contribution to the Company Employees signed a new the transfer of salaried personnel stabilisation of the number of per- agreement, under which the plant’s to a Group subsidiary to support sonnel of MYTILINEOS Group in jobs and production capacity are the implementation of the Group’s 2012 came from the reorganisation maintained, with substantial cost business plan. (b) The completion of the Energy Management and rationalizations introduced on a sus- of company projects in Greece and Trading Division of PROTERGIA S.A., tainable and long-term basis. abroad. with the inclusion in it of three thermal plants (Ag. Nikolaos and Korinthos Energy Centres) and of the RES plants. Staffing needs for the thermal plants and for the Re- tail Division led to the recruitment of 123 employees, helping to boost the Group’s total workforce level for 2012.

36 Employability in MYTILINEOS Group is DELPHI-DISTOMON S.A. is assigned to and abroad. Changes in employment primarily affected by the need to re- specialist subcontractors and free- data for the various regions are due cruit employees under fixed-term em- lance professionals. The tables below mainly to fluctuating needs by geo- ployment contracts in aluminium pro- present data on the breakdown of the graphical region, depending on the duction during the summer, and by Group’s force by gender, employment progress of the EPC projects carried the fact that a significant part of the type, type of employment contract out locally by METKA S.A. activities of METKA S.A. and and geographical region, in Greece SUSTAINABILITY REPORT 2012

Personnel by Personnel by type of 2010 2011 2012 employment type 2010 2011 2012 employment contract

Total full-time Total open-ended 1.839 1,620 1,580 1.747 1,540 1,480 employees employment contracts

Men 1,414 1,387 Men 1,342 1,297 Women 206 193 Women 198 183

Total part-time Total fixed-term employment - 34 92 83 104 employees contracts

Men 23Men 75 93 Women 11Women 6 11

Personnel by geographical 2010 2011 2012 Personnel by geographical region – Greece region – Other countries 2010 2011 2012 Sterea 1.399 1,470 1,547 Turkey 34 32 113 Men 1,248 1,345 Men 18 83 Women 222 202 Women 14 31

Macedonia 265 79 23 Syria 752 Men 62 14 Men 42 Women 17 9 Women 10

Thessaly 183 172 167 Iraq 10 Men 160 156 Men 10 Women 12 11 Women 0

Peloponnese 12 23 42 Jordan 9 Men 21 37 Men 9 Women 25Women 0

Other regions 61 45 Romania 62 11 2 Men 55 42 Men 51 Women 63Women 1

37 With regard to the mobility of per- and around 6% to voluntary depar- ered to possess the skills and knowl- sonnel, the Group’s actual personnel tures of Group employees. In specific edge that meet the needs of the re- turnover during 2012 (after taking in- cases of voluntary departures, exit in- spective vacancies in their organisation. to account that 30% of departures, as terviews were held to discuss the At the next step, our Group compa- shown in the corresponding table reasons for the departure, always nies hired a total of 374 new em- below, involved employee transfers with a view to improving the respec- ployees, giving priority to women within the Group) grew by 3 per cent tive Group company. In order to fill the and young people – two categories units to 14.2%. Actual employee de- vacancies created as a result of the de- whose share of newly-hired employ- partures stood at a total of 221, partures, a common priority for our ees compared to 2011 grew by 47.5% down 15% from 2011. Of these de- subsidiaries is to put to the best pos- and 12.5%, respectively, thus helping partures, around 37% were due to re- sible use the capabilities of their ex- strengthen the employability of these tirement; 27% were due to termina- isting personnel, through internal job social groups, which are particularly tion of employment contracts, expiry rotation or promotions, provided that vulnerable to unemployment. of fixed-term contracts and dismissals; the candidate employees are consid-

T During 2012, a total of 126 employees left METKA S.A. Of these departures, the largest part (58%) were due to the transfer of personnel to another Group subsidiary, 14% to the termination of employment contracts, 13% to During 2012, a total of 140 em- voluntary departures, 10% to expiry of fixed-term employment or work ployees left ALUMINIUM S.A. Of contracts, and 5% to retirement. As regards recruitment, significant in- these departures, the largest part creases in terms of the share of newly-hired employees regarded women (65%) were due to retirement (+9.5%) and workers over 50 years old (10%). and the remaining 35% due to termination of employment con- The volatility in the business environment necessitates adjustments in the T tracts and voluntary departures. company’s strategy and adoption of flexible arrangements in the utilisa- The company also hired 199 em- tion of its human resources, so that high performance levels can be main- ployees to cover its staffing tained. As part of the efforts to use in the best possible way the potential needs. Of this total number of of its existing human capital, the company gave priority to using personnel new employees, almost 80% freed from their duties following the completion of its projects in Turkey, were up to 30 years old and 15% over sourcing new personnel from its external environment (labour mar- were women. ket). In addition, in all its activity sectors and where this is practicable, the company keeps flexible working hours, in order to help employees deal with personal needs and reduce absences from work.

38 Personnel recruitment Personnel departures (by gender, age group 2010 2011 2012 (by gender, age group 2010 2011 2012 and geographical region) and geographical region)

Personnel recruitment - Total 350 364 374 Personnel departures – Total 278 265 321

Men 277 323 312 Men 240 226 271

Women 73 41 62 Women 38 39 50 SUSTAINABILITY REPORT 2012

% share of total full-time employees % share of total full-time employees

Personnel recruitment -Total 19.0% 22.5% 23.7% Personnel departures 15.1% 16.3% 20.3% Men 15.1% 20.0% 19.7% Men 13.1% 14.0% 17.2% Women 4.0% 2.5% 3.9% Women 2.0% 2.3% 3.1% Recruitment (<30 y.o.) 165 177 199 Departures (<30 y.o.) 48 67 70 Recruitment (30-50 y.o.) 151 177 160 Departures (30-50 y.o.) 102 91 130 Recruitment ( >50 y.o.) 34 10 15 Departures (>50 y.o.) 128 107 121 % share of total full-time employees % share of total full-time employees <30 y.o. 9.0% 10.9% 12.6% <30 y.o. 2.6% 4.1% 4.4% 30-50 y.o. 8.2% 10.9% 10.1% 30-50 y.o. 5.5% 5.6% 8.2% >50 y.o. 1.8% 0.6% 1.0% >50 y.o. 7.0% 6.6% 7.6% Recruitment-Sterea - 289 294 Departures-Sterea 114 167 247 Recruitment-Macedonia - 15 1 Departures-Macedonia 66 21 16 Recruitment-Peloponnese - 20 44 Departures-Thessaly 34 13 7 Recruitment- Other regions - 14 9 Departures-Peloponnese 3229 Recruitment-Syria --4 Departures-Other regions 40 49 - Recruitment-Turkey - 26 20 Departures-Syria 1 - 3 Recruitment-Iraq --2 Departures-Turkey 199

% share of total full-time employees Departures-Romania 8410

Sterea - 17.8% 18.6% % share of total full-time employees

Macedonia - 0.9% 0.06% Sterea 6.2% 10.3% 15.6% Peloponnese - 1.2% 2.8% Macedonia 3.6% 1.3% 1.0% Other regions --0.6% Thessaly 1.8% 0.8% 0.4% Syria --0.2% Peloponnese 0.2% 0.1% 1.8% Turkey - 1.6% 1.3% Other regions 2.2% 3.0% 0.0% Iraq --0.1% Syria 0.2% 0.0% 0.2%

Turkey 0.05% 0.7% 0.6%

Romania 0.4% 0.2% 0.6%

39 Departures of newly-hired personnel during 2012 2011 2012

Departures of newly-hired personnel - Total 69 47

Men 63 45 Women 62

% share of total full-time employees

Departures of newly-hired personnel – Total 4.2% 3.0%

Men 3.9% 2.8% Women 0.4% 0.1%

Departures of newly-hired personnel (<30 y.o.) 32 28

Departures of newly-hired personnel (30-50 y.o.) 34 17

Departures of newly-hired personnel (>50 y.o.) 32

% share of total full-time employees

<30 y.o. 2.0% 1.8% 30-50 y.o. 2.1% 1.1% >50 y.o. 0.1% 0.1%

The recruitment policy of MYTILINEOS Percentage of Senior Management Group provides opportunities for the Executives of the Group companies 2010 2011 2012 development of local employment. In recruited from the local communities all the geographical regions where we 1 operate, the majority of our human re- ALUMINIUM S.A. 11.1% 11.1% 11.1% sources come from the local popula- DELPHI-DISTOMON S.A.2 40.0% 44.4% 33.0% tion. In addition, our practice to include members of the local commu- METKA S.A.3 90.0% 80.0% 80.0% nities in the management teams of our subsidiaries creates economic benefits PROTERGIA S.A.4 67.0% 67.0% 70.0% for the local communities involved and improves our ability to understand lo- MYTILINEOS HOLDINGS S.A.5 100.0% 100.0% 100.0% cal needs. The Group companies have developed reliable personnel selection proce- 1. The term “Senior Management” refers to the company’s Plant Steering Committee, dures adapted to the particular char- 2. The term “Senior Management” refers to the company’s Executives and to its Board of Direc- acteristics and needs of their business tors. 3. The term “Senior Management” refers to all persons holding the position of Supervisor or higher activity sector. These procedures are positions. designed to assess the qualifica- 4. The term “Senior Management” refers to the Managers of the company’s Headquarter Divi- tions/skills of candidates in relation to sions, the Managers of its Energy Centres, and the General Management. the corresponding corporate require- 5. The term “Senior Management” refers to all company Executives. ments and needs, as well as in terms of their personality and behaviour traits.

40 6.2 Employee Education, Training and Development

In line with the priority that we attach long-term needs of our personnel. guages learning. The total training cost to the continuous development and Through our subsidiaries, during 2012, for the Group stood at €1.27 million. improvement of our people’s qualifi- we carried out a total of 54,029 A large part of these training pro- cations, the education and training ini- hours of training programmes, in- grammes were carried out as in-house tiatives in MYTILINEOS Group are the creasing the average training hours per seminars, especially in ALUMINIUM framework which ensures the devel- employee to 34.2, up from 31.5 in S.A. and PROTERGIA S.A., as in addi- opment of the necessary skills of our 2011. In terms of the subjects covered tion to facilitating the educational SUSTAINABILITY REPORT 2012 employees, so that they can play an ac- by our training plan, 77% of the total process itself, this approach offers a tive part in the Group’s evolution, number of training hours were allo- number of further advantages: It al- and guarantees our competitiveness in cated to Health & Safety, 12% to Tech- lows direct intervention to improve the the long-term. In this context, the nical Training, and 11% to a variety of training procedure where required, it training programmes carried out an- subjects, of which the most important increases the number and qualifica- nually by our subsidiaries are the prod- ones were the development of Per- tions of the in-house trainers involved, uct of a well-planned, comprehensive sonal Skills and Continuous Progress, and it improves the propagation of effort that is driven by the short- and as well as IT Skills and Foreign Lan- best practices at all levels.

Average personnel training hours 2011 2012 employment position

Average training hours (Executives) METKA S.A. gives priority to the 31.3 26.3 development of the knowledge and skills of engineers and of their Average training hours (Administrative employees) 17.7 18.2 capacity for dynamic adjustment to the demands of modern-day Average training hours (Technical & Labour personnel) 45.1 44.6 technologies. In line with this approach, the company has strength- ened the technical training of its site engineers, who take active part in technical on-the-job train- Average personnel training hours by gender 2011 2012 ing programmes, during which training is delivered under actual work conditions. Average training hours (Men) 35.0 37.2

Average training hours (Women) 8.5 10.5

With 17.7 training hours per year, ALUMINIUM S.A. and PROTERGIA S.A. post the highest average training hours per year and per employee for women – a figure considerably higher than the corresponding average of the Group.

41 In addition to our basic training plan, in-house seminars and vocational training programmes for skills development are carried out. These are fi- nanced through the funds available from the Employment and Vocation- EMPLOYEE TRAINING AND SUPPORT PROGRAMMES: 80 Employees (Executives, Technical & Labour personnel). al Training Account [LAEK] of the Manpower Employment Organisa- OPERATION OF ENERGY CENTRES: 100 Employees (Executives, Technical & tion [OAED] and are held in our com- Labour personnel). panies’ offices, plants and construction INDUCTION TRAINING PROGRAMME: Mandatory for all newly-hired employees. sites. In addition, paid educational HEALTH & SAFETY AT THE WORKPLACE PROGRAMME: 150 Employees (all cate- leave is granted to employees at- gories). tending long-term courses of study (at FIRE SAFETY PROGRAMME: 66 Employees (all categories). the graduate or post-graduate level) during the examination periods, to QUALITY ASSURANCE PROGRAMME: 30 Employees (Executives, Administrative employees). help them prepare for their exams. In line with its policy on education and SAP TRAINING PROGRAMME: 15 Employees (Executives, Administrative Em- training, the Group also encourages ployees). the participation of its employees in The funds available through the Employment and Vocational Training Account external training seminars that help [LAEK] of the Manpower Employment Organisation [OAED] were used to fi- them develop their professional skills, nance training seminars on the following: OHSAS 18001:2007/ELOT 18001:2008; and covers 100% of the relevant ISO 9001; ISO 14001; and Effective Negotiation Techniques. training costs.

42 With regard to practices relating to the tion is payable in accordance with the performance review systems of our provision of transition programmes de- provisions of Law 3863/2010 and companies rely on measurable criteria signed to support employees about to Law 4093/2012, while in some cases and have the following overall objec- retire, the Group for the time being the compensation actually paid is tives: (a) To evaluate personnel in an does not provide placement services higher than the statutory one. objective manner; (b) to help achieve or support, training and advice pro- In MYTILINEOS Group we encourage continuous performance improve- grammes to departing employees. initiative, reward innovation and eval- ment; (c) to review the goals set for However, it maintains in effect and ap- uate the individual performance of our every employee; and (d) to identify new education and training needs. In plies specific pension plans. In addition, people. Our companies have in place SUSTAINABILITY REPORT 2012 2012, more than 82% of our em- in order to ensure the smooth suc- advanced performance review sys- ployees received annual reviews of cession of the persons who retire, suc- tems for their personnel, whose key their performance and career cession plans are developed to iden- priority is to help fill all vacancies which prospects, with this percentage rising tify suitable successors to the positions may be created through internal promotions, provided that the candi- to nearly 90% in the case of full-time vacated and to help them adjust date employees possess the knowl- employees. smoothly to their new jobs. In addi- edge and qualifications required. The tion, through its Talent Management System, the Group identifies employees with exceptional capabilities who become candidates for senior man- Percentage of employees who received a performance review, agement positions. by company

In the case of dismissals, compensa- 100% G 2012 82,3% G 2011 80% 71,9% 72,4% 63,1% 60%

40%

20% 10,0% 8,8% 0%

Percentage of employees who received a performance review, by company

100,0% ALUMINIUM S.A. 100%

80% 100,0% 67,8% DELPHI-DISTOMON S.A. MYTILINEOS S.A. 60% 40%

20%

68,5% 86,3% PROTERGIA S.A. ΜΕΤΚΑ S.A.

43 The company applies a Perform- The company applies a Professional Development Review Process in the form ance Review System to record and of annual meetings held to facilitate the exchange of views, assessments, rec- asses in an objective manner the ommendations and information between an employee and his/her immediate performance of every employee supervisor, in the presence of the supervisor in the next level up the manage- against specific performance crite- ment hierarchy, if this is possible from an organisational point of view. The em- ria. The relevant procedure takes ployee and his/her supervisors review and discuss regularly the employee’s place at the end of every year. The progress and his/her overall career path within the company. The general and evaluation (carried out by the em- specific criteria for advancement are examined and taken into consideration in ployee’s direct and indirect super- setting the personal goals and training needs for the employee concerned, as visors) and the performance well as in formulating an appropriate succession plan for those employees who appraisal interview that follows are close to retirement. provide employees and their asses- In addition, the company has developed an Executive Evaluation Guide that sors with the opportunity to ex- serves the following key objectives: change views, to reward specific aspects of performance, to identify -Τo assess the progress made by the evaluee. areas for employee improvement - To identify and agree/accept the priorities for the next year. and to establish a training and per- - To resolve problems that arise during the year. sonal development plan for the next year. The purpose of the sys- - To mobilize personnel towards the achievement of corporate targets. tem is twofold: To guide the objec- - To ensure the comprehensive planning of actions and initiatives to help tive evaluation of the performance achieve corporate targets. of employees on the basis of their - To provide evaluees with counseling regarding their personal professional contribution to the achievement of development. the corporate targets, and to help employees improve and develop - To provide the supervisor-evaluator with feedback on the views of the eval- further. The application of this sys- uee regarding any problems in their collaboration. tem during 2012 led to the promo- - To improve the performance of the evaluee and of the company in its en- tion of five (5) employees. tirety, and to identify priorities for improvement as input to the Executive development and training process.

As a new company, the goal of PROTEGRIA S.A. is to evaluate the performance of all its employees and to ensure that they receive information on their career development from their supervisors. The company applies a Performance Re- view System for all personnel employed for more than six (6) months. Under this system, employees during the year receive from their direct supervisors regular verbal updates on their performance and – at the end of the year – a written performance and career development review. Newly-recruited employees work on probation for a first “trial” period, during which they are evaluated in terms of their adjustment to their job, the interest that they show in the subject scope of their work, and their know-how and ability to cope with the requirements of their position.

44 6.3 Occupational Health & Safety

During 2012, we continued our efforts zero serious accidents or work-related utives of our subsidiaries, in order to to develop and incorporate into the fatalities and zero incidents related to emphasise even more their responsi- operations of all Group companies a occupational diseases. An additional bility for combining business priorities “Safe Work Rule” attitude and ap- future goal is to include the achieve- with Corporate Social Responsibility in proach that focuses on the prevention ment of Occupational Health & Safe- every respect. of accidents and occupational dis- ty targets as a specific criterion in the eases. Every year, our goal is to have evaluation of the Management Exec- SUSTAINABILITY REPORT 2012

Rate of Accidents and Work-related Fatalities

25,0 22 Accidents During 2012 two accidents occurred leading to Work-related Fatalities 20,0 temporary interruption of work. These involved injuries in the limbs (legs) sustained by employees in the Alumina production department. The two 15,0 incidents were analysed using the “Cause Tree 10 Analysis” method, the reasons that caused them were 10,0 established, and relevant corrective actions were planned (including, for each action, the designation of a person in a charge, a deadline and a completion 5,0 2 date), with a view to informing employees and to preventing the occurrence of any conditions that 0,0 could cause such accidents to happen again. 2010 2011 2012

Our performance in 2012 was marked- § METKA S.A.: The company pro- Safety Visits; 10 inspections of sub- ly improved compared to the previous vided training on Health & Safety to contracts in progress; 8 inspections year, as only two (2) injuries were all newly-hired Personnel, as part of of confined spaces; 15 installation recorded. In addition, there were no its formal induction programme (ap- lockout inspections; and 12 circula- work-related fatalities and no inci- plied in the company’s Offices / tion inspections. In addition, the dents related to occupational dis- Construction Sites / Manufacturing company monitors the following eases. Plants), which new employees attend Safety indicators: LTI (Lost Time Injury – number of accidents with inter- This improved performance was made before they commence work. Reg- ruption of work); RCR (Recordable possible by several key initiatives in our ular training updates on Health & Case Rate – number of recorded ac- subsidiaries, as follows: Safety issues were provided to all company personnel, with a focus on cidents without interruption of § PROTERGIA S.A.: The company in- the particular characteristics of each work); and FA (number of visits to tensified its actions to prevent injuries specific work environment e.g. (Evac- the Medical Station). For every inci- and occupational diseases at the dent recorded, the Incident Analysis uation Drills, Fire Safety, Health and workplace, by adopting the OHSAS Rate (using the “Cause Tree Analy- Safety in construction sites or man- 18001 International Standard for its sis” method) and the 48-hrs Safety ufacturing plants). Occupational Health & Safety Man- Incident Analysis Rate are also agement System and obtaining the § ALUMINIUM S.A.: The company logged. Finally, 185 measurements of relevant certification in late 2012. carried out the following actions dur- safety conditions (noise, vibrations, The company’s training plan for ing the year: 60 Personal Safety Ac- presence of fluoride etc.) and 743 2012 included training on emer- tions (PSAs) and 10 Management regular employee medical check- gency response procedures, focusing Safety Visits (MSVs) for every man- ups were carried out, and 310 em- on fire-fighting and the evacuation agement executive who received ployees were tested for the presence of facilities. relevant training; 18 Health and of fluoride in their body.

45 Evolution of Occupational Health and Safety indicators

Injury Rate (IR) Occupational Diseases Rate (ODR)

2.0 2.0 1.8 2012 IR 2012 ODR Men: 0.1 Women: 0.0 Men: 0.0 Women: 0.0 1.5 1.5

1.1 1.0 1.0

0.5 0.5

0.1 0.1 0.0 0.0

0.0 0.0 2010 2011 2012 2010 2011 2012

Lost Days Rate (LDR) Absenteeism Rate (ΑR)

20.0 6,000.0 5743.3 2012 ΑR 16.7 2012 LDR Men: 3.3 Women: 0.0 5,000.0 Men: 289.3 Women: 828.9 15.0 11.9 4,000.0

10.0 3,000.0

2,000.0 5.0 2.9 1,000.0 364.8 134.9 0.0 0.0 2010 2011 2012 2010 2011 2012

In METKA S.A., Health & Safety Committees function at In ALUMINIUM S.A. the Plant Health & Safety Committee the facility level (in every construction site or plant). More (PHSC) represents all personnel in the meetings held with specifically the Health & Safety Committee at the Volos the Management. The PHSC is composed of five (5) mem- Plant is composed of employees, Union representatives bers, which (in accordance with the laws and in propor- and members of the Management, and is established in tion to the number of plant personnel) are elected by the accordance with the provisions of the Greek laws. The personnel every 2 years. The PHSC has extended respon- Safety Technician and the Occupational Physician work sibilities and its members participate in all key proce- closely with the committee on all issues regarding the dures, committees or working groups. More specifically, safety, protection and health of employees. The Com- the PHSC members participate in: mitte's members, the Safety Technician, the Occupational - The “Green Light Committees” for new projects/works Physician and the Company's representatives attend Train- and major modifications to facilities. ing Programmes on Health & Safety and related official in- - The analyses of accidents and incidents carried out us- formation days. In addition, in all of the company’s con- ing the “Cause Tree Analysis” method. struction sites specialized personnel is on duty at all times - The working groups established for the written as- at to handle Health & Safety issues, First Aid services are sessment of occupational hazards and risks, and provided (personnel & equipment), and an Ambulance - The Occupational Health & Safety visits scheduled with and Occupational physician are available to administer the Occupational Physician and the Safety Officer. First Aid care and handle emergencies.

On our Website: - Our official policy on Occupational Health and Safety - The Health & Safety indicators calculation method

46 6.4 Benefits ployees’ individual performance and ture of their activities, our subsidiaries capabilities, which are monitored –especially in aluminium production In MYTILINEOS Group, we apply reli- through the annual performance re- and EPC projects– employ primarily able and objective methods to deter- view process. men in positions with higher speciali- mine compensations and benefits – sation requirements (technical or man- and their evolution– for all our em- Differences in salaries arise exclusive- agerial) and women in less specialised ployees, so that we can ensure meri- ly from the average level of expertise positions, a situation that is reflected tocracy in earning levels, guarantee by gender and category of employ- in the corresponding salary levels. competitive earnings in relation to the ment position. Due to the specific na-

Greek market, and lay the foundations SUSTAINABILITY REPORT 2012 for long-term relations with our employees in all Group companies. The Basic salary for women vs. basic salary for men, by 2012 compensations and benefits pack- employment position ages that we offer to our employees are of course determined in accor- Executives -16,5% dance with the minimum entry levels provided under the laws in force. Administrative employees -11,5% Any compensations over and above Technical & Labour personnel -17,7% these levels are based on the em-

In addition to pecuniary benefits, our fessional and family obligations. To this ones, to the employees of all our sub- key concern is to create an attractive end, we are extending a number of sidiaries. work environment in which our em- voluntary long- and short-term bene- ployees are able to balance their profits, over and above the statutory

Basic benefits extended DELHPI- MYTILINEOS ALUMINIUM METKA PROTERGIA DISTOMON by the Group companies HOLDINGS S.A. S.A. S.A. S.A. to full-time employees S.A.

Life insurance xxxxx Health and medical care xxxxx Coverage against disability/incapacitation xxxxx Retirement provisions xxxxx Maternity / paternity leave xxxxx

Voluntary benefits extended DELHPI- MYTILINEOS ALUMINIUM METKA PROTERGIA DISTOMON by the Group companies HOLDINGS S.A. S.A. S.A. A.E. to full-time employees S.A.

Additional leave for parents of large families (>3 children) x Housing for non-local employees xx x Personnel transport xxxx Ownership of company shares xx Company credit card xxx Theatre tickets and tickets for various cultural events x Company car and parking space for Executives xχχχ Electronic pass for toll stations χ χ Company fuel card χχ Mobile phone, laptop and smartphones χχχχ Fuel allowance χχχ Work gear and meals χχ χ

47 Despite the adverse economic conditions, the company continues with its current employee benefits plan, de- The company supports its personnel on health-related is- signed to help improve the standard of living of its em- sues, offering a private insurance plan which includes life ployees. Indicative such benefits include a health and insurance and comprehensive health and medical care medical plan, payment of higher compensations for coverage in Greece and abroad. In 2012 the company day-labourer retirement or layoffs, interest-free loans started its cooperation with a new private insurer and and cash facilities to employees, special anniversary gift created a new coverage plan. Special policies were also payments to employees on completion of 10, 20, and 35 developed and introduced regarding company credit years of service with the company, coverage of school cards, company cars with a fixed quantity of fuel, mobile expenses for children of company employees etc. Special telephones, and e-pass devices (electronic passes for toll emphasis is given to our employees in foreign countries, stations) for travels to/from the company’s thermal with a set of benefits that ensure a framework of secu- plants. In addition, we are particularly sensitive to the rity and protection of personnel of the company. In- issue of parental leaves, granting such leaves to the full dicative examples include: 1. Travel insurance for em- extent under the law to employees who are entitled to ployees who travel frequently abroad on company them. For women, our policy provides for their tempo- business; and 2. Special insurance package medical and rary replacement until the end of their maternal leave hospital coverage tailored to national circumstances. and the smooth return to their job duties.

Employees returning and remaining at work after parental leave, by gender 2011 2012

Employees entitled to parental leave 22 310 Men 15 84 Women 7 226 Employees who used parental leave 4 10 Men 01 Women 49 Employees returning to work after the end of parental leave 26 Men 01 Women 25

% share of total full-time employees Employees returning to work after the end of parental leave 0.1% 0.4% Men 0.0% 0.1% Women 0.1% 0.3% Employees returning to work after the end of parental leave and still employed 26 after 12 months from their return Men 01 Women 25 % share of total full-time employees Employees returning to work after the end of parental leave and still employed after 12 0.1% 0.4% months from their return Men 0.0% 0.1% Women 0.1% 0.3%

48 7. PROTECTION OF HUMAN RIGHTS SUSTAINABILITY REPORT 2012

In 2012, 7.1 Fundamental labour rights 30 women he respect of the fundamental ploitation for labour and undeclared rights of employees, as these are employment, and prohibits all sexual held management positions in or other harassment or exploitation of the Group, a rate that represents T defined in the Declaration on the Group's best performance Fundamental Principles and Rights at the Group’s employees in the work- since its establishment. Work of the International Labour Or- place and in general in the premises ganisation (ILO) is a key strategic goal where its activities take place” (extract for our Group, as also stated in our from the Professional Ethics Code of Professional Ethics Code: the MYTILINEOS Group). “The Management of the Group se- In line with the above: lects, assigns duties to, rewards and T Since the end of 2010, we have in- compensates its employees based on 90% of all our direct troduced the inclusion of criteria on employees receive performance their formal and essential qualifications the protection of Labour Rights in reviews on an annual basis. with respect to the requirements of our major business agreements in their work, without discrimination on terms of economic volume and grounds of race, religion, ethnic origin, strategic importance, as well as in colour, gender, identity, age, nation- the contracts that we conclude ality, sexual orientation, family status, with major suppliers, contractors and disability or of any other characteris- other business partners. We prohibit tics protected by the law. It encourages all types of compulsory or forced T Since the end of 2012, we are de- and recommends to all its employees labour. veloping a specific screening system to respect the individuality of every em- regarding our key suppliers and ployee, supplier or client of the Group subcontractors, which includes pro- and to refuse to concede to any be- cedures for self-evaluation and for haviour that is offensive to the per- the conduct of audits by official In- We prohibit sonal dignity of the individual, creates ternational Organisations and NGOs the employment of minors. discriminations of any type or results to ensure compliance with the re- in forced labour. It pledges to protect quirement for protection of Labour children and minors against their ex- Rights in their work premises.

The percentage of the contracts which the company concluded with major suppliers and contractors during 2012 and which included cri- The percentage of the contracts teria on the protection of Human which the company concluded with Rights stood at 12%. With regard major suppliers and contractors dur- to the company’s major business ing 2012 and which included criteria agreements, this percentage stood on the protection of Human Rights at 7.7%. stood at 10%.

49 T During 2012, we communicated to handling complaints regarding vio- son is first of all responsible for tak- all our subsidiaries clear instruc- lations of Human Rights. According ing action to prevent the occurrence tions on the inclusion of the pro- to the procedures currently in place, of such practices, and then for deal- tection of Human Rights as a subject in every business unit one person ing with cases of related complaints in their employee training plans. We (the Construction Site Manager, immediately, in full compliance with are also working to implement a rel- the General Manager, the Man- the local national laws and the evant in-house seminar at the Group agers of Headquarter Divisions, the principles of the Company. level, to be coordinated by Managers of the Energy Centres, MYTILINEOS HOLDINGS S.A. as the and the Human Resources Depart- Group’s Corporate Centre. ments) is designated as supervisor or On our Website: T Additionally, during 2013 we will be- as the person responsible for re- - Our Management Approach regarding gin work on the formulation of a for- ceiving all complaints regarding vi- the protection of Human Rights mal Group-level policy for specifically olations of Human Rights. This per-

50 7.2 Equal opportunities & diversity

The particular characteristics and the nic origin of our human resources, to- salaries, but also regarding the edu- needs of the business activity sectors gether with information on any cases cation, training and professional de- of MYTILINEOS Group, especially in of disability, in the interests of prop- velopment of employees. During 2012, production-related areas, are the fac- er management and in order to pro- as shown in the tables below, we in- tors that determine the indicators of vide assistance and support to those creased the participation of women diversity which we use in connection who need it. In all cases, we adopt so- and of employees aged from 30 to 50 with the promotion of equal oppor- cial practices characterised by the re- in all employment position categories. tunities and the respect of the indi- spect for the individuality of employ- Furthermore, no incidents of discrim- SUSTAINABILITY REPORT 2012 viduality of every employee. With the ees, in all the geographical regions and ination were reported in the plant fa- outmost respect for the personality of the countries where we operate and cilities or administrative premises of the every individual, we monitor and col- we offer equal opportunities not on- Group companies. lect data on the gender, age and eth- ly in terms of filling vacancies and of

Personnel breakdown according to 2011 2012 Administrative employees: special indicators of diversity Breakdown according to special 2011 2012 Men 87.3% 86.0% indicators of diversity Women 12.7% 14.0% Men 85.7% 70.1% Employees <30 y.o. 16.7% 16.0% Women 14.3% 29.9% Employees 30-50 y.o. 61.1% 67.4% Employees <30 y.o. 12.6% 8.3% Employees >50 y.o. 22.2% 16.6% Employees 30-50 y.o. 60.5% 67.3% Employees from ethnic minorities 1.3% 0.4% Employees >50 y.o. 27.3% 24.4% Employees with a disability (PWD) 0.2% 0.2% Employees from ethnic minorities 2.0% 0.6% Employees with a disability (PWD) 0.5% 0.8%

Executives: Breakdown according 2011 2012 to special indicators of diversity Technical & Labour personnel: Men 85.7% 85.6% Breakdown according to special 2011 2012 indicators of diversity Women 14.3% 14.4% Men 98.2% 98.0% Employees <30 y.o. 6.9% 8.6% Women 1.8% 2.0% Employees 30-50 y.o. 61.1% 64.6% Employees >50 y.o. 32.0% 26.8% Employees <30 y.o. 21.5% 19.2% Employees from ethnic minorities 0.0% 0.0% Employees 30-50 y.o. 61.6% 68.2% Employees >50 y.o. 16.9% 12.6% Employees from ethnic minorities 1.0% 0.1% Personnel breakdown according to special 2012 indicators of diversity, by gender Employees with a disability (PWD) 0.0% 0.2% Employees with a disability (PWD) 0.1% Men 0.1% Women 0.0% Board members of Group companies: Breakdown by gender and breakdown 2011 2012 Employees <30 y.o. 16.1% according to special indicators of diversity Men 12.7% Women 3.4% Men 97.1% 95.0% Employees 30-50 y.o. 67.4% Women 2.9% 5.0% Men 58.8% Women 8.6% Board members <30 y.o. 0.0% 0.0% Employees >50 y.o. 16.6% Board members 30 - 50 y.o. 2.9% 12.5% Men 15.1% Board members >50 y.o. 97.1% 87.5% Women 1.5% Employees from ethnic minorities 0.4% Board members from ethnic minorities 0.0% 0.0% Men 0.3% Board members with a disability (PWD) 0.0% 0.0% Women 0.1%

51 7.3 Freedom of Association

In MYTILINEOS Group, we guarantee guarantee the continuation of their ac- to all our employees, without excep- quired rights and their improvement in METKA S.A. fully respects the right tion, the right to assemble and asso- terms of quality and quantity. During of its employees to participate in ciate and to collective negotiations. In 2012, no reports were made of inci- trade unions or other representative this context, all our subsidiaries recog- dents involving a violation of the free bodies. There is one official em- nise the trade union rights of em- “trade union right” of employees by ployee Union in operation at the ployees, i.e. their right to establish the Human Resources Divisions of our company, as well as a company-level agreement currently in force, which Unions, to participate in them and to companies, which are responsible for was the product of collective nego- enter into collective negotiations. The handling such incidents and for taking tiations between the Union and the purpose of the employee unions in the appropriate action in collaboration company, are more favourable for Group Companies is to safeguard the with the Employee Unions, where employees than the corresponding interests (financial, work-related and in- these exist. provisions under the labour legisla- surance-related) of employees and to tion in force.

52 7.4 Child Labour proach of the abovementioned laws, an association with any supplier or con- their enforcement in practice faces sig- tractor known to operate using un- The key activities of MYTILINEOS Group nificant difficulty. The major hindrance lawful practices that encourage, con- take place in the territory of Greece. that dampens the effectiveness of done or cover up incidents of child The Greek legislation in force includes their enforcement are the long delays labour. a number of legislative initiatives to in the procedure for the hearing of rel- protect the employment of minors, In addition, the risk of occurrence of in- evant cases by the Courts, which such as: The ratification of the UNICEF cidents of child labour is also ad- varies from one to two years at the very Convention on the Rights of the Child dressed by the rigorous personnel se-

least. As a result, employed minors in SUSTAINABILITY REPORT 2012 (Law 2101/1992), on the definition of lection procedure that our Group Greece are left exposed to all kinds of companies have in place. The Human child labour; the ratification of the Con- exploitation and pressures. The figures Resources Divisions of all our compa- vention182 of the International Labour on child labour in Greece, which NGOs nies monitor closely all such occur- Organisation (ILO) concerning the pro- and International Organisations re- rences and take appropriate action as hibition and immediate action for the lease based on an growing corpus of required, in consultation with the Top elimination of the worst forms of evidence, paint a disheartening picture. child labour (Law 2918/0011); the Management of the respective Group In this context, as a responsible cor- adoption of Law 1837/1989 on the company and in collaboration with the porate citizen, we recognise our share Executives of the company’s Manage- protection of minors from employ- of the responsibility to play a part in the ment hierarchy and the representatives ment, which includes an article on the efforts to limit this phenomenon and of employee unions, where these ex- protection of employed minors under we are committed to the principles of ist. Law 3144/2003 (“Social dialogue for the UN Global Compact which refer to the promotion of employment and so- Through our subsidiary METKA S.A., the effective abolition of child labour. cial protection”), as well as a reference active in construction and EPC Projects, We also declare that we oppose the to minors who are victims of human we operate business units in geo- unlawful use of child labour and the ex- graphical regions which are considered trafficking under the relevant Law ploitation of children. Furthermore, it to present a higher risk of occurrence 3064/2002. is our standing policy to carry out pri- of incidents involving child labour. In However, despite the rigorous ap- or checks and to refuse to enter into these specific regions, METKA S.A. takes all necessary steps to ensure compliance with the provisions of the laws prohibiting child labour, by means of its internal regulations and Profes- sional Ethics Code, which reflect the business ethics and values that apply to all employees. In parallel, the company requires its Managers and Senior Executives to undertake a binding commitment to adopt fully and defend these principles and to adhere to the applicable legal framework, while all the contracts and agreements that the company concludes with its business partners contain clauses on the mandatory compliance with the applicable national laws, rules and regulations, in order to rule out all likelihood of incidents involving child labour or the employment of young contracted personnel in hazardous work. Finally, during 2012 no reports were made of incidents of child labour in the Group companies and in their principal associates.

53 7.5 Forced Labour gions. In these regions, METKA S.A. for Human Rights, to the prohibition takes all necessary steps to ensure of forced labour, and to the company’s The Constitution of Greece (art. 22 compliance with the provisions of right to request the audit of its Sup- par. 4) establishes in principle the the laws prohibiting forced labour by pliers and Subcontractors by official In- freedom of labour, through the pro- means of its internal regulations and ternational Organisations for ensuring hibition of forced or compulsory Professional Ethics Code, which reflect compliance with the requirements labour. No person can be forced to units commitment to the protection of on the protection of Human Rights. dertake work in general or specifical- Human Rights. In parallel, the com- Furthermore, the company’s supervi- ly. Any form of compulsory work is pany requires its Senior Executives to sors at its construction sites and prohibited. undertake a binding commitment to plants are carrying out constant checks In MYTILINEOS Group, we oppose all check and deal immediately with any of its subcontractors for adherence to forms of forced or compulsory labour, conditions which may encourage the law and compliance with the as we first and foremost believe that forced labour, while all the contracts contractual terms, to eliminate all coercion against the will of any person and agreements that the company likelihood of incidents of forced labour, who is working, relegates that person concludes with its business partners while the company itself is subject to to a means of achieving profit and (Suppliers – Subcontractors) contain supervision and to regular Quality, constitutes a violation of that person’s clauses on the mandatory compli- Health & Safety and contractual com- dignity. ance with the applicable national pliance audits, conducted by inde- The business activities of our Group in laws, rules and regulations, in order to pendent organisations in connection the construction of power plants, rule out all likelihood of incidents in- with all the projects it undertakes. Fi- through its subsidiary METKA S.A., are volving any form of forced labour. nally, during 2012 no reports were considered to present a higher risk of Where a Code of Conduct on Human made of incidents of forced labour in occurrence of incidents of forced Rights forms part of a contract, spe- the Group companies and in their prin- labour in certain geographical re- cific reference is made to the respect cipal associates.

54 8. ENVIRONMENTAL PROTECTION SUSTAINABILITY REPORT 2012

In 2012 our total expenditures 8.1 Environmental Footprint of MYTILINEOS Group related to the implementation of the Group’s environmental policy stood The respect for the environment has mental conscience cross all our sub- at more than been a core value of MYTILINEOS sidiaries, through relevant education Group since its very establishment. Our and training activities. €10 million. Group seeks to mitigate the impact of In line with the above, in 2012 we in- its activities on the environment, by fol- troduced and applied a specific pro- lowing closely the developments in en- cedure to determine the key environ- vironmental technologies and practices mental issues which are of concern to and by applying the best available tech- us, with the participation of the CSR niques. The environmental protection teams of all our subsidiaries. The results 100% of our business and industrial hazard control policies units have in place Environmental of this exercise, shown in the table be- that we have in place form the basis of Management Systems certified in low and accompanied by clarifications accordance with the ISO 14001 a comprehensive and effective system and references to the corresponding international standard. of Environmental Management rules, actions, represent our Group’s Envi- which we aim to gradually integrate in- ronmental Footprint, published here for to our business activities and into the the first time. This procedure will be ap- procedures that define the daily op- plied annually and its results will be pre- eration of all Group companies. In this sented in a dedicated section of our In our aluminium production sector, context, during 2012 we completed we achieved a specific energy Sustainability Report, so that any the implementation of the ISO 14001 consumption of changes or deviations – positive or neg- International Standard procedures in ative– in our environmental perform- 13.255kwh/t our subsidiary PROTERGIA S.A., which ance are immediately visible to our - one of the best in all aluminium subsequently obtained the respective Stakeholders. processing plants. certification. This development marked the suc- cessful attainment of our goal, which was to ensure that all our business units have in place ISO 14001-certified We have already restored Environmental Management Systems. Additionally, to further enhance our en- of all areas affected by 85% vironmental performance, we are fo- our mining activity. cusing on knowledge acquisition, net- working and collaboration with environmental organisations in order to develop new policies and adapt existing systems, such as for example to develop a system for measuring greenhouse gas emissions at the Group level. We are also continuing with our efforts to foster a uniform environ-

55 MYTILINEOS GROUP ENVIRONMENTAL FOOTPRING 2012

IMPACT LEVEL ENVIRONMENTAL FOOTPRINT Insignificant Limited Moderate Significant Very COMPONENTS No impact significant (0) impact impact impact impact impact (1) (2) (3) (4) (5) 1. Compliance with environmental laws and regulations Performance: 0/5

2. Consumption of raw materials Performance: 4,3/5

3. Control of greenhouse gas emissions:: (CO2), (CH4), (N2O), Performance: 3/5 (HFCs), (PFCs), (SF6) 4. Other significant air emissions: (Νοx), (SΟx), (VOC), (HAP) Performance: 2/5 Chimney emissions and Particles

5. Energy consumption Performance: 3,5/5

6. Waste management Performance: 3,5/5

7. Water consumption in the company’s production activity. Performance: 2/5

8. Water consumption in the company’s buildings Performance: 4/5 9. Spills of hazardous substances (oil, fuels, waste or chemicals) Performance: 1/5 in the soil and in the water

10. Impacts on Biodiversity Performance: 1/5

11. Rehabilitation of the natural landscape Performance: 1/5

1. All Group companies comply fully with the envi- 2. The percentage of the use of recycled or renew- ronmental laws and regulations. able materials as input materials to the production processes of the Group, thus helping reduce demand for raw materials and conserve mineral resources, ranges from 11% to 30%. NOTE: This performance refers to all Group subsidiaries except PROTERGIA S.A., whose electricity production plants use as raw material natural gas, which cannot be recycled and is not a renewable source. ACTION PLAN: To carry out a study on the use in the production processes of our companies of recycled or renewable materials, thus helping reduce demand for raw materials and conserve mineral resources, at a percentage ranging from 31% to 50%.

56 3. The Group has identified partly the greenhouse 4. The Group has set targets for the reduction of sig- gas [GHG] emission sources of its activities and has nificant air emissions and dust from its activities, calculated the corresponding emissions, which it dis- which also include the corresponding actions for closes in its Sustainability Report. NOTES: (a) PROTERGIA achieving these targets. NOTES: (a) The electricity pro- S.A. operates gas-fired, state-of-the art high-efficien- duction plants of PROTERGIA S.A. only produce NΟx cy power plants, which are more environment-friend- (as NO2) and not SO2 and particles. In full compliance ly than other conventional electricity production with the applicable environmental terms, the ΝΟ2 emis- plants. Taking into account the primary objective, which sions of the company’s plants are significantly lower

is the production of electricity, and the fact that these than the limits allowed by the law. (b): For METKA S.A. SUSTAINABILITY REPORT 2012 plants are governed by and operate using Best Avail- and MYTILINEOS HOLDINGS S.A., the results of the able Techniques (BATs), the reduction of CO2 emissions company-level activity regarding other significant air is not feasible. In addition, from 2013 onwards the com- emissions and dust have not yet been investigated. pany will have to incur significant expenditures for the ACTION PLAN: purchase of CO2 emissions trading rights for the Group’s Initially a direct identification at the construction sec- total emissions. (b): For METKA S.A. and MYTILINEOS tor, as well as a report from the mining activity, of HOLDINGS S.A., the results of the company-level ac- all sources of significant air emissions and of their tivity regarding CO2 emissions have not yet been in- calculation. Setting targets for the reduction of di- vestigated. rect and indirect significant air emissions and dust ACTION PLAN: at the Group level, and specifying the corresponding To gradually identify all CO2 emission sources at actions for achieving these targets. Group-level and calculate the corresponding emissions. To set targets for the reduction of direct and indirect CO2 emissions at Group level and to spec- ify the corresponding actions for achieving these targets.

6. The percentage of the Group’s waste which can 5. The Group has identified the direct and indirect be recycled, reused/utilized, exchanged or recov- energy consumption sources of its activities and has ered ranges from 10% to 30%, while the percentage calculated the corresponding consumptions, which it of the Group’s waste which can be disposed of in land- discloses in its Sustainability Report. Nevertheless, of- fills, at sea or by means of any other method used by ficial targets for energy savings have not yet been de- its companies ranges from 70% to 89%. NOTE: This per- termined at Group level. formance refers to our mining and aluminium pro- ACTION PLAN: duction activities, which account for around 98% of To establish and gradually incorporate targets for en- the Group’s total quantity of waste. ergy savings through (a) process reengineering in the ACTION PLAN: departments of the Group companies, e.g. in pro- Carry out a study on the reduction of the disposal in duction; (b) equipment conversion and refurbish- landfills to a percentage ranging from 10% to 30% ment; and (c) changes in the behaviour of our sub- of the total waste from the mining and aluminium sidiaries’ personnel, together with the corresponding production activities. actions for achieving these targets.

57 7. It has been proved that the consumption of water 8. Group's total water consumption is around 6m3 by the activities of the Group companies does not to 7.5m3 per person annually. The goal is to limit affect aquifer levels or the quantity of the water avail- this consumption initially to 4.5m3 to 6m3 per person able for use or the capability of an ecosystem to func- annually. NOTE: DELPHI-DISTOMON has already tion. Irrespective of this fact, however, PROTERGIA S.A. achieved its desired water consumption level, which is and DELPHI-DISTOMON have not yet determined tar- <1.5m3 per person annually. gets and related actions for water savings in their pro- ACTION PLAN: duction processes. To take action at company-level with the aim of ACTION PLAN: achieving a consumption level for potable water in Establishment and gradual incorporation of targets the range of 4.5m3 to 6m3 per person annually. and proposals for continuous improvement in the Group companies, focusing on the achievement of the highest possible conservation and on the reuse 10. of water in their production processes. The locations of the Group’s business activities do not form part of any area protected by law or designated as an area of high biodiversity value. Never- theless, the activities of PROTERGIA S.A. at local level result in a minimal disturbance to the existing flora 9. Incidents at the level of facilities, involving main- and fauna, and the company has developed and ap- ly the spillage of lubricants in the soil in under- plied special rehabilitation studies and has also carried ground tunnels, due to the breakdown of machinery. out environmental development projects (Environmental These incidents were of a limited extent and their im- parks etc.). Additionally, a more thorough study is re- pact was reversible. NB: This performance refers only quired to accurately assess the impacts on biodiversi- to the Group’s mining and aluminium production ac- ty of the disposal of bauxite residues on land by tivities. ALUMINIUM S.A. ACTION PLAN: ACTION PLAN: DELPHI-DISTOMON S.A. has already set a target for No deviation from the policy of PROTERGIA S.A. As reduction of the number of incidents involving spills, a result of our efforts for full compliance of the com- to be achieved primarily by informing the compa- pany’s production plants with the environmental ny’s contractors of the need for better maintenance rules and regulations in force, disturbance to the lo- of their machinery or for its replacement with new- cal flora and fauna is negligible. ALUMINIUM S.A. to er-technology equipment, where required. explore the possibility for a study on the impacts on biodiversity of its disposal of bauxite residues on land.

11. Since the launch of the Group’s business activity, 80% to 100% of the areas affected have been fully rehabilitated. ACTION PLAN: No deviation from our policy. We are continuing with the rehabilitation of affected areas, with respect to the natural environment and with a view to minimising the impact of our activities on biodiversity.

58 8.2 Management of raw & other materials

Our efforts regarding the rational mineral resources and reduce total op- which cannot be recycled and is not management of raw and other ma- erating costs in our Group. Today, the a renewable source. terials focus on the identification and percentage of the use of alternative During 2012, a total of 2.37 million specification of suitable methods, raw materials in MYTILINEOS Group, tons of raw and other materials were which will allow our subsidiaries to al- especially in aluminium production used to produce the Group's end so use recycled materials in process- and in construction, does not exceed products, down by 5.2% from the ing and manufacturing of their prod- 20%. quantity used last year. The largest part SUSTAINABILITY REPORT 2012 ucts. The maximum possible use of re- On the other hand, a particularity of of this quantity came from the mining cycled materials in our production the Energy sector is that the raw ma- activity and involved the consumption processes will help reduce demand for terial used to drive our electricity of bauxite in aluminium production. virgin materials, maintain the level of production plants is natural gas,

Raw materials 2011 2012 Change

Bauxite (t) 1,816,912.0 1,745,940.7 -3.9% Limestone (t) 118,579.0 54,363.0 -54.1% Anhydrous alumina for electrolysis (t) 317,082.0 317,911.7 +0.3% Other metals from third parties (t) 3,194.0 291.9 -90.8% Alloys (t) 145.0 157.5 +8.3% Oil - fuels (lt) 1,247,706.0 1,319,134.0 +5.7% Petrol – fuels (lt) 36,351.0 33,949.0 -6.6% Electricity (kWh) 3,791,533.0 3,440,762.0 -9.2% Natural gas (TJ) 7,671.6 27,160.3 +254.0%

Materials used but not incorporated in the end product 2011 2012 Change

Caustic soda (new soda) (t) 26,293.0 25,451.0 -3.2% Calcium oxide (lime) (t) 66,760.0 66,397.0 -0.5% Lubricants (t) 102.0 117.4 +15.0% Tar (t) 14,578.0 15,000.3 +2.9% Coke (t) 65,336.0 75,038.5 +14.8% Aluminium fluoride (t) 2,644.0 3,182.0 +20.3% Baked anodes consumed in the electrolysis process (t) 68,972.0 70,193.1 +1.8% Mineral oil (t) 1.9 1.7 -10.5% Liquid coolant (t) 3.9 3.6 -7.7% Oxygen (t) 193.0 118.0 -38.8% Acetylene (t) 4.9 4.1 -16.3% Carbon dioxide (t) 24.0 27.9 +16.2% Argon & Nitrogen (t) 76.0 76.8 +1.0% Lubricating oils (t) 12.7 12.1 -5.0%

59 Semi-finished goods or parts (other than raw materials) 2011 2012 Change that form part of the end product Paints (t) 8,733.0 6,056.0 -30.6% Welding materials (t) 17.6 15.6 -11.3% Special materials for projects (pcs) 13,570.0 8,995.0 -33.7% Connection material (bolts, nuts etc.) (pcs) 35,094.0 33,142.0 -5.5%

Packaging materials 2011 2012 Change

Pine planks (lt) 1,028.0 919.4 -10.6% Polyester rings (t) 27.0 14.7 -45.5% Wood for packaging ς (m3) 3.0 2.0 -33.3% Tarpaulin (m2) 3,163.0 3,322.0 +5.0%

Materials directly used, by weight or volume 2011 2012 Change (for materials incorporated in the end product) Bauxite (t) 1,816,912.0 1,745,940.7 -3.9% Alumina (t) 317,082.0 317,911.7 +0.3% Steel, in plates or merchant bars (t) 850.0 669.0 -21.2%

60 8.3 Energy consumption Total consumption of direct energy per company in TJ Aluminium production and electricity production are our two most energy- 28.648,2 intensive activities, accounting for 50% and 49%, respectively,of the Group’sto- 21,8 tal consumption of direct primary energy in 2012. The group’s total energy consumption increased by approximately 70,2 48,4 116% compared to 2011, driven pri- SUSTAINABILITY REPORT 2012 marily by the full operation of the pow- G ALUMINIUM S.A. er production plant of PROTERGIA S.A. 27.599,1 G PROTERGIA S.A. in Ag. Nikolaos (Viotia) throughout G DELPHI-DISTOMON S.A. 2012 and the launch of the commercial G ΜΕΤΚΑ S.A. operation of the company’s power production plant in Ag. Theodoroi (Korithia) Total consumption of direct in April 2012. 2011 2012 primary energy (TJ) Total direct energy consumption* 26,092.3 56,317.5

* Total direct energy consumption = direct primary energy purchased + direct primary energy produced – direct primary energy sold (exported).

The quantity of energy purchased Total consumption of primary energy purchased: 41,584.7 Tj and used by the Group in 2012 came exclusively from non-renewable 39.023,6 sources and increased by approxi- 40.000,00 G Natural Gas mately 60%, as extensive use was G Fuel Oil made of natural gas, as the primary fu- 30.000,00 G Diesel oil el in the production processes of all (Transport, Heating, DBF) Group companies. G Petrol 20.000,00

10.000,00 2.457,5 92,3 11,3 0,00

The energy produced by the Group in- Total primary energy produced: 32,022.8 Tj creased by approximately 622%, driven primarily by the quantities con- 14.354,2 Energy from fuels (natural 15.000,0 13.472,0 G tributed by the consumption of fuels gas, fuel oil, diesel oil, petrol) and the High-Efficiency Combined G Energy produced from IPPs 12.000,0 Heat and Power (CHP) Plant of G Energy produced from the ALUMINIUM S.A., as well as by the op- CHP Plant 9.000,0 eration of the power production plants G Energy produced from RES of PROTERGIA S.A. It should be not- plants ed that the energy produced from RES 6.000,0 3,810.2 plants accounted for 2.8% of the Group’s total energy production. 3.000,0 386,4 0,0

61 The Group’s energy exports increased Total primary energy exports: 17,290 Tj by approximately 322% from 2011. Of the total energy exported by the 15.000,0 Group, 75% was contributed by the 13.033,2 G Exports of energy from IPPs combined-cycle IPPs of PROTERGIA G Injection of electricity from S.A. to the Greek wholesale electric- 12.000,0 the CHP Plant into the ity markets, and 22% represented national grid electricity produced by all thermal 9.000,0 G Exports of energy from RES plants and RES plants and injected into the Greek National Grid. 6.000,0 3.870,4

3.000,0 386,4 0,0

In addition, during 2012 our sub- Total Consumption of secondary energy from sidiaries consumed in total 13,096 TJ non-renewable energy sources: 13,093.6 Tj of secondary energy, about the same as last year. Of this total quantity, 99% 10,000 9,282.2 came from non-renewable sources, G Electricity namely electricity (71%) and steam 8,000 G Steam (28%). G Petrol At the level of the individual Group 6,000 companies, electricity consumption 3.810,2 posted a significant increase in the con- 4,000 struction sites of METKA S.A., primarily as a result of “hot tests” and of the 2,000 trial operation under full load of the fa- 1,2 cilities (power plants) whose construc- 0,0 tion the company had undertaken.

62 Total Consumption of Secondary energy from Renewable energy sources: 3,3 Tj

10,000 G Solar 8,000 G Hydropower

6,000 SUSTAINABILITY REPORT 2012 4,000 2,1 2,000 1,2

0,0

During 2012 the company continued its systematic efforts for energy The company’s initiatives for en- conservation, through initiatives ergy conservation (work quality The operation of the company’s which include the reengineering of checks, daily and weekly checks of Gas - fired Combined Cycle Thermal processes, the introduction of au- alumina quality, mobilisation-sen- power plants is based on Best Avail- tomations and the refurbishment of sitisation of the personnel in- able Techniques (BATs). The com- equipment in its production depart- volved, optimisation of parame- pany’s goal is to achieve the maxi- ments. The implementation of these ters, swift identification of mum possible efficiency and initiatives resulted in 1.22 TJ of en- problem-prone basins, improve- availability rates for its power pro- ergy savings in total, up by approx- ments in equipment and meth- duction plants and to maintain imately 336% from last year. ods), resulted in a specific con- these throughout the year. sumption of 13,255kWh/t – one of the best among all aluminium plants.

63 8.4 Water consumption consumption of water by all other ac- the Sterea Regional Administration. tivities. The water required for Total water consumption for the ac- Of the above total quantity of water tivities of MYTILINEOS Group in 2012 aluminium production is obtained consumed, 96% was drawn from stood at around 4.6 million m3 of wa- from wells drilled and managed by groundwater and 6.2% from the mu- ter, down 1.6% from 2011, with ALUMINIUM S.A. in the broader re- nicipal water supply company, 1.5% 95% of this total quantity consumed gion around its plant, in strict com- refers to seawater used in the desali- by our industrial production activities, pliance with the provisions of the rel- nation process, and the remaining namely aluminium production, and evant Decision of the Water Re- 0.3% representing rainwater quanti- the remaining 5% accounting for the sources Management Directorate of ties collected for consumption.

2012: Group's Total water consumption: 4,607,341.5 m3

I 3.28% I 0.25% I1.04% I 0.03% I MYTILINEOS S.A. I ALUMINIUM S.A. I ΜΕΤΚΑ S.A. I PROTERGIA S.A. I DELPHI-DISTOMON S.A.

I 95.40%

Total water consumption by source (m3) 2010 2011 2012

Total water consumption. 4,640,581.8 4,685,049.1 4,607,341.5 Groundwater. 4,362,530.0 4,486,616.0 4,244,006.0 Rainwater collected directly and stored. 6,000.0 6,000.0 9,340.0 Surface water, including water from wetlands, 66,403.0 rivers, lakes and seas.

Municipal water reserves or other public water supply companies. 251,610 192,433.1 287,592.5

Water recycled and reused (m3) 2010 2011 2012

Total volume of water recycled. 2,000.0 2,000.0 5,340.0

Volume of water reused as a percentage of the Group’s 0.043% 0.042% 0.11% total water consumption.

The areas from which the Group perts as particularly sensitive, be- companies draw water (especially cause they support a specific endan- ALUMINIUM S.A., which has drilled gered plant or animal species or be- On our Website: and is using a network of wells in the cause they are located in any other -Our policy and systematic actions area around its plant facilities), do not area as a protected area. regarding the management of water consumption contain water masses regarded by ex-

64 8.5 Emissions and further reduce these emissions. The increase of direct CO2 emissions observed in 2012 is due to the emis- CO2 emissions During 2012, our target regarding the disclosure of the Group’s total carbon sions from the Combined Heat and The production processes in all the ac- dioxide emissions was not achieved. Power Plant (CHP) of ALUMINIUM tivity sectors of MYTILINEOS Group re- The relevant results, shown in the S.A., as a result of its consumption of sult in air emissions. These emissions graphs that follow, refer to 60% and natural gas, which was not used in are under the law subject to specific 20% of our subsidiaries for the dis- 2011, and to the operation of the limits, to which the Group fully con- closure of direct and indirect CO2 two power production plants of

forms. SUSTAINABILITY REPORT 2012 emissions, respectively, and to 40% of PROTERGIA S.A. – the Ag. Nikolaos As part of our efforts to address the the Group companies for the disclo- Plant (Viotia), which was in operation issue of Climate Change, we remain sure of other significant greenhouse for entire year, and the Ag. Theodor- committed to our goal to identify the gas emissions. As a result, specific oi Plant (Korinthos), which entered in- carbon dioxide (CO2) emission sources quantitative targets for their overall re- to commercial operation in April in all our subsidiaries and to measure duction cannot be set for next year. 2012.

Direct and Indirect CO2 emissions

5,000,000 4,688,410

4,000,000

3,026,444 3,000,000 2,490,643 2,503,169 2,185,241 2,000,000

1,000,000 535,801

0 2011 2012

G Direct greenhouse gas emissions for all sources owned or controlled by the company. G Indirect greenhouse gas emissions from the production of purchased electricity, heat or stream. G Total greenhouse gas emissions (direct + indirect).

Methods for the calculation of direct and indirect CO2 emissions

In the Metallurgy sector (aluminium production): In the Energy sector: Emissions from fuel oil burning are calculated in accordance with the The methodology for the calculation of carbon dioxide emissions is based provisions of Decision 2007/589/EC (Annex II), using a national emis- on calculations in accordance with the stipulations of Annex IV of Di- sion factor and the corresponding Net Calorific Value (NCV). Emissions rective 2003/87/EC and the provisions of Decision 2007/589/EC. Emis- from the lime production process are also calculated in accordance with sions from source flows are determined based on activity data obtained the same Decision (Annex VIII). Emissions from the anodes baking and with the help of measurement systems and on additional parameters consumption processes are calculated using the formulas of the IPCC resulting from laboratory analyses or standard emission factors. guidelines, as these were adopted by the Implementing Regulation 2011/540/EC. For calculating indirect carbon dioxide emissions, a conversion factor of 0.85 was used (i.e.: electricity consumption in kWh*0.85). More specifically, the factor used for 2011 was 0.85 t CO2/MWh. This factor is weighted for the contribution from each type of energy source.

65 Other significant air emissions (ton)

5,000 4,330.5

4,000 3,553.9

3,000 G 2011 G 2012

2,000 1,444.5 1,023.0 1,000

222.9 239.2 157.7 16.1 2.7 57.7 19.2 5.1 7.4 110.1 0

Nox Sox N20 CH4 Fluoride PFC’s Particles emissions

Calculation methods for ΝΟx, SOx and Dust emissions

In the Metallurgy sector (aluminium production): C. SO2: Α. Dust: Annual sulphur dioxide emissions refer only to fuel consumption Dust concentration in the plant’s point emission sources is meas- (fuel oil) and are calculated based on its sulphur content as this is ured as follows: (a) By isokinetic sampling, with a frequency of four shown on the chemical analysis sheets. Sulphur dioxide emissions samplings per year at the plant’s Α070, FLN, H15, H1, H28 chim- from the anodes baking process are not calculated (no verifiable neys; (b) using continuous measurement analysers at the anodes method is available). kiln, revolving and static components and lime kiln furnaces; and In the Energy sector: (c) by isokinetic sampling, with monthly samplings at the no. 1-2 In the case of the power production plants of PROTERGIA S.A., be- and no.3-4 Gas Treatment Centres for the electrolysis gases. For cause of the quality of the consumed fuel (natural gas), no emis- calculating the quantities of annual emissions in tons, the following sion limit values apply for SO2 and particle emissions (in accordance were used: (a) For point sources where isokinetic sampling is used, with the Environmental Terms Approval Decisions in force for these the average of the four concentration values (in mg/Nm3) and of plants, and under the applicable Community and Greek law on air the flow rate (in Nm3/s); and (b) for point sources where contin- emissions from combustion plants). Consequently, emission limit uous measurement is used, the average of the daily concentration values only apply for NOx (in this particular case, NO2) with the fol- values (in mg/Nm3) and of the flow rate (in Nm3/s) from the iso- lowing acceptance limits: kinetic samplings of all years for which these are available. - 50 mg/Nm3 (on a dry basis with 15% Ο2), for operation with a load above 70%; Β. ΝΟx: - 75 mg/Nm3 (on a dry basis with 15% Ο2), for operation with a Annual emissions of nitrogen oxides refer only to fuel consump- load above 70% and with an annual total electrical efficiency above tion (fuel oil) and were calculated stoichiometrically, using an emis- 50%. sion factor of 5.363 g/kg of fuel (Guide to Energy Investments, Min- NOx levels are measured continuously by the plants’ CEMS and the values logged istry of Development, 2005). NOx emissions from processes are not are expressed in mg/Nm3. On the basis of inventory data, acceptance limits measured or calculated (no official method is available yet). were not exceeded.

Nevertheless, the environmental strat- next years. These include the follow- with ALUMINIUM S.A. already mak- egy of MYTILINEOS Group comprises ing: ing efforts to optimise the use of key initiatives that focus on improv- T The most extensive possible use of lime (purchase/production). ing our performance relating to green- natural gas as the primary fuel in- T In the Energy sector, PROTERGIA

house gas and CO2 emissions over the stead of oil in aluminium production, S.A. by selecting natural gas as the

66 primary fuel to produce electricity 8.6 Significant spills one for 2011. The company respond- and by using Combined Cycle Ther- ed immediately, dealing with the in- During 2012 a total of 27 incidents mal Power Plants (CCGTs) and High cidents and collecting the contami- were recorded in DELPHI-DISTOMON Efficiency Combined Heat and Pow- nated soil. No high or medium gravi- S.A. involving spillage in the soil in un- er (CHP/High Efficiency CHP) with a ty environmental pollution incidents derground tunnels, due to the break- total production capacity of 1,200 occurred and no incidents were re- down of machinery, of lubricants MW, which introduce Best Available ported involving the spillage of haz- weighing nearly 3.5 tons, a quantity re- ardous materials to the environment Techniques (BATs) and, because of duced by 30% from the corresponding by any other Group company.

their flexibility and high efficiency, SUSTAINABILITY REPORT 2012 contributes towards the reduction of greenhouse gas emissions. In Renewable Energy Sources, PROTERGIA S.A. is already producing electricity from Wind farms (36 MW in operation), Photovoltaic plants (11.5 MW in operation) and small Hydropower plants (6 MW in operation) and is developing a 1,400 MW portfolio of RES assets in various licensing stages. These investments will also substantially contribute to the efforts for achieving of the 20-20-20 target for Greece. 8.7 Waste management T Collection: During this stage, waste T In the EPC sector, METKA S.A. is are collected and loaded onto their The efforts to optimise the manage- planning to replace oil with natural ment and utilisation of our waste are transport means (usually a vehicle), gas as the fuel used in its Plants and based on the principles of waste min- for transport to a transfer station, Offices, to use company cars with imisation and proper disposal. The key treatment location or disposal area. new, low-emissions technology, and goals of MYTILINEOS Group are to re- T Transport: Refers to the stage to replace Freon in its refrigerating duce the quantity of waste disposed where waste is transported to a machinery with new technology in landfills and at sea, and to increase transfer station and from there to cooling agents. in parallel the use of recycling. the treatment location or disposal T We also intend to explore the In managing its solid waste, area. prospects regarding the application MYTILINEOS Group follows a clearly T Treatment/recovery: During this of the innovative Carbon Capture defined procedure with specific stages, stage, a variety of processes and and Storage (CCS) technology. summarised below: equipment are used to either utilise T Waste production: Refers to the waste itself by improving certain stage where certain types of solid characteristics or to obtain useful in- waste are designated as undesirable gredients/components or energy. and the decision is taken either to T Disposal: This stage refers to the fi- throw them away or to collect nal disposal of waste. them for disposing of them centrally. Sorting of materials for recycling or During 2012 we permanently dis- recovery takes place at this stage. continued the disposal of bauxite T On-site management (storage): residues at sea. The quantity of non- During this stage, the future of hazardous waste disposed through re- waste is decided. On-site storage is cycling increased by 35% from last of primary importance because of year, and the quantity of waste dis- aesthetic and public health reasons, patched to Landfills, primary from but also because of the financial cost aluminium production, increased by to the companies. 22%.

67 In more detail, for 2012 the types and quantities of the Group’s waste and the corresponding disposal methods are as follows:

Waste quantities from the Group's activities (ton) 2011 2012 Change

Hazardous waste 19,769.6 20,952.6 +6.0%

Non-hazardous waste 982,078.6 929,231.8 -5.4%

Waste quantities by disposal method (ton) 2011 2012 Change

Recycling / Recovery (paper & carton, plastic, wood packaging materials, aluminium, iron scrap, batteries, metals & metallic 3,182.1 4,957.7 +55.8% compounds)

Reuse / Reutilisation 88,430.3 28,295.2 -68.0% (primarily non-productive decalcification stock)

Incineration (or use as fuel) 5.0 28.5* +570.0% Disposal in landfill for Non-Hazardous Waste 681,077.9 832,028.0 +22.2% Disposal in landfill for Hazardous Waste 16,430.3 16,997.3 -5.4% Disposal in Uncontrolled Landfills (household waste) 8.0 6.0 +3.4%

Storage on-site (quarry aggregates disposed of in the quarry slopes 66,100.0 & old tyres)

Storage & oil separation (in third-party facilities) 529.0 345.1 -34.8%

Destruction (management of mud residue from the natural separation 352.0 31.5 -91.0% in mining site workshops)

Disposal at sea 212,061.0 Waste oil re-refining or other reuse of waste oil 81.7 152.2 +86.3% Exchange of waste 23.4

* Management of mud residue from the natural separation in mining site workshops in DELPHI-DISTOMON S.A.: The mud is packaged in metal barrels and dispatched to Germany for incineration through ENVIROCHEM S.A.

The company’s key initiatives for the utilisation of bauxite residues: • Operation of pilot unit for the utilisation of bauxite residues. • Production of the first quantities of cast iron, with tests in progress for stabilising production to commercial-grade specifications. • Waiting to purchase a spinning machine to utilise the residue (bauxite) in the production of stone wool. • Participation in research projects to investigate other forms of utilisation of bauxite residues.

On our Website: - Our policy regarding waste management

68 MYTILINEOS Waste Quantities Clarifications / Comments GROUP Companies 2012

TOTAL WASTE 948,660 ton The quantities of the company’s waste did not vary significantly compared to 2011. A major achievement for the company during 2012 was the permanent discontinuation of the disposal of 2% bauxite residues (red mud) at sea. 20% of all hazardous waste produced by the company are recycled. SUSTAINABILITY REPORT 2012

98%

TOTAL WASTE 1,413 ton The increase of the quantity of non-hazardous waste of METKA S.A. is primarily the result of the emphasis which was given on the provision of relevant information and training to employees, which increased their sensitisation, and to the 0.1% increase in the number of waste collection points in company facilities . 100% of all waste produced by the company are recycled. 99.9%

TOTAL WASTE 34.2 ton The significant increase of company's total waste arises from the commercial operation of two new power production plants during 2012. The company also produced 50,840m3 of liquid 37.4% waste, of which 3,340 m3 were recycled and the rest (47,500 m3) were delivered to the waste treatment plant of MOTOR OIL S.A. 100% of all waste produced by the company are recycled. 62.6%

TOTAL WASTE An increase by 72.9% of hazardous waste was 75.9 ton posted in the company, due to the existence of a stock of mud from natural separation (dating back to 2011), which was disposed through a certified organisation during 2012. Correspondingly, the 43% reduction of the quantity of non-hazardous waste (-27,5%) is due to the lower quantity of waste produced (tyres and scrap). 100% of all hazardous waste produced by the 57% company are recycled.

TOTAL WASTE 1.2 ton The company posted a reduction in the quantity of its waste (-71.5%), as a result of the reduced quantities of batteries and paper for recycling, given also that in 2011 these quantities had been significantly higher due to the clearance of 0.0% warehouses and archives and to the recycling of old paper files. 100% of all waste produced by the company are recycled. 100.0%

I Hazardous Waste - I Non-Hazardous Waste

69 8.8 Environmental expenditures

The total expenditures budgeted and posal areas for bauxite residues, the re- penditures for the installation of clean- carried out in 2012 in connection with habilitation of landfills for Hazardous er, more environmental-friendly tech- the implementation of the Group’s en- and for Non-Hazardous waste, the in- nology. The remaining €3.6 million or vironmental policy stood at €10.7 mil- stallation of the 3rd and 4th Filter Press- 32.3% of total expenditures were al- lion. This amount is reduced by around es for the treatment of bauxite residues, located to environmental manage- 17% from the corresponding amount and the conversion of fuel oil boilers in ment actions such as: Development and in 2011, due primarily to cuttings in the local settlement. application of quality control systems prevention and environmental man- In detail, the total amount for 2012 in- under the ISO 14001 International agement expenditures, a move made cludes €7.1 million of investments, Standard, independent certification of necessary by the increased level of ex- which correspond to 66.7% of the to- Environmental Management Systems, penditures during 2011 for the imple- tal expenditures and concern waste various chemical analyses carried out, mentation of new environmental pre- treatment and discharge, the treatment Research & Development, protection of vention projects in aluminium produc- of gas emissions (e.g. expenditures green areas, offices and facilities etc. tion, such as: the configuration of dis- for filters, active equipment), and ex-

MYTILINEOS Group – Environment Expenditures 2012. Total: € 10,722,197

2012 G Prevention and Environment management costs G Waste disposal, Gas emissions treatment and Rehabilitation costs

2011

0 2,000,000 4,000,000 6,000,000 8,000,000

Waste disposal, gas emissions treatment and rehabilitation costs. Total € 7,459,183

3.1% I Waste treatment and discharge 16.7% I Gas emissions treatment 35.4% (e.g. expenditures for filters, active equipment) 1.5% I Expenditures for the purchase and use of gas emissions certificates 4.4% I Depreciation of relevant equipment, operation-related materials and services, and personnel-related costs 0.1% I Environmental liability insurance I Cleaning costs, including spillage rehabilitation costs I Landscape rehabilitation (landscaping, fencing planting, watering-fertilizing) 38.9%

70 Prevention and environmental management costs. Total 3,263,014€

5.9% 21.1% 0.3% I Third-party services for environmental management 14.7% I Independent certification of Environmental Management Systems I Personnel for general Environmental Management activities 1.6% I Research & Development

I Additional expenditures for installation of “cleaner” technology SUSTAINABILITY REPORT 2012 (e.g. extra costs in addition to standard technology) I Other environmental management costs 56.3%

8.9 Biodiversity The conservation, protection and re- In the Metallurgy sector (aluminium mine the fluoride content of olive tree habilitation of biodiversity are core en- production), in addition to the estab- leaves, vine leaves and pine needles vironmental goals of MYTILINEOS lishment of an initial inventory of the (twice per year), as well as that of Group. To this end, we have ensured local flora and fauna, checks are car- grapes (once per year). that the facilities of our subsidiaries, es- ried out to monitor the quality of the Furthermore, the Group’s mining ac- pecially in raw materials mining, flora in the wider region, to the extent tivity for the production of aluminium aluminium production and construc- that this is introduced into the food may impact on the biodiversity of fau- tion, are not adjacent to areas pro- chain. The Company operates a net- na and flora. To mitigate this impact, tected by law and to areas of high bio- work of 28 stations for static meas- Environmental Impact assessments diversity value. Thus, there are no sig- urements of fluoride levels, located and rehabilitation plans have been de- nificant effects that may have an ad- within a radius of 0 to 12 km around veloped and are carried out for the ar- verse direct or indirect impact on the the ALUMINIUM S.A. plant. In addi- integrity of the area where the facili- tion, samplings take place and chem- eas affected. In more detail: ties of our companies are located. ical analyses are carried out to deter-

Locations where rehabilitation Rehabilitation Rehabilitation approved / work has been completed or Area percentage under approval by active protection measures are in km2 of the area independent specialist taken on 31.12.2012 organisations or scientists

VARTOS B 0.4 100% Amfissa Forest Department

PSILO KOTRONI 0.2 100% -

ACHLADES 1,12,14,15,16 – ANO 0.02 100% - KATO SOROS

PERA LAKKOS 0.02 100%

PROSOREMA 0.18 90% -

Rehabilitation of 2,500 sq.m. LIMESTONE QUARRY AREA with 1000 saplings planted, 0.018 - Metohi (Kyriaki municipality ) according to the usage of the quarry.

LANDFILL FOR HAZARDOUS WASTE Planting of 2500 plants - (Agios Athanasios) (~3,500 sq.m.).

71 The Energy sector presents certain par- company’s power production plants impacts, if any, are fully remedied ticularities, as according to the laws in currently in operation, only the wind based on specialised studies developed force on the protection of the envi- farm at Sidirokastro (Prefecture of and applied (rehabilitation planting ronment and of biodiversity, con- Serres), for which 0.12 km2 of land studies, ecological studies, ornitho- struction of power production plants was allocated, lies at a distance of 1.5 logical studies etc.). is allowed inside protected areas be- km from the outer boundary of the The table below summarises the im- longing to the NATURA 2000 Net- area proposed for inclusion in the pacts of our activity on biodiversity and work. The power plants (thermal and NATURA 2000 Network with code GR the management of these impacts in RES plants) of our subsidiary 126000, and of more than 15 km from the Metallurgy sector (aluminium pro- PROTERGIA S.A. are constructed and the Special Protection Area with code duction) and the Energy sector (elec- operated to the strictest technical GR 126008. It is an environmental- tricity production), through our sub- and operational standards, in full friendly power plant, with zero pollu- sidiaries ALUMINIUM S.A. and compliance with the applicable Com- tant emissions, zero soil and subsoil munity and national laws on the pro- pollution and negligible disturbance to PROTERGIA S.A., respectively. tection of biological diversity. From the the indigenous flora and fauna. Minor

Significant direct and indirect impacts on biodiversity

Significant direct and The disposal of bauxite residues on land (as Power plant producing electricity from wind indirect impacts on declared in the indicators for 2011) had a localised energy (Wind farm), located adjacent to an area biodiversity impact on biodiversity. As this particular practice protected by law, is environmental-friendly, with was not extended, impacts have not worsened any zero pollutant emissions, zero soil pollution and further. negligible disturbance of the local flora and fauna.

Management of impacts To address the impacts on biodiversity from the 1. The protection of biodiversity as an aspect of on biodiversity from the disposal of bauxite residues on land, the company the natural environment is expressed indirectly Group’s activities. takes measures to deal with dust emission, which in the company’s environmental policy. include the following: 2. Full compliance with the environmental 1. Scheduled maceration, particularly during the legislation in force, in the context of the summer or in general during low-humidity restrictions and special conditions imposed periods. regarding the operation of the company’s 2. Coverage of slopes with topsoil, after carrying thermal power plants and RES plants. out relevant technical studies. 3. It is pointed out that the environmental 3. Maintenance of the access roads already legislation also includes the legislative opened, to avoid new impacts from the instruments on the protection of the opening of new ones. environment, and the company's power plants 4. Launch of a large-scale water-engineering have been granted their operating licenses project to capture and retain rainwater within taking into consideration the protection of the area designated for the disposal of bauxite biodiversity. residues, so that it can be discharged in a 4. Development of additional specialised studies in controlled way without adverse impacts. regions where projects are carried out, even if these studies are not mandatory under the laws in force, in order to ensure the protection of biodiversity of the wider region. 5. Adoption of protection and rehabilitation measures through the operation of the company’s projects. 6. In its relations with the local communities where its projects are developed, the company implements compensatory actions, some of which focus on the protection of the natural environment and biodiversity.

72 Significant direct and indirect impacts on biodiversity

Construction or use of No change from 2011. Nil. plants, mines and transport infrastructures.

Pollution. No pollution incidents reported in the wider area Nil. of the plant facilities (including the areas for disposal of bauxite residues and of solid waste SUSTAINABILITY REPORT 2012 from the production process).

Introduction of invasive Does not apply to the company. Does not apply to the company. species, pests and pathogenic organisms.

Reduction of species. According to a recent study by the Hellenic Centre Nil. for Marine Research (HCMR), sea populations do not appear to have sustained significant changes compared to previous studies. For land populations, no studies have been carried out recently (the latest one has been included in the Environmental Impact Study (EIS) 2007.

Preservation of the natural No change from 2011. No change from 2011. habitat.

Changes in ecological None due to the company’s activities. Nil. processes outside the normal differentiation range.

Species affected. Has not been investigated. Flora / Fowl.

Size of areas affected. Has not been investigated. Outside Protection Zones.

Duration of impacts. Has not been investigated. Temporary.

Reversibility or irreversibility Has not been investigated. Fully reversible for flora / Nil for fowl after of impacts. the adoption of measures.

8.10 Compliance with environmental laws and regulations The strict adherence to the applicable tal Inspectors Service during 2012 were and no violations of environmental laws and regulations by the Group very positive, as no remarks were made rules and regulations were established. companies, the implementation of an environmental legislation review and up- dating procedure, and the application f all relevant regulations concerning the Group's activities, have resulted in the absence of sanctions (monetary or oth- erwise) for non-compliance with environmental provisions. Furthermore, the findings of the unannounced inspections and audits carried out in the Group companies by the Environmen-

73 9. SOCIAL COHESION ANDDEVELOPMENT

We have retained 9.1 Social Footprint of MYTILINEOS Group 2,000 uided by our values of “Socially key social development issues which jobs across the Group, despite Responsible Development” are of concern to us and through the adverse economic conditions G and “Gaining the trust of the which we feel that we can make an ac- in the country. society around us”, we continue our tive contribution. efforts to enhance our role as an ac- This procedure did not involve the tive corporate citizen in the local mere listing of issues, but instead communities on which our activities, was carried out by executives in our depending on their nature, have a pos- Our social investments subsidiaries who are members of the stood at itive or negative effect. Based on the respective CSR teams, with knowledge experience from our participation in so- and experience in the specific subject €740 thousand cial contribution initiatives and on promoting culture, sports and the positive messages that we receive, area, thus bringing significant added entrepreneurship, while also and with no intention of downplaying value to the task. The results of this ex- helping meet infrastructure needs the importance of potential omis- ercise, shown on the graph below and in the local communities. sions or of turning a blind eye to the accompanied by clarifications and ref- adverse impact of our activities, we are erences to the corresponding actions, convinced that our involvement in pro- represent the Group’s Social Foot- rd moting social cohesion can help print. It is our intention to make this We implemented for the 3 achieve prosperity for the local com- disclosure on an annual basis, so that consecutive year munities where we operate. In line any changes or deviations in our social the process of dialogue with with the above, in 2012 we considered performance can be immediately vis- our key Stakeholders that it was necessary to determine the ible to our Stakeholders. with positive results.

We have produced and are disclosing for the first time our Social Footprint.

74 MYTILINEOS GROUP SOCIAL FOOTPRINT 2012

IMPACT LEVEL SOCIAL Very FOOTPRINT Insignificant Limited Moderate Significant No impact significant COMPONENTS impact impact impact impact (0) impact (1) (2) (3) (4) (5)

1. Corporate image & reputation. Performance: 0,5/5 SUSTAINABILITY REPORT 2012

2. Legal & Regulatory Compliance. Performance: 0/5

3. Tax Compliance. Performance: 0/5

4. Dialogue with Stakeholders. Performance: 2/5

5. Employee Safety. Performance: 0,5/5

6. Employee Health. Performance: 0,5/5

7. Employee Satisfaction. Performance: 3/5

8. Employee Education & Training. Performance: 0,5/5

9. Employee Development. Performance: 1,25/5

10. Strengthening employability (recruitment from local Performance: 2/5 communities).

11. Investments to meet basic needs Performance: 0/5 in the life of local communities.

12. Preference for products and services from local suppliers and contribution to their Performance: 0,25/5 development.

13. Promotion of the right to health and avoidance of activities Performance: 0,75/5 posing a risk to public health.

14. Actions to combat corruption. Performance: 4/5

15. Actions to combat forced labour. Performance: 0/5

16. Actions to combat forced labour in the company’s principal Performance: 2/5 suppliers and associates.

17. Actions to combat child labour. Performance: 0/5

18. Actions to combat child labour in the company’s principal Performance: 2/5 suppliers and associates.

75 1. Limited complaints at the local level for ALUMINIUM 7. Employee satisfaction ranges from 60% to 70%. S.A. and PROTERGIA S.A. NOTE: This aggregate performance is a “guessti- ACTION PLAN: mate” based on the employee performance review Toeliminate complaints by incorporating the results of the process. ALUMINIUM S.A., PROTERGIA S.A. and consultations (Dialogue Forums) with our Stakeholders in METKA S.A. do not have in place a mechanism to reg- our Corporate, Social and Environmental strategy. ularly measure employee satisfaction. ACTION PLAN: To study and design a procedure for conducting regular employee satisfaction surveys in all our Group 2. All Group Companies comply fully with the reg- companies. Actions will be planned according to the ulations and the provisions of the law that govern results obtained. their operation.

3. The Group companies fulfil completely all their tax obligations, at local as well as at central level. 8. All Group companies have in place a formal education and training policy and carry out annual educational initiatives with clear objectives, which 4. Each Group company has defined its Stakehold- are aligned with their business activities and with their er groups and engages in regular dialogue with employees’ needs. them. The results of this consultation process are published annually. ACTION PLAN: To improve our educational objectives in order to ACTION PLAN: combine more effectively the employees' needs with (a) To improve and reconfigure the consultation the Group’s social and environmental objectives. process with our Stakeholders; (b) To include Human Rights Protection and the Actions to combat -Cor- ruption as subjects in the consultations with our Stakeholders; (c) To intensify our efforts for incorporating the results of the consultations with our Stakeholders in the development of the business, social and environmental plans of our subsidiaries. 9. The aggregate percentage of employees evaluated through the Career Development Review process applied by the Group companies’ ranges from 81% to 5. During 2012 a number of light accidents occurred, 90%. without interruption of work. NOTE: Two (2) ac- ACTION PLAN: cidents that led to interruption of work occurred in AL- To achieve a percentage in excess of 90% of em- IMINIUM S.A. ployees receiving Career Development Reviews, ACTION PLAN: through the systematic application of the procedures Although our performance is stable, constant efforts for Career Development Reviews which our sub- are required in accordance with our policy which focuses sidiaries have in place. on the achievement of the only acceptable target – “ZE- RO ACCIDENTS AND ZERO INCIDENTS RELATED TO OC- CUPATIONAL DISEASES IN OUR WORK AREAS”.

10. The aggregate percentage of employees re- 6. A very small number of light incidents related to cruited from the local communities where the occupational diseases occurred, without inter- Group companies operate ranges from 70% to ruption of work. 85%. ACTION PLAN: ACTION PLAN: Although our performance is stable, constant efforts No deviation from our policy on recruitment of em- are required in accordance with our policy which focuses ployees from our local communities, whose objec- on the achievement of the only acceptable target – “ZE- tive is to achieve a percentage in excess of 85% (al- RO ACCIDENTS AND ZERO INCIDENTS RELATED TO OC- ways taking into account the particular character- CUPATIONAL DISEASES IN OUR WORK AREAS”. istics of each one of our business activity sectors).

76 11. A common principle of all Group companies is to 15. All Group business units comply with the laws in cover their local communities’ basic needs in in- force. No incidents of forced or compulsory labour frastructures, always taking into account the particu- have occurred in any one of the Group’s subsidiaries. lar characteristics of each one of our business activity Nevertheless, there is a need for establishing a specific sectors (irrespective of the percentage of their total procedure that will allow the Group to formally audit turnover), thus helping their efforts for prosperity. its business units in this regard. SUSTAINABILITY REPORT 2012

12. The total contribution of the Group companies to 16. The Group companies have secured the com- local suppliers, expressed in terms of economic val- mitment of 31%-60% of their principal associates ue, ranges from 11% to 31% of the Group companies’ and suppliers to the adoption of measures to combat total purchases budget. NOTE: In meeting their needs, forced labour in their activities. ALUMINIUM S.A. and DELPHI-DISTOMON give priority to local suppliers (according to their needs and specif- ACTION PLAN: ic characteristics and irrespective of the corresponding To promote the principles of the UN Global Compact share of their total purchases budget), thus contribut- in our supply chain, in order to secure the commitment ing to the development of the local economy and to the of the Group’s principal associates and suppliers – at prosperity of the local community where they operate. a level between 60% and 90% – to the avoidance of practices which may encourage forced or compulso- ACTION PLAN: ry labour in their work environment. No deviation from our policy, whose objective is to gradually stabilise the share of outlays to local suppliers to a level between 40% and 50% of the total purchases budget (always taking into account the particular characteristics of each one of our business 17. All Group business units comply fully with the laws activity sectors). in force. No incidents of child labour have been reported.

13. The Group companies undertake, through the adoption of international and national standards 18. The Group companies have secured the com- that the stages of their products’ lifecycle and their ac- mitment of 31%-60% of their principal associates tivities in general do not pose risks to public health. and suppliers to the adoption of measures to combat ACTION PLAN (for all subsidiaries): child labour in their activities. To collaborate with NGOs and to implement vol- ACTION PLAN: untary initiatives for the prevention of serious dis- To promote the principles of the UN Global Compact eases (other than occupational ones), which will be in our supply chain, in order to secure the commit- addressed to their employees and to the citizens of ment of the Group’s principal associates and sup- the local communities where they operate. pliers – at a level between 60% and 90% – to the avoidance of practices which may encourage child labour in their work environment..

14. No incidents of corruption were reported in any of the Group’s subsidiaries. Nevertheless, the Group does not have in place a separate organisational unit responsible for the management of risks associated with corruption. ACTION PLAN: To establish collaborations with specialised organisations and to design a custom internal control mechanism that will allow us to formally audit our business units in this regard.

77 9.2 Participation in the development of local communities

With the aim of helping develop and benefits over and above the statu- fits to the local communities and to maintain social cohesion in the local tory ones and those provided under also contribute to the progress in the communities where our activities are agreements based on collective ne- achievement of national targets of a higher visibility, we have focused gotiations. (such as the 20-20-20 target under our efforts through our subsidiaries on the EU’s energy strategy). T The development of our local eco- areas which are directly related to our nomic activities: During 2012 near- activities. ly 30% of the purchases budget of More specifically, our efforts focus on our companies represented pay- the following: ments to local suppliers, but also ex- T The provision of jobs: With 2,000 penditures for the provision of jobs maintained and 374 new em- know-how and technical support to ployees recruited, in 2012 the num- Local Authorities and other local or- ber of employees coming from our ganisations. local communities reached 85% of T The added value generated by our our total workforce. business operation: In the Energy T The creation of income: Our a sys- Sector in particular, the development tem of employee compensations of projects based on Renewable takes into account the market situ- Energy Sources (RES) through our ation as well as the expectations of subsidiary PROTERGIA S.A. has al- employees, and is combined with lowed us to offer significant bene-

Environmental benefits from the Economic and Social benefits from the development of RES projects development of RES projects

T Significant reduction of the gas pollutants produced T Investments in “green growth” projects, which are key when using mineral fuels (lignite, coal, oil) and con- for Greece’s growth in the current economic juncture. tributing to Climate Change, by substituting the “fu- T Guaranteed income for the local communities from the el” used to produce electricity with air, water and so- operation of the RES projects. According to art. 7, par. lar energy. 3(A.3) of Law 3851/2010, the amounts corresponding T Virtually zero environmental disturbance (e.g. noise), to the special tax are withheld by the competent Op- minimal disruption to the natural ecosystem and pro- erator and paid as follows: tection of biodiversity (flora and fauna) in the wider - 1% is credited to the electricity bills of household con- area. sumers in the Local Authority; T Improvement of the existing road networks and routes - 1.7% to the Local Authority; in the wider area where the RES project is located. - 0.3% to the Special Fund for the Implementation of T During the final land allocation stage, the specific fea- Master Plans and Land Use Plans (ETERPS). tures of each site are taken into consideration, so that Stimulation of employment in the local communities the wind turbines will blend harmoniously with the T during construction and operation of the projects. landscape. T Revitalisation of economically and socially disadvan- T During the construction of RES projects, works are car- taged areas and contribution to local development ried out in an environmental-friendly manner and all through the promotion of similar investments, driven necessary measures are taken to ensure the rehabili- by the development of the RES project (promotion of tation of the site, not only during construction but – educational tourism for RES projects) and by the con- more importantly – during its operation, so that in its tributions from the project-owner companies in the final form the site is fully integrated into the natural context of their CSR policies. environment.

78 In accordance with the policy of projects in support of local communi- construction of Municipal buildings PROTERGIA S.A., a Memorandum of ties are implemented primarily during and facilities, in collaboration with Understanding (MoU) is concluded the construction stage of RES projects the Municipalities concerned and de- between the company and the local and can indicatively include the fol- pending on their needs. authorities regarding the implemen- lowing: T Creation of environmental parks tation of public benefit projects, in- T Donations to Municipalities towards and recreation areas adjacent to the frastructure works or cultural activities the purchase of vehicles and equip- company’s RES projects, so that the in the area concerned, aiming to im- ment required for the operation of site can become an Educational prove the quality of life of local resi- Municipal Services and for fire pro- Tourism attraction. SUSTAINABILITY REPORT 2012 dents, in consultation and collabora- tection. tion with the local Municipality and de- T Construction of infrastructure works pending on the latter’s needs, with the that will improve the life of the Mu- On our Website: local community stating its acceptance nicipality residents, such as road - Our Management Approach regarding our Local Communities of the RES project. Public benefit building or maintenance, repairs or

79 9.3 Social expenditures hard-hit by the financial and social cri- mote Entrepreneurship, our social pol- sis that Greece has been experiencing icy in 2012 – which in terms of expen- Our role in our local communities is pri- during the last years. Seeking to keep diture stood at around €740,000 – was marily determined by our desire – and, alive the ideals of Sports, Arts and Cul- expressed by all our subsidiaries and secondarily, by our capability – to help ture, to assist Non-Governmental Or- covered a diverse range of social issues, address and promote issues of concern ganisations in their work and to support as shown in the graphs below: for our local communities, which are for yet another year the efforts to pro-

MYTILINEOS Group – Social Expenditures 2012, by Group company. Total: € 741,607

Key sections Key actions • Donation of technical equip- • Repair and reformation of ment to one Lower Secondary the Rural Medical Station in School and one Upper Sec- Katsaroni (Evia). ondary School in the Munici- • Financial assistance for the pality of Patmos. needs of the Municipality of • Donation of clothing articles & Sintiki (Sidirokastro). toys for the Christmas Bazaar • Financial assistance to the of the "Friends of the Child” IFNA International Non-prof- Association. I MYTILINEOS S.A. it Educational Research 16% I PROTERGIA S.A. • Financial assistance for the 17% Organisation. “Dare to Lead” Executive Din- ner event organised by the ICAP Group. I METKA S.A. 34% Key actions I ALUMINIUM S.A. • Donation of equipment (PCs 30% to schools, prefabricated constructions, medical equip- Key actions 3% I DELPHI -DISTOMON S.A. ment). • Financial assistance to the • Support of the Social Grocery foundations of the Holy Me- Stores in the area of Volos tropolis of Thiva and Levadia. with food provisions. • Long-standing financial sup- Indicative actions • Long-standing assistance to port and assistance in kind • Financial assistance to the the ELEPAP organisation and (equipment and materials) of FOKIKOS Football Team and annual “financial adoption" the ASA and Medeon Sports of two children’s football of one child without health Clubs. academies. insurance from the 12 chil- • Exclusive sponsorship of the lit- • Financial assistance to the dren under ELEPAP’s care. erary magazine “Emvolimon" Amfissa and Itea voluntary • Financial support of the and of the events it organised blood donor societies. preparation of athletes for the in Aspra Spitia. • Provisioning and moral sup- London 2012 Olympic and • Technical support and dona- port for the establishment Paralympic Games. tion of materials to the schools and operation of the Social • The company was the Exclu- of the Municipality of Dis- Grocery Store of the Munic- sive Sponsor of the 13th Jun- tomon, Arachova and An- ipality of Delphi. ior Synchronised Swimming tikyra. Championships hosted in Vo- los.

80 MYTILINEOS Group – Social Expenditures 2012, by category of actions. Total: 741,607 €

6.7% 7.7% 33.5% I Sports I Arts & Culture

9.9% I Environment SUSTAINABILITY REPORT 2012 I Local Authorities I Education 7.1% I Strengthening Entrepreneurship I Support of NGOs 7.8% I Employees 14.0% I Donations 13.2% 0.1%

On our Website: - More details on the categories of our social actions

81 9.4 Actions to strengthen Transparency & combat bribery

Corruption, bribery and extortion un- Global Compact, according to which dures for the selection of suppliers and dermine the moral environment of “We work against corruption in all its other associates which our Purchases businesses and have a broad range of forms, including extortion and and Procurement Units have in place, negative effects, as they can result in bribery.” we check the conditions under which violations of Human Rights, in adverse Additionally, as the formal develop- every single transaction is carried out, impacts on the environment, in dis- ment of an internal control mechanism in order to identify and eliminate tortion of competition, and in im- for prevention and detection of inci- those which may give rise to incidents pediments to the distribution of dents of corruption or bribery has not of corruption, extortion or bribery. wealth and economic development. In yet been completed, we are taking During 2012, we applied all neces- general, they are a major hindrance to steps at the Group level to evaluate saryinternal procedures to ensure sustainable development, with a dis- and improve our risk management pro- compliance with the aforementioned proportionate impact on poor com- cedures and to verify the compliance principle. With regard to the above, no munities, and corrode the very fabric of our subsidiaries' operations with our reports were made of conditions of society. established policies and procedures, as which may give rise to incidents of cor- In MYTILINEOS Group, the references these are defined in our Code of Pro- ruption in the Group companies, nor for our efforts to promote trans- fessional Ethics, in the Internal Rules have such conditions been identified parency are the following two: Our of Operation of each individual com- in them. Nevertheless, our plans for the corporate value which refers to the pany, and in the laws and regulatory immediate future include the imple- Principle of Integrity in all transactions provisions in force. Furthermore, we mentation of concerted preventive and which is implemented by avoiding take care to ensure that the collabo- actions, including the provision of all transactions and contacts with rations and transactions of all share- specific training to our employees of any third party which may be guilty or holders and employees, in all Group all levels and the formal audit of our suspect of encouraging conditions companies, are characterised by a business units for the existence of con- giving rise to corruption, extortion or high level of integrity and by high ditions which may give rise to incidents bribery; and Principle 10 of the UN moral standards. Through the proce- of corruption, bribery or extortion.

82 10. FAIR MARKET PRACTICES SUSTAINABILITY REPORT 2012

10.1 Product Quality & Safety

The total contribution of the ll MYTILINEOS Group compa- Group complies fully with the relevant Group companies to local nies place particular emphasis on requirements. Clients have at their dis- suppliers, expressed in terms of Athe quality of the products they posal the tools allowing them to check economic value, stood at manufacture and of the services that all significant information which we they offer. The innovations which are ap- provide and to proceed to the corre- 30% of the Group plied in production processes and which sponding tests, if they wish so. In the companies’ total purchases improve the quality, safety and envi- EPC Projects Sector, METKA S.A. carries budget. ronmental impacts of the final product, out complex large-scale projects award- are considered to represent business op- ed as a result of competitive tender pro- portunities. Although in most cases the cedures, which are carried out by the clients of the Group are not the end Client and under which the prices of- users of its products, the Group’s poli- fered by the participants are compared. cy is to ensure that all the products it In all cases, the scope, responsibilities and of our business 100% places to the market will fully meet the commercial terms and conditions for the units have in place Quality statutory requirements and the expec- projects have been initially determined Management Systems certified in tations of the end users. by the client and, upon conclusion of the accordance with the ISO 9001 final negotiations, all specifications re- international standard. The strict compliance with the laws and regulations governing the manu- quired are agreed in writing as part of facture of products; the adherence to the project's contract. the principle that no product is signed off to the next production stage unless We are seeking to ensure the quality criteria of the previous stage regulatory compliance and, in line have been met; the strict implementa- with our key principles, tion of the procedures under the EN ISO we avoid any 9001 Quality Management System; the cooperation with development of a Hazard & Operability potential unfair (HAZOP) Study for operational risk analy- competitors sis; and the staffing of the Quality Con- which may lead to anti- trol Departments with experienced per- competitive behaviour or sonnel who are provided with continu- practices. ous training, are some of the fundamental aspects of the specific policies on product quality and safety that the Group Companies apply in their respective activity sectors. Regarding the provision of verifiable and clear labelling information for our products, including their price and – as the case may be – their safe use, environmental impacts, maintenance, storage and disposal, the

83 Life cycle stages in which health and safety impacts of projects/ products are assessed for improvement

Product concept development YES NO Research & Development YES NO Certification YES YES Manufacturing and production YES YES Marketing and promotion YES NO Storage, distribution and supply YES YES Use and maintenance YES YES Disposal, reuse or recycling YES YES

Categories of information relevant to the labelling of the Group’s products and services Collection of product or service data YES No particular labelling Content, especially regarding substances which may have requirements, as all YES a potential environmental or social impact products traded by the company are not Safe use of product or service hazardous. All necessary YES information is provided Product disposal and environmental/ upon request. YES social impacts

Percentage of significant product categories subject to assessment for compliance with the above procedures Alumina 100%

Aluminium 100% EPC Contracts 100% Metal & Mechanical Constructions 100%

The company is committed to ensuring on an ongoing ba- The company’s products and services comply fully with sis the satisfaction of its clients’ needs and expectations, the terms and conditions of the respective Contracts and providing them with products (alumina and primary cast with its contractual obligations to its Clients regarding aluminium) and associated services that meet strict qual- Health & Safety issues. ity requirements. To this end, the Company takes the nec- Clients are supplied with all Safety, Health & Environ- essary steps to obtain the ISO 9002 Quality Certificate, mental information and warnings, including: while its quality control laboratory has been accredited by - Instructions for the use, maintenance and disposal for Hellenic Accreditation System S.A. (ESYD S.A.) in accor- all equipment (Operation & Maintenance Manuals) dance with the requirements of the ISO 17025:2005 In- and materials. ternational Standard, for the chemical analysis of bauxite, - Clearly visible labelling of all materials and equipment alumina (both hydrated and calcined), and of aluminium (signs, warnings and relevant instructions). and its alloys. This accreditation concerns the Quality - Instructions for use and recycling in the form of Mate- Management System of the Laboratory and its technical rial Safety Data Sheets (MSDS) for all hazardous ma- skills and adequacy for carrying out tests in the areas for terials. which it has been accredited.

84 10.2 Management of Local Suppliers

Given that the demand for new prod- accordance with the specifications protection of their personnel, to ucts with longer lifecycle spans and re- set by the respective Group sub- pay all types of statutory or con- duced environmental impacts is steadi- sidiary. tractual personnel wages and ly increasing, we invest in Research and salaries, and to take out and main- (b) Efforts are also being made to make Development, looking for solutions tain in effect appropriate insurance all our purchases from the Greek that will to satisfy the varying needs of policies. They also contain clauses market, where possible, as quite of-

our clients and seeking to offer a com- on environmental compliance (in SUSTAINABILITY REPORT 2012 ten projects have a requirement for prehensive service with the lowest pos- accordance with the ISO 140001 specialised suppliers from eco- sible burden on the environment. In International Standard) and on nomically developed countries, by this direction, our principal associ- the protection of human rights. following selection principles and ates and suppliers can act as catalysts, procedures characterised by trans- (d) Finally, as part of our efforts to pro- as they are an integral part of our ef- parency and meritocracy. Addi- mote CSR in our sphere of influ- forts. Therefore, the management of ence, we plan to also focus on local suppliers by the Group sub- tionally, in many cases we provide our supply chain participants with communicating and promoting sidiaries is governed by specific rules the principles of the UN Global the know-how and methods re- and also includes plans for future ini- Compact to our principal associates quired to process the materials tiatives, as follows: and suppliers. Our aim in doing so which we need for our activities, a) Depending on the scope and na- is to obtain the commitment of our and we encourage investment ini- ture of each specific purchase, lo- suppliers to the Compact, a de- tiatives involving more environ- cal suppliers are selected on the ba- velopment which will lead to mu- mental-friendly production process- sis of their solvency, reliability in tual benefits. In addition, we be- es. terms of quality and punctuality in lieve that our effort will elicit con- terms of delivery, cost of products (c) All the contracts signed with our siderable positive responses, main- or services, available capacity to en- major subcontractors and suppliers ly because of the large size of the sure the quantities required, and contain clauses regarding their companies concerned and their capability to meet the require- obligation to comply with the exposure to challenges in the ex- ments of the particular purchase in laws, to ensure the safety and ternal environment.

85 10.3 Client satisfaction ALUMINIUM S.A. is scheduled for 2013. Because of the varied nature of its activity sectors and the geographical dis- In addition, as part of the efforts to en- persion of its operations, MYTILINEOS sure customer satisfaction, the Group Group has a very broad client base. As provides clients with access to claims and to equitable and effective proce- part of our efforts for continuous im- dures for out-of-court resolution of dis- provement and drawing on the qual- putes in connection with seeking ity standards that we have in place, we compensation in the event that the conduct client satisfaction surveys, products which we provide them do mainly in ALUMINIUM S.A. (every two not meet the agreed specifications. In years) and in METKA S.A. (to assess the the EPC Projects Sector, the settlement progress and the results of every proj- procedure is always specified in writ- ect the company has undertaken, af- ing as part of the project contract, and ter its completion). No client satisfac- may typically involve arbitration by in- tion survey results are available for ternationally recognised authorities 2012, as during the year all projects of such as the Arbitration Bodies of the METKA S.A. were in progress, while International Chamber of Commerce the next client satisfaction survey of (ICC).

10.4 Responsible Communication & Marketing In MYTILINEOS Group, our commit- subsidiaries are bound by the Hellenic ment to responsible communication Code of Advertising-Communication and marketing is ensured by our com- Practice, whose principles provide that pliance with the laws in force and the all advertising should be legal, decent, application of best practices that gov- honest and truthful, should be pre- ern “below-the-line” promotion of our pared with a due sense of social re- products and companies, by our sponsibility and should conform to the “above-the-line” communication at principles of fair competition as gen- the central corporate level, and by our erally accepted in business. During annual corporate sponsoring plan. 2012 there were no incidents of non- We seek to provide transparent in- compliance with the regulations and formation and to ensure that our voluntary codes on marketing com- messages are fully understood by all munications, including product pro- our clients. To this end, the commu- motion and sponsorships. nication/marketing associates of our

10.5 Protection of client privacy In all MYTILINEOS Group companies, limited to the information which is ab- our respect for the privacy of clients is solutely necessary for the provision of demonstrated by the application of rig- its products and services, after the orous systems for collection, use and clients concerned have been informed protection of their personal data. The and their free consent has been ob- Group’s key concern is to ensure that tained. During 2012, no incidents of private client data are collected in a violation of client privacy occurred in lawful and acceptable manner and are the Group companies.

86 10.6 Relations with the Competition & Regulatory Compliance

A core commitment and principle of the importance of adhering to all ap- monetary sanctions were imposed for the corporate philosophy of plicable laws on competition, and es- non-compliance of our subsidiaries MYTILINEOS Group, in all the markets pecially to provide Management Ex- with the relevant applicable laws and where it operates, is to avoid all unfair ecutives with suitable training. In ad- regulations. associations with potential competitors dition, each one of our subsidiaries is However, December 2012 saw the which may lead to anti-competitive be- at the disposal of the competent launch of the arbitration procedure behaviour or practices, which may include Competition Authorities and is avail-

tween the Group’s subsidiary SUSTAINABILITY REPORT 2012 fixing of prices, concerted bidding, the able to cooperate substantially and ef- ALUMINIUM S.A. and the Public Pow- implementation of restrictions on pro- fectively with them, whenever re- er Corporation S.A. (PPC), which is cur- duction and/or the joint exploiting of quired. rently in full progress. Given the markets through the sharing of clients, During 2012 the Group was not the above, the completion of the arbitra- suppliers, regions or trade activities. subject of any petitions to the Courts tion procedure and the issue of a Rul- Our key concern is to regularly inform under Greek or international law for ing are expected in the next few the personnel of our subsidiaries about anti-competitive behaviour, and no months.

87 11. MYTILINEOS GROUP – AGGREGATE PERFORMANCE SUMMARY

11.1. GRI Disclosures and Indicators

This symbol is used to indicate a reference to the MYTILINEOS Group website (Corporate Social Responsibility section) This symbol is used to indicate a reference to the MYTILINEOS Group Annual Report 2012 GRI Strategy and Analysis – Description of indicators Cross reference pages Reported Code or direct answer 2 & 3, 14 - 16, 28 - 31, 2 & 3 1.1 Statement from the most senior decision maker of the organization. http://www.mytilineos.gr/el-gr/corporate- Fully social-responsibility/of-mytilineos-group 2 & 3, 6 & 7, 20, 23 - 31, 55 - 58, 74 - 77 2 & 3, 51 - 57, 95 - 103 1.2 Description of key impacts, risks, and opportunities. http://www.mytilineos.gr/el-gr/strengthing- Fully transparency/information#tab-information- on-corporate-governance GRI Cross reference pages Code Organisational profile – Description of indicators or direct answer Reported 2.1 Name of the organisation. MYTILINEOS HOLDINGS S.A. Fully 2.2 Primary brands, products and/or services. 9 - 10 Fully 2.3 Operational structure of the organisation. 9 Fully 2.4 Location of organisation’s headquarters. 5-7 Patroklou Str., Maroussi 15125 Athens, Greece Fully 2.5 Number of countries where the organisation operates. 4 (Greece, Romania, Turkey, Syria) Fully 2.6 Nature of ownership and legal form. 9 & 44 Fully 2.7 Markets served. 8, 9 & 10 Fully 2.8 Scale of the reporting organisation. 14 Fully 2.9 Significant changes during the reporting period regarding size, structure or ownership. 32 & 33 Fully 2.10 Awards received in the reporting period. 16 Fully GRI Cross reference pages Code Report parameters – Description of indicators or direct answer Reported 3.1 Reporting period for the information provided. 1.1.2012 - 31.12.2012 Fully 3.2 Date of most recent previous report (if any). August 2011 Fully 3.3 Reporting cycle. Annual Fully

3.4 Contact point for questions regarding the report or its contents. 7 Fully

3.5 Process for defining report content. 4, 5 & 6 Fully Boundary of the report (e.g. countries, divisions, subsidiaries, leased 3.6 5 Fully facilities, joint ventures, suppliers). 3.7 State any specific limitations on the scope or boundary of the report. 5 Fully

Basis for reporting on joint ventures, subsidiaries, leased facilities, 3.8 6 & 7 Fully outsourced operations, and other entities.

6, 65, 66 & 3.9 Data measurement techniques and the bases for calculations. http://www.mytilineos.gr/el-gr/health-and- Fully safety/info#tab-health-and-safety-indicators Explanation of the effect of any re-statements of information provided 3.10 4 Fully in earlier reports, and the reasons for such re-statement.

Significant changes from previous reporting periods in the scope, 3.11 4 & 5 Fully boundary, or measurement methods applied in the report.

Table identifying the location of the GRI-compliant Standard Disclosures 3.12 88 - 93 Fully in the report. Policy and current practice with regard to seeking external assurance 3.13 7 Fully for the report.

88 GRI Governance, commitments and engagement – Cross reference pages Reported Code Description of indicators or direct answer Governance structure of the organisation, including committees under the 4.1 highest governance body responsive for specific tasks, such as setting 11 & 51 - 57 Fully strategy or organisational oversight. Indicate whether the Chair of the highest governance body is also an 4.2 56 Fully executive officer.

4.3 Independent and/or non-executive members of the Board of Directors.. 56 Fully

The key mechanisms are the following: Annual and extraordinary General Meetings of the SUSTAINABILITY REPORT 2012 Shareholders, Financial results presentations, regular and ad hoc communication between Mechanisms for shareholders and employees to provide recommendations the Management and the employees' collective 4.4 Fully or direction to the highest governance body. bodies, personal communication at the employees' request, employee performance reviews procedures and the formal annual dialogue forums with Stakeholders. 45 - 48

Linkage between compensation for members of the highest governance body, http://www.mytilineos.gr/el- 4.5 general managers and top management executives and the organisation’s gr/strengthing-transparency/information# Fully performance (including social and environmental performance). tab-information-on-corporate-governance

http://www.mytilineos.gr/el- Processes in place for the highest governance body to ensure conflicts of 4.6 gr/strengthing-transparency/information# Fully interest are avoided. tab-information-on-corporate-governance

Process for determining the qualifications and expertise of the members of http://www.mytilineos.gr/el- 4.7 the highest governance body for guiding the organisation’s strategy on gr/strengthing-transparency/information# Fully economic, environmental and social topics. tab-information-on-corporate-governance

15, 16 &17 : http://www.mytilineos.gr/el- Internally developed statements of mission or values, codes of conduct gr/strengthing-transparency/information# 4.8 and principles relevant to economic, environmental and social performance tab-ethics-code Fully and the status of their implementation. : http://www.mytilineos.gr/el- gr/strengthing-transparency/information#t ab-csr-vision-and-values

17 & 18 47 - 62 : http://www.mytilineos.gr/el- gr/strengthing-transparency/information# 4.9 Exercise of governance by the Board of Directors. Fully tab-information-on-corporate-governance http://www.mytilineos.gr/el-gr/csr- governance/info

Processes for evaluating the highest governance body’s own performance, : http://www.mytilineos.gr/el- 4.10 particularly with respect to economic, environmental and social gr/strengthing-transparency/information# Fully performance. tab-information-on-corporate-governance

11, 20 & 21 47 - 62 : http://www.mytilineos.gr/el- Explanation of whether and how the precautionary approach or principle gr/strengthing-transparency/information# 4.11 Fully is addressed by the organisation. tab-information-on-corporate-governance : http://www.mytilineos.gr/el-gr/csr- governance/info Externally developed economic, environmental and social charters, 4.12 principles, or other initiatives subscribed to or endorsed by the 15 & 17 Fully organization.

Membership of associations (such as industry associations) and/or national/ 4.13 16 Fully international advocacy organisations in which the organization participates. http://www.mytilineos.gr/el-gr/ 4.14 List of Stakeholder groups engaged by the organisation. Fully dialogue-with-stakeholders/details Basis for identification and selection of Stakeholders with whom to http://www.mytilineos.gr/el-gr/ 4.15 Fully engage. dialogue-with-stakeholders/details

Approaches to stakeholder engagement, including frequency of 4.16 22 Fully engagement by type and by Stakeholder group.

4.17 Key topics and concerns rose through Stakeholder engagement. 23 - 27 Fully

89 GRI Cross reference pages Economic Performance – Description of Indicators Reported Code or direct answer MANAGEMENT APPROACH 32 EC1 Direct Economic Value. 33 Fully Financial implications and other risks and opportunities for the EC2 organization’s activities due to climate change. 15 Fully

EC3 Coverage of the Group’s defined benefit plan obligations. 90, 91 & 119 - 121 Fully EC4 Significant financial assistance received from government. 33 Fully Policy, practices and proportion of spending on locally-based suppliers at EC6 significant locations of operation. 77 & 85 Fully Procedures for local hiring and proportion of senior management EC7 executives hired from the local community at locations of significant 40 & 76 Fully operation. Development and impact of infrastructure investments and services EC8 provided primarily for public benefit through commercial, in kind, or pro 78, 79 Fully bono engagement. GRI Cross reference pages Environmental Performance – Description of Indicators Reported Code or direct answer http://www.mytilineos.gr/el-gr/climate- MANAGEMENT APPROACH change/csr#tab-climate-change- management-approach EN1 Materials used by weight or volume 59 & 60 Fully

EN2 Percentage of materials used that are recycled input materials. 56 Fully

EN3 Direct energy consumption by primary energy source. 61 & 62 Fully

EN4 Indirect energy consumption by primary energy source. 63 Fully

EN5 Energy saved due to conservation and efficiency improvements. 63 Fully

Initiatives to provide energy-efficient or renewable energy based products http://www.mytilineos.gr/el-gr/ EN6 and services, and reductions in energy requirements as a result of these climate-change/csr#tab-responsible- Partially initiatives. management-of-energy

EN8 Total water withdrawal by source. 64 Fully

EN9 Water sources significantly affected by withdrawal. 64 Fully

EN10 Percentage and total volume of water recycled and reused. 64 Fully

Location and size of land owned, leased, managed in, or adjacent to, pro- EN11 tected areas and areas of high biodiversity value outside protected areas. 58, 71 Fully

Description of significant impacts of activities, products, and services on EN12 biodiversity. 72 & 73 Fully

EN13 Habitats protected or restored.. 58, 71 & 72 Fully

Strategies, current actions, and future plans for managing impacts on EN14 biodiversity. 58 & 72 Fully

Number of IUCN Red List species and national conservation list species with EN15 habitats in areas affected by operations, by level of extinction risk. Nil Fully

EN16 Total direct and indirect greenhouse gas emissions by weight. 65 Fully

EN18 Initiatives to reduce greenhouse gas emissions and reductions achieved. 66 & 67 Partially

EN20 NOx, SOx, and other significant air emissions by type and weight. 66 Fully EN22 Total weight of waste by type and disposal method. 67 - 69 Fully EN23 Total number and volume of significant spills. 67 Fully

Monetary value of significant fines and total number of non-monetary sanctions EN28 for non-compliance with environmental laws and regulations. 73 Fully

EN30 Total environmental protection expenditures and investments by type. 70 & 71 Fully

I Core Indicator I Additional Indicator

90 GRI Cross reference pages Labour practices and decent work – Description of indicators Reported Code or direct answer

http://www.mytilineos.gr/el-gr/labour- MANAGEMENT APPROACH practices/information LA1 Total workforce by employment type, employment contract and region. 36 & 37 Fully LA2 Total number and rate of employee turnover by age group, gender and region. 38 - 40 Fully Benefits provided by the Group to full-time employees of its companies, LA3 which are not provided to temporary or part-time employees. 47 & 48 Fully LA15 Return to work and retention rates after parental leave, by gender. 48 Fully SUSTAINABILITY REPORT 2012 The 98% of full-time employees in the LA4 Percentage of employees covered by collective bargaining agreements. Mytilineos Group of Companies are covered by collective bargaining agreements

With respect to significant operational changes, all Group employees affected by such changes are informed of them within Minimum notice period(s) regarding operational changes, including the time limits prescribed by the applicable LA5 whether it is specified in collective agreements. laws to ensure that they adapt smoothly to Fully the new situation. The timeframe varies between Group companies and in many cases exceeds the statutory obligation.

Percentage of total workforce represented in formal joint management– LA6 worker health and safety committees that help monitor and advise on 46 Fully occupational health and safety programmes.

Rates of injury, occupational diseases, lost days and absenteeism, and total LA7 number of work-related fatalities by region. 45 & 46 Fully

LA10 Average hours of training per year per employee by employee category. 41 Fully

Programs for skills management and lifelong learning that support the LA11 continued employability of employees and assist them in managing career 42 & 43 Fully endings. Percentage of employees receiving regular performance and career LA12 development reviews. 43 & 44 Fully Composition of governance bodies and breakdown of employees per LA13 category according to gender, age group, minority group membership and 51 Fully other indicators of diversity.

LA14 Ratio of basic salary of men to women by employee category. 47 Partially GRI Cross reference pages Human Rights – Description of indicators Reported Code or direct answer http://www.mytilineos.gr/el- MANAGEMENT APPROACH gr/safeguarding-of-human-rights/information Percentage and total number of significant investment agreements that HR1 include human rights clauses or that have undergone human rights screening. 49 Fully

Percentage of significant suppliers, contractors and other business partners HR2 that have undergone human rights screening, and actions taken. 50 Fully

Total hours of employee training on policies and procedures concerning HR3 aspects of human rights that are relevant to operations, including the 50 Partially percentage of employees trained. HR4 Total number of incidents of discrimination and actions taken. Νil Fully Group operations and significant suppliers identified in which the right to HR5 exercise freedom of association and collective bargaining may be violated or at 52 Partially significant risk, and actions taken to support these rights.

Operations identified as having significant risk for incidents of child labour, and HR6 measures taken to contribute to the elimination of child labour. 53 Fully

Operations identified as having significant risk for incidents of forced or HR7 compulsory labour, and measures taken to contribute to the elimination of 54 Fully forced or compulsory labour. Total number of incidents of violations involving rights of indigenous people HR9 and actions taken. Νil Fully Number of grievances related to human rights filed, addressed and resolved HR11 through formal grievance mechanisms. Νil Fully

I Core Indicator I Additional Indicator

91 GRI Cross reference pages Social Performance – Description of indicators Reported Code or direct answer http://www.mytilineos.gr/el-gr/local- MANAGEMENT APPROACH communities/about-csr#tab-local- communities-management-approach

Percentage of Group business units with implemented local community SO1 engagement, impact assessments, and development programmes. 78 - 81 Fully

Operations with significant potential or actual negative impacts on local SO9 communities. 55 & 56, 74 & 75 Fully Prevention and mitigation measures implemented in Group business units SO10 operations with significant potential or actual negative impacts on local 56 - 58, 65, 76 & 77, 82 Fully communities. Percentage and total number of business units analysed for risks related to SO2 corruption. 82 Fully Percentage of employees trained in organization’s anti-corruption policies SO3 and procedures 82 Fully

SO4 Actions taken in response to incidents of corruption. 82 Fully

Public policy positions and participation in public policy development and SO5 lobbying. 16 Fully Total value of financial and in-kind contributions to political parties, SO6 politicians, and related institutions by country. Νil Fully

Total number of legal actions for anticompetitive behaviour, anti-trust and SO7 monopoly practices prohibition and their outcomes. 87 Fully

Monetary value of significant fines and total number of non-monetary SO8 sanctions for non-compliance with laws and regulations. 87 Fully

GRI Product responsibility – Description of indicators Cross reference pages Reported Code or direct answer

http://www.mytilineos.gr/el-gr/climate- MANAGEMENT APPROACH change/csr#tab-climate-change- management-approach

Life cycle stages in which health and safety impacts of products and PR1 services are assessed for improvement, and percentage of significant 63 Fully products and services categories subject to such procedures.

Total number of incidents of non-compliance with regulations and PR2 voluntary codes concerning health and safety impacts of products and 63 Fully services during their lifecycle, by type of outcomes.

Total number of incidents of non-compliance with regulations and : http://www.mytilineos.gr/el-gr/climate- PR3 voluntary codes concerning product and service information and labelling, change/csr#tab-responsible-management- Partially by type of outcomes. of-energy

Total number of incidents of non-compliance with regulations and PR4 voluntary codes concerning product and service information and labelling, 64 Fully by type of outcomes.

Practices related to customer satisfaction, including results of surveys PR5 measuring customer satisfaction. 64 Fully

Programmes for adherence to laws, standards, and voluntary codes related to PR6 marketing communications, including advertising, promotion, and sponsorship. 64 Fully

Total number of incidents of non-compliance with regulations and voluntary PR7 codes concerning marketing communications, including advertising, promo- 58, 71 Fully tion, and sponsorship by type of outcomes.

Total number of substantiated complaints regarding breaches of customer PR8 privacy and losses of customer personal data. 72 & 73 Fully

Monetary value of significant fines for non-compliance with laws and regu- PR9 lations concerning the provision and use of products and services. 58, 71 & 72 Fully

I Core Indicator I Additional Indicator

92 SUSTAINABILITY REPORT 2012

93 11.2. Coverage of the Principles of the UN Global Compact

See Group’s website www.mytilineos.gr (Corporate Social Responsibility Section).

THE TEN PRINCIPLES Cross reference OF THE UN GLOBAL COMPACT (Sustainability Report pages & Group website sections)

16, 32, 45 - 47, 49 - 54, 83 & 84, 86 GRI indicators: HR9 & HR11, PR2 : http://www.mytilineos.gr/el-gr/labour-practices/information#tab- Businesses should support and respect the labour-management-approach Principle protection of internationally proclaimed : http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/information# 1 human rights. tab-management-approach : http://www.mytilineos.gr/el-gr/market-practicies/management-approach T 98% of full-time employees in the Mytilineos Group of Companies are covered by collective labour agreements

16, 49 - 50, 52 - 54 Principle Businesses should make sure that they are not GRI indicators: HR9 & HR11 2 complicit in human rights abuses. : http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/ information#tab-management-approach

16, 49, 50, 52 : http://www.mytilineos.gr/el-gr/labour-practices/information#tab-labour- management-approach : http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/ Businesses should uphold the freedom of Principle information#tab-management-approach association and the effective recognition of 3 T 98% of full-time employees in the Mytilineos Group of Companies are covered the right to collective bargaining. by collective labour agreements T All Group employees affected by significant operational changes are informed of them within the time limits prescribed by the applicable laws, which in several cases exceed the statutory ones.

16, 32, 49 & 50, 54, HR11 Principle Businesses should uphold the elimination of : http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/ 4 all forms of forced and compulsory labour. information#tab-management-approach

Principle Businesses should uphold the effective : http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/ 5 abolition of child labour. information#tab-management-approach

16, 32, 38 - 40, 47, 49 - 51, 76 Businesses should uphold the elimination of : http://www.mytilineos.gr/el-gr/labour-practices/ Principle discrimination in respect of employment and information#tab-labour-management-approach 6 occupation. : http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights /information#tab-management-approach

16, 15, 32, 66 & 67, 70 & 71 Principle Businesses should support a precautionary : http://www.mytilineos.gr/el-gr/climate-change/csr# 7 approach to environmental challenges. tab-climate-change-management-approach

16, 56, 66 & 67, 58 - 73, GRI indicators: PR4 : http://www.mytilineos.gr/el-gr/climate-change/csr# Principle Businesses should undertake initiatives to tab-responsible-management-of-energy 8 promote greater environmental responsibility. : http://www.mytilineos.gr/el-gr/climate-change/csr# tab-climate-change-management-approach : http://www.mytilineos.gr/el-gr/market-practicies/management-approach

16, 56, 63 & 64, 66 & 67,70 & 71 Businesses should encourage the : http://www.mytilineos.gr/el-gr/climate-change/csr#tab-responsible- Principle development and diffusion of environmentally management-of-energy 9 friendly technologies. : http://www.mytilineos.gr/el-gr/climate-change/csr#tab-climate-change- management-approach

16, 82 Principle Businesses should work against corruption in GRI indicators: SO6 10 all its forms, including extortion and bribery. : http://www.mytilineos.gr/el-gr/local-communities/about-csr#tab-local- communities-management-approach

94 11.3. Coverage of the clauses of the ISO 26000 Social Responsibility Guidance Standard

See Group’s website www.mytilineos.gr (Corporate Social Responsibility Section).

Α. Principles of social responsibility Sustainability Report sections & Group website reference Reported

• SOCIAL FOOTPRINT OF MYTILINEOS GROUP • Accountability Fully • ENVIRONMENTAL FOOTPRINT OF MYTILINEOS GROUP • MYTILINEOS GROUP PROFILE

• STRATEGY AND KEY FIGURES SUSTAINABILITY REPORT 2012 • GROUP GOVERNANCE STRUCTURE • GOVERNANCE OF CORPORATE SOCIAL RESPONSIBILITY • COLLABORATIONS WITH SOCIAL PARTNERS AND ORGANISATIONS • Transparency Fully • MEMBERSHIPS OF CSR INITIATIVES AND STANDARDS • CSR PERFORMANCE IN 2012 & TARGETS FOR 2013 • SOCIAL FOOTPRINT OF MYTILINEOS GROUP • ENVIRONMENTAL FOOTPRINT OF MYTILINEOS GROUP • STAKEHOLDERS ENGAGEMENT

• APPROACH TO CORPORATE SOCIAL RESPONSIBILITY • GROUP GOVERNANCE STRUCTURE • Ethical behaviour • GOVERNANCE OF CORPORATE SOCIAL RESPONSIBILITY Fully • COLLABORATIONS WITH SOCIALPARTNERS AND ORGANISATIONS • PROFESSIONAL ETHICS CODE

• Respect for stakeholder interests • STAKEHOLDERS ENGAGEMENT Fully

• COMPLIANCE WITH ENVIRONMENTAL LAWS AND REGULATIONS • ENVIRONMENTAL FOOTPRINT OF MYTILINEOS GROUP • Respect for the rule of law • RELATIONS WITH THE COMPETITION & REGULATORY COMPLIANCE Fully • GRI DISCLOSURES AND INDICATORS • UN GLOBAL COMPACT DISCLOSURES

• SUSTAINABILITY REPORT PARAMETERS • Respect for international • COLLABORATIONS WITH SOCIAL PARTNERS AND ORGANISATIONS Fully norms of behaviour • MEMBERSHIPS OF CSR INITIATIVESAND STANDARDS • PROTECTION OF HUMAN RIGHTS • Respect for human rights • PROFESSIONAL ETHICS CODE Fully • UN GLOBAL COMPACT DISCLOSURES

Β. Recognizing social responsibility Sustainability Report sections & Group website reference Reported and engaging stakeholders

• CORPORATE SOCIAL RESPONSIBILITY FUNDAMENTAL COMMITMENTS • PROTECTION OF HUMAN RIGHTS • EMPLOYMENT & LABOUR PRACTICES • Recognizing social responsibility Fully • ENVIRONMENTAL PROTECTION • FAIR MARKET PRACTICES • SOCIAL COHESION & DEVELOPMENT

• Stakeholder identification • STAKEHOLDER ENGAGEMENT Fully and engagement • DIALOGUE WITH STAKEHOLDERS C. Social Responsibility Sustainability Report sections & Group website reference Reported core subjects

• Human rights • PROTECTION OF HUMAN RIGHTS Fully

• Labour practices • EMPLOYMENT & LABOUR PRACTICES Fully

• The Environment • ENVIRONMENTAL PROTECTION Fully

• Fair operating practices • FAIR MARKET PRACTICES Fully

• Consumer issues • FAIR MARKET PRACTICES Fully • Community involvement • SOCIAL COHESION & DEVELOPMENT Fully and development

95 D. Integrating social responsibility throughout Sustainability Report sections & Group website reference Reported an organization

• The relationship of an • APPROACH TO CORPORATE SOCIAL RESPONSIBILITY organization’s • GOVERNANCE OF CORPORATE SOCIAL RESPONSIBILITY Fully characteristics to social • IMPACT OF CLIMATE CHANGE ON BUSINESS ACTIVITY responsibility • DIALOGUE WITH STAKEHOLDERS

• DISCLOSURE MANAGEMENT APPROACHES (ENVIRONMENT - LABOUR PRACTICES ç • Understanding the social HUMAN RIGHTS - SOCIAL COHESION - FAIR MARKET PRACTICES) responsibility of the Fully • CORPORATE SOCIAL RESPONSIBILITY FUNDAMENTAL COMMITMENTS organization • STAKEHOLDERS ENGAGEMENT

• APPROACH TO CORPORATE SOCIAL RESPONSIBILITY • SOCIAL FOOTPRINT OF MYTILINEOS GROUP • Practices for integrating • ENVIRONMENTAL FOOTPRINT OF MYTILINEOS GROUP social responsibility • STAKEHOLDER ENGAGEMENT Fully throughout an organization • SUSTAINABILITY REPORT PARAMETERS • PROFESSIONAL ETHICS CODE • GOVERNANCE OF CORPORATE SOCIAL RESPONSIBILITY

• DIALOGUE WITH STAKEHOLDERS • Communication on social • CORPORATE SOCIAL RESPONSIBILITY PUBLICATIONS Fully responsibility • CSR PROMOTION AND COMMUNICATION BELOW THE LINE ACRIVITIES • COLLABORATIONS WITH SOCIAL PARTNERS AND ORGANISATIONS

• STAKEHOLDER ENGAGEMENT • Enhancing credibility • MEMBERSHIPS OF CSR INITIATIVES AND STANDARDS regarding social • GOVERNANCE OF CORPORATE SOCIAL RESPONSIBILITY Fully responsibility • GRI DISCLOSURES AND INDICATORS • UN GLOBAL COMPACT DISCLOSURES

• Reviewing and improving • APPROACH TO CORPORATE SOCIAL RESPONSIBILITY an organization's actions • DIALOGUE WITH STAKEHOLDERS Fully and practices related to • DISCLOSURE MANAGEMENT APPROACHES (ENVIRONMENT - LABOUR PRACTICES - social responsibility HUMAN RIGHTS - SOCIAL COHENSION - FAIR MARKET PRACTICES)

• GRI DISCLOSURES AND INDICATORS • Voluntary initiatives • UN GLOBAL COMPACT DISCLOSURES Fully for social responsibility • MEMBERSHIPS OF CSR INITIATIVES AND STANDARDS

The Sustainability Report is the result of a coordinated effort of the Corporate Social Responsibility Teams of the MYTILINEOS Group Companies. We would like to express our thanks to all Group personnel for their important contribution and cooperation. We would also like to thank all our Stakeholders and external associates, whose participation in our annual dialogue forums is an invaluable help in the adoption of international standards and the implementation of best practices that further improve our activities.

MEDA COMMUNICATION A.E.

5-7 Patroklou str, Μaroussi, 151 25 Αthens Τel. +30 210 6877300 Fαχ +30 210 6877400 www.mytilineos.gr