Governance

METLEN demonstrates responsible corporate behavior through its participation in international and national initiatives that promote transparency, and having adopted the 10th principle of the UN Global Compact, actively engages against all forms of corruption, consistently strengthening the culture of integrity at all levels. In addition, the Company seeks to develop strong and long-term relationships of trust and mutual benefit with its suppliers and partners,  while it has as a priority to support its local communities, by entering into partnerships with local suppliers and contractors. At the same time, as part of its strategy for sustainable development, METLEN has started implementing specific initiatives aimed at expanding responsible practices in its supply chain.  According to the 2025 Double Materiality Assessment, the significant impacts associated with the above challenge are:

• Established culture of business ethics / zero tolerance for bribery and corruption
• Emergence of unethical practices in the value chain
• Responsible supply chain management

See more in the  Company's Annual Report 2025.

METLEN has established a comprehensive governance framework for the management of sustainability issues, which is integrated into the Company's core decision-making and oversight processes. The role of the Management is clearly defined and ensures continuous supervision and strategic guidance on sustainability issues.

In particular, the Sustainable Development Committee, as a committee of the Board of Directors, is responsible for monitoring the implementation of the sustainable development strategy, approving relevant policies and monitoring the Company's ESG performance. The Committee meets regularly and cooperates with the Directorate-General for Corporate Governance and Sustainable Development, which plays a crucial role in coordinating all sustainability issues within the Company.

The governance of sustainability issues is supported by specially defined organisational structures, which include teams and sustainability officers in each Business Sector and a key subsidiary. ESG thematic pillar managers work with central and local management teams, ensuring coordination, monitoring progress and providing technical guidance, with the aim of systematically integrating the principles of sustainable development across the Company's range of activities.

At the same time, METLEN applies a systematic due diligence approach to manage actual and potential significant sustainability impacts, risks and opportunities. This approach is based on the international guidelines for responsible business conduct and includes: identification and impact assessment processes, setting targets, action plans, monitoring mechanisms, taking corrective actions, consulting stakeholders and promoting value chain partnerships.

Through these mechanisms, METLEN ensures that sustainability issues are integrated into its business strategy and day-to-day operation, enhancing long-term value creation for all stakeholders.

See more in the  Company's Annual Report 2025.

METLEN implements a comprehensive system of monitoring and compliance with legislative and regulatory changes, avoiding risks that could affect its financial stability, reputation and ability to meet its obligations. It embeds corporate responsibility and ethics in all its activities, promoting transparency and sustainable business practices. It is committed to tackling corruption and any form of unfair practice through strict control and evaluation mechanisms, both within the Company and in the context of cooperation with suppliers. It adopts ethical and responsible supply chain policies, requiring full compliance with ESG criteria and international standards. It systematically invests in staff training and the utilization of reporting mechanisms, while conducting regular audits with the aim of continuous improvement and prevention of non-compliance phenomena. With modern digital tools, it enhances transparency and internal control, maintaining constant monitoring of legal developments. Through responsible partnerships, it cultivates a fair and safe business environment based on trust and ethics.

METLEN applies an integrated methodology for the evaluation of its key suppliers, which incorporates environmental, social and intergovernmental criteria, in accordance with the Code of Conduct and the Responsible Supply Chain Policy. Through the dedicated digital platform, data on sustainability and compliance are collected and evaluated on an annual basis, with the aim of identifying risks and enhancing the continuous improvement of suppliers. METLEN is committed to adhering to strict standards of transparency and ethics, and no political contributions or politically influenced activities are permitted under corporate policy. The Regulatory Compliance Directorate supervises the implementation of the Code, while providing extensive training to staff, in order to raise awareness and ensure proper functioning at all levels.

See more in the  Company's Annual Report 2025.

METLEN recorded measurable results in key areas of responsible business operations, with a focus on ESG supplier evaluation, employee training on ethics and compliance, and ensuring zero tolerance for corruption. In particular,

1. 56 % of key suppliers were evaluated with environmental-social-governance (ESG) criteria.
2. 91 % of key evaluated suppliers were classified as low/negligible risk.
3. 20 online and on-site audits were carried out on assessed key suppliers
4. 2,968 employees were trained in the METLEN Code of Conduct.
5. 3,000 employees completed training in personal data protection (GDPR).
6. 2,462 employees participated in Regulatory Compliance and Whistleblowing training programs, while in 2025 two new training programs on anti-corruption and use of reporting channels were implemented.
7. 57% of all employees participated in anti-corruption and anti-bribery trainings.
8. Zero (0) incidents of corruption or bribery.

Indicative objectives:

1. To enhance the level of maturity through the implementation of training programs to cultivate and integrate a culture of sustainability into its supply chain.
2. The continuation of the implementation of the evaluation of key suppliers with ESG criteria and the gradual extension of the evaluation to new and potential suppliers who take part in tender procedures.
3. The inclusion of an ESG dimension in the tender procedures for the selection of partners/suppliers, taking into account their performance from the ESG evaluation process.
4. The continuation of  on-site inspections at the premises of a sample of evaluated suppliers of the Energy & Metals Sectors and its subsidiaries, which will be selected by the purchasing/procurement departments of the Sectors/subsidiaries, based on the outcome of the ESG assessment.
5. Preparation for the implementation of the renewed supplier assessment approach through the new Third-Party Risk Management (TPRM) System, starting in 2026.

See more in the  Company's Annual Report 2025.