Buildingthe Futurewe want

SustainabilityReport2012

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1. MESSAGE FROM THE CHAIRMAN2. SUSTAINABILITY REPORT PARAMETERS2.1 Report Scope and Boundary

2.2 Report Methodology

3. MYTILINEOS GROUP PROFILE3.1 Structure & Activity Sectors

3.2 Group Governance Structure

3.3 Business Milestones

3.4 Strategy & Key Figures

3.5 Impact of Climate Change on business activity

3.6 Collaborations with social partners and organisations

3.7 Awards and distinctions

4. APPROACH TO CORPORATE SOCIAL RESPONSIBILITY4.1 ESG (Environmental, Social and Governance) Milestones

4.2 Corporate Social Responsibility – Fundamental Commitments

4.3 Governance of Corporate Social Responsibility

4.4 Stakeholder engagement

4.5 CSR Performance in 2012 & Targets for 2013

5. ECONOMIC PERFORMANCE5.1 Key economic value data

5.2 New investments

6. EMPLOYMENT & LABOUR PRACTICES6.1 Employment

6.2 Employee Education, Training and Development

6.3 Occupational Health & Safety

6.4 Benefits

7. PROTECTION OF HUMAN RIGHTS7.1 Fundamental labour rights

7.2 Equal opportunities & diversity

7.3 Freedom of Association

7.4 Child Labour

7.5 Forced Labour

8. ENVIRONMENTAL PROTECTION8.1 Environmental Footprint of MYTILINEOS Group

8.2 Management of raw & other materials

8.3 Energy consumption

8.4 Water consumption

8.5 Emissions

8.6 Significant spills

8.7 Waste management

8.8 Environmental expenditures

8.9 Biodiversity

8.10 Compliance with environmental laws and regulations

9. SOCIAL COHESION AND DEVELOPMENT9.1 Social Footprint of MYTILINEOS Group

9.2 Participation in the development of local communities

9.3 Social expenditures

9.4 Actions to strengthen Transparency & combat corruption

10. FAIR MARKET PRACTICES10.1 Product Quality & Safety

10.2 Management of Local Suppliers

10.3 Client satisfaction

10.4 Responsible Communication & Marketing

10.5 Protection of client privacy

10.6 Relations with the Competition & Regulatory Compliance

11. MYTILINEOS GROUP – AGGREGATE PERFORMANCE SUMMARY11.1 GRI Disclosures and Indicators

11.2 Coverage of the Principles of the UN Global Compact

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

CONTENTS2446881112141515161718202122283232343536414547494951525354555559616465676770717374747880828383858686868788889495

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1. MESSAGE FROM THE CHAIRMAN

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In a country going through its fifth year of deep recession, formulating andadhering to a well-organised, visionary strategy is a sine qua non for mov-ing forward, both in the short and in the long term.

In MYTILINEOS Group we are taking carefully planned steps, seeking to growevery day while protecting the interests of the Company, of our people andof our shareholders. With a clearly focused strategy that relies on our strongexporting profile and on strict cost controls, we have laid the foundations thatconsolidate our position today and create positive prospects for the future.

Our strategy, however, is also driven by an additional key element: our desireto create shared value for society and for the economy. We do not limit our-selves to a social responsibility policy, which has a marginal role within our busi-ness strategy, functioning merely as a mechanism for redistributing a part ofour profits or for mitigating any unavoidable impacts of our business activity.

We know very well that the sustainability and the progress of organisations areinextricably linked with the development of their environment and, therefore,prosperity for any enterprise is inextricably linked to the prosperity of the so-ciety in which it operates. The only way forward is to move forward togeth-er.

Our priority to become a driver for social growth and for development, carry-ing forward with us the society and the economy, is at the core of our Group’soperation. And with a corporate and economic footprint that is the reflectionof 2,500 employees, €1.454 billion in turnover and subsidiary companies whichgain distinctions in Greece and abroad, our dynamism is commensurate withour size.

This dynamism translates into a holistic philosophy of responsibility, contribu-tion and progress that is part of our corporate DNA. MYTILINEOS Group doesnot rest on its achievements, but instead works tirelessly to improve its socialand economic footprint and to achieve nothing less than excellence.

In taking every step, we want to help the efforts to strengthen the Greek econ-omy, we support society, we protect the environment and we promote a prop-er and balanced work environment. We are not trying to build our own im-age along these four key action pillars, but to achieve real business and buildthe future that we wish for ourselves and for our children.

We are building this future through a consistent, long-term strategy that is di-rectly linked to our business operations and remains aligned with internationalstandards and requirements. It is this philosophy which, despite last years eco-nomic adversities, made us achieve once more remarkable results.

We generated a “social product” with a value of €233 million, allocated to tax-es, salaries and social, business and environmental investments. Indeed, theGroup’s aggregate social product since 2009 has exceeded €1 billion, in spiteof the domestic recession.

With Greece’s social structures in ever-increasing need of support, the Groupremained steadfast in its commitment to address relevant issues. During 2012we contributed approximately €800,000 to the promotion of culture, sports

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and entrepreneurship, and we also provided local communities with assistancefor covering local infrastructure needs.

Conscious of the fact that our people are the Group’s heart and soul and afamily for which we are responsible, we not only managed to safeguard thejobs that we provide, which now exceed 2,500, but we also hired 374 newemployees. At the same time, we have created a work environment which of-fers 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 weachieved our target for “Zero Accidents and Zero Occupational Diseases” whilekeeping the rate of incidents at near-zero levels.

Regarding the protection of the environment, the Group’s initiatives in this areaexceed the boundaries of statutory obligations and duties, always seeking tominimise the impacts resulting from its activities. We invested more than €10million in environmental projects for waste treatment and discharge, the treat-ment of air emissions and the installation of “greener” technology.

Finally, we remained a driving force for the Greek market and economy, as dur-ing the year we not only carried out €92 million of total investments, but wealso demonstrated – and continue to do so, that despite the adverse economicjuncture – the talent and creativity of Greek entrepreneurship, can and mustgrow.

Of course the combination of difficult conditions, negative economic climate,overtaxation and red tape create inevitably a climate of uncertainty that hitsthe business community and, consequently, all social responsibility initiatives.In MYTILINEOS Group, however, we do not make easy compromises and re-main steadfast in the course we have set for ourselves – to create shared val-ue for all.

As additional proof of our success in following this course and of our compliancewith international standards, we obtained for yet another year the certifica-tion of the Global Reporting Initiative (GRI), international assessment organ-isation for the compliance of our Sustainability Report with the GRI-G3.1 Ap-plication, Level B reporting requirements. We also participated for the first timein Bloomberg’s ESG (Environmental, Social and Governance) indicator, and wereranked No. 1 among all participating Greek enterprises in terms of overall per-formance.

Of course, distinctions are not an end in themselves – it is the essence of whatthey stand for that counts. Thomas Edison once remarked that “If we did allthe things we are capable of, we would literally astonish ourselves.” InMYTILINEOS Group, we wish to astonish ourselves in this way every day.

Evangelos G. MytilineosChairman of the Board & CEO

MYTILINEOS Group of Companies

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We welcome you to the 5thannual Sustainability Re-port of MYTILINEOS Group

(hereinafter “Sustainability Report”or simply “Report”). Our Sustain-ability Reports, which are releasedand published annually, present asummary of the challenges that weface in the domain of Corporate So-cial Responsibility and of our relat-ed efforts and performance, in linewith our goal to achieve socially re-sponsible and sustainable develop-ment, as defined by our corporatevalues. The present Report that

covers the period from 1st Januaryto 31st December 2012, is a con-tinuation of our previous Sustain-ability Report 2011 and comple-ments the Group’s Annual Report2012.

2.1 Report Scope and Boundary

This year’s Sustainability Report in-troduces substantial changes fromthe structure of our previous Re-ports, as its preparation has beenbased for the first time on thecombination of a number of inter-national standards and guidelines,such as:

- The seven fundamental principlesof social responsibility defined bythe ISO 26000 Social Responsibil-ity Guidance Standard, which cov-er accountability, transparency,ethical behaviour, respect forStakeholder interests, respect forthe rule of law and for interna-tional norms of behaviour, and re-spect for Human Rights.

- The OECD Guidelines on Corpo-rate Social Responsibility, whichwe take into account in our effortsto determine and apply our re-sponsible business conduct.

- The Ten Principles of the UN Glob-al Compact; and

- The Guidelines of the Global Re-porting Initiative (GRI) interna-tional organisation on the publi-cation of Sustainability Reports.

The novel features introduced withour Report for 2012 refer to theconcrete description of our Socialand Environmental footprints andthe presentation of our performanceregarding the economic, social andenvironmental dimensions of our ac-tivities. To this end, in the presentReport we have done away with theindividual company sections which

2. SUSTAINABILITY REPORTPARAMETERS

The key purpose of the Sustainability Report isto provide all social groups and all natural andlegal persons which the Group recognises as itskey Stakeholders (employees, shareholders,financial analysts, corporate clients, suppliers,business partners, government officials, the Press& Media, and the local communities where theGroup deploys and develops its activities) withdirect, reliable and transparent information aboutthe Group’s efforts, performance and futurecommitments concerning the integration ofCorporate Social Responsibility in its operations.

�

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2presented information on our sub-sidiaries and had served as the ba-sis for our previous Reports. In-stead, we have chosen to high-light by means of suitable graphs ortextboxes the aspects of our sub-sidiaries’ performance, whether pos-itive or negative, that play a signif-icant part in establishing the over-all picture for the Group in each ref-erence area.

In putting together the Sustain-ability Report 2012, our goal was topresent its contents in a more con-cise way, in order to make it moreeasily accessible to as many of ourStakeholder groups as possible. Toachieve this, the information con-tained in the Report is comple-mented by the new, dedicated sec-tion on Corporate Social Responsi-bility which is now available on theGroup's website, as well as by rel-evant references to our Annual Re-port.

This year’s Report opens with themessage from the Chairman of theGroup, which focuses on the key is-sues and the progress made in2012, introducing briefly the Re-port’s contents and the Group’snew business goals for the comingyears. The next section describes theSustainability Report parameters,which define the Report’s scopeand boundary, and is followed by abrief presentation of the Group’sbusiness profile. Of particular sig-nificance is the section that presentsour approach to the Governance ofCorporate Social Responsibility, theresults of our third cycle of consul-tation with our Stakeholders, ourperformance against the targetswe had set ourselves in 2012, andthe new CSR targets we have set for2013. It is followed by a summary ofthe Group’s key financial figures(which are discussed in detail in theAnnual Report 2012). The next sec-tions contain data on employment

and labour practices and on the pro-tection of human rights and the en-vironment, together with data con-cerning our contribution to the so-cial cohesion and development ofthe local communities where we op-erate. The results presented for theGroup cover extensively the envi-ronmental and social initiatives andperformance (sustainability frame-work) of MYTILINEOS HOLDINGSS.A. (Corporate Centre) and it'swholly owned three subsidiaries(ALUMINIUM S.A. with its subsidiaryDELPH I -D ISTOMON S.A., andPROTERGIA S.A.) with reference toGreece, as well as of METKA S.A., inwhich MYTILINEOS HOLDINGS S.A.is the majority shareholder andwhich – in addition to Greece – is al-so active abroad, in Algeria, Turkey,Syria, Iraq and Jordan.

There are no significant changesfrom the previous Report in terms ofthe scope and boundaries of theSustainability Report 2012 and ofthe calculation methods used to ob-tain the quantitative data present-ed. However, specific revisions of theReport’s contents compared to pre-vious Reports are as follows:

(a) The policies and the systematicactions undertaken by the Group inthe Corporate Social Responsibilitydomain were covered in detail in theSustainability Report 2010, whichserves as reference for the on-goingmechanisms and directions in placeto guide the efforts of our sub-sidiaries towards sustainable devel-opment. The Sustainability Reportspublished after 2010 only containreferences to any changes or majorrevisions to these policies and sys-tematic actions.

(b) The contents of the section on“Corporate Governance” have beendrastically reduced, because thecomposition and responsibilities ofthe Group’s Board of Directors andBoard Committees are described

in detail in the Group’s Annual Re-port 2012, and because the CSRsection of the Group’s website nowprovides comprehensive coverage ofthe following subjects:

- The degree of compliance with theCorporate Governance Code andany deviations from it.

- The relationship between the earn-ings of management executivesand the performance of the Groupand the Group companies.

- Conflicts of interests.

- The procedures for specifying thequalifications of the Board mem-bers.

- The corporate policies and valuesrelating to the Group's econom-ic, environmental and social per-formance.

- Risk management.

- The procedure for evaluating theperformance of the Board with re-spect to the Group’s economic,environmental and social per-formance.

- The Group’s initiatives relating tothe precautionary approach orprinciple.

(c) Finally, the Report does not con-tain any data on the Group’s new-ly-established company “M&M GASCo S.A.”, established jointly withMOTOR OIL to engage in the sup-ply and trading of natural gas. Theinvestigation and assessment ofthe possibility to include this com-pany in the Sustainability Report2013 has been scheduled for thisyear.

�This symbol is used to indicate areference to the MYTILINEOS GroupAnnual Report 2012.

�This symbol is used to indicate a referenceto the MYTILINEOS Group website, at:www.mytilineos.gr.

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2.2 Report Methodology

The data and information presentedin the Report have been collected us-ing the procedures and scientific cap-ture methods applied by each Groupsubsidiary, as well as from the data-bases kept in the respective corporatesystems. The data capture and the cal-culation of the indicators referring tothe performance of MYTILINEOSGroup are checked and verified usingthe corporate SAP system, officialdocuments (e.g. financial statements),in-house calculation systems avail-able in the respective departments ofeach individual Group company (e.g.custom Excel worksheets created andregularly updated for this specifictask), and internationally accepted cal-culation methods, such as those pro-vided under the OHSAS 18001 –ELOT 1801 Occupational Health &Safety Management Systems and theISO 14001 Environmental Manage-ment Standard. With regard to socialdata, these cover the initiatives takenby each company individually as wellas the actions carried out by

MYTILINEOS HOLDINGS S.A., whichrepresents the entire Group. Thepresent Report contains data ob-tained from direct measurements,while – to help comparisons – the cor-responding data for 2010 and 2011are also given, where available. Ad-ditionally, the Report sections on car-bon dioxide emissions and the per-formance in the Health & Safety do-main provide detailed descriptionsof the calculations used to obtain thevalues for the indicators developed toaddress these subjects.

The procedure to determine the sub-ject areas (materiality) contained in theReport and relating to the challengesthat the Group faces in connectionwith Sustainable Development, wasbased on the following:

� The expectations on the part ofStakeholders in connection withCSR issues, after the conclusion ofthe cycle of Dialogue Forums withStakeholders, organised in 2012for the third year running byALUMINIUM S.A. and METKA S.A.,and for the second year running by

PROTERGIA S.A. (expectations ofparticipants).

� The principles and values of theGroup and its core commitments inthe framework of Corporate SocialResponsibility.

� The introduction and application ofthe procedure to determine thekey issues pertaining to the Group’sEnvironmental and Social footprint,which, in addition to the individualCSR Teams, also involves the Man-agement of all our subsidiaries.

� The results of the working meet-ings of the CSR Teams of theGroup companies and the collab-oration with the Heads of Depart-ments in the context of the datacapture and evaluation tasks. In car-rying out the data capture andevaluation work regarding the in-formation required for the Report,the CSR Teams of the Group com-panies used as guidance the prin-ciples of the GRI standard, to en-sure the maximum possible com-pleteness, comparability, accuracy,

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2clarity and reliability of the Report’scontents.

� The results of the Corporate SocialResponsibility Mapping project,which involved the assessment ofthe significance of the issues per-taining to responsible entrepre-neurship, which are renewed an-nually by the Group companies andform the basis of the SustainabilityReport for each year.

The establishment of the Report’sstructure, the guidance on the datacapture and checking activities, andthe authoring and editing of the Re-port texts were carried out with thescientific support of a specialistprovider, MEDA Communication S.A.– Social Management, Developmentand Communication Company.

The Report was checked by the Glob-al Reporting Initiative (GRI), interna-tional organisation for compliancewith the Application Level B require-ments, in accordance with the self-de-claration made by MYTILINEOS Group.The procedure for third-party check-ing and assessment of the Report (as-

surance) by an external assuranceprovider has been postponed, due tothe need for the CSR Teams of theGroup companies to become accus-tomed to their duties and for the plan-

ning for this procedure to be fullyadopted across all Group companies(e.g. familiarisation with the special-purpose data capture forms, system-atic filing of data capture forms andrelated material, collaboration withthe individual Sections of Group com-panies for obtaining the informationrequired etc.). The external assur-ance procedure is scheduled to be ap-plied starting with the SustainabilityReport 2013.

Finally, as with the Group’s previousReports, the Sustainability Report2012 is published in both Greek andEnglish and is also accessible in digi-tal form over the Internet from theGroup’s website, so as to help inter-ested users who wish to make com-parisons with previous Reports orforward their comments or sugges-tions.

� The terms “Corporate Centre”,“Parent Company”, “MYTILINEOSHoldings” and the name“MYTILINEOS S.A.” refer to thecompany under the business name“MYTILINEOS HOLDINGS S.A.”.

� The terms “Company”, “Business”and the names “MYTILINEOS S.A.”,“ALUMINIUM S.A.”, “DELPHI-DISTOMON S.A.”, “METKA S.A.”and “PROTERGIA S.A.” refer toeach company that represents therespective business activity sector ofthe Group and to that company’sactivities in Greece.

� The terms “Group” and“MYTILINEOS Group” refer toMYTILINEOS HOLDINGS S.A. and toits subsidiaries, all of which to-gether make up MYTILINEOS Group.

Your views, comments or sugges-tions are most welcome. Please ad-dress them to:

Vivian BouzaliGroup Communication DirectorTel.: +30 210 6877300,Fax: +30 210 6877400

MYTILINEOS Groupdeclares that itsSustainability Report2012, which is publishedin accordance with theGuidelines of the GlobalReporting Initiative (GRI)international organisationregarding the publicationof Sustainability Reports,meets the ApplicationLevel B requirementsunder the G3.1 reportingguidelines of the GRI levelstructure.

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3. MYTILINEOS GROUPPROFILE

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With vision, boldness and effi-cient strategic planning,MYTILINEOS Group is flexibly

deploying its resources across its threekey business activity sectors – EPC Proj-ects, Metallurgy & Mining, and Ener-gy. It establishes the products of theGreek metallurgical industry as world-class products in the international

markets, is ranked among the Top 10of the world’s largest EPC contractorsfor energy projects and – through pi-oneering investments in the Energysector – has been firmly established asGreece’s largest private electricity pro-ducer and the very first private natu-ral gas supplier.

MYTILINEOS Group has a stronginternational presence in theEPC Projects and Metallurgysectors. The Group's activities to-day are located in 29 countriesthat span the markets of Eu-rope, Turkey, the Middle Eastand Africa.

Geographical map of Activities

3.1 Structure & Activity Sectors

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Starting with the acquisition ofALUMINIUM OF GREECE S.A. in 2005,which marked a major turning point inits evolution, the Group gave top pri-ority to the efforts to develop and en-hance the competitiveness of its met-allurgy branch, and has since evolvedinto one of the sector’s strongestplayers in SE Europe. ALUMINIUM S.A.and its subsidiary DELPHI-DISTOMON S.A. are today a key driv-ing force for the growth of the Greekeconomy and for the development ofthe Greek periphery. From 1960 to thisday, ALUMINIUM S.A. remains a strongpillar of Greek industry, with an annualproduction capacity that exceeds170,000 tons of aluminium and810,000 tons of alumina. The Com-pany is today the largest vertically in-tegrated alumina and aluminium pro-ducer in Europe, and its industrialcomplex in Ag. Nikolaos (Viotia) appliesproduction and trading practices on a

par with those of the world’s top met-allurgical industries. In addition, 2012saw the launch of the company’s“MELLON” competitiveness-improve-ment programme, designed to safe-guard ALUMINIUM S.A. from the chal-lenges stemming from Greece’s deeprecession and to improve the com-petitiveness of the Group’s Metallur-gy Sector for the next twenty years.

DELPHI-DISTOMON S.A.

DELPHI-DISTOMON S.A. is the secondlargest bauxite producer in Greece andin Europe, with an annual productionof 650,000 tons. The company’s mines,which supply bauxite to ALUMINIUMS.A., are located in the Amfissa regionand employ around 100 people.

Established in 1962, METKA S.A. is to-day Greece’s top EPC (Engineering-Procurement-Construction) contrac-tor, undertaking implementation of

turn-key projects from design andprocurement through to constructionand commissioning. The Companyspecialises in the construction of pow-er plants (combined-cycle, conven-tional thermal and hydropower) andhas achieved significant penetration indeveloping markets abroad, with proj-ects currently under way in Europe,Turkey, the Middle East and NorthAfrica. METKA S.A. competes on anequal footing with global EPC giants,as it has been established as one of thestrongest players in the market for EPCprojects in Europe and beyond, as wellas one of the leading Greek exportingcompanies. The Company has beenlisted on the Athens Exchange since1973 and its share is today a con-stituent of the FTSE-ASE/25 LargeCap index. In parallel, its strong in-dustrial production base allows it tomanufacture custom mechanical partsand to have a strong presence as a spe-cialist contractor for Infrastructureand Defence projects. Finally, the 7thClass Contractor’s Certificate obtainedby METKA S.A. has expanded the op-portunities for its participation in abroad range of public works in theGreek market.

Activity sectors

METALLURGYand MINING

EPC PROJECTS

MYTILINEOS Group - Structure

ACTIVITYSECTORS

GROUPCOMPANIES

OWNERSHIPSTAKE

COMPANYHEADQUARTERS

METALLURGY &MINING

ALUMINIUM S.A.DELPHI-DISTOMON S.A.

100.00%100.00%

Athens, GREECEAthens, GREECE

ENERGYPROTERGIA S.A. X

M&M GAS Co S.A.KORINTHOS POWER S.A.

100.00%50.00%65.00%

Athens, GREECEAthens, GREECEAthens, GREECE

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

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Over the last ten years, MYTILINEOSGroup has been established as thedominant independent energy pro-ducer in Greece by carrying out €1 bil-lion of energy investments in a marketthat opens up significant prospects forthe Greek economy and for Greekbusinesses. Today, the Group has inplace a broad range of operations inthe energy sector, ranging from theconstruction of power plants to thesupply of natural gas and the injectionof the electricity produced into the na-tional grid.

PROTERGIA S.A. is the flagship com-pany of MYTILINEOS Group in the en-ergy sector, bringing under the sameroof the management of all energy as-sets and activities of the Group. The

energy portfolio under the company’smanagement comprises 1200MWfrom Gas-fired Combined Cycle Ther-mal Power plants (CCGTs and CHP /High-Efficiency CHP) and 54 MW fromRenewable Energy Sources (RES), main-ly wind farms and photovoltaic parks,in operation. The strategic priorities ofProtergia are the following:

- To build and/or manage a dynamicand balanced portfolio of energy assetsmainly from gas-fired thermal plants(CCGTs) who successfully meet theever-changing environment of theGreek energy market and to the Eu-ropean Union requirements.

- To enter dynamically the wholesaleand retail electricity markets and theCO2 emissions trading market.

- To expand in the future to neigh-boring countries with high energydemand.

Finally, 2012 was the first year duringwhich all three thermal power plantsmanaged by PROTERGIA S.A. were in

full operation. As a result, the Group’sEnergy Sector is on a par with its oth-er business activity sectors and repre-sents the third pillar on which theGroup’s prospects for improved fi-nancial performance rely.

«M&M GAS Co. S.A.»

M&M GAS Co S.A was established bythe MYTILINEOS and MOTOR OILGroups in 2010 and is active in thesupply and trading of natural gas (liq-uefied or non-liquefied). The Compa-ny seeks to meet the needs of its twofounding Groups in natural gas undercompetitive terms and to also marketnatural gas to third parties. Its estab-lishment has paved the way for the lib-eralisation of the domestic marketfor natural gas, as M&M GAS Co S.A.was the very first company in Greeceto import a private Liquefied NaturalGas (LNG) cargo.

Αctivity sectors

ENERGY

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GROUP ORGANISATIONAL STRUCTURE

In MYTILINEOS Group, we apply theprinciples of Corporate Governance inaccordance with the Greek laws inforce, in order to ensure transparen-cy and operate responsibly across allour business activity sectors. Above all,we seek to safeguard the interests andthe sustainability of our subsidiariesand to maximise the benefits to our

shareholders and to the investingpublic. Guided by the principles ofCorporate Governance, MYTILINEOSHOLDINGS S.A. formulates the strat-egy and lays down the general direc-tions, policies and principles that gov-ern the operation of all Group sub-sidiaries. The organisational struc-ture of MYTILINEOS HOLDINGS S.A.

defines the boundaries of responsi-bility, assisting and facilitating deci-sion-making and implementation inline with the Group’s strategy. Its pur-pose is to establish the relationshipsand roles that guarantee the smoothoperation of the Group, withMYTILINEOS HOLDINGS S.A. acting asthe coordination centre.

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

�On our Website:- Information on the Group’s corporategovernance

AUDITCOMMITTEE

REMUNERATIONSCOMMITEE

CSRCOMMITTEE

INTERNALAUDIT

BOARDOF DIRECTORS

CHAIRMAN &CHIEF EXECUTIVE OFFICER

CO

RPO

RA

TIO

NC

ENTR

E

Group Legal &Regulatory

Affairs

GroupTreasury

GroupFinance

GroupAdministration

Mergers &Acquisitions

InternationalBusinessAffairs

GroupCorporate

Affairs

ENERGYProtergia

M&M GASKorinthos Power

ΜΕΤΑLLURGY

ΑLUMINIUMDelfi-Distomon

EPC WORKS

ΜΕΤΚΑSECTORS

OF ACTIVITY

3.2 Group Governance Structure

1990 1995 1996 1998

2006 2007 20092008

3.3 Business Milestones

Establishmentof MYTILINEOS S.A.

MYTILINEOS S.A.is listed on the

Athens Exchange.

Strategic agreements forcommercial cooperationwith leading metallurgygroups in the Balkan region.

1. Acquisition of a majoritystake in METKA S.A., thelargest metal constructionsplant in Greece.

2. Acquisition of the zinc andlead processing metallurgyplant SOMETRA S.A. in Ro-mania.

Acquisition of SPRIDERENERGY S.A. and DELTAPROJECT S.A., active in thedevelopment, constructionand operation of hy-dropower plants and windfarms.

1. Strategic partnership withEndesa. Establishment ofEndesa Hellas, which aimsto play a key part in theGreek energy market,along with its selective ex-pansion in SE Europe.

2. Completion of the triplemerger by absorption ofALUMINIUM OF GREECES.A. and DELTA PROJECTS.A. with the MYTILINEOSGroup.

1. Signature of a strategicagreement with MOTOROIL in the energy sector forthe construction and op-eration of a commercialpower plant.

2. The High Efficiency Com-bined Heat and Powerplant (CHP/High EfficiencyCHP) enters into commis-sioning. The 334 MW plantis the first thermal plant ofthe Group to be connect-ed to the Greek NationalGrid.

1. The MOTOR OIL andMYTILINEOS Groups an-nounce the establishmentof a joint company for theimport and trading ofNatural Gas in all its forms(LNG, CNG etc.).

2. First full scope EPC ofthe Group in Turkey, un-der METKA and its 100%Turkish subsidiary PowerProjects, for the consor-tium "RWE & TURCASGüney Elektrik UretimA.S."

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2002 2005

2010 2011 2012

20001999

1. Establishment and operation of M&M GAS Co S.A.,the joint company to result from the Group’s strate-gic alliance with MOTOR OIL. It is the first private-sector company to enter the market for trading andsupply of natural gas in Greece, thus marking the ef-fective liberalisation of the market for natural gas.

2. Establishment of Power Projects, a subsidiary ofMETKA S.A. in Turkey. METKA S.A. wins the contractfor construction of Syria’s largest power plant, witha capacity of 724 MW.

3. MYTILINEOS Group concludes with Enel an agreementfor the acquisition of the 50.1% stake held by ENDESASA in Endesa Hellas. With this agreement, MYTILINEOSGroup becomes the sole shareholder of Endesa Hel-las, which is renamed Protergia S.A., and strengthensits position as the largest independent power producerin Greece.

4. METKA S.A. and POWER PROJECTS reached anagreement with “BORASCO ELEKTRIK URETIM SANAYIVE TICARET A.S.” for construction works as well assupply of most of the equipment for a 870 MW ther-mal power plant in Samsun, Turkey.

1. METKA S.A. winsthe contract forthe constructionof a 1250 MWthermal powerplant in Iraq.

2. The 444 MWCCGT plant ofAg. Nikolaos (Vio-tia) enters intocommercial oper-ation.

1. The 436 MW Gas-Fired Combined Cycle Ther-mal Plant (CCGT) owned by KORINTHOSPOWER S.A., enters into commercial operation.

2. METKA S.A. wins its first two EPC contracts forconstruction of a 143 MW power plant and a146 MW wind turbine facility in Jordan.

3. METKA S.A. through its subsidiary in Turkey,Power Projects, wins the contract for con-struction of an energy project in Algeria.

4. 2nd EPC major project for METKA S.A.,through Power Projects, in Algeria. The proj-ect concerns the engineering, procurement, in-stallation and commissioning of twenty-four(24) gas turbine power generation units witha total output of 481,7 MW at site conditions.

5. METKA S.A. completed the construction of Ro-mania's largest power plant, a 860 MWCombined-Cycle Power Plant in Ploesti, Ro-mania.

Acquisition of a 30% stakein Hellenic Copper MinesLtd., a copper processingmetallurgy in Cyprus.

Acquisition of a 43% stakein State-owned vehiclemanufacturer ELVO S.A.through privatisation, alsotaking over the company’smanagement.

Establishment of MYTILINEOSPower Generation and Sup-ply S.A. & MYTILINEOS Hel-lenic Wind Power S.A.

Acquisition of 53% ofALUMINIUM OF GREECES.A., one the largest verti-cally integrated aluminaand aluminium producers inEurope.

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With a disciplined, vision-driven strat-egy that relies on our strong export-ing profile and strict cost controls, andaware of our role as a large, respon-sible corporate citizen, in MYTILINEOSGroup we are enhancing our positionin order to cope with the adverse en-vironment brought about by the eco-nomic crisis in Greece.

� Our consolidated turnover for 2012stood at €1,454 million.

� Through METKA S.A., active in the

EPC Projects Sector, we achieve anunprecedented penetration in for-eign markets, with a signed backlogstanding at nearly €1.7 billion.

� Through a long-term investmentplan, we fortify the traditionallystrong Greek metallurgical industryand secure the current and futureoperation of ALUMINIUM S.A. as thelargest vertically integrated aluminaand aluminium producer in the EU.

� Leveraging the portfolio of energy as-

sets of PROTERGIA S.A. andKORINTHOS POWER S.A., we main-tain our position as the largest in-dependent energy producer inGreece and, through M&M GASCo S.A., as Greece’s largest privatesupplier of natural gas.

Additionally, despite the suffocatingeconomic conditions created by the cri-sis that prevails in Greece, we remainsteadfast in our strategic commit-ments to:

� Promote Greece’s potential forgrowth across the globe, by deliver-ing products and services that gaininternational distinction.

� Showcase the competitiveness ofGreek businesses and the talentand creativity that Greek entrepre-neurship shows in dealing with theobstacles posed by the current ad-verse economic environment.

� Provide unwavering support to theGreek economy and society, secur-ing more than 2,500 direct and in-direct jobs and generating a “socialproduct” which for 2012 stood atnearly €233 million.

� Ensure that each one of our businessactivities is inextricably linked to oursocial and environmental footprint,guided by the principles of Sustain-able Development and Corporate Re-sponsibility and with respect for so-ciety, the environment, our peopleand our shareholders.

14

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

KEY FIGURES – 2012

Turnover (in million €) 1,453.6

EBITDA (in million €) 170.1

Net profits (in million €) 21.7

Social product (in €) 233,290,213

Activity sectors 3

Total number of subsidiaries 3

Total number of countries where the Group is present 7

Total number of production plants 7

Total workforce 1,836

Social expenditure (€) 741,607

Environmental expenditure (€) 10,722,197

Average annual production of Bauxite (tons) 555,983

Average annual production of Alumina (tons) 757,517

Average annual production of finished Aluminium (tons) 165,045

EPC signed backlog (in million €) 1,682.1

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

Total number of shares – MYTILINEOS HOLDINGS S.A. 116,915,862

Share price – MYTILINEOS HOLDINGS S.A.(as at 31-12-2012) (€) 4.47

Total number of shares – METKA S.A. 51,950,600.00

Share price – METKA S.A. (as at 31-12-2012) (€) 9.79

3.4 Strategy & Key Figures

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Energy is a key raw material for the ac-tivities of MYTILINEOS Group and is al-so expected to become a significantsource of income in the near future. Inaddition, our activities extend to thebroader energy sector, through theconstruction of turn-key energy proj-ects (EPC). According to a view that israpidly gaining ground, the con-sumption of the energy produced bymineral fuels is one of the key factorsthat contribute to global warming. Anincreasing number of Governments orState bodies and committees have al-ready introduced or intend to intro-duce legislative and regulatory changesin response to the potential risks as-sociated with global warming.

The Group’s operating margins mightbe affected by changes which may bemade to production facilities of theGroup with high greenhouse gasemission levels and to Group facilitieswith increased requirements in ener-

gy, as a result of new regulatoryarrangements primarily in the EU,where the Group is active. The po-tential impact of the future legislationand of the regulatory framework onclimate change, as well as of the Eu-ropean and international conventionsand agreements, cannot be estimat-ed with any certainty, given the wide-ranging purposes of these potentialchanges. In the future, our Group maybe forced to make substantial invest-ments, due to the requirement forcompliance with the amended legis-lation and the new arrangements. Fi-nally, as its management of CO2 emis-sion rights may post negative (deficit)or positive (surplus) results, and as aconsequence of its high energy con-sumption (due primarily to theAluminium production process), theGroup in the future may have torecognise significant expenditures orrevenues, respectively.

3.6 Collaborations withsocial partners andinstitutions

The application of Responsible Entre-preneurship in practice relies on thecollaboration with social partners andinstitutions, in order to jointly work outand promote solutions to important is-sues of concern at national level. Tothis end, MYTILINEOS Group is devel-oping initiatives and is participating asan active member in voluntary Greekand international organisations, seek-ing to promote CSR and the principlesof Sustainable Development, to ex-change views on CSR-related issues, toimprove its social and environmentalcontribution and to develop respon-sible practices in the broader businesscommunity.

The Group participates in, endorses orsupports voluntary initiatives, such as:

� The UN Global Compact, which theGroup has joined and co-signedsince 2008.

� The Global Reporting Initiative (GRI)international organisation, whose re-porting guidelines on the compila-tion of its Sustainability Reports ithas adopted and applies since 2008.

� The annual Environmental, Socialand Governance (ESG) Survey of theBloomberg international financialdata service, in which the Group par-ticipated for the first time in 2012.

� The Hellenic Network for CorporateSocial Responsibility, in whose work-ing groups and initiatives, aimed atpromoting Corporate Social Re-sponsibility, it participates since2006.

� The Hellenic Federation of Enter-prises (SEV), in whose “Council forSustainable Development” theGroup has participated and whoseCode of Principles it adopts.

� The international standards on Qual-ity (ISO 9001), Environmental Man-agement (ISO 14001) and Occupa-tional Health & Safety (OHSAS

3.5 Impact of Climate Change on business activity

16

18001), which have been adoptedby all Group Companies.

In addition, we are actively contribut-ing to significant developments relat-ing to public policy in the energy sec-tor and directly affecting our businessactivities, such as:

- The promotion of RES investmentsin Greece, which is a contractual ob-ligation of the country in line withthe EU target of a RES penetrationof 20% in final electricity consump-tion by 2020.

- The liberalisation of the domesticelectricity market, which is expect-ed to result in significant benefits forthe national economy, the environ-ment and consumers.

Through our subsidiary PROTERGIAS.A. we participate actively in publicconsultations on specific Bills and ondraft decisions and regulations whichconcern the energy sector.

In the context of our participation inthe above initiatives:

- We promote the liberalisation of thedomestic electricity market, through

the participation of PROTERGIA S.A.in the Hellenic Association of Inde-pendent Power Producers (HAIPP).

- We support the promotion of RES in-vestments in Greece, through the par-ticipation of PROTERGIA S.A. in theGreek Association of RES ElectricityProducers (GAREP) and in the HellenicWind Energy Association (HWEA).

- Through the participation ofPROTERGIA S.A. in the Institute of En-ergy for Southeast Europe (IENE), wealso contribute to the development ofpositions and recommendations andto lobbying on energy-related issuesin the wider region of SE Europe.

Finally, in addition to the abovemen-tioned bodies, MYTILINEOS Group isa member of, and works closely with,the following industry associationsand other organisations:

� The Greek Mining Enterprises As-sociation (SME).

� The Hellenic Management Associa-tion (HMA).

� The Athens Chamber of Commerceand Industry (ACCI).

� The Hellenic-Arab Chamber of Com-merce and Development.

� The Hellenic-German Chamber ofCommerce and Industry.

� The Hellenic-Chinese Chamber ofCommerce and Industry.

� The Hellenic-French Chamber ofCommerce and Industry.

� The Hellenic-African Chamber ofCommerce and Development.

� The Aluminium Association ofGreece.

� The Hellenic Foundation for Euro-pean and Foreign Policy (ELIAMEP).

� The Pan-Hellenic Exporters’ Associ-ation (PEA).

� The Viotia Chamber.

� The Association of SociétésAnonymes and Limited LiabilityCompanies.

� The ALBA Graduate Business School.

� The Association of Industries inThessaly and Central Greece (AITC).

� The Hellenic Institute of Entrepre-neurship & Sustainable Develop-ment (IEA).

3.7 Awards and distinctions

Awards

� 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.

� MYTILINEOS HOLDINGS S.A. was presented with the 3rd Prize in “Best FTSE-ASE/20 Company – 2012” catego-ry of the “MONEY – G. OUZOUNIS Business Awards 2012” institution

� 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

� MYTILINEOS Group was presented with a special award by the “Together for Children” Association in recogni-tion of its generous support of the Association's cause and activities.

� 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.

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

CSRManagement

Process

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4. APPROACH TO CORPORATESOCIAL RESPONSIBILITY

Our approach to Corporate So-cial Responsibility is a multi-faceted and complex process

characterised by our conscious self-commitment to continuous improve-ment. It is directly linked to our busi-ness operations and defines the wayin which we choose each time to moveforward, taking steady steps towardsachieving Continuous Responsible De-velopment, guided by our vision andvalues.

Starting with the definition of our fun-damental commitments regardingCorporate Social Responsibility, we es-tablished a more systematic manage-

ment of our CSR function (shown inthe graph below). We developed a uni-form system for the governance ofCSR and for its integration into our or-ganisational structure, taking into ac-count the particular characteristics ofour business activity sectors. We in-troduced a process of open dialoguewith our Stakeholders, which we im-prove every year; we adopted inter-national standards and committedourselves to international initiativesthat promote responsible entrepre-neurship; and we continue with our ef-forts to set realistic targets and to en-sure the proper disclosure of our per-formance.

6. Evaluation &Improvement of

CSR Practices& Actions

3. Developmentof CSR Policies in

the individualsectors

2. Developmentof CSR Strategic

Directions

1. Assessmentof the current

situation

4. Implementationof CSR Policies

(actions)

5. Μeasurements,Reports &

Communication

Our principleto ensure that the business

excellence and growth of ourGroup are guided by the moralprinciples and the values thatkeep unbroken our alliance

with society, with our peopleand with the environment.

Our dutyto create value for our clients,

business partners andshareholders.

Our goalto maintain our position

as the dominant independentEnergy producer in Greeceand a strong, competitive

European Heavy Industry Groupin the sectors of Energy,

Metallurgy and Construction.

BusinessExcellence

“We are pursuingthe continuous

improvement of ourperformance inorder to achive

optimal businessresults”

Financialsoundness / High

profitability

High efficiency /Excellent result

Competitiveadvantage

Continuousprogress /Innovation

High Safety &Quality standards

HumanCapital

“Our Businesssuccess is based on

our people”

TeamSpirit

Integrity

Communication

Professionalattitude

Health& Safety

at theWorkplace

Society& Environment

“We elevate ourcorporate social

responsibility to adaily practice”

Sociallyresponsible

development

Gaining the trustof the society

around us

Respect towardsthe environment

Safety &Environmental

Conscience

Our values

Our Vision

�On our Website:- Our CSR strategic directions- More details on our approach to CSR

2000 2001 2002 2003

2007 2008 2009

18

4.1 ESG (Environmental, Social and Governance) Milestones

1.Pechiney award toALUMINIUM OF GREECES.A. for best safety resultsamong all alumina andaluminium plants of thePechiney Group.

2.METKA S.A. obtains ISO9001:2008 certification ofits Quality ManagementSystem (the first such certi-fication for METKA datesback to 1997).

ALUMINIUM OF GREECES.A. wins EuropeanAluminium Associationaward for best Health &Safety results among all alu-mina processing plants inEurope.

ALUMINIUM OF GREECES.A. wins EuropeanAluminium Associationaward for best Health &Safety results among allaluminium processingplants in Europe.

1. ELVO S.A. obtains ELOT ENISO 9001:2000 certifica-tion of its Quality Man-agement System.

2. ALUMINIUM OF GREECES.A. wins EuropeanAluminium Associationaward for best Health &Safety results among allaluminium processingplants in Europe.

MEKA S.A. obtains ISO14001:2004 certification ofits Environmental Manage-ment System.

1. Implementation of Corporate So-cial Responsibility Mapping proj-ect in ALUMINIUM S.A., METKAS.A. and DELPHI-DISTOMON S.A.

2. DELPHI-DISTOMON obtainsOHSAS 18001: 2007 certifica-tion of its Occupational Health &Safety Management System.

1. ALUMINIUM OF GREECE S.A. launches op-eration of its 2nd Filter Press for BauxiteResidues Utilisation.

2. MYTILINEOS Group joins the United Na-tions Global Compact on human rights,labour, environment and anti-corruption.

3. Adoption of the G3 Level C reportingguidelines of the Global Reporting Initia-tive (GRI) for the publication of theGroup’s Sustainability Report.

4. DELPHI-DISTOMON obtains ΕΝ ISO14001:2004 certification of its Environ-mental Management System.

2005 2006

2010 2011 2012

2004

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1. ALUMINIUM OF GREECE S.A. isranked No 1 in the world (among allaluminium plants with 1-3 millionworking hours), on the basis of theresults published annually by the In-ternational Aluminium Institute (IAI).

2. ALUMINIUM OF GEECE S.A. ob-tains OHSAS 18001 – ELOT 1801 cer-tification if it’s Occupational Health &Safety Management System.

1. ALUMINIUM OF GREECE S.A. obtains ELOT9001:2000 certification of its QualityManagement System.

2. MYTILINEOS Group joins the HellenicNetwork for Corporate Social Responsibility.

3. ALUMINIUM OF GREECE S.A. launches op-eration of its 1st Filter Press for BauxiteResidues Utilisation.

1. Establishment of the CorporateSocial Responsibility Committeeat the level of the Group’s Boardof Directors.

2. Establishment of Corporate So-cial Responsibility structures in allGroup companies.

3. 1st Dialogue Forum with Stake-holders at the Group level and atthe level of individual companies(ALUMINIUM S.A. and METKAS.A.).

4. Establishment of the ClimateChange Management Sectionunder the Department for GroupLegal & Regulatory Affairs.

5. The Group's Sustainability Reportis officially certified by the GRI in-ternational organisation for com-pliance with the Application Lev-el B requirements of the GRI-G3level structure.

1. ALUMINIUM OF GREECES.A. obtains ELOT ΕΝ ISO14001:2004 certification ofits Environmental Manage-ment System.

2. METKA S.A. obtains OHSAS18001 Certification of itsOccupational Health & Safe-ty Management System.

1. The Group’s Sustainability Report is upgraded to theISO 26000 Social Responsibility Guidance Standard andthe OECD Guidelines on Corporate Social Responsi-bility.

2. ALUMINIUM S.A. and METKA S.A. hold 3rd DialogueForum with Stakeholders. PROTERGIA S.A. holds s 2ndDialogue Forum with Stakeholders.

3. 1st participation of MYTILINEOS Group in the annu-al ESG (Environmental, Social and Governance)Bloomberg Survey, where it is ranked No 1 among allparticipating Greek companies in terms of its overallperformance.

4. ALUMINIUM S.A. permanently discontinues the dis-posal of bauxite residues in the sea.

5. PROTERGIA S.A. obtains ΕΝ ISO 14001:2004 certifi-cation of its Environmental Management System.

6. PROTERGIA S.A. obtains OHSAS 18001: 2007 Certi-fication of its Occupational Health & Safety Man-agement System.

7. PROTERGIA S.A. obtains EN ISO 9001: 2008 certifi-cation of its Quality Management System.

1. The Group's Sustainabili-ty Report is upgraded toGRI-G3.1 Application Lev-el B and is officially certi-fied by the GRI interna-tional organisation forcompliance with the re-spective requirements.

2. ALUMINIUM S.A. andMETKA S.A. hold 2nd Di-alogue Forum with Stake-holders. PROTERGIA S.A.holds 1st Dialogue Fo-rum with Stakeholders.

Human Resources

20

Our commitment:To maintain labour peace by developing performancereward & management systems, ensuring internalcommunication and evaluating individual peformance.To invest continuously in the improvement of labour re-lations, showing confidence in our employees’ skills andencouraging the development of their capabilitiesthat help achieve individual, team and corporate results.

Occupational Health & Safety

Our commitment:To ensure that the target “Zero Accidents & Zero Oc-cupational Diseases” is achieved in the workplaces ofall our companies, by adopting modern methods, pro-moting constant alertness and providing appropriateeducation and training to employees of all levels in theprocuction process across all Group companies.

Anti-Corruption

Our commitment:To adhere to market rules, to participate in internationalanti-corruption standards and to strengthen trans-parency through the dialogue with our Stakeholders andtheir active participation in full alignment with our Val-ues and Principles. To abide by integrity practices andthe corporate governance rules, in order to minimiseour exposure to corruption.

Local communities

Our commitment:To record local needs and help address them, so thatviable conditions for the development of the local com-munities concerned are created, especially in regionswhere the Group’s activities are of a higher visibility.

Human Rights

Our commitment:To strive in a continuous and concerted manner to es-tablish procedures and methods that will define our ac-tions, so that our commitments remain aligned with theprinciples of the United Nations Global Compact re-garding labour rights.

Environment

Our commitment:To identify the sources and assume the responsibility forthe unavoidable impacts of our operations on the nat-ural environment and to carry out concerted “green”actions or programmes to mitigate these impacts, cou-pled with systematic monitoring and application of theGroup’s Environmental Measures and Principles acrossall Group companies.

Corporate Governance

Our commitment:To focus on safeguarding the interests of our share-holders and on creating value for all our Stakeholders.To continously strengthen corporate culture by up-holding integrity, ethical standards and transparency,and by adopting internal practices over and above thestatutory ones to ensure our full compliance with theregulatory framework on corporate governance to thehighest possible standard.

Fair Market practices

Our commitment:To strengthen our efforts for strategic investments at thelevel of products and technologies, also taking into ac-count social and environmental needs and parameters.To promote the gradual incorporation of CSR across oursupply chain and to maintain the ethical characteristicsof our communication policy.

The sustainability of our Group is directly linked to our so-cial and environmental footprint and is founded on the prin-ciples of Sustainable Development. Our sincere commitmentto CSR does not only affect our daily decisions and actions,but also impacts on our relations with our Stakeholders.

In this context, we seek to achieve the best possible un-derstanding of the implications of our business activities,which reinforces our efforts to adhere to our individual com-mitments, which are presented below, and thus improveour overall maturity and competitiveness.

4.2 Corporate Social Responsibility – Fundamental Commitments

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For MYTILINEOS Group, the design andapplication of the Corporate Social Re-sponsibility structures – or CSR Gover-nance system – is indicative of our ap-proach to the concept of CSR.

Our Group’s CSR Governance systemconsists of: (a) the CSR Committee,which functions at the level of theGroup’s Board of Directors and is re-sponsible for monitoring and ensuringthe correct application of ResponsibleEntrepreneurship; (b) the CSR Teams ofour subsidiaries, which carry out specifictasks and have clearly defined obliga-tions; and (c) the Group Communica-tion Department, involved in CSR ac-tivities in a crucial coordinating role. Theintegration of the CSR Governance Sys-tem in the Group's organisationalstructure relies on a uniform set of pro-cedures and on a specific reporting hi-erarchy, in order to overcome any ob-stacles which might result from the par-ticular characteristics of our individualbusiness activity sectors.

The aims of the Group’s CSR Gover-nance system are:

(a) To highlight the scope and depth ofthe relevant concepts, with the ultimategoal to prevent business, social and en-vironmental risks.

(b) To identify and implement policiesand initiatives that will substantially con-tribute to the achievement of Sustain-able Development; and

(c) To balance the economic, social andenvironmental implications of theGroup's business activities, while gen-erating value for its shareholders andfor all its other Stakeholder groups.

In parallel, the Group’s ProfessionalEthics Code plays an important part inensuring the commitment of the entireGroup to the requirements of Re-sponsible Entrepreneurship. The Codecovers the rules of acceptable conductregarding the Management’s conducttowards its employees and the rulesthat govern the conduct of our em-ployees between themselves and to-wards third parties, especially towardsour Stakeholder groups.

The Group’s Corporate Social Respon-sibility Committee is composed of twoBoard members without executive au-thority within the company, with theother Committee members being ex-ecutives of MYTILINEOS HOLDINGSS.A.

The CSR Committee is responsible tothe Board of Directors for monitoringand ensuring the correct application ofCorporate Social Responsibility in theGroup in terms of policies, goals/tar-gets, actions and results, in connectionwith environmental, social and ethicalissues in the internal, as well as the ex-ternal environment of the Group com-panies. The CSR Committee may alsoact as advisor to the Group’s Executive

Management and to the relevant BoardCommittees on the above issues, to as-sist in their implementation in a morecomplete manner.

During 2012, the CSR Committee heldtwo meetings:

� On 24.04.2012, with the followingitems on the Agenda: (a) TheAluminium History Museum in AspraSpitia (Viotia); (b) the events organ-ised at the Athens Concert Hall; (c)the update on the Group’s partici-pation in the BLOOMBERG, GRI andCarbon Disclosure Project organisa-tions; (d) Volunteerism; and (e) theproposal regarding the appointmentof new members to the Committee.

� On 6.11.2012, with the followingitems on the Agenda: (a) TheAluminium History Museum in AspraSpitia (Viotia); (b) the events organ-ised at the Athens Concert Hall; (c)the Group’s financial assistance to thePenteli Branch of the Patriotic Insti-tute for Social Welfare and Aware-ness (PIKPA); (d) the update on theGroup’s participation in theBLOOMBERG and GRI organisationsand the setting of the Group’s nextobjectives; (e) other matters regard-ing the Group’s progress towards Re-sponsible Entrepreneurship.

4.3 Governance of Corporate Social Responsibility

�On our Website:- The Group’s Professional Ethics Code- The Group’s CSR Governance structure

CSR COMMITTEE Composition

CSR COMMITTEEComposition Name Executive / Non-

Executive MembersIndependentMembers

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

22

Our continuous efforts to apply Re-sponsible Entrepreneurship in practice,rely on our collaboration with ourStakeholder groups, in order to joint-ly work out and promote solutions toissues of mutual concern.

In this context, transparency in com-munication and open dialogue are keyto fostering mutual trust and collab-oration with all our Stakeholder groups– employees, local communities,clients, suppliers, shareholders, thePress & Media, business partners,

public bodies and voluntary organisa-tions.

In 2010, in an effort to strengtheneven more the collaboration and en-gagement of all our Stakeholders,we organised for the first time dedi-cated consultation events (DialogueForums) to all our subsidiaries. This ini-tiative, which today has been estab-lished as an institution within theGroup, is continuing with consisten-cy and is subject to self-evaluation andself-improvement procedures. In

adopting these procedures, we aim toestablish specific internal processesthat will allow us to assess the pro-posals and recommendations put for-ward by our Stakeholders and to in-corporate them in the formulation ofour annual CSR strategic directions.These processes will also allow us toconsolidate the application by oursubsidiaries of the precautionary prin-ciple regarding economic, environ-mental and social issues, thus ensur-ing their sustainable development.

4.4 Stakeholder engagement

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

Stakeholder Groups Approaches to Stakeholder engagement & collaboration

Employees

- Regular and ad hoc meetings between the Management and representatives ofemployee unions.

- Representation of employees in the BoD and in the General Meetings of theShareholders.

- 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 ResponsibilityOrganisations

- Annual consultation (Dialogue Forum) on CSR-related issues.- Participation at events.

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

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

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

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

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

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Overview & key issues raised in the Consultations of the Group Companieswith their key Stakeholder groups.

(The Dialogue Forum was organised on 11 December 2012 at the company's plant inAspra 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 participantson almost all the issues raised. Emphasis was placed on the “MELLON” programme, designed toboost 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 inVolos).

The response to the Forum was very positive, serving as recognition of the efforts that the com-pany and the Group made in order to hold this year's Forum locally. The views presented were veryeffective in terms of the issues raised, while and the comments made by the participants focusedprimarily on issues relating to the company’s business growth.

(The Dialogue Forum was held on 26 November 2012 at the company's headquartersin Athens).

The Company’s presentation of its key CSR activities and of the CSR policies and actions it hasadopted led to a particularly constructive dialogue with its Stakeholders. The Forum covered is-sues such as labour practices, the environment, management systems, health & safety, compli-ance with the laws and relations with local communities, thus providing participants with a com-plete picture of the company's activities.

Key issues raised & expectations by Stakeholder group

� Concerns were expressed by the Municipality of Kyria-ki about the impact of Bauxite residues on the envi-ronment. The Company was asked to supply quantifiedinformation to certify the extent of this impact and todisclose information on the respective protection meas-ures.

� The matter of adhering to the ratio for recruitment ofemployees from the local communities was raised – arequest was made for the recruitment of more em-ployees from the Municipality of Kyriaki.

� The wish was expressed for a shift in the company’s so-cial policy to the immediate problems of the local com-munities, with participation from all Municipalities. The

reduction of the amount allocated by the company in2012 for its social policy compared to previous years wasdiscussed.

� Emphasis was given to the need for industrial compa-nies of the size of MYTILINEOS Group to remain inGreece. This particular Stakeholder group expressed itsconcerns in connection with the risks to social cohesionfrom the exploding unemployment and the companywas asked to provide help for dealing with the problem,by increasing its social product. The Regional Adminis-tration stressed that it supports all company's activitiesto provide assistance and relief to vulnerable socialgroups.

1. LOCAL AUTHORITIES

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

2. EMPLOYEES

24

� Satisfaction was expressed about the fact that this year’sDialogue Forum was held in Volos, as the relevant re-quest had been made during the Dialogue Forum 2011.The subject of robust investments and collaborations asan answer to the financial crises was presented, and pri-ority was given to the allocation of the social productof businesses.

� References were made to the lack of a well-organisedinvestment plan in Greece. The wish was expressed forthe company to remain in Volos area and to increase itsproduction output and employability in the local com-munity. It was also mentioned that sustainable businessesalso result in sustainable local communities.

� In connection with its collaboration with the Associa-tion of Industries in Thessaly and in Central Greece, theRegional Administration put a request to the companyto assist financially the establishment by the Associationof a centre for support and encouragement of youngentrepreneurs.

� Thanks were expressed to the company for its contri-bution in helping meet the social needs of the local com-munity, as well as for its unreserved and discreet sup-port to the Municipality, whenever this was requested.Mention was made of the synchronised swimming cham-pionships, the donation of school books, the support oflocal events and the provisioning of local grocer’sstores. Finally, satisfaction was expressed about thegrowth of the company’s investment in the local com-munity, which during 2012 was increased, in responseto the request made during the Dialogue Forum 2011.

� Very positive comments were made about the Group’sCSR policy, focusing on the concept of Transparency.Representatives of the Orchomenos and Karystos Mu-nicipalities confirmed the very good collaboration be-tween the company and the respective Municipalities.Additionally, regarding the request for more invest-ments in the Municipality of Orchomenos, it was men-tioned that the Municipality is open to proposals forcollaboration and owns lands on which photovoltaicsystems can be installed.

� The Mayor of Karystos stated his satisfaction with theway in which «PROTERGIA S.A.» responds to the needsof the local community and spoke of the good col-laboration between the Municipality and the com-pany’s executives.

1. LOCAL AUTHORITIES

� No particular positions were presented, as negotiationsbetween employees and the company’s Manage-ment regarding their employment contracts are underway. The employees expect that jobs will be maintainedduring the particularly difficult period of the financialcrisis. During the time since last year’s Dialogue Forum,namely in December 2012, the company’s Managementand the Union of Company Employees signed a newagreement, under which the plant’s jobs and produc-tion capacity are maintained, with substantial cost ra-tionalisations introduced on a sustainable and long-termbasis.

� The employees expressed their overall appreciation ofthe company and their trust in it, together with theirhopes that this very good climate of collaboration willcontinue. Additionally, the company and the Group ingeneral were asked to remain closely in touch with theemployees and their problems, as they have done sofar. The raise in employees’ earnings, which the com-pany decided despite the financial crisis, was mentionedwith very positive comments.

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� A proposal was made for participation of the com-pany’s shareholders in the Dialogue Forum 2013. Thewish for the company to continue investing in theregion was expressed.

� It was pointed out that the KORINTHOS POWER in-vestment could have been made in the Volos region,as initially planned. The facts which led to the changein this decision were mentioned, emphasising the lo-cal community’s lack of readiness to accept this par-ticular investment.

� Great significance was given to the fact that the com-pany is located within the city and yet there are nocomplaints regarding environmental impacts or oth-er issues, such as noise. The wish was expressed forthe company’s development and for the continua-tion of the good collaboration between the em-ployees, the shareholders and the Management thatpromotes social stability.

� The Company was asked to broaden its contacts withlocal labour unions.

4. PRESS & MEDIA

� Concerns were expressed about whether the com-pany has in place a mechanism linking work with pro-ductivity. An issue raised with some insistence wasthe absence of employees from Lidoriki.

� The concerns regarding the pollution to the envi-ronment from the company’s activity were stressed,together with the need to rehabilitate any adverseeffects to the environment. More specifically, the ap-pearance of tar in the Corinthian Gulf waters wasmentioned, and the company was asked to provideclarifications.

� The Company’s support for the reforestation projectin the broader region was requested.

6. CHURCH

� Thanks were extended to the company for its supportof the local Diocese’s foundations, which carry out in-valuable social work. The need for a more social pro-file during these times was expressed, taking of courseinto consideration the difficulties that the companyis facing.

� A proposal was made for devising a mechanism whichwill help assistance to be directed to the social groupsor to the individuals who really need it. The regularrecruitment of young people was also proposed, sothat they may gain professional experience which willbe useful to them in the future.

� Ideas were put forward for supporting educationalcoaching establishments in the region by provisioningthem with heating oil, and for the organisation of eventsto promote optimism and strengthen social cohesion.

7. ASSOCIATED COMPANIES

� It was stated that the company’s initiative to engagein dialogue with its Stakeholders creates a very posi-tive image.

� It was asked whether the Group-via the company- in-tends to develop facilities for the use of biomass.

� Concerns were expressed about the continuing in-stallation of photovoltaic systems, especially on flat fer-tile land, when mountainous and arid land could beused for the same purpose. The question was thenraised about the existence of a specific land planningmap regarding photovoltaic installations.

5. VOLUNTARY ORGANISATIONS

� Special thanks were extended to the company for itssupport of the local branch of the Hellenic CancerSociety.

� Thanks were extended to the company for its supportof the Hellenic Society for Disabled Children (ELEPAP)during the last ten years. Emphasis was placed on the“financial adoption" by METKA – the only one of allthe local industries to do so, as it was stressed – ofone child without health insurance from the 12 chil-dren which ELEPAP takes under its care every year.

� ELEPAP presented its plans for a new day-care, edu-cational and creative activity programme for pre-schoolchildren, and invited the company to provide finan-cial assistance for this programme during 2013, as ithas been delayed due to financial difficulties.

3. BUSINESS PARTNERSAND PROFESSIONAL ASSOCIATIONS

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This section provides a brief overview of the approach of our subsidiaries or of the initiatives that they have takenin response to the requests made by their Stakeholders during the consultations (Dialogue Forum events) held in2011. Relevant details are for ALUMINIUM S.A. and METKA S.A., as in the case of PROTERGIA S.A. no requests weremade requiring the company to respond with specific actions.

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

Key Stakeholder expectations � Company Response �

DIALOGUE FORUM 2011

�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

Stakeholder Groups: Local Communities

- The wish was expressed for the company to show greater trust to suppliers from the local com-munities.

- The Viotia Chamber of Commerce proposed a new meeting to be arranged with the companyfor the presentation of its proposals under a systematic joint effort to address CSR-related issues.

- The representative of the Regional Administration expressed a demand for the company to in-crease its social product.

- The collaboration of the Region with the company was proposed, using as leverage the data whichthe former can supply and the latter can use in its initiatives to support and provide relief to vul-nerable social groups.

� During 2012, the company continued to support its local sup-pliers.

� The Company's financial assistance to social bodies and soci-eties was maintained at 2011 levels. The exceptionally adverseeconomic conditions during 2012 did not allow the compa-ny to increase its social product. However, its financial supportof vulnerable social groups through various foundations re-mained substantial.

Stakeholder Groups: Employees

- Expect the company to maintain jobs in the current difficult period of financial crisis.- The issue of the threats made by contractors about salary reductions was raised; it was point-

ed out that the company can play a part in this, as contractors are its direct partners.- Particular emphasis was placed on the need for a more active contribution by the company

in helping address issues faced by employees (more help and increased sensitivity).- The need was pointed out for more investments in the company’s facilities, because of their

age.

� During 2012, a three-year bilateral company-level agreementwas signed by the Management and the employees.

� The jobs were maintained.� Facilities are improved through the necessary investments as well

as through adequate maintenance. A significant investmentmade involved the substitution of fuel oil with natural gas ascombustion fuel. This investment has been fully completed inthe Alumina processing plant, and its completion in theAluminium 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 wasstressed.

- It was stressed how important it is for the company to be willing to follow closely developmentsin the local communities where its operations are located. Particular emphasis was given to cul-ture, with the expectation than the company will continue to support it.

� The support of cultural activities was continued. ALUMINIUMS.A. was the exclusive sponsor of the publication of the twobiannual issues of the literary magazine "Emvolimon" and ofthe events held at the magazine's lounge.

� The Company continued to support the local cultural societiesand their events, by making available premises (halls), equip-ment 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,with time requested for a more detailed presentation of local problems.

- Proposal for innovative actions to protect the environment, always combined with actions aimedat sensitising citizens, and invitation to participate in a dialogue on the environmental propos-als of the Municipality of Livadia.

- It was observed that, despite the company’s significant activities in the CSR domain, no budgetwas presented on its social contribution.

- Complaints were relayed from agricultural cooperatives for dust deposits on cultivations.

� During the Dialogue Forum 2012, time was allocated for thepresentation of local problems by the Municipalities, in responseto their request.

� The Company remains open to dialogue and collaborations,and will examine all proposals which could help further improveissues relating to the protection of the environment.

� Data (both quantitative and qualitative) on the company’s so-cial contribution are presented annually as part of the Group’sSustainability Report.

DIALOGUE FORUM 2011

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Key Stakeholderexpectations � Company Response �

Stakeholder Groups: Associated Companies – Suppliers

- The Company can play an important part in the ab-sorption of unemployment.

- The need was expressed, for the second year in arow, for the systematic measurement of total car-bon dioxide emissions from the company’s activi-ties, and details were requested on the subject.

� During a very difficult year with high unemployment and underemployment rates, METKA S.A. managed tomaintain jobs, as the largest share of employee departures represents inter-Group transfers.

� Committed to its strategic goal to strive to protect the natural environment and to promote consistency andtransparency in CSR issues, in late 2012 the company launched the development of its Quality ManagementSystem regarding measurement and reporting of its greenhouse gas emissions (greenhouse gas inventory).The procedures regarding the greenhouse gas inventory and the company-level measures regarding energymanagement and savings will be completed at the end of 2013 and the relevant results will be announcedin early 2014.

Stakeholder Groups: Non-Governmental Organisations (NGOs)

- The Company was requested to continue to sup-port and provide financial assistance for theirwork.

� METKA continued to actively support NGOs, societies, associations and public benefit foundations, with em-phasis on the support of children with disabilities and chronic diseases, through regular sponsorships to spe-cial groups such as the Volos Branch of the Hellenic Society for Disabled Children (ELEPAP), the Magnisia Branchof “FLOGA” (“FLAME” – The Association of Parents of Children with Neoplastic Diseases), and the HellenicTherapeutic Riding Association.

Stakeholder Groups: Business partners

- It was proposed to the company to consider the Vo-los area as an area for its future investments.

- The idea was proposed to adopt the institution ofscholarships to engineers with specialisations of in-terest to the company, and the possibility for fur-ther collaboration with Tertiary Education Institu-tions was pointed out.

� During 2012, SERVISTEEL S.A., a subsidiary of METKA S.A. located in Volos, invested in the production ofelectricity through the installation of a 2.50 MWp photovoltaic station in the open grounds of its facilities.In parallel, as part of its efforts to modernise the installations of its Volos plant, METKA S.A. installed pho-tovoltaic panels at the roofs of the plant's buildings. These activities form part of the company’s overall planinvolving constant investments in its local facilities in the Volos area and the support of the local commu-nity.

� In line with its commitment to closely collaborate with Tertiary Education Institutions, the company providedpractical training opportunities to students of various disciplines, so that they can obtain work-related knowl-edge 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-tutions to support the dissemination of techno-logical knowledge.

- Proposal for adopting the institution of scholarshipsto engineers with specialisations of interest to thecompany.

- Proposal for further collaboration with Tertiary Ed-ucation Institutions.

- References were made to the Health & Safety of em-ployees, and the company was asked to clarifywhether or not the Management is participating ac-tively in the dialogue with employees on the rele-vant issues.

� Seeking to assist research institutions and support the dissemination of technological knowledge, during 2012METKA S.A. participated actively in the research project of the National Technical University of Athens withthe title “Development of a System for Monitoring and Optimising the Operation and Maintenance of a Com-bined-Cycle Power Plant”. The project is coordinated by the Laboratory of Thermal Turbo Machines of the offaculty of Mechanical Engineering, in collaboration with the Electric Energy Systems Laboratory of the facul-ty of Electrical and Computer Engineering.

� The issue of transparency and the method for the company’s certification with regard to the documentationof transparency will be investigated at Group level under a 3-year plan.

� A Health & Safety Committee functions at the Volos plant, composed of Company employees and Manage-ment executives, thus strengthening the dialogue between the employees and the Management on the rel-evant issues. Regular and ad hoc meetings are held to evaluate work conditions, and measures to improvethem are also proposed. The Management evaluates all proposals and provides responses to all Occupation-al Health & Safety issues raised by its employees.

� During 2012 the company, taking into account the financial crisis prevailing in Greece, gave priority to theneeds of vulnerable social groups, increasing its financial assistance to social actions and its sponsorships anddonations from 3% to 37% of its total social expenditure.

Stakeholder Groups: Press & Media

- The employees’ concern for the future of their jobsand for the well-being of their families was stressed.

- It was stressed how important it is for the compa-ny to be willing to follow closely developments inthe local communities where its operations are lo-cated. Particular emphasis was given to culture, withthe expectation than the company will continue tosupport it.

� In a particularly adverse economic environment, the company managed to keep stable the number of its em-ployees and to maintain all benefits to them without cutting jobs or other financial benefits. Indeed, the com-pany raised the earnings of its Volos plant employees, on the basis of the new collective employment con-tract signed during 2012.

� In parallel, the company provided again financial support for Arts & Culture, investing 17% of its social ex-penditure in related actions.

Stakeholder Groups: Local Authorities

- The need was expressed for a shift of priorities by thecompany and in general by the Group to the infra-structure needs of the local communities, particularlyduring the period of the current crisis. This was ac-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 con-tribution to the local communities for 2011.

� Maintaining close ties with its local communities, the company provided substantial financial support to in-frastructure works in the Volos Swimming Centre, where the 2012 Junior Synchronised Swimming Cham-pionships were hosted, and was the Event’s Exclusive Sponsor. It also supported extensively various educa-tional institutions, such as the Aliveri Nursery and Upper Secondary School (Lykeio).

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4.5 CSR Performance in 2012 & Targets for 2013

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

LABOUR PRACTICES(description)

GroupCompany

Targetfor 2012

Status of Targetfor 2012

Targetfor 2013

Training hours per year and per employee –Executives.

2.5 � >3

70.0 � 70.0

Training hours per year and per employee –Administrative employees.

3 � >3

34.0 � 35.0

Training hours per year and per employee –Labour & Technical personnel.

2.0 � >3

50.0 � 50.0

Average training hours per year and per employee(Men).

1.5 � >3

52.0 � 52.0

Average training hours per year and per employee(Women).

1.5 � >3

35.0 � 35.0

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

0 � 0

0 � 0

Percentage of employees receiving performanceand career development reviews.

80% � 80%

100% � 100%

100% � 100%

�: Target achieved �: Target not achieved

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

HUMAN RIGHTS(description)

GroupCompany

Targetfor 2012

Status of Targetfor 2012

Targetfor 2013

Percentage of inclusion of specific clauses on HumanRights in Company contracts with significant suppliers,contractors or other business partners.

5% � 5%

Total incidents of discrimination.0 � 0

0 � 0

Total incidents of child labour. 0 � 0

Total incidents of forced labour. 0 � 0

Total incidents of employment of young contractedpersonnel in hazardous work. 0 � 0

Total incidents involving rights of indigenous people. 0 � 0

Percentage of security personnel directly employed bythe company who have received formal training inHuman Rights.

100% � 100%

ENVIRONMENT(description)

GroupCompany

Targetfor 2012

Status of Targetfor 2012

Targetfor 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 thetreatment of bauxite residues (Filter Presses). 16% � 100%

Solid waste sorting. > 80% � > 85%

Hazardous waste collection. >30 �>50%/ 1000t

of grossproduct

Generation of unsorted basin waste. <20 t/cellAB � < 20 t/basinΑΒ equ

Final waste disposal for the Alumina production line. <20 kg/t AH � < 10 kg/t AHof waste

Total abstraction of water (industrial use + potable). 14.560 m3/d � < 14.500m3/day

Reduction of direct consumption of energy fromprimary sources by 5%. By 5%

Reduction of direct consumption of energy fromnon-renewable sources by 5%. By 5%

Conservation of energy and/or increase of energysavings due to improvements and process reengineering. By 10%

Reduction of water consumption. By 10%

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�: Target achieved �: Target not achieved �: Target for 2013

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

ENVIRONMENT(description)

GroupCompany

Targetfor 2012

Status of Targetfor 2012

Targetfor 2013

Total incidents involving significant spills.< 30 � < 25

0

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

Percentage of waste recycled. 100%

IΡΡ: regular maintenance of the plant to maintain itshigh efficiency, which results in the least possibleburden to the environment.

100% � 100%

SOCIETY(description)

GroupCompany

Targetfor 2012

Status of Targetfor 2012

Targetfor 2013

Outlays to local suppliers as a share of totalpurchases budget. 30% � 30%

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

LABOUR PRACTICES(description)

GroupCompany

Status of Targetfor 2012

Targetfor 2013

Certification of the company’s Occupational Health & SafetyManagement System in accordance with the OHSAS 18001International Standard.

�To maintain

thecertification

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

�

HUMAN RIGHTS(description)

GroupCompany

Status of Targetfor 2012

Targetfor 2013

Addition of specific framework clauses (“Code of Conduct”) onHuman Rights as a condition for the conclusion of commercialagreement contracts.

� �

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

ENVIRONMENT(description)

GroupCompany

Status of Targetfor 2012

Targetfor 2013

Control of the consumption of raw materials. �Improvement of disposal costs for Bauxite Residues. �Control of the consumption of energy. �Monitoring of the percentage of the filtrate from the treatmentof bauxite residues which is recycled in the production process,leading to reduced abstraction of water.

� �

Control and, within our technological and financialcapabilities, continuous reduction of solid and liquid wasteand waste gas.

� �

Installation of air duct for transporting hot air from the aircompressors to the work rooms in the company’s subsidiarySERVISTEEL S.A. � �

Development of management system for greenhouse gasemissions. � �Lowest possible impact on biodiversity during the constructionof RES projects. Full and strict compliance with the approvedEnvironmental Terms of power plants (thermal and RES-based).

� �

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

� �

SOCIETY(description)

GroupCompany

Status of Targetfor 2012

Targetfor 2013

Continuation of the collaboration and dialogue withStakeholders and response to the fullest possible extent totheir requirements, as these were expressed in the DialogueForums held in 2012.

� �

� �

� �Maximisation of social dissemination of actions & programmesand focus on supporting vulnerable social groups in the currentadverse economic juncture. Establishment and development ofclose, stable and long-term ties with social partners and otherbodies and organisations.

� �

�: Target achieved �: Target not achieved �: Target for 2013

5. ECONOMIC PERFORMANCE

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Our consolidated turnoverfor 2012 stood at

€1,453 million.

The Group’s Business Investmentsreached the amount of

€92million.

We generated a “social product”with a total value of

€233million.

Driven by our desire for contin-uous development andprogress and seeking to al-

ways be at the forefront of develop-ments, as we have always done inthe course of our long history, inMYTILINEOS Group we consistentlypursue our vision to become a strongand competitive European “heavy in-dustry” group. In an constantlychanging economic environment,maintaining high liquidity and miti-gating financial risk are key to en-suring the smooth continuation ofinvestments in all our activity sectors.

Drawing on our highly qualified hu-man resources, significant assets andfinancial robustness, we aim toachieve a steady organic growth in thewider region of Europe, Middle Eastand Αfrica, and we focus on consol-idating the significant synergies avail-able between our core activity sectors,seeking in this way to ensure their bal-anced development. At the sametime, through our investment plan, wedevelop methods to curtail costs andwe exploit the capabilities of sophis-ticated risk-hedging tools and tech-niques to optimise our economic per-

formance in the coming years.

Our core development goal is “TO EX-PLOIT THE OPPORTUNITIES OPENINGUP THROUGH THE LIBERALISATIONOF THE ENERGY MARKET” inGreece. The Group is currently hold-ing a dominant position in the Greekmarket, as it is the country’s largestelectricity producer after the PPC.With persistence and a clear focus onconcrete targets, we carried out anenergy investment plan in excess of€1 billion during the last few years,managing to overcome business andregulatory difficulties in the process.Today, these efforts are rewarded, asat the end of 2012 a substantial partof our total turnover and operatingprofits came from our activities in theEnergy sector.

In addition, the goals of “SEEKINGNEW VERTICAL INTEGRATION PROJ-ECTS OR PROJECTS FOR EXPANDINGMETALLURGY OPERATIONS” and of“INCREASING COMPETITIVENESSTHROUGH STRATEGIC INVEST-MENTS AND RISK-HEDGING METH-ODS” show the Group’s orientation inthe Metallurgy sector, while the focuson “UTILISING THE SIGNIFICANT IN-DUSTRIAL KNOW-HOW AND IN-FRASTRUCTURE” and on “MAIN-TAINING THE GROUP’S LEADINGROLE IN ENERGY PROJECTS INGREECE AND EXPANDING ITS OP-ERATIONS ABROAD” is indicative ofthe Group’s strategic priorities in theEPC Projects sector.

5.1 Key economic value data

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* 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].

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

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 subsidiesand other relevant types of subsidies (€) 1.084.914 133.739 0

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5.2 New investments

The economic climate during 2012 re-sulted in suffocating conditions forGreek businesses, characterised pri-marily by the uncertainty regarding theprogress of investment plans. In thisnegative juncture, MYTILINEOS Group,relying on its strong export orientation,consistent cash flow and liquidity

management and strict cost controls,succeeded in posting financial resultsthat stood at levels comparable to itsrecord-high ones of 2011.

2012 saw the completion of our sub-stantial energy investment plan, despitethe particularly adverse conditions.The end of the year found the Groupin a strong position, as it has achieved

its strategic goals – to globalise its busi-ness operations, to improve its com-petitiveness and to build a balancedportfolio of industrial activities, thus lay-ing solid foundations that allow it tolook to the future with optimism.

In particular, developments during2012 in the Group’s activity sectorswere as follows:

EPCProjects

Throughout last year, METKA S.A. wasfaced with the consequences of thevolatile economic environment. The lackof confidence in Greece led to serious ob-stacles in the company’s international ac-tivity, making its efforts to secure newprojects all the more difficult. At the sametime, the company had to address the is-sues and challenges caused by the esca-lating tension in Syria. With a strongsense of responsibility, the company’sManagement took all necessary measuresto ensure the protection of its employ-ees and facilities, working out alternativeways in which work on its local projectcould progress, so that the project couldbe completed as soon as possible. Despitethese obstacles, the company remainedsteadily on a positive course during2012, rising to the challenges with a highlevel of professionalism and drawing onthe credibility and reliability it had buildfor itself over the previous years.

Remaining committed to its strategy ofinternational orientation and continuedenhancement of its exporting profile;METKA continued to generate most ofits revenues abroad and achieved a sub-stantial expansion of its portfolio of in-ternational projects.

Energy

For MYTILINEOS Group, thecommercial operation of thePROTERGIA S.A. plant inAg. Nikolaos and of theKORINTHOS POWER plant, inJune 2011 and April 2012, re-spectively, signalled the comple-tion of the first phase of theGroup’s investment plan withinstalled thermal capacity 1,2GW.Additionally, on 17/1/2013 theMinistry of Environment, Energyand Climate Change issued thecommercial operation licence forthe High Efficiency CombinedHeat and Power plant (CHP/HighEfficiency CHP) of ALUMINIUMS.A. This plant was already in tri-al operation since 28/11/2012, asthe Electricity Market Operator in-cluded it in the national gridconfiguration as a DistributedHigh-Efficiency CHP Plant in trialoperation, following the conclu-sion of an agreement underwhich the electricity produced bythe plant and injected into thenational grid was measured andpriced accordingly.

Metallurgy& Mining

We have given priority to the ap-plication of strict cost controlsand to reducing operating costsin ALUMINIUM S.A., in order toimprove the company’s compet-itive position. The satisfactoryprogress of the “MELLON” com-petitiveness improvement pro-gramme was already reflected inthe sector’s financial results forthe second half of 2012, whichwere markedly improved com-pared to the first half of the year.More specifically, the actionswhich ALUMINIUM S.A. had iden-tified under the “MELLON” pro-gramme by the end of 2012 ac-count for more than 80% of theprogramme’s final cost savingstarget. The full recognition of thebenefits of these actions in the fi-nancial results posted byALUMINIUM S.A. and by theGroup has already started during2012 and is expected to be grad-ually completed during 2013.

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26. EMPLOYMENT &LABOUR PRACTICES

For MYTILINEOS Group, the pro-motion of dialogue and collabo-ration with its people on issues of

common interest is a daily concern. Ouremployees and their representatives areencouraged to express their opinion onbusiness, social and environmental is-sues through appropriate constructivechannels such as, for example, their par-ticipation in the consultations withour Stakeholders, in line with our com-mitment to open and constructivecommunication that promotes thepublic good as well as mutual interests,as well as their participation in the reg-ular and ad hoc meetings between theManagement and their collectiveUnions, in the annual employee per-formance review procedures, etc. Ad-ditionally, meetings with employees are

held in all our subsidiaries to providethem with information on importantcorporate matters and on potential op-erational changes. With respect to thelatter, all Group employees affected bysuch changes are informed of themwithin the time limits prescribed by theapplicable laws, which in several casesexceed the statutory ones. Finally, in allgeographical locations of its operationsabroad, our subsidiary METKA S.A.complies with the applicable nationalor regional laws and adheres to em-ployment and labour practice standards,which are the same as those that ap-ply in Greece.

100% of our businessunits have in place OccupationalHealth & Safety ManagementSystems certified in accordancewith the OHSAS 18001international standard.

We hired

374new employees.

85% of our employeescome from our localcommunities.

We provided

54,029training hours, increasing theaverage hours of training per yearper employee to

34.2 h.

�On our Website:Our Management Approach regardingLabour Practices

36

6.1 Employment

A standing goal of MYTILINEOS Groupis to successfully attract competentprofessionals and to support theirdevelopment, ensuring that their ca-reers evolve within our Group com-panies and contribute to our efforts foreconomic, social and environmentalprogress towards sustainable devel-opment. We recognise and appreciate

the efforts of our people, whose sci-

entific qualifications; effectiveness

and professional dependability help us

meet our business targets in the con-

stantly changing and difficult economic

conditions of the last years.

On 31.12.2012, MYTILINEOS Group

employed a total of 1,965 people in-

cluding freelance professionals and

subcontractor personnel, slightly

(2.7%) less than 2011 – a developmentattributed to the difficult economicconditions in Greece. Almost 89% ofour people are employed in mining ac-tivities, aluminium production andEPC construction projects, while 8%are employed in the Energy sector, ashare that is expected to increaseduring 2013 driven by the entry ofPROTERGIA S.A. in the retail marketfor electricity.

In late 2012 the Management ofALUMINIUM S.A. and the Union ofCompany Employees signed a newagreement, under which the plant’sjobs and production capacity aremaintained, with substantial costrationalizations introduced on a sus-tainable and long-term basis.

In METKA S.A. the number of per-sonnel dropped by 15% from theprevious year, mainly due to: (a)the transfer of salaried personnelto a Group subsidiary to supportthe implementation of the Group’sbusiness plan. (b) The completionof company projects in Greece andabroad.

Total workforce 2010 2011 2012

Total 2,249 2,020 1,965

Men 1,732 1,703

Women 288 262

Contracted personnel 2010 2011 2012

Total 410 397 384

Men 315 315

Women 82 69

A substantial contribution to thestabilisation of the number of per-sonnel of MYTILINEOS Group in2012 came from the reorganisationof the Energy Management andTrading Division of PROTERGIA S.A.,with the inclusion in it of threethermal plants (Ag. Nikolaos andKorinthos Energy Centres) and ofthe RES plants. Staffing needs forthe thermal plants and for the Re-tail Division led to the recruitmentof 123 employees, helping to boostthe Group’s total workforce levelfor 2012.

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2Employability in MYTILINEOS Group isprimarily affected by the need to re-cruit employees under fixed-term em-ployment contracts in aluminium pro-duction during the summer, and bythe fact that a significant part of theactivities of METKA S.A. and

DELPHI-DISTOMON S.A. is assigned tospecialist subcontractors and free-lance professionals. The tables belowpresent data on the breakdown of theGroup’s force by gender, employmenttype, type of employment contractand geographical region, in Greece

and abroad. Changes in employmentdata for the various regions are duemainly to fluctuating needs by geo-graphical region, depending on theprogress of the EPC projects carriedout locally by METKA S.A.

Personnel by geographicalregion – Greece 2010 2011 2012

Sterea 1.399 1,470 1,547

Men 1,248 1,345

Women 222 202

Macedonia 265 79 23

Men 62 14

Women 17 9

Thessaly 183 172 167

Men 160 156

Women 12 11

Peloponnese 12 23 42

Men 21 37

Women 2 5

Other regions 61 45

Men 55 42

Women 6 3

Personnel by geographicalregion – Other countries 2010 2011 2012

Turkey 34 32 113

Men 18 83

Women 14 31

Syria 7 5 2

Men 4 2

Women 1 0

Iraq 10

Men 10

Women 0

Jordan 9

Men 9

Women 0

Romania 62 11 2

Men 5 1

Women 1

Personnel by type ofemployment contract 2010 2011 2012

Total open-endedemployment contracts 1.747 1,540 1,480

Men 1,342 1,297

Women 198 183

Total fixed-term employmentcontracts 92 83 104

Men 75 93

Women 6 11

Personnel byemployment type 2010 2011 2012

Total full-timeemployees 1.839 1,620 1,580

Men 1,414 1,387

Women 206 193

Total part-timeemployees - 3 4

Men 2 3

Women 1 1

� 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 anotherGroup subsidiary, 14% to the termination of employment contracts, 13% tovoluntary departures, 10% to expiry of fixed-term employment or workcontracts, and 5% to retirement. As regards recruitment, significant in-creases in terms of the share of newly-hired employees regarded women(+9.5%) and workers over 50 years old (10%).

� The volatility in the business environment necessitates adjustments in thecompany’s strategy and adoption of flexible arrangements in the utilisa-tion of its human resources, so that high performance levels can be main-tained. As part of the efforts to use in the best possible way the potentialof its existing human capital, the company gave priority to using personnelfreed from their duties following the completion of its projects in Turkey,over sourcing new personnel from its external environment (labour mar-ket). In addition, in all its activity sectors and where this is practicable, thecompany keeps flexible working hours, in order to help employees dealwith personal needs and reduce absences from work.

38

During 2012, a total of 140 em-ployees left ALUMINIUM S.A. Ofthese departures, the largest part(65%) were due to retirementand the remaining 35% due totermination of employment con-tracts and voluntary departures.The company also hired 199 em-ployees to cover its staffingneeds. Of this total number ofnew employees, almost 80%were up to 30 years old and 15%were women.

With regard to the mobility of per-sonnel, the Group’s actual personnelturnover during 2012 (after taking in-to account that 30% of departures, asshown in the corresponding tablebelow, involved employee transferswithin the Group) grew by 3 per centunits to 14.2%. Actual employee de-partures stood at a total of 221,down 15% from 2011. Of these de-partures, around 37% were due to re-tirement; 27% were due to termina-tion of employment contracts, expiryof fixed-term contracts and dismissals;

and around 6% to voluntary depar-tures of Group employees. In specificcases of voluntary departures, exit in-terviews were held to discuss thereasons for the departure, alwayswith a view to improving the respec-tive Group company. In order to fill thevacancies created as a result of the de-partures, a common priority for oursubsidiaries is to put to the best pos-sible use the capabilities of their ex-isting personnel, through internal jobrotation or promotions, provided thatthe candidate employees are consid-

ered to possess the skills and knowl-edge that meet the needs of the re-spective vacancies in their organisation.At the next step, our Group compa-nies hired a total of 374 new em-ployees, giving priority to womenand young people – two categorieswhose share of newly-hired employ-ees compared to 2011 grew by 47.5%and 12.5%, respectively, thus helpingstrengthen the employability of thesesocial groups, which are particularlyvulnerable to unemployment.

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Personnel recruitment(by gender, age groupand geographical region)

2010 2011 2012

Personnel recruitment - Total 350 364 374

Men 277 323 312

Women 73 41 62

% share of total full-time employees

Personnel recruitment -Total 19.0% 22.5% 23.7%

Men 15.1% 20.0% 19.7%

Women 4.0% 2.5% 3.9%

Recruitment (<30 y.o.) 165 177 199

Recruitment (30-50 y.o.) 151 177 160

Recruitment ( >50 y.o.) 34 10 15

% share of total full-time employees

<30 y.o. 9.0% 10.9% 12.6%

30-50 y.o. 8.2% 10.9% 10.1%

>50 y.o. 1.8% 0.6% 1.0%

Recruitment-Sterea - 289 294

Recruitment-Macedonia - 15 1

Recruitment-Peloponnese - 20 44

Recruitment- Other regions - 14 9

Recruitment-Syria - - 4

Recruitment-Turkey - 26 20

Recruitment-Iraq - - 2

% share of total full-time employees

Sterea - 17.8% 18.6%

Macedonia - 0.9% 0.06%

Peloponnese - 1.2% 2.8%

Other regions - - 0.6%

Syria - - 0.2%

Turkey - 1.6% 1.3%

Iraq - - 0.1%

Personnel departures(by gender, age groupand geographical region)

2010 2011 2012

Personnel departures – Total 278 265 321

Men 240 226 271

Women 38 39 50

% share of total full-time employees

Personnel departures 15.1% 16.3% 20.3%

Men 13.1% 14.0% 17.2%

Women 2.0% 2.3% 3.1%

Departures (<30 y.o.) 48 67 70

Departures (30-50 y.o.) 102 91 130

Departures (>50 y.o.) 128 107 121

% share of total full-time employees

<30 y.o. 2.6% 4.1% 4.4%

30-50 y.o. 5.5% 5.6% 8.2%

>50 y.o. 7.0% 6.6% 7.6%

Departures-Sterea 114 167 247

Departures-Macedonia 66 21 16

Departures-Thessaly 34 13 7

Departures-Peloponnese 3 2 29

Departures-Other regions 40 49 -

Departures-Syria 1 - 3

Departures-Turkey 1 9 9

Departures-Romania 8 4 10

% share of total full-time employees

Sterea 6.2% 10.3% 15.6%

Macedonia 3.6% 1.3% 1.0%

Thessaly 1.8% 0.8% 0.4%

Peloponnese 0.2% 0.1% 1.8%

Other regions 2.2% 3.0% 0.0%

Syria 0.2% 0.0% 0.2%

Turkey 0.05% 0.7% 0.6%

Romania 0.4% 0.2% 0.6%

40

The recruitment policy of MYTILINEOSGroup provides opportunities for thedevelopment of local employment. Inall the geographical regions where weoperate, the majority of our human re-sources come from the local popula-tion. In addition, our practice to in-clude members of the local commu-nities in the management teams of oursubsidiaries creates economic benefitsfor the local communities involved andimproves our ability to understand lo-cal needs.

The Group companies have developedreliable personnel selection proce-dures adapted to the particular char-acteristics and needs of their businessactivity sector. These procedures aredesigned to assess the qualifica-tions/skills of candidates in relation tothe corresponding corporate require-ments and needs, as well as in termsof their personality and behaviourtraits.

1. The term “Senior Management” refers to the company’s Plant Steering Committee,

2. The term “Senior Management” refers to the company’s Executives and to its Board of Direc-tors.

3. The term “Senior Management” refers to all persons holding the position of Supervisor or higherpositions.

4. The term “Senior Management” refers to the Managers of the company’s Headquarter Divi-sions, the Managers of its Energy Centres, and the General Management.

5. The term “Senior Management” refers to all company Executives.

Departures of newly-hired personnel during 2012 2011 2012

Departures of newly-hired personnel - Total 69 47

Men 63 45

Women 6 2

% 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.) 3 2

% 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%

Percentage of Senior ManagementExecutives of the Group companiesrecruited from the local communities

2010 2011 2012

ALUMINIUM S.A.1 11.1% 11.1% 11.1%

DELPHI-DISTOMON S.A.2 40.0% 44.4% 33.0%

METKA S.A.3 90.0% 80.0% 80.0%

PROTERGIA S.A.4 67.0% 67.0% 70.0%

MYTILINEOS HOLDINGS S.A.5 100.0% 100.0% 100.0%

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In line with the priority that we attachto the continuous development andimprovement of our people’s qualifi-cations, the education and training ini-tiatives in MYTILINEOS Group are theframework which ensures the devel-opment of the necessary skills of ouremployees, so that they can play an ac-tive part in the Group’s evolution,and guarantees our competitiveness inthe long-term. In this context, thetraining programmes carried out an-nually by our subsidiaries are the prod-uct of a well-planned, comprehensiveeffort that is driven by the short- and

long-term needs of our personnel.

Through our subsidiaries, during 2012,we carried out a total of 54,029hours of training programmes, in-creasing the average training hours peremployee to 34.2, up from 31.5 in2011. In terms of the subjects coveredby our training plan, 77% of the totalnumber of training hours were allo-cated to Health & Safety, 12% to Tech-nical Training, and 11% to a variety ofsubjects, of which the most importantones were the development of Per-sonal Skills and Continuous Progress,as well as IT Skills and Foreign Lan-

guages learning. The total training costfor the Group stood at €1.27 million.A large part of these training pro-grammes were carried out as in-houseseminars, especially in ALUMINIUMS.A. and PROTERGIA S.A., as in addi-tion to facilitating the educationalprocess itself, this approach offers anumber of further advantages: It al-lows direct intervention to improve thetraining procedure where required, itincreases the number and qualifica-tions of the in-house trainers involved,and it improves the propagation ofbest practices at all levels.

6.2 Employee Education, Training and Development

Average personnel training hoursemployment position 2011 2012

Average training hours (Executives) 31.3 26.3

Average training hours (Administrative employees) 17.7 18.2

Average training hours (Technical & Labour personnel) 45.1 44.6

Average personnel training hours by gender 2011 2012

Average training hours (Men) 35.0 37.2

Average training hours (Women) 8.5 10.5

METKA S.A. gives priority to thedevelopment of the knowledgeand skills of engineers and of theircapacity for dynamic adjustmentto the demands of modern-daytechnologies. In line with this ap-proach, the company has strength-ened the technical training of itssite engineers, who take activepart in technical on-the-job train-ing programmes, during whichtraining is delivered under actualwork conditions.

With 17.7 training hours per year,ALUMINIUM S.A. and PROTERGIAS.A. post the highest averagetraining hours per year and peremployee for women – a figureconsiderably higher than the cor-responding average of the Group.

42

EMPLOYEE TRAINING AND SUPPORT PROGRAMMES: 80 Employees (Executives,Technical & Labour personnel).

OPERATION OF ENERGY CENTRES: 100 Employees (Executives, Technical &Labour personnel).

INDUCTION TRAINING PROGRAMME: Mandatory for all newly-hired employees.

HEALTH & SAFETY AT THE WORKPLACE PROGRAMME: 150 Employees (all cate-gories).

FIRE SAFETY PROGRAMME: 66 Employees (all categories).

QUALITY ASSURANCE PROGRAMME: 30 Employees (Executives, Administrativeemployees).

SAP TRAINING PROGRAMME: 15 Employees (Executives, Administrative Em-ployees).

The funds available through the Employment and Vocational Training Account[LAEK] of the Manpower Employment Organisation [OAED] were used to fi-nance training seminars on the following: OHSAS 18001:2007/ELOT 18001:2008;ISO 9001; ISO 14001; and Effective Negotiation Techniques.

In addition to our basic training plan,in-house seminars and vocationaltraining programmes for skills devel-opment are carried out. These are fi-nanced through the funds availablefrom the Employment and Vocation-al Training Account [LAEK] of theManpower Employment Organisa-tion [OAED] and are held in our com-panies’ offices, plants and constructionsites. In addition, paid educationalleave is granted to employees at-tending long-term courses of study (atthe graduate or post-graduate level)during the examination periods, tohelp them prepare for their exams. Inline with its policy on education andtraining, the Group also encouragesthe participation of its employees inexternal training seminars that helpthem develop their professional skills,and covers 100% of the relevanttraining costs.

Percentage of employees who received a performance review,by company

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0%

20%

40%

60%

80%

100%

20%

0%

40%

60%

100%

80%

71,9%

100,0%ALUMINIUM S.A.

100,0%DELPHI-DISTOMON S.A.

86,3%ΜΕΤΚΑ S.A.

68,5%PROTERGIA S.A.

67,8%MYTILINEOS S.A.

63,1%

72,4%

8,8%10,0%

With regard to practices relating to theprovision of transition programmes de-signed to support employees about toretire, the Group for the time beingdoes not provide placement servicesor support, training and advice pro-grammes to departing employees.However, it maintains in effect and ap-plies specific pension plans. In addition,in order to ensure the smooth suc-cession of the persons who retire, suc-cession plans are developed to iden-tify suitable successors to the positionsvacated and to help them adjustsmoothly to their new jobs. In addi-tion, through its Talent ManagementSystem, the Group identifies employ-ees with exceptional capabilities whobecome candidates for senior man-agement positions.

In the case of dismissals, compensa-

tion is payable in accordance with theprovisions of Law 3863/2010 andLaw 4093/2012, while in some casesthe compensation actually paid ishigher than the statutory one.

In MYTILINEOS Group we encourageinitiative, reward innovation and eval-uate the individual performance of ourpeople. Our companies have in placeadvanced performance review sys-tems for their personnel, whose keypriority is to help fill all vacancies whichmay be created through internal pro-motions, provided that the candi-date employees possess the knowl-edge and qualifications required. The

performance review systems of ourcompanies rely on measurable criteriaand have the following overall objec-tives: (a) To evaluate personnel in anobjective manner; (b) to help achievecontinuous performance improve-ment; (c) to review the goals set forevery employee; and (d) to identifynew education and training needs. In2012, more than 82% of our em-ployees received annual reviews oftheir performance and careerprospects, with this percentage risingto nearly 90% in the case of full-timeemployees.

Percentage of employees who received a performance review,by company

� 2012� 201182,3%

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The company applies a Professional Development Review Process in the formof annual meetings held to facilitate the exchange of views, assessments, rec-ommendations and information between an employee and his/her immediatesupervisor, in the presence of the supervisor in the next level up the manage-ment hierarchy, if this is possible from an organisational point of view. The em-ployee and his/her supervisors review and discuss regularly the employee’sprogress and his/her overall career path within the company. The general andspecific criteria for advancement are examined and taken into consideration insetting the personal goals and training needs for the employee concerned, aswell as in formulating an appropriate succession plan for those employees whoare close to retirement.

In addition, the company has developed an Executive Evaluation Guide thatserves the following key objectives:

- Τo assess the progress made by the evaluee.

- To identify and agree/accept the priorities for the next year.

- To resolve problems that arise during the year.

- To mobilize personnel towards the achievement of corporate targets.

- To ensure the comprehensive planning of actions and initiatives to helpachieve corporate targets.

- To provide evaluees with counseling regarding their personal professionaldevelopment.

- To provide the supervisor-evaluator with feedback on the views of the eval-uee regarding any problems in their collaboration.

- To improve the performance of the evaluee and of the company in its en-tirety, and to identify priorities for improvement as input to the Executive de-velopment and training process.

The company applies a Perform-ance Review System to record andasses in an objective manner theperformance of every employeeagainst specific performance crite-ria. The relevant procedure takesplace at the end of every year. Theevaluation (carried out by the em-ployee’s direct and indirect super-visors) and the performanceappraisal interview that followsprovide employees and their asses-sors with the opportunity to ex-change views, to reward specificaspects of performance, to identifyareas for employee improvementand to establish a training and per-sonal development plan for thenext year. The purpose of the sys-tem is twofold: To guide the objec-tive evaluation of the performanceof employees on the basis of theircontribution to the achievement ofthe corporate targets, and to helpemployees improve and developfurther. The application of this sys-tem during 2012 led to the promo-tion of five (5) employees.

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

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During 2012, we continued our effortsto develop and incorporate into theoperations of all Group companies a“Safe Work Rule” attitude and ap-proach that focuses on the preventionof accidents and occupational dis-eases. Every year, our goal is to have

zero serious accidents or work-relatedfatalities and zero incidents related tooccupational diseases. An additionalfuture goal is to include the achieve-ment of Occupational Health & Safe-ty targets as a specific criterion in theevaluation of the Management Exec-

utives of our subsidiaries, in order to

emphasise even more their responsi-

bility for combining business priorities

with Corporate Social Responsibility in

every respect.

Our performance in 2012 was marked-ly improved compared to the previousyear, as only two (2) injuries wererecorded. In addition, there were nowork-related fatalities and no inci-dents related to occupational dis-eases.

This improved performance was madepossible by several key initiatives in oursubsidiaries, as follows:

� PROTERGIA S.A.: The company in-tensified its actions to prevent injuriesand occupational diseases at theworkplace, by adopting the OHSAS18001 International Standard for itsOccupational Health & Safety Man-agement System and obtaining therelevant certification in late 2012.The company’s training plan for2012 included training on emer-gency response procedures, focusingon fire-fighting and the evacuationof facilities.

� METKA S.A.: The company pro-vided training on Health & Safety toall newly-hired Personnel, as part ofits formal induction programme (ap-plied in the company’s Offices /Construction Sites / ManufacturingPlants), which new employees attendbefore they commence work. Reg-ular training updates on Health &Safety issues were provided to allcompany personnel, with a focus onthe particular characteristics of eachspecific work environment e.g. (Evac-uation Drills, Fire Safety, Health andSafety in construction sites or man-ufacturing plants).

� ALUMINIUM S.A.: The companycarried out the following actions dur-ing the year: 60 Personal Safety Ac-tions (PSAs) and 10 ManagementSafety Visits (MSVs) for every man-agement executive who receivedrelevant training; 18 Health and

Safety Visits; 10 inspections of sub-contracts in progress; 8 inspectionsof confined spaces; 15 installationlockout inspections; and 12 circula-tion inspections. In addition, thecompany monitors the followingSafety indicators: LTI (Lost Time Injury– number of accidents with inter-ruption of work); RCR (RecordableCase Rate – number of recorded ac-cidents without interruption ofwork); and FA (number of visits tothe Medical Station). For every inci-dent recorded, the Incident AnalysisRate (using the “Cause Tree Analy-sis” method) and the 48-hrs SafetyIncident Analysis Rate are alsologged. Finally, 185 measurements ofsafety conditions (noise, vibrations,presence of fluoride etc.) and 743regular employee medical check-ups were carried out, and 310 em-ployees were tested for the presenceof fluoride in their body.

0,0

5,0

10,0

15,0

20,0

2010 2011 2012

25,0

AccidentsWork-related Fatalities

22

10

During 2012 two accidents occurred leading totemporary interruption of work. These involvedinjuries in the limbs (legs) sustained by employees inthe Alumina production department. The twoincidents were analysed using the “Cause TreeAnalysis” method, the reasons that caused them wereestablished, and relevant corrective actions wereplanned (including, for each action, the designationof a person in a charge, a deadline and a completiondate), with a view to informing employees and topreventing the occurrence of any conditions thatcould cause such accidents to happen again.

Rate of Accidents and Work-related Fatalities

2

6.3 Occupational Health & Safety

Evolution of Occupational Health and Safety indicators

46

0.0

0.5

1.0

1.5

2.0

2012

0.1

2011

1.1

2010

1.8

2012

0.0

2011

0.0

0.0

0.5

1.0

1.5

2.0

0.1

2010

0.0

5.0

10.0

15.0

20.0

2.9

2012

11.9

2011

16.7

20100.0

1,000.0

2,000.0

3,000.0

4,000.0

5,000.0

6,000.0

364.8

2012

134.9

2011

5743.3

2010

Injury Rate (IR)

2012 IRMen: 0.1 Women: 0.0

2012 LDRMen: 3.3 Women: 0.0

2012 ΑRMen: 289.3 Women: 828.9

2012 ODRMen: 0.0 Women: 0.0

Occupational Diseases Rate (ODR)

In METKA S.A., Health & Safety Committees function atthe facility level (in every construction site or plant). Morespecifically the Health & Safety Committee at the VolosPlant is composed of employees, Union representativesand members of the Management, and is established inaccordance with the provisions of the Greek laws. TheSafety Technician and the Occupational Physician workclosely with the committee on all issues regarding thesafety, protection and health of employees. The Com-mitte's members, the Safety Technician, the OccupationalPhysician and the Company's representatives attend Train-ing Programmes on Health & Safety and related official in-formation days. In addition, in all of the company’s con-struction sites specialized personnel is on duty at all timesat to handle Health & Safety issues, First Aid services areprovided (personnel & equipment), and an Ambulanceand Occupational physician are available to administerFirst Aid care and handle emergencies.

Lost Days Rate (LDR) Absenteeism Rate (ΑR)

In ALUMINIUM S.A. the Plant Health & Safety Committee(PHSC) represents all personnel in the meetings held withthe Management. The PHSC is composed of five (5) mem-bers, which (in accordance with the laws and in propor-tion to the number of plant personnel) are elected by thepersonnel every 2 years. The PHSC has extended respon-sibilities and its members participate in all key proce-dures, committees or working groups. More specifically,the PHSC members participate in:- The “Green Light Committees” for new projects/works

and major modifications to facilities.- The analyses of accidents and incidents carried out us-

ing the “Cause Tree Analysis” method.- The working groups established for the written as-

sessment of occupational hazards and risks, and- The Occupational Health & Safety visits scheduled with

the Occupational Physician and the Safety Officer.

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

6.4 BenefitsIn MYTILINEOS Group, we apply reli-able and objective methods to deter-mine compensations and benefits –and their evolution– for all our em-ployees, so that we can ensure meri-tocracy in earning levels, guaranteecompetitive earnings in relation to theGreek market, and lay the foundationsfor long-term relations with our em-ployees in all Group companies. Thecompensations and benefits pack-ages that we offer to our employeesare of course determined in accor-dance with the minimum entry levelsprovided under the laws in force.Any compensations over and abovethese levels are based on the em-

ployees’ individual performance andcapabilities, which are monitoredthrough the annual performance re-view process.

Differences in salaries arise exclusive-ly from the average level of expertiseby gender and category of employ-ment position. Due to the specific na-

ture of their activities, our subsidiaries–especially in aluminium productionand EPC projects– employ primarilymen in positions with higher speciali-sation requirements (technical or man-agerial) and women in less specialisedpositions, a situation that is reflectedin the corresponding salary levels.

In addition to pecuniary benefits, ourkey concern is to create an attractivework environment in which our em-ployees are able to balance their pro-

fessional and family obligations. To thisend, we are extending a number ofvoluntary long- and short-term bene-fits, over and above the statutory

ones, to the employees of all our sub-sidiaries.

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Basic salary for women vs. basic salary for men, byemployment position 2012

Executives -16,5%

Administrative employees -11,5%

Technical & Labour personnel -17,7%

Basic benefits extendedby the Group companiesto full-time employees

MYTILINEOSHOLDINGS S.A.

ALUMINIUMS.A.

METKAS.A.

PROTERGIAS.A.

DELHPI-DISTOMON

S.A.

Life insurance x x x x x

Health and medical care x x x x x

Coverage against disability/incapacitation x x x x x

Retirement provisions x x x x x

Maternity / paternity leave x x x x x

Voluntary benefits extendedby the Group companiesto full-time employees

MYTILINEOSHOLDINGS S.A.

ALUMINIUMS.A.

METKAS.A.

PROTERGIAA.E.

DELHPI-DISTOMON

S.A.

Additional leave for parents of large families (>3 children) x

Housing for non-local employees x x x

Personnel transport x x x x

Ownership of company shares x x

Company credit card x x x

Theatre tickets and tickets for various cultural events x

Company car and parking space for Executives x χ χ χ

Electronic pass for toll stations χ χ

Company fuel card χ χ

Mobile phone, laptop and smartphones χ χ χ χ

Fuel allowance χ χ χ

Work gear and meals χ χ χ

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The company supports its personnel on health-related is-sues, offering a private insurance plan which includes lifeinsurance and comprehensive health and medical carecoverage in Greece and abroad. In 2012 the companystarted its cooperation with a new private insurer andcreated a new coverage plan. Special policies were alsodeveloped and introduced regarding company creditcards, company cars with a fixed quantity of fuel, mobiletelephones, and e-pass devices (electronic passes for tollstations) for travels to/from the company’s thermalplants. In addition, we are particularly sensitive to theissue of parental leaves, granting such leaves to the fullextent under the law to employees who are entitled tothem. For women, our policy provides for their tempo-rary replacement until the end of their maternal leaveand the smooth return to their job duties.

Employees returning and remaining at workafter 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 0 1

Women 4 9

Employees returning to work after the end of parental leave 2 6

Men 0 1

Women 2 5

% 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 employedafter 12 months from their return 2 6

Men 0 1

Women 2 5

% share of total full-time employees

Employees returning to work after the end of parental leave and still employed after 12months from their return 0.1% 0.4%

Men 0.0% 0.1%

Women 0.1% 0.3%

Despite the adverse economic conditions, the companycontinues with its current employee benefits plan, de-signed to help improve the standard of living of its em-ployees. Indicative such benefits include a health andmedical plan, payment of higher compensations forday-labourer retirement or layoffs, interest-free loansand cash facilities to employees, special anniversary giftpayments to employees on completion of 10, 20, and 35years of service with the company, coverage of schoolexpenses for children of company employees etc. Specialemphasis is given to our employees in foreign countries,with a set of benefits that ensure a framework of secu-rity and protection of personnel of the company. In-dicative examples include: 1. Travel insurance for em-ployees who travel frequently abroad on companybusiness; and 2. Special insurance package medical andhospital coverage tailored to national circumstances.

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7. PROTECTION OF HUMANRIGHTS

The respect of the fundamentalrights of employees, as these aredefined in the Declaration on

Fundamental Principles and Rights atWork of the International Labour Or-ganisation (ILO) is a key strategic goalfor our Group, as also stated in ourProfessional Ethics Code:

“The Management of the Group se-lects, assigns duties to, rewards andcompensates its employees based ontheir formal and essential qualificationswith respect to the requirements oftheir work, without discrimination ongrounds of race, religion, ethnic origin,colour, gender, identity, age, nation-ality, sexual orientation, family status,disability or of any other characteris-tics protected by the law. It encouragesand recommends to all its employeesto respect the individuality of every em-ployee, supplier or client of the Groupand to refuse to concede to any be-haviour that is offensive to the per-sonal dignity of the individual, createsdiscriminations of any type or resultsin forced labour. It pledges to protectchildren and minors against their ex-

ploitation for labour and undeclaredemployment, and prohibits all sexualor other harassment or exploitation ofthe Group’s employees in the work-place and in general in the premiseswhere its activities take place” (extractfrom the Professional Ethics Code ofthe MYTILINEOS Group).

In line with the above:

� Since the end of 2010, we have in-troduced the inclusion of criteria onthe protection of Labour Rights inour major business agreements interms of economic volume andstrategic importance, as well as inthe contracts that we concludewith major suppliers, contractors andother business partners.

� Since the end of 2012, we are de-veloping a specific screening systemregarding our key suppliers andsubcontractors, which includes pro-cedures for self-evaluation and forthe conduct of audits by official In-ternational Organisations and NGOsto ensure compliance with the re-quirement for protection of LabourRights in their work premises.

In 2012,

30 womenheld management positions inthe Group, a rate that representsthe Group's best performancesince its establishment.

90% of all our directemployees receive performancereviews on an annual basis.

We prohibitall types of compulsory or forcedlabour.

We prohibitthe employment of minors.

7.1 Fundamental labour rights

The percentage of the contractswhich the company concluded withmajor suppliers and contractorsduring 2012 and which included cri-teria on the protection of HumanRights stood at 12%. With regardto the company’s major businessagreements, this percentage stoodat 7.7%.

The percentage of the contractswhich the company concluded withmajor suppliers and contractors dur-ing 2012 and which included criteriaon the protection of Human Rightsstood at 10%.

� During 2012, we communicated toall our subsidiaries clear instruc-tions on the inclusion of the pro-tection of Human Rights as a subjectin their employee training plans. Weare also working to implement a rel-evant in-house seminar at the Grouplevel, to be coordinated byMYTILINEOS HOLDINGS S.A. as theGroup’s Corporate Centre.

� Additionally, during 2013 we will be-gin work on the formulation of a for-mal Group-level policy for specifically

handling complaints regarding vio-lations of Human Rights. Accordingto the procedures currently in place,in every business unit one person(the Construction Site Manager,the General Manager, the Man-agers of Headquarter Divisions, theManagers of the Energy Centres,and the Human Resources Depart-ments) is designated as supervisor oras the person responsible for re-ceiving all complaints regarding vi-olations of Human Rights. This per-

son is first of all responsible for tak-ing action to prevent the occurrenceof such practices, and then for deal-ing with cases of related complaintsimmediately, in full compliance withthe local national laws and theprinciples of the Company.

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�On our Website:- Our Management Approach regardingthe protection of Human Rights

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The particular characteristics and theneeds of the business activity sectorsof MYTILINEOS Group, especially inproduction-related areas, are the fac-tors that determine the indicators ofdiversity which we use in connectionwith the promotion of equal oppor-tunities and the respect of the indi-viduality of every employee. With theoutmost respect for the personality ofevery individual, we monitor and col-lect data on the gender, age and eth-

nic origin of our human resources, to-gether with information on any casesof disability, in the interests of prop-er management and in order to pro-vide assistance and support to thosewho need it. In all cases, we adopt so-cial practices characterised by the re-spect for the individuality of employ-ees, in all the geographical regions andthe countries where we operate andwe offer equal opportunities not on-ly in terms of filling vacancies and of

salaries, but also regarding the edu-cation, training and professional de-velopment of employees. During 2012,as shown in the tables below, we in-creased the participation of womenand of employees aged from 30 to 50in all employment position categories.Furthermore, no incidents of discrim-ination were reported in the plant fa-cilities or administrative premises of theGroup companies.

7.2 Equal opportunities & diversity

Personnel breakdown according tospecial indicators of diversity 2011 2012

Men 87.3% 86.0%

Women 12.7% 14.0%

Employees <30 y.o. 16.7% 16.0%

Employees 30-50 y.o. 61.1% 67.4%

Employees >50 y.o. 22.2% 16.6%

Employees from ethnic minorities 1.3% 0.4%

Employees with a disability (PWD) 0.2% 0.2%

Executives: Breakdown accordingto special indicators of diversity 2011 2012

Men 85.7% 85.6%

Women 14.3% 14.4%

Employees <30 y.o. 6.9% 8.6%

Employees 30-50 y.o. 61.1% 64.6%

Employees >50 y.o. 32.0% 26.8%

Employees from ethnic minorities 0.0% 0.0%

Personnel breakdown according to specialindicators of diversity, by gender 2012

Employees with a disability (PWD) 0.1%Men 0.1%Women 0.0%Employees <30 y.o. 16.1%Men 12.7%Women 3.4%Employees 30-50 y.o. 67.4%Men 58.8%Women 8.6%Employees >50 y.o. 16.6%Men 15.1%Women 1.5%Employees from ethnic minorities 0.4%Men 0.3%Women 0.1%

Administrative employees:Breakdown according to specialindicators of diversity

2011 2012

Men 85.7% 70.1%

Women 14.3% 29.9%

Employees <30 y.o. 12.6% 8.3%

Employees 30-50 y.o. 60.5% 67.3%

Employees >50 y.o. 27.3% 24.4%

Employees from ethnic minorities 2.0% 0.6%

Employees with a disability (PWD) 0.5% 0.8%

Technical & Labour personnel:Breakdown according to specialindicators of diversity

2011 2012

Men 98.2% 98.0%

Women 1.8% 2.0%

Employees <30 y.o. 21.5% 19.2%

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%

Employees with a disability (PWD) 0.0% 0.2%

Board members of Group companies:Breakdown by gender and breakdownaccording to special indicators of diversity

2011 2012

Men 97.1% 95.0%Women 2.9% 5.0%

Board members <30 y.o. 0.0% 0.0%

Board members 30 - 50 y.o. 2.9% 12.5%

Board members >50 y.o. 97.1% 87.5%

Board members from ethnic minorities 0.0% 0.0%

Board members with a disability (PWD) 0.0% 0.0%

In MYTILINEOS Group, we guaranteeto all our employees, without excep-tion, the right to assemble and asso-ciate and to collective negotiations. Inthis context, all our subsidiaries recog-nise the trade union rights of em-ployees, i.e. their right to establishUnions, to participate in them and toenter into collective negotiations. Thepurpose of the employee unions in theGroup Companies is to safeguard theinterests (financial, work-related and in-surance-related) of employees and to

guarantee the continuation of their ac-quired rights and their improvement interms of quality and quantity. During2012, no reports were made of inci-dents involving a violation of the free“trade union right” of employees bythe Human Resources Divisions of ourcompanies, which are responsible forhandling such incidents and for takingappropriate action in collaborationwith the Employee Unions, wherethese exist.

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METKA S.A. fully respects the rightof its employees to participate intrade unions or other representativebodies. There is one official em-ployee Union in operation at thecompany, as well as a company-levelagreement currently in force, whichwas the product of collective nego-tiations between the Union and thecompany, are more favourable foremployees than the correspondingprovisions under the labour legisla-tion in force.

7.3 Freedom of Association

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27.4 Child Labour

The key activities of MYTILINEOS Grouptake place in the territory of Greece.The Greek legislation in force includesa number of legislative initiatives toprotect the employment of minors,such as: The ratification of the UNICEFConvention on the Rights of the Child(Law 2101/1992), on the definition ofchild labour; the ratification of the Con-vention182 of the International LabourOrganisation (ILO) concerning the pro-hibition and immediate action for theelimination of the worst forms ofchild labour (Law 2918/0011); theadoption of Law 1837/1989 on theprotection of minors from employ-ment, which includes an article on theprotection of employed minors underLaw 3144/2003 (“Social dialogue forthe promotion of employment and so-cial protection”), as well as a referenceto minors who are victims of humantrafficking under the relevant Law3064/2002.

However, despite the rigorous ap-

proach of the abovementioned laws,their enforcement in practice faces sig-nificant difficulty. The major hindrancethat dampens the effectiveness oftheir enforcement are the long delaysin the procedure for the hearing of rel-evant cases by the Courts, whichvaries from one to two years at the veryleast. As a result, employed minors inGreece are left exposed to all kinds ofexploitation and pressures. The figureson child labour in Greece, which NGOsand International Organisations re-lease based on an growing corpus ofevidence, paint a disheartening picture.

In this context, as a responsible cor-porate citizen, we recognise our shareof the responsibility to play a part in theefforts to limit this phenomenon andwe are committed to the principles ofthe UN Global Compact which refer tothe effective abolition of child labour.We also declare that we oppose theunlawful use of child labour and the ex-ploitation of children. Furthermore, itis our standing policy to carry out pri-or checks and to refuse to enter into

an association with any supplier or con-tractor known to operate using un-lawful practices that encourage, con-done or cover up incidents of childlabour.

In addition, the risk of occurrence of in-cidents of child labour is also ad-dressed by the rigorous personnel se-lection procedure that our Groupcompanies have in place. The HumanResources Divisions of all our compa-nies monitor closely all such occur-rences and take appropriate action asrequired, in consultation with the TopManagement of the respective Groupcompany and in collaboration with theExecutives of the company’s Manage-ment hierarchy and the representativesof employee unions, where these ex-ist.

Through our subsidiary METKA S.A.,active in construction and EPC Projects,we operate business units in geo-graphical regions which are consideredto present a higher risk of occurrenceof incidents involving child labour. Inthese specific regions, METKA S.A.takes all necessary steps to ensure com-pliance with the provisions of thelaws prohibiting child labour, by meansof its internal regulations and Profes-sional Ethics Code, which reflect thebusiness ethics and values that applyto all employees. In parallel, the com-pany requires its Managers and SeniorExecutives to undertake a bindingcommitment to adopt fully and defendthese principles and to adhere to theapplicable legal framework, while allthe contracts and agreements that thecompany concludes with its businesspartners contain clauses on the manda-tory compliance with the applicable na-tional laws, rules and regulations, in or-der to rule out all likelihood of incidentsinvolving child labour or the employ-ment of young contracted personnelin hazardous work. Finally, during2012 no reports were made of inci-dents of child labour in the Group com-panies and in their principal associates.

7.5 Forced Labour

The Constitution of Greece (art. 22par. 4) establishes in principle thefreedom of labour, through the pro-hibition of forced or compulsorylabour. No person can be forced to un-dertake work in general or specifical-ly. Any form of compulsory work isprohibited.

In MYTILINEOS Group, we oppose allforms of forced or compulsory labour,as we first and foremost believe thatcoercion against the will of any personwho is working, relegates that personto a means of achieving profit andconstitutes a violation of that person’sdignity.

The business activities of our Group inthe construction of power plants,through its subsidiary METKA S.A., areconsidered to present a higher risk ofoccurrence of incidents of forcedlabour in certain geographical re-

gions. In these regions, METKA S.A.takes all necessary steps to ensurecompliance with the provisions ofthe laws prohibiting forced labour bymeans of its internal regulations andProfessional Ethics Code, which reflectits commitment to the protection ofHuman Rights. In parallel, the com-pany requires its Senior Executives toundertake a binding commitment tocheck and deal immediately with anyconditions which may encourageforced labour, while all the contractsand agreements that the companyconcludes with its business partners(Suppliers – Subcontractors) containclauses on the mandatory compli-ance with the applicable nationallaws, rules and regulations, in order torule out all likelihood of incidents in-volving any form of forced labour.Where a Code of Conduct on HumanRights forms part of a contract, spe-cific reference is made to the respect

for Human Rights, to the prohibitionof forced labour, and to the company’sright to request the audit of its Sup-pliers and Subcontractors by official In-ternational Organisations for ensuringcompliance with the requirementson the protection of Human Rights.Furthermore, the company’s supervi-sors at its construction sites andplants are carrying out constant checksof its subcontractors for adherence tothe law and compliance with thecontractual terms, to eliminate alllikelihood of incidents of forced labour,while the company itself is subject tosupervision and to regular Quality,Health & Safety and contractual com-pliance audits, conducted by inde-pendent organisations in connectionwith all the projects it undertakes. Fi-nally, during 2012 no reports weremade of incidents of forced labour inthe Group companies and in their prin-cipal associates.

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8. ENVIRONMENTALPROTECTION

The respect for the environment hasbeen a core value of MYTILINEOSGroup since its very establishment. OurGroup seeks to mitigate the impact ofits activities on the environment, by fol-lowing closely the developments in en-vironmental technologies and practicesand by applying the best available tech-niques. The environmental protectionand industrial hazard control policiesthat we have in place form the basis ofa comprehensive and effective systemof Environmental Management rules,which we aim to gradually integrate in-to our business activities and into theprocedures that define the daily op-eration of all Group companies. In thiscontext, during 2012 we completedthe implementation of the ISO 14001International Standard procedures inour subsidiary PROTERGIA S.A., whichsubsequently obtained the respectivecertification.

This development marked the suc-cessful attainment of our goal, whichwas to ensure that all our businessunits have in place ISO 14001-certifiedEnvironmental Management Systems.Additionally, to further enhance our en-vironmental performance, we are fo-cusing on knowledge acquisition, net-working and collaboration with envi-ronmental organisations in order to de-velop new policies and adapt existingsystems, such as for example to de-velop a system for measuring green-house gas emissions at the Grouplevel. We are also continuing with ourefforts to foster a uniform environ-

mental conscience cross all our sub-sidiaries, through relevant educationand training activities.

In line with the above, in 2012 we in-troduced and applied a specific pro-cedure to determine the key environ-mental issues which are of concern tous, with the participation of the CSRteams of all our subsidiaries. The resultsof this exercise, shown in the table be-low and accompanied by clarificationsand references to the correspondingactions, represent our Group’s Envi-ronmental Footprint, published here forthe first time. This procedure will be ap-plied annually and its results will be pre-sented in a dedicated section of ourSustainability Report, so that anychanges or deviations – positive or neg-ative– in our environmental perform-ance are immediately visible to ourStakeholders.

In 2012 our total expendituresrelated to the implementation of theGroup’s environmental policy stoodat more than

€10 million.

100% of our businessunits have in place EnvironmentalManagement Systems certified inaccordance with the ISO 14001international standard.

In our aluminium production sector,we achieved a specific energyconsumption of

13.255kwh/t- one of the best in all aluminiumprocessing plants.

We have already restored

85% of all areas affected byour mining activity.

8.1 Environmental Footprint of MYTILINEOS Group

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Performance: 3/5

Performance: 2/5

Performance: 3,5/5

Performance: 3,5/5

Performance: 0/5

Performance: 4,3/5

Performance: 1/5

Performance: 1/5

Performance: 1/5

Performance: 2/5

Performance: 4/5

ENVIRONMENTALFOOTPRINTCOMPONENTS

IMPACT LEVEL

No impact(0)

Insignificantimpact

(1)

Limitedimpact

(2)

Moderateimpact

(3)

Significantimpact

(4)

Verysignificant

impact(5)

1. Compliance with environmentallaws and regulations

2. Consumption of raw materials

3. Control of greenhouse gasemissions:: (CO2), (CH4), (N2O),(HFCs), (PFCs), (SF6)

4. Other significant air emissions:(Νοx), (SΟx), (VOC), (HAP)Chimney emissions and Particles

5. Energy consumption

6. Waste management

7. Water consumption in thecompany’s production activity.

8. Water consumption in thecompany’s buildings

9. Spills of hazardous substances(oil, fuels, waste or chemicals)in the soil and in the water

10. Impacts on Biodiversity

11. Rehabilitation of the naturallandscape

All Group companies comply fully with the envi-ronmental laws and regulations.

The percentage of the use of recycled or renew-able materials as input materials to the production

processes of the Group, thus helping reduce demandfor raw materials and conserve mineral resources, rangesfrom 11% to 30%. NOTE: This performance refers toall Group subsidiaries except PROTERGIA S.A., whoseelectricity production plants use as raw material natu-ral gas, which cannot be recycled and is not a renew-able source.

ACTION PLAN:To carry out a study on the use in the productionprocesses of our companies of recycled or renewablematerials, thus helping reduce demand for rawma-terials and conserve mineral resources, at a per-centage ranging from 31% to 50%.

1. 2.

MYTILINEOS GROUP ENVIRONMENTAL FOOTPRING 2012

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The Group has identified partly the greenhousegas [GHG] emission sources of its activities and has

calculated the corresponding emissions, which it dis-closes in its Sustainability Report. NOTES: (a) PROTERGIAS.A. operates gas-fired, state-of-the art high-efficien-cy power plants, which are more environment-friend-ly than other conventional electricity productionplants. Taking into account the primary objective, whichis the production of electricity, and the fact that theseplants are governed by and operate using Best Avail-able Techniques (BATs), the reduction of CO2 emissionsis not feasible. In addition, from 2013 onwards the com-pany will have to incur significant expenditures for thepurchase of CO2 emissions trading rights for the Group’stotal emissions. (b): For METKA S.A. and MYTILINEOSHOLDINGS S.A., the results of the company-level ac-tivity regarding CO2 emissions have not yet been in-vestigated.

ACTION PLAN:To gradually identify all CO2 emission sources atGroup-level and calculate the corresponding emis-sions. To set targets for the reduction of direct andindirect CO2 emissions at Group level and to spec-ify the corresponding actions for achieving these tar-gets.

The Group has set targets for the reduction of sig-nificant air emissions and dust from its activities,

which also include the corresponding actions forachieving these targets. NOTES: (a) The electricity pro-duction plants of PROTERGIA S.A. only produce NΟx(as NO2) and not SO2 and particles. In full compliancewith the applicable environmental terms, the ΝΟ2 emis-sions of the company’s plants are significantly lowerthan the limits allowed by the law. (b): For METKA S.A.and MYTILINEOS HOLDINGS S.A., the results of thecompany-level activity regarding other significant airemissions and dust have not yet been investigated.

ACTION PLAN:Initially a direct identification at the construction sec-tor, as well as a report from the mining activity, ofall sources of significant air emissions and of theircalculation. Setting targets for the reduction of di-rect and indirect significant air emissions and dustat the Group level, and specifying the correspondingactions for achieving these targets.

The Group has identified the direct and indirectenergy consumption sources of its activities and has

calculated the corresponding consumptions, which itdiscloses in its Sustainability Report. Nevertheless, of-ficial targets for energy savings have not yet been de-termined at Group level.

ACTION PLAN:To establish and gradually incorporate targets for en-ergy savings through (a) process reengineering in thedepartments of the Group companies, e.g. in pro-duction; (b) equipment conversion and refurbish-ment; and (c) changes in the behaviour of our sub-sidiaries’ personnel, together with the correspondingactions for achieving these targets.

The percentage of the Group’s waste which canbe recycled, reused/utilized, exchanged or recov-

ered ranges from 10% to 30%, while the percentageof the Group’s waste which can be disposed of in land-fills, at sea or by means of any other method used byits companies ranges from 70% to 89%. NOTE: This per-formance refers to our mining and aluminium pro-duction activities, which account for around 98% ofthe Group’s total quantity of waste.

ACTION PLAN:Carry out a study on the reduction of the disposal inlandfills to a percentage ranging from 10% to 30%of the total waste from the mining and aluminiumproduction activities.

3.

5. 6.

4.

58

It has been proved that the consumption of waterby the activities of the Group companies does not

affect aquifer levels or the quantity of the water avail-able for use or the capability of an ecosystem to func-tion. Irrespective of this fact, however, PROTERGIA S.A.and DELPHI-DISTOMON have not yet determined tar-gets and related actions for water savings in their pro-duction processes.

ACTION PLAN:Establishment and gradual incorporation of targetsand proposals for continuous improvement in theGroup companies, focusing on the achievement ofthe highest possible conservation and on the reuseof water in their production processes.

Group's total water consumption is around 6m3

to 7.5m3 per person annually. The goal is to limitthis consumption initially to 4.5m3 to 6m3 per personannually. NOTE: DELPHI-DISTOMON has alreadyachieved its desired water consumption level, which is<1.5m3 per person annually.

ACTION PLAN:To take action at company-level with the aim ofachieving a consumption level for potable water inthe range of 4.5m3 to 6m3 per person annually.

Incidents at the level of facilities, involving main-ly the spillage of lubricants in the soil in under-

ground tunnels, due to the breakdown of machinery.These incidents were of a limited extent and their im-pact was reversible. NB: This performance refers onlyto the Group’s mining and aluminium production ac-tivities.

ACTION PLAN:DELPHI-DISTOMON S.A. has already set a target forreduction of the number of incidents involving spills,to be achieved primarily by informing the compa-ny’s contractors of the need for better maintenanceof their machinery or for its replacement with new-er-technology equipment, where required.

The locations of the Group’s business activities donot form part of any area protected by law or des-

ignated as an area of high biodiversity value. Never-theless, the activities of PROTERGIA S.A. at local lev-el result in a minimal disturbance to the existing floraand fauna, and the company has developed and ap-plied special rehabilitation studies and has also carriedout environmental development projects (Environmentalparks etc.). Additionally, a more thorough study is re-quired to accurately assess the impacts on biodiversi-ty of the disposal of bauxite residues on land byALUMINIUM S.A.

ACTION PLAN:No deviation from the policy of PROTERGIA S.A. Asa result of our efforts for full compliance of the com-pany’s production plants with the environmentalrules and regulations in force, disturbance to the lo-cal flora and fauna is negligible. ALUMINIUM S.A. toexplore the possibility for a study on the impacts onbiodiversity of its disposal of bauxite residues on land.

Since the launch of the Group’s business activity,80% to 100% of the areas affected have been ful-

ly rehabilitated.

ACTION PLAN:No deviation from our policy. We are continuingwith the rehabilitation of affected areas, with re-spect to the natural environment and with a viewto minimising the impact of our activities on bio-diversity.

7. 8.

9.

10.

11.

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Our efforts regarding the rationalmanagement of raw and other ma-terials focus on the identification andspecification of suitable methods,which will allow our subsidiaries to al-so use recycled materials in process-ing and manufacturing of their prod-ucts. The maximum possible use of re-cycled materials in our productionprocesses will help reduce demand forvirgin materials, maintain the level of

mineral resources and reduce total op-erating costs in our Group. Today, thepercentage of the use of alternativeraw materials in MYTILINEOS Group,especially in aluminium productionand in construction, does not exceed20%.

On the other hand, a particularity ofthe Energy sector is that the raw ma-terial used to drive our electricityproduction plants is natural gas,

which cannot be recycled and is nota renewable source.

During 2012, a total of 2.37 milliontons of raw and other materials wereused to produce the Group's endproducts, down by 5.2% from thequantity used last year. The largest partof this quantity came from the miningactivity and involved the consumptionof bauxite in aluminium production.

8.2 Management of raw & other materials

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%

60

Semi-finished goods or parts (other than raw materials)that form part of the end product 2011 2012 Change

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(for materials incorporated in the end product) 2011 2012 Change

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%

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28.3 Energy consumption

Aluminium production and electricityproduction are our two most energy-intensive activities, accounting for 50%and 49%, respectively, of the Group’s to-tal consumption of direct primary energyin 2012. The group’s total energy con-sumption increased by approximately116% compared to 2011, driven pri-marily by the full operation of the pow-er production plant of PROTERGIA S.A.in Ag. Nikolaos (Viotia) throughout2012 and the launch of the commercialoperation of the company’s power pro-duction plant in Ag. Theodoroi (Korithia)in April 2012.

The quantity of energy purchasedand used by the Group in 2012 cameexclusively from non-renewablesources and increased by approxi-mately 60%, as extensive use wasmade of natural gas, as the primary fu-el in the production processes of allGroup companies.

The energy produced by the Group in-creased by approximately 622%, driv-en primarily by the quantities con-tributed by the consumption of fuelsand the High-Efficiency CombinedHeat and Power (CHP) Plant ofALUMINIUM S.A., as well as by the op-eration of the power production plantsof PROTERGIA S.A. It should be not-ed that the energy produced from RESplants accounted for 2.8% of theGroup’s total energy production.

� ALUMINIUM S.A.

� PROTERGIA S.A.

� DELPHI-DISTOMON S.A.

� ΜΕΤΚΑ S.A.

21,8

28.648,2

27.599,1

70,2 48,4

Total consumption of direct energy per company in TJ

Total consumption of primary energy purchased: 41,584.7 Tj

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

Total consumption of directprimary energy (TJ) 2011 2012

Total direct energy consumption* 26,092.3 56,317.5

10.000,00

0,00

20.000,00

30.000,00

40.000,00� Natural Gas

� Fuel Oil

� Diesel oil(Transport, Heating, DBF)

� Petrol

39.023,6

2.457,592,3 11,3

Total primary energy produced: 32,022.8 Tj

0,0

3.000,0

6.000,0

9.000,0

12.000,0

15.000,0 � Energy from fuels (naturalgas, fuel oil, diesel oil, petrol)

� Energy produced from IPPs

� Energy produced from theCHP Plant

� Energy produced from RESplants

14.354,213.472,0

3,810.2

386,4

Total Consumption of secondary energy fromnon-renewable energy sources: 13,093.6 Tj

62

0,0

2,000

4,000

6,000

8,000

10,000

� Electricity

� Steam

� Petrol

9,282.2

3.810,2

1,2

The Group’s energy exports increasedby approximately 322% from 2011. Ofthe total energy exported by theGroup, 75% was contributed by thecombined-cycle IPPs of PROTERGIAS.A. to the Greek wholesale electric-ity markets, and 22% representedelectricity produced by all thermaland RES plants and injected into theGreek National Grid.

In addition, during 2012 our sub-sidiaries consumed in total 13,096 TJof secondary energy, about the sameas last year. Of this total quantity, 99%came from non-renewable sources,namely electricity (71%) and steam(28%).

At the level of the individual Groupcompanies, electricity consumptionposted a significant increase in the con-struction sites of METKA S.A., prima-rily as a result of “hot tests” and of thetrial operation under full load of the fa-cilities (power plants) whose construc-tion the company had undertaken.

Total primary energy exports: 17,290 Tj

0,0

3.000,0

6.000,0

9.000,0

12.000,0

15.000,0� Exports of energy from IPPs

� Injection of electricity fromthe CHP Plant into thenational grid

� Exports of energy from RESplants

13.033,2

3.870,4

386,4

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During 2012 the company contin-ued its systematic efforts for energyconservation, through initiativeswhich include the reengineering ofprocesses, the introduction of au-tomations and the refurbishment ofequipment in its production depart-ments. The implementation of theseinitiatives resulted in 1.22 TJ of en-ergy savings in total, up by approx-imately 336% from last year.

The operation of the company’sGas - fired Combined Cycle Thermalpower plants is based on Best Avail-able Techniques (BATs). The com-pany’s goal is to achieve the maxi-mum possible efficiency andavailability rates for its power pro-duction plants and to maintainthese throughout the year.

The company’s initiatives for en-ergy conservation (work qualitychecks, daily and weekly checks ofalumina quality, mobilisation-sen-sitisation of the personnel in-volved, optimisation of parame-ters, swift identification ofproblem-prone basins, improve-ments in equipment and meth-ods), resulted in a specific con-sumption of 13,255kWh/t – one ofthe best among all aluminiumplants.

Total Consumption of Secondary energy fromRenewable energy sources: 3,3 Tj

0,0

2,000

4,000

6,000

8,000

10,000

� Solar

� Hydropower

2,1

1,2

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

64

8.4 Water consumption

Total water consumption for the ac-tivities of MYTILINEOS Group in 2012stood at around 4.6 million m3 of wa-ter, down 1.6% from 2011, with95% of this total quantity consumedby our industrial production activities,namely aluminium production, andthe remaining 5% accounting for the

consumption of water by all other ac-

tivities. The water required for

aluminium production is obtained

from wells drilled and managed by

ALUMINIUM S.A. in the broader re-

gion around its plant, in strict com-

pliance with the provisions of the rel-

evant Decision of the Water Re-

sources Management Directorate of

the Sterea Regional Administration.

Of the above total quantity of waterconsumed, 96% was drawn fromgroundwater and 6.2% from the mu-nicipal water supply company, 1.5%refers to seawater used in the desali-nation process, and the remaining0.3% representing rainwater quanti-ties collected for consumption.

The areas from which the Groupcompanies draw water (especiallyALUMINIUM S.A., which has drilledand is using a network of wells in thearea around its plant facilities), do notcontain water masses regarded by ex-

perts as particularly sensitive, be-cause they support a specific endan-gered plant or animal species or be-cause they are located in any otherarea as a protected area.

� MYTILINEOS S.A.� ALUMINIUM S.A.� ΜΕΤΚΑ S.A.� PROTERGIA S.A.� DELPHI-DISTOMON S.A.

�

1.04%0.03%

3.28%0.25%

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,rivers, lakes and seas. 66,403.0

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’stotal water consumption. 0.043% 0.042% 0.11%

�On our Website:-Our policy and systematic actionsregarding the management of waterconsumption

Direct and Indirect CO2 emissions

8.5 Emissions

CO2 emissions

The production processes in all the ac-tivity sectors of MYTILINEOS Group re-sult in air emissions. These emissionsare under the law subject to specificlimits, to which the Group fully con-forms.

As part of our efforts to address theissue of Climate Change, we remaincommitted to our goal to identify thecarbon dioxide (CO2) emission sourcesin all our subsidiaries and to measure

and further reduce these emissions.

During 2012, our target regarding thedisclosure of the Group’s total carbondioxide emissions was not achieved.The relevant results, shown in thegraphs that follow, refer to 60% and20% of our subsidiaries for the dis-closure of direct and indirect CO2

emissions, respectively, and to 40% ofthe Group companies for the disclo-sure of other significant greenhousegas emissions. As a result, specificquantitative targets for their overall re-duction cannot be set for next year.

The increase of direct CO2 emissionsobserved in 2012 is due to the emis-sions from the Combined Heat andPower Plant (CHP) of ALUMINIUMS.A., as a result of its consumption ofnatural gas, which was not used in2011, and to the operation of thetwo power production plants ofPROTERGIA S.A. – the Ag. NikolaosPlant (Viotia), which was in operationfor entire year, and the Ag. Theodor-oi Plant (Korinthos), which entered in-to commercial operation in April2012.

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0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

2011 2012

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

535,801

2,490,643

3,026,444

2,503,1692,185,241

4,688,410

In the Metallurgy sector (aluminium production):

Emissions from fuel oil burning are calculated in accordance with theprovisions of Decision 2007/589/EC (Annex II), using a national emis-sion factor and the corresponding Net Calorific Value (NCV). Emissionsfrom the lime production process are also calculated in accordance withthe same Decision (Annex VIII). Emissions from the anodes baking andconsumption processes are calculated using the formulas of the IPCCguidelines, as these were adopted by the Implementing Regulation2011/540/EC.

For calculating indirect carbon dioxide emissions, a conversion factor of0.85 was used (i.e.: electricity consumption in kWh*0.85). More specif-ically, the factor used for 2011 was 0.85 t CO2/MWh. This factor isweighted for the contribution from each type of energy source.

In the Energy sector:

The methodology for the calculation of carbon dioxide emissions is basedon calculations in accordance with the stipulations of Annex IV of Di-rective 2003/87/EC and the provisions of Decision 2007/589/EC. Emis-sions from source flows are determined based on activity data obtainedwith the help of measurement systems and on additional parametersresulting from laboratory analyses or standard emission factors.

Methods for the calculation of direct and indirect CO2 emissions

Other significant air emissions (ton)

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0

1,000

2,000

3,000

4,000

5,000

1,023.0

1,444.5

16.1 2.7 57.7 19.2222.9 239.2

5.1 7.4 157.7 110.1

4,330.5

3,553.9

Nox Sox N20 CH4 Fluorideemissions

PFC’s Particles

� 2011� 2012

Calculation methods for ΝΟx, SOx and Dust emissions

Nevertheless, the environmental strat-

egy of MYTILINEOS Group comprises

key initiatives that focus on improv-

ing our performance relating to green-

house gas and CO2 emissions over the

next years. These include the follow-ing:

� The most extensive possible use ofnatural gas as the primary fuel in-stead of oil in aluminium production,

with ALUMINIUM S.A. already mak-ing efforts to optimise the use oflime (purchase/production).

� In the Energy sector, PROTERGIAS.A. by selecting natural gas as the

In the Metallurgy sector (aluminium production):

Α. Dust:

Dust concentration in the plant’s point emission sources is meas-ured as follows: (a) By isokinetic sampling, with a frequency of foursamplings per year at the plant’s Α070, FLN, H15, H1, H28 chim-neys; (b) using continuous measurement analysers at the anodeskiln, revolving and static components and lime kiln furnaces; and(c) by isokinetic sampling, with monthly samplings at the no. 1-2and no.3-4 Gas Treatment Centres for the electrolysis gases. Forcalculating the quantities of annual emissions in tons, the followingwere used: (a) For point sources where isokinetic sampling is used,the average of the four concentration values (in mg/Nm3) and ofthe flow rate (in Nm3/s); and (b) for point sources where contin-uous measurement is used, the average of the daily concentrationvalues (in mg/Nm3) and of the flow rate (in Nm3/s) from the iso-kinetic samplings of all years for which these are available.

Β. ΝΟx:

Annual emissions of nitrogen oxides refer only to fuel consump-tion (fuel oil) and were calculated stoichiometrically, using an emis-sion factor of 5.363 g/kg of fuel (Guide to Energy Investments, Min-istry of Development, 2005). NOx emissions from processes are notmeasured or calculated (no official method is available yet).

C. SO2:

Annual sulphur dioxide emissions refer only to fuel consumption(fuel oil) and are calculated based on its sulphur content as this isshown on the chemical analysis sheets. Sulphur dioxide emissionsfrom the anodes baking process are not calculated (no verifiablemethod is available).

In the Energy sector:

In the case of the power production plants of PROTERGIA S.A., be-cause of the quality of the consumed fuel (natural gas), no emis-sion limit values apply for SO2 and particle emissions (in accordancewith the Environmental Terms Approval Decisions in force for theseplants, and under the applicable Community and Greek law on airemissions from combustion plants). Consequently, emission limitvalues only apply for NOx (in this particular case, NO2) with the fol-lowing acceptance limits:

- 50 mg/Nm3 (on a dry basis with 15% Ο2), for operation with aload above 70%;

- 75 mg/Nm3 (on a dry basis with 15% Ο2), for operation with aload above 70% and with an annual total electrical efficiency above50%.

NOx levels are measured continuously by the plants’ CEMS and the values loggedare expressed in mg/Nm3. On the basis of inventory data, acceptance limitswere not exceeded.

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28.6 Significant spills

During 2012 a total of 27 incidentswere recorded in DELPHI-DISTOMONS.A. involving spillage in the soil in un-derground tunnels, due to the break-down of machinery, of lubricantsweighing nearly 3.5 tons, a quantity re-duced by 30% from the corresponding

one for 2011. The company respond-ed immediately, dealing with the in-cidents and collecting the contami-nated soil. No high or medium gravi-ty environmental pollution incidentsoccurred and no incidents were re-ported involving the spillage of haz-ardous materials to the environmentby any other Group company.

primary fuel to produce electricityand by using Combined Cycle Ther-mal Power Plants (CCGTs) and HighEfficiency Combined Heat and Pow-er (CHP/High Efficiency CHP) with atotal production capacity of 1,200MW, which introduce Best AvailableTechniques (BATs) and, because oftheir flexibility and high efficiency,contributes towards the reductionof greenhouse gas emissions. InRenewable Energy Sources,PROTERGIA S.A. is already produc-ing electricity from Wind farms (36MW in operation), Photovoltaicplants (11.5 MW in operation) andsmall Hydropower plants (6 MW inoperation) and is developing a1,400 MW portfolio of RES assets invarious licensing stages.

These investments will also sub-stantially contribute to the effortsfor achieving of the 20-20-20 targetfor Greece.

� In the EPC sector, METKA S.A. isplanning to replace oil with naturalgas as the fuel used in its Plants andOffices, to use company cars withnew, low-emissions technology, andto replace Freon in its refrigeratingmachinery with new technologycooling agents.

� We also intend to explore theprospects regarding the applicationof the innovative Carbon Captureand Storage (CCS) technology.

8.7 Waste managementThe efforts to optimise the manage-ment and utilisation of our waste arebased on the principles of waste min-imisation and proper disposal. The keygoals of MYTILINEOS Group are to re-duce the quantity of waste disposedin landfills and at sea, and to increasein parallel the use of recycling.

In managing its solid waste,MYTILINEOS Group follows a clearlydefined procedure with specific stages,summarised below:

� Waste production: Refers to thestage where certain types of solidwaste are designated as undesirableand the decision is taken either tothrow them away or to collectthem for disposing of them centrally.Sorting of materials for recycling orrecovery takes place at this stage.

� On-site management (storage):During this stage, the future ofwaste is decided. On-site storage isof primary importance because ofaesthetic and public health reasons,but also because of the financial costto the companies.

� Collection: During this stage, wasteare collected and loaded onto theirtransport means (usually a vehicle),for transport to a transfer station,treatment location or disposal area.

� Transport: Refers to the stagewhere waste is transported to atransfer station and from there tothe treatment location or disposalarea.

� Treatment/recovery: During thisstage, a variety of processes andequipment are used to either utilisewaste itself by improving certaincharacteristics or to obtain useful in-gredients/components or energy.

� Disposal: This stage refers to the fi-nal disposal of waste.

During 2012 we permanently dis-continued the disposal of bauxiteresidues at sea. The quantity of non-hazardous waste disposed through re-cycling increased by 35% from lastyear, and the quantity of waste dis-patched to Landfills, primary fromaluminium production, increased by22%.

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.

68

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

In more detail, for 2012 the types and quantities of the Group’s waste and the corresponding disposalmethods 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 packagingmaterials, aluminium, iron scrap, batteries, metals & metalliccompounds)

3,182.1 4,957.7 +55.8%

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

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& old tyres) 66,100.0

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

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

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

�On our Website:- Our policy regarding waste management

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TOTAL WASTE948,660 ton

TOTAL WASTE1,413 ton

TOTAL WASTE34.2 ton

TOTAL WASTE75.9 ton

TOTAL WASTE1.2 ton

98%

2%

99.9%

0.1%

37.4%

62.6%

57%

43%

0.0%

100.0%

� Hazardous Waste - � Non-Hazardous Waste

MYTILINEOSGROUP Companies

Waste Quantities2012 Clarifications / Comments

The quantities of the company’s waste did notvary significantly compared to 2011. A majorachievement for the company during 2012 wasthe permanent discontinuation of the disposal ofbauxite residues (red mud) at sea.

20% of all hazardous waste produced by thecompany are recycled.

The increase of the quantity of non-hazardouswaste of METKA S.A. is primarily the result of theemphasis which was given on the provision ofrelevant information and training to employees,which increased their sensitisation, and to theincrease in the number of waste collection pointsin company facilities .

100% of all waste produced by the companyare recycled.

The significant increase of company's total wastearises from the commercial operation of two newpower production plants during 2012. Thecompany also produced 50,840m3 of liquidwaste, of which 3,340 m3 were recycled and therest (47,500 m3) were delivered to the wastetreatment plant of MOTOR OIL S.A.

100% of all waste produced by the companyare recycled.

An increase by 72.9% of hazardous waste wasposted in the company, due to the existence of astock of mud from natural separation (dating backto 2011), which was disposed through a certifiedorganisation during 2012. Correspondingly, thereduction of the quantity of non-hazardous waste(-27,5%) is due to the lower quantity of wasteproduced (tyres and scrap).

100% of all hazardous waste produced by thecompany are recycled.

The company posted a reduction in the quantityof its waste (-71.5%), as a result of the reducedquantities of batteries and paper for recycling,given also that in 2011 these quantities had beensignificantly higher due to the clearance ofwarehouses and archives and to the recycling ofold paper files.

100% of all waste produced by the companyare recycled.

The total expenditures budgeted andcarried out in 2012 in connection withthe implementation of the Group’s en-vironmental policy stood at €10.7 mil-lion. This amount is reduced by around17% from the corresponding amountin 2011, due primarily to cuttings inprevention and environmental man-agement expenditures, a move madenecessary by the increased level of ex-penditures during 2011 for the imple-mentation of new environmental pre-vention projects in aluminium produc-tion, such as: the configuration of dis-

posal areas for bauxite residues, the re-habilitation of landfills for Hazardousand for Non-Hazardous waste, the in-stallation of the 3rd and 4th Filter Press-es for the treatment of bauxite residues,and the conversion of fuel oil boilers inthe local settlement.

In detail, the total amount for 2012 in-cludes €7.1 million of investments,which correspond to 66.7% of the to-tal expenditures and concern wastetreatment and discharge, the treatmentof gas emissions (e.g. expendituresfor filters, active equipment), and ex-

penditures for the installation of clean-er, more environmental-friendly tech-nology. The remaining €3.6 million or32.3% of total expenditures were al-located to environmental manage-ment actions such as: Development andapplication of quality control systemsunder the ISO 14001 InternationalStandard, independent certification ofEnvironmental Management Systems,various chemical analyses carried out,Research & Development, protection ofgreen areas, offices and facilities etc.

70

2011

2012

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

� Waste treatment and discharge

� Gas emissions treatment(e.g. expenditures for filters, active equipment)

� Expenditures for the purchase and useof gas emissions certificates

� Depreciation of relevant equipment, operation-related materialsand services, and personnel-related costs

� Environmental liability insurance

� Cleaning costs, including spillage rehabilitation costs

� Landscape rehabilitation (landscaping, fencing planting,watering-fertilizing)

35.4%

3.1%

0.1%

4.4%

1.5%

16.7%

38.9%

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

� Prevention and Environment managementcosts

� Waste disposal, Gas emissions treatmentand Rehabilitation costs

8.8 Environmental expenditures

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The conservation, protection and re-habilitation of biodiversity are core en-vironmental goals of MYTILINEOSGroup. To this end, we have ensuredthat the facilities of our subsidiaries, es-pecially in raw materials mining,aluminium production and construc-tion, are not adjacent to areas pro-tected by law and to areas of high bio-diversity value. Thus, there are no sig-nificant effects that may have an ad-verse direct or indirect impact on theintegrity of the area where the facili-ties of our companies are located.

In the Metallurgy sector (aluminiumproduction), in addition to the estab-lishment of an initial inventory of thelocal flora and fauna, checks are car-ried out to monitor the quality of theflora in the wider region, to the extentthat this is introduced into the foodchain. The Company operates a net-work of 28 stations for static meas-urements of fluoride levels, locatedwithin a radius of 0 to 12 km aroundthe ALUMINIUM S.A. plant. In addi-tion, samplings take place and chem-ical analyses are carried out to deter-

mine the fluoride content of olive treeleaves, vine leaves and pine needles(twice per year), as well as that ofgrapes (once per year).

Furthermore, the Group’s mining ac-tivity for the production of aluminiummay impact on the biodiversity of fau-na and flora. To mitigate this impact,Environmental Impact assessmentsand rehabilitation plans have been de-veloped and are carried out for the ar-eas affected. In more detail:

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

� Third-party services for environmental management

� Independent certification of Environmental Management Systems

� Personnel for general Environmental Management activities

� Research & Development

� Additional expenditures for installation of “cleaner” technology(e.g. extra costs in addition to standard technology)

� Other environmental management costs

14.7%

5.9%0.3%

1.6%

56.3%

21.1%

8.9 Biodiversity

Locations where rehabilitationwork has been completed oractive protection measures aretaken

Areain km2

Rehabilitationpercentageof the area

on 31.12.2012

Rehabilitation approved /under approval by

independent specialistorganisations or scientists

VARTOS B 0.4 100% Amfissa Forest Department

PSILO KOTRONI 0.2 100% -

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

PERA LAKKOS 0.02 100%

PROSOREMA 0.18 90% -

LIMESTONE QUARRY AREAMetohi (Kyriaki municipality ) 0.018

Rehabilitation of 2,500 sq.m.with 1000 saplings planted,

according to the usageof the quarry.

-

LANDFILL FOR HAZARDOUS WASTE(Agios Athanasios)

Planting of 2500 plants(~3,500 sq.m.). -

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Significant direct andindirect impacts onbiodiversity

Significant direct andindirect impacts onbiodiversity

The disposal of bauxite residues on land (asdeclared in the indicators for 2011) had a localisedimpact on biodiversity. As this particular practicewas not extended, impacts have not worsened anyfurther.

Power plant producing electricity from windenergy (Wind farm), located adjacent to an areaprotected by law, is environmental-friendly, withzero pollutant emissions, zero soil pollution andnegligible disturbance of the local flora and fauna.

Management of impactson biodiversity from theGroup’s activities.

To address the impacts on biodiversity from thedisposal of bauxite residues on land, the companytakes measures to deal with dust emission, whichinclude the following:1. Scheduled maceration, particularly during the

summer or in general during low-humidityperiods.

2. Coverage of slopes with topsoil, after carryingout relevant technical studies.

3. Maintenance of the access roads alreadyopened, to avoid new impacts from theopening of new ones.

4. Launch of a large-scale water-engineeringproject to capture and retain rainwater withinthe area designated for the disposal of bauxiteresidues, so that it can be discharged in acontrolled way without adverse impacts.

1. The protection of biodiversity as an aspect ofthe natural environment is expressed indirectlyin the company’s environmental policy.

2. Full compliance with the environmentallegislation in force, in the context of therestrictions and special conditions imposedregarding the operation of the company’sthermal power plants and RES plants.

3. It is pointed out that the environmentallegislation also includes the legislativeinstruments on the protection of theenvironment, and the company's power plantshave been granted their operating licensestaking into consideration the protection ofbiodiversity.

4. Development of additional specialised studies inregions where projects are carried out, even ifthese studies are not mandatory under the lawsin force, in order to ensure the protection ofbiodiversity of the wider region.

5. Adoption of protection and rehabilitationmeasures through the operation of thecompany’s projects.

6. In its relations with the local communitieswhere its projects are developed, the companyimplements compensatory actions, some ofwhich focus on the protection of the naturalenvironment and biodiversity.

The Energy sector presents certain par-ticularities, as according to the laws inforce on the protection of the envi-ronment and of biodiversity, con-struction of power production plantsis allowed inside protected areas be-longing to the NATURA 2000 Net-work. The power plants (thermal andRES plants) of our subsidiaryPROTERGIA S.A. are constructed andoperated to the strictest technicaland operational standards, in fullcompliance with the applicable Com-munity and national laws on the pro-tection of biological diversity. From the

company’s power production plantscurrently in operation, only the windfarm at Sidirokastro (Prefecture ofSerres), for which 0.12 km2 of landwas allocated, lies at a distance of 1.5km from the outer boundary of thearea proposed for inclusion in theNATURA 2000 Network with code GR126000, and of more than 15 km fromthe Special Protection Area with codeGR 126008. It is an environmental-friendly power plant, with zero pollu-tant emissions, zero soil and subsoilpollution and negligible disturbance tothe indigenous flora and fauna. Minor

impacts, if any, are fully remediedbased on specialised studies developedand applied (rehabilitation plantingstudies, ecological studies, ornitho-logical studies etc.).

The table below summarises the im-pacts of our activity on biodiversity andthe management of these impacts inthe Metallurgy sector (aluminium pro-duction) and the Energy sector (elec-tricity production), through our sub-sidiaries ALUMINIUM S.A. andPROTERGIA S.A., respectively.

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The strict adherence to the applicablelaws and regulations by the Groupcompanies, the implementation of anenvironmental legislation review and up-dating procedure, and the applicationf all relevant regulations concerning theGroup's activities, have resulted in theabsence of sanctions (monetary or oth-erwise) for non-compliance with envi-ronmental provisions. Furthermore, thefindings of the unannounced inspec-tions and audits carried out in theGroup companies by the Environmen-

tal Inspectors Service during 2012 werevery positive, as no remarks were made

and no violations of environmentalrules and regulations were established.

Significant direct andindirect impacts onbiodiversity

Construction or use ofplants, mines and transportinfrastructures.

No change from 2011. Nil.

Pollution. No pollution incidents reported in the wider areaof the plant facilities (including the areas fordisposal of bauxite residues and of solid wastefrom the production process).

Nil.

Introduction of invasivespecies, pests andpathogenic organisms.

Does not apply to the company. Does not apply to the company.

Reduction of species. According to a recent study by the Hellenic Centrefor Marine Research (HCMR), sea populations donot appear to have sustained significant changescompared to previous studies. For landpopulations, no studies have been carried outrecently (the latest one has been included in theEnvironmental Impact Study (EIS) 2007.

Nil.

Preservation of the naturalhabitat.

No change from 2011. No change from 2011.

Changes in ecologicalprocesses outside thenormal differentiationrange.

None due to the company’s activities. Nil.

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 irreversibilityof impacts.

Has not been investigated. Fully reversible for flora / Nil for fowl afterthe adoption of measures.

8.10 Compliance with environmental laws and regulations

9. SOCIAL COHESIONAND DEVELOPMENT

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Guided by our values of “SociallyResponsible Development”and “Gaining the trust of the

society around us”, we continue ourefforts to enhance our role as an ac-tive corporate citizen in the localcommunities on which our activities,depending on their nature, have a pos-itive or negative effect. Based on theexperience from our participation in so-cial contribution initiatives and onthe positive messages that we receive,and with no intention of downplayingthe importance of potential omis-sions or of turning a blind eye to theadverse impact of our activities, we areconvinced that our involvement in pro-moting social cohesion can helpachieve prosperity for the local com-munities where we operate. In linewith the above, in 2012 we consideredthat it was necessary to determine the

key social development issues whichare of concern to us and throughwhich we feel that we can make an ac-tive contribution.

This procedure did not involve themere listing of issues, but insteadwas carried out by executives in oursubsidiaries who are members of therespective CSR teams, with knowledgeand experience in the specific subjectarea, thus bringing significant addedvalue to the task. The results of this ex-ercise, shown on the graph below andaccompanied by clarifications and ref-erences to the corresponding actions,represent the Group’s Social Foot-print. It is our intention to make thisdisclosure on an annual basis, so thatany changes or deviations in our socialperformance can be immediately vis-ible to our Stakeholders.

We have retained

2,000jobs across the Group, despitethe adverse economic conditionsin the country.

Our social investmentsstood at

€740 thousandpromoting culture, sports andentrepreneurship, while alsohelping meet infrastructure needsin the local communities.

We implemented for the3rd

consecutive yearthe process of dialogue withour key Stakeholderswith positive results.

We have produced and aredisclosing for the first time our

Social Footprint.

9.1 Social Footprint of MYTILINEOS Group

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Performance: 2/5

Performance: 2/5

Performance: 2/5

Performance: 2/5

Performance: 0,5/5

Performance: 0,75/5

Performance: 0,5/5

Performance: 0,5/5

Performance: 0,5/5

Performance: 0/5

Performance: 0/5

Performance: 0/5

Performance: 0/5

Performance: 0/5

Performance: 1,25/5

Performance: 0,25/5

Performance: 4/5

Performance: 3/5

MYTILINEOS GROUP SOCIAL FOOTPRINT 2012IMPACT LEVEL

No impact(0)

Insignificantimpact

(1)

Limitedimpact

(2)

Moderateimpact

(3)

Significantimpact

(4)

Verysignificant

impact(5)

1. Corporate image & reputation.

2. Legal & Regulatory Compliance.

3. Tax Compliance.

4. Dialogue with Stakeholders.

5. Employee Safety.

6. Employee Health.

7. Employee Satisfaction.

8. Employee Education & Training.

9. Employee Development.

10. Strengthening employability(recruitment from localcommunities).

11. Investments to meet basic needsin the life of local communities.

12. Preference for products andservices from local suppliersand contribution to theirdevelopment.

13. Promotion of the right to healthand avoidance of activitiesposing a risk to public health.

14. Actions to combat corruption.

15. Actions to combat forced labour.

16. Actions to combat forced labourin the company’s principalsuppliers and associates.

17. Actions to combat child labour.

18. Actions to combat child labourin the company’s principalsuppliers and associates.

SOCIALFOOTPRINTCOMPONENTS

76

Limited complaints at the local level for ALUMINIUMS.A. and PROTERGIA S.A.

ACTION PLAN:To eliminate complaints by incorporating the results of theconsultations (Dialogue Forums) with our Stakeholders inour Corporate, Social and Environmental strategy.

The Group companies fulfil completely all their taxobligations, at local as well as at central level.

Each Group company has defined its Stakehold-er groups and engages in regular dialogue with

them. The results of this consultation process are pub-lished annually.

ACTION PLAN:(a) To improve and reconfigure the consultationprocess with our Stakeholders; (b) To include HumanRights Protection and the Actions to combat -Cor-ruption as subjects in the consultations with ourStakeholders; (c) To intensify our efforts for incor-porating the results of the consultations with ourStakeholders in the development of the business, so-cial and environmental plans of our subsidiaries.

During 2012 a number of light accidents occurred,without interruption of work. NOTE: Two (2) ac-

cidents that led to interruption of work occurred in AL-IMINIUM S.A.

ACTION PLAN:Although our performance is stable, constant effortsare required in accordance with our policy which focuseson the achievement of the only acceptable target – “ZE-RO ACCIDENTS AND ZERO INCIDENTS RELATED TO OC-CUPATIONAL DISEASES IN OUR WORK AREAS”.

A very small number of light incidents related tooccupational diseases occurred, without inter-

ruption of work.

ACTION PLAN:Although our performance is stable, constant effortsare required in accordance with our policy which focuseson the achievement of the only acceptable target – “ZE-RO ACCIDENTS AND ZERO INCIDENTS RELATED TO OC-CUPATIONAL DISEASES IN OUR WORK AREAS”.

All Group Companies comply fully with the reg-ulations and the provisions of the law that govern

their operation.

Employee satisfaction ranges from 60% to 70%.NOTE: This aggregate performance is a “guessti-

mate” based on the employee performance reviewprocess. ALUMINIUM S.A., PROTERGIA S.A. andMETKA S.A. do not have in place a mechanism to reg-ularly measure employee satisfaction.

ACTION PLAN:To study and design a procedure for conducting reg-ular employee satisfaction surveys in all our Groupcompanies. Actions will be planned according to theresults obtained.

All Group companies have in place a formal ed-ucation and training policy and carry out annu-

al educational initiatives with clear objectives, whichare aligned with their business activities and with theiremployees’ needs.

ACTION PLAN:To improve our educational objectives in order tocombine more effectively the employees' needs withthe Group’s social and environmental objectives.

The aggregate percentage of employees evaluatedthrough the Career Development Review process

applied by the Group companies’ ranges from 81% to90%.

ACTION PLAN:To achieve a percentage in excess of 90% of em-ployees receiving Career Development Reviews,through the systematic application of the proceduresfor Career Development Reviews which our sub-sidiaries have in place.

The aggregate percentage of employees re-cruited from the local communities where the

Group companies operate ranges from 70% to85%.

ACTION PLAN:No deviation from our policy on recruitment of em-ployees from our local communities, whose objec-tive is to achieve a percentage in excess of 85% (al-ways taking into account the particular character-istics of each one of our business activity sectors).

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

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A common principle of all Group companies is tocover their local communities’ basic needs in in-

frastructures, always taking into account the particu-lar characteristics of each one of our business activitysectors (irrespective of the percentage of their totalturnover), thus helping their efforts for prosperity.

The total contribution of the Group companies tolocal suppliers, expressed in terms of economic val-

ue, ranges from 11% to 31% of the Group companies’total purchases budget. NOTE: In meeting their needs,ALUMINIUM S.A. and DELPHI-DISTOMON give priorityto local suppliers (according to their needs and specif-ic characteristics and irrespective of the correspondingshare of their total purchases budget), thus contribut-ing to the development of the local economy and to theprosperity of the local community where they operate.

ACTION PLAN:No deviation from our policy, whose objective is togradually stabilise the share of outlays to local sup-pliers to a level between 40% and 50% of the to-tal purchases budget (always taking into account theparticular characteristics of each one of our businessactivity sectors).

The Group companies undertake, through theadoption of international and national standards

that the stages of their products’ lifecycle and their ac-tivities in general do not pose risks to public health.

ACTION PLAN (for all subsidiaries):To collaborate with NGOs and to implement vol-untary initiatives for the prevention of serious dis-eases (other than occupational ones), which will beaddressed to their employees and to the citizens ofthe local communities where they operate.

No incidents of corruption were reported in anyof the Group’s subsidiaries. Nevertheless, the

Group does not have in place a separate organisationalunit responsible for the management of risks associ-ated with corruption.

ACTION PLAN:To establish collaborations with specialised organ-isations and to design a custom internal controlmechanism that will allow us to formally audit ourbusiness units in this regard.

All Group business units comply with the laws inforce. No incidents of forced or compulsory labour

have occurred in any one of the Group’s subsidiaries.Nevertheless, there is a need for establishing a specificprocedure that will allow the Group to formally auditits business units in this regard.

The Group companies have secured the com-mitment of 31%-60% of their principal associates

and suppliers to the adoption of measures to combatforced labour in their activities.

ACTION PLAN:To promote the principles of the UNGlobal Compactin our supply chain, in order to secure the commitmentof the Group’s principal associates and suppliers – ata level between 60% and 90% – to the avoidance ofpractices which may encourage forced or compulso-ry labour in their work environment.

All Group business units comply fully with the lawsin force. No incidents of child labour have been

reported.

The Group companies have secured the com-mitment of 31%-60% of their principal associates

and suppliers to the adoption of measures to combatchild labour in their activities.

ACTION PLAN:To promote the principles of the UN Global Compactin our supply chain, in order to secure the commit-ment of the Group’s principal associates and sup-pliers – at a level between 60% and 90% – to theavoidance of practices which may encourage childlabour in their work environment..

11.

12.

13.

14.

15.

16.

17.

18.

78

With the aim of helping develop andmaintain social cohesion in the localcommunities where our activities areof a higher visibility, we have focusedour efforts through our subsidiaries onareas which are directly related to ouractivities.

More specifically, our efforts focus onthe following:

� The provision of jobs: With 2,000jobs maintained and 374 new em-ployees recruited, in 2012 the num-ber of employees coming from ourlocal communities reached 85% ofour total workforce.

� The creation of income: Our a sys-tem of employee compensationstakes into account the market situ-ation as well as the expectations ofemployees, and is combined with

benefits over and above the statu-tory ones and those provided underagreements based on collective ne-gotiations.

� The development of our local eco-nomic activities: During 2012 near-ly 30% of the purchases budget ofour companies represented pay-ments to local suppliers, but also ex-penditures for the provision ofknow-how and technical support toLocal Authorities and other local or-ganisations.

� The added value generated by ourbusiness operation: In the EnergySector in particular, the developmentof projects based on RenewableEnergy Sources (RES) through oursubsidiary PROTERGIA S.A. has al-lowed us to offer significant bene-

fits to the local communities and toalso contribute to the progress in theachievement of national targets(such as the 20-20-20 target underthe EU’s energy strategy).

Environmental benefits from thedevelopment of RES projects

� Significant reduction of the gas pollutants producedwhen using mineral fuels (lignite, coal, oil) and con-tributing to Climate Change, by substituting the “fu-el” used to produce electricity with air, water and so-lar energy.

� Virtually zero environmental disturbance (e.g. noise),minimal disruption to the natural ecosystem and pro-tection of biodiversity (flora and fauna) in the widerarea.

� Improvement of the existing road networks and routesin the wider area where the RES project is located.

� During the final land allocation stage, the specific fea-tures of each site are taken into consideration, so thatthe wind turbines will blend harmoniously with thelandscape.

� During the construction of RES projects, works are car-ried out in an environmental-friendly manner and allnecessary measures are taken to ensure the rehabili-tation of the site, not only during construction but –more importantly – during its operation, so that in itsfinal form the site is fully integrated into the naturalenvironment.

Economic and Social benefits from thedevelopment of RES projects

� Investments in “green growth” projects, which are keyfor Greece’s growth in the current economic juncture.

� Guaranteed income for the local communities from theoperation of the RES projects. According to art. 7, par.3(A.3) of Law 3851/2010, the amounts correspondingto the special tax are withheld by the competent Op-erator and paid as follows:

- 1% is credited to the electricity bills of household con-sumers in the Local Authority;

- 1.7% to the Local Authority;

- 0.3% to the Special Fund for the Implementation ofMaster Plans and Land Use Plans (ETERPS).

� Stimulation of employment in the local communitiesduring construction and operation of the projects.

� Revitalisation of economically and socially disadvan-taged areas and contribution to local developmentthrough the promotion of similar investments, drivenby the development of the RES project (promotion ofeducational tourism for RES projects) and by the con-tributions from the project-owner companies in thecontext of their CSR policies.

9.2 Participation in the development of local communities

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2In accordance with the policy ofPROTERGIA S.A., a Memorandum ofUnderstanding (MoU) is concludedbetween the company and the localauthorities regarding the implemen-tation of public benefit projects, in-frastructure works or cultural activitiesin the area concerned, aiming to im-prove the quality of life of local resi-dents, in consultation and collabora-tion with the local Municipality and de-pending on the latter’s needs, with thelocal community stating its acceptanceof the RES project. Public benefit

projects in support of local communi-ties are implemented primarily duringthe construction stage of RES projectsand can indicatively include the fol-lowing:

� Donations to Municipalities towardsthe purchase of vehicles and equip-ment required for the operation ofMunicipal Services and for fire pro-tection.

� Construction of infrastructure worksthat will improve the life of the Mu-nicipality residents, such as roadbuilding or maintenance, repairs or

construction of Municipal buildingsand facilities, in collaboration withthe Municipalities concerned and de-pending on their needs.

� Creation of environmental parksand recreation areas adjacent to thecompany’s RES projects, so that thesite can become an EducationalTourism attraction.

�On our Website:- Our Management Approach regardingour Local Communities

80

9.3 Social expenditures

Our role in our local communities is pri-

marily determined by our desire – and,

secondarily, by our capability – to help

address and promote issues of concern

for our local communities, which are

hard-hit by the financial and social cri-sis that Greece has been experiencingduring the last years. Seeking to keepalive the ideals of Sports, Arts and Cul-ture, to assist Non-Governmental Or-ganisations in their work and to supportfor yet another year the efforts to pro-

mote Entrepreneurship, our social pol-icy in 2012 – which in terms of expen-diture stood at around €740,000 – wasexpressed by all our subsidiaries andcovered a diverse range of social issues,as shown in the graphs below:

Key sections• Donation of technical equip-

ment to one Lower SecondarySchool and one Upper Sec-ondary School in the Munici-pality of Patmos.

• Donation of clothing articles &toys for the Christmas Bazaarof the "Friends of the Child”Association.

• Financial assistance for the“Dare to Lead” Executive Din-ner event organised by theICAP Group.

Key actions• Repair and reformation of

the Rural Medical Station inKatsaroni (Evia).

• Financial assistance for theneeds of the Municipality ofSintiki (Sidirokastro).

• Financial assistance to theIFNA International Non-prof-it Educational ResearchOrganisation.

Indicative actions• Financial assistance to the

FOKIKOS Football Team andof two children’s footballacademies.

• Financial assistance to theAmfissa and Itea voluntaryblood donor societies.

• Provisioning and moral sup-port for the establishmentand operation of the SocialGrocery Store of the Munic-ipality of Delphi.

Key actions• Financial assistance to the

foundations of the Holy Me-tropolis of Thiva and Levadia.

• Long-standing financial sup-port and assistance in kind(equipment and materials) ofthe ASA and Medeon SportsClubs.

• Exclusive sponsorship of the lit-erary magazine “Emvolimon"and of the events it organisedin Aspra Spitia.

• Technical support and dona-tion of materials to the schoolsof the Municipality of Dis-tomon, Arachova and An-tikyra.

Key actions• Donation of equipment (PCs

to schools, prefabricated con-structions, medical equip-ment).

• Support of the Social GroceryStores in the area of Voloswith food provisions.

• Long-standing assistance tothe ELEPAP organisation andannual “financial adoption"of one child without healthinsurance from the 12 chil-dren under ELEPAP’s care.

• Financial support of thepreparation of athletes for theLondon 2012 Olympic andParalympic Games.

• The company was the Exclu-sive Sponsor of the 13th Jun-ior Synchronised SwimmingChampionships hosted in Vo-los.

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

16%17%

3%

34%

30%

� PROTERGIA S.A.

� METKA S.A.

� DELPHI -DISTOMON S.A.

� ALUMINIUM S.A.

� MYTILINEOS S.A.

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

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� Sports

� Arts & Culture

� Environment

� Local Authorities

� Education

� Strengthening Entrepreneurship

� Support of NGOs

� Employees

� Donations

33.5%

6.7%

7.7%

14.0%

0.1%

13.2%

7.8%

7.1%

9.9%

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

82

Corruption, bribery and extortion un-dermine the moral environment ofbusinesses and have a broad range ofnegative effects, as they can result inviolations of Human Rights, in adverseimpacts on the environment, in dis-tortion of competition, and in im-pediments to the distribution ofwealth and economic development. Ingeneral, they are a major hindrance tosustainable development, with a dis-proportionate impact on poor com-munities, and corrode the very fabricof society.

In MYTILINEOS Group, the referencesfor our efforts to promote trans-parency are the following two: Ourcorporate value which refers to thePrinciple of Integrity in all transactionsand which is implemented by avoidingall transactions and contacts withany third party which may be guilty orsuspect of encouraging conditionsgiving rise to corruption, extortion orbribery; and Principle 10 of the UN

Global Compact, according to which“We work against corruption in all itsforms, including extortion andbribery.”

Additionally, as the formal develop-ment of an internal control mechanismfor prevention and detection of inci-dents of corruption or bribery has notyet been completed, we are takingsteps at the Group level to evaluateand improve our risk management pro-cedures and to verify the complianceof our subsidiaries' operations with ourestablished policies and procedures, asthese are defined in our Code of Pro-fessional Ethics, in the Internal Rulesof Operation of each individual com-pany, and in the laws and regulatoryprovisions in force. Furthermore, wetake care to ensure that the collabo-rations and transactions of all share-holders and employees, in all Groupcompanies, are characterised by ahigh level of integrity and by highmoral standards. Through the proce-

dures for the selection of suppliers andother associates which our Purchasesand Procurement Units have in place,we check the conditions under whichevery single transaction is carried out,in order to identify and eliminatethose which may give rise to incidentsof corruption, extortion or bribery.

During 2012, we applied all neces-saryinternal procedures to ensurecompliance with the aforementionedprinciple. With regard to the above, noreports were made of conditionswhich may give rise to incidents of cor-ruption in the Group companies, norhave such conditions been identifiedin them. Nevertheless, our plans for theimmediate future include the imple-mentation of concerted preventiveactions, including the provision ofspecific training to our employees ofall levels and the formal audit of ourbusiness units for the existence of con-ditions which may give rise to incidentsof corruption, bribery or extortion.

9.4 Actions to strengthen Transparency & combat bribery

The total contribution of theGroup companies to localsuppliers, expressed in terms ofeconomic value, stood at

30% of the Groupcompanies’ total purchasesbudget.

100% of our business

units have in place Quality

Management Systems certified in

accordance with the ISO 9001

international standard.

We are seeking to ensureregulatory compliance and, in linewith our key principles,

we avoid anycooperation withpotential unfaircompetitorswhich may lead to anti-competitive behaviour orpractices.

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10. FAIR MARKETPRACTICES

All MYTILINEOS Group compa-nies place particular emphasis onthe quality of the products they

manufacture and of the services thatthey offer. The innovations which are ap-plied in production processes and whichimprove the quality, safety and envi-ronmental impacts of the final product,are considered to represent business op-portunities. Although in most cases theclients of the Group are not the endusers of its products, the Group’s poli-cy is to ensure that all the products itplaces to the market will fully meet thestatutory requirements and the expec-tations of the end users.

The strict compliance with the lawsand regulations governing the manu-facture of products; the adherence tothe principle that no product is signedoff to the next production stage unlessthe quality criteria of the previous stagehave been met; the strict implementa-tion of the procedures under the EN ISO9001 Quality Management System; thedevelopment of a Hazard & Operability(HAZOP) Study for operational risk analy-sis; and the staffing of the Quality Con-trol Departments with experienced per-sonnel who are provided with continu-ous training, are some of the funda-mental aspects of the specific policies onproduct quality and safety that theGroup Companies apply in their re-spective activity sectors. Regarding theprovision of verifiable and clear labellinginformation for our products, includingtheir price and – as the case may be –their safe use, environmental impacts,maintenance, storage and disposal, the

Group complies fully with the relevantrequirements. Clients have at their dis-posal the tools allowing them to checkall significant information which weprovide and to proceed to the corre-sponding tests, if they wish so. In theEPC Projects Sector, METKA S.A. carriesout complex large-scale projects award-ed as a result of competitive tender pro-cedures, which are carried out by theClient and under which the prices of-fered by the participants are compared.In all cases, the scope, responsibilities andcommercial terms and conditions for theprojects have been initially determinedby the client and, upon conclusion of thefinal negotiations, all specifications re-quired are agreed in writing as part ofthe project's contract.

10.1 Product Quality & Safety

The company’s products and services comply fully withthe terms and conditions of the respective Contracts andwith its contractual obligations to its Clients regardingHealth & Safety issues.Clients are supplied with all Safety, Health & Environ-mental information and warnings, including:- Instructions for the use, maintenance and disposal for

all equipment (Operation & Maintenance Manuals)and materials.

- Clearly visible labelling of all materials and equipment(signs, warnings and relevant instructions).

- Instructions for use and recycling in the form of Mate-rial Safety Data Sheets (MSDS) for all hazardous ma-terials.

84

The company is committed to ensuring on an ongoing ba-sis the satisfaction of its clients’ needs and expectations,providing them with products (alumina and primary castaluminium) and associated services that meet strict qual-ity requirements. To this end, the Company takes the nec-essary steps to obtain the ISO 9002 Quality Certificate,while its quality control laboratory has been accredited byHellenic Accreditation System S.A. (ESYD S.A.) in accor-dance with the requirements of the ISO 17025:2005 In-ternational Standard, for the chemical analysis of bauxite,alumina (both hydrated and calcined), and of aluminiumand its alloys. This accreditation concerns the QualityManagement System of the Laboratory and its technicalskills and adequacy for carrying out tests in the areas forwhich it has been accredited.

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 labellingof the Group’s products and services

Collection of product or service dataNo particular labellingrequirements, as all

products traded by thecompany are not

hazardous. All necessaryinformation is provided

upon request.

YES

Content, especially regarding substances which may havea potential environmental or social impact YES

Safe use of product or service YES

Product disposal and environmental/social impacts YES

Percentage of significant product categories subject to assessmentfor compliance with the above procedures

Alumina 100%

Aluminium 100%

EPC Contracts 100%

Metal & Mechanical Constructions 100%

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Given that the demand for new prod-ucts with longer lifecycle spans and re-duced environmental impacts is steadi-ly increasing, we invest in Research andDevelopment, looking for solutionsthat will to satisfy the varying needs ofour clients and seeking to offer a com-prehensive service with the lowest pos-sible burden on the environment. Inthis direction, our principal associ-ates and suppliers can act as catalysts,as they are an integral part of our ef-forts. Therefore, the management oflocal suppliers by the Group sub-sidiaries is governed by specific rulesand also includes plans for future ini-tiatives, as follows:

a) Depending on the scope and na-ture of each specific purchase, lo-cal suppliers are selected on the ba-sis of their solvency, reliability interms of quality and punctuality interms of delivery, cost of productsor services, available capacity to en-sure the quantities required, andcapability to meet the require-ments of the particular purchase in

accordance with the specificationsset by the respective Group sub-sidiary.

(b) Efforts are also being made to makeall our purchases from the Greekmarket, where possible, as quite of-ten projects have a requirement forspecialised suppliers from eco-nomically developed countries, byfollowing selection principles andprocedures characterised by trans-parency and meritocracy. Addi-tionally, in many cases we provideour supply chain participants withthe know-how and methods re-quired to process the materialswhich we need for our activities,and we encourage investment ini-tiatives involving more environ-mental-friendly production process-es.

(c) All the contracts signed with ourmajor subcontractors and supplierscontain clauses regarding theirobligation to comply with thelaws, to ensure the safety and

protection of their personnel, topay all types of statutory or con-tractual personnel wages andsalaries, and to take out and main-tain in effect appropriate insurancepolicies. They also contain clauseson environmental compliance (inaccordance with the ISO 140001International Standard) and onthe protection of human rights.

(d) Finally, as part of our efforts to pro-mote CSR in our sphere of influ-ence, we plan to also focus oncommunicating and promotingthe principles of the UN GlobalCompact to our principal associatesand suppliers. Our aim in doing sois to obtain the commitment of oursuppliers to the Compact, a de-velopment which will lead to mu-tual benefits. In addition, we be-lieve that our effort will elicit con-siderable positive responses, main-ly because of the large size of thecompanies concerned and theirexposure to challenges in the ex-ternal environment.

10.2 Management of Local Suppliers

86

10.3 Client satisfaction

Because of the varied nature of its ac-tivity sectors and the geographical dis-persion of its operations, MYTILINEOSGroup has a very broad client base. Aspart of our efforts for continuous im-provement and drawing on the qual-ity standards that we have in place, weconduct client satisfaction surveys,mainly in ALUMINIUM S.A. (every twoyears) and in METKA S.A. (to assess theprogress and the results of every proj-ect the company has undertaken, af-ter its completion). No client satisfac-tion survey results are available for2012, as during the year all projects ofMETKA S.A. were in progress, whilethe next client satisfaction survey of

ALUMINIUM S.A. is scheduled for2013.

In addition, as part of the efforts to en-sure customer satisfaction, the Groupprovides clients with access to claimsand to equitable and effective proce-dures for out-of-court resolution of dis-putes in connection with seekingcompensation in the event that theproducts which we provide them donot meet the agreed specifications. Inthe EPC Projects Sector, the settlementprocedure is always specified in writ-ing as part of the project contract, andmay typically involve arbitration by in-ternationally recognised authoritiessuch as the Arbitration Bodies of theInternational Chamber of Commerce(ICC).

In MYTILINEOS Group, our commit-ment to responsible communicationand marketing is ensured by our com-pliance with the laws in force and theapplication of best practices that gov-ern “below-the-line” promotion of ourproducts and companies, by our“above-the-line” communication atthe central corporate level, and by ourannual corporate sponsoring plan.We seek to provide transparent in-formation and to ensure that ourmessages are fully understood by allour clients. To this end, the commu-nication/marketing associates of our

subsidiaries are bound by the HellenicCode of Advertising-CommunicationPractice, whose principles provide thatall advertising should be legal, decent,honest and truthful, should be pre-pared with a due sense of social re-sponsibility and should conform to theprinciples of fair competition as gen-erally accepted in business. During2012 there were no incidents of non-compliance with the regulations andvoluntary codes on marketing com-munications, including product pro-motion and sponsorships.

In all MYTILINEOS Group companies,our respect for the privacy of clients isdemonstrated by the application of rig-orous systems for collection, use andprotection of their personal data. TheGroup’s key concern is to ensure thatprivate client data are collected in alawful and acceptable manner and are

limited to the information which is ab-solutely necessary for the provision ofits products and services, after theclients concerned have been informedand their free consent has been ob-tained. During 2012, no incidents ofviolation of client privacy occurred inthe Group companies.

10.4 Responsible Communication & Marketing

10.5 Protection of client privacy

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A core commitment and principle ofthe corporate philosophy ofMYTILINEOS Group, in all the marketswhere it operates, is to avoid all unfairassociations with potential competitorswhich may lead to anti-competitive be-haviour or practices, which may includefixing of prices, concerted bidding, theimplementation of restrictions on pro-duction and/or the joint exploiting ofmarkets through the sharing of clients,suppliers, regions or trade activities.

Our key concern is to regularly informthe personnel of our subsidiaries about

the importance of adhering to all ap-plicable laws on competition, and es-pecially to provide Management Ex-ecutives with suitable training. In ad-dition, each one of our subsidiaries isat the disposal of the competentCompetition Authorities and is avail-able to cooperate substantially and ef-fectively with them, whenever re-quired.

During 2012 the Group was not thesubject of any petitions to the Courtsunder Greek or international law foranti-competitive behaviour, and no

monetary sanctions were imposed fornon-compliance of our subsidiarieswith the relevant applicable laws andregulations.

However, December 2012 saw thelaunch of the arbitration procedure be-tween the Group’s subsidiaryALUMINIUM S.A. and the Public Pow-er Corporation S.A. (PPC), which is cur-rently in full progress. Given theabove, the completion of the arbitra-tion procedure and the issue of a Rul-ing are expected in the next fewmonths.

10.6 Relations with the Competition & Regulatory Compliance

GRICode Strategy and Analysis – Description of indicators Cross reference pages

or direct answer Reported

1.1 Statement from the most senior decision maker of the organization.2 & 3, 14 - 16, 28 - 31, 2 & 3

http://www.mytilineos.gr/el-gr/corporate-social-responsibility/of-mytilineos-group

Fully

1.2 Description of key impacts, risks, and opportunities.

2 & 3, 6 & 7, 20, 23 - 31, 55 - 58, 74 - 772 & 3, 51 - 57, 95 - 103

http://www.mytilineos.gr/el-gr/strengthing-transparency/information#tab-information-

on-corporate-governance

Fully

GRICode Organisational profile – Description of indicators Cross reference pages

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 Fully2.3 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) Fully2.6 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 FullyGRICode Report parameters – Description of indicators Cross reference pages

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

3.6Boundary of the report (e.g. countries, divisions, subsidiaries, leasedfacilities, joint ventures, suppliers).

5 Fully

3.7 State any specific limitations on the scope or boundary of the report. 5 Fully

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

3.9 Data measurement techniques and the bases for calculations.6, 65, 66 &

http://www.mytilineos.gr/el-gr/health-and-safety/info#tab-health-and-safety-indicators

Fully

3.10 Explanation of the effect of any re-statements of information providedin earlier reports, and the reasons for such re-statement. 4 Fully

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

3.12 Table identifying the location of the GRI-compliant Standard Disclosuresin the report. 88 - 93 Fully

3.13 Policy and current practice with regard to seeking external assurancefor the report. 7 Fully

11. MYTILINEOS GROUP –AGGREGATE PERFORMANCESUMMARY

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11.1. GRI Disclosures and IndicatorsThis 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�

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GRICode

Governance, commitments and engagement –Description of indicators

Cross reference pagesor direct answer Reported

4.1Governance structure of the organisation, including committees under thehighest governance body responsive for specific tasks, such as settingstrategy or organisational oversight.

11 & 51 - 57 Fully

4.2 Indicate whether the Chair of the highest governance body is also anexecutive officer. 56 Fully

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

4.4 Mechanisms for shareholders and employees to provide recommendationsor direction to the highest governance body.

The key mechanisms are the following: Annualand extraordinary General Meetings of the

Shareholders, Financial results presentations,regular and ad hoc communication between

the Management and the employees' collectivebodies, personal communication at the

employees' request, employee performancereviews procedures and the formal annual

dialogue forums with Stakeholders.45 - 48

Fully

4.5Linkage between compensation for members of the highest governance body,general managers and top management executives and the organisation’sperformance (including social and environmental performance).

http://www.mytilineos.gr/el-gr/strengthing-transparency/information#tab-information-on-corporate-governance

Fully

4.6 Processes in place for the highest governance body to ensure conflicts ofinterest are avoided.

http://www.mytilineos.gr/el-gr/strengthing-transparency/information#tab-information-on-corporate-governance

Fully

4.7Process for determining the qualifications and expertise of the members ofthe highest governance body for guiding the organisation’s strategy oneconomic, environmental and social topics.

http://www.mytilineos.gr/el-gr/strengthing-transparency/information#tab-information-on-corporate-governance

Fully

4.8Internally developed statements of mission or values, codes of conductand principles relevant to economic, environmental and social performanceand the status of their implementation.

15, 16 &17: http://www.mytilineos.gr/el-

gr/strengthing-transparency/information#tab-ethics-code

: http://www.mytilineos.gr/el-gr/strengthing-transparency/information#t

ab-csr-vision-and-values

Fully

4.9 Exercise of governance by the Board of Directors.

17 & 18 47 - 62: http://www.mytilineos.gr/el-

gr/strengthing-transparency/information#tab-information-on-corporate-governance

http://www.mytilineos.gr/el-gr/csr-governance/info

Fully

4.10Processes for evaluating the highest governance body’s own performance,particularly with respect to economic, environmental and socialperformance.

: http://www.mytilineos.gr/el-gr/strengthing-transparency/information#tab-information-on-corporate-governance

Fully

4.11 Explanation of whether and how the precautionary approach or principleis addressed by the organisation.

11, 20 & 21 47 - 62: http://www.mytilineos.gr/el-

gr/strengthing-transparency/information#tab-information-on-corporate-governance

: http://www.mytilineos.gr/el-gr/csr-governance/info

Fully

4.12Externally developed economic, environmental and social charters,principles, or other initiatives subscribed to or endorsed by theorganization.

15 & 17 Fully

4.13 Membership of associations (such as industry associations) and/or national/international advocacy organisations in which the organization participates. 16 Fully

4.14 List of Stakeholder groups engaged by the organisation. http://www.mytilineos.gr/el-gr/dialogue-with-stakeholders/details Fully

4.15 Basis for identification and selection of Stakeholders with whom toengage.

http://www.mytilineos.gr/el-gr/dialogue-with-stakeholders/details Fully

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

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

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90

GRICode Economic Performance – Description of Indicators Cross reference pages

or direct answer Reported

MANAGEMENT APPROACH 32

EC1 Direct Economic Value. 33 Fully

EC2 Financial implications and other risks and opportunities for theorganization’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

EC6 Policy, practices and proportion of spending on locally-based suppliers atsignificant locations of operation. 77 & 85 Fully

EC7Procedures for local hiring and proportion of senior managementexecutives hired from the local community at locations of significantoperation.

40 & 76 Fully

EC8Development and impact of infrastructure investments and servicesprovided primarily for public benefit through commercial, in kind, or probono engagement.

78, 79 Fully

GRICode Environmental Performance – Description of Indicators Cross reference pages

or direct answer Reported

MANAGEMENT APPROACHhttp://www.mytilineos.gr/el-gr/climate-

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

EN6Initiatives to provide energy-efficient or renewable energy based productsand services, and reductions in energy requirements as a result of theseinitiatives.

http://www.mytilineos.gr/el-gr/climate-change/csr#tab-responsible-

management-of-energyPartially

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

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

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

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

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

EN15 Number of IUCN Red List species and national conservation list species withhabitats 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

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

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

� Core Indicator � Additional Indicator

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GRICode Labour practices and decent work – Description of indicators Cross reference pages

or direct answer Reported

MANAGEMENT APPROACH http://www.mytilineos.gr/el-gr/labour-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

LA3 Benefits provided by the Group to full-time employees of its companies,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

LA4 Percentage of employees covered by collective bargaining agreements.The 98% of full-time employees in the

Mytilineos Group of Companies are coveredby collective bargaining agreements

LA5 Minimum notice period(s) regarding operational changes, includingwhether it is specified in collective agreements.

With respect to significant operationalchanges, all Group employees affected bysuch changes are informed of them withinthe time limits prescribed by the applicablelaws to ensure that they adapt smoothly to

the new situation. The timeframe variesbetween Group companies and in manycases exceeds the statutory obligation.

Fully

LA6Percentage of total workforce represented in formal joint management–worker health and safety committees that help monitor and advise onoccupational health and safety programmes.

46 Fully

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

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

LA11Programs for skills management and lifelong learning that support thecontinued employability of employees and assist them in managing careerendings.

42 & 43 Fully

LA12 Percentage of employees receiving regular performance and careerdevelopment reviews. 43 & 44 Fully

LA13Composition of governance bodies and breakdown of employees percategory according to gender, age group, minority group membership andother indicators of diversity.

51 Fully

LA14 Ratio of basic salary of men to women by employee category. 47 Partially

GRICode

Human Rights – Description of indicators Cross reference pagesor direct answer Reported

MANAGEMENT APPROACH http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/information

HR1 Percentage and total number of significant investment agreements thatinclude human rights clauses or that have undergone human rights screening. 49 Fully

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

HR3Total hours of employee training on policies and procedures concerningaspects of human rights that are relevant to operations, including thepercentage of employees trained.

50 Partially

HR4 Total number of incidents of discrimination and actions taken. Νil Fully

HR5Group operations and significant suppliers identified in which the right toexercise freedom of association and collective bargaining may be violated or atsignificant risk, and actions taken to support these rights.

52 Partially

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

HR7Operations identified as having significant risk for incidents of forced orcompulsory labour, and measures taken to contribute to the elimination offorced or compulsory labour.

54 Fully

HR9 Total number of incidents of violations involving rights of indigenous peopleand actions taken. Νil Fully

HR11 Number of grievances related to human rights filed, addressed and resolvedthrough formal grievance mechanisms. Νil Fully

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GRICode Social Performance – Description of indicators Cross reference pages

or direct answer Reported

MANAGEMENT APPROACHhttp://www.mytilineos.gr/el-gr/local-communities/about-csr#tab-local-

communities-management-approach

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

SO9 Operations with significant potential or actual negative impacts on localcommunities. 55 & 56, 74 & 75 Fully

SO10Prevention and mitigation measures implemented in Group business unitsoperations with significant potential or actual negative impacts on localcommunities.

56 - 58, 65, 76 & 77, 82 Fully

SO2 Percentage and total number of business units analysed for risks related tocorruption. 82 Fully

SO3 Percentage of employees trained in organization’s anti-corruption policiesand procedures 82 Fully

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

SO5 Public policy positions and participation in public policy development andlobbying. 16 Fully

SO6 Total value of financial and in-kind contributions to political parties,politicians, and related institutions by country. Νil Fully

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

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

GRICode Product responsibility – Description of indicators Cross reference pages

or direct answer Reported

MANAGEMENT APPROACHhttp://www.mytilineos.gr/el-gr/climate-

change/csr#tab-climate-change-management-approach

PR1Life cycle stages in which health and safety impacts of products andservices are assessed for improvement, and percentage of significantproducts and services categories subject to such procedures.

63 Fully

PR2Total number of incidents of non-compliance with regulations andvoluntary codes concerning health and safety impacts of products andservices during their lifecycle, by type of outcomes.

63 Fully

PR3Total number of incidents of non-compliance with regulations andvoluntary codes concerning product and service information and labelling,by type of outcomes.

: http://www.mytilineos.gr/el-gr/climate-change/csr#tab-responsible-management-

of-energyPartially

PR4Total number of incidents of non-compliance with regulations andvoluntary codes concerning product and service information and labelling,by type of outcomes.

64 Fully

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

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

PR7Total number of incidents of non-compliance with regulations and voluntarycodes concerning marketing communications, including advertising, promo-tion, and sponsorship by type of outcomes.

58, 71 Fully

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

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

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THE TEN PRINCIPLESOF THE UN GLOBAL COMPACT

Cross reference(Sustainability Report pages & Group website sections)

Principle1

Businesses should support and respect theprotection of internationally proclaimedhuman rights.

16, 32, 45 - 47, 49 - 54, 83 & 84, 86GRI indicators: HR9 & HR11, PR2

: http://www.mytilineos.gr/el-gr/labour-practices/information#tab-labour-management-approach

: http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/information#tab-management-approach

: http://www.mytilineos.gr/el-gr/market-practicies/management-approach� 98% of full-time employees in the Mytilineos Group of Companies are covered

by collective labour agreements

Principle2

Businesses should make sure that they are notcomplicit in human rights abuses.

16, 49 - 50, 52 - 54GRI indicators: HR9 & HR11

: http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/information#tab-management-approach

Principle3

Businesses should uphold the freedom ofassociation and the effective recognition ofthe right to collective bargaining.

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/

information#tab-management-approach� 98% of full-time employees in the Mytilineos Group of Companies are covered

by collective labour agreements� All Group employees affected by significant operational changes are informedof them within the time limits prescribed by the applicable laws, which in several

cases exceed the statutory ones.

Principle4

Businesses should uphold the elimination ofall forms of forced and compulsory labour.

16, 32, 49 & 50, 54, HR11: http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/

information#tab-management-approach

Principle5

Businesses should uphold the effectiveabolition of child labour.

: http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/information#tab-management-approach

Principle6

Businesses should uphold the elimination ofdiscrimination in respect of employment andoccupation.

16, 32, 38 - 40, 47, 49 - 51, 76: http://www.mytilineos.gr/el-gr/labour-practices/information#tab-labour-management-approach

: http://www.mytilineos.gr/el-gr/safeguarding-of-human-rights/information#tab-management-approach

Principle7

Businesses should support a precautionaryapproach to environmental challenges.

16, 15, 32, 66 & 67, 70 & 71: http://www.mytilineos.gr/el-gr/climate-change/csr#

tab-climate-change-management-approach

Principle8

Businesses should undertake initiatives topromote greater environmental responsibility.

16, 56, 66 & 67, 58 - 73,GRI indicators: PR4

: http://www.mytilineos.gr/el-gr/climate-change/csr#tab-responsible-management-of-energy

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

: http://www.mytilineos.gr/el-gr/market-practicies/management-approach

Principle9

Businesses should encourage thedevelopment and diffusion of environmentallyfriendly technologies.

16, 56, 63 & 64, 66 & 67,70 & 71: http://www.mytilineos.gr/el-gr/climate-change/csr#tab-responsible-

management-of-energy: http://www.mytilineos.gr/el-gr/climate-change/csr#tab-climate-change-

management-approach

Principle10

Businesses should work against corruption inall its forms, including extortion and bribery.

16, 82GRI indicators: SO6

: http://www.mytilineos.gr/el-gr/local-communities/about-csr#tab-local-communities-management-approach

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11.2. Coverage of the Principles of the UN Global Compact

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

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

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

Fully

• Transparency

• MYTILINEOS GROUP PROFILE• STRATEGY AND KEY FIGURES• GROUP GOVERNANCE STRUCTURE• GOVERNANCE OF CORPORATE SOCIAL RESPONSIBILITY• COLLABORATIONS WITH SOCIAL PARTNERS AND ORGANISATIONS• 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

Fully

• Ethical behaviour

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

Fully

• Respect for stakeholder interests • STAKEHOLDERS ENGAGEMENT Fully

• Respect for the rule of law

• COMPLIANCE WITH ENVIRONMENTAL LAWS AND REGULATIONS• ENVIRONMENTAL FOOTPRINT OF MYTILINEOS GROUP• RELATIONS WITH THE COMPETITION & REGULATORY COMPLIANCE• GRI DISCLOSURES AND INDICATORS• UN GLOBAL COMPACT DISCLOSURES

Fully

• Respect for internationalnorms of behaviour

• SUSTAINABILITY REPORT PARAMETERS• COLLABORATIONS WITH SOCIAL PARTNERS AND ORGANISATIONS• MEMBERSHIPS OF CSR INITIATIVESAND STANDARDS

Fully

• Respect for human rights• PROTECTION OF HUMAN RIGHTS• PROFESSIONAL ETHICS CODE• UN GLOBAL COMPACT DISCLOSURES

Fully

Β. Recognizing social responsibilityand engaging stakeholders

Sustainability Report sections & Group website reference Reported

• Recognizing social responsibility

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

Fully

• Stakeholder identificationand engagement

• STAKEHOLDER ENGAGEMENT• DIALOGUE WITH STAKEHOLDERS

Fully

C. Social Responsibilitycore subjects

Sustainability Report sections & Group website reference Reported

• 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 involvementand development

• SOCIAL COHESION & DEVELOPMENT Fully

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

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

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D. Integrating socialresponsibility throughoutan organization

Sustainability Report sections & Group website reference Reported

• The relationship of anorganization’scharacteristics to socialresponsibility

• APPROACH TO CORPORATE SOCIAL RESPONSIBILITY• GOVERNANCE OF CORPORATE SOCIAL RESPONSIBILITY• IMPACT OF CLIMATE CHANGE ON BUSINESS ACTIVITY• DIALOGUE WITH STAKEHOLDERS

Fully

• Understanding the socialresponsibility of theorganization

• DISCLOSURE MANAGEMENT APPROACHES (ENVIRONMENT - LABOUR PRACTICES çHUMAN RIGHTS - SOCIAL COHESION - FAIR MARKET PRACTICES)

• CORPORATE SOCIAL RESPONSIBILITY FUNDAMENTAL COMMITMENTS• STAKEHOLDERS ENGAGEMENT

Fully

• Practices for integratingsocial responsibilitythroughout an organization

• APPROACH TO CORPORATE SOCIAL RESPONSIBILITY• SOCIAL FOOTPRINT OF MYTILINEOS GROUP• ENVIRONMENTAL FOOTPRINT OF MYTILINEOS GROUP• STAKEHOLDER ENGAGEMENT• SUSTAINABILITY REPORT PARAMETERS• PROFESSIONAL ETHICS CODE• GOVERNANCE OF CORPORATE SOCIAL RESPONSIBILITY

Fully

• Communication on socialresponsibility

• DIALOGUE WITH STAKEHOLDERS• CORPORATE SOCIAL RESPONSIBILITY PUBLICATIONS• CSR PROMOTION AND COMMUNICATION BELOW THE LINE ACRIVITIES• COLLABORATIONS WITH SOCIAL PARTNERS AND ORGANISATIONS

Fully

• Enhancing credibilityregarding socialresponsibility

• STAKEHOLDER ENGAGEMENT• MEMBERSHIPS OF CSR INITIATIVES AND STANDARDS• GOVERNANCE OF CORPORATE SOCIAL RESPONSIBILITY• GRI DISCLOSURES AND INDICATORS• UN GLOBAL COMPACT DISCLOSURES

Fully

• Reviewing and improvingan organization's actionsand practices related tosocial responsibility

• APPROACH TO CORPORATE SOCIAL RESPONSIBILITY• DIALOGUE WITH STAKEHOLDERS• DISCLOSURE MANAGEMENT APPROACHES (ENVIRONMENT - LABOUR PRACTICES -

HUMAN RIGHTS - SOCIAL COHENSION - FAIR MARKET PRACTICES)

Fully

• Voluntary initiativesfor social responsibility

• GRI DISCLOSURES AND INDICATORS• UN GLOBAL COMPACT DISCLOSURES• MEMBERSHIPS OF CSR INITIATIVES AND STANDARDS

Fully

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

5-7 Patroklou str, Μaroussi, 151 25 ΑthensΤel. +30 210 6877300 Fαχ +30 210 6877400

www.mytilineos.gr

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