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P.P.A. S.A. Annual Report 2025

Mar 31, 2026

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Untitled ANNUAL FINANCIAL REPORT 2025 FROM 1 st JANUARY TO 31 st DECEMBER 2025 PIRAEUS PORT AUTHORITY S.A.

PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

ir PIRAEUS PORT AUTHORITY S.A. ANNUAL FINANCIAL REPORT FOR THE YEAR ENDED DECEMBER 31, 2025 (IN ACCORDANCE WITH THE L. 3556/2007)

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

Contents

STATEMENTS OF THE MEMBERS OF THE BOARD OF DIRECTORS ............................................................................................................ 5

ANNUAL REPORT OF THE BOARD OF DIRECTORS .................................................................................................................................... 6

STATEMENT OF CORPORATE GOVERNANCE ......................................................................................................................................... 24

ANNUAL SUSTAINABILITY STATEMENT ............................................................................................................................................... 115

ESRS 2 GENERAL DISCLOSURES .................................................................................................................................................................. 115

EUROPEAN TAXONOMY ............................................................................................................................................................................. 195

ESRS E1 & E2– CLIMATE CHANGE & POLLUTION .......................................................................................................................................... 213

ESRS S1- OWN WORKFORCE ..................................................................................................................................................................... 254

ESRS S3- AFFECTED COMMUNITIES ............................................................................................................................................................ 291

ESRS S4 – CUSTOMERS AND END-USERS ...................................................................................................................................................... 304

ESRS-G1 BUSINESS CONDUCT ................................................................................................................................................................... 322

INDEPENDENT PRACTITIONER’S LIMITED ASSURANCE REPORT ON PIRAEUS PORT AUTHORITY S.A SUSTAINABILITY STATEMENT ... 360

INDEPENDENT AUDITOR’S REPORT ..................................................................................................................................................... 365

STATEMENT OF COMPREHENSIVE INCOME FOR THE YEAR ENDED DECEMBER 31, 2025 .................................................................. 375

STATEMENT OF FINANCIAL POSITION AS AT DECEMBER 31, 2025 .................................................................................................... 376

STATEMENT OF CHANGES IN EQUITY FOR THE YEAR ENDED DECEMBER 31,2025 ............................................................................ 377

CASH FLOW STATEMENT FOR THE YEAR ENDED DECEMBER 31,2025 ............................................................................................... 378

NOTES TO THE FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2025 ....................................................................... 379

  1. ESTABLISHMENT AND ACTIVITY OF THE COMPANY .................................................................................................................. 379

  2. BASIS OF PRESENTATION OF FINANCIAL STATEMENTS: ........................................................................................................... 380

  3. MATERIAL ACCOUNTING POLICIES ........................................................................................................................................... 383

  4. PROPERTY, PLANT & EQUIPMENT ............................................................................................................................................ 399

  5. RIGHT OF USE ASSETS – LEASE LIABILITIES ................................................................................................................................ 400

  6. INVESTMENT PROPERTY ........................................................................................................................................................... 402

  7. INTANGIBLE ASSETS ................................................................................................................................................................. 403

  8. ADVANCES AND OTHER NON-CURRENT ASSETS ....................................................................................................................... 404

  9. INCOME TAX (CURRENT AND DEFERRED) ................................................................................................................................. 405

  10. INVENTORIES........................................................................................................................................................................... 409

  11. TRADE AND OTHER RECEIVABLES ............................................................................................................................................ 410

  12. PREPAID EXPENSES .................................................................................................................................................................. 412

  13. CASH AND CASH EQUIVALENTS ............................................................................................................................................... 412

  14. SHARE CAPITAL ........................................................................................................................................................................ 412

  15. RESERVES ................................................................................................................................................................................ 413

  16. GOVERNMENT GRANTS ........................................................................................................................................................... 413

  17. RESERVE FOR STAFF LEAVING INDEMNITIES ........................................................................................................................... 415

  18. PROVISIONS ............................................................................................................................................................................ 416

  19. LONG-TERM & SHORT TERM BORROWINGS............................................................................................................................ 417

  20. SUPPLIERS ............................................................................................................................................................................... 418

  21. DIVIDENDS .............................................................................................................................................................................. 418

  22. ACCRUED AND OTHER CURRENT LIABILITIES ........................................................................................................................... 419

  23. DEFERRED INCOME ................................................................................................................................................................. 420

  24. SEGMENT INFORMATION ........................................................................................................................................................ 421

  25. REVENUES ............................................................................................................................................................................... 423

  26. ANALYSIS OF EXPENSES ........................................................................................................................................................... 425

  27. OTHER OPERATING INCOME / EXPENSES ................................................................................................................................ 426

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

  1. FINANCIAL INCOME/EXPENSES ........................................................................................................................................... 426

  2. DEPRECIATION AND AMORTISATION .................................................................................................................................. 427

  3. PAYROLL AND EMPLOYEE RELATED COST ............................................................................................................................ 427

  4. EARNINGS PER SHARE .......................................................................................................................................................... 427

  5. COMMITMENTS, CONTINGENT LIABILITIES AND REQUIREMENTS ....................................................................................... 428

  6. RELATED PARTIES ................................................................................................................................................................. 430

  7. FINANCIAL INSTRUMENTS ................................................................................................................................................... 432

35.SUBSEQUENT EVENTS .......................................................................................................................................................... 435

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

STATEMENTS OF THE MEMBERS OF THE BOARD OF DIRECTORS

Statements of the Members of the Boards of Directors

The Board of Directors Members of the Company “Piraeus Port Authority Societé Anonyme” and trade title “PPA S.A.” (hereinafter referred to as “Company” or as “PPA S.A.”) and the undersigned:

  1. HAN CHAO, Chairman of the Board of Directors
  2. SU XUDONG, Chief Executive Officer
  3. LI JIN, Member of the Board of Directors

In our above-mentioned capacity and as specifically appointed by the Board of Directors of the Company, we state and we assert that to the best of our knowledge:

(a) the financial statements of the societe anonyme Company under the name “Piraeus Port Authority Societe Anonyme” and trade title “PPA S.A.” for the period from January 1, 2025 to December 31, 2025, which were compiled according to the applicable International Financial Reporting Standards as adopted by the E.U., provide a true and fair view of the assets and the liabilities, the equity and the results of the period of the Company, according to that stated in paragraphs 3 to 5 of article 4 of the L.3556/2007 and the relevant executive Decisions of the Board of Directors of the Capital Market Commission.

(b) the annual Report of the Board of Directors fairly represents the performance, results of operations and financial position of the Company, as well as a description of the main risks and uncertainties it faces and was drafted in accordance with the sustainability reporting standards referred to in article 154A of Law 4548/2018 (A’ 104) and with the specifications approved pursuant to paragraph 4 of article 8 of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020, as referred to in article 4, paragraph 2(c) of Law 3556/2007, which was amended by article 16 of Law 5164/2024.

Athens, March 31 , 2026

HAN CHAO SU XUDONG LI JIN
Chairman of the Board of Directors Chief Executive Officer Member of the Board of Directors
Passport No PE3327142 Passport No PE2263059 Passport No PE2316564

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

(amounts in Euro unless stated otherwise)

ANNUAL REPORT OF THE BOARD OF DIRECTORS of the Company “PIRAEUS PORT AUTHORITY S.Α.” with the distinctive title “PPA S.A.” from 1st January 2025 until 31st December 2025 (In accordance with article 4 par. 2(c) of L. 3556/2007)

On the Financial Statements for the year from 1 January 2025 to 31 December 2025

Economic performance, comments on Financial Statements

A.Economic performance

International Trade Conditions

The nature of Company's business activities depends on Greek and international trade, as well as on external macroeconomic and geopolitical conditions. The immediate market of Piraeus port focuses on the countries of the eastern Mediterranean and thus economic and geopolitical conditions have a key influence on the volume served. It is further influenced by developments in the global port industry in general, as well as by the developments of individual port activities, highly interconnected to both PPA's investment plan and to the level of service provided to port users.

The economic environment in 2025 was highly influenced by the rising unilateral tariffs and geopolitical tensions. Global tariffs rose in 2025, with manufacturing most affected. Governments are expected to continue using tariffs in 2026 to pursue industrial and strategic objectives. Global rising tariffs had two results. The threat of a trade war between the United States and the EU led to a sharp rise in both imports and, particularly, exports in Q1 2025. However, in Q2 2025, EU imports fell by 3.2%, while exports declined more markedly by 6.7%. The downward trend continued in Q3 and Q4 2025, although at a slower pace, with imports down 1.4% and exports down 0.8% in Q4 2025. This meant that both imports and exports registered decreases for 3 consecutive quarters. 1


1 https://ec.europa.eu/eurostat/statistics-explained/index.php?title=EU_international_trade_in_goods_-_latest_developments

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

(amounts in Euro unless stated otherwise)

In the middle of a turbulent economic environment created by rising trade tariffs and geopolitical challenges, IMF expects global economy to grow at 3.3% in 2026 at par with 2025. World trade volume growth is expected to decline from 4.1 percent in 2025 to 2.6 percent in 2026 and increase to 3.1 percent in 2027 2 . The EU Commission expects World trade volume to decline from 2.8 percent in 2025 to 2.1 percent in 2026 and increase to 2.7 percent in 2027.

Greek Economy

For the Greek economy, a growth rate is expected, exceeding the Eurozone average, at 2.1% in 2025 and 2.2% in 2026, according to the Commission’s autumn forecasts 3 . In January 2026, imports decreased by 7.4% and exports decreased by 11.9%. Excluding petroleum products and ships, the value of imports fell by 4.7% and exports by 3.6% compared to the corresponding month of 2025 4 . The EU estimates that in 2026 imports will increase by 3.7% and exports by 2.4%.

The geopolitical conditions in the east Mediterranean and middle east continue to affect Piraeus port volumes. On one hand the closure of the Suez Canal instigated by the turbulence in Israel and subsequent attacks by Houthis is seized. However, there is still no mass rerouting through Suez as shipping lines are still testing the durability of the status quo 5 . As a result, volume build up at the Port of Piraeus, which is a key transshipment hub, is expected to be gradual and can significantly benefit port volumes within 2026.

B. Comments on Financial Statements for the 2025 Revenues

The «Revenues” for the year 2025 amounted to € 250.8 million, where compared to the corresponding year of 2024 increased by 8.6% or € 19.9 million (2024: € 230.1 million). The increase is mainly due to the revenues’ increase of the container terminal sector, of the revenue from the concession of piers II & III as well as from the the cruise sector by 17.0%, 10.8% and 24.8% or by € 8.5 million, € 8.8 million and € 7.5 million respectively.

The increase in revenue from loading/unloading is mainly due to the activities of the Container Terminal. Throughput at the Container Terminal, Pier I, for the year 2025 reached 664,581 TEUs, recording an increase of 17.9% compared to the corresponding year 2024 (563,725 TEUs). In particular, a significant increase was recorded in domestic cargo (imports and exports) from 232,252 TEUs in 2024 to 254,591 TEUs in 2025 (+9.6%), as well as transshipment cargo by 23.7% from 331,473 TEUs in 2024 to 409,990 TEUs in 2025.

Cruise ship arrivals in 2025 amounted to 862 compared to 810 in 2024, recording an increase of 6.42%.


2 https://economy-finance.ec.europa.eu/document/download/34538512-fff6-451a-8bbc- 4c8d60e4d132_en?filename=ip327_en.pdf [accessed 20, February]
3 https://www.imf.org/en/publications/weo/issues/2026/01/19/world-economic-outlook-update-january-2026 [accessed 20, February]
4 https://www.statistics.gr/el/statistics/-/publication/SFC02/- [accessed 20, March]
5 https://www.reuters.com/world/middle-east/what-are-shipping-companies-plans-return-suez-canal-2025-12-19/ [accessed January 2026]

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

(amounts in Euro unless stated otherwise)

The total number of passengers recorded an increase of 9.68% (1,863,397 passengers) compared to 2024 (1,698,877 passengers). Specifically, compared to 2024, there was an 8.2% increase (1,091,364 passengers compared to 1,008,209 passengers) in homeport passengers and an 11.8% increase (772,033 passengers compared to 690,668 passengers) in transit passengers.

The significant increase in revenue from the Pier II + III concession agreement is mainly due to the increase in the variable consideration, which amounted to € 74,215,831.56 (31.12.2024: € 66,009,391.37). The concession consideration is calculated and recognized in income for the period in accordance with the terms of the contract and considered as lease contract based on IFRS 16. This increase was offset by a decrease in revenue of the ferry sector by 28.4% or by € 3.6 million (Note 24 &25). The decrease in revenue from ferry shipping is mainly because, from May 1, 2025, and for a period of one (1) year, the Company proceeded to reduce the fees for ships and passengers of Ferry Shipping by 50% in accordance with the relevant amendment of the Ministry of Shipping & Island Policy. The amendment has a significant impact on the revenue of the activity for the period of application of the current year, i.e. reduction by an amount of € 3.4 million compared to the corresponding period last year, as well as a decrease of € 1.1 million resulting from the mooring of coastal shipping and included in the "Mooring" item.

Cost and Expenses

"Payroll and employee related costs" constitute the most important category of the Company's operating expenses, which during 2025 showed a significant increase and amounted to € 79.7 million compared to € 71.1 million in 2024 (Note 26).The significant increase in Payroll and employee related costs in the current year compared to the corresponding last year is mainly due to the additional staggered increase of payroll of employees and dock workers according to the Collective Bargaining Agreements in force from 1/8/2024 and 1/7/2024 respectively, the implementation from 1/4/2025 of the new Collective Bargaining Agreement for Supervisors & Foremen, the increased employment (hourly wages) of dock workers to serve the organic growth that occurs in most of the Company's activity sectors during year 2025, as well as the increase in personnel during the current year compared to the previous year. Also, the Company's Management, both in the current and the previous year, decided to grant voluntary retirement incentives to those employees who had established the right to retirement and had reached the age of 60 on December 31, 2025 and 2024 respectively. The total charge for the current year amounted to € 0.9 million compared to € 0.7 million in the previous year. In regard to the remaining operating costs, except for payroll costs, they remained consistent to the prior year figures except for the following:

  • A significant increase was recorded in “Various expenses” by € 3.7 million or 44.7%, which is mainly due to the increase in cleaning port services expenses by the amount of € 2.0 million or 102.1%, and in port guard fee by the amount of € 1.0 million or 32.3% (Note 26).
  • An increase was recorded in “Third Party Fees and Expenses” by € 1.2 million or 23.4%, which is mainly due to the increased use of external partners for loading and unloading services by approximately € 1.8 million compared to the previous year, which was partially offset by the decrease in consultants' fees and expenses by the amount of € 0.4 million (Note 26).

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  • An increase was noted by € 0.9 million in legal cases due to to provisions for legal cases that arose during the current year (Notes 18 & 26).
  • The "Greek State Concession" fee presented an increase during the year 2025, by € 0.7 million or by 14.1% which is mainly due to the increase in revenues of the current year compared to the corresponding year of 2024 (Note 22 & 26).
  • Decrease was noted in inventories consumption by € 0.3 million or by 11.1%, which amounted during the current year to € 2.4 million while in the corresponding last year it amounted to € 2.7 million (Notes 10 & 26).

Other Income/Expenses

  • Other operating income for the current year showed a decrease compared to the previous year amounting to € 0.5 million or by 7.0% amounting to € 6.4 million (31.12.2024: € 6.9 million) (Note 27).
  • Other operating expenses for the current year amounted to € 1.7 million compared to the corresponding year of 2024 (€ 0.6 million) presented an increase amounting to € 1.1 million. This increase is due to the increase in compensation to suppliers arising from the execution of their contracts by the Company (Note 27).

Net impairment losses on financial assets

The net impairment loss on financial assets for the current year amounted to € 0.8 million while a prior years’ provision of € 0.6 million was used (31.12.2024: € 0.4 million) (Note 11).

Financial Expenses

In financial expenses during the current year an increase was noted by € 0.3 million or by 10.7% (31.12.2025: € 2.9 million instead of € 2.6 million in 31.12.2024) (Note 28).

Financial Income

In financial income during the current year a significant decrease was noted amounted to € 3.1 million or by 59.8% (31.12.2025: € 2.1 million instead of € 5.2 thousand in 31.12.2024) which is due to the decrease to the amount of the time deposits concluded, as well as the relevant interest rates (Note 28).

Total Assets

Total assets at December 31, 2025 amounted to € 689.8 million, increased by 4.1% or € 27.0 million (31.12.2024: € 662.8 million). The increase in total assets was mainly due to the following sub-items, namely:

  • increase of the unamortized balance of tangible property, plant and equipment by € 93.5 million or by 26.1% due to the additions € 110.9 million of the year reduced by € 17.3 million current year depreciation and net value of write-offs-sales/transfers to intangible assets by € 0.1 million

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These increases were mainly offset by:

  • decrease in cash and cash equivalents by € 54.7 million or by 26.8% mainly due to the early repayment of the Company's loan obligations, the high dividend yield of the previous year, as well as the significant tangible investments of the current year (Note 13).
  • decrease in “Trade and other receivables” by € 10.0 million or 47.2% mainly due to the decrease in the net balance of customers by € 2.7 million, the decrease in other receivables for the collection of grants by the amount of € 7.0 million, as well as the decrease in interest receivable by the amount of € 1.6 million (Note 11). The above decreases were mainly offset by the increase in advances to suppliers- creditors by the amount of € 0.8 million.
  • decrease in “Right of use assets” by € 1.9 million or by 3.6% due to the current’ s year depreciation (Note 5).

Total Liabilities

Total liabilities as at 31.12.2025 amounted to € 242.6 million decreased by € 11.2 million or by 4.4% (31.12.2024: € 253.7 million). The fluctuation in total liabilities was mainly due to the following:

  • decrease in bank debt by € 26.5 million due to the due to early repayment of the Company's two bank loans (Note 19).
  • decrease of tax income payable by the amount of € 2.4 million or by 17.3%,
  • decrease in short-term and long-term lease liabilities by € 1.3 million or by 2.0%, due to the current year payments of € 3.7 million, finance cost € 2.2 million and additions of € 0.2 million (Note 5).

The above decreases were mainly offset by the following increases:

  • increase in “Accrued and other short-term liabilities” by 9.9 million or 36.1% mainly due to the increase in accrued liabilities by 9.5 million during the current year.
  • increase in liabilities to "Suppliers" by the amount of € 8.3 million or 29.75%.
  • Increase in the provision for personnel compensation by the amount of € 0.5 million or by 3.7% (Note 17)
  • increase in grants by € 1.2 million or 3.0%, due to the approval of an additional grant of € 2.0, less to depreciation for the year (Note 16).

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Financial and Non-Financial Performance Indicators

A. Financial indicators and Alternative Performance Measures (APM’s)

Financial indicators showing the Company's financial position are presented in the table below:

Total Debt / Equity

It is calculated as the ratio of the sum of Debt Liabilities (Short-Term and Long-Term Loans) plus the total of Lease Liabilities at the end of the year to the Total Equity at the end of the year.

Earnings before interest, taxes, depreciation and amortization (EBITDA) ratio as a % of Revenue

It is calculated as the ratio of Earnings before taxes, interest and depreciation (EBITDA) to its Revenues.The Company uses as Alternative Performance Measures (“APMs”) the ratios No 4, 5 and 9, in the context of making decisions concerning its financial, operational and strategic planning, as well as assessing and publishing its performance. These APMs help better understand the Company’s financial and operating results, financial position and cash flow statement. Alternative performance measures (APMs) must always be taken into account in combination with the financial results prepared in accordance with International Financial Reporting Standards (“IFRS”) and will not replace the latter under any circumstances.

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B. Financial and Non-Financial Performance Indicators Presentation

Presentation of a mixture of financial indicators took place in the previous modules with a distinct reference to traffic data of each Company's business sector (Cruise, Coastal Shipping, Car Terminal, Container Terminal, and Ship Repair). In addition, PPA S.A. recognizing that the international ESG indicators (in the already published Corporate Responsibility and Sustainable Development Report 2020, there is a special reference to ESG issues entitled "ESG Data Scorecard") are a strategic tool for investor support in the context of identifying risks and opportunities associated with the viability of their investment portfolio and responding at the same time to the challenges of the new environment, builds a sustainable development strategy, aiming to minimize the negative impact that its activities may have. The Company's long-term commitment to Sustainable Development has already led to its participation (August 2020) in the new ATHEX ESG index of the Athens Stock Exchange. As demonstrated in the Corporate Governance Statement, PPA S.A. attaches great importance to Sustainable Development and taking into account both the new legislation on Corporate Governance and the principles of Taxonomy (EU Taxonomy).

C. Commentary on the Company’s significant intangible assets

According to article 150 of Law 4548/2018, large enterprises are required to disclose information regarding the key intangible assets that directly affect their business model, strategic direction and value creation process.Intangible assets are a critical factor in sustainable development, as they are not fully reflected in the financial statements, but they decisively affect the competitiveness and long-term performance of a company. The Company relies heavily on its intangible assets to create added value, differentiate the services provided and maintain a strong position in the competitive international port environment. In the case of the Port of Piraeus, intangible assets do not simply function as complementary assets, but are fundamental pillars of its operation, contributing decisively to ensuring its financial performance, business continuity and long-term sustainability. In the port of Piraeus, intangible resources contribute substantially to value creation and include a set of elements that enhance the operational efficiency, reputation, innovation and strategic advantage of the Company. These resources are categorized as follows:

1. Human Capital

Human capital is one of the most important intangible resources of the Company, as the skills, experience and know-how of the staff directly affect the quality of the services provided and the operational efficiency.
* Specialization and experience of staff: The Company's employees have a high level of know-how and long-term experience in providing a wide range of port services, such as the handling of containers, vehicles and passengers (cruise and coastal shipping), the supply chain and ship repair. This accumulated knowledge is a critical factor in ensuring the reliability and efficiency of port operations.

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  • Corporate culture and organizational knowledge: The corporate culture, characterized by cooperation, responsibility and goal-orientedness, strengthens the cohesion of work teams and contributes to the optimization of internal processes.
  • Education and continuous training: The Company systematically invests in the continuous education and development of human resources, with the aim of upgrading skills, adapting to technological developments and improving productivity and safety of operations.

2. Corporate Reputation and Partnership Network

The strong corporate reputation and the extensive partnership network constitute strategic intangible resources that strengthen the position of the port on the international map.
* International recognition: The port of Piraeus has established itself as the leading multi-purpose port in the Mediterranean and is among the five largest ports in Europe in terms of container traffic. At the same time, in terms of passenger traffic – including the Perama-Salamina ferry connection – it is the largest port in Europe and one of the most important in the world.
* Customer and port user relations: Long-term partnerships with leading international shipping companies and the port’s operation as a key transshipment hub for the southeastern Mediterranean enhance the Company’s credibility and create added value for itself as well as for the local community and the national economy.
* Contracts and concessions: Strategic agreements and long-term concession contracts ensure revenue predictability, enhancing financial stability and the ability to implement long-term investments.

3. Technology and Information Systems

Technology is a critical intangible resource for improving the efficiency and quality of the services provided.
* Digital platforms and automated systems: The adoption of modern digital solutions and automated information systems contributes to the optimization of cargo handling, storage and delivery processes, reducing operational costs and service time.

4. Regulatory Advantages

  • Exploitation rights and institutional framework: The Company holds strategic exploitation rights to port infrastructure, which ensure stable cash flows and enhance its long-term viability, while creating significant entry barriers for potential competitors.

5. Strategic Location and Competitive Advantage

  • Geographical position: The strategic geographical position of the port of Piraeus makes it the main gateway for Asian products to the European market, strengthening its role in international trade and global supply chains.
  • Interconnection with other means of transport: The effective connection of the port with the railway network, the road system and the international airport strengthens the position.

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Conclusion

The intangible assets of the Port of Piraeus play a decisive role in the operation, competitiveness and value creation of the Company. The exploitation of human capital, technology, corporate reputation, strategic partnerships and regulatory advantages allows the development of a strong and sustainable business model. Value creation is achieved through the combined exploitation of intangible resources, with an emphasis on technological investments, continuous optimization of processes and the development of human resources. Through these mechanisms, the Port of Piraeus strengthens its competitiveness, efficiency and attractiveness, consolidating its position as a leading global shipping and transit hub.

OWN SHARES

The Company does not hold any own shares as of December 31, 2025.

BRANCHES

The Company does not have any branches as of December 31, 2025.

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Related Parties

The Company has transactions (provides and receives services) in the normal course of its business with certain companies controlled by its main Shareholders and considered related parties. The Company’s transactions and account balances with related companies, as these are defined in IAS 24 ,are as follows:

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The revenues of € 90,511,252.16 (2024: € 81,706,669.33) (Note 25) from Piraeus Container Terminal S.A. are related to the fixed and variable revenue from the concession agreement (PIER II & III) and revenues of € 1,852,057.64 (2024: € 805,208.86 ) related mainly loading/unloading and mooring. The Company recharged energy costs to the related party under the concession agreement until January 14, 2025, amounted to € 376.064,88 (2024: € 9.169.250,06). After that date, the related party acquired its own electrical substation, and the re-billing process was therefore concluded.

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The transactions with COSCO SHIPPING LINES GREECE S.A. of the previous year mainly related to the supply of ship services (from loading/unloading and berthing), as well as the provision of car transportation services from China. In the current year, transactions mainly related to loading/unloading, berthing and storage services. The transaction with COSCO SHIPPING TECHNOLOGY Co. LTD relates to software support costs. The transactions with COSCO SHIPPING GLOBAL EXH relate to exhibition expenses. The transaction with COSCO SHIPPING TECHNOLOGY (Beijing) relates to software update . The transaction with COSCO (HONG KONG) INSURANCE BROKERS L.T.D. of the current and the previous period relates to the insurance coverage of PPA S.A. regarding third party liability, employer's liability, property and business interruption and directors and officers liability, according to article 17 of the Concession Agreement (Law 4404/2016).

Board of Directors Members Remuneration:

During the year ended December 31, 2025, were paid to the Board of Directors members. remuneration and attendance costs, amounted to € 1,185,793.99 (31.12.2024: € 1,395,877.64 ) Furthermore during the year ended December 31, 2025 emoluments of € 1,174,245.45 (31.12.2024: € 846,326.35 ) were paid to Managers / Directors for services rendered.

Principal Risks Analysis and Risk Management

A. Monitoring the supply chain with reference to the main suppliers and their cooperation rules

There are no suppliers, the interruption of which would jeopardize the operation of the Company in the event of a temporary failure of supplies provision.

B. Other risks that are related to the activity or sector that the company is operating.

B1. Maximum Probable Loss (MPL) analysis

According to the requirements of Art. 17 and Annex 17.1 of the CA, the company has carried out the Maximum Probable Loss (MPL) study in collaboration with a specialized consulting firm in the field of risk insurance. The MPL analysis includes the following elements:
1. Estimation of Maximum Probable Property Loss and loss of income for normal risks, excluding natural disasters (such as earthquakes, tsunamis, etc.).
2. Estimation of Maximum Probable Property Damage and Loss of Revenues concerning natural disasters, and in particular in the event of an earthquake.
3. Risk Quantification analyzing and quantifying the probable scenarios of liability losses, including environmental liability, under the worst-case scenario.6 The Maximum Probable Loss (MPL) is defined as the maximum estimated loss resulting from a single event or risk assessed with due diligence, considering all the distinct elements of the Port of Piraeus and its environment

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The conclusions and recommendations of MPL have already been incorporated into PPA’s Property Damage and Business Interruption Loss of Profit insurance policy.

B2. Risk of property loss

The Company takes all necessary measures to minimize the risk and possible losses of assets due to natural disasters or other causes.

Property Damage and Business Interruption Loss of Profit

The Company has insured all its assets in accordance with the provisions of Article 17.1 of the CA with the Greek State for the following indicative but not limited to perils:
* Fire, lightning, explosion, storm damage, aircraft crashes and named perils or Property All Risks, based on new replacement cost of asset.
* The income loss due to disaster-related closing / business interruption of the business facility or due to the rebuilding process after a disaster, i.e. storm, earthquake, flood, strikes, riots and terrorist actions, has been insured.

B3. Hull and Machinery Insurance

The Hull and Machinery (H&M) insurance policy provides comprehensive asset protection tailored for PPA’s three floating docks Piraeus I, II & III against physical damage and maritime perils.

B4. Third Party Liability

The Company maintains insurance in respect of third-party liability in accordance with the provisions of Article 17.1 of the CA with the Greek State for all its activities.

Business Risks Associated with the Company's business activities

A detailed report on the main risks associated with the sector in which the Company operates is set out in Chapter of the Sustainability Report, which follows (Risk Policy and Risk Management / Major Business Risks and Uncertainties).

Financial Instruments Fair Value

The carrying amounts reflected in the accompanying sheets of financial position for cash and cash equivalents, trade and other receivables, suppliers and accrued and other current liabilities approximate their respective fair values due to the relatively short-term maturity of these financial instruments. The fair value of variable rate loans and borrowings approximate the amounts appearing in the statements of financial position.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

The Company categorized its financial instruments carried at fair value in three categories, defined as follows:
* Level 1: Quoted (unadjusted) values from active financial markets for identical negotiable assets or liabilities.
* Level 2: Other techniques for which all inflows that have a significant impact on the recorded fair value are identified or determined directly or indirectly from active financial markets.
* Level 3: Techniques that use inflows that have a significant impact on the recorded fair value and are not based on quoted prices from active financial markets.

During the year ended December 31, 2025, there were no transfers between Level 1 and Level 2 fair value measurements, and no transfers into and out of Level 3 fair value measurements.

Financial risk management:

The financial risks related to the Company and their respective management are as follows:

Credit Risk:

The Company's Management estimates that its exposure to credit risk is limited towards the contracting parties, - as a matter of policy - it receives advances payments or letters of guarantee for most of its provided services. From the above applied policy are excluded customers who belong to the same group of companies, as mentioned in note 32 "Related Party Transactions". In addition, the transactional activity between the Company and its related party company, Piraeus Container Terminal SA, which is the Company's largest customer in terms of volume, is mainly covered by the terms of the concession agreement between them, which is under the supervision of the Greek State. It should be noted that despite the very significant amount and range of related parties transactions, no credit event has occurred until now that could raise a credit risk. In addition, the Company's cash at banks and time deposits are placed in bank financial institutions in Greece and generally in European Union, with the following ratings (Moody's credit rating):

Foreign Exchange Risk:

The Company is neither involved in international trade nor has any long-term loans in foreign currency and therefore is not exposed to foreign exchange risk resulting from foreign currency rate variations.

Interest rate risk:

The Company's bank lending concerns two loans in Euro and is subject to one fixed rate and the other to a variable interest rate (Note 19). The Company, during the year does not use bank borrowing and therefore there is no interest rate risk.

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Additionally, in the context of managing its assets as effectively as possible, as well as limiting any possible impact of increased borrowing interest rates on its results, the Company's Management, taking advantage of its strong liquidity, implements short-term reinvestments of these, expoiting the increased interest rates on term deposits. The table below presents and analyses the sensitivity of the result in relation to financial assets (cash on hand and in banks) and financial liabilities (loans) of the Company to the interest rate risk changes assuming a simultaneous change in interest rates by $\pm$ 100 basis points on the Company’s profit.

Liquidity risk:

The effective management of liquidity risk is ensured by maintaining sufficient cash and the availability of financing in case of need. Corporate liquidity risk management is based on the proper management of working capital and cash flows. The following table summarizes the maturity dates of the financial liabilities of 31 December 2025 and 2024 respectively, arising from the relevant contracts at unpaid prices.

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The above table includes the interest on long-term loans, which were calculated until maturity according to the European Investment Bank quarterly information note for the 1st quarter of 2025. Trade payables do not have interest and are settled in up to 60 days. Other payables also do not bear any interest and are settled in up to 12 months.

Capital Management

The primary objective of the Company's capital management is to ensure the maintenance of high credit rating, and healthy capital ratios in order to support and expand the Company's operations and maximize shareholder value. The Company's policy is to maintain leverage targets, according to an investment grade profile. The Company monitors capital adequacy using the ratio of total debt to operating profits. The debt includes interest-bearing loans and lease liabilities, while the operating profit includes profit/(loss) before taxes, financing costs and depreciation.

Amounts of fiscal year 2025 Current portion
Less than 6 months 6-12 months 2 to 5 years >5 years Total
Borrowings - - - - - -
Lease liabilities 4.368,74 3.514.703,69 11.076,00 14.000.000,00 77.437.500,00 94.967.648,43
Trade and other payables* 23.710.719,51 26.084.597,02 12.857.973,91 - - 62.653.290,44
Total 23.715.088,25 29.599.300,71 12.869.049,91 14.000.000,00 77.437.500,00 157.620.938,87
Amounts of fiscal year 2024 Current portion
Less than 6 months 6-12 months 2 to 5 years >5 years Total
Borrowings - 3.443.636,38 3.389.257,92 21.828.157,50 - 28.661.051,80
Lease liabilities 8.718,00 3.543.657,00 19.148,00 14.000.000,00 80.937.500,00 98.509.023,00
Trade and other payables* 16.438.265,11 18.187.960,56 10.029.851,49 - - 44.656.077,16
Total 16.446.983,11 25.175.253,94 13.438.257,41 35.828.157,50 80.937.500,00 171.826.151,96

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

SUBSEQUENT EVENTS

The most significant events after December 31, 2025, are the following:

First Investment Period Duration

In accordance with the provisions of article 7.2 and Annex 7.2a of the Concession Agreement between PPA SA and the Hellenic Republic (the contracting parties), ratified by law 4404/2016, as amended (law 4838/2021), the identification and quantification of one or more Suspension Events, by the Independent Engineer, during the execution of the Mandatory Investment projects, results in a corresponding extension of the First Investment Period. The identification and quantification of the Suspension Events falls under the competence of the Independent Engineer and is recorded in the Reports that they submit to the contracting parties. In this case, the Independent Engineer has identified, quantified and recorded in his Reports, to date, Suspension Events of a total duration of 1177 days. Consequently, the First Investment Period, which was to expire on August 9, 2026, has been extended by the corresponding period, i.e. by 1177 days, with a new expiration date (as of this day and subject to any occurrence of new Suspension Events in the future) on October 29, 2029.The above is established and recorded in the most recent 35th Quarterly Report of the Independent Engineer referenced to the last quarter of 2025, which has been duly notified by the Independent Engineer to both parties (PPA SA and the Greek State) on January 28, 2026.

Evolutions in the Middle East

Following the reporting date, and specifically during February 2026, an armed conflict broke out in Iran, forming part of the broader context of geopolitical instability in the Middle East. This development does not constitute an adjusting event in accordance with IAS 10 “Events after the Reporting Period”, as the relevant conditions did not exist at the reporting date.

The Company’s Management closely monitors and continuously assesses the impact of the volatile situation in the Middle East on the macroeconomic and financial environment, such as potential energy instability and increase in energy costs, inflationary pressures, and severe disruptions in international shipping and global trade, in order to ensure that all necessary actions and measures are taken to minimize any potential effects on the Company’s operations.

As part of the Company’s operations, cargo containers are transported either from or to ports in the countries involved or neighboring regions. These shipments for the 2025 fiscal year were not significant in relation to the Company’s overall operations.

At the same time, in the context of developments in international shipping and trade flows in the wider region, certain changes and diversions in routes and cargoes towards to Piraeus have been observed so far. The nature of these changes is currently assessed as temporary, as the situation is evolving dynamically and is constantly being reassessed in light of geopolitical developments, both by the Company and by shipping providers. As of the date of approval of the financial statements, it is not possible to estimate any potential quantitative impact of this development on the Company’s results and financial position.

Other than the above, there are no other significant events after December 31, 2025, that may have a material impact on the company's financial position.

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GOING CONCERN DISCLOSURE

The Company, for the preparation of the Financial Information of December 31, 2025, has adopted the going concern basis. For the application of this principle, the Company took into account the current financial developments as well as the risks arising from the financial environment and made estimates for the shaping, in the near future, of the trends and the economic environment in which it operates.

The main factors that can affect the implementation of this principle are mainly related to the economic environment in Greece and internationally as well as the ongoing Russia/Ukraine, unstable environment in the Middle East region), with the resulting issues in the energy sector, rising inflation and the free navigation of commercial ships.

As part of the consideration of whether to adopt the going concern basis in preparing the financial statements, management has considered the Company’s financial performance in the year, as well as a quantitative viability exercise, including the performance of various stress tests that consider the Company’s principal risks, including that relating to climate change, and confirms the Company’s ability to generate cash in 12 months from the date of approval of the financial statements and beyond.

The Company’s strong balance sheet and liquidity position, its operation in several segments, the strong and dynamic management and the experienced human resources will allow the Company to successfully overcome any period of uncertainty.Therefore, it is deemed appropriate that the Company continues to adopt the going concern basis for the preparation of the financial statements. Accordingly, and having reassessed the principal risks, the Directors continue to adopt the going concern basis of accounting in preparing the Annual Financial Statements and have not identified any material uncertainties to the Company's ability to continue trading as a going concern over a period of at least 12 months from the date of approval of annual financial statements.

Piraeus, March 31, 2026

THE CHAIRMAN OF BoD
HAN CHAO

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STATEMENT OF CORPORATE GOVERNANCE (Article 152 of L. 4548/2018)

Introduction

Corporate Governance is the framework of structures, principles, rules, procedures and practices, through which the continuous improvement of the efficient operation of the Company, the enhancement of the long-term economic value and the protection of its general corporate interest. The implementation and adherence of the optimum corporate governance practices is a priority for the Company due to the important role it plays both as a gateway for import and export trade, and as a gateway to serve the country's tourism industry, for the benefit of the local and national economy in general.

The Company, in compliance with Law 4706/2020, harmonized all the provisions of its Articles of Association and adopted a series of Policies and Regulations, which ensure transparent and effective governance, and instituted the necessary organizational structures for their adoption and implementation.

The Company continues to update existing and draft new Policies and Regulations, due to the constantly changing environment in which it operates and the need to continuously adapt both the organizational structure and the organizational and management practices it adopts and applies, taking into account in particular the provisions to the Greek Corporate Governance Code of the Hellenic Corporate Governance Council, which the Company has adopted and applies and the relevant decisions of the Capital Market Commission.

The Company, taking into account international trends, in terms of Corporate Governance is moving in the direction of adopting Environmental and Social Governance (ESG: Environmental, Social, Governance) practices, recognizing that the creation of value for its stakeholders (shareholders, employees, suppliers, users of the port, local community) is not achieved solely through the achievement of strong financial performance but mainly through proper Governance, and the impact of its activity on Society and the Environment.

Structure of the Corporate Governance Statement

The current Statement of Corporate Governance is prepared pursuant to the provisions of article 152 of Law 4548/2018, article 18 of Law 4706/2020, as in force, the provisions of the Hellenic Corporate Governance Code of the Hellenic Corporate Governance Council (HCGC), which was issued in June 2021 and has been adopted and is implemented by the Company, following the relevant approval of its BoD, and in conformance with article 17 of Law 4706/2020, as well as relevant explanatory circulars and letters of the Capital Market Commission, and in particular, the Letter of the Capital Market Commission with no. prot. 434/24.02.2025 to companies with securities listed on the Athens Stock Exchange This Statement of Corporate Governance is a special part of the Annual Management Report of the Board of Directors and contains all the information required by law. In addition, it includes the Company’s response to specific practices under the Chapters of the Hellenic Corporate Governance Code of the HCGC, which has been adopted and is implemented.

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In particular, the structure of this Statement of Corporate Governance is as follows:
I. Statement of Compliance with the Corporate Governance Code
II. Deviations from the Corporate Governance Code and Justification of Deviations
III. Description of the main features of the Company’s internal control and risk management systems in relation to the financial reporting process
IV. Reference to the information required for cases c, d, e, f and hof par 7 of article 4 of Law 3556/2007 (Α 91)
V. Composition and function of the administrative and supervisory bodies of the Company - General Assembly of Shareholders - Board of Directors - Audit Committee - Nomination Committee - Remuneration Committee - Strategy Committee
VI. Periodic Evaluation Policy of the Internal Control System of PPA SA and Implementation of the provisions on Corporate Governance of Law 4706/2020
VII. Periodic Evaluation Policy of the Corporate Governance System
VIII. Diversity Policy applied in relation to the Company’s administrative, managerial and supervisory bodies

Ι. Code of Corporate Governance

Law 4706/2020 (Government Gazette 136 / Α / 17-7-2020), on Corporate Governance of public limited companies, modern capital market, which incorporated in Greek legislation the Directive (EU) 2017/828 of the European Parliament and Council, measures to implement Regulation (EU) 2017/1131 and other provisions, as well as Decision 2/905 / 3.3.2021 of the Board of Directors of the Hellenic Capital Market Commission establish the obligation to adopt and implement the Corporate Governance Code, which has been prepared by a body of known prestige.

The Company, in compliance with the requirements and regulations of the said law, implements with a relevant decision of its BoD the Code of Corporate Governance, of the Hellenic Corporate Governance Council issued in June 2021, the text of which is available at website of the Company at the following link: https://www.esed.org.gr/en/code-listed.The implementation of this Code aims at the continuous improvement of the corporate institutional framework and the wider business environment, as well as the improvement of the Company's competitiveness as a whole.

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II. Deviation from the Corporate Governance Code and Justification of Deviations

The Company fully complies with the provisions of the relevant Greek legislation, rules and regulations and internal corporate values for the development of corporate governance principles it applies and has adapted to those defined by the existing institutional framework of corporate governance. As mentioned above, following a Board of Directors (BoD) decision and in accordance with article 17 of law 4706/2020, it implements and adopts the Hellenic Corporate Governance Code (HCGC, June 2021) of the Hellenic Corporate Governance Council (HCGC).

The Company has not adopted some specific practices of the Code that are specifically mentioned below but remains faithful to its commitment to take all the necessary actions for the implementation of the provisions of Law 4706/2020:

Deviation from the Special practice of Code 2.2.15: “The company ensures that the diversity criteria concern, in addition to the members of the BoD, senior and/or senior management with specific representation objectives by gender, as well as timetables for achieving them”.

Explanation: Due to the particular nature of the port industry area in which the Company operates and given that the overwhelming percentage of its staff is employed in labor-intensive activities (dockworkers, operators of lifting machines, drivers of heavy-duty vehicles, workshop staff, etc.), it is not possible to define and ensure specific goals of representation by gender, (beyond the BoD members in accordance with the provisions of Law 4706) among the Managerial staff. Apart from the BoD members selection where the Company applies the diversity criteria provided for in the BoD Suitability Policy, no specific gender representation goals and specific timetables for their achievement have been set for the selection of the Company's Managerial staff. However, the Company's Code of Conduct, which is uploaded on the Company's website, states (Chapter of Equal Opportunities) that the Company promotes a work environment that respects equality, individual rights and diversity no matter on characteristics such as age, gender, race, nationality and physical ability. On 31.12.2025, the participation of women in all of the Company's managerial positions amounted to 36.5%.

Deviation from the Special practices of Code:
* 2.2.21: “The Chair shall be elected by the independent non- executive members. In the event that the Chair is elected by the non-executive members, one of the independent non-executive members shall be appointed, either as vice-chair or as a senior independent member (Senior Independent Director)”.
* 2.2.22: “The independent non-executive Vice-Chair or Senior Independent Director shall, as appropriate, have the following responsibilities: to support the Chair, to act as a liaison between the Chair and the members of the BoD, to coordinate the independent non- executive members and lead the evaluation of the Chair”.
* 2.2.23: “Where the Chair is an executive, then the independent non-executive vice-chair or the senior independent member (Senior Independent Director) shall not replace the Chair in his executive duties.”.

Explanation: The Company's BoD, when constituted as a Body, applies the provisions of article 8 of Law 4706/2020 "In the event that the BoD appoints one of the executive members as Chairman, it must appoint a Vice-Chairman from among the non-executive members". In addition, 67% of the members of the Company's existing BoD are Non-Executive members, while the Chairmen and the majority of the members of the Article 10 Committees (Audit, Remuneration, Nomination) are Independent Non- Executive members.

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Taking into account the above, the Company's BoD considers that the non-appointment of one of its members as Senior Independent Director does not create any problem in its orderly operation and the fulfillment of its duties, as well as that the burden of the independent non-executive members with the additional burden of the object of the Vice Chairman of the BoD was not desirable, while it might cause obstacles in the work of the above Committees. With the above specific balance, its efficient and productive operation has been ensured during all the last years.

Deviation from the Special practices of Code:
* 2.3.1: “The company has a framework for filling positions and succession of the members of the BoD, in order to identify the needs for filling positions or replacements and to ensure each time the smooth continuation of the management and the achievement of the company's purpose”.
* 2.3.2: “The company ensures the smooth succession of the members of the BoD with their gradual replacement in order to avoid the lack of management.”.
* 2.3.3: “The succession framework shall in particular take into account the findings of the evaluation of the BoD in order to achieve the necessary changes in composition or skills and to maximise the effectiveness and collective suitability of the BoD.”.

Explanation: Regarding to the succession of the BoD members, given that the term of office of the BoD members launched in July 2025, it was not considered appropriate within 2025 to have a procedure for the activiation of the Nominations Committee. In the event of the need to replace one or more members of the BoD, the Nominations Committee is activated to find suitable candidates for new members in accordance with the Company's Nominations Policy in order to carry out the replacement of members, the procedure defined in the Committee's Operation Regulation and the BoD Operation Regulation.

Deviation from the Special practice of Code 2.3.4: “The company also has a succession plan for the Chief Executive. The preparation of an integrated succession plan for the Chief Executive shall be entrusted to the nomination committee, which in this case shall be responsible for: (a) identifying the required quality characteristics that the Chief Executive should have, (b) ongoing monitoring and identification of potential internal nominees, (c) where appropriate, search for potential external nominees, (d) and a dialogue with the Chief Executive on the evaluation of nominees for his / her position and other senior management positions. ”.

Explanation: The company has not formulated a special succession plan for the CEO, as the CEO is replaced (by BoD decision), in case of absence or impediment, by the Chief Financial Officer who is also an executive BoD member. In addition, the CEO has six (6) Deputies CEO, thus ensuring the smooth continuity of the management of the Company's affairs and its daily corporate operation.

Deviation from the Special practice of Code 2.3.7: “The Board of Directors shall set up a nomination committee, which shall play a leading role in the nomination process, in the design of the succession plan and for the members of the Board of Directors and senior management.”

Explanation: The approval of the recruitment process of a senior management member and the evaluation of his/her performance in the context of the implementation of the Corporate Governance Law is of crucial importance for the successful achievement of the Company's objectives, as these executives make the key decisions that lead to its development. In the event of the quit of a senior management member of the Company or the creation of a need for a new position, the major Shareholder proposes the appropriate candidate for it, and after a review of his/her qualifications by the Nomination Committee, a proposal is submitted for approval by the BoD to fill the specific position.

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ΙIΙ. Description of the main features of the Company’s internal control and risk management systems in relation to the financial reporting process

a) Company level controls

  • The ICS of the Company covers adequately the control procedures involving risk management and preparation of financial reports.
  • In respect of the preparation of financial statements, the Company considers its accounting system adequate for reporting to the Management and external users. The financial statements are prepared in compliance with the International Financial Reporting Standards, as adopted by the European Union for reporting purposes to the administration, and also for the purpose of publication in line with the applicable regulations (hereinafter, “IFRS”). All reports include the data of the current period, compared to the respective data of the Budget as approved by the BoD, and to the data of the respective period of the year before the report. All published interim and annual financial statements include all necessary information and disclosures in compliance with the IFRS, are reviewed by the Audit Committee and are approved in their entirety by the BoD.
  • Safeguards are implemented with respect to: a) supervision and approval of all important transactions through the structural hierarchy of the Company; b) monitoring of financial figures and risk evaluation as for the reliability of the financial statements; c) fraud prevention and tracking; and d) protection of data provided by information systems.
  • The Company’s progress is monitored through a detailed budget per operating sector.The budget is adjusted when is necessary to take into account the changes in the development of the Company’s financials that depend greatly on external factors. Management monitors the development of the Company’s financial results through regular notes and reports.
  • The Company's Operating Regulations, in which, among other things, the responsibilities and responsibilities of the basic jobs are defined, aim at the adequate separation of responsibilities within the Company. The approved Operating Regulations have been posted on the Company's website in accordance with par. 2 of article 14 of Law 4706/2020.
  • The internal reports to the Management and the reports required from the provisions of the legislation and by the supervisory authorities are prepared by the Financial Management Department, which is staffed with adequate and experienced executives to this effect.

b) Information systems’ controls
Given that the financial reporting processes are highly dependent on information systems, the Company has undertaken a series of actions aimed at enhancing the operating effectiveness of controls in order to ensure the completeness and accuracy of the financial records. Specifically, the IT & BPS Department is responsible for defining and implementing the strategy. Their responsibilities include the development, operation, and support of information systems, as well as the implementation and monitoring of appropriate information security safeguards.

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Information Systems Security

The Company implements a comprehensive monitoring and control framework for its information systems which includes a set of control mechanisms, policies, and procedures in order ensure compliance with required regulatory frameworks and guidelines (e.g. NIS2 Directive L. 5160/2024). To enhance cybersecurity in 2025, the Company has implemented the following measures:
* Implementation of security policies based on cybersecurity risk assessments.
* Implemented cybersecurity training program including user awareness courses and campaigns.
* Initiation of enhanced data protection controls, including information classification and sensitivity labeling, as well as improved secure file storage and sharing controls to reduce the risk of data loss.
* Design and execute IT Emergency plan and drill, including tests and recovery procedures for critical infrastructure.
* Regular penetration and vulnerability Assessments for public and internal systems.
* Enhanced vulnerability patch management via dedicated module and automated patch policies.
* Collaborated with internal and external auditors to strengthen controls and compliance.
* Collaboration with competent national and European cybersecurity authorities in the execution of threat landscape analysis and information systems risk assessment.
* Performed regular IT risk assessments to identify, evaluate and address potential risk.

Information Systems Governance

In 2025, the Company continue the implementation of information security and IT governance policies. The development of these policies was based on a comprehensive consulting engagement, focused on an audit of the IT management system, penetration test, baseline inspection, risk assessment, etc. This involved meticulously outlining processes that oversee Information Systems governance and taking several measures to strengthen the controls for its information systems. By implementing these measures and continuously monitoring and improving information systems controls, the Company can enhance the security and integrity of its data and mitigate potential threats and risks.

During 2025, the Company further strengthened its information systems governance framework through the establishment of a dedicated Chief Information Security Officer role, who is responsible for managing the Information Security Framework. This Framework includes cybersecurity policies and procedures aligned with international best practices and standards, reflecting Management's commitment to managing cyber risks enhancing at the same time oversight, accountability, and coordination of information security and cyber risk management.

The Company employs a multi-layered approach to protect its information, supported by a strategic plan that incorporates state-of-the-art technologies and top-tier information systems, while ensuring compliance with the required regulatory frameworks and directives. Indicatively, the Company has adopted AI-enabled cutting-edge security solutions that continuously improve support for the digital transformation strategy, while addressing the ever-evolving cybersecurity landscape.

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Furthermore, the Company has invested in fostering a culture of cybersecurity awareness through e- learnings, face to face training sessions and phishing simulation drills aiming to minimize the risk of human errors that could lead to unintentional or intentional adverse incidents. Finally, the Company has implemented technical and organizational arrangements to enhance the continuity of IT services in case of unexpected events that could affect system availability.

IV. Reference to the information required for cases c, d, e, f and hof par 7 of article 4 of Law 3556/2007 (Α 91).

The above information is included in another part of the Management Report, i.e. in the Explanatory Report of the BoD according to article 4, par. 7 and 8 of Law 3556/2007.

V. Composition and function of the administrative and supervisory bodies of the Company

A. General Assembly of Shareholders

  1. The General Assembly (GA) of the shareholders of the company is the supreme body of the Company and is entitled to decide on any affair regarding the Company. Its legal resolutions also bind the absent or disagreeing shareholders.
  2. The GA of shareholders is convened by the BoD and meets obligatorily at the seat of the Company or in the region of another municipality within the region where the seat of the company is located, at least once in any corporate fiscal year until the tenth (10th) calendar day of the ninth month at the latest after the end of the corporate financial year. It may also be convened at the region of the Municipality, in which the seat of the Athens Stock Exchange is located.
  3. The GA has a quorum and validly meets on the issues of the daily agenda, provided they are present or represented therein shareholders representing at least one fifth (1/5) of the paid share capital. If no such quorum occurs at the first meeting, a repetitive GA is convened within twenty (20) days from the date of the cancelled meeting, which is convened at least ten (10) days prior to this meeting, unless the procedure of article 9 par. 5 last sentence of these articles of association has been applied. This repetitive GA has quorum and validly meets on the issues of the initial daily agenda, whichever is the part of the paid share capital of the company, which represented in the meeting. The resolutions of the GA are taken upon full majority of the votes represented in the meeting.
  4. Until the election of its Chairman, performed by the same meeting with a simple majority, in the GA chairs the Chairman of the BoD or his/her alternate. The Chairman of the meeting may be assisted by a secretary and a teller, elected in the same way. The Chairman checks if the convocation of the GA follows the normal procedure, the identity and legalization of those present in the meeting, the accuracy of the minutes, administers the discussion, sets the issues on vote and announces the results of the vote.
  5. The discussions and resolutions of the GA are limited to the issues of the daily agenda. The result of the voting is announced by the Chairman of the GA as soon as it is confirmed. The company, under the responsibility of its BoD, publishes in its website the results of the voting within maximum five (5) days from the date of the GA, specifying for each resolution at least the number of shares for which valid votes were given, the percentage of the share capital that is represented by these votes, the total number of valid votes, as well as the number of votes for and against each resolution and the number of the absences.

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The Ordinary GA of the Company's Shareholders in the year 2025, took the following decisions:
1. Approval of the Annual Financial Statements, along with the Board of Director’s Annual Report and the Independent Auditors’ Report.
| Item | Shares Agreed | % of Paid-up Capital | % of Voting Shareholders |
| :--- | ---: | ---: | ---: |
| For the above item | 20,854,752 | 83.299% | 99.684% |

  1. Approval for dividend’s distribution.
    | Item | Shares Agreed | % of Paid-up Capital | % of Voting Shareholders |
    | :--- | ---: | ---: | ---: |
    | For the above item | 20,851,179 | 83.405% | 99.811% |

  2. Approval of the remuneration report under article 112 of law 4548/2018.
    | Item | Shares Agreed | % of Paid-up Capital | % of Voting Shareholders |
    | :--- | ---: | ---: | ---: |
    | For the above item | 20,448,661 | 81.795% | 97.884% |

4.a) Approval of the remuneration and fees paid to the BoD members for the fiscal year 01.01.2024 – 31.12.2024, according to article 109, paragraph 1 of Law 4548/2018, and b) Approval of advance payment of remuneration and fees for the fiscal year 01.01.2025 – 31.12.2025 according to article 109, paragraph 4 of Law 4548/2018. For the above item agreed regarding the item (a) shareholders who participated in the GA, representing 20.776.615 registered shares, representing 83.106% of the paid-up share capital of the Company or 99.454% of the voting shareholders, and regarding the item (b) shareholders who participated in the GA, representing 19,816,779 registered shares, representing 79.267% of the paid-up share capital of the Company or 94.859% of the voting shareholders.

  1. Approval of the overall management of the Company according to article 108 of Law 4548/2018, as in force, and discharge, pursuant to the article 117 of L. 4548/2018, of the Statutory Auditors of the Company from any liability for compensation For the above item agreed shareholders who participated in the GA, representing 20,768,950 registered shares, representing a percentage of 83.076% of the paid-up share capital of the Company or a percentage of 99.417% of the voting shareholders.

  2. Appointment of Auditing Firm, and determination of its remuneration, for the fiscal year 01.01.2025 – 31.12.2025, for a) the statutory audit of the financial statements and the issuance of the annual tax report of PPA SA and b) for the assurance of the Sustainability Report. For the above item agreed regarding the item (a) shareholders who participated in the GA, representing 20.701.620 registered shares, representing 82.806% of the paid-up share capital of the Company or 99.095% of the voting shareholders, and regarding the item (b) shareholders who participated in the GA, representing 20,780,909 registered shares, representing 83.124% of the paid-up share capital of the Company or 99.474% of the voting shareholders.

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  1. Election of a new Board of Directors of the Company, definition of its term of office and appointment of its independent members, in accordance with the current regulatory framework. For the above item regarding the election of Mr. LIN Ji agreed shareholders who participated in the GA, representing 18,835,986 registered shares, representing a percentage of 75.344% of the paid-up share capital of the Company or a percentage of 90.164% of the voting shareholders. For the above item regarding the election of Mr. ZHU Changyu agreed shareholders who participated in the GA, representing 18,496,364 registered shares, representing a percentage of 73.973% of the paid- up share capital of the Company or a percentage of 88.524% of the voting shareholders. For the above item regarding the election of Mr. Su Xudong agreed shareholders who participated in the GA, representing 19,049,946 registered shares, representing a percentage of 76.200% of the paid- up share capital of the Company or a percentage of 91.189% of the voting shareholders. For the above item regarding the election of Mrs. LI Jin agreed shareholders who participated in the GA, representing 19,010,869 registered shares, representing a percentage of 76.043% of the paid-up share capital of the Company or a percentage of 91.002% of the voting shareholders. For the above item regarding the election of Mr. ZHOU Zhonghui agreed shareholders who participated in the GA, representing 19,066,211 registered shares, representing a percentage of 76.265% of the paid- up share capital of the Company or a percentage of 91.267% of the voting shareholders. For the above item regarding the election of Mr. LIN Lan agreed shareholders who participated in the GA, representing 19,066,739 registered shares, representing a percentage of 76.267% of the paid-up share capital of the Company or a percentage of 91.269% of the voting shareholders. For the above item regarding the election of Mrs. ZHANG Xueyan agreed shareholders who participated in the GA, representing 18,991,739 registered shares, representing a percentage of 75.965% of the paid- up share capital of the Company or a percentage of 90.908% of the voting shareholders. For the above item regarding the election of Mrs. ZARAKELI Andriana agreed shareholders who participated in the GA, representing 19,062,552 registered shares, representing a percentage of 76.267% of the paid-up share capital of the Company or a percentage of 91.269% of the voting shareholders.

  2. Election of a new Audit Committee (redefinition of its type, its term, the number and capacity of its members). For the above item agreed shareholders who participated in the GA, representing 19,062,552 registered shares, representing a percentage of 76.250% of the paid-up share capital of the Company or a percentage of 91.249% of the voting shareholders.

The following were also presented for the information of the shareholders of the Ordinary General Meeting, without being put to a vote:

  1. Presentation of Company’s Annual Audit Committee Activity Report, in accordance with the article 44 of L. 4449/2017, as in force.

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  1. Presentation of the Report of the Independent non-Executive members of the BoD Activity Report, in accordance with the article 9 of L. 4706/2020, as in force.

B. Board of Directors

1. Composition - Operation - Power - Duties of the BoD

Composition - Operation of the BoD

  1. The Company is managed by the BoD composed by nine (9) to thirteen (13) members (directors), elected by the GA, subject to paragraph 2 below, with absolute majority of the represented votes, for a duty up to five (5) years, which is extended until the expiry of the deadline, within which the next ordinary GA following directly the previous one must be convened and until the adoption of the relevant resolution.
  2. As long as the Hellenic Corporation of Assets and Participations SA or any global successor or successor by operation of law of the Hellenic Corporation of Assets and Participations SA(each and collectively, the “GROWTHFUND”) holds at least one million two hundred and fifty thousand (1,250,000) voting shares and less than 10% of the voting shares issued by the Company and subject to the GROWTHFUND is entitled to appoint one (1) Member pursuant to article 79 of Law 4548/2018 as in force. If the GROWTHFUND holds at least 10% of the voting shares, the GROWTHFUND is entitled to appoint 1/3 of the total number of Members of the BoD of the Company.
  3. Should any Director appointed pursuant to paragraph 2 of this article resign or become incapacitated for whatever reason, they shall be replaced by such persons the GROWTHFUND shall specify in a pertinent written notice to the Company, with immediate effect.
  4. The directors, shareholders and non-shareholders may always be reelected and are freely revocable.
  5. Member of the BoD may also be a legal person. In this case the legal person is obliged to appoint a natural person for the exercise of the powers of the legal person as member of the BoD. This appointment is subject to publicity according to article 13 of the L.4548/2018. The natural person is jointly and severally liable together with the legal person for the company's management.
  6. The BoD consists of executive, non-executive and independent nonexecutive members.
  7. Executive members are those who deal with the day-to-day management of the Company. The executive members of the BoD, in particular: (a) are responsible for the implementation of the strategy determined by the BoD and (b) consult at regular intervals with the non-executive members of the BoD on the most appropriate strategy to be implemented. In situations of crisis or risk, as well as when circumstances require it to take measures that are reasonably expected to significantly affect the Company, such as when decisions are to be made regarding the development of the business and the risks that are expected to affect the financial situation of the Company, the executive members inform the BoD in writing without delay, either jointly or separately, submitting a relevant report with their estimates and proposals.

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  1. The non-executive members of the BoD, including the independent nonexecutive members, have, in particular, the following obligations: (a) They monitor and examine the Company's strategy and its implementation, as well as the achievement of its objectives. (b) Ensure effective oversight of executive members, including monitoring and control of their performance. (c) Examine and express views on the proposals submitted by the executive members, based on existing information.
  2. The number of non-executive members of the BoD must not be less than 1/3 of the total number of members, including independent non-executive members.
  3. Independent non-executive members are those members who are elected by the GA, or appointed by the BoD (according to par. 4 of article 9 of Law 4706/2020), who are free from financial, business, family or other relationships of dependency with the Company or with persons related to it, which may influence their decisions and their independent and objective judgment, and meet the additional conditions provided by the relevant legislation (article 9 of Law 4706/2020), including non-executive obstruction assistance and not exceeding the maximum permitted percentage of their participation in the share capital of the Company.

Power - Duties of the BoD

1.The BoD, acting collectively, exercises the management of the Company and exercises control over its all activities. Manages the corporate property, represents the Company and makes decisions on all matters concerning the Company with a view to promoting the corporate purpose, except for matters relating to the exclusive responsibilities of the GA of Shareholders. It is further responsible for the complete and effective control of the Company's activities and acts in accordance with the provisions of the law and the articles of incorporation. The main responsibilities of the BoD include:

  • The drawing up of strategic directions, including the sale or otherwise disposal of the Company's shares, the acquisition of any company or the proposal to merge the Company with another company, which are subject to the final approval of the GA of the shareholders.
  • The management and disposal of the corporate property and the representation of the Company in court and out of court.
  • The conclusion and receipt of loans on behalf of the Company.
  • The conclusion of any kind of contract, subject to articles 99 -101 of Law 4548/2018 and agreements with any third physical or legal persons.
  • Ensuring the completeness and reliability of the data and information required for the accurate and timely determination of the financial situation of the Company and the preparation of reliable financial statements, as well as its non-financial situation, according to article 151 of law 4548/2018.
  • The preparation of the annual budget and the business plan of the Company.
  • Defining and achieving the Company's efficiency goals.
  • Monitoring the progress of the Company and the control of large capital expenditures.
  • Ensuring the adequacy and efficiency of the Company's ICS, which aims in particular:
    • a) the consistent implementation of the business strategy,

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* b) the identification and management of material risks associated with its business and operation,
* c) the efficient operation of the internal control unit.
  • Ensuring that the functions of the Internal Audit System are independent of the business sectors they control, and that they have the appropriate financial and human resources, as well as the powers to operate them effectively.
  • The definition of the strategy and business risk management of the Company.
  • The formulation, dissemination and application of the basic values and principles of the Company that govern its relations with all parties, whose interests are related to those of the Company.
  • The convergence of the General Assemblies (regular or extraordinary) and the determination of the issues of its agenda.
  • The preparation of the Company's remuneration policy, which is submitted for approval by the GA of Shareholders (following a relevant proposal of the Remuneration Committee).
  • The submission of a proposal for approval by the GA of Shareholders for the distribution of dividends.
  • The submission of a proposal for approval by the GA of Shareholders for the election of Statutory Auditors, for the regular audit of the financial statements of the Company (following a relevant proposal of the Audit Committee).
  • The submission of a proposal for approval by the GA of Shareholders for the eligibility policy of the members of the BoD (as well as any substantial modification) and its posting on the Company's website.
  • The preparation of training policy for the members of the BoD and executives of the Company.
  • The approval and any revision of the Internal Regulation of the Remuneration Committee as well as the Nominations Committee (following a relevant suggestion of the above Committees).
  • The responsibility for the compliance of all types of activities of the Company with the regulatory and legislative framework, as well as the internal regulations governing the operation of the Company.
  • The succession planning for the members of the BoD and the Chief Executive Officers.
  • The annual collective evaluation of the effective BoD functioning, the fulfillment of its duties as well as its committees. The adoption of a calendar of meetings and an annual action plan, at the beginning of each calendar year, which is revised according to the developments and needs of the Company, in order to ensure the correct, complete and timely fulfillment of its duties.
  • Supervising the implementation as well as ensuring the adequacy and effectiveness of the corporate governance systems on which the Company operates and taking appropriate action to address deficiencies.
  • The appointment of the head of the Internal Audit Service of the Company.
  • The possibility of assigning the duties of Coordinator or Mandated Advisor to one or more of its members.
  • Ensuring that the detailed curriculum vitae of the members of the Board of Directors is updated without delay and is kept posted throughout the term of office of each member.

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  1. The BoD may, only and exclusively in writing, assign the exercise of all its powers and duties, save these requiring a collective action, as well as the representation of the company to one or more persons, members of the BoD, managers and employees of the company or third parties, by specifying at the same time the scope of such assignment as well. All these persons may, as long as it is provided by the relevant resolution of the BoD, assign further the exercise of the powers entrusted to them or part of these powers to other members or third parties.

2.Constitution and Convocation of the BoD

  1. The BoD elects one of the Directors as Chairman and may designate up to two (2) other Directors as Vice Chairmen.
  2. The Chairman of the BoD chairs its meetings and exercises the responsibilities provided by law and the articles of association. When the Chairman is absent or hindered, he shall be replaced by the appointed for this purpose Vice Chairman.
  3. In case the BoD, by way of derogation from par. 1, of article 8 of law 4706/2020 appoints as Chairman one of the executive members of the BoD, it obligatorily appoints a vice-chairman from the non-executive members.
  4. The BoD elects a Member as the Chief Executive Officer of the Company. The Chief Executive Officer and the Chairman may be the same person.

Chairman of the BoD

The Chairman of the BoD (in addition to his duties, which stem from his capacity as executive member of the BoD and as legal representative of the Company) coordinates and directs the meetings and the general operation of the BoD. Chairman of the BoD, has the responsibility of convening the BoD in a meeting, setting the agenda, ensuring the good organization of the work of the BoD, but also the effective conduct of its meetings. It is also the responsibility of the Chairman to ensure the timely and correct information of the members of the BoD, as well as his effective communication with all shareholders, with a view to fair and equal treatment of the interests of all shareholders.

Vice Chairman of the BoD

In case of temporary absence or impediment of the Executive member and Chairman of the BoD, the Vice Chairman of the BoD convenes and chairs the meetings, ratifies the minutes, as well as issues the official copies and extracts of his minutes.

Chief Executive Officer

The Chief Executive Officer in collaboration with the Executive Chairman of the BoD monitors and controls the implementation of the strategic objectives of the Company and the management of the affairs (day-to-day management) of the Company and draws up the guidelines of the Company. Supervises and ensures its smooth, orderly and efficient operation, in accordance with the strategic objectives, business plans and action plan, as determined by decisions of the BoD and the GA. The BoD of the Company may elect Deputies and Assistants of the Chief Executive Officer, whose responsibilities may relate to the responsibilities and jurisdictions of the Chief Executive Officer as well as the coordination and supervision of the individual organizational units of the Company.

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Convocation of the BoD

  1. The BoD should meet any time provided by law, the articles of association or required under the needs of the company.
  2. Meetings of the BoD shall convene within the Municipality of the registered office of the Company or alternatively within the prefecture of the Municipality of the registered office of the Athens Exchange. Alternatively, meetings of the BoD may convene in Mainland China or Hong Kong.
  3. The BoD may duly meet at another place out of the seat of the company, located either in Greece or abroad, provided that in this meeting all the members of the BoD are present or represented, and no member objects to the execution of the meeting and to the adoption of resolutions.
  4. The invitation to the members of the BoD may provide that the meeting of the BoD will take place through conference call for some or for all members. In this case, the invitation addressed to the members of the BoD includes the necessary information and technical instructions about their participation in the meeting.
  5. The BoD is convened by the Chairman or Vice Chairman who chairs its meetings, upon invitation notified to its members at least two (2) working days prior to the meeting, and at least five (5) working days if the meeting is going to be held in a location outside the seat of the company.In the invitation the issues of the daily agenda must be stated clearly, otherwise the adoption of resolutions is permitted only if present or represented are all the members of the BoD and none objects to the adoption of resolutions.

Corporate Secretary

The Board of Directors appoints a Corporate Secretary. The Corporate Secretary is in charge of keeping the minutes of the meetings of the Board of Directors and its Committees. The responsibilities of the Corporate Secretary include ensuring a good flow of information between the Board of Directors and its Committees, as well as between the top management and the Board of Directors. The Corporate Secretary formulates the introductory information program of the members of the Board of Directors, immediately after the beginning of their term of office and their continuous information and training on issues concerning the Company.

Decision making

a. The Board of Directors is quorum and meets validly, when more than one of the directors is present or represented in this half, but the number of present or represented directors can never be less than six (6).
b. In the meetings of the Board of Directors that have as subject the Company’s financial statements approval or include issues for the approval of which the decision of the general assembly is foreseen with increased quorum and majority, according to law 4548/2018, the Board of Directors is in quorum when at least two (2) independent non-executive members are present.
c. The decisions of the Board of Directors are validly taken by an absolute majority of the members present and represented, while in case of a tie, the vote of the Chairman prevails
d. Each consultant may validly represent only one other consultant.
e. Representation on the Board of Directors may not be assigned to persons who are not members of the Board of Directors.

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3. Number of meetings of the BoD, frequency of participation of each member and major issues dealt with by the BoD

In 2025, thirteen (13) meetings of the BoD took place. In particular, the table below shows the number of meetings attended by the members of the BoD.

Name BoD position Gender Number of BoD meetings within 2025, during the BoD Member term of office Percentage of participation or representation in BoD meetings Date of commencement of term office or re- election End of term of office
Lin Ji* BoD Chairman, Executive Member M 9 100% 08/07/2025 07/11/2025
Han Chao* BoD Chairman, Executive Member M 4 100% 07/11/2025 08/07/2027
Su Xudong CEO, Executive Member M 13 100% 08/07/2025 08/07/2027
Li Jin CFO, Executive Member F 13 100% 08/07/2025 08/07/2027
Zhu Changyu BoD Vice Chairman, Non Executive Member M 12 92% 08/07/2025 08/07/2027
Yu Tao** Non Executive Member F 6 100% 02/08/2023 08/07/2025
Zhang Xueyan** Non Executive Member F 7 100% 08/07/2025 08/07/2027
Kwong Che Keung Gordon*** Independent, Non Executive Member M 6 100% 02/08/2023 08/07/2025
Zhou Zhonghui*** M 7 100% 08/07/2025 08/07/2027
Arvanitis Nikolaos*** Independent, Non Executive Member M 6 100% 02/08/2023 08/07/2025

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Name BoD position Gender Number of BoD meetings within 2025, during the BoD Member term of office Percentage of participation or representation in BoD meetings Date of commencement of term office or re- election End of term of office
Lin Lan*** Independent, Non Executive Member M 7 100% 08/07/2025 08/07/2027
Moralis Ioannis*** Independent, Non Executive Member M 5 83% 02/08/2023 08/07/2025
Zarakeli Adriana*** Independent, Non Executive Member F 7 100% 08/07/2025 08/07/2027
Giourelis Stefanos**** Non Executive Member M 1 100% 24/01/2025 13/03/2025
Politis Dimitrios**** Non Executive Member M 12 100% 13/03/2025 08/07/2027
  • Mr. LIN Ji served as executive Chairman of the Board until 07.11.2025, date on which Mr. Han Chao assumed the duties of executive Chairman.
    ** Ms. YU Tao served as a non-executive member of the Board until 08.07.2025, date on which Ms. Zhang Xueyan assumed the duties of non-executive member of the Board.
    *** Messrs. Kwong Che Keung Gordon, Arvanitis Nikolaos, Moralis Ioannis served as independent non- executive members of the Board until 08.07.2025, date on which Messrs. Zhou Zhonghui, Lin Lan, Zarakeli Andriana assumed the duties of independent non-executive member of the Board.
    *** Mr. Politis Dimitrios served as a non-executive member of the BoD from 01.01.2025 to 24.01.2025 and from 13.03.2025 onwards, while in the interval from 24.01.2025 to 13.03.2025 the above duties were performed by Mr. Giourelis Stefanos.

The main issues discussed at the BoD’ meetings during the 2025 financial year:
* Approval of the Annual Financial Report.
* Submission of a proposal to the GA of PPA SA Shareholders for the distribution of profits (dividend).
* Submission of proposal to the GA for the approval of the Remuneration Report.
* Approval of the Annual Budget.
* Approval of the Annual Donations and Sponsorships Plan
* Approval of the Annual Investment and Asset Disposal Plan
* Approval of the Annual Activity Report of the Audit Committee
* Approval of the Annual Activity Report of the Remuneration Committee
* Approval of the Annual Activity Report of the Nominations Committee
* Approval of the results of the Evaluation Process: a) of the Board of Directors of PPA SA and b) of its Committees

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  • Risk Management Annual Report
  • Approval of PPA S.A. Risk Appetite Statement.
  • Approval of the Contract Conclusion Regulation
  • Submission of a proposal for approval by the Ordinary General Meeting of PPA SA Shareholders (following a relevant proposal by the Nominations Committee), of the election of the new Board of Directors due to the expiration of its term of office
  • Approval of updated Company’s Internal Organization and Operation Regulation (IOOR)
  • Approval of the Company's Strategic Business Plan
  • Approval of: the Operating Regulations of the Risk Management Unit
  • Approval of the Risk Management Unit Policy, Methodology & Procedures
  • Approval of the "Policy Suitability-Eligibility" of the Members of the Board of Directors
  • Approval of the "Policy Diversity" of the Members of the Board of Directors
  • Early Retirement Incentives Plan implementation to PPA SA personnel.
  • Conclusion of a service contract between PPA SA and COSCO SHIPPING TECHNOLOGY (BEIJING) CO., LTD
  • Conclusion of a service contract between PPA SA and COSCO SHIPPING GLOBAL EXHIBITION SERVICES BEIJING Co Ltd
  • Conclusion of a service contract between PPA SA and COSCO Shipping Specialized Carriers Co., Ltd .
  • In the last three cases, the approval procedures of the above contracts were followed, in accordance with article 100 par. 1 of Law 4548/2018.

4. CV’s of members of the BoD and Deputies

CEO CV’s of the BoD members

Below are presented the CV’s of the members of the BoD members pursuant to the provision of Article 18 of Law 4706/2020 which can are available on the web page of the Company, at the link https://www.olp.gr/en/about-us/corporate-governance/board-of-directors.

Mr. LIN Ji, Chairman of BoD, Executive BoD member (expiration of term of service 07.11.2025)

Mr. Lin Ji has extensive international professional experience in management - strategic planning – organization of port industry and maritime sector affairs in general. Mr. LIN JI, is Executive Vice President of China COSCO SHIPPING Corporation Limited and he has also served in various senior management positions such as:
* Deputy Director of the Secretariat of the Presidential Affairs Department of China Ocean Shipping (Group) Company,
* Deputy Director of the Research Center of the Advisory Office of the President's Affairs Department of China Ocean Shipping (Group) Company,
* Director of China Ocean Shipping (Group) Company,

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  • General Manager of COSCO Africa Limited,
  • General Manager of Xiamen Ocean Shipping Company
  • President of COSCO Europe Limited,
  • President of COSCO Shipping (Europe) Co., Ltd.

Mr. HAN Chao, Chairman of BoD, Executive BoD member (launching of term of service 07.11.2025)

Mr. HAN Chao is Chairman of Board of Directors of the Piraeus Port Authority S.A since 07.11.2025.Mr. HAN Chao has extensive professional experience in administration, human resources management, and the overall organization of maritime sector affairs. Throughout his thirty-year career, he has served in major maritime industry companies, including COSCO Container Lines Company, Shanghai Ocean Shipping Company, Xiamen Ocean Shipping Company, China Shipping International Ship Management Company, and COSCO Shipping Seafarer Management Company, holding various senior managerial and leadership positions up to the level of General Manager and Chairman. He also engaged actively in the academic field, serving as Executive Vice President of the Corporate University of China COSCO Shipping Corporation and President of the COSCO Shipping Talent Development Institute, where he led initiatives to cultivate the next generation of maritime industry leaders. Mr. HAN Chao graduated from Shanghai Maritime University, where he earned a Bachelor’s degree in Engineering in Marine Engineering Management and a Master’s degree in Engineering in Transportation Engineering.

Mr. SU Xudong, CEO, Executive BoD member

Mr. Su Xudong, appointed on 29 April 2024 as a member of the Board of Directors of the Port of Piraeus S.A. and currently serving as CEO.He has extensive international experience in information technology, port operations, shipping, and logistics, having previously served in several senior management roles, including Deputy General Manager of IT Development at COSCO Container Lines, General Manager of COSCO (Belgium) Co., Ltd., General Manager of COSCO SHIPPING Lines (Belgium), General Manager of COSCO SHIPPING Lines (Greece), and holds the position of deputy CEO at COSCO Shipping (Europe) Co., Ltd while concurrently managing COSCO SHIPPING Lines (Greece) and Ocean Rail Logistics. He holds a degree in Applied Informatics from Shanghai Maritime University.

Mr. Zhu Changyu, Vice Chairman of BoD, Non Executive BoD member

Mr. Zhu Changyu is a member and Vice Chairman of Board of Directors of the Piraeus Port Authority SA. since 03.05.2023. Mr. Zhu is a director and president of COSCO SHIPPING (Hong Kong) Co., Limited. He is also executive director, chairman and managing director of COSCO SHIPPING International (Hong Kong) Co., Ltd. and a non-executive director of Piraeus Port Authority S.A.. He had been the head and division chief (handling division duty) of Planning Division, the deputy manager of Marketing Division of China Shipping Group International Trade Co., Ltd., the manager of Procurement Division and the assistant to general manager of Shenzhen China Shipping Haisheng Asphalt Co., Ltd., the manager of Comprehensive Trade Division of China Shipping Group International Trade Co., Ltd., the manager of Development and Research Division, the manager of Investment Management Division and the assistant to general manager of China Shipping Page 42 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise) Group Investment Co., Ltd., the deputy supervisor of Research Office, the senior manager of Secretarial Office of Executive Division, the deputy general manager of Strategic Development Division of China Shipping (Group) Company, the deputy supervisor of Integration Management Office, the general manager of Strategy & Corporate Management Division and the supervisor of Deepening Reform Office of China COSCO Shipping Corporation Limited. He has extensive experience in strategic planning, capital operation, corporate governance, integration and reorganization. He graduated from Shanghai Maritime College (now known as Shanghai Maritime University), majoring in Transportation Management Engineering and obtained a Master’s degree. He is a senior economist.

Ms. LI Jin, CFO, Executive BoD member

Ms. Li Jin, serves since May 2020 till today as a Deputy Chief Executive Officer and Chief Financial Officer of PPA SA while since 17.07.2021 she is an executive member of the Board of Directors of the Company. Ms. LI has 30 years’ professional experience and throughout her career professional served COSCO Ocean Shipping, China COSCO Holding and COSCO Shipping in various Financial Managerial positions up to the General Manager of Finance Division level and she has international working experience by serving COSCO Shipping Group, In Oceania and Europe. Ms. LI got the senior accountant qualification certificate and senior economist qualification certificate in 2008, and became a Certified management accountant in 2015. Ms. LI participated in “the National Accounting Leading Talents training project” which was organized by Ministry of Finance of the People’s Republic of China from 2012 to 2019 and in “the special training course for international talents” which was organized by China COSCO Shipping Group in 2019. Ms. LI graduated from Capital University of Economics and Business and holds a bachelor’s degree in International Credit and Investment and a Master’s Degree in Finance from Central University of Finance and Economics.

Mr. Kwong Che Keung Gordon, Independent Non Executive BoD member (expiration of term of service 08.07.2025)

Mr.Kwong has been the Independent Non-executive Director of the COSCO SHIPPING INTERNATIONAL (HONG KONG) CO., LTD since July 2020. Mr. Kwong is also independent non executive director of a number of listed companies in Hong Kong, namely, Agile Group Holdings Limited, Chow Tai Fook Jewellery Group Limited, FSE Lifestyle Services Group Limited, Henderson Investment Limited, Henderson Land Development Company Limited. Mr. Kwong graduated from The University of Hong Kong with a bachelor’s degree in social sciences in 1972 and is a fellow member of the Institute of Chartered Accountants in England and Wales and the Hong Kong Institute of Certified Public Accountants respectively. Mr. Kwong was a partner of international accounting firms from 1984 to 1998 and an independent member of the Hong Kong Stock Exchange Council from 1992 to 1997, during which he had also served as Chairman of both the Listing Committee and the Compliance Committee of the Hong Kong Stock Exchange. He has over 40 years of experience in accounting and auditing, as well as long experience in shipping industry. Page 43 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Mr. ZHOU Zhonghui, Independent Non Executive BoD member (launching of term of service 08.07.2025)

Mr. Zhou Zhong Hui is currently the Managing Director of China Appraisal Society. He is also an Independent Non-Executive Director of CloudWalk Technology Co. Ltd. Previously, he held various Independent Non-Executive Director positions in companies such as CITIC Securities Co. Ltd., China Pacific Insurance (Group) Co., Ltd. and COSCO SHIPPING Holdings Co. Ltd. He also served as Chief Accountant, General Manager and Senior Partner of PricewaterhouseCoopers Zhong Tian LLP from 1992 to 2007. In addition, he served as a Professor at Shanghai University of Economics from 1989 to 1998. He holds a master’s degree and a doctorate in economics from Shanghai University of Economics and Finance. Mr. ZHOU is a senior member of the China Institute of Certified Public Accountants, a member of the Specialized Committee of Financial Directors of the China Association of Public Companies, and a member of the Advisory Committee of the China Appraisal Society since November 2010. He is a member of the International Advisory Committee of the China Securities Regulatory Commission, the Audit Regulation Committee of the China Institute of Certified Public Accountants.

Mr. Nikolaos Arvanitis, Independent Non Executive BoD member (expiration of term of service 08.07.2025)

He studied and participated in seminars in the Maritime Economics, in the Management and Organization of Shipping Companies and in Combined Transport. He has been graduated from BCA College of Athens, London School of Foreign Trade and City of London Polytechnic. He started his career in 1980 in London at FENTON STEAMSHIP CO, a subsidiary of Hellenic Lines LTD, and continued in Top Management positions in Piraeus at ZIM HELLAS SA 1984-2010 and at VISTA MARITIME & LOGISTICS LTD since 2010. He has participated since April 2000, as an elected member of the BoD of the International Maritime Union, (an institution representing the agencies of international shipping companies in Greece) and was elected President of the BoD for two consecutive terms Apr. 2006 - Mar- 2012. In June 2013 the International Maritime Union BoD unanimously named him as Honorary President. Due to his institutional role as President of the International Maritime Union, he participated in working committees and meetings on issues related to the Port Industry, Shipping Policy, Customs and Regulation Issues, in collaboration with the Ministry of Merchant Shipping & Island Policy, the General Secretariat of Ports Policy and Maritime Investments, the PPA SA and other Port Organizations, the PCT SA, the Customs Administration.

Mr. LIN Lan, Independent Non Executive BoD member (launching of term of service 08.07.2025)

Dr. Lin Lan started his professional career in 1993 as General Manager of (GCT) Canada. From 1995, he joined H.A. Simons Limited (now AMEC) as Director of Power System Software Development and from 2002, he held key management positions in Simons Limited (AMEC) and General Electric Power Systems. In 2002, he became Vice President of Guangdong Korun Electric Company. From 2006 to 2023, he served Hisense Group in many senior management positions such as Vice President, Director, General Manager, Senior Vice President and Chairman of the Group. Page 44 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise) Dr. Lin Lan, is a mechanical engineer, a graduate of North China Electric Power University, and holds master and PhD degrees from the University of Tennessee in Mechanical Engineering. During his career at Hisense Group, Dr. Lin Lan was responsible for Hisense’s international operations and promoted Hisense’s global layout, including the establishment of production bases in N. America, Europe, Mexico and Eastern Europe. In his official evaluation by Hisense, Dr. Lin Lan was recognized as “an active professional and key contributor of the Company’s internationalization strategy and a to the Company’s outstanding achievements in overseas expansion and layout.” He was awarded the title of Economic Person of the Year for 2022 in the "Influential People" list of China News Weekly.

Ms. Yu Tao, Non Executive BoD member (expiration of term of service 08.07.2025)

Ms.Yu Tao is economist (graduated from University of International Business and Economics) and she also holds a Master degree in Business Administration (Guanghua School of Management Peking University), while she has significant experience in the following areas:
* "International Transportation"
* "Business Administration"
* "Import/Export trade"
* "Logistics"
* "Shipping Lines Management"
* "Container Lines Management"

Ms. YU Tao has also served in various management positions (Deputy Chief Executive Officer) at COSCO Logistics Co., COSCO Container Lines Co., and COSCO SHIPPING Lines Co.

Ms. ZHANG Xueyan, Non Executive BoD member (launching of term of service 08.07.2025) Ms. Zhang Xueyan is currently a non-executive Director of COSCO SHIPPING Development Co, ltd. Ms. Zhang has served in roles including a deputy general manager of Capital Management & Operation Division of China COSCO Shipping Corporation Limited since December 2017 and has extensive experience in capital operation. She started her career in 1999 and since 2013, she has successively served as a deputy manager of the capital operation office of the Strategic Development Division of China Ocean Shipping Co. (listed on the Hong Kong Stock Exchange), Ltd. and COSCO SHIPPING Holdings Co., Ltd. (listed on the Shanghai Stock Exchange). She served as manager of capital operation office of the Capital Management & Operation Division and a deputy general manager of the Capital Management & Operation Division of China COSCO Shipping Corporation Limited. Ms. Zhang graduated from Beijing Normal University with a master’s degree in economics, majoring in international investment and international trade. She holds a professional title of senior economist and is a certified public accountant.

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Mr. Moralis Ioannis, Independent Non Executive BoD member (expiration of term of service 08.07.2025) Mr. Moralis Ioannis studied at the finance department of the University of Piraeus. Son of the late Minister Petros Moralis was always interest in citizenship and politics but without having actively joined a political party. He works since the age of 22 years old. For more than 20 years he was engaged in Piraeus both as a freelancer in the field of Sports Marketing and communication, as well as the strain Olympiacos FC having taken major positions of responsibility. In 2011 he was appointed Vice President and General Manager of Olympiacos FC. In 2012 he was elected Chairman of the Super League. Since 2014 is continuously elected Mayor of Piraeus.

Ms. ZARAKELI Adriana, Independent Non Executive BoD member (launching of term of service 08.07.2025) Ms. Zarakeli Adriana has been a twice-elected member of the Piraeus Municipal Council (since May 2019) and since September 2019, she has been appointed, as Vice Mayor for Extroversion, Tourism, and EU Funding Programs, responsible for the Extroversion, Communication, Promotion, and Tourism and Media Directorate, as well as for the Department for the Utilization of European Programs. Ms. Zarakeli began her career in 1996 working as an editor in printed media, as well as in various television and radio stations and undertaking roles of Head Editor and Newscaster and has ever since been serving journalism with undiminished interest through both radio and TV stations. Ms. Zarakeli holds a Master degree in Journalism and New Technologies from ΕCI - European Communication Institute, Donau Universität Krems - Austria, Athena Research and Innovation Centre, and National (Metsovian) Technical University of Athens, with expertise in the examination of the parameters that optimize the function of communication and journalism and emphasis on the possibilities of digital technology. Ms. Zarakeli has also obtained two specialization diplomas from National and Kapodistrian University of Athens in “Design and Management of European Programs’ and “Mix of Marketing and Brand.” Ms. Zarakeli is a member of the Journalist's Union of Athens Daily Newspapers (ESIEA) and the International Federation of Journalists (IFJ). She is the co-founder and managing director of PROTZECT LTD, a corporate communication, PR, & marketing agency and she fluently speaks English and German.

Mr. Giourelis stefanos, Non Executive BoD member, Growthfund Representative (launching of term of service 24.01.2025 - expiration of term of service 13.03.2025) Mr. Giourelis holds a Diploma from the School of Mining and Metallurgical Engineering of the National Technical University of Athens and has extensive international experience of over 25 years in the IT and technology sector. During his professional career, he has held leadership positions of increasing responsibility in the areas of strategic development, corporate governance, international sales and organizational management. For 19 years, he served in senior management positions at Hewlett-Packard, with geographical responsibility spanning Greece, the Middle East, the Mediterranean and Africa, based in Athens and subsequently in Dubai. He served as General Manager of Greece (4 years) and Managing Director of Greece and Africa (8 years), where he led multinational teams, managed complex business ecosystems and contributed to the strategic transformation and growth of the markets under his responsibility. He also served as Deputy Managing Director of the Superfund, actively participating in the formulation of strategic directions, the management of corporate holdings and the supervision of investment initiatives of national importance.

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Mr. Dimitris Politis, Non Executive BoD member, Growthfund Representative (Terms of service 01.01.2025 to 24.01.2025 and relaunching from 13.03.2025) Mr. Politis Dimitrios is a graduate of the American College of Greece and holds a postgraduate degree in International Business and Export Management from City University Business School, London. Since 1993, he has held positions of responsibility in international financial institutions. He began his career at HSBC Bank PLC, initially in Athens and later in London, in the Investment Banking Department covering Greece and the wider region of Southeastern Europe and the Middle East. He returned to Athens in 2001 as Head of the French Credit Commercial de France, while in 2003 he assumed the duties of Head of Corporate and Institutional Banking at HSBC Bank plc Greece. From 2012 to September 2020, he worked at Credit Suisse AG, based in Zurich, as Head of the Wealth Management- UHNWI Sector for Greece and Cyprus, while from October 2020 he took on the same role at EFG Bank AG, based in Zurich. From August 2021 to December 2024, he held the position of Managing Director at the Hellenic Republic Asset Development Fund S.A. (HRADF), while in March 2025 he was appointed as the Superfund representative on the Board of Directors of PPA S.A. Mr. Politis has particular experience in attracting and managing investments in strategic sectors of the economy and close professional relationships with international institutional and private investors, and since April 2025 he has assumed the position of advisor to the Prime Minister on investment matters.

Sanozidis Savvas - Corporate Secretary Mr. Sanozidis Savvas is a Transport Economist and serves as Corporate Secretary of PPA S.A. since December 2021. He has been Secretary to the Company’s Board of Directors since 2007 and has also served as Secretary to all Board Committees (Audit Committee, Remuneration Committee, Nomination Committee, and Strategy Committee) since their establishment. He holds a Bachelor’s degree in Economics from the University of Piraeus and an MSc in Transport Economics from the University of Leeds. He is a member of the Association of Greek Transportation Engineers and brings professional experience in financial consulting services for transportation and infrastructure projects in Greece and abroad, and keeps a long-standing track record and expertise in corporate secretariat services and board governance support.

CV’s of Deputies CEO

Captain Jin Beiyuan has ten years’ officer experience on Ocean Going Ship from 1991-2002. Since then he has served for China Shipping Container Line as planner and operator, General Manager of China Shipping Europe Holding operator and planner department, General Manager of China Shipping (France) Agency, Vice General Manager of China Shipping Car Carrier Company Limited, and General Manager of Guangzhou Cosco Shipping Car Carrier company limited. He now serves as Deputy CEO in Piraeus Port Authority (since 2022).

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Mr. QU Shengbin is a Senior Economist and holds a University Degree and an MSc in Transportation Planning and Management. He has two decades of work experience in the shipping and logistics industry. He joined the COSCO family initially working and gaining extensive business experience, covering a wide range of fields such as shipping agent, cargo forwarder, air cargo transport, project logistics, project management, etc.. He then enriched his company management experience, serving as top management member in COSCO Logistics ShenZhen, KunMing, GuangXi and PENAVICO FangCheng. Furthermore, Mr. Qu was appointed to upper managerial positions in COSCO SHIPPING headquarters, in both the Operation Management Division and the Strategic and Corporate Management Division. He now serves as Deputy CEO in Piraeus Port Authority (since 2022). Mr.Chen Dong is a senior port and terminal management executive with over 30 years of experience in shipping, port operations, safety management and corporate governance within COSCO Group (such as COSCO Shipping Ports Limited) and its affiliated companies (such as Lianyungang New Orient International Container Terminal Co., Lianyungang COSCO Container Transport Co.,). He has proven experience in terminal operations, safety systems, performance evaluation, engineering and innovation management. He is a graduate of the Department of Economics of Jiangsu University, specializing in foreign trade and international economics, and holds a Master's degree in Business Administration from Dalian Maritime University. In July 2025 he was assigned Deputy CEO duties of PPA S.A. Mr. Angelos Karakostas joined COSCO SHIPPING Lines (Greece) S.A. in 1997 as General Manager. In 2009, he was appointed Deputy General Manager of the Piraeus Container Station (PCT SA). In August 2016, he took over the duties of Deputy CEO of the Port of Piraeus SA. He holds a degree in Mathematics and a postgraduate degree in Business Research from the University of Patras. He holds an MBA and an MSc in Management from Teeside University of the United Kingdom. Mr. Panagiotis Tsonis is a graduate of the Department of Civil Engineering of the Polytechnic School of the University of Patras and holds a master's degree in the Organization and Administration of Public Services, Public Organizations & Enterprises of the University of Peloponnese. He has many years of experience as a Civil Engineer and has served in leadership positions in organizations in both the private (construction companies) and public sectors. In the period 2019-2023, he held the position of CEO of the Patras Port Authority. He has been vice-president of the Delegation of the Technical Chamber of Greece, President of the Association of Civil Engineers of Achaia and member of the governing committee of the Technical Chamber of Greece/TDE, while he is a member of the ELOT/TE 20 Technical Committee and of the National Accreditation Council. In July 2023 he was assigned Deputy CEO duties of PPA S.A. From the above Members of the BoD and Company Executives Mr. Angelos Karakostas on 31/12/2023 held 1559 shares of PPA S.A. For the fiscal year 01.01.2024-31.12.2024, the compensations paid to the BoD members are those provided in the current Remuneration Policy and as has been approved by GA of Shareholders decision (gross annual compensation for each BoD member of the amount of € 40,000.00 as well as gross annual maximum total amount for the independent members of the BoD and the FUND representative, for their participation in the meetings of the BoD Committees (Audit - Remuneration - Nominations Committees), regardless of the total number of Committees in which they participate, amounting to € 20,000.00.

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It is to be noted that in 2024, the Company prepared the members of the BoD remuneration report for fiscal year 01.01.2023-31.12.2023 in accordance with article 112 of Law 4548/2018. The remuneration report for the fiscal year 01.01.2023-31.12.2023 is available on the Company's website: https://www.olp.gr/en/about-us/corporate-governance/board-of-directors.

CV’s of other Senior Staff

Tsomakos Nikolaos - Manager of Internal Audit

Mr. Tsomakos Nikolaos serves as Head of the Internal Audit Department of PPA S.A. since April 2024. He holds a bachelor’s degree in business administration from the University of Piraeus and possesses the professional certifications CIA (Certified Internal Auditor) and CCSA (Certification in Control Self-Assessment) awarded by the Global Institute of Internal Auditors, along with Postgraduate degree from Cornell University. He is a member of committees of the Hellenic Institute of Internal Auditors and is registered in the Internal Auditors Registry of the Economic Chamber of Greece. He has professional experience in financial management and external audit roles and has served for many years as Head of Internal Audit in companies across various sectors.

Palia Afroditi - Regulatory Compliance Manager

Ms. Palia Afroditi, Attorney-at-Law at the Supreme Court, serves as Regulatory Compliance Manager of PPA S.A. since January 2024. She holds a bachelor’s degree in Law from the Law School of the National and Kapodistrian University of Athens and a postgraduate Degree (MSc) in Banking and Financial Law from the University of Piraeus and possesses a professional certification as a Certified Compliance Officer awarded by TUV AUSTRIA HELLAS. She is a member of the Athens Bar Association (A.B.A.) and member of the Association of Compliance Officers in Greece (ASCO). She has extensive professional experience in positions of legal counsel to Societe Anonyms companies, specializing in the areas of Corporate Law, Capital Market Law and Corporate Governance Law.

Tsakalogiannis Christos - Risk Management Manager

Mr. Tsakalogiannis Christos has served as the Risk Management Manager of PPA S.A. since July 2021. He holds a Bachelor’s degree in International & European Studies and an MBA with a specialization in the Financial Sector from the University of Hertfordshire (UK). In September 2023, he earned the prestigious COSO ERM (Committee of Sponsoring Organizations— Enterprise Risk Management) certification. He has an extensive background in financial management and stock markets, previously served for many years as the Head of various investment institutions, where he developed deep expertise in financial risk.

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5.Assertion of compliance with independence criteria for Independent BoD members (par. 3 article 9 of Law 4706/2020)

The BoD, following a relevant recommendation of the Nominations Committee, taking into account paragraph 3 of article 9 of Law 4706/2020, pursuant to which the fulfillment of the conditions for the classification of a member of the Board of Directors as an independent member is reviewed by the Board of Directors at least annually, per financial year, ascertained (BoD resolution no 42/2025, meeting of 10th of June 2025) that each of the three (3) independent members (a) ZHOU Zhonghui, (b) LIN Lan, (c) Zarakeli Andriana, at the time of their appointment met all suitability and reliability criteria included in the Suitability Policy, for their election as members of the Company's BoD, and the conditions of independence defined in article 9 par. 1 and 2 of law 4706/2020, as in force, as well as that there are no obstacles or incompatibility in the face of any Candidate in relation to any relevant provisions, including the Corporate Governance Code (HCGC) applied by the Company and the Rules of Operation of the Company. In particular, none of the above, directly or indirectly held a percentage of voting rights greater than zero-point five percent (0.5%) of the share capital of the Company and each of them was free from financial, business, family or other dependent relationships, which may influence their decisions and their independent and objective judgment. Furthermore, from the performed audit and from the relevant personal declarations submitted by each of the above independent members, it had been confirmed that, apart from the criteria of par. 1 of article 9 of Law 4706/2020, as in force, the indicative dependence criteria of par. 2 of article 9 of Law 4706/2020, as in force, are not met either, as each of the above proposed independent members:
a) Did not receive any significant remuneration or benefit from the Company, or from a company affiliated with it, nor participated in a stock options scheme or in any other remuneration or benefit system related to the performance, other than the fee for their participation in the BoD or its committees, nor participates in the collection of fixed benefits under the pension system, including deferred benefits, for previous services to the Company.
b) Had neither the same nor a person, who had close ties with it, a business relationship during the last three (3) financial years before their appointment with:
ba) the Company or
bb) a person affiliated with the Company or
bc) a shareholder who directly or indirectly held a participation percentage equal to or greater than ten percent (10%) of the share capital of the Company during the last three (3) financial years before their appointment, or a company affiliated with them, if this relationship affected the business activity of either the Company or the candidate independent non-executive member of the BoD of the Company or the person who had close ties with them.
c) Had neither the same nor a person who had close ties with it had:
c1) served as member of the BoD of the Company or any company affiliated thereto for more than nine (9) financial years in total at the time of their election,
c2) been an executive or maintained an employment or contractor or services provision relationship or a paid mandate with the Company or with a company affiliated with it during the last three (3) financial years prior to its appointment,
c3) a second degree kinship by blood or by marriage, or is a spouse or partner equated with a spouse, member of the BoD or senior executive or shareholder, with a participation percentage equal to or greater than ten percent (10%) of the share capital of the Company or a company affiliated with it,
c4) been appointed by a certain shareholder of the Company, in accordance with the articles of association, as provided in article 79 of law 4548/2018,
c5) been nominated as represented of shareholders who directly or indirectly hold a percentage equal to or greater than five percent(5%) of the voting rights at the GA of the Company's shareholders during his/her term of office, without written instructions, c6) conducted a mandatory audit of the Company or a company affiliated with it, either through a company or himself or a second-degree relative by blood or by marriage of him/her or his/her spouse, during the last three (3) financial years prior to his/her appointment, c7) been assigned as an executive member in another company, in the BoD of which an executive member of the Company participates as a non-executive member.

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The fulfillment of the independence criteria of the Independent Non-Executive Members of the Board of Directors, in accordance with the provisions of the law, was re-evaluated, for a second time within 2025, at a meeting of the Nomination Committee (Dec 2025) and relevant information was provided to the BoD, which in turn proceeded to a relevant determination of fulfillment of the independence criteria of its Independent Non-Executive Members (BoD resolution no. 86/2025, meeting of December 17 th , 2025).

6. Suitability Policy of the BoD Members

The Company has adopted and implements a Policy for the Suitability Assessment of the Members of the BoD (Suitability Policy), which has been approved by decision of the GA of 02.08.2023, following BoD recommendation by its resolution dated 22.12.2022, and constitutes the set of principles and criteria that apply when selecting, replacing, and re-appointing Board members, in terms of assessing their suitability on an individual and collective level. This Policy aims to ensure the quality of recruitment to the Board, its effective functioning and fulfilment of its role, based on the Company’s general strategy and medium and long -term business goals for promoting its corporate interest.

The Suitability Policy of the Members of the BoD is posted on the Company’s website at the following address: https://www.olp.gr/en/about-us/corporate-governance/policies.

The Eligibility/Suitability Policy aims to ensure that;
a) the BoD is staffed with sufficient number of members and a suitable composition;
b) the BoD is staffed with persons of morality and reputation;
c) the members of the BoD have the skills and experience required based on the duties they undertake and their role on the BoD, while at the same time they have sufficient time to perform their duties;
d) in the selection, renewal of the term of office and replacement of a member, the evaluation of individual and collective suitability is taken into consideration;
e) the Eligibility/Suitability Policy stipulates that the candidate members of the BoD know, among other things, as much as possible, before taking the position, the culture, the values and the general strategy of the Company.

The suitability of the BoD members is assessed both on an individual and a collective level. Individual suitability means that a person is considered to have - as a Board member - sufficient knowledge, skills, experience, independence of mind, good repute and moral standing for the performance of their duties as a member of the Company’ s BoD, for which performance of duties he/she shall also commit sufficient time, pursuant to the said Policy, which establishes specific criteria for the assessment of all above factors. Collective suitability means that the Board collectively should be suitable for carrying out its responsibilities and should be composed in such manner as to contribute to the effective management of the Company and to balanced decision-making. BoD members should collectively be able to take appropriate decisions taking into account the business model, risk-taking, strategy and markets in which the Company operates. Also, the members of the BoD collectively are able to effectively monitor and critique the decisions of senior management.

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All areas of knowledge required for the business activities of the Company are recommended to be covered by the Board collectively with sufficient expertise among its members. It is recommended that there be a sufficient number of knowledgeable members in each area to be able to discuss the decisions to be taken. The Bod members collectively have the necessary skills to present their views. The composition of the BoD reflects the knowledge, skills and experience required to carry out his / her responsibilities. The BoD in its executive function should benefit from a high level of managerial skills as a whole; whereas in its supervisory function the BoD should avail itself of sufficient management skills as a whole in order to organize its work efficiently and be able to understand and process the proposals for respective decisions. In this context, the BoD as a whole adequately understands the areas for which members are collectively responsible and to have the necessary skills to exercise the actual management and supervision of the Company, including in terms of:
- its business and the main risks associated with it,
- strategic planning,
- financial reports,
- compliance with the legislative and regulatory framework,
- understanding corporate governance issues,
- the ability to identify and manage risks,
- the impact of technology on its activity,
- adequate gender representation.

In compliance with Law 5178/2025 and in particular with the provisions concerning the balanced representation of genders on the Board of Directors, it is necessary to update the Company's regulatory framework and specifically the "Suitability and Eligibility Policy of the Members of the Board of Directors". The new law provides for an increase in the minimum percentage of representation of the underrepresented gender on the Board of Directors from 25% to 33%, further strengthening the principles of equality, diversity and inclusion in the administrative operation of companies. This change requires its respective incorporation into the approved Regulations of the Company, so that they are fully aligned with the current institutional and regulatory framework. The Company's Board of Directors, with the resolution no. 77/2025, of December 17th, 2025, approved the update of the "Suitability-Eligibility Policy" of its Members (which will be submitted for approval by the upcoming Ordinary General Assembly of Shareholders), in order to explicitly include this specific quantitative parameter in the said policy.

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7. Fulfillment of the conditions and requirements of the legislative and regulatory provisions regarding the balanced representation of genders on the Board of Directors

The table below presents the percentage of women among all members of the Board of Directors, among Executive members, among non-Executive members and among independent members.

Data on gender representation in the Board of Directors

Total members Male members Female members Underrepresented gender percentage
Members 9 6 3 33%
Executive members 3 2 1 33%
Non-executive members 6 4 2 33%
Independent non-executive members 3 2 1 33%

As it turns out, the Company already fully complies with the provisions of article 3A par. 3 and 4 of Law 4706/2020, which was introduced by Law 5178/2025, with effect from 30.06.2026, as the participation of the underrepresented gender in the Company's Board of Directors, due to its size, is not less than thirty- three percent (33%) for all four indicators in the above table.

The Company recognizes that compliance with the relevant provisions on balanced gender representation in the Board of Directors, in addition to being a legal obligation, is also an indicator of sound corporate governance and is committed, as a leading Company in its sector of activity, to remaining committed to its principles of eliminating any type of exclusion or unfair treatment based on gender.

Measures implemented by the company to improve gender balance representation on the Board of Directors

Despite the provisions (Articles 3A par (3), (4), and (5) and 3B of Law 4706/2020, as applicable) coming into force on June 30, 2026, the already Company's compliance as from this very present moment, confirms both its constant vigilance in ensuring, through continuous review and implementation of the necessary measures, its timely compliance with the legislative and regulatory framework, with the aim of its lawful and smooth operation, as well as its willingness to adopt best corporate practices.

Indicative, but not restrictive, are mentioned:
* Representation in executive positions: Since July 2021, the underrepresented gender has been represented by 33% of the executive members of the Board of Directors, in order to ensure balance in decision-making.
* Promotion of women to positions of responsibility: Despite the particular nature of the port industry in which the Company operates and given that the overwhelming majority of its workforce is employed in labor-intensive activities (dockworkers, crane and forklift operators, truck drivers, manual services staff, etc.), the participation of women in all management positions in the Company amounted to 36.5% on 31 December 2025.Page 53 από 437
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  • Continuous monitoring and compliance: The composition of the Board of Directors is assessed annually by an external consultant (a relevant report is included in the corporate governance statement of the Annual Financial Report) to ensure that the percentage of the underrepresented gender remains within or, ideally, exceeds the limits set by law.
  • Training: Training executives on gender equality, discrimination prevention, and fair selection enhances the effectiveness of the practice followed and contributes to changing mindsets, avoiding unconscious biases, and promoting balanced representation.
  • Integration into corporate governance: Promoting balanced gender representation is not a stand-alone action, but is integrated into the company's governance policies, strategy, and internal procedures, such as the Company's Suitability Policy and Diversity Policy.

Conclusion

The Company fully complies with the obligations of Article 3A of Law 4706/2020, as applicable. It constantly strives to improve balanced representation through the above measures and ensures the continuous monitoring and adjustment of its policies. On the above, the Company drafted a special annual report in accordance with the provisions of paragraph 1 of article 3C of Law 4706/2020, which was added by article 7 of Law 5178/2025 as well as in accordance with the letter no. prot. 12678/8.9.2025 of the General Secretariat for Equality and Human Rights of the Ministry of Cohesion and Family. The report is posted on the Company's website and was communicated within the prescribed deadline to the following competent bodies:
a) to the Capital Market Commission, as the competent body for the supervision of listed companies and specifically for compliance with the obligations of articles 3A, 3B and 3C of Law 4706/2020, as in force,
b) to the "Documentation, Research and Digital Support Department (Observatory)" of the General Secretariat for Equality and Human Rights of the Ministry of Social Cohesion and Family and
c) to the "Ombudsman".

8. Training Policy for BoD Members and company Executives

The primary obligation and duty of the BoD is to oversee the functions of the Company and ensure the continuous pursuit of strengthening the long-term financial value of the company and the defense of the general Corporate interest. The Training Policy aims at providing Orientation & Training programs to be offered to the BoD members and other Company Executives (particularly those involved in internal control, risk management, regulatory compliance and information systems). It aims at building leadership qualities and providing a platform to share the knowledge, skills and experience gained by the BoD members and other Company Executives.

The Company invests on the education of BoD members and other Company Executives, with their individual areas of expertise on an ongoing basis, since the attendance of regular training programmes and organization of regular in-house or external trainings will enable them:
* to discharge their roles and responsibilities in a most effective manner.

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  • to empower and equip the BoD and its Committees with skills and attitudes required to perform their challenging tasks and play their role manner as per the best corporate governance practices.
  • to promote better understanding of professional requirements within the socio-economic and political environment in which Company is operating.
  • to promote an environment conducive to learning and development by serving as a role model for all the other employees in the corporation.

Within 2025, the BoD Members attended for the fourth year in a row a training seminar of the Hellenic Corporate Governance Council, with the aim of improving skills and a better understanding of corporate governance issues. The Company also shall ensure:
* on the one hand, that upon taking up their duties all BoD members are provided with a full induction programme, and on the other hand, that all BoD members update their skills and knowledge on an ongoing basis, in order to effectively fulfil their duties as members of the BoD and its committees, subject to continuous training by the Company for this purpose, in accordance with the provisions of the Training Policy.

9. BoD and Committee Evaluation Process – Results of Evaluation Process

In compliance with the provisions of Law 4706/2020, Circular 60 of the Capital Market Commission, the Hellenic Code of Corporate Governance and the Internal Operating Regulations of the BoD, the Company commissioned for third consecutive year, the assessment of the adequacy and effectiveness of the BoD and its Committees to an external consultant. The BoD Assessment Policy and the BoD Operation Regulation provides for the annual evaluation of the effectiveness of the BoD (as a collective body), its committees and their individual members, while this evaluation is provided by an external consultant every three years. To this end, as mentioned above, the Company awarded to the company KPMG Single Member Societe Anonyme for the Provision of Advisory Services to carry out the evaluation process. The evaluation concerned the collective abilities of the BoD as a body, its committees and the individual abilities of its members. The evaluation was carried out using evaluation tools provided by the external advisor (filling out an electronic questionnaire, etc.) and through personal interviews. The evaluator had access to the BoD’s and BoD’s Committees operating details. The purpose of the evaluation was to determine whether the Board and its Committees function effectively and efficiently, based on the Board Directors’ responses to the online questionnaires covering a wide range of topics, documentation review and selected interviews with Board Directors.

The conclusion of the above evaluation states, among other things, the following based on the Evaluation of the BoD as a Body and its Committees, as of 18th of March 2026:
* No significant weaknesses have been identified in the performance of the Board, its Committees, or individual Board members. Furthermore, there are no immediate corrective actions required under the current legislative and regulatory framework.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

  • The Board’s performance remains stable, operating effectively, while, also, fostering an environment that encourages open and constructive discussions, where all Board Directors feel confident in expressing their views.
  • The Board Committees (Audit Committee, Nomination Committee, Remuneration Committee) are functioning effectively, with each contributing significantly to the overall governance and decision-making processes of the Board, with the Nomination Committee demonstrating a strong contribution to the Board’s operations.
  • In respect to the individual evaluation of each Board member, all Board members perform their duties effectively and demonstrate commitment to their role, as does the Chairperson of the Board. The Board has taken proactive steps to develop a long-term strategic plan, enhancing alignment with the Company’s broader business objectives.

The above result is a confirmation of both the proper functioning of the BoD and its compliance with the current legislative and regulatory framework.

Independently of the assessment of the adequacy and effectiveness of the BoD and its Committees by an external consultant, in the context of the obligations set out in article 1.13 of the Hellenic Corporate Governance Code, was conducted the annual collective evaluation of the Executive BoD members performance by non-Executive PPA SA BoD members. In that framework is mentioned that executive BoD members:
* fulfill all the suitability and credibility criteria included in the Suitability Policy of the BoD members for appropriately exercise their responsibilities for the benefit of Shareholders.
* proved their ability to face and overcome difficult situations and the ongoing challenges such as the Red Sea crisis, which affected the supply chain and port industry (especially for Mediterranean area). In particular, despite the above disruptive conditions, through efficient management, the Company continued its upward progress, achieving growth in most of its business segments resulting to historically high performances (Record-highest ever revenues) that clearly reflect the successful implementation of Management's plans.
* successfully implemented the transition to the new EU reporting requirements (CSRD) by engaging internationally recognized auditing firms in the drafting and assurance of these reports, ensuring in this way not only the company’s compliance with the regulatory framework but also the high quality of provided services.
* successfully contributed to defining the company's strategic orientation, through the preparation of its strategic and business plan by a renowned external consultant, with the ultimate goal of achieving sustainable growth and optimizing its value, for the benefit of all parties involved (Major Shareholder, Hellenic State, Investors).Page 56 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

In respect to the evaluation of Executive BoD Members individually, it is concluded that:

Board of Directors

Executive Chairman
* Organizes and coordinates the Board and ensures effective functioning and organization of Board meetings.
* Promotes good relations between BoD members and a culture of dialogue.
* Contributes effectively to the work of the BoD.
* Maintains the business plan and sets long-term goals for the organization.
* Monitors the results of the day-to-day actions and decisions of the Board.
* Identifies risks related to the Board members’ work.

Chief Executive Officer
* Implements Board decisions throughout the organization.
* Presents company goals, objectives, and performance to the Board.
* Establishes the tone for the company’s culture and vision.
* Manages the company’s resources and coordinated the works of all departments.
* Manages market placement and explores expansion of commercial opportunities.
* Perform duties of strategic planning and oversight.

Chief Financial Officer
* Provides guidance and management on financial issues.
* Manages the processes for financial forecasting and budgets, and overseeing the preparation of all financial reporting.
* Provides advises on long-term business and financial planning.
* Establishes and develops relations with shareholders and investors community.

Conclusion
In this context, for the year 2025, the non-executive BoD members, in the field of executive BoD members performance evaluation unanimously concluded that the Executive BoD members of the Company:
* have the skills, the knowledge of the PPA’s Environment and the necessary experience on Company’s functions and activities.
* are ensuring Company’s efficient management, operation and supervision, in order to serve the long- term interests and sustainability of the Company.
* are distinguished for their integrity, objectivity and professionalism and have worked well together just as harmoniously.
* have a healthy and transparent working relationship.
* consistently educate themselves on external landscape and industry trends and they concern for the education of the whole BoD training and education.
* respond quickly and effectively to crises/unforeseen events

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Given the term of office of the current BoD, which started in summer 2025, it was also judged by the non- executive BoD members of the Company that the performance of the Board of Directors and its executive members will be evaluated and by the Ordinary General Assembly, at the same time of evaluation of the Company’s annual financial statements and the relevant reports in combination with the results of the year and the general course of the Company's operations.

10. External professional commitments of the BoD members

With a solemn declaration, the BoD members informed twice, about their other professional commitments, that they do not participate in more than five (5) BoD of listed companies. For the position of the President, the number is limited to three participations of other BoD based on the Hellenic Corporate Governance Code provision. Detailed CV’s of the BoD members are posted on the Company's website. The GA of July 8th 2025 approved the election of existing BoD members for two years. The term of the above BoD expires on July 8th 2027.

11. BoD members' Remuneration

The remuneration of the members of the BoD is determined by the Remuneration Policy, which was prepared in the context of article 110 of Law 4548/2018 and includes all the information provided for in article 111 of Law 4548/2018. The existing Policy was approved by the Extraordinary GA of August 2nd, 2023 (quorum: 79.99%, votes in favor: 98.1% of the represented shareholders). The Policy is available on the corporate website www.olp.gr in the most specific option: Organization > Corporate Governance > Policies.

Regarding Executive BoD Members
During the fiscal year 2025 and in compliance with the approved Company Remuneration Policy, the remuneration of the Executive BoD Members shall be analyzed as follows:

Page 58 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Fixed Remuneration of Executive BoD Members
During the fiscal year 2025, the Company held contracts of employment with the Executive Members of BoD, Mr Su Xudong (CEO), Ms LI Jin (CFO). These contracts of employment were for an indefinite period and included a monthly salary and ancillary benefits, and applied to those requirements of the labor law relating to periods of notice, retirement and the payment of legal compensation in the event of termination of the contract. Furthermore, the above Executive BoD Members received fees for their participation in the meetings of the BoD (in proportion to the period of expiry or the beginning of their term of office within the year) which had been approved by the Decision of 02/08/2023 of Annual GA (40,000.00€ annually per Member).

Variable remuneration of Executive BoD Members
During the fiscal year 2025, no variable remuneration was paid to any Executive Member of BoD. All the above remuneration of the Executive BoD Members shall be subject to the deductions provided for in the applicable tax and labor legislation.

Regarding Non-Executive BoD members
During the fiscal year 2025 and in compliance with the approved Company Remuneration Policy, the remuneration of the Non-Executive BoD Members shall be analyzed as follows:

Fixed remuneration of Non-Executive BoD Members
During the fiscal year 2025, the Non-Executive BoD members received fees for their participation in the meetings of BoD, which were approved by the Annual GA Decision of 08.07.2025 (€40,000.00 annually per Member). In addition, is granted a gross annual amount for the independent members of the BoD and the FUND representative, for their participation in the meetings of the BoD Committees (Audit - Remuneration - Nominations Committees), regardless of the total number of Committees in which they participate.

Variable remuneration of Non-Executive BoD Members
During the fiscal year 2025 no variable remuneration was paid to any non-executive BoD member. All the above remuneration of the Non-Executive BoD members shall be subject to the deductions provided for in the applicable tax and labor legislation.

Shares and/or stock options for shares
The Company has not granted any shares or stock options for shares to either the BoDs or the DCEOs.

Use of retrievability of variable remuneration
The Company did not make use of the possibility to recover variable remuneration during the fiscal year 2025. It is to be noted that in 2025, the Company prepared the members of the BoD remuneration report for fiscal year 01.01.2024-31.12.2024 in accordance with article 112 of Law 4548/2018.

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12. Disclosure of direct and indirect conflicts of interest

The Company, exercising the exclusive right to own, use, manage, maintain, improve and exploit the Port Concession Items, provides a wide range of port services and facilities. In the context of the provision and in the exercise of these activities it is possible to create conflict of interest situations detrimental to the interests of the Company, its shareholders, its customers and its suppliers. The Company, in accordance with the current regulatory framework for the defense of its own interests and the interests of its shareholders, its customers and its suppliers, establishes the following Policy and the following internal procedures, which include organizational measures aimed at Identifying, Preventing and Dealing with Conflict of Interest Situations.

As Conflict of interest" is meant the situation that arises when either the private interests, personal relationships, or any external activities of the "covered" persons could unjustly influence their decisions of any kind in the performance of their obligations and duties. That includes any professional, personal, family, financial condition, which affects or could unfairly affect a person's ability to assess a situation or make a decision independently and impartially, and which is likely to result in jeopardizing the interests of the Company for the benefit of another interest.

In accordance with the Policy, all members of the BoD of the Company and any third person to whom duties have been assigned by them must, notify, in a timely, adequate and written manner, the other members of the BoD and the Top management of the direct or indirect conflict of interest of which they are aware of and which has arisen from the Company’s transactions and/or during the performance of their duties.

Procedures of preventive measures to avoid situations of conflict of interest
The Company takes measures and implements policies and procedures for the determination of the means of dealing with conflict of interest situations, as described:

Submission of a Conflict of Interest and Confidentiality Declaration.
In order to effectively identify and prevent situations of conflict of interest, the Company has established an obligation to submit a declaration of non-conflict of interest of the members of the BoD as well as members of Top Management, who are obliged at least 1 at the beginning of each year to submit such declarations.In addition to the above declaration and as a further verification and cross-check of the Independent Members declaration’s content accuracy, the following certificates are collected by the BoD Secretariat:

  • Certification from the Financial Management Department, that after checking the accounting records and books, the candidate for election as BoD Independent member does not receive fees or benefits, except his remuneration (in case of re-election) for his term of office as a BoD member.
  • Certification by the Legal Department that, following check of the contract archive maintained, the candidate for election or re-election as an Independent BoD member has not signed into any type of contract with the Company.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

  • Certification from the BoD Secretariat, Public Relations & Investors Relations Department, that following a check of the Shareholding Registry, the candidate for election or re-election as an Independent BoD member, does not own a percentage of the Company's shares equal to or greater than 0.5%.

Code of Conduct

The Company has established and implements a Code of Conduct, which provides specific principles for avoiding conflict of interest situations for all Company's staff.

Code against Corruption and Bribery

The Company is committed to its activities in accordance with the applicable National and European Legislation and commercial customs and this commitment is incorporated into the present Code. Company considers that on Company level, participation in corruption phenomena inflicts the reputation, credibility of the Company itself, causes penal consequences and other legal risks as well as financial damage (in the case of fines imposition), increases operational cost, affects the loyalty and faith of Company personnel, creates negative corporate culture and causes exclusion from potential business opportunities.

Remuneration

The Company takes the necessary measures so that the remuneration, the evaluation and the assigned responsibilities do not encourage behaviors by the "covered" persons that may lead to conflict of interest situations.

Gifts and personal benefits

The acceptance and offer of gifts and other personal benefits is governed by the relevant policies and procedures of the Company, which are designed to prevent the use of the position within the Company, in order to provide personal benefits for himself or for “related persons”.

Donations and Sponsorships

The Company has established and implements a Donations and Sponsorships Policy, which specifies on the one hand the conditions and characteristics that should govern the sponsored actions and the sponsored bodies, and on the other hand the procedure that should be followed up to the final stage of their implementation.

BoD members' fees

The Company has established and applies principles and rules regarding the remuneration of the members (executive and non-executive) of the BoD, in a transparent, clear and understandable manner in accordance with the Company's Remuneration Policy in order not to encourage behaviors which may lead to situations of conflict of interest or the taking of excessive risks. In this direction, the Remuneration Committee of the Company's BoD operates as an independent and objective body, consisting of non-executive members, the majority of whom are independent, in order to provide guidance in a transparent manner on issues related to the remuneration of the BoD members and Top Management.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

13. Monitoring conflict of interest situations

In order to timely diagnose and deal with possible situations of conflict of interest:

The Internal Audit Department reports to the BoD of the Company cases of conflict of private interests of the BoD Members or Executives with the interests of the Company, which they ascertain during the exercise of their duties. In the event of a conflict of interest being identified, the BoD undertakes to deal with it, deciding on any corrective measures or consequences, including their escalation according to the seriousness of the situation and the potential invitation of negative consequences to the Company’s interests (indicative and not limited to: temporary removal from the position of responsibility, suspension of performance of duties, non-continuation of performance of duties, imposition of penalties provided for by law).

14. Communication with stakeholders and shareholders

Dialogue with other stakeholders

As a responsible corporate organization that prioritizes transparency and continuous communication of its actions and activities, Company interacts systematically with its Stakeholders, who play an important role in the Company's decision-making process. The Company's objective is to create the conditions for a continuous two-way dialogue with the interested parties in order to understand the effects of its activity and to improve its performance taking into account the opinion, needs, expectations and proposals of all the parties it affects and they influence the decision-making and the formulation of the Company's strategy. For this reason, and in the context of conducting a materiality analysis, the Company redefines the stakeholders who participate in, influence, and are significantly affected by its business activities, in accordance with its principles/values, strategy, market, and the proximity of its activities to them. The materiality analysis is a key to identifying, defining, and evaluating the priorities set by the Company for sustainable development. To this end, it has been implementing a materiality analysis systematically since 2018. In addition, the Company, in the context of its interaction with stakeholders, continuously assesses its impact on people and the environment. This regular review allows for the timely identification and management of the impacts of its activity, even if these change or new ones arise. In 2025, the Company proceeded to a double materiality analysis for the second time, taking into account the European Sustainability Reporting Standards (ESRS), while at the same time adhering to the requirements of the GRI Standards, as the main reference standard for determining the content relating to the completeness of the data, the double materiality of the issues, the response to the needs of stakeholders and the overall framework for the Company's approach to Sustainable Development, as well as all the principles for its quality. Four main steps were followed in this process, to understand and address the most critical issues that shape Company’s sustainability performance and financial success:

Step 1: Contextualization and Mapping
Step 2: Material Impact Identification
Step 3: Assessment of Financial Risks and Opportunities
Step 4: Double Materiality Results

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Results

Following the ESRS process and evaluating the outcomes of the interviews with internal and external stakeholders, material topics were identified. The impact materiality assessment process enabled Company to identify topics which considered material to the organization, topics which are recognized for promoting a positive impact on one or more dimensions (environment, economy and people), and topics were identified as having the potential to cause a negative impact on one of these dimensions. The financial materiality assessment supported the process of identifying which of these material topics are associated with financial risks and opportunities for the organization. Were identified financial opportunities and financial risks to which Company is potentially exposed. As a final step, the double materiality score was calculated considering both impact and financial materiality assessments.

Communication with the shareholders and the investor community

The BoD Secretariat, Public Relations and Investors Relations Department is in constant communication with shareholders, institutional investors, financial analysts and the investment community in general, providing information (based on publicly available information) on the progress of Company’s activites and current business developments through:

  • teleconferences that takes place to comment on the financial results.
  • participation in roadshows, both in Greece and abroad:
    (a) WOOD’s Greek Retreat, Athens, May 2025,
    (b) Geneva Investment Conference, June 2025,
    (c) Morgan Stanley and Athens Stock Exchange Greek Investment Conference, London, December 2025,
    (d) WOOD’s Winter Wonderland EMEA Conference, Prague, December 2025.
  • one-on-one meetings with institutional investors.
  • presentations of its strategy (Investor Days)
  • presentation of the Annual Financial Statements during the Annual General Meeting where comments and questions of the shareholders are answered by the Management. For any questions that did not manage to be answered within the time of the General Meeting, the BoD Secretariat, Public Relations and Investor Relations Department contacts the shareholders who raised the questions directly for further clarifications.

Share course

In 2025, the General Index of Athens Stock Exchange showed an increase of 44.3%. The share of the Company recorded an increase of 36.0%, closing at €40.80 on 31.12.2025, with an annual average transaction volume of 10,478 pieces/day and an average price of €40.67. On 11/06/2025 the share of the Company closed at € 49.70 which is an all-time high. The next day intraday reached the high of € 49.95.The year low was intraday on 20/01/2025 at € 28.30.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

The following table presents the average closing price and the average daily trading volume of the Company's share per month, for the financial year 2025 in relation to the corresponding time period of 2024.

Average Closing Price (€) Average Daily Volume (# pieces)
2025 2024
January 30.16 24.28
February 32.30 25.34
March 33.22 26.72
April 38.36 25.27
May 43.80 24.74
June 45.55 25.41
July 47.19 26.57
August 46.24 25.91
September 43.93 27.15
October 43.58 27.68
November 41.34 29.87
December 40.84 30.22

The diagram below presents the development of the Company's stock for 2025, in relation to the corresponding progress of the General Index of the Athens Stock Exchange.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Diagrammatic Illustration of the Evolution of the PPA Share Price in Relation to the Athens Stock Exchange General Index

Regarding the dividend distribution, taking into account, among other things, the Company's progress, prospects and investment plans, the Ordinary General Meeting of the Company's shareholders on 08.07.2025 approved the distribution of a dividend of a gross amount of € 1,92/share for the financial year 2024 before withholding tax (according to current tax legislation) against € 1.336 per share for the previous financial year. Over the past decade, the dividend per share has increased from € 0.0892 for the financial year 2016 to €1.92 for the financial year 2024, an increase of 2,052.47%. The proposed dividend for distribution for the year 2025 is € 1.896/share, with the dividend yield at 4.6% (based on the closing price on 31.12.2025) and the dividend payout ratio stable at 55%.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

The diagrams below show the course of the dividend distributed by the Company per share and overall, combined with dividend yield and dividend payout ratio, during the economic period 2016-2025.

Diagrammatic Illustration of Dividend Distribution - Dividend Yield
Diagrammatic Illustration of Total Dividend Distributed - Dividend Payout Ratio

*Proposed total dividend to be distributed, subject to the approval of the General Assembly of Shareholders

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

The company has a wide shareholders base with a total of 4,426 shareholders (reference date 31.12.2025), the majority (91.5%) of which are shareholders with less than 1.000 shares. However, the biggest part of the share capital, besides “COSCO SHIPPING (Hong Kong) Co., Limited” which holds 67.00% and the “Hellenic Corporations of Assets and Participations S.A.” which holds 7.14% of the share capital, is held by foreign and Greek institutional investors.

Number of Investors Number of shares Percentage (%)
0<Shares<=1.000 604,530 2.42%
1.000<Shares<=10.000 887,194 3.55%
10.000<Shares<=100.000 2,178,113 8.71%
100.000<Shares<=1.000.000 2,795,723 11.18%
1.000.000<Shares<=10.000.000 1,784,440 7.14%
10.000.000<Shares 16,750,000 67.00%
Total: 25,000,000 100.00%

Note: The 'Number of Investors' column seems to be missing the counts for each bracket, only showing the number of brackets themselves in the input text structure for the middle columns. I've adjusted the table based on the visual representation provided in the raw text, using the counts from the text structure:

Number of Investors Number of shares Percentage (%)
0<Shares<=1.000 604,530 2.42%
1.000<Shares<=10.000 887,194 3.55%
10.000<Shares<=100.000 2,178,113 8.71%
100.000<Shares<=1.000.000 2,795,723 11.18%
1.000.000<Shares<=10.000.000 1,784,440 7.14%
10.000.000<Shares 16,750,000 67.00%
Total: 25,000,000 100.00%

Correction based on the input text structure for investor count:

Number of Investors Number of shares Percentage (%)
4,050 604,530 2.42%
295 887,194 3.55%
71 2,178,113 8.71%
8 2,795,723 11.18%
1 1,784,440 7.14%
1 16,750,000 67.00%
Total: 4,426 25,000,000 100.00%

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

C. Audit Committee (AC)

The AC operates within the framework of the provisions of Article 10 of Law 4706/2020 “on corporate governance” and in accordance with the provisions of relevant circulars and decisions of the Hellenic Capital Market Commission, as in force from time to time (indicatively the circulars/letters 1302/28.04.2017, 1508/17.07.2020, 1149/17.05.2021, 427/21.02.2022) of the Directorate of Listed Companies of the Hellenic Capital Market Commission.

Composition of the Committee, skills and experience

The existing Audit Committee operates in accordance with the provisions of article 44 of Law 4449/2017. It is a Committee of the Board of Directors and is composed of three (3) non-executive members of the Board of Directors, of which two (2) are independent under article 9 of Law 4706/2020, who were appointed by the BoD meeting that took place on 08.07.2025.

Until 07.07.2025, the Audit Committee’s composition was as follows:
- Kwong Che Keung Gordon, Board of Directors independent Non-Executive Member and Chairman of the Audit Committee.
- ARVANITIS Nikolaos, Board of Directors independent Non-Executive Member and Member of the Audit Committee.
- POLITIS Dimitrios, Board of Directors Non-Executive Member and Member of the Audit Committee.

Since 08.07.2025 the Audit Committee’s composition is as follows:
- ZHOU Zhonghui, Board of Directors independent Non-Executive Member and Chairman of the Audit Committee.
- LIN Lan, Board of Directors independent Non-Executive Member and Member of the Audit Committee.
- POLITIS Dimitrios, Board of Directors Non-Executive Member and Member of the Audit Committee.

Detailed CVs of the Audit Committee members are posted on the Company's website. The term of office of the Audit Committee is equal to the term of office of the elected Board of Directors of the Company, whose term of office is two years, ie until 08.07.2027 and which is extended, in accordance with the provisions of article 85, par. c of Law 4548/2018 until the expiration of the deadline, within which the next Ordinary General Assembly must be convened in 2027 and until the relevant decision is taken. The members of the Audit Committee, all non-executive members, did not hold positions incompatible with their status during 2025. Their objectivity and independence were ensured, in the absence of any transaction with the Company which could affect them. The members of the Committee have competencies related to the sectors in which the Company operates, as they have as a whole sufficient knowledge in the field of industrial products and services, in auditing or accounting and experience in the areas of Corporate Governance and Internal Control Systems.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Evaluation of the AC

The Chairman of the Committee ensures the organization of the evaluation of the work of the Committee on an annual basis. In the above context, it was carried out both a self-evaluation process of the AC and an evaluation process by an external consultant based on the provisions of the Corporate Governance Code (article 3.3.14), of the Law 4706/2020 and the Circular 60 of the Capital Market Committee. The above process was carried out using evaluation tools provided by the external advisor (filling out an electronic questionnaire, etc.) and through personal interviews, which referred to the collective ability of the AC as a body, as well as to the individual abilities of its members. The conclusion of the above evaluation of the external consultant stated, among other things, that the Audit Committee is functioning effectively contributing significantly to the overall governance and decision-making processes of the Board. The above result is a confirmation of both the proper functioning of the AC and its compliance with the current legislative and regulatory framework.

Purpose - Responsibilities

The main objective of the Audit Committee is to provide support to the Board of Directors of the Company in the context of issues falling within its responsibilities, in accordance with the applicable legal and regulatory framework and its Operational Regulation. The members of the Committee as a whole have proven sufficient knowledge in the field in which the Company operates, while the Chairman of the Committee has proven sufficient knowledge in issues of accounting and auditing. The main responsibilities of the Audit Committee are the following:
• Monitoring the financial reporting process.
• Monitoring the effective operation of the Internal Control System and the Risk Management System.
• Monitoring of proper functioning of the Company’s Internal Audit Department.
• Monitoring of the statutory audit of Financial Statements.
• Supervision of the official announcements concerning the Company's financial issues.
• Review and monitor issues related to the existence and maintenance of objectivity and independence of the External Auditor or audit firm, particularly regarding the provision from them to the Company and other non-audit services.
• Review the Financial Statements prior to approval by the Board of Directors.
• The Company's compliance with legal and regulatory framework of operation.

The responsibilities and the way of operation of the Audit Committee are described in the Operational Regulation of the Committee, which has been approved by the Board of Directors.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

During 2025, the Audit Committee met in total fourteen (14) times (including cases of decisions issuing through circulation of minutes), with the participation of each member in the meetings of the Audit Committee amounted to 100%.In order to ensure the Company’s independence, the meetings took place without the presence of other top management executives, except in cases where their presence was deemed necessary (such as the cases of discussion of the review of the interim and annual Financial Reports). All Committee members participated in all the meetings and all Committee decisions were taken unanimously. The main issues handled by the Audit Committee in 2025 were the following:
* Monitoring and evaluation in collaboration with the competent bodies of the Management and the External Auditor of the Company the process of preparation of the semi-annual and annual Financial Statements, prepared in accordance with the International Financial Reporting Standards, and confirmation of their accuracy completeness and consistency, according to the information provided to its members.
* Discussion with the External Auditor and receiving information about their cooperation with the Management in issues of financial control.
* Discussion and provision of its agreement to all official announcements concerning the Company's financial issues.
* Evaluation of the results of the audits carried out by the Internal Audit Department. Approval of the annual internal audit program for the current year.
* Monitoring the effective operation of the internal control and risk management system, in accordance with international standards and the applicable legal and regulatory framework.
* Provision of its consent to the proposal of the Board of Directors to the Ordinary General Assembly of Shareholders for the appointment of the auditing company “ERNST & YOUNG (HELLAS) Chartered Auditors Accountants S.A.”, (with Institute of Certified Public Accountants of Greece (SOEL)) register number 107”, for the mandatory audit of the Company for the year 2025.
* Evaluation and confirmation the objectivity and independence of the cooperating External Auditor, receiving a relevant letter.
* Assessing the nature and cost of the non-audit services provided by the auditing firm “ERNST & YOUNG (HELLAS) Chartered Auditors Accountants S.A.” regarding the regular audit of the fiscal year 2025, in accordance with the provisions of Law 4449/2018 and Regulation 537/2014 of the EU.
* Awarding of services for conducting the Control System evaluation process of PPA S.A.
* Awarding of services for conducting the Periodic Evaluation Policy of the Corporate Governance System of PPA S.A.
* Internal Control System evaluation process
* Awarding of external assurance services provision for the information included in the PPA SA Corporate Sustainability Report in accordance with European Directive 2022/2464 for the year ended Dec. 31, 2025.

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  • Approval of Risk Management Unit Operational Regulation of.
  • Approval of Risk Management Unit Policy, Methodology & Procedures.
  • Monitoring of Regulatory Compliance Unit action plan implementation for 2025 and approval of 2026 respective annual Action Plan.

In the context of non-audit services, whose provision by the Statutory Auditor is not prohibited by law, the Committee applied judgement on and assessed the following:
i. threats to independence and objectivity resulting from the provision of such services and any safeguards in place to eliminate or reduce these threats to a level where they would not compromise the auditors’ independence and objectivity,
ii. the nature of the non-audit services,
iii. whether the skills and experience of the audit firm make it the most suitable supplier of the non-audit services,
iv. the fees incurred, or to be incurred, for non-audit services both for individual services and in aggregate, relative to the audit fee, including special terms and conditions (for example contingent fee arrangements), and
v. the criteria which govern the compensation of the individuals performing the audit.

During 2025, the Committee examined the non-audit services that were proposed to be performed by the external auditor for the Company, which concerned pre-agreed procedures, and after evaluating the nature of proposed services and receiving relevant clarifications, declarations and assurance from the external auditor, considered that they did not pose a threat to the external auditor's independence in accordance with the provisions of article 44 of Law 4449/2017 and article 5 of Regulation (EU) 537/2014.
* Information towards the Board of Directors of the Company about the issues within its competence.

In carrying out its work in general, the Audit Committee had full access to all the information necessary for the effective performance of its duties. The discussions and the decisions of the Audit Committee are recorded in minutes signed by the members.

A. Audit Committee Performance in relation to: Mandatory External Audit (article 44, par. 3, case a of the Law).

Particularly:
a) Regarding the performance of the statutory audit (external audit) of the Company financial statements, were not found significant deviations in the recognition, valuation and classification of assets and liabilities and we consider that the Management's assumptions and estimates are reasonable. We have found that the relevant disclosures in the notes to the financial statements are adequate.
b) During the mandatory inspection, were performed the following procedures:
1. Control of the process of registration and accounting of expenses, fixed assets, sales and other accounting subjects.

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  1. Control of the tax issues.
  2. Control of the processes and procedures of Financial Management Department.
  3. Review of External Auditor Report.
  4. Evaluating risks of pending litigation

In the exercise of our responsibilities, were not identified any material weaknesses which may have an impact on the truth and fairness of the financial information presented to shareholders. It is noted that the Audit Committee always takes into account the content of any additional reports submitted to it by the External Auditor hired by the Company, which contains the results of the statutory audit performed and meets at least the specific requirements in accordance with Article 11 of Regulation (EU) No 537/2014 of the European Parliament and of the Council of 16 April 2014. In particular, based on the Supplementary Report delivered to the Audit Committee, there is no material change, compared to the previous year, in the accounting principles and assumptions. Furthermore, no material errors were found which should have been corrected by the Company's Management.
c) Within the framework of its responsibilities, was informed about the procedure and the schedule of preparation of the financial information by the management of the Company, as well as was informed by the External Auditor on the statutory audit program for the year 2025 before its implementation. Was evaluated and made sure that this program covered the most important areas of control, considering the key areas of business and financial risk of the Company. We also held meetings with the Company's management / responsible executives and the External Auditor, during the preparation of the financial statements, during the planning stage of the audit, its execution and during the stage of preparation of the audit reports, respectively.
d) It was taken into account and examined the most important issues and risks that may have an impact on the Company's financial statements, as well as the significant judgments and estimates of management during their preparation. Specifically, were examined and evaluated in detail the following issues with reference to specific actions on these issues:
(d1) Regarding the important judgments, assumptions and estimates in the preparation of the financial statements, were found that they are reasonable.
( (d2) Regarding the disclosures for the above issues required by IAS / IFRS, were found that the disclosures included in the financial statements were sufficient.
(d3) Regarding the transactions with related parties, was not found any significant unusual transactions.
e) Finally, there was timely and substantial communication with the External Auditor of the preparation of the audit report and its supplementary report to the Audit Committee.
e) Were reviewed the financial reports before their approval by the Company's Board of Directors and considered that were complete and consistent in relation to the information that was brought to attention of Audit Committee, as well as to the accounting principles applied by the Company.

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Based on the aforementioned, it was found that the Company's financial statements are in accordance with the mandatory by law content and preparation framework and the Committee assessed that the annual financial report, together with the financial statements and the Company's management report, depict in a true, correct, balanced and comprehensible manner the evolution, performance and position of the Company and provide the required information to the shareholders.

Financial information process (article 44, par. 3, per. B' of the Law).

In relation to the process of preparing the financial information, the Audit Committee monitored, examined and evaluated:
(1) the mechanisms and systems of flow and dissemination of financial information produced by the involved organizational units of the Company and
(2) other disclosed information in any way (e.g.stock market announcements, press releases) in relation to financial information. In the exercise of our responsibilities, we did not find any material weaknesses in the process of compiling the financial information. In particular, the Audit Committee held meetings to receive briefings on the financial information process on the financial statements and was informed by the Chief Financial Officer on the Company's financial statements, which were drafted in accordance with IFRS. The Audit Committee was also informed about the accounting principles followed by the Company for the preparation of the said financial statements, which did not differ from those adopted by the Company in the previous fiscal year, apart from the immaterial changes reflected in the financial statements, and for the main issues that occupied the Department of Financial Management during the preparation of these financial statements. During the exercise of the responsibilities of the Audit Committee, no significant weaknesses were found in the process of preparing the financial information.

Financial Results for the first half of 2025

The Audit Committee was informed by the Financial Management Department of the financial results of the 1st semester of 2024 and no gaps or discrepancies were found in the assurances provided for the correctness and accuracy of the information. The Committee prepared a relevant report on the overview of the company's six-monthly individual and consolidated financial statements to the Board of Directors.

Financial Results of the 1st and 3rd quarters of 2025

The Audit Committee was informed by the Financial Management Department about the financial results of the 1st and 3rd quarters of 2025 and brought to its attention a draft of the relevant announcement to the investing public. The Committee, after receiving assurances about the correctness and accuracy of the information to be made public, expressed its satisfaction with the Company's progress.

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Procedures of internal control and risk management systems and the internal control unit (article 44, par. 3, point B' of the Law).

Particularly In connection with the monitoring, examination and evaluation of the adequacy and effectiveness of all the policies, procedures and safety controls of the Company regarding the internal control system, the corporate governance system and the assessment and management of risks, in relation to the financial information, the Audit Committee proceeded to actions below:

  1. The assignment of services for the "Assessment of adequacy and effectiveness of Internal Control System Evaluation" by an external auditing company (KPMG Certified Auditors S.A.) in accordance with the provisions of Law 4706/2020, the Decisions of the Capital Market Commission and any other relevant legislation on Corporate Governance, for the period 01.01.2023 – 31.12.2025.
  2. The assignment of services for the "Assessment of adequacy and effectiveness of Corporate Governance System Evaluation" by Regulatory Compliance Unit in accordance with the provisions of Law 4706/2020, the Decisions of the Capital Market Commission and any other relevant legislation on Corporate Governance, for the period 01.01.2025 – 31.12.2025.
  3. After reviewing the approval of the following items related to the Risk Management function:
    • Risk Management Report
    • Risk Appetite Statement
  4. Evaluation of the functioning of the Internal Audit Department according to the professional standards as well as the current legal and regulatory framework and evaluation of the work it performs, its adequacy and effectiveness, without however affecting its independence.
  5. Overview of the disclosed information regarding the internal audit and the main risks and uncertainties of the Company in relation to the financial information.
  6. Evaluation of the organizational structure of the Internal Audit Department and the Regulatory Compliance and Risk Management Functions, and any staffing weaknesses of the above units, i.e. if they have the necessary means, if they are insufficiently staffed with potential with insufficient knowledge, experience, and training.
  7. Assessing the existence or non-existence of restrictions on the work of the Internal Audit Department and the functions of Regulatory Compliance and Risk Management as well as their independence that they must have, to perform their work unobstructed.
  8. Evaluation of the annual audit program of the Internal Audit Department before its implementation, taking into account the main areas of business financial risk as well as the results of previous audits.
  9. Considering that the annual audit program, in conjunction with any corresponding medium-term programs, covers the most important areas of control and financial information systems.
  10. Organizing regular meetings with the head of the Internal Audit Department, as well as with the Managers of Regulatory Compliance and Risk Management functions on matters within their competence and gaining knowledge of their work and their regular and ad-hoc reports.

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  1. Monitoring the effectiveness of internal control systems through the work of the internal control unit and the work of the External Auditors.
  2. Overview of the management of the main risks and uncertainties of the Company and their periodic review, evaluating the methods used by the Company to identify and monitor the risks, the treatment of the main ones through the internal audit work of the Internal Audit Department as well as their disclosure in the published financial information in a proper manner.

The Audit Committee was informed and has evaluated the reports of the audit program for the year 2025 and evaluated and approved the audit program of the year 2026 (before its submission for discussion to the Company’s BoD) having thoroughly considered the proposed areas for scrutiny, in line with the Internal Audit Department proposals, and judging that the control environment in relation to risk assessment is adequately reflected, in line with the risk-based approach followed by the regulatory framework and International Standards on Internal Auditing.

The Audit Committee, was informed of the following main risks for the year 2025:
* Risk of loss of assets.
* Property insurance.
* Third Party Liability and Employer’s Liability.
* Maximum Probable Loss (MPL) analysis.
* Business Risks Associated with the Company's business activities.
* Fair Value.
* Credit Risk.
* Foreign Exchange Risk.
* Interest rate risk.
* Liquidity risk.
* Commercial - Operation Risk, associated with:
* Wider Economic Environment.
* Economic instability.
* Energy policy.
* Non-expanded clientele (Container terminal).
* Geopolitical conditions.
* Legal risk, related to:
* Pending legal claims against third parties.
* Legal claims of third parties.

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In the exercise of the responsibilities of the Audit Committee on the above-mentioned issues, it was not identified any material weaknesses that may have an impact on the truth and fairness of the financial information presented to shareholders. The Audit Committee continuously kept the Board of Directors of the Company informed about its activities.

B. Sustainable development policy followed by the Company

In accordance with the provisions of article 44 par. 1 of Law 4449/2017, as replaced by the provisions of article 74 par. 4 case 9 of L.4706/2020, the Audit Committee is obliged to include in the annual report of the proceedings to the ordinary General Assembly also a description of the sustainable development policy followed by the Company. The Company's long-term commitment to Sustainable Development has already led to its participation in the ATHEX ESG Index of the Athens Stock Exchange, while it takes into consideration both the new legislation on Corporate Governance and the principles of the EU Taxonomy. The Company, the Sustainable Development seeks, over time, to create value for its stakeholders, i.e. shareholders, customers, employees and society in general. To achieve this goal, the Company places particular emphasis on, among others, the training and development of its personnel, health and safety at work, as well as respect for the environment, following the principles of sustainable development. Responsible operation is a continuous commitment to action of substance, in order to generate value for all stakeholders that meet the modern needs of society and contribute in general to its prosperity. The Company has a specific strategy, which focuses on the important issues related to its activity and seeks its continuous responsible development, focusing on the critical pillars of business responsibility: Economy, Society, Environment. Sustainable development is an integral part of the Company's business practice model and culture. In the context of the implementation of Sustainable Development, the Company develops activities, among others, in the following areas:

The policy, the results of the Company's performance in the issues of Sustainable Development, as well as the implementation of the programs and the achievement of the objectives, are published on an annual basis, in order to fully and comprehensively inform under a general framework of transparency.The Company supports the United Nations 2030 Agenda, as set out in the 17 Sustainable Development Goals, with a view to actively contributing to their achievement by promoting the prosperity and security of the people; environmental protection and the fight against poverty. The Company’s priority is the fulfillment of the objectives that are directly related to the activities and challenges of the sector in which it operates, as well as to the essential issues arising from the Corporate Responsibility and Sustainable Development Report, which details the connection of the programs and of the Company's actions.

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The Company recognizes that international ESG indicators are a strategic tool to support investors in identifying risks and opportunities linked to the sustainability of their investment portfolio. Subsequently, simultaneously responding to the challenges of the new environment, it builds a sustainable development strategy aiming at minimizing the negative impact that its activities may have.

Environmental responsibility

The Company recognizes its leading position in the Mediterranean region and in the wider maritime sector and takes action to prevent and mitigate its environmental impacts, in accordance with European, national and international environmental laws and regulations. Its goal is to achieve balanced economic growth combined with environmental responsibility.

The Company implements a certified Integrated Quality, Environmental, Energy and Emissions Management System that is aligned with the requirements of the ISO 9001:2015, ISO 14001:2015, ISO 50001:2018 and ISO 14064-1:2018 standards and which is adopted in all activities of PPA S.A. Through this system, the Company's commitments are demonstrated and goals are set related to excellent quality, minimizing the environmental footprint, energy saving and emission reduction, sustainable procurement, as well as responsibility throughout the value chain.

At the same time, the Company is committed to the principles of the ESPO Green Guide and sets goals and objectives to improve its environmental performance. In addition, it maintains long-term cooperation with institutes and universities in the development and implementation of environmental quality monitoring programs (Air quality, Noise nuisance, Marine water and sediment quality) and in the preparation of a specific study on "Vulnerability and adaptation to climate change" covering sectors such as port projects, infrastructure and activities.

Social Responsibility

Social responsibility is a key issue for the wider shipping industry, and for this reason the Company emphasizes and is committed to maintaining the highest standards of integrity and ethical behavior in all its business transactions. The Company invests in its employees and is committed to creating an evolving, dynamic, cohesive and diverse work environment that supports their professional development, and promotes a balance between professional and personal life, prioritizing their health and well-being.

With a view to promoting equality, the Company recognizes the particularities of each person and consistently seeks to support people with different backgrounds, regardless of gender, age, nationality, disability or any other personal characteristic. Consequently, the Company does not tolerate any form of discrimination in the workplace and the determining factors for the development of its people are based on performance, efficiency, skills and qualifications.

In support of international labor standards, the Company complies with the conventions of the International Labor Organization (ILO), including those on working conditions, freedom of association and occupational health and safety.

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The Company invests in the upskilling and retraining of its employees, enhancing talent development and their responsiveness to customer needs, while supporting the communities in which it operates with the aim of their economic development and well-being. The Company promotes the protection of human rights and well-being in the context of its business activities, as well as those of the supply chain, in accordance with its human rights policy and Code of Conduct.

Corporate Governance

Transparency and accountability remain at the heart of the Company’s governance, both internally and across its value chain. The Company remains committed to effective corporate governance, which demonstrates a strong and ongoing commitment to serving the interests of shareholders. The Company encourages its people to practice and promote responsible business conduct throughout the value chain, in all directions, by defining the rights and responsibilities and the power of corporate bodies, ensuring a clear picture of the existing dynamics.

The Company remains committed to zero tolerance for behaviors and practices that may promote corruption or unethical competition. To this end, a series of policies have been established that serve as guidelines on how to avoid, prevent, mitigate and address corruption, and in particular the Code of Conduct (COD), the Anti-Corruption and Bribery Code and the Internal Operating Regulations.

The Company promotes the interests of suppliers, as the management of relationships with suppliers and contractors is largely determined in both the Company's Code of Conduct and the Contracts and Sub- Concessions Regulation. The strategy, programs, results and related commitments are analyzed in the annual Corporate Responsibility and Sustainable Development Report, which is based on the Global Reporting Initiative (GRI) guidelines and more specifically the Standards (In Accordance - Core), which are the most internationally recognized and demanding guidelines of their kind, and is available in the Company’s website.

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D. Nomination Committee Composition

The existing Nomination Committee operates in accordance with the provisions of articles 10 and 12 of L.4706/2020. It is a Committee of the BoD and is composed of three (3) non-executive members of the BoD, of which two (2) are independent under the article 9 of Law 4706/2020, who were appointed by from the Board of Directors meeting that took place on 08.07.2025.

The existing Nomination Committee operates in accordance with the provisions of articles 10 and 12 of L.4706/2020. It is a Committee of the Board of Directors and is composed of three (3) non-executive members of the Board of Directors, of which two (2) are independent under the article 9 of Law 4706/2020, who were appointed by the BoD meeting that took place on 08.07.2025.

Until 07.07.2025, the Nomination Committee’s composition was as follows:
* Kwong Che Keung Gordon, Board of Directors independent Non-Executive Member and Chairman of the Nomination Committee.
* ZHU Changyu, Board of Directors Non-Executive Member and Member of the Nomination Committee.
* ARVANITIS Nikolaos, Board of Directors independent Non-Executive Member and Member of the Nomination Committee.

Since 08.07.2025 the Nomination Committee’s composition is as follows:
* LIN Lan, Board of Directors independent Non-Executive Member and Chairman of the Nomination Committee.
* ZHU Changyu, Board of Directors Non-Executive Member and Member of the Nomination Committee.
* ZARAKELI Andriana, Board of Directors independent Non-Executive Member and Member of the Nomination Committee.

The term of office of the Nomination Committee will be equal to the term of office of the elected Board of Directors of the Company, whose term of office is two years, i.e. until 08.07.2027, which is extended, in accordance with the provisions of article 85, par. c of Law 4548/2018 until the expiration of the deadline, within which the next Ordinary General Assembly must be convened in 2027 and until the relevant decision is taken. The members of the Nomination Committee, all non-executive members, did not hold positions incompatible with their status during 2025, while both their objectivity and independence were ensured, in the absence of any transaction with the Company could affect they.

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Evaluation of the Nomination Committee

The Chairman of the Committee ensures the organization of the evaluation of the work of the Committee on an annual basis. In the above context, it was carried out both a self-evaluation process of the Nomination Committee and an evaluation process by an external consultant based on the provisions of the Corporate Governance Code (article 3.3.14).

The above process was carried out using evaluation tools provided by the external advisor (filling out an electronic questionnaire, etc.) and through personal interviews, which referred to the collective ability of the Nomination Committee as a body, as well as to the individual abilities of its members. The conclusion of the above evaluation of the external consultant stated, among other things, that the Nomination Committee is functioning effectively contributing significantly to the overall governance and decision-making processes of the Board. The above result is a confirmation of both the proper functioning of the Nomination Committee and its compliance with the current legislative and regulatory framework.# Purpose - Responsibilities

The main objective of the Nomination Committee is to provide support to the Board of Directors of the Company in the context of issues falling within its responsibilities, in accordance with the applicable regulatory framework and its Operational Regulation, for achieving the following objectives:
➢ Ensuring that the composition, structure and operation of the Board of Directors meet relevant legal, regulatory and supervisory requirements.
➢ Ensuring that there is an effective and transparent procedure for the nomination of candidates to the Board of Directors.
➢ Ensuring an appropriate mix of knowledge, skills and experience at Board level.
➢ Steering the process for the regular evaluation of the Board of Directors and of the Individual Members' performance and effectiveness.
➢ Ensuring fit-for-purpose guidelines regarding the Member nomination process for the Boards of Directors.
➢ Establishing the conditions required for effective succession and continuity in the Board of Directors.

The responsibilities and the mode of operation of the Nomination Committee are described in the Internal Rules of Operation of the Committee, which has been approved by the Board of Directors.

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Exercise of duties of the Nomination Committee

During 2025, the Nominations Committee met six (6) times. To ensure the independence of the Nomination Committee, the meetings were held without the presence of other members of the Management. All the members of the Committee attended all the meetings and all the decisions of the Committee were taken unanimously.

The main issues handled by the Nomination Committee in 2025 were the following:
➢ The continuation of the collective suitability and diversity of the Board of Directors, in such a way that the composition of the Company’s Board of Directors, fully covers the appropriate and suitable exercise of the responsibilities of the Board of Directors of the Company, and reflects the size and activity of the Company and can further contribute to the implementation of its business objectives.
➢ The submission of proposal for the election of new Board of Directors of the Company, , taking into consideration the expiration of the term of the previous Board of Directors of the Company elected by the Ordinary General Assembly of the Company's shareholders of 2023, the completion of the maximum total term of office of the current Independent Members and the obligation of electing a new Board of Directors arises, following the identification and the submission of proposal to the Board of Directors persons suitable for the acquisition of the status of member of the Board of Directors, taking into account the factors and criteria of individual and collective suitability determined by the Company, in accordance with the suitability policy it has adopted (which has been approved, in accordance with article 3 par. 3 of law 4706/2020, as in force, by the Ordinary General Assembly of the Company's shareholders of 02.08.2023) and based on the relevant procedure provided in the Rules of Operation of the Committee.

Regarding the identification of persons suitable for the acquisition of the status of a member of the Board of Directors of the Company and their proposal to the Board of Directors of the Company as candidates for election, the Committee unanimously considered appropriate to initiate the above process of suitability assessment by the existing members of the Board of Directors, namely the Executive Chairman, the CEO, the CFO and the Vice Chairman of the Board. As for the other members, given the completion (based on the provisions of article 9, paragraph 2ca of Law 4706/2020) of the maximum total term of office of the Independent Members, the Committee unanimously deemed it appropriate, following a suitability assessment process, to propose Messrs. Zhou Zhonghui, Zhang Xueyan, Lin Lan and Zarakeli Andriana as new independent BoD members.

Specifically, the Committee, following the procedure for the evaluation of the suitability of the candidate members of the Board of Directors, proceeded to the following actions:
Α) Regarding the (individual and collective) suitability criteria.
Regarding the verification of the fulfillment of the eligibility criteria of the candidates to be elected members of the Board of Directors of the Company, the Committee:
a) thoroughly studied the detailed CVs of each of the candidate members of the Board of Directors,

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b) took into account the participation and general presence of the candidates in the meetings of the existing Board of Directors of the Company throughout its term, of which the candidates are members, in which meetings it was noted by the members of the Committee, the independence of their judgment, the possibility to allocate the necessary time to fulfill their duties, the adequacy of knowledge in the field of activity of the Company (which is the use and exploitation of the port of Piraeus in accordance with the Concession Agreement with the Greek State, as applicable, and in particular the provision of services and facilities to ships, cargo and passengers, including the mooring of ships and the management of cargo and passengers to and from the port, and the creation, organization and operation of any kind of port infrastructure), the skills and experience required to perform their duties, were established,
c) collected and processed on a case by case basis based on the approved Suitability Policy of the Company, documents such as solemn declarations about non-occurrence of incompatibility / barriers, qualifications, certificates, excerpts from criminal records, etc...

Β) Regarding the conditions and criteria of independence.
Regarding the verification of the fulfillment of the independence criteria and conditions, within the meaning of article 9 par. 1 and 2 of law 4706/2020, as in force, of the candidates to be elected members of the Board of Directors of the Company, the Committee:
a) received solemn declarations from the proposed independent members, regarding their independence of the Company, within the meaning of article 9 par. 1 and 2 of law 4706/2020, as in force,
b) carried out an investigation and audit in the shareholders' register of the Company and found that does not occur the case of article 9 par. a of law 4706/2020, as in force,
c) carried out a research and audit of the Company's accounting books and contracts and found that none of the proposed members is a significant customer or supplier of the Company and that none of the cases of article 9 par. 2 par. b) of law 4706/2020, as in force, occurs,

In particular, during the evaluation process of the above candidates in terms of determining the fulfillment (a) of the eligibility criteria in accordance with the Suitability Policy and (b) the conditions of independence defined in article 9 par. 1 and 2 of law 4706/2020, as in force, were unanimously established that:

The proposed for election members of the Board of Directors individually:
(a) have the required knowledge, skills and experience for the exercise of their duties and significant practical experience in the issues relating to the business operation and the business scope of the Company and the operation of its Board of Directors,
(b) have the guarantees of morality (honesty and integrity) and reputation which they are presumed to possess, since the Committee has not been informed of the existence of objective and proven reasons or facts to the contrary;
(c) are not in a state of conflict of interest with the Company and has an independent and objective judgment in the performance of her duties, and
(d) may devote the time required to carry out their role within the Company.

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The proposed for election members of the Board of Directors collectively constitute a Board of Directors suitable for the exercise of its responsibilities that will contribute to the effective corporate governance of the Company and balanced decision-making, reflecting the guarantees of ethics, reputation, adequacy of knowledge, skills, independence of judgment and experience for the performance of its role for the benefit of the Company and its Shareholders, which (BoD) is in a position to:
- to make appropriate and informed decisions taking into account the opportunities as well as the various risks and parameters that accompany a business decision, such as business environment and the business prospects in the international markets, the risk appetite, the medium-long term growth strategy decided by the Company, the developments in the sector in which the Company operates (which is the use and exploitation of the port of Piraeus in accordance with the Concession Agreement with the Greek State, as applicable, and in particular the provision of services and facilities to ships, cargo and passengers, including the mooring of ships and the management of cargo and passengers to and from the port, and the creation, organization and operation of any kind of port infrastructure), the issues related to the protection of the environment, and the sustainable development etc.
- to supervise the top management that plays a very important role of its business and operational activity,
- to monitor in essence, discuss and critique constructively the decisions of senior executives and intervene directly in situations, if and when required.- to have an adequate understanding of the areas for which the members are collectively responsible and has the necessary skills to monitor the implementation of the strategy of the Company and the basic business decisions relating to enterprise matters in the medium term, the financial reporting references, the compliance with the legal and regulatory framework, the understanding of corporate governance issues, the ability to identify and manage risks, the impact of technology on its activity, etc.. Of the above proposed members of the Board of Directors of the Company, following, on the one hand, a relevant examination carried out by the Committee and on the other hand, their relevant responsible declarations, it was found that the following proposed candidates for election meet the independence criteria of article 9 par. 1 and 2 of Law 4706/2020, as in force: (a) ZHOU Zhonghui, (b) LIN Lan, and (c) ZARAKELI Andriana, Based on findings regarding: a) the individual suitability of the members of the Board of Directors, b) the collective suitability of the Board of Directors, c) the absence of impediments or incompatibilities in the person of the candidate members proposed for election, d) the incompatibility of article 3 par. 4 of Law 4706/2020, e) the determination of independence, f) the legal composition of the Board of Directors, the Committee unanimously decided:

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1) To propose to the Board of Directors of the Company, to recommend to the Ordinary General Assembly of Shareholders of the Company, the election of a new nine-member Board of Directors of the Company with two years term, which is automatically extended, according to article 85 par. 1 point c of Law 4548/2018, as in force, and article 11 par. 2 of the Company's Articles of Association, until the expiration of the deadline, within which the Ordinary General Assembly of 2027 and until the relevant decision is taken, consisting of : the below proposed members to be elected:
1) Mr. LIN Ji,
2) Mr. ZHU Changyu,
3) Mr. SU Xudong,
4) Ms LI Jin,
5) Mr. ZHOU Zhonghui,
6) Mr. LIN Lan,
7) Ms ZHANG Xueyan,
8) Ms. ZARAKELI Adriana.

as well as the appointment of the Candidates (a) ZHOU Zhonghui, (b) LIN Lan, and (c) ZARAKELI Adriana, as independent non-executive members of the Board of Directors. [is noted that the Growthfund, in the exercise of its relevant constitutional right is entitled to appoint one (1) Member (ie in this case the 9th member of the Board of Directors) pursuant to article 79 of Law 4548/2018 as in force by announcing with a statement the appointment of the members to the Board of Directors of the Company, three (3) full days before the General Assembly.]

2) That the documents and information contained in the Candidates' dossier are complete and substantiate, without any doubt, that the Candidates meet all suitability and reliability criteria included in the Suitability Policy, for their election as members of the Company's Board of Directors, and, regarding the Candidates (a) Mr. ZHOU Zhonghui, (b) Mr. LIN Lan, and (c) Ms. ZARAKELI Adriana, the conditions of independence defined in article 9 par. 1 and 2 of law 4706/2020, as in force, as well as that there are no obstacles or incompatibility in the face of any Candidate in relation to any relevant provisions, including the Corporate Governance Code (HCGC) applied by the Company and the Rules of Operation of the Company.

[...]».

In consequence, it is proposed that the new Board of Directors of the Company have the following composition, which allows the fulfillment and enhancement of the Board of Directors' expertise in the field of the Company's activities, the implementation of the Company's strategy and the conduct of its daily operations, enhances the proper and effective exercise of the Board of Directors duties and responsibilities, reflects the size of the Company, its organization and its mode of operation, covering the main risks associated with it, strategic planning, corporate governance issues, the ability to identify and manage risks and the impacts of technology on the Company, includes members of different nationalities,

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strengthening the pool of skills, experience and vision that the Company has for its top positions, as well as its competitiveness, productivity and innovation, and fully meets the requirements of law 4706/2020 on corporate governance and fully covers the appropriate and appropriate exercise of its responsibilities for the benefit of its Shareholders, given that all the criteria of individual and collective suitability of the new candidate members of the Board of Directors of the Company are met, in accordance with article 3 of law 4706/2020, as in force, and the approved Suitability Policy of the Company, there are no obstacles or incompatibilities in the person of the new candidate members of the Board of Directors of the Company, regarding any provisions of the relevant legal framework of corporate governance, including the Corporate Governance Code implemented by the Company (Hellenic Code of Corporate Governance of HCGC of June 2021), the Rules of Operation of the Company and the approved Suitability Policy of the Company, there is no incompatibility / impediment of the provision of article 3 par. 4 of law 4706/2020 for any of the new candidate members of the Board of Directors, as in force, and there is an adequate representation per gender in a percentage that is not less than thirty three- percent (33%) both of all the members of the Board of Directors of the Company and its Executives members, with the resulting fraction being rounded to the previous integral number, according to articles 3 and 4 of Law 51758/2025, as in force, as from the eight (8) members are prosed three (3) women and five (5) men are proposed for election, while of the three executive members, one (1) woman and two (2) men are proposed for election.:

1) Mr. LIN Ji,
2) Mr. ZHU Changyu,
3) Mr. SU Xudong,
4) Ms LI Jin,
5) Mr. ZHOU Zhonghui,
6) Mr. LIN Lan,
7) Ms ZHANG Xueyan,
8) Ms. ZARAKELI Adriana.

A. As for the Mr. HAN Chao nomination proposal following the resignation of Executive Chairman Mr. LIN Ji , the Nomination Committee examined the below:

  1. General conclusion of individual suitability:
    Education – training
    Professional experience
    Personal skills
    Reputation, ethics, honesty, and integrity
    Allocating sufficient time

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  1. Determination of criteria of collective suitability. It is considered that the appointment of Mr. HAN Chao, who has progressive leadership experience in shipping, crew management, and organizational development within COSCO Shipping Group and proven expertise in corporate management, talent development, corporate governance and excellent performance results and driving strategic transformation, can add significant value to the operation of the Board. Therefore, he can actively and effectively contribute to the monitoring of issues related to the strategic planning, organization and further growth of the Company's business activity. Mr. HAN Chao can contribute to the identification and management of risks associated with the above, helping to safeguard the interests of all stakeholders to the best of his ability.

➢ The conducting of an Induction Training Program for BoD members whose main objectives were to (a) communicate the Company's vision and culture, (b) communicate practical procedural duties, (c) reduce the time taken for them to become productive in their duties, (d) become familiar with the Company's organizational structure, (e) give them an understanding of Company's business and strategy and the markets in which it operates, (f) to provide a link with the Company’s people and an understanding of its main relationships. Also, the BoD members, upon their appointment received information material of Company’s Obligations towards Supervisory Authorities, aiming to inform them on their main obligations under the legislative and regulatory framework that the Company operates.

➢ The organizing (in Dec. 2025), of a training session conducted by Hellenic Corporate Governance Council, in the thematic area “Key ESG concepts for board members and senior executives”.

➢ The evaluation of the fulfillment of the independence criteria of the Independent Non-Executive BoD Members, according to the definition of the law, as well as the evaluation of the existence of conflicts of interest to the extent that hinders the ability of Members to perform their duties independently and objectively will).

➢ The information towards the Company’s BoD about the issues within its competence. In carrying out its work in general, the Nomination Committee had full access to all the information necessary for the effective performance of its duties. The discussions and the decisions of the Nomination Committee are recorded in minutes signed by the members.

BoD and Committee Evaluation Process – Results of Evaluation Process

In compliance with the provisions of Law 4706/2020, Circular 60 of the Capital Market Commission, the Hellenic Code of Corporate Governance and the Internal Operating Regulations of the Board of Directors and in line with the commitment to adhering to leading corporate governance standards, the Company assigned the assessment of the adequacy and effectiveness of the Board of Directors and its Committees to an external consultant.Page 86 από 437
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The BoD Assessment Policy and the BoD Operation Regulation provides for the annual evaluation of the effectiveness of the Board of Directors (as a collective body), its committees and their individual members. To this end, as mentioned above, the Company awarded to the company KPMG Advisors Single Member SA for the Provision of Advisory Services to carry out the evaluation process. The evaluation concerned the collective abilities of the Board of Directors as a body, its committees and the individual abilities of its members. The evaluation was carried out using evaluation tools provided by the external advisor (filling out an electronic questionnaire, etc.) and through personal interviews. The evaluator had access to the BoD’s and BoD’s Committees operating details. The purpose of the evaluation was to determine whether the Board and its Committees function effectively and efficiently, based on the Board Directors’ responses to the online questionnaires covering a wide range of topics, documentation review and selected interviews with Board Directors.

The conclusion of the above evaluation states, among other things, the following:

Based on the evaluation of the Board of Directors and its Committees, with a reference date of March 18th, 2026, is mentioned among others:

No significant weaknesses have been identified in the performance of the Board, its Committees, or individual Board members. Furthermore, there are no immediate corrective actions required under the current legislative and regulatory framework. The Board’s performance remains stable, operating effectively, while, also, fostering an environment that encourages open and constructive discussions, where all Board Directors feel confident in expressing their views. The Board Committees (Audit Committee, Nomination Committee, Remuneration Committee) are functioning effectively, with each contributing significantly to the overall governance and decision-making processes of the Board, with the Nomination Committee demonstrating a strong contribution to the Board’s operations. In respect to the individual evaluation of each Board member, all Board members perform their duties effectively and demonstrate commitment to their role, as does the Chairperson of the Board. The Board has taken proactive steps to develop a long-term strategic plan, enhancing alignment with the Company’s broader business objectives. The above result is a confirmation of both the proper functioning of the Board of Directors and its compliance with the current legislative and regulatory framework.

E. Remuneration Committee Composition

The existing Remuneration Committee operates in accordance with the provisions of articles 10 and 11 of L.4706/2020. It is a Committee of the Board of Directors and is composed of three (3) non-executive

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members of the Board of Directors, and are independent in majority under the article 9 of Law 4706/2020, who were appointed by the BoD meeting that took place on 08.07.2025.

Until 07.07.2025, the Remuneration Committee’s composition was as follows:

  • ARVANITIS Nikolaos, Board of Directors independent Non-Executive Member and Chairman of the Remuneration Committee.
  • KWONG Che Keung Gordon, Board of Directors independent Non-Executive Member and Member of the Remuneration Committee.
  • POLITIS Dimitrios, Board of Directors Non-Executive Member and Member of the Remuneration Committee.

Since 08.07.2025 the Remuneration Committee’s composition is as follows:

  • LIN Lan, Board of Directors independent Non-Executive Member and Chairman of the Remuneration Committee.
  • POLITIS Dimitrios, Board of Directors Non-Executive Member and Member of the Remuneration Committee.
  • ZARAKELI Andriana, Board of Directors independent Non-Executive Member and Member of the Remuneration Committee.

The term of office of the Remuneration Committee will be equal to the term of office of the elected Board of Directors of the Company, whose term of office is two years, ie until 08.07.2027, which is extended, in accordance with the provisions of article 85, par. c of Law 4548/2018 until the expiration of the deadline, within which the next Ordinary General Meeting must be convened in 2027 and until the relevant decision is taken.

The members of the Remuneration Committee, all non-executive members, did not hold positions incompatible with their status during 2025, while both their objectivity and independence were ensured, in the absence of any transaction with the Company could affect they.

Evaluation of the Remuneration Committee

The Chairman of the Committee ensures the organization of the evaluation of the work of the Committee on an annual basis. In the above context, it was carried out both a self-evaluation process of the Remuneration Committee and an evaluation process by an external consultant based on the provisions of the Corporate Governance Code (article 3.3.14). The above process was carried out using evaluation tools provided by the external advisor (filling out an electronic questionnaire, etc.) and through personal interviews, which referred to the collective ability of the Remuneration Committee as a body, as well as to the individual abilities of its members. The conclusion of the above evaluation of the external consultant stated, among other things, that the Remuneration Committee is functioning effectively contributing significantly to the overall governance and decision-making processes of the Board.

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The above result is a confirmation of both the proper functioning of the Remuneration Committee and its compliance with the current legislative and regulatory framework.

Purpose - Responsibilities

The Remuneration Committee acts as an independent and objective body that assists the Board of Directors in the performance of its duties with regard to the remuneration of the Board of Directors and the executives of the Company. drawing up procedures and monitoring of the Remuneration Policy and the Remuneration Report of Articles 110-113 of Law 4548/2018. and is generally responsible for proposing, making decisions and expressing an opinion on any matter falling under Articles 109-114 of Law 4548/2018, either voluntarily or at the request of the Board of Directors or the General Assembly. The role of Remuneration Committee is fulfilled on the basis of the following responsibilities and duties through the procedures applied by it.

In particular, the Remuneration Committee in compliance with articles 109 to 114 of law 4548/2018:

a) formulates proposals to the Board of Directors regarding the remuneration policy submitted for approval to the General Assembly, in accordance with paragraph 2 of article 110 of law 4548/2018,
b) formulates proposals to the Board of Directors regarding the remuneration of persons falling within the scope of the remuneration policy, in accordance with article 110 of Law 4548/2018, and the remuneration of the Company's executives; and in particular the head of the internal audit service,
c) examines the information included in the final draft of the annual remuneration report, providing its opinion to the Board of Directors, before submitting the report to the General Assembly, in accordance with article 112 of law 4548/2018.
d) examines and submits proposals to the Board of Directors for the performance targets for any variable remuneration of the Executive Members of the Board and senior executives, and the objectives associated with rights or stock options.
e) examines and submits proposals to the Board of Directors (and, as such, to the General Assembly of Shareholders, when required) regarding any stock option or stock option plans.
f) submits proposals for the review and improvement of any process related to the drafting of the remuneration policy, the remuneration report and the determination of the information contained therein.
g) submits a report to the Board of Directors describing the way in which the Remuneration Report takes into account the result of the General Assembly vote on the previous Remuneration Report.

The responsibilities and the mode of operation of the Remuneration Committee are described in the Internal Rules of Operation of the Committee, which has been approved by the Board of Directors.

Exercise of duties of the Remuneration Committee

During 2025, the Remuneration Committee met ten (10) times.

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To ensure the independence of the Remuneration Committee, the meetings were held without the presence of other members of the Management, All the members of the Committee attended all the meetings and all the decisions of the Committee were taken unanimously.The main issues handled by the Remuneration Committee were the following:
➢ The submission of proposal to the Company’s BoD, for the setting up of the regular remuneration up to the amount of 40.000€ per annum, for each BoD member for the fiscal year 2025 (equal to the fiscal year 2024), as well as an annual gross maximum total compensation for the financial year 2025 of € 20,000.00 (equal to the fiscal year 2024) for the independent BoD members and Hellenic FUND representative for their participation in the meetings of the BoD Committees (Audit–Remuneration- Nomination Committees), regardless of the total number of BoD Committees in which they participate;
➢ The review and the afterwards submission of a proposal to the Company's BoD for the Remuneration Report of the members of the Board of Directors, taking into account the last vote at the General Assembly of Shareholders of the Company regarding the approval of the relevant report.
➢ The submission of a proposal to the Board of Directors of PPA SA for the granting of an extraordinary voluntary benefit of the Company's Top Management executives based on exceptional performance.
➢ The submission of a proposal to the Board of Directors of PPA SA for the granting of an extraordinary voluntary benefit to an executive of the Company's Senior Management based on his exceptional performance.
➢ The submission of a proposal to the Company's BoD regarding the remuneration of persons falling within the scope of the remuneration policy, in accordance with article 110 of N. 4548/2018. In particular, after a review, the following was approved the readjustment of Company’s CEO and DCEOs remuneration and the forwarding to the PPA SA BoD of respective formulated proposal that these remunerations are in line with the high level of responsibility related with the performance of the duties of the CEO and DCEO positions and can be supported by the Company's strong financial position.
➢ The granting of consent for the submission to the PPA SA Board of Directors " Incentives Plan for voluntary leave /retirement to Company’s personnel " as it has been prepared in a correct, balanced and understandable manner in its implementation, can be supported by the Company's strong financial position, and contributes to the sustainability of the Company, promoting its interests and ensuring its business continuity (through effective replacement of existing staff in a manner that will not negatively impact service delivery, operations, customer relationships).
➢ Conducting contacts of the Committee’s Chairman with the Senior Management of the Company on issues related to the responsibilities of the Committee.

In carrying out its work in general, the Remuneration Committee had full access to all the information necessary for the effective performance of its duties. The discussions and the decisions of the Remuneration Committee are recorded in minutes signed by the members.

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F. Strategy Committee

Composition

The existing Strategy Committee operates in accordance with the provisions of its Operation Regulation. It is a Board of Directors Committee and is composed by BoD and Top Management (DCEO level) members, six (6) of them having the BoD membership and one (1) to have the DCEO capacity, who were appointed by the BoD meeting that took place on 28.11.2025, with the below composition:
1. Company’s CEO and Executive BoD member Mr. SU Xudong, Chairman of the Strategy Committee.
2. Company’s BoD member and Vice chairman Mr. ZHU Changyu, member of the Strategy Committee.
3. Company’s CFO and Executive BoD member Ms. LI Jin, member of the Strategy Committee.
4. Independent Non- Executive ΒοD member Mr. LIN Lan, member of the Strategy Committee.
5. Non- Executive BoD member Mr. POLITIS Dimitrios, member of the Strategy Committee.
6. Non- Executive BoD member Ms. ZHANG Xueyan, member of the Strategy Committee.
7. Company’s Deputy CEO Mr. QU Shengbin, member of the Strategy Committee.

The term of office of the Remuneration Committee will be equal to the term of office of the elected Board of Directors of the Company, whose term of office is two years, ie until 08.07.2027.

Strategy Committee Evaluation

The above process did not take place as it was considered that the brief operation period (just one month) in 2025 was not sufficient itself for drawing safe conclusions.

Purpose - Responsibilities

The Strategy Committee acts as an independent and objective body that assists the Board of Directors in the performance of its duties on issues related to the general strategy of the Company, and also specifically on issues of strategy regarding sustainable development, as well as new technologies and innovation, including the Company's digital transformation and sustainability through innovative technologies. The ultimate goal of the Committee is the sustainable development and optimization of the Company's value. The role of Strategy Committee is fulfilled on the basis of the following responsibilities and duties through the procedures applied by it. In particular, the Strategy Committee in compliance with its operation Regulation:
(1) Stays up-to-date, evaluates, advises and expresses an opinion on the main long-term strategic goals of the Company and its medium-term strategy, in compliance with the guidelines and objectives set by the BoD.
(2) Stays up-to-date, evaluates, advises and expresses an opinion on Greek, European and international Sustainable Development trends, as well as the best practices that may have a significant impact on the Company's business activities and performance. In this context, it monitors the work of other international organizations and entities in Greece and abroad, respecting the principle of confidentiality and the rules of competition.

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(3) Stays up-to-date, evaluates, advises and expresses an opinion on the strategy relating to new technologies, innovation and transformation of the Company.
(4) Stays up-to-date, evaluates, advises and expresses an opinion on the strategy regarding issues of risk from digital and new technologies.
(5) Stays up-to-date, evaluates, advises and expresses an opinion on the strategy regarding the implementation of the Sustainable Development Policy, in accordance with the Company's relevant strategy.
(6) Monitors the implementation of the Company's strategy on a semi-annual basis, regarding the Company's strategic projects as well as innovation and digital transformation projects. Provides an opinion to the BoD in the framework of the preparation of the annual budget and the investment plan regarding the above.
(7) Examines and approves the process of defining the essential issues of sustainable development, validating, whenever appropriate, the results that form the structure of the Sustainable Development Annual Report of the Company.
(8) Stays up-to-date and approves the context of the Sustainable Development Annual Report of the Company.
(9) Organizes presentations in cooperation with Management at the invitation of Management or the BoD or on its own initiative in order to inform the BoD Members on the issues within its competence.
(10) Submits to the BoD a Regular Annual Report on matters of Strategy of the Company. It can also submit specialized reports on specific technologies or innovations when needed or requested by BoD.

The Strategy Committee assists the BoD in its responsibilities regarding the goals, the vision and the strategic direction of the Company. More specifically, in carrying out its purpose the Committee shall undertake the following duties and responsibilities:
i. Business Plan
Submits proposal to the BoD on the approval of the business plan, reviews it at least annually or where deemed necessary and monitor on a regular basis its implementation. To this effect, the Committee shall review all material information and documentation relating to planning and strategy (including for example, significant efforts on commercial model, operating model, technology, and ESG - Climate & Environment issues) and shall develop goals, vision and strategic initiatives as well as its main innovative programs and services, according to the needs of the Company, and innovative solutions based on changes in the market, the needs of the community and other factors
ii. Annual Budget
Reviews and proposes to the BoD for approval the Annual Budget of the Company and monitors its implementation on a semiannual basis.

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iii. Strategic and Organizational Transformation
Submits proposals with regard to initiatives taken in the context of strategic and corporate transformation, oversees related activities and monitors on a regular basis the implementation of Strategic and Corporate Transformation Projects undertaken by the Company.
iv. Corporate Structure related Actions, Strategic Transactions, Mergers, Acquisitions and Partnerships
Reviews all significant actions concerning Company’s structure, such as divestments, mergers, acquisitions of shareholdings in other companies or the creation of special purpose companies, the formation of joint ventures, partnerships and any other major investments by Company, apart from those which are purely related to Concession Agreement and where deemed necessary, make proposals, to the BoD on all of the above issues. To this effect, should be ensured that the Committee is apprised of all relevant, material information in a timely manner.Reviews transactions and provides guidance, as stipulated within the applicable Mergers and Acquisitions (M&A) and Partnership framework of the Company, as each time in force, in which context the Committee can engage in the early stages of a potential transaction and have a role in providing initial guidance.

v. Issues of strategic importance
Review and, as needed, make proposals to the BoD on other issues of strategic importance to the Company, as put forward for discussion by the Chair or the CEO, and in conjunction with the competencies of the BoD for discussion on matters of strategic importance.

Exercise of duties of the Strategy Committee

During 2025, the Remuneration Committee met once, given the fact that its establishment took place just one month before the year-end. The main issue handled by the Strategy Committee was the submission of a proposal to the Company’s BoD, for the approval of the Strategic Business Plan of the period 2025 - 2032 and its deliverables, which were related to be below:

Stage 1 “AS-IS ANALYSIS”
Stage 2 “MARKET ANALYSIS”
Stage 3 “STRATEGIC PLAN”
Stage 4 “INVESTMENT PLAN”
Stage 5 “FINANCIAL PROJECTIONS”

In carrying out its work in general, the Strategy Committee had full access to all the information necessary for the effective performance of its duties. The discussions and the decisions of the Strategy Committee are recorded in minutes signed by the members.

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a) Periodic Evaluation Policy of the Internal Control System of PPA SA and Implementation of the provisions on Corporate Governance of Law 4706/2020

1. Key Elements

The Company recognizing the importance of the operation of an adequate and integrated Internal Control System (hereinafter "ICS") to achieve its business objectives and in accordance with Law 4706/2020 regarding corporate governance and decision of the BoD of the Hellenic Capital Market Commission 1/891/30.09.2020 as in force from time to time, adopts the present policy of periodic evaluation of the Company's ICS as well as of the Implementation of the provisions on Corporate Governance of Law 4706/2020.

The Company's ICS includes five (5) basic elements that exist and operate in the Company and are described in general terms below:

a. Control Environment

The Company is committed to operate with integrity and ethical values. Its organizational structure determines a specific position and specific and distinct responsibilities for each body and organizational unit of the Company. There are specific benchmarks and areas of responsibility in achieving the Company's goals, while a regulation is followed on the selection and recruitment of staff and senior management as well as a remuneration policy aiming at attracting and retaining highly qualified human resources.

In particular:
* Integrity, Moral Values & Top Management Behavior: The Management of the Company provides direction, leadership as well as an appropriate environment for its operation, in order to ensure that all its available resources are fully utilized to achieve its objectives. The Company has a Code of Conduct. Any deviation is reported to the Top Management which is solely responsible for taking relevant actions.
* Organizational structure: The Company maintains an organizational structure sufficient for the planning, execution, control and supervision of corporate operations for all its Departments and operational activities, according to which the main areas of responsibility are determined while at the same time the appropriate reference lines are established.
* BoD: The BoD follows the Law, the Bylaws or the needs of the Company dictate and decides on any matter concerning the management of the Company, the management of its assets and the general pursuit of its purpose. The BoD maintains adequate oversight of the operation and effectiveness of the ICS. For this purpose, it consists of a sufficient number of executive, non-executive and independent non-executive members, with a variety of knowledge, skills and experience in order to achieve the business model and strategy of the Company.
* Corporate Responsibility: The Company maintains appropriate structures and pursues policies that promote the principle of responsibility, the speed of decision making, the smooth operation of the Company, and the effective control of all its actions. Based on this principle, responsibilities are assigned to the executives of the Company, according to their position in the hierarchy and their qualifications.

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Furthermore, the Company forms the framework to enable the individual organizational units to operate within the components of the specific management authority (Responsibility – Accountability Obligation - Assumption of Responsibility), as well as the Management to control its effectiveness.

  • Human Resources: Recognizing the utilization of human resources as a cornerstone for the achievement of the Company's goals, the Company pursues specific policies of recruitment, training, remuneration, and evaluation of staff.
b. Risk Management

The Organization’s risk management methodology constitutes a structured framework of strategic importance for identifying, assessing, and addressing threats that may impact the achievement of business objectives. The primary goal is to minimize uncertainty and limit negative consequences through a proactive approach. The core stages of the methodology are:

  • Risk Identification: Identifying and recording internal and external risks (financial, technological, legal, geopolitical, operational, etc.) using tools such as SWOT analysis, executive interviews, and historical data analysis. The scope includes factors classified into categories such as financial, technological, legal, operational, and human resources.
  • Risk Assessment: Estimating the probability of occurrence and the severity of impact. The assessment combines qualitative and quantitative criteria to prioritize risks using a Risk Heat Map.
  • Risk Response: Designing and implementing response strategies, such as avoidance, mitigation, transfer, or conscious acceptance of the threat.
Reporting & Monitoring System

Seeking maximum transparency and timely decision-making, the Company has established a strict reporting schedule:

  • Monthly Risk Reports: These focus on monitoring Key Risks for each functional unit and analyzing significant events. They serve as an Early Warning system, recording deviations from tolerance limits and allowing for immediate corrective intervention at both the departmental and organizational levels.
  • Quarterly Risk Reviews: These provide a holistic analysis of the Company’s risk profile, presenting trends of the most significant risks and the progress of mitigation plans, while proposing strategic revisions to Management and the Audit Committee.
  • Annual Comprehensive Assessment: A full update of the Risk Registry is conducted across all Company activities.

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Risk Management Unit

The Company maintains a Risk Management Unit that utilizes effective policies and tools (Risk Registry, Risk Assessment, Historical Data, and KRIs) for identifying and managing every form of risk. The implementation of Key Risk Indicators (KRIs) per department enables early detection and transforms risk management from a formal compliance procedure into a dynamic management tool that enhances operational resilience.

c. Control Mechanisms and Security Controls

The Company develops policies and procedures aligned with Management’s objectives. It implements a system of safeguards based on identified risks while considering its unique organizational characteristics. Specific evaluations are conducted regarding the adequacy and correct application of procedures, the handling of errors, and the frequency of policy re-evaluations.

As part of strengthening corporate governance, the Organization has established the Risk Management and Compliance Committee. This Committee acts as an advisory body to the Board of Directors with the following primary missions:

  • Oversight & Strategy: Approving risk management policies and ensuring that the Organization’s strategy aligns with the defined Risk Appetite.
  • Regulatory Compliance: Ensuring full alignment with the current legislative and regulatory framework to prevent legal or reputational risks.
  • Report Review: Evaluating monthly and quarterly risk reports and monitoring the implementation of Mitigation Plans.

In addition, the Company implements adequate security controls for issues of conflict of interest, segregation of duties, as well as the governance and security of its information systems.

d. Cοmmunication System

The Company ensures the quality of financial and non-financial information and follows appropriate ways of internal and external communication, such as communication with the members of the BoD, shareholders and investors, communication with the existing Company committees, complaint on whistleblowing, Regulatory Authorities etc.

e.Monitoring of the ICS The Company has mechanisms and functions that have as object the continuous evaluation of the ICS and the reporting of findings to be corrected or improved:

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Audit Committee

The Company has an AC, which is a committee of the BoD, consists in its majority of independent non- executive members of the BoD and its goal is to support the BoD fulfilling its responsibilities for overseeing compliance control procedures with the legislative and regulatory framework on:
(a) financial information,
(b) the ICS, the risk management system, the regulatory compliance system and
(c) its supervision of the (external) statutory audit of the financial statements of the Company.

Internal Audit Department

The Company has an Internal Audit Department, which operates in accordance with the applicable Regulation approved by the BoD. The Internal Audit Department is organizationally independent and adequately staffed. Implements the appropriate tools and control methodology in order to achieve the best result, while the audit reports that are prepared are submitted at least quarterly to the AC and then to the BoD.

The responsibilities of the Internal Audit Department, are the following:
a) To monitor, audit and evaluate:
* the implementation of the Internal Organization & Operation Regulation and the ICS, in particular as to the adequacy and accuracy of the provided financial and non-financial information, risk management, regulatory compliance and the Code of Corporate Governance adopted by the Company,
* the internal controls of quality assurance
* corporate governance mechanisms, and
* the compliance with the commitments contained in newsletters and the Company's business plans regarding the use of funds raised from the regulated market.
b) To prepare reports to the audited Departments with findings regarding tasks, the risks arising from them and suggestions for improvement, if any. The reports, after incorporating the relevant comments of the audited Departments, the agreed actions, if any, or the acceptance of the risk of non-action by them,the limitations on its scope of audit, if any, the final internal audit proposals and the results of the response of the audited Departments of the Company to its proposals, are submitted at least quarterly to the AC.
c) To inform the AC on a monthly basis about its activities, the audits carried out and the progress of its work.
d) To submit at least every three (3) months to the AC reports, including its most important issues and proposals, regarding the tasks a) and b), which the AC presents and submits along with recommendations to the BoD.

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Regulatory Compliance Unit

The Company has a Regulatory Compliance Unit (RCU), which is functionally independent and its staff has sufficient knowledge, experience to carry out its responsibilities, appropriate training and information to monitor the effective adoption and smooth implementation of the changes that take place in a regulatory and legislative context and concern the Company. The Manager and the members of the RCU have received a Compliance Officer Certification according to the international standard ISO/IEC 17024 and have attended numerous specialized training courses, seminars and conferences, receiving the corresponding certificates.

The main mission of RCU is the establishment and implementation of effective and updated policies and procedures, in order to accomplish timely and continuous compliance of the Company with the applicable regulatory framework and to have a full picture at all times of the degree of achievement of this objective, through the effective management of regulatory and statutory implementation as a prerequisite for high standards of Corporate Governance leading to high efficiency and optimal operational performance.

The purpose of RCU is the preparation and implementation of the appropriate procedures methodology for the regulation, assessment and management of the Company's policies and procedures in accordance with the existing legislation, and the general coordination of the relevant process through the Company's Departments. RCU must comprehend future changes in the regulatory field, while having the appropriate response at the process level. It monitors the effective adoption and smooth implementation of changes that take place in the regulatory framework, having direct access to all sources of information required for the proper performance of its tasks.

RCU with direct reporting line to the Audit Committee and Top Management, has the following responsibilities:
* operates as an advisory and preventive service on Company's compliance within its legal and regulatory obligations,
* adopts appropriate and updated policies and procedures, monitors and reviews their proper implementation, and proposes solutions to issues that need improvement or development,
* communicates with the supervising Authorities and try to resolve any problems that arise,
* designs processes, integrating security safeguards to mitigate risks and monitors their proper implementation,
* drafts an annual action working plan which is subject to approval by the Audit Committee and includes the compliance audits to be conducted,
* replies to questions raised by Departments, related to responsibilities that RCU already has, such as new legislation and harmonization of Departments with them.

RCU assess possible regulatory risks, arising from the non - application or deviant behavior of legal and regulatory framework, in order to predict, process and reduce potential negative impact. The responsibilities of RCU, as defined and specified by the Law and the instructions of the Capital Market Commission as in force, are indicative by the following:
* mapping of the systemic difficulties and compliance weaknesses within the Company and making recommendations to resolve them,
* cooperation with relevant Departments and provision of information, suggestions and strategic references in relation to regulatory compliance issues,
* regular cooperation, communication and interaction with Top Management, having full access to Company’s Data, while monitoring the work of the relevant Committees,
* establishment and implementation of appropriate and updated practices, policies and procedures aiming to timely and full compliance of the Company with the applicable legislative framework on National and European level,
* assessment of the new procedures and practices, as to their nature and complexity, contribution to the enhancement of corporate governance through compliance audits and other Regulatory Compliance tools.

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2. General Description

The Company in the context of ensuring the continuous operation of an adequate and integrated ICS and the continuous improvement where and when deemed appropriate, follows this policy, which sets out the framework for periodic evaluation of the ICS and implementation of the provisions on Corporate Governance of Law 4706/2020 that is in effect and governs its operation.

3. Legal and regulatory framework

The content of this policy fully complies with Law 4706/2020 and the relevant decision 1/891/30.09.2020 of the BoD of the Hellenic Capital Market Commission. The terms of periodic evaluation policy of CGS are applied in combination with the respective provisions of the Company's Internal Organization and Operation Regulations, the Regulations of the AC, the Internal Audit Department, the Regulatory Compliance function and the Risk Management function.

4. Policy Purpose

The purpose of this policy is to establish the framework to ensure the timely and correct implementation of the periodic evaluation of the ICS based on the respective standards by appropriate evaluators and the compliance of the Company with the applicable legislation on relevant corporate governance matters.

5. Policy Scope - Compliance

This policy applies to Top Management, the collective bodies and all the organizational units of the Company, its processes and functions, as well as its Information Systems. The Top Management, the collective bodies and all the organizational units are obliged to comply with the content of this policy.

6. Policy Subject

The subject of this policy includes the general principles regarding the object, the periodicity of the audit, the scope of evaluation and the general process which governs the periodic evaluation of the Company's ICS as well as the Implementation of the provisions on Corporate Governance of Law 4706 / 2020 as well as the assignment and monitoring of the results of the evaluation and the determination of the object of the evaluation.

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7. Evaluation Process

7 a. General

The periodic assessment of the adequacy of the ICS is carried out on the basis of international best practices. The purpose of the evaluation is to evaluate the system of identification and risk management and regulatory compliance developed by the Company, the system of safeguards that applies to the adequacy and effectiveness of financial information, as well as the application of corporate governance provisions of the Law. 4706/2020.

7 b.# Subjects of evaluation

Subject of the evaluation are the following:

  • Control Environment The review of the control environment consists mainly of the following:
    • ▪ Integrity, Morals & Conduct of the Management
    • ▪ Organization structure
    • ▪ BoD
    • ▪ Corporate responsibility
    • ▪ Human Resources
  • Risk Management It consists of the review of the risk acknowledgement and assessment procedure (risk assessment), management and response procedures of the Company to the said risks (risk response) and the procedures on the monitoring of the development of the risk (risk monitoring).
  • Control Activities Review of the mechanisms on the control of the critical safety net emphasizing on the safety net related to conflict of interest issues, separation of duties and governance and security of Information Systems.
  • Information and Communication Review of the procedure of the development of the financial, including the reports of the auditing mechanisms and non-financial information as well as the review of the procedures on the critical internal and external communication of the Company.

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  • Monitoring of ICS Review of the infrastructure and the mechanisms of the Company that are competent for the constant evaluation of the components of the ICS and the report of the findings to be corrected or improved. In particular, the operation of the following infrastructure and mechanisms are reviewed:
    • ▪ Audit Committee
    • ▪ Internal Audit Department
    • ▪ Regulatory Compliance

7 c. Timing – periodicity

The evaluation of the ICS is carried out either periodically or on an ad hoc basis. Periodicity is defined as the time period between two consecutive evaluations and which is determined in three (3) years starting from the reference date of the last evaluation. The time is defined as the time at which it is required to carry out either the periodic evaluation or the ad hoc evaluation at the request of the Hellenic Capital Market Commission. In any case, the evaluation of the ICS is part of the overall evaluation of the corporate governance system of the Company, according to article 4 par. 1 of Law 4706/2020. The first evaluation of the ICS for the period 17.07.2021 – 31.12.2022 is completed and forwarded to the Capital Market Commission, according to the provisions of this decision, as in force to the law 4706/2020. The second evaluation of the ICS for the period 01.01.2023 – 31.12.2024 is completed (as a preparation for the next evaluation to be carried out by 31.03.2026, with a reference period of 01.01.2023 - 31.12.2025),, discussed and its results were approved both by the Audit Committee (meeting of 27.03.2025) and the BoD (meeting of 31.03.2025)

7 d. Characteristics of the persons that carry out the evaluation

The evaluator is a legal or natural entity or association of persons. The evaluator shall have the following characteristics:

Matters of independence and objectivity

When selecting the evaluator of the ICS, matters of independence and integrity of the Company are taken into consideration. The evaluator and the members of his taskforce must be independent and do not have any dependency according to par. 1 of article 9 as particularized in par. 2 of Law 4706/2020 as well as be objective in the course of exercising his duties. When the evaluation is carried out by a physical person in the context of an employment or cooperation relationship with a legal entity, the dependency relationship concerns the physical pearson himself and not necessarily the legal entity with which he has an employment or cooperation relationship. Objectivity is the impartial attitude and ways of thinking that shall allow for the evaluator to perform his duties as he thinks proper and do not settle as to its quality. The objectivity requires for the evaluator not to be affected by third parties or other facts.

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In the course of ensuring the independence and the objectivity, the evaluation of the ICS shall not be carried out by the same evaluator for three subsequent evaluations.

Proven relevant professional experience and training

When selecting the evaluator of the ICS matters related to the knowledge and his professional experience are taken into consideration. In particular, the head of the taskforce of the evaluation of the ICS and in any case the signatory of the evaluation must have the appropriate professional qualifications (depending on the professional standards that he refers to) as well as proven relevant experience (such as in evaluations of other ICS and structures of corporate governance). The evaluator implements all the necessary measures in order in the course of his work the persons that participate therein have the appropriate knowledge and experience as to the duties assigned to them and he uses the suitable systems on quality assurance, sufficient human and material resources and procedures in order to ensure the continuity, periodicity and quality of the performance of the works.

7 e. Candidates selection and award of evaluation – Responsibilities

The Company assigns timely, through its competent bodies, the evaluation of the ICS to a suitable external evaluator. Specifically:

Within a reasonable time and at least six months before the date of mandatory submission of the final evaluation report to the Hellenic Capital Market Commission, the AC arranges for the selection of suitable candidate or candidates to submit a tender within a specific deadline, after the relevant invitation (7 d). Interested parties are invited to submit a bid within a specific deadline specified in the relevant invitation, where relevant reference is especially made to the independence and proven experience and training in relevant ICS and corporate governance structure evaluation projects as defined in point (7 d). The submitted offers are reviewed and evaluated by the AC, which proposes as the competent body to the BoD, the assignment of the evaluation of the ICS to an appropriate at their discretion candidate, considering the independence and professional experience of the candidate. The BoD decides upon the assignment of the project of the periodic evaluation of the ICS to the appropriate evaluator. The Regulatory Compliance function and / or the Internal Audit Department, under the guidance of the AC, facilitate the evaluator during the implementation of his project regarding the communication and cooperation with the various bodies or Departments of the Company.

7 f. Evaluation report and recipients

The evaluator carries out the evaluation of the ICS, within the agreed schedule and upon completion submits an evaluation report, which should at least include:

  • ▪ Summary of test results and a detailed description of them;
  • ▪ The time of submission of the evaluation report;
  • ▪ The reference date of the evaluation and the period it covers (which starts from the next day of the reference date of the previous evaluation).

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The summary includes the evaluator’s conclusion regarding the adequacy and effectiveness of the ICS. It also includes the most important findings of the evaluation, the risks and the consequences arising from them as well as the response from Top Management to these findings, including the relevant action plans with clear and realistic timetables. The detailed report includes all the findings of the evaluation with the relevant analyses. Recipients of the report are defined the AC and the BoD. The Company submits without delay to the Hellenic Capital Market Commission, and in any case within three (3) months from the reference date of the evaluation report, the report and, if required, the detailed report. The annual declaration on corporate governance includes a relevant reference on the results of the Evaluation Report, the response of the Company’s management through a competent body decision, as well as the action plans of the Company with the relevant time plans.

8. Relevant documents – references

Reference of this policy is made to the Internal Organization and Operation Regulation of the Company as it applies, the Regulation of operation of the AC and the Internal Audit Department and the Hellenic Corporate Governance Code adopted by the Company.

9. Force – Exceptions

This policy shall enter into force on the date of its adoption and shall not be subject to any exceptions.

10. Policy Update

This Policy will be evaluated for update when significant changes are identified in the covered area or upon the implementation of legislative changes.

VI. b) Results of the process of the evaluation of the ICS of PPA S.A. for the period 01-01-2023 until 31-12-2025

The Company, by decision of its BoD, assigned to KPMG Certified Auditors S.A. the assessment of the adequacy and effectiveness of the ICS of the Company, with reference date of 31 December 2025. In accordance with the provisions of section j of par. 3 and par. 4 of article 14 of L. 4706/2020 and decision 1/891/30.09.2020 of the Capital Market Commission’s BoD as applicable (the "Legislative Framework"). and the Letter of the Capital Market Commission with protocol number 434/24.02.2025, the Company will carry out the next ICS evaluation by 31.03.2026, with a reference period of 01.01.2023 - 31.12.2025).The assurance was carried out in accordance with the audit program included in the decision of the Hellenic Accounting and Auditing Standards Oversight Board (HAASOB), number 278/16.01.2026 and the International Standard on Assurance Engagement 3000 (updated) "Assurance Engagements other than Audits or Reviews of Historical Financial Information". Based on the work carried out on March 27, 2026 by the evaluator and the evidence obtained regarding the assessment of the adequacy and effectiveness of the Company’s ICS, is reported that nothing was identified that could be considered as a material weaknesses of ICS according to the Regulatory Framework.

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This result for the period 01-01-2023 until 31-12-2025 is one more confirmation that the Company is constantly vigilant in order to ensure, through continuous review and taking corrective actions, its compliance with the applicable legislative and regulatory framework governing the ICS with the aim of its lawful and orderly operation.

VII. a) Evaluation Policy of the Corporate Governance System

1. Introduction

The Company recognizing the importance of ensuring the continuous operation of an adequate and complete Corporate Governance System (hereinafter referred to as the "CGS") and its continuous improvement, where and when deemed appropriate, for the achievement of its business objectives and in compliance with Law 4706/2020 on corporate governance, adopts this policy of Periodic Evaluation of the Corporate Governance System (the "Policy").

2. Key elements

The scope of this policy includes the basic principles of the evaluation of the pillars of the CGS in terms of periodicity and evaluation scope, the roles involved and the general process by which the evaluation of the Company's CGS is carried out.

The Company's CGS includes the following:
a) ICS, including risk management and compliance systems,
b) Procedures for preventing, detecting and addressing conflict of interest situations;
c) Communication mechanisms with shareholders to facilitate the exercise of their rights and active dialogue with them (shareholder engagement);
d) Remuneration policy, which contributes to the business strategy, long-term interests and sustainability of the Company.

The Company through the (a) Audit Committee (b) Internal Audit Department (c) Regulatory Compliance Unit (d) Risk Management Unit has mechanisms and functions that have as their object the continuous evaluation of the CGS and the reporting of findings for correction or improvement.

Procedures for preventing, detecting and suppressing situations of conflict of interest

The Company has established and implements a policy and procedure for preventing and dealing with conflict of interest situations, through which it seeks (a) the indicative recording of any harmful situations that may arise for the interests of the Company, its shareholders, customers, and suppliers, (b) the establishment and implementation of procedures, mechanisms and systems for managing conflicts of interest and (c) the design and implementation of procedures and systems for the prevention and deterrence of potential losses to the interests of the Company, its shareholders, its customers and its suppliers.

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Mechanisms of communication with shareholders

The Company has an Investor Relations sector to promote active dialogue with its shareholders. The main responsibilities of the specialized sector are (a) the design and implementation of the Company's communication strategy, the service and information of shareholders and other third parties, as well as the compliance with the obligations arising from the relevant legislation, regarding the services of shareholders and the company's announcements on the Athens Exchange market, (b) maintaining and developing relationships with investor’s community, institutional analysts and Company’s shareholders and (c) organizing meetings, conference calls and other events to inform investors and drafting of corporate presentations for meetings with institutional investors in Greece and abroad.

Remuneration policy

The Company, in compliance with the legislative and regulatory framework governing its operation, has established a remuneration policy. The purpose of the policy is to ensure that the Company remunerates BoD members based on its short- and long-term business plan, so as to continue to create value for its customers, shareholders and employees.

3. General Description

The Company, in the context of ensuring the continuous operation of an adequate and comprehensive CGS and continuous improvement where and when deemed appropriate, follows this policy, which constitutes the framework for periodic evaluation of the CGS.

4. Legal and Regulatory Framework

The content of this policy is governed by Law 4706/2020 as in force from time to time, the decisions of the Hellenic Capital Market Commission issued under its authority, certain provisions of Law 4548/2018 on sociétés anonymes and the principles and best practices and recommendations of self-regulation incorporated in the Greek Corporate Governance Code which the Company has adopted in accordance with a decision of its BoD.

5. Policy Purpose

The purpose of this policy is to establish the framework to ensure the timely and correct implementation of the CGS and the Company's compliance with the applicable legislation on relevant corporate governance issues and corporate governance principles.

6. Policy Scope – Compliance

This policy applies to the evaluation of the CGS of PPA SA. The BoD defines and supervises the implementation of the CGS, monitors and evaluates its implementation and effectiveness, taking appropriate actions to address deficiencies.

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7. Policy Scope

The scope of this policy includes the basic principles of the evaluation of the pillars of the CGS in terms of periodicity and scope of evaluation, the roles involved and the general process by which the evaluation of the Company's CGS is carried out.

8. Assessment Objectives

The following are the main pillars of evaluation:
(a) Internal Control System: The company's ICS is evaluated by an external evaluator, in accordance with the approved Periodic Evaluation Policy of the ICS of PPA S.A. and the Implementation of the provisions on Corporate Governance of Law 4706/2020, as included in the Internal Organization and Operation Regulation of PPA SA. In any case, the evaluation of the ICS is part of the overall evaluation of the Company's CGS, in accordance with article 13 of Law 4706/2020.
(b) Procedures for preventing, detecting and combating conflict of interest situations: The Company has established and implements multiple safeguards to prevent and detect situations of conflict of interest. These include the adoption of the Code of Ethics by all staff and members of the BoD of PPA S.A., the submission of an Annual Declaration of meeting the Independence criteria, Confidentiality and Non-Conflict of Interest situations (for independent Non-Executive Members of the BoD), the submission of an Annual Declaration of Confidentiality and Non-Conflict of Interest situations (for BoD Members (except Independent) and Members of Senior Management) and the submission of a Declaration of Independence for employees involved in tendering procedures.
(c) Communication mechanisms with shareholders to facilitate the exercise of their rights and shareholder engagement: The mechanisms of (a) immediate, accurate and equal information to shareholders, as well as their support, regarding the exercise of their rights and (b) adequate information to shareholders and compliance of the Company with the obligations provided for in article 17 of Regulation (EU) 596/2014, regarding the disclosure of inside information, are reviewed.
d) Remuneration Policy: The Remuneration Policy is reviewed and evaluated in terms of:
- compliance with Law 4548/2018,
- compliance with the respective Corporate Governance Code adopted by the Company,
- its contribution to the long-term interests and viability of the Company.

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9. Evaluation Process

9.a. General

The purpose of the evaluation is to monitor the implementation, application and effectiveness of the CGS as defined by the BoD in the context of provisions 1 to 24 of Law 4706/2020 as in force from time to time, and the Greek Corporate Governance Code as adopted by the Company.

9.b. Time - periodicity

The evaluation of the CGS is carried out periodically at least every three (3) financial years and coincides with the periodic evaluation of the ICS except for the first evaluation which will concern the period 17/07/2021 to 31/12/2024.

9.c. Selection of candidates and assignment of assessment

The Company ensures, through its competent bodies, that the competent evaluator of the CGS is determined, either through internal resources or by assignment to an external evaluator. Interested parties are evaluated in terms of independence and proven experience in relevant CGS evaluation projects. The AC recommends, as the competent body, to the BoD the assignment of the task of evaluating the CGS to the appropriate evaluator, according to its judgement. The BoD by decision decides the assignment to the appropriate evaluator.

9.d.Evaluation report and addressees The evaluation report of the CGS shall contain the following:

  • Summary of the audit results and their detailed description;
  • The timing of the evaluation report;
  • The period covered;
  • The conclusion regarding the Corporate Governance System.

The recipient of the evaluation report is the BoD of the Company. A relevant reference is included in the Corporate Governance Statement, which will be included in the respective Annual Financial Report.

  1. Validity - Exceptions
    This policy is effective from the date of its adoption and is not subject to exceptions.

  2. Review of the Policy
    This Policy will be evaluated for any update when significant changes/developments are identified in the area covered or in implementation of legislative changes.

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VΙΙ. b) Results of the process of the evaluation of the CGS of PPA S.A. for the period 01-01-2025 until 31-12-2025, in accordance with article 4, par. 1 and article 13 par. 1 of L. 4706/2020 and the relevant letters of the Capital Market Commission (prot. no 434/24-02-2025 "Comments, clarifications and recommendations regarding the actions of listed companies in view of the assessment of the CGS and the implementation of the law 4706/2020, in order to comply with its provisions, with a view to assessing the Company's CGS for the period 01.01.2025- 31.12.2025”).

The Company, by decision of its BoD, following respective recommendation of AC, decided the conducting of the evaluation process of the CGS through internal resources and specifically by the Regulatory Compliance Unit. The content of this policy fully complies with Law 4706/2020 and the relevant decision 1/891/30.09.2020 of the BoD of the Hellenic Capital Market Commission. The terms of periodic evaluation policy of CGS are applied in combination with the respective provisions of the Company's Internal Organization and Operation Regulations, the Regulations of the AC, the Internal Audit Department, the Regulatory Compliance function and the Risk Management function. Detailed presentation of the regulatory framework considered in the evaluation, the methodology adopted, the material evaluated and evaluator’s findings, which do not constitute material weaknesses, have been recorded in the Analytical Report to the AC and BoD of the Company. This result constitutes one more confirmation that the Company is in constant compliance with the current legislative and regulatory framework governing the CGS to ensure the lawful and orderly operation towards achieving its sustainable development strategy.

VΙΙΙ.Diversity Policy applied in relation to the Company’s administrative, managerial and supervisory bodies

Description of the policy of diversity with regard to the administrative bodies of the Company

Given the fact the BoD is the highest administrative body of the Company, which is responsible for the safeguarding of the broader corporate interests, the policy making and the growth strategy of the Company as well as for the strengthening of the long-term economic value of the Company, it is very essential for the particular body to possess, with regard to its composition, a diversity of skills, views and abilities which at the same time respond to the need to effectively attain corporate goals.

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From the time of the Company’s establishment and until today, the entire members of the BoD fulfill all necessary conditions and have set the foundations in order to be granted with the capacity of the member of the BoD. At the same time, they are distinguished for their high professional skills, educational level, knowledge, capabilities, experiences and their organizational and administrative abilities, and at the same time they possess high standards of ethics and integrity of character. The members of the BoD cover a broad range in terms of age combining effectively their dynamics and experience. The members, in their majority, are holders of graduate and postgraduate degrees of domestic as well as international universities, have worked in high ranked positions of major companies domestically and abroad. They have also been members of the higher managerial staff of large organizations and as a result they possess significant international experience in the corporate as well as the broader social fields and are in position to actively contribute to the growth prospects of the Company. They finally fulfill the requirements of suitability as well as the criteria with regard to the Company’s effective staffing and operation. The current composition of the BoD aims undoubtedly at the best possible facilitation of corporate goals, as it increases the pool of skills, experience and vision that the Company has for its highest-ranking personnel, and consequently its competitiveness, productivity and innovation. The current nine-member BoD of the Company, consists of 6 men and 3 women and was elected in the framework of the decision of the Company’s Management for immediate, substantial and effective compliance and harmonization with the provisions of the law 4706/2020, as amended and in force after law 5178/2025, on suitability, diversity and, above all, adequate representation by gender on the BoD and completely covers the appropriate exercise of the responsibilities of the BoD of the Company, reflects the size and activity of the Company and its characteristic feature is diversity of knowledge, skills and experience that can contribute to the achievement of business objectives.

Procedure to comply with the obligations arising from Articles 99 to 101 of law 4548/2018, regarding transactions with related parties

The Company recognizes the importance of its compliance with the obligations arising from articles 99 to 101 of Law 4548/2018, regarding transactions with related parties, to ensure the smooth and efficient operation of the market. Therefore, the Company establishes the following procedure of compliance with the obligations arising from articles 99 to 101 of Law 4548/2018, regarding transactions with related parties:

The Group to which the Company belongs, maintains a list of related parties, from which the Company has the opportunity to obtain relevant information.

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Contracts of the Company with related parties, as well as the provision of security and guarantees to third parties in favor of such parties, within the meaning of articles 99-101 of Law 4548/2018, are only permitted upon prior authorization by the BoD or, in the case of paragraph 4 of this article, by the GA. Related parties with respect to the Company are those parties defined as related parties of the Company pursuant to International Accounting Standard 24, as well as the legal entities controlled by them, pursuant to International Accounting Standard 27. In the case where, a contract with a related party of the Company is awarded after and according to tender procedures, as they are described in the approved and posted on the Company's website Regulations for the Award of Contracts and Sub-concessions of the Company, the above paragraph is not followed. The BoD may grant authorization, pursuant to the preceding paragraph, which is valid for six (6) months. In the case of recurring contracts with the same person, a single authorization may be provided that sets forth the characteristics of the contracts concerned and is valid for one (1) year. Within ten (10) days as of the publication of the notice on the granting of the said permission by the BoD, shareholders representing one twentieth (1/20) of the paid-in share capital may request the convocation of the GA in order for the GA to adopt a resolution on the matter of the said permission. The contract for which permission has been granted by the BoD shall be considered as effective only after the lapse of the said ten-day time period or upon securing the permission of the GA or upon a written statement by all shareholders to the Company to the effect that they do not intend to request the convocation of the GA. If by the time permission is granted by the GA, the contract under par. 1 of this article has already been concluded or the guarantee or security has been provided, then the granting of permission by the GA is canceled if objected to by shareholders representing one twentieth (1/20) of the capital represented at the Meeting. If the transaction involves a shareholder of the Company, the shareholder concerned does not take part at the vote in the GA and is not counted for the purposes of quorum and majority. Other shareholders with whom the counterparty is related under a relationship falling under paragraph 2 of article 99 of Law 4548/2018 will not take part in the vote either. This paragraph is not applicable when permission by the BoD was given with the concurrence of the majority of its independent members. In all cases, the granting of permission by the GA is canceled if opposed by shareholders representing one third (1/3) of the capital represented thereat. If the permission for the conclusion of the contract was given by the GA, any amendments thereto may be made under permission by the BoD, unless the GA has reserved for itself the right to authorize such amendments as well.Page 110 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Decision thereon by the BoD or the GA is made on the basis of a report by a certified public accountant or auditing firm or other third party unrelated to the Company, that assesses whether the transaction is fair and reasonable for the Company and shareholders who are not a related party, including the minority shareholders of the Company, and explains the assumptions on which it has relied together with the methods employed. The BoD issues a notice about the granting of permission to the conclusion of the contract by the BoD itself or by the GA, and the lapse of the time period set forth in paragraph 4 of the present article. Such notice is published prior to the conclusion of the transaction. An inaccuracy in the notice cannot be invoked towards third parties, unless the Company demonstrates that such third parties were aware of the inaccuracy in question. The notice shall as a minimum include information: (a) on the nature of the relationship of the Company to the related party; (b) the date and value of the transaction; (c) any other information as necessary in order to assess whether the transaction is fair and reasonable for the Company and those persons who are not a related party, including the minority shareholders. The said notice is accompanied by the report referred to in the preceding paragraph. A transaction entered into between the related party of the Company shall also be subjected to the publication formalities.

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Board of Directors Explanatory Report (according to article 4, par. 7 and 8 of Law 3556/2007)

The present explanatory report of the Company’s BoD to the annual GA of Shareholders is an integral part of the Annual Report of the BoD.

Share capital structure

The Company’s share capital amounts to Euro fifty million (50,000,000€) and is divided into 25 million ordinary shares, of a nominal value of Euro two (€2,00) each. Each share is entitled to one vote. The Company’s shares are dematerialised and listed to trading on the Athens Stock Exchange. According to the Company’s Articles of Association, the Company’s shares and rights deriving therefrom are indivisible and, in case of joint ownership, the joint owners exercise their rights through a common representative, whereas each joint owner is jointly and severally liable to the Company for the fulfillment of the obligations deriving from the share.

Restrictions on the transfer of the Company’s shares

The Company’s shares may be transferred in the manner laid down by law and there are no restrictions on their transfer contained in the Articles of Association of the Company.

Major direct or indirect holdings within the meaning of Articles 9 to 11 of Law 3556/2007

The major holdings (over 5%) as at 31.12.2025 were as follows:

Following the execution of a share purchase agreement and corresponding over the counter transaction made on August 10th, 2016, COSCO SHIPPING (Hong Kong) Co., Limited obtained 51% of shares and voting rights in the Company. As a result of an over-the-counter transaction that took place on 06 October 2021, the percentage of voting rights of COSCO SHIPPING (Hong Kong) Co., Limited in PPA S.A. has increased from 51% to 67%. With the above over-the counter transaction, COSCO SHIPPING (Hong Kong) Co., Limited has acquired from Hellenic Republic Asset Development Fund S.A. an additional 16% of shares in PPA S.A. The above transaction has taken place under an Amended Share Purchase Agreement between COSCO SHIPPING (Hong Kong) Co., Limited as Purchaser and Hellenic Republic Asset Development Fund S.A. as Seller, following ratification of an Amendment to the Concession Agreement between the Hellenic Republic and PPA S.A. (Law 4838/2021, Government Gazette 180A/ 01.10.2021). COSCO SHIPPING (Hong Kong) Co., Limited is 100% held by China Shipping Group Co. Ltd, which is 100% held by China COSCO Shipping Corporation Limited. As a result of the transaction, China COSCO Shipping Corporation Limited indirectly holds 67% of voting rights in PPA S.A.

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As a result of the above referred transaction, the “Hellenic Republic Asset Development Fund S.A.” (HRADF) percentage of voting rights in PPA S.A. directly has fallen from 23.1378% to 7.1378%. The total (100%) of the shares in HRADF is owned by HELLENIC CORPORATIONS OF ASSETS AND PARTICIPATIONS S.A (H.C.A.P)., which is 100% controlled by the Greek State. The transfer is attributed to an amended Share Purchase Agreement following ratification of the amendment of the Concession Agreement (Law 4838/2021, Government Gazette 180A/ 01.10.2021). Pursuant to a transaction made on November 10, 2021, the percentage of voting rights in PPA held by the shareholder Helikon Long Short Equity Fund Master ICAV amounts to 5.376%.

Holders of any type of shares granting special rights of control

There are no shares of the Company that grant to their holders special rights of control.

Restrictions to voting rights

The Company’s Articles of Association do not contain any restrictions to the voting rights deriving from the Company’s shares.

Agreements between shareholders which result in restrictions on the transfer of shares or limitations on voting rights

The Company is aware of a Shareholders Agreement dated 8 April 2016 between COSCO Hong Kong Group Limited (currently incorporated under the corporate name COSCO SHIPPING (Hong Kong) Co., Limited) and Hellenic Republic Asset Development Fund S.A., which contains certain restrictions on the transfer of shares and certain limitations on voting rights of the contracting parties. The rules contained in the Company’s Articles of Association on appointment and replacement of members of the BoD and on amendment of the provisions of the Articles of Association are not different from the provisions of the legislation. However, the Company wishes to inform that according to article 18 of the Articles of Association, as long as the Hellenic Republic Asset Development Fund S.A. or any global successor or successor by operation of law of the Hellenic Republic Asset Development Fund S.A. (each and collectively, the “FUND”) holds at least one million two hundred and fifty thousand (1,250,000) voting shares and less than 10% of the voting shares issued by the Company and subject to the FUND is entitled to appoint one (1) Member pursuant to article 79 of Law 4548/2018 as in force. If the FUND holds at least 10% of the voting shares, the FUND is entitled to appoint 1/3 of the total number of Members of the BoD of the Company.

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Should any Director appointed pursuant to paragraph 2 of this article resign or become incapacitated for whatever reason, they shall be replaced by such personas the HRADF shall specify in a pertinent written notice to the Company, with immediate effect.

Competence of the BoD or of some of its members to issue new shares or purchase own shares

No special competence different from the provisions of the legislation is awarded by the Articles of Association to the BoD or to some of its members to issue new shares or purchase own shares of the Company.

Important agreements contracted by the Company, which will enter into effect, be amended or expire in case of change in the Company’s control following a public offer and the results of such agreements.

There are no such agreements.

Agreements that the Company has contracted with the members of the BoD or with its personnel, which provide for the payment of compensation in case of resignation or release without substantiated reason or in case of termination of their term or employment due to a public offer.

There are no such agreements.

Piraeus, March 31 , 2026

THE CHAIRMAN OF THE BoD
HAN CHAO

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Piraeus Port Authority S.A.
Transformation of the port into a sustainability hub

Sustainability Statement 2025

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ANNUAL SUSTAINABILITY STATEMENT

ESRS 2 General Disclosures Sustainability Report

General Disclosures Sustainability Report

Piraeus Port Authority S.A. (hereinafter the Company or PPA S.A.) publishes its second Sustainability Report (hereinafter the “Report”) for the reporting period from 01/01/2025 to 31/12/2025. The current report is prepared in accordance with the requirements of the European Sustainability Reporting Standards (ESRS) and the Corporate Sustainability Reporting Directive (CSRD), Law 5164/2024 as in force and the EU Taxonomy Regulation (2020/852). The Double Materiality Principle forms the foundation of this Report, constituting a methodological framework that was first applied in 2024. For the current reporting year, the approach included a comprehensive reassessment of the actual and potential impacts arising from port operations. In addition, all financial risks and opportunities were reviewed and re-evaluated, taking into account not only direct effects but also the broader interconnections, dependencies, and conditions extending across the entire value chain.This holistic approach ensures that both impact materiality and financial materiality are accurately reflected. In this context, the impacts, risks, and opportunities (IROs) presented in this Report have been updated compared to the previous year, primarily with regard to their definitions and designations, in order to enhance clarity and achieve closer alignment with the ESRS Standards. However, the material topics, as identified in accordance with the ESRS Standards, remain unchanged compared to the previous year.

Scope of the Sustainability Report [ESRS 2: BP-1_5 a, bi ]

The Sustainability Report has been prepared on an individual basis, consistent with the scope applied in the Company’s annual financial statements for the financial year 2025. As the Company does not have subsidiaries, the preparation of a consolidated Sustainability Report is not required.

Assessment of the Value Chain [ESRS 2: BP-1_5 c ]

Information relating to the value chain is presented in various sections of the Sustainability Report. This includes a description of the Company’s upstream and downstream value chain, due diligence processes across the value chain, and Scope 3 greenhouse gas (GHG) emissions. The assessment conducted includes an analysis of impacts, risks, and opportunities and considers how these extend across the Company’s value chain.

Omission of Information

The Company did not make use of the option to omit information related to intellectual property, know-how, or the results of innovation [ESRS 2:BP-1_5 d]. It also did not apply the exemption from disclosure relating to pending developments or matters under negotiation [ESRS 2: BP-1_5 e].

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Time Horizon, Metrics, and Uncertainty Framework

Definition of Time Horizons [ESRS 2: BP-2_9 a, b]

Throughout the Report, the Company applies the time horizons defined by the European Sustainability Reporting Standards (ESRS) without deviation from the established definitions. This ensures the preparation of the Report with transparency, consistency, and accuracy. The definitions used are as follows:
* Short-term: objectives with a time horizon of less than one year
* Medium-term: objectives with a time horizon of one to five years
* Long-term: objectives with a time horizon of more than five years

Data Related to the Value Chain [ESRS 2: BP-2_10 a, b, c, d], [ESRS 2: BP-2_11 a, bi, bii]

The data included in this Report primarily reflect the Company’s own operations and are recorded and monitored directly through internal systems, covering energy consumption, water use, waste management, and procurement activities. Where relevant, data from third-party providers are also incorporated, particularly where such services influence the Company’s environmental and operational performance, including maintenance contractors, waste management partners, logistics providers, and suppliers. While most quantitative indicators (such as Scope 1 and Scope 2 emissions) are based on direct, primary, and verifiable data, certain environmental metrics—specifically Scope 3 emissions (see Environment Chapter, Climate Change section)—are often calculated using industry-average data or other proxy values and are therefore subject to a degree of uncertainty.

The measurement indicators used are based on primary data collected for Categories 3.3 and 3.5, while in certain cases average values were used to estimate the relevant parameters. In particular, for Category 5.1, emission factors as well as engine power were based on average data due to limited availability of asset-specific information.

For Category 3.3, the distance-based approach of the GHG Protocol was applied, whereby emissions are estimated based on distances travelled per mode of transport and the application of appropriate emission factors per kilometre. The data used for the calculations were derived from a staff mobility survey conducted within the organisation, with a participation rate of 46%.

For Category 3.5, the distance-based approach of the GHG Protocol was applied to air travel, while the average- data approach was applied to hotel stays during business travel. In the case of air travel, the data were primary and verifiable; however, in a limited number of instances, due to the absence of information on ticket class, the assumption of an average passenger was applied. For the calculation of emissions from overnight stays, the data used were primary and verifiable, while the emission factors applied were based on country-level average data.

For Category 5.1, the fuel-based approach of the Fourth IMO GHG Study 2020 was applied for CO₂ emissions, while the energy-based approach was used for CH₄ and N₂O emissions from berthed vessels, using the respective emission factors from the Fourth IMO GHG Study 2020. The available primary data included vessel type and size, year of construction, and time spent at berth. Based on vessel size and type, engine power was determined using data from the Fourth IMO GHG Study 2020, which provides average operational power values per vessel type and size. Based on engine power and berthing time, the required energy was estimated, and subsequently, based on the required energy and standard fuel consumption per engine type, fuel consumption was estimated for the duration of the vessel’s engine operation.

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Changes in the Preparation and Presentation of Sustainability Information Compared to the Previous Reporting Period [ESRS 2: BP-2_13 a, b, c]

This Report marks the Company’s second disclosure of sustainability information in accordance with the ESRS. Following a review of the previous report, the changes implemented, along with the rationale behind them, are outlined below:

Changes Reasoning 2025 Report (Data) (Reference) Where the Change Is Identified
Energy Efficiency & Scope 1 & 2 Emissions Revision of emission factors and improvement of available activity data Update of emission factors and improvement of available activity data. The revised information provides a more accurate and comparable representation of emissions between the two reporting periods. (The revised 2024 figures are presented in the “Energy Efficiency and Carbon Footprint” section of Chapter E1)
Performance Monitoring Indicators Restatement of the 2024 final calculations for comparability purposes, without changes to the organizational or operational boundaries of the inventory.
Scope 3 emissions (Catg. 3.3, 3.5, 5.1) Revision of the calculation methodology (from the GHG Protocol to a more targeted ISO-based approach) In 2025, the calculations were carried out using a more targeted and well- documented methodology, with increased use of primary data. (The revised 2024 figures are presented in the “Energy Efficiency and Carbon Footprint” section of Chapter E1) Performance Monitoring Indicators
Performance Monitoring Indicators Direct comparability with 2024 is limited due to the change in the underlying calculation methodology.
Water Management Revision of water consumption categorization and update of 2024 data In 2025, water consumption is presented in different and more detailed categories compared to 2024. (The revised 2024 figures are presented in the “Water Management” section of Chapter E2) “Water Management” section
Direct comparability with 2024 is limited due to the change in data categorization.

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Other Legislation or Generally Accepted Sustainability Reporting Standards and Frameworks Used in the Sustainability Report [ESRS 2: BP-2-15]

In addition to the indicators defined by the ESRS, the Company has included selected disclosures in line with the standards of the Global Reporting Initiative (GRI). The table below presents sustainability topics disclosed in this Report that are derived from other reporting standards.

Additional Disclosures / Indicators Data Point description and definition Section in the 2025 Sustainability Report where the metrics are presented
C-G1 C-G1-7 Board of Directors Composition – Average age of Board members ESG Information Disclosure Guide 2024 issued by the Athens Stock Exchange
ESRS 2 GOV-1 – Role of the administrative, management and supervisory bodies
C-G1 C-G1 Board of Directors Composition – Average tenure of Board members ESG Information Disclosure Guide 2024 issued by the Athens Stock Exchange
ESRS 2 GOV-1 – Role of the administrative, management and supervisory bodies

Incorporation of Information by Reference [ESRS 2: BP-2-16]

Specific information has been incorporated by reference in order to address specific disclosure requirements. The table below outlines the relevant European Sustainability Reporting Standards (ESRS) elements that are covered through this approach. The table below includes sustainability topics disclosed in this Report that originate from other reporting standards.ESRS Disclosure Requirement Data Point Document Source
GOV-1 — The role of the administrative, management and supervisory bodies G1.GOV-1_5b Corporate Governance Statement
GOV-2 — Information received by and sustainability matters addressed by the Company’s administrative, management and supervisory bodies ESRS2.GOV-2_26a, ESRS2.GOV-2_26b, ESRS2.GOV-2_26c Corporate Governance Statement
GOV-5 Risk Management and Internal Control System in relation to sustainability reporting ESRS2.GOV-5_36e Corporate Governance Statement
G1-1 Business Conduct Policies and Corporate Culture G1.MDR-P_65e Corporate Governance Statement
E1-5 Energy Consumption E1-5_43_ΑR_38 Annual Financial Statements
E2-2 — Actions and resources related to pollution MDR-A_69_a, MDR-A_69_b Annual Financial Statements
E2-4 — Pollution of air, water and soil MDR-A_69_a, MDR-A_69_b, MDR-A_69_c Annual Financial Statements
S1-6 Employee Characteristics of the Company S1-6_50 f Annual Financial Statements

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Strategy, Business Model and Value Chain [ESRS 2: SBM-1-40a]

The Port of Piraeus serves as a key hub for both the Greek and the global economy, bringing together multiple business activities within an integrated operational ecosystem. Its strategic location between Europe, Asia, and Africa, combined with strong connectivity to major shipping routes and modern infrastructure, supports its role as an important centre for logistics and trade. The Port facilitates the movement of goods and passengers, supports a broad range of industries, and contributes to economic activity at both national and international levels. Its core objective is to operate as a reliable and secure hub for trade, communication, and exchange, supporting the smooth and safe flow of goods, services, and information across regions.

Services [ESRS 2: SBM-1 40 ai]

The Company provides a wide range of services, including cargo handling, passenger and cruise-related services, ship repair, and integrated logistics solutions across its four terminalsThe Company is also active in the real estate sector, offering land and buildings both within the port area and in surrounding locations outside the port, which are available for concession. The information provided during 2025 is presented below.

Passenger Traffic

Cruise Terminal

The Company aims to increase its share of the cruise market, thereby generating significant benefits for the national economy through the creation of new jobs and the growth of income derived from tourism-related spending.

Characteristic Description
Cruise terminals Cruise Terminal A – Miaoulis
Cruise Terminal B – Themistocles
Cruise Terminal C – Alkimos
Berthing Positions 9–11 berthing positions (depending on the length of the vessels to be accommodated), with two additional piers currently under construction to enable the reception of larger ships.
Key Facilities 240 coach parking spaces; arrivals and departures halls; designated parking areas for buses and taxis; X-ray screening equipment; passport control counters; complimentary shuttle buses from the anchorage areas to the passenger terminals; Tourist Police presence; duty-free shops; free Wi-Fi; check-in counters; currency exchange services; baby-changing facilities; facilities for persons with disabilities; close proximity to the centre of Piraeus; and public transport connections near the terminals.

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Ferry Terminal

The Piraeus ferry terminal serves as a vital link between mainland Greece and the islands, handling millions of passengers each year and supporting both local and regional transportation needs. The main technical characteristics and facilities are outlined below:

Characteristic Description
Passenger Terminal Passenger Terminal – Vassiliadis Quay
Passenger Terminal – Hetionas
Passenger Terminal – Agios Dionysios
Key Facilities Covered passenger waiting areas along the entire length of the main port; 130 parking spaces; taxi stands; pedestrian bridges; complimentary shuttle buses within the port; free Wi-Fi within the terminals; water coolers inside the terminals; restrooms, including facilities for persons with disabilities; digital information screens; 24-hour telephone service providing schedule information; and pedestrian walkways.

Cargo Handling Unit

Container Terminal

The container terminal at Pier 1, operated by the Company, serves as a key hub for imports, exports, and transshipment across the Mediterranean and Black Sea. The terminal is equipped to handle the largest container vessels, featuring advanced electromechanical equipment.

Characteristic Description
Technical Characteristics • Annual Capacity: 1,100,000 TEUs
• Operating Hours: 24/7, 365 days a year
• Total Quay Length: 1,150 meters
• Maximum Depth: 18 meters
• Total Storage Area: 72,400 m²
Infrastructure capabilities Equipped with 8 ship-to-shore cranes, 5 Over Super Post-Panamax Twinlift and 3 Panamax Twinlift, 1 mobile port crane, 8 rail-mounted gantry cranes (RMGs), 22 wheeled straddle carriers for material handling, 36 terminal tractors, 2 front-lift stacking cranes, and 4 empty container handling vehicles.

Car Terminal

The car terminal is one of the largest hubs for domestic and transshipment vehicle traffic in the Eastern Mediterranean, the Black Sea, and North Africa. In addition to the loading, unloading, and storage of new vehicles, the terminal handles all types of wheeled cargo vehicles, including heavy machinery, trucks, mafi trailers (roll trailers), standard trailers, and general cargo.

Characteristic Description
Technical characteristics • Location: Terminal Management G2 (Keratsini – Drapetsona)
• Annual Total Throughput: over 300,000 vehicles/year
• Storage Capacity: 6,700 vehicles

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• Total Area: 145,000 m²

Ship Repair Zone

The Ship Repair Zone provides essential maintenance and repair infrastructure for a wide range of vessels. The Company operates five dry docks, including three floating docks and two fixed docks, all fully equipped with cranes. With upgraded floating piers and onshore dry-dock facilities, operational efficiency is enhanced while strict environmental regulations are maintained, reinforcing the port’s reputation as a regional hub for ship repair activities.

Floating Dry Docks in the Perama Ship Repair Zone

Lifting Capacity (tn) Length (m) Internal breadth (m)
Floating dry dock «Piraeus I» 15,000 202
Floating dry dock «Piraeus II» 4,000 113
Floating dry dock «Piraeus III» 22,000 240

Permanent Dry Docks on Vassiliadis Quay, Drapetsona

Length (m) Internal breadth (m)
Small Permanent Dry- Dock - 85
Large Permanent Dry- Dock - 140

Logistics Center

The Logistics Center in Keratsini offers a wide range of cargo handling services, including TIR truck unloading, container emptying, storage, sorting, and direct deliveries. Strategically located near the national road network within the urban area of Attica, it ensures easy and secure access to the warehouses and supports multimodal transport. The center features specialized facilities, modern equipment, enhanced security, and direct access to Customs and related services, facilitating the smooth execution of customs procedures. It comprises four warehouses: two for imported food (G-3, G-5), one for unclaimed goods (G-8), and the export warehouse.

Characteristic Description
Storage Areas Fenced area of 86,402 m² with a perimeter of 1,157 meters and covered storage space of approximately 10,000 m²
Safety and protection • Fire detection and suppression systems and generator for uninterrupted operation • 24/7 guards and patrols, CCTV coverage throughout all areas
Equipment Forklift trucks, specialized container lifting equipment, self-propelled scissor lift, pallets

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Real Estate & Concessions

The Company’s concessioned real estate assets available for lease play a significant role in supporting the growth and development of the concession area, while also generating additional revenue streams. These include modern warehouses, high-quality office spaces, retail premises, and other facilities that support business activity within and around the port. Their prime locations and modern infrastructure make them attractive for investment and reinforce the port’s role as a key economic hub. The underground parking facility at Karaiskaki Square is also available for concession, offering convenient access to passenger terminals and transport connections.

Customer Segmentation [ESRS 2: SBM-1 40 aii]

The Company’s markets and customer groups are broad and diverse.# CARGO HANDLING UNIT

Segment Terminal Customers Market Served Compeve Advantage Strategic Role ESG Priority
Containers International shipping companies, logiscs service providers, exporters/ importers Trade routes of Europe, the Mediterranean, the Black Sea, and the Middle East Deep-water berths, state- of-the-art cranes, highly ecient terminal layout Serves as a commercial hub and a vital part of the value chain for many businesses Key driver of the port’s compeveness and revenue Strengthens its posion in the global market
Cars (Ro-Ro) Car manufacture rs, vehicle logiscs providers, and car distributors Eastern Mediterranean, the Black Sea, and North Africa Rail connecvity, specialized storage areas, and high- capacity Ro- Ro handling equipment Supports industrial supply chains and trade corridors Diversied cargo base As part of the supply chain for numerous imports and exports, the adopon of sustainability principles directly inuences stakeholders’ preference for the Company as a port of choice

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PASSENGER TRAFFIC

Terminal Customers Marget served Compeve Advantage Strategic role ESG Priority
Cruise Internaonal cruise companies, cruise service providers Mediterranean tourism routes Deep-water berths, high simultaneous berthing capacity, highly ecient terminal layout, operaon of three passenger terminals with passenger services, and gateway to the country Key pillar for the development of tourism and the regional economy Enhances the port’s visibility
Ferries Ferry operators, tourists, and local passengers Domesc Greek market, connecng mainland Greece with the islands Advanced passenger facilies, digital informaon systems, and free internal port transport services Essenal for naonal connecvity and social cohesion, stable and recurring trac The port serves as a crical hub supporng a signicant part of the naonal economy and tourism

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SHIP REPAIR ZONE

Customers Markets Served Compeve Advantage Strategic Role ESG Priority
Shipowners, commercial shipping companies, and marime service providers Mediterranean and global marime industry Modern repair berths, investments in infrastructure upgrades Strengthens the port’s industrial ecosystem Supports marime compeveness and employment

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OTHER ACTIVITIES

Acvity Customers Markets Served Compeve Advantage Strategic role ESG Priority
Supply Chain Import/export businesses, logiscs companies Naonal and internaonal supply chains Proximity to customs services, direct cargo handling, and expansion plans for addional logiscs facilies Strengthens the port’s role as a regional logiscs hub, increases throughput and connecvity with Europe and Asia; supports revenue diversicaon Health and safety of the local community
Real Estate & Concessions Tenants (warehouses, oces), commercial/retail businesses, parking facility operators Local and regional businesses seeking port-adjacent facilies; internaonal companies needing logiscs, oce, or commercial space within the port area Strategic waterfront locaons near the port; integrated access to port infrastructure, logiscs services, and transport networks; exible mix of industrial, logiscs, commercial, and oce spaces Provides stable, recurring rental income and diversies port revenues; aracts complementary businesses that strengthen the port ecosystem Building energy eciency and potenal for green building cercaon; opmized land use and revitalizaon of abandoned industrial areas instead of unchecked expansion

Company Performance in 2025

The table below presents the Company’s activity by business unit for 2025 in relation to 2024, along with the corresponding percentage change.

Business Unit 2025 2024 % Μεταβολή
Container (TEUs) 664,581 563,725 17.9% increase in total throughput
RO/RO (individual units) 291,287 247,600 17.6% increase in total throughput
Cruise (passengers) 1,863,397 1,698,877 9.8% increase in passenger trac
Ferries (vehicles) 3,055,596 3,025,457 1% increase in vehicle throughput
Ferries (passengers) 17,213,513 17,053,118 0.9% increase in passenger trac
Ship Repair (vessels) 256 275 6.9% decrease in ship repair acvies
Dry docking (vessels ) 115 143 19.6% decrease in dry docking services
Logistics (tonnage) 130,882 128,953 1.5% increase in cargo volumes

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To meet these market demands and the specific needs of its customer groups, the Company continuously invests in its infrastructure, service development and people. At present, a total of 1,058 persons are employed at the port, 100% of whom form part of the Company’s workforce working at the port facilities. Employees are further organized into specialized business units, leveraging their expertise to meet the evolving need of global shipping and trade. The workforce consists of the Company’s employees as well as self-employed persons (NACE 78, self- employed persons). [ESRS 2: SBM-1_40 a iii]

In 2025, the Company recorded revenue of approximately €250.8 million, reflecting its strong market presence. To respond to the evolving needs of global trade and the wider shipping sector, the Company continues to invest in the development of its infrastructure and services.

Sector Cruise Coastal Shipping Concession of Piers II & III Container Terminal Car Distribuon Ship Repair (Dry Docks and Mooring) Other Sectors Total
2024 Income (million €) 30.4 12.5 81.7 50.0 27.1 15.9 13.3 230.9
2025 Income (million €) 37.9 9.0 90.5 58.5 25.6 14.8 14.5 250.8

[ESRS 2: SBM-1_40 b]

Research and Development

At PPA S.A. our purpose is to drive innovation and sustainable growth through strategic R&D collaborations with Greek and international partners. By focusing on green technologies, we actively contribute to the European Green Deal and Fit for 55 objectives, promoting energy efficiency and climate neutrality. These ongoing projects in 2025 continue to build on the progress made in previous years.

Program Project Descripon PPA Budget Co- Funding Rate Role of the Company
Climate Resilient Regions Through Systemic Soluons and Innovaons ARSINOE (HORIZON 2020) Studying the potenal eects of Climate Change in Ports within the Mediterranean basin. A Systems Innovaon Approach (SIA) is applied with which challenges are analyzed, opportunies are idened, and innovave soluons are designed. The ulmate goal is to create an Ecosystem that adopts Climate Change Adaptaon soluons for the port of Piraeus. - 70% Project Partner
Completed within 2025 497,500.00€
TRIERES (HORIZON EUROPE) Greece’s rst Hydrogen Valley that brings together business, knowledge, and regional interests. PPA’s involvement concerns two pilots: 1. One (1) short sea ferry vessel retroed with 200kW FC system, which will be operated on the 1.6 naucal mile route of Perama- Paloukia, situated near the port of Piraeus. 2. One (1) Fuel Cell Auxiliary Power Unit (FC-APU) with a capacity of 100kWe to produce electricity via green hydrogen used for the heang in PPA premises. 705,000.00€ 70% Project Partner
GREENLIFE4SEAS (LIFE+) Demonstrates the technical feasibility, full safety and commercial viability of innovave soluons for in situ recovery and reuse of sediments from harbor dredging and shellsh shells, used as secondary raw materials. 258,402.87€ 60% Project Partner
MISSION (HORIZON EUROPE) An interoperable digital real- me-based opmizaon and decision support tool enabling coordinated port call operaons, planning and execuon in terms of me, fuel consumpon, environmental impact, and safety, spanning the overall marime supply chain. A pilot applicaon on the “JustInTime “concept will be applied at the port of Valencia, the port of Genoa, with the cooperaon of COSCO SHIPPING Lines Spain 162,500.00€ 60% Project Partner
RENEWPORT (MED) Supports the clean energy transion of Mediterranean ports, transforming ports into clean energy hubs by exploing the untapped potenal of renewable energy sources (RES). It concerns the installaon of photovoltaic units on a roof and vehicle chargers. 319,800.00€ 80% Project Partner

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Program Project Descripon PPA Budget Co- Funding Rate Role of the Company
TREASURE (MED) Soil and water polluon reducon in and around Mediterranean port areas through transnaonal tesng mini-labs, development and applicaon of novel techniques to restore degraded and polluted port ecosystems. It concerns the installaon of a port environment quality monitoring system with sensor systems and sample collecon tools. 328,160.00€ 80% Project Partner
ADRIREC (ADRION) Refers to renewable Energy Communies (RECs) for ports. The project facilitates the energy transion of ADRION ports by exploing untapped potenal of RES through the establishment of Renewable Energy Communies (RECs), to enhance their decarbonisaon potenal.
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TRAVEL WISE (HORIZON) As the EU promotes synergies between connected destinations (e.g., ports, airports, train stations). The project involves companies that are operationally connected, particularly for the Greek pilot implementation, with participants such as AEGEAN, HELLENIC TRAIN, and the ATHENS INTERNATIONAL AIRPORT. The port links to the operational information flows and systems of each organization involved gaining access to schedules and passenger flows to and from the port's previous and subsequent destinations, as well as receiving real-time notifications in case of crises or incidents. 162,500€ 60% Project Partner

Investments

PPA S.A. designs and implements an annual investment plan to strengthen its financial position, as well as to secure the necessary capital investments required for the adaptation of infrastructure and the financing of actions that support sustainable operation. According to the current Concession Agreement, the Company's Mandatory Investments amount to a reference cost of € 293.8 million for the First Investment Period and € 56 million for the Second Investment Period. The additional voluntary investments amount to a reference cost of € 156 million, while the additional voluntary investments for the maintenance and repair of port and building facilities amount to € 33.3 million. By the end of 2025, the Construction Contracted amount of the above Mandatory Investments amounts to € 380.7 million. The Accumulated Investment amount up to December 2025 of Mandatory Investments, reached € 320 million, which concerns completed projects of € 96.2 million, projects under execution of € 210.0 million, as well as advances of € 13.8 million.
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Strategic Priorities

PPA S.A., serves as a dynamic hub of economic activity, connecting international economies with local communities. As a natural global connector, it facilitates communication and coordination of trade flows across the world, with a vision to deliver operational and sustainable added value to the communities it serves and the broader value chains in which the port is embedded. With connectivity and accessibility as core principles, the port drives growth and business development through the adoption of innovative practices and technologies. At its core, the port is driven by a fundamental commitment to safety and security for its employees, stakeholders, and the wider local community.

Mission, Vision, Values

Mission

To build and operate port facilities in an efficient and reliable way to optimize productivity of available resources, minimize environmental footprint, advance digital capabilities, and create both economic and social value for its stakeholders.

Vision

To be established as the port of choice in the Mediterranean Sea and a major node for freight transportation in Europe, while promoting intermodal, sustainable and smart solutions.
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Values

  • Profitability: Safeguarding and promoting corporate interest and the interests of our shareholders
  • Excellence: Striving for continuous improvement
  • Safety: Maintaining high standards for health and safety
  • Professional Growth: Guiding the professional development of employees
  • Responsibility: Acting to ensure both environmental and social responsibility

Sustainability Strategy [ESRS 2: SBM-1 40 e, f, g]

Being one of the largest ports in Europe, PPA S.A. aspires to create long-term value through strong service governance and strategic partnerships. Our strategic approach progressively integrates sustainability ambitions and ESG principles into decision-making, ensuring the effective management of impacts, risks and opportunities. The Company’s commitments are outlined in its ESG and Sustainability Policy (see Policies related to business conduct and corporate culture – Chapter G1-1). The policy is reviewed annually and provides the framework for the sustainability strategy, which is evaluated through the double materiality assessment (DMA). This approach ensures comprehensive monitoring and supports the ongoing update of policies, actions, and targets to effectively manage material impacts, risks, and opportunities (IROs). The sustainability strategy of PPA S.A. is grounded in three ambitions that drive economic progress and sustainable outcomes, focusing on reducing the environmental footprint, fostering social involvement, and supporting the growth and development of employees, alongside strong corporate governance. Through these commitments, we set a series of key objectives. As part of the Group’s sustainability strategy, the ESG Committee, established by the Board of Directors, oversees the Company’s environmental, social, and governance performance and ensures the effective integration of non- financial factors into business strategy and decision-making. In 2025, the Committee met five times to review the value chain, significant impacts, risks and opportunities, and to propose sustainability goals and monitoring indicators to the Board, while also supporting the preparation of the Sustainability Report. Through its work, the Committee strengthens the port’s risk management and due diligence processes and ensures the implementation of the Company’s Sustainability Policy.
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As part of its sustainability development strategy, the Company has set targets and actions, as described in the table below.

Actions Targets Year KPIs Progress
Integra$\text{t}$ion of the Sustainability Strategy into the Corporate Strategy 3 Targets per ESG Pillar 2025 3 Targets 100% achieved in 2025
Prepara$\text{t}$ion of the Net Zero Strategy for the entire Company Achievement of European targets, such as the Paris Agreement goals, by mid-century 2027 - No progress was recorded during 2025 – Ongoing

Business Model and Value Chain [ESRS 2: SBM-1 42]

Identifying Stakeholders

A clear understanding of PPA S.A.’s business environment and the key parties involved at each stage was achieved through a comprehensive value chain mapping. This mapping enabled the identification of the core stakeholder groups embedded in the Company’s upstream and downstream activities, as well as how these stakeholders interact with and influence the Company’s operations

Upstream Activities

The upstream segment of the value chain encompasses all entities involved in supplying the essential products, services, and resources required for the port’s operations. This stage focuses on the delivery of foundational inputs such as infrastructure, utilities and energy, skilled workforce, and operational as well as management systems. These elements collectively ensure the port’s efficient, safe, and continuous functioning. Upstream activities are organized into Tier 1, consisting of direct providers of core services and assets, and Tier 2, comprising indirect suppliers and contractors who support and enable the primary providers.

Own Activities

PPA S.A. oversees interconnected port operations. Its core activities include cargo handling, cruise and ferry passenger services, and ship repair, supported by warehousing and coordinated transport. Commercial operations target shipping lines, logistics providers, cruise operators, ship repair clients, and real estate tenants. Service quality is ensured through customer support, infrastructure upkeep, and adherence to environmental, safety, and regulatory standards. These functions rely on procurement, advanced IT systems, skilled staff, and financial and administrative support.

Downstream Activities

The downstream value chain of PPA S.A. includes entities that rely on the port’s after-delivery services. The downstream boundaries extend to Tier 1 and 2, covering Tier 1 direct customers (shipping companies, terminal operators, vehicle importers/exporters, cruise lines and tenants) and Tier 2 indirect customers (the customers of those customers), as well as suppliers and partners involved in service and product distribution and further handling of cargo and passenger flows. It also includes regulatory authorities, environmental and waste service providers (working directly with the port’s output rather than vessels), as well as the local community impacted by the port’s operations.Page 134 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

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How the Company creates value [ESRS-2_SBM-1 42a, b, c]

The Company creates long-term value for stakeholders. The main purpose of the port is to act as a secure hub for trade, communication and exchanges. Our strategic focus on operational efficiency, safety, and sustainability guides all operations, guided by our values. The value creation model demonstrates the transformation of input capital into output capital and highlights the multidimensional impacts generated across economic, environmental and social sectors.

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Stakeholder Engagement [ESRS 2: SBM-2_45]

Interest and views of stakeholders

PPA S.A. interacts with a wide range of stakeholder groups across all parts of the value chain. The engagement process is designed to support a comprehensive understanding of stakeholders’ interests and expectations. As part of an ongoing action plan initiated in 2024, a survey was conducted targeting key stakeholder groups and remained open throughout 2025. This survey has now been updated and is to run for yet another year. This step establishes an open communication channel and enables the identification of material issues along the value chain that require attention, planning, and action. The Company’s goal is to ensure transparency, build trust, and provide stakeholders with insight into its strategy, performance, and objectives. Feedback gathered through various communication channels (as presented at the table below), is supporting regular and constructive dialogue tailored to each stakeholder group.

The importance of this engagement is reflected during the Double Materiality Assessment, where stakeholders actively participate in identifying actual and potential negative impacts of the organization and are informed about the measures taken to mitigate or remediate these impacts. The Company actively informs and engages employees and other key stakeholders on materiality results and ESG performance through ongoing communication and through its sustainability reporting. Stakeholder input (based on surveys, meetings, and feedback collection) is assessed and presented during the Company’s annual management review, with emphasis on issues related to sustainability. These insights are discussed among the Board of Directors and the ESG Committee for the determination of relevant actions [ESRS 2: SBM-2 45 b, d]. The outcomes of this process contribute to the adjustment of corporate strategy, governance practices, and capital allocation decisions. The material issues and associated material impacts, risks and opportunities are recorded as important factors that become the subject of internal strategic reviews.

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The table presents an overview of stakeholders’ views.

Stakeholder Group [ESRS-2: SBM-2 45a(i)] Engagement Channels [ESRS-2: SBM-2 45a (ii, iii)] Areas of Interest Engagement Focus (purpose & outcomes) [ESRS-2: SBM-2 45a (iv, v)]
• Shareholders • Annual General Meeting • Press releases / announcements • Financial statements and reports • Risk Management Reports • Achieving financial returns • Maximize shareholder value • Strengthening competitiveness and the opening of new markets • Ensure robust corporate governance • Ensure transparency and accountability • Build trust through consistent reporting and governance • Minimize financial risks • Ensure profitability and deliver dividends • Expand market presence and foster economic growth (Cruise sector, Concessions) • Strengthen governance and implement risk management • Develop and apply risk mitigation strategies • Maintain transparent and accountable reporting
• Financial Institutions, Investors and Creditors • Regular investor presentations • Press releases / announcements • Financial statements and reports • Investor calls / meetings • Stakeholder survey • ESG performance assessment questionnaires • Maximize return on investment (ROI) • Ensure access to capital and favorable credit terms • Ensure Company financial stability • Minimize credit risk • Minimize risk exposure to ensure financial stability • Ensure compliance with financial agreements • Ensure responsible investment Practices • Ensure financial stability and access to capital • Diversify revenue streams and grow market presence (Cruise sector, Concessions) • Secure contract reliability and foster co-development of strategies • Maintain regular stakeholder feedback and engagement • Enhance governance and risk management practices • Develop and implement risk mitigation strategies • Provide transparent and accountable reporting

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Stakeholder Group [ESRS-2: SBM-2 45a(i)] Engagement Channels [ESRS-2: SBM-2 45a (ii, iii)] Areas of Interest Engagement Focus (purpose & outcomes) [ESRS-2: SBM-2 45a (iv, v)]
• Employees and Workers • Internal communication channels (Newsletter) • Office automation system designed to expedite the completion of internal processes • Employee satisfaction survey • Corporate announcement board • Internal portal • Internal complaints process (whistleblowing mechanism) • Employee committees and delegations • Employee unions • Stakeholder survey • Job security • Career development and education • Health and safety at work • Fair compensation and benefits • Equal opportunities • Recognition • Ensure fair contract agreements and promote union collaboration • Maintain robust health and safety systems • Provide competitive remuneration and benefits policies • Advance diversity, equity, and inclusion (DEI) initiatives • Support ongoing training, upskilling, and reskilling opportunities • Implement regular performance evaluations
• Customers and End users (Direct / Indirect end-users) • Support via phone, e-mails • Sustainability Report • Press releases, announcements • Customer satisfaction survey • Feedback mechanism • Events and exhibitions • Complaints Management Procedure • Stakeholder survey • Corporate website • Complaint and reporting mechanisms • Fast, reliable, responsive, and efficient service • Well-maintained facilities, infrastructure • Safe operations and secure environment • Environmental responsibility • Competitive pricing • Professional, responsive, and customer-focused staff • Competent management ensuring fair treatment of employees and stakeholders • Innovation and market reputation • Integrate ESG principles into products and services • Deliver strong value proposition and responsiveness to customer needs • Invest in infrastructure upgrades and maintenance • Develop competitive pricing strategies and benchmark against peers • Maintain skilled and professional workforce • Strengthen governance and management systems • Implement risk management and invest in R&D • Ensure effective whistleblowing mechanisms and complaint handling
• Complaint Management and willingness to collect and act on feedback for continuous improvement • Collect and act on customer feedback through surveys • Maintain certified management systems for quality and compliance
Suppliers and Service providers • Public tenders • Contracts management • Joint planning sessions for common development • Press releases / announcements • Performance reviews • Service level agreements • Stakeholder survey • Payment and credit issues • Terms of collaboration (fair contracts) • Reliability • Delivery times • Certified management systems • Mutual business growth and success • Minimize credit risk through sound financial practices • Establish mutually beneficial and fair contracts • Build capacity and streamline supply chain processes • Maintain certified management systems and operational protocols • Foster collaboration for effective dispute resolution • Develop long-term partnerships based on clear agreements and timely payments • Implement automated systems to improve efficiency • Provide training and capability-building programs (induction and other job) • Conduct regular performance and competency evaluations
• Government and Regulatory Authorities • Compliance and regulatory reporting • Direct meetings with policy makers and regulators • Collaboration on policies shaping • Stakeholder survey • Regulatory compliance (local, national, international) • Influence policy decisions related to maritime industry • Facilitate cross-sectoral collaboration and stakeholder engagement • Ensure transparency in operations and reporting • Maintain full regulatory compliance • Promote active participation and consultation in policy-making

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Stakeholder Group [ESRS-2: SBM-2 45a(i)] Engagement Channels [ESRS-2: SBM-2 45a (ii, iii)] Areas of Interest Engagement Focus (purpose & outcomes) [ESRS-2: SBM-2 45a (iv, v)]
• R & D (Industry Associations, Academia and EU Institutions) • Participation in industry conferences and workshops • Collaboration on R & D projects • Partnerships with Universities and Research centers • Educational visits and guided tours within PPA S.A.’s premises • Stakeholder survey • Knowledge exchange • Achieving innovation • Contribute to technological advancement • Promote cross-sector collaboration through EU programmes • Facilitate expertise and knowledge exchange • Secure co-funding for joint projects • Advance decarbonisation

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• Conduct environmental monitoring initiatives
• Support infrastructure development and modernization
• Driving technological innovation and advancements
• Local community and NGOs
• Public meetings
• Community outreach programs
• Environmental and CSR initiatives
• Annual Reports (Financial and Sustainability)
• Joint Environmental and CSR programs
• Press releases
• Meetings / For a
• Stakeholder survey
• Economic and social benefits
• Employment opportunities
• Sponsorships and donations
• Sustainable business practices that minimize environmental impact
• Ensure alignment of business practices with SDGs
• Ensure transparency
• Work towards mitigation of negative impacts on society and the environment
• Develop partnerships to mitigate environmental and social impacts
• Invest in renewable energy and emissions reduction projects
• Promote regional job creation and economic development
• Support community investments and fund donations
• Provide detailed and transparent reporting
• Engage in consultation and collaboration for policymaking
• Maintain ongoing communication with stakeholders

A detailed description of the key elements of engagement with stakeholders is available in the relevant sections of this Report, as set out in the table below. [S1.SBM-2_12, S3. SBM-2_7, S4.SBM-2_8]

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Key elements of engagement with stakeholders Chapter and Section in the Report Report page
S1.SBM-2_12 Chapter: “Our People” ESRS S1 – The Company’s Workforce Section: Interests and Views of Stakeholders 254
S3. SBM-2_7 Chapter: “S3 Affected Communities” Section: Interests and Views of Stakeholders 291
S4.SBM-2_8 Chapter: “PPA S.A.’s commitment to its customers ESRS S4 – Consumers and End-users” Section: Interests and Views of Stakeholders 304

Double Materiality Assessment [ESRS 2: IRO-1 53]

Prioritizing sustainability and transparency, PPA S.A. conducted the first Double Materiality Assessment in 2024 to evaluate the material topics that have environmental and social impacts resulting from its operations, and the associated material risks and opportunities alongside their effects on financial performance and value creation. In 2025, the DMA exercise was re-evaluated and the relevant IROs have been re-defined. The materiality of each IRO has not changed, yet the definitions on specific IROs have been clarified. .

The Double Materiality Assessment followed a structured methodological approach in four steps. The process involved data collection and analysis with the active participation of experts and stakeholders. This enabled the clear identification of the Company’s material impacts, risks, and opportunities. The results of this assessment have been incorporated into the central risk management system, to ensure resilience of the business strategy in managing challenges, meeting stakeholder expectations and effectively addressing its material topics. The review of the process during the second year of implementation included the incorporation of updates and additional data sources. This review included a reassessment of stakeholder engagement approaches, monitoring and reporting mechanisms, and the integration of sustainability into overall business strategy.

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The four-step DMA process: [ESRS2: IRO-1-53 a, b]

The DMA methodological approach [ESRS 2: IRO-1 53 a]

The DMA is founded on the principles outlined in the ESRS. The process evaluates how the activities of PPA S.A. have actual and potential positive or negative impacts on the environment, people, and society (impact materiality). Additionally, it considers how sustainability issues influence the Company’s operations by presenting real and potential financial risks and opportunities (financial materiality). To address this dual approach the following step was followed:

1. Understanding the business context

PPA S.A. conducted a thorough analysis of its internal and external environments, as well as its entire value chain, to identify key material topics. To support this evaluation, internal data, including stakeholder inquiries, existing due diligence processes, and the risk management system were all reviewed alongside publicly available company information from published reports. Insights from the value chain analysis, stakeholder feedback, and external expert contributions were all incorporated to identify the key topics for the assessment. This assessment phase was completed during 2024. In the cycle of the current reporting period (2025), no significant internal changes occurred in the Company’s operations and strategy and thus the exercise has only been updated rather than repeated.

2. Identification of Impacts, Risks, and Opportunities (IROs)

To ensure a robust and comprehensive identification of potential impacts, risks and opportunities, the process began with an extensive review of leading sustainability frameworks and external sources. This included analysing SASB and ISSB sector-specific standards, MSCI and other ESG rating methodologies, emerging industry and sustainability trends, and benchmarking against peer reporting practices.

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Insights from these sources, together with relevant regulatory requirements and sustainability-focused guidelines, were consolidated to develop an initial long list of topics that reflect the most relevant sustainability considerations for the sector. The long list of sustainability topics was initially compiled from various sources and subsequently reviewed and refined into a list of relevant topics through consultations with internal and external stakeholders. This stakeholder engagement, including workshops, working groups, and interviews with executives and relevant teams, ensured that the topics reflect the Group’s actual impacts, risks, and opportunities. Based on this refined list, a preliminary inventory of potential impacts, risks, and opportunities (IROs) was developed, which was further elaborated and validated through ongoing stakeholder dialogue. In the current reporting period (2025), the process was reviewed through additional discussions and stakeholder input. The identified impacts, risks and opportunities were reassessed, and the IROs list was reviewed accordingly.

3. Evaluation of Impacts, Risks, and Opportunities (IROs)

After identifying the potential material IROs, company executives, external experts and stakeholders were engaged to evaluate their materiality from an impact and a financial perspective. In this step, the company applied defined criteria for assessing impact and financial materiality to identify which actual and potential impacts, risks, and opportunities are considered material.

Impact Assessment- Impact Materiality [ESRS 2: IRO-1_53 c]

PPA carried out the impact materiality assessment to identify the most significant environmental and social topics across its value chain, examining both direct and indirect effects from operations, partners, and local communities, with a focus on sensitive operations and spots along the value chain. The analysis considered both actual and potential impacts. The evaluation combined internal data derived from Company operations and processes with external sources, including academic research and industry reports. The materiality assessment for negative impacts is based on likelihood and severity, considering scale, scope, and irremediability. For positive impacts, it is based on scale, scope, and likelihood. These criteria are scored to assess the materiality of impacts. Materiality thresholds help establish significance, while scoring supports the prioritization of future sustainability actions. The Company maintains an ongoing dialogue with its stakeholders, including the survey conducted in 2024–2025, which incorporates the Double Materiality assessment for identifying and prioritizing ESG matters that affect the Company. The feedback collected through this process was used to inform the assessment of material topics.

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Risk and Opportunities Assessment - Financial Materiality [ESRS 2: IRO-1 53 c]

This process began with the assessment of potential financial risks and opportunities by analyzing PPA’s operations, market environment, and value chain. Focus was placed on activities or contexts related to sustainability, such as regulatory shifts, stakeholder expectations, or environmental pressures, may have an impact on financial outcomes. The materiality of risks and opportunities was assessed based on the likelihood of and the potential magnitude of the financial effects. The likelihood of occurrence is estimated based on industry experience, market trends, historical data, and professional judgment. A standardized scoring scale is applied to facilitate prioritization and integration of the risks into strategic risk planning. The magnitude of the financial impact is estimated based on their potential impact on key financial and operational indicators such as revenue, operating costs, brand reputation, customer trust, investor appeal, and regulatory compliance. The nature of the financial impact is categorized and assessed based on the following criteria [ESRS 2: IRO-1_53 c ii]:
• Direct or indirect impact (e.g. operational cost increases due to regulation or demand shifts due to environmental performance)
• Short-term or long-term (e.g. compliance costs incurred today to secure access to green financing in the future)
• Financial or non-financial (e.g.reduced occupancy rates in the event of a safety incident or loss of trust due to poor HR or waste management) Integrating Sustainability risks into risk management and strategy The Double Materiality Assessment process has been fully embedded into the Group’s strategic and risk management systems, ensuring that material impacts and dependencies are identified promptly and considered in strategic decision-making. This approach enhances the Group’s long-term resilience and allows for continuous adaptation to market dynamics and the evolving regulatory requirements. During the materiality assessment, attention was given to how material impacts, whether positive or negative, arising from the Group’s operations, products, and stakeholder relationships could lead to financially material risks or opportunities. Likewise, key dependencies were also assessed, including the availability of natural resources (such as water and energy), geopolitical stability, the availability of skilled workforce, and the stability of Supply Chains and Logistics. Disruptions to these dependencies may significantly affect operational continuity, reputation, and financial performance. [ESRS 2: IRO-1 53 ci]

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The following table provides a detailed breakdown of the dependencies influencing the port's operations:

Dependency Category Description Link to Impacts, Risks, and Opportunity
Infrastructure and Utilities Energy Supply (Electricity, Fuel, Renewable Sources) The port relies on a reliable supply of electricity for operations, lighting, and IT systems. Cold ironing (shore connection) is crucial for reducing emissions and to cover for the upcoming needs of customers, and fluctuations in fuel prices or delays in transitioning to renewable sources can impact performance
Water Supply A stable supply of freshwater is essential for ship services such as cleaning and cooling and drinking.
Waste Management Waste management (in line with MARPOL standards) depends on external contractors for effective disposal
Digital and IT Infrastructure Advanced IT systems are essential for cargo tracking, customs clearance, and security. Cybersecurity threats or delays in infrastructure upgrades (e.g., blockchain integration) can disrupt operations.
Climate and Environmental Factors Extreme Weather Events Storms, high winds, and rising sea levels can disrupt cargo loading/unloading operations and potentially damage port infrastructure (refer to the Appendix IRO table)
Shipping and Logistics Supply Chains Global Trade Flows
Rail and Road Connectivity Efficient integration with national and regional transportation networks via rail and road is crucial for moving cargo from the port to inland markets
Workforce and Availability Availability of Skilled Labor The port depends on specialized labor for operational activities, logistics management, and ship repair services. Labor shortages, rising wage costs, or changes in working conditions (due to legislation or automation) can affect efficiency.

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Sustainability risks are prioritized within the Company’s overall risk management framework, using the same methodology applied to operational and financial risks. Emphasis is placed on serious ESG risks with long-term implications. These key risks are integrated into the central risk register and monitored by the Board of Directors, ensuring a holistic approach and increased strategic priority relative to other risks. [ESRS 2: IRO-1_53 ciii]

4. Selecting Material Topics

The outcome of the assessment finalized the selection and prioritization of the material impacts, risks, and opportunities included in the Sustainability Report. The assessment criteria were based on clear and well-documented methodologies to ensure that the topics identified as material have a genuinely significant effect on the Company’s business model, as well as on the environment and society. Upon completion of the assessment, the material impacts, risks, and opportunities were identified by comparing their scores against the established thresholds. The process for determining material topics included the use of specific criteria and thresholds to assess which issues should be considered material. The methodology was applied by evaluating the range of scores assigned to impacts, risks, and opportunities. Issues exceeding the predefined minimum thresholds were classified as material. The Company identified as material those matters that affect the environment and society, operating costs or revenues, as well as any issue that may have an adverse impact on the Company’s reputation or its compliance with regulatory requirements. In addition, issues affecting the Company’s strategy and its ability to respond to sustainability-related challenges are also assessed. [ESRS-2: IRO-2_59]

Regulatory and Legislative Dependencies

Dependency Category Description
Legislation and Regulations National and international regulations (covering environmental standards, safety, and labor laws) establish the operational framework and can impact processes and operational costs.
Security and Cybersecurity Physical and Cyber Security
Financial Dependencies Investment Flows and Economic Conditions
International Relations and Cooperation Cross-border and Commercial Agreements

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Decision-Making process and related safeguards [ESRS-2: IRO-1_53 d]

The Double Materiality Assessment, initially implemented in 2024, is now integrated into the Company’s broader strategic and risk management framework. Through this process, material ESG topics are identified and assessed with the active involvement of executives from various business units, ensuring their timely integration into strategic and operational planning. Throughout the process, the ESG Committee was consulted on the Double Materiality Assessment, the approval of which forms part of the overall approval of the Sustainability Statement. For more information, see the discussion in GOV 5.

Integration of Risks and Opportunity Management in the General Management System [ESRS-2: IRO- 1 _53 e, f, c]

PPA S.A. assesses risks through a structured COSO-based ERM approach, integrating sustainability considerations identified in the DMA. A central Risk Register consolidates all conventional and ESG-related risks and opportunities, supporting consistent prioritization across business units. Risks are assessed for inherent and residual exposure, ranked by likelihood and severity, and reviewed through internal audits, the Board-approved Risk Appetite Statement, probability–impact matrices, and Key Risk Indicators (KRIs). Opportunities are evaluated in a similar manner and monitored through Key Opportunity Indicators (KOIs) to support strategic development. Risk reporting is conducted quarterly and annually, updating senior management and the Audit Committee on exposures, mitigation progress and emerging issues. The 2025 Risk Registry covers key areas such as climate change, resource management, health and safety, regulatory compliance and data protection. As per ISO standards requirements, each department has established its own SWOT analysis and Risk & Opportunities assessment. In line with these requirements and governance practices, the Quality Department records risks and opportunities at departmental level, progressively integrating sustainability-related aspects. This includes embedding both climate-related and other ESG risks and opportunities into operational business risk assessments. All identified risks and opportunities are documented, evaluated, and communicated through the Management Review process (ISO 9001, 14001, 50001, 14064-1). This integrated approach strengthens oversight and accountability, ensuring that sustainability-related risks and opportunities emerging from the DMA, are embedded into strategic and operational decision-making and contribute to the Company’s long-term resilience and performance. For more information see the discussion in GOV 5 – Risk Management and Internal Control Systme related to sustainability reporting.

Input Parameters to the Impact, Risk & Opportunity Assessment Process [ESRS 2: IRO-1_53g]

The company’s DMA process is based on a combination of quantitative and qualitative input parameters. The company’s business units contributed by providing the necessary data and relevant information. The collection, processing, and analysis of data were conducted in accordance with internationally recognized standards, scientifically established methodologies, and applicable reporting frameworks.Page 148 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

The main input parameters include:

Analysis of the value chain (upstream, own operations, downstream):
* Operational performance data (energy consumption, waste generation, water use)
* Regulatory and institutional frameworks (EU Taxonomy, ESRS, CSRD)
* Market-based, voluntary sustainability frameworks (SASB, MSCI)
* Risk assessments and industry-specific benchmarking (sectoral trends, peer review)
* Stakeholder insights gathered through consultations, surveys, and interviews with employees, suppliers, customers, and institutional stakeholders

These parameters inform both the selection of material topics, and the mapping of impacts, risks, and opportunities.

Changes in the Impact, Risk and Opportunity Assessment Process [ESRS 2: IRO-1_53h]

During the current reporting period, the Company introduced several improvements to the impact, risk and opportunity assessment process compared to the previous reporting period. These enhancements improve clarity, reliability and alignment, and include:
* A clear distinction between impacts and risks and opportunities, along with the development of a clear, concise and robust IRO matrix.
* An assessment of sustainability trends within the sector and among peer companies.
* Enhanced stakeholder engagement through more structured feedback processes and a recurring simplified stakeholder survey.

The DMA is reviewed and updated on an annual basis, with future revisions scheduled to be carried out annually as part of the Company’s regular reporting cycle and strategic planning process.

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Information regarding the management of impacts, risks and opportunities is disclosed in relevant sections of this Report, as presented in the table below. [E1.IRO-1, E2.IRO-1, E3.IRO-1, E4.IRO-1, E5.IRO-1, G1.IRO-1]

Key Elements in Managing the Impacts of Risks and Opportunities

Chapter and Section in the Report Report Page
E1. IRO-1 Chapter: “Our Commitment to Environmental Responsibility: ESRS E1 – Climate Change, E2 – Pollution” Section: Climate Change Management, Energy, and Greenhouse Gas Emissions 220
E2.IRO-1 Chapter: “Our Commitment to Environmental Responsibility: ESRS E1 – Climate Change, E2 – Pollution” Section: Climate Change Management, Energy, and Greenhouse Gas Emissions 235
E3.IRO-1 Chapter: “Our Commitment to Environmental Responsibility: ESRS E1 – Climate Change, E2 – Pollution” Section: Water Management 248
E4.IRO-1 Chapter: “Our Commitment to Environmental Responsibility: ESRS E1 – Climate Change, E2 – Pollution” Section: Biodiversity 252
E5.IRO-1 Chapter: “Our Commitment to Environmental Responsibility: ESRS E1 – Climate Change, E2 – Pollution” Section Circular Economy 249
G1. IRO-1 Chapter: “G1 Business Conduct” Section: Policies related to business conduct and corporate culture 321

Material Impacts, Risks, and Opportunities and Their Interaction with the Company’s Strategy and Business Model [ESRS 2: SBM-3_48 a, b, c i, ii, iii, iv, d, h]

By identifying the material impacts, risks and opportunities, the Company builds resilience and can anticipate emerging challenges while constructing a resilient response framework and shaping an agile strategy that leverages opportunities and enhances differentiation. In this way, sustainability becomes a driver of transformation and may eventually turn into a source of competitive advantage. PPA integrates all environmental, social, and governance IROs into its overall corporate strategy and enterprise risk management system ensuring oversight, improved decision-making, and alignment between sustainability priorities and operational performance.

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The table below presents the results of the Company’s double materiality analysis following the reassessment process, as described above in the various stages of the methodological approach, as well as topics that are specific to the Company.

Material impacts on people and the environment arising from port operations.

Sustainability Topic Subtopic Time Horizon Value Chain Position
ESRS E1 Climate change E1 Energy Consumption and GHG Emissions Actual Upstream, Own Operation, Downstream
Activities controlled either directly by the Company or by entities along the port’s value chain consume energy. This consumption leads to greenhouse gas (GHG) emissions, which contribute to climate change. To ensure the smooth operation of its activities, as well as to support services and business relationships, the Company requires a continuous and reliable energy supply. Negative
ESRS E2 Pollution E2 Pollution of Air Actual Upstream, Own Operation, Downstream
Air pollution is a key focus for the Company and includes emissions of sulfur oxides (SOx), nitrogen oxides (NOx), particulate matter (PM), carbon monoxide (CO), and volatile organic compounds (VOCs). These emissions originate from ships, cargo handling equipment, trucks, and traffic generated by port activities, affecting the wider region. To a large extent, air pollution arises along the Company’s value chain and has negative impacts on local air quality, public health, and the broader ecosystem. Negative

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Sustainability Topic Subtopic Time Horizon Value Chain Position
ESRS E2 Pollution E2 Pollution of Coasts, Water Column and Sediments (Company Specific) Actual Upstream, Own Operation, Downstream
The Company’s activities across the entire value chain significantly affect marine ecosystems through the pollution of coastal waters, the water column, and sediments. Over time, port expansions lead to the loss of marine habitats, increased stress on aquatic species, and negative impacts on fisheries, while the overall ecosystem of the wider area is degraded. At the same time, the quality of life of neighboring communities is affected, as they may lack access to clean coastal waters. Oil and chemical spills, although usually limited in scale, still occur, while ocean acidification constitutes an additional form of pollution linked to port activities and locally impacts the water column. Negative
ESRS E2 Pollution E2 Noise Pollution (Company Specific) Actual Upstream, Own Operation, Downstream
The Company’s activities and business relationships are linked to traffic control within the port and the wider area, cargo handling, construction works, shipping, and land transportation. These activities generate noise pollution, which degrades the quality of life of neighbouring communities and may cause health effects for residents of the surrounding areas. Negative

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Sustainability Topic Subtopic Time Horizon Value Chain Position
ESRS S1 Own Workforce S1 Work-life Balance & Well-being Actual Own Operation
PPA S.A. provides safe and fair working conditions through a clear internal regulatory framework and continuous dialogue with employees. Employees benefit from stable employment, access to health services, and family‑oriented benefits, which create a lasting positive impact on their well-being and strengthen the Company’s trust, commitment, and operational stability. Positive
S1 Occupational Health and Safety Actual – Potential Own Operation
The Company operates in a demanding and inherently high-risk port environment, where employees are exposed to occupational hazards arising from vessel movements, the use of heavy equipment, and the continuous operation of facilities. Although the Company implements strict procedures, targeted training programs, and monitoring systems to ensure Occupational Health and Safety, work-related risks cannot be eliminated, making the existence of effective response and remediation mechanisms essential. Negative Longterm impact (>5 years)

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Sustainability Topic Subtopic Time Horizon Value Chain Position
S1 Equal Opportunities Actual Own Operation, Downstream
The shipping and port sector has long faced gaps in diversity and gender equality, with women and minority groups being significantly underrepresented in most positions. The Company integrates key principles of equal opportunities and non-discrimination into its human resources management framework, ensuring fair treatment in recruitment, remuneration, and career development. While the Company currently records a low percentage of female employees, in line with broader industry trends; it implements inclusive hiring practices, equal-pay assurance controls, and mentoring programs that can generate measurable social value and highlight PPA S.A. Positive
S1 Employee Engagement and Social Dialogue Actual Upstream, Own Operation, Downstream
The Company plays a vital role in job creation at the local level, in strengthening national economic development, and in facilitating international trade. The Company has a tangible positive impact on employment and on the economic development of the communities neighboring the port, as well as on the national economy as a whole. Positive

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Sustainability Topic Subtopic Time Horizon Value Chain Position
S1 Training and Skills Development for New Technologies (Company Specific) Medium Term Own Operation
The Company exhibits dependencies on its human capital. In light of international decarbonization targets and the search for alternative fuels within the broader maritime sector, the upskilling and reskilling of employees—so that the skills required for new technologies remain available—is critical for maintaining operational performance. The potentially positive impact lies in the Company’s ability to anticipate these developments promptly and to strengthen workforce readiness, thereby mitigating safety risks and supporting a smooth and sustainable transition.

ESRS S3 Affected Communities

S3 Job Creation and Economic Growth (Company Specific)

The Company plays a vital role in job creation at the local level, in strengthening national economic development, and in facilitating international trade. The Port of Piraeus has a tangible positive impact on employment and on the economic development of the communities neighboring the port, as well as on the national economy.
Actual Positive Medium-term Impact (<5 years)

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S3 Pollution Related Community Effects in Relation to Health & Quality of Life (Spills, Noise, Emissions, Waste, Traffic)

The communities surrounding the Port of Piraeus are exposed to tangible pressures associated with the Company’s port and maritime activities, primarily due to traffic congestion linked to the movement of heavy vehicles, transport flows, and the overall operational activity in the wider area. This impact may affect residents’ daily lives, causing delays in transportation, increased disturbance, and a deterioration in the quality of life in the neighborhoods adjacent to the port.
Actual Negative Medium-term Impact (<5 years)

S3 Corporate Social Responsibility (Company Specific)

PPA S.A., as a port authority, interacts directly with the local communities. As a critical hub in global trade, the port is required to operate responsibly, ensuring safe working conditions, the protection of human rights across the value chain, the reduction of pollution, and the transparent and meaningful engagement of stakeholders. A strong Corporate Social Responsibility approach by the Company reinforces
Actual Positive Medium-term Impact (<5 years)

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the trust of local communities, regulatory authorities, and business partners, supporting the Company’s social license to operate and its reputation.

ESRS S4 Consumers & end-users

S4 Passenger Port Operation Safety & Security (Company Specific)

The operation of the Company may have potentially negative impacts on the safety, health, and protection of passengers who use the port facilities and services, including adults, children, older individuals, persons with disabilities, and other visitors. Due to the scale and intensity of maritime and passenger activities, port users may be exposed to accidents, emergencies, or security incidents that could endanger their well-being or disrupt their travel. Such incidents directly affect individuals who interact with the port or depend on its safe and smooth operation.
Potential Negative Medium-term Impact (<5 years)

ESRS G1 Business Conduct

G1 Stakeholder Trust

Maintaining and strengthening stakeholder trust is a critical factor for PPA S.A., as it supports the Port’s social license to operate, ensures investor confidence, and reinforces long‑term partnerships throughout the value chain.
Actual Positive Medium-term Impact (<5 years)

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Risks and Opportunities Identified through the Double Significance Assessment

The table below summarizes the key risks (R) and opportunities (O) identified through the Double Materiality Assessment, along with their relevant descriptions and specific points of occurrence in the value chain (upstream activities, own operations, downstream activities).

| ESRS | Description | Time Horizon | Position in the Value Chain |
| :--- | :--- | :--- | :--- | :--- | :--- |
| | | | Upstream | Own Activities | Downstream |
| ESRS E1 Climate Change | E1 Energy Dependence | Energy consumption is a critical factor for the Company, as almost all operations depend on a continuous supply of energy. The energy comes from the national grid, with possible support from EU reserves during periods of high demand. Energy consumption is not only a cost, but also a systemic risk that affects the long-term resilience and sustainability of operations. | Long-Term Risk >5 years | | X | |
| ESRS E1 Climate Change | E1 Natural Hazards due to Climate Change | The Company is exposed to natural risks stemming from climate change, which may negatively affect its operations. The associated natural hazards include, but are not limited to, marine flooding from storms, heavy rainfall, increased wind speeds, and more frequent or prolonged heatwaves. These phenomena negatively affect safety and operational continuity throughout the value chain and may cause disruptions, especially if the energy supply is also affected. The Company can strengthen its resilience through appropriate adaptation actions. | Long-Term Risk >5 years | | X | |
| ESRS E1 Climate Change | E1 Transition Risks | The Company faces transition risks related to regulatory changes and the tightening of greenhouse gas emissions legislation, as well as market-driven changes. These risks arise from the transition to a low-carbon economy and include policy, market, technology and reputational impacts. Addressing them requires mitigation actions and measures, such as decarbonisation, electrification and adaptation to relevant regulatory developments. | Long-Term Risk >5 years | | X | |

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ESRS Description Time Horizon Position in the Value Chain
Upstream
ESRS E1 Climate Change E1 Transition to Renewable Energy Sources / Energy Mix Improvement The improvement of the energy mix and the gradual full transition to renewable energy sources is an important opportunity for the Company. Electricity from renewable sources can lead to cost reduction, reduction of emissions, enhancement of competitiveness and reduction of negative impact on the environment and society. Long-Term Opportunity >5 years
ESRS E1 Climate Change E1 Participation in EU Climate Finance Programs Access to European programs, such as the EU Green Deal, CEF Transport, LIFE, HORIZON or the EU Innovation Fund, offers external financing opportunities that can support both the transition to renewable energy sources and the implementation of specific mitigation actions. The use of these financial tools can reduce the Company's capital expenditures, foster innovation and promote cross-sectoral cooperation. Long Term Opportunity >5 years
ESRS E1 Climate Change E1 Use of Artificial Intelligence Platforms The Company can benefit from the implementation of digital energy monitoring platforms, artificial intelligence solutions for ship traffic planning, and integrated smart grid systems. These systems allow for real-time monitoring and optimization of energy consumption in loading and unloading equipment, lighting, and electric vehicles. Overall, an improvement in the performance of the Company is expected, as well as reducing the impact and risks of the transition. Long-Term Opportunity >5 years
ESRS S1 Own Workforce S1 Employee Health and Safety Incidents Employee health and safety incidents constitute a constant risk to the Company, as the nature of port operations exposes personnel to potential risks related to heavy machinery and ship activity. Such incidents may result in injuries, business interruptions, legal obligations or even negative effects on the reputation of the Company. Short-term Danger <1 year
ESRS S1 Own Workforce S1 Attracting Diverse Human Resources The limited diversity that characterizes the shipping sector creates a strategic opportunity for PPA SA to position itself as an employer of choice and leader in inclusion issues. By attracting and retaining a wider range of talent including women, younger professionals, people from diverse cultural backgrounds and underrepresented groups. The Company can strengthen the whole better meet market and stakeholder expectations, and ultimately improve its operational performance. Medium-term Opportunity <5 years

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ESRS Description Time Horizon Position in the Value Chain
Upstream
ESRS S1 Own Workforce S1 Skills Shortage and Technological Readiness The increasing automation, digitalization and energy transition of port operations creates a material risk for the Company in case human resources are not sufficiently prepared for new technologies. The skills deficit may lead to reduced productivity, increased security risks and loss of competitiveness compared to more technologically advanced ports. Medium-term risk <5 years
ESRS S1 Own Workforce S1 Upskilling - Technological Skills of the Workforce The transition to digital and sustainable port operations offers PPA SA a substantial opportunity to enhance its competitiveness by upgrading the skills of its human resources. The systematic development of employees' skills ensures business continuity and supports the long-term viability of the Company. Medium-Term Opportunity <5 years
ESRS S4 Consumers and End Users S4 Failures and Safety Incidents A significant operational risk for PPA S.A. is related to the possible occurrence of failures or safety incidents, which could cause damage to individuals, disrupt operations or damage critical infrastructure. Medium-term risk <5 years
ESRS G1 Business Conduct G1 Robust Governance and Risk Management Having strong governance and risk management policies in place creates significant opportunities for the Company, as it can ensure effective oversight, clear decision-making, and limiting exposure to corruption or regulatory non-compliance. Additionally, having a robust governance and risk management framework in the Company prevents mismanagement of financial resources, regulatory violations, and reputational deterioration.

Medium-Term Opportunity <5 years

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G1 Cybersecurity Threats

The lack of effective cybersecurity measures can put the Company at critical risk, with potential repercussions such as operational disruptions, data breaches, and loss of trust from stakeholders. A successful cyberattack could paralyze key port operations, compromise sensitive commercial and personal data, and bring significant financial and legal consequences.

Medium-term risk <5 years

G1 Operational Procedures and Controls

The strengthening of operational processes and controls offers PPA SA the opportunity to improve governance, efficiency and accountability. Through digitalization and automation, standardized processes can optimize resource utilization, support data-driven decision-making, and ensure consistent compliance with international standards.

Medium-Term Opportunity <5 years

G1 Technology and Digital Transformation

Digital transformation offers the Company a significant opportunity to enhance efficiency, transparency and resilience. Smart technologies support data-driven operations, optimize resource utilization, and enhance cybersecurity and compliance. These developments can make PPA a leader as a smart and sustainable port in the Mediterranean.

Long-Term Opportunity >5 years

G1 Access to Green Finance

Strong ESG performance offers the Company the opportunity to attract financing tied to green growth and sustainability. Access to such funds allows for investments in energy-efficient infrastructure and renewable energy initiatives that reduce environmental footprint and operating costs.

Medium-Term Opportunity <5 years

G1 Competitive Advantage and Regional Leadership

The integration of strong governance, digital innovation, and sustainability can enable the Company. to strengthen its regional leadership in the Eastern Mediterranean. Improved efficiency, transparency, and environmental performance may make the port a benchmark for sustainable operations and a preferred partner in global trade networks.

Long-Term Opportunity >5 years

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G1 Geopolitical Externalities and Domestic Political Environment (Special Topic for the Company)

Regional and international political instability may disrupt the Company's operations, trade flows and investment activity. Geopolitical tensions, political changes, or economic uncertainty can impact sea routes, costs, and investor confidence.

Medium-term risk <5 years

G1 Supplier/Contractor Selection Risk

Inadequate adherence to specifications and standards during the supplier/contractor selection process and tender processes may lead to regulatory violations, contractual failures, or ethical issues. However, this risk is mitigated through enhanced due diligence processes, the integration of ESG criteria, and anti-bribery clauses into contracts. guarantees for the protection of suppliers' data as well as systematic and enhanced oversight of partners.

Medium-term risk <5 years

Information on the interaction of impacts, risks and opportunities with the Company's strategy and business model are disclosed in the relevant sections of the Report, as set out in the table below. [E1.SBM-3, S1.SBM-3, S3. SBM-3, S4.SBM-3]

Significant Impacts, Risks and Opportunities and their Interaction with the Company's Strategy and Business Model

Chapter and Section Report Page
E1. SBM-3 Chapter: Our Approach to Manage PPA S.A. Material Impacts, Risks, and Opportunities (IROs) - Climate Change- E2 – Pollution" Secon: Climate Change 215
S1. SBM-3 Chapter: "Our People ESRS S1 – The Company's Workforce" Secon: The Company's Workforce 253
S3. SBM-3 Chapter: "S3 Affected Communities" Secon: Material impacts, risks and opportunies and their interacon with the strategy and business model of the Piraeus Port Authority 290
S4. SBM-3 Chapter: "The Company’s commitment towards the customers of ESRS S4 – Consumers and end users" Secon: Material IRO Issues and Their Interacon with Strategy and Operaons 303

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Impact on the Environment and People

Environmental, social and governance issues affect the Company's business model and value chain, requiring strategic adaptation and investment. Climate change, greenhouse gas emissions, resource consumption, and community health risks are key challenges for businesses. These issues influence the Company's strategy, shape the business model, and also arise throughout the entire value chain, from upstream suppliers to downstream port users. In the previous reporting period, a list of ESG-related objectives was submitted (see updated version of the Objectives, Targets and Progress section). In the current Sustainability Report, the Company presents the progress made and the efforts to gradually incorporate the necessary changes into its operations. The Company has launched actions to address climate change and reduce carbon dioxide emissions, focusing on investments in renewable energy sources, alternative fuel supply services to ships, circular economy practices and digital technologies (IoT, preventive maintenance and automation) to improve efficiency. This direction has already begun to guide project planning and resource allocation. [ESRS 2: SMB-3_48 b].

The Company recognizes that its operations create both positive and negative impacts. Negative environmental impacts include greenhouse gas and air pollutant emissions, noise pollution, and potential marine or coastal pollution, which can impact ecosystems and community well-being. Positive impacts include contributing to economic development, creating jobs and strengthening green infrastructure and services. These impacts stem both from direct activities, such as ship movements and cargo management, and from activities along the entire value chain, including relationships with suppliers and shipping companies. [ESRS 2: SMB-3_48 c(i)] To manage these impacts, the Company has started to implement targeted actions, such as switching to electrified equipment, enhancing environmental monitoring and applying ESG criteria to supplier selection (see section Governance G1-2). The Company is also actively involved in 9 EU-funded projects that support decarbonization and biodiversity protection. Through the risk assessment process, the Company integrates and monitors the environmental impacts that may create financial obligations, regulatory risks and loss of stakeholder trust, while opportunities support innovation and competitive advantage. [ESRS 2: SMB-3_48 c(i)]

The Company recognizes the social dimension of its operations, including employee well-being, health and safety, and the port's relationship with local communities. Initiatives to improve infrastructure, port-city connectivity, and stakeholder engagement have been initiated and continue to enhance resilience and compliance with evolving expectations. negative or positive. Among the negatives are the pressure on local communities and the challenges for the workforce, while the positive ones include local employment, skills development and the strengthening of regional economic activity. Unmanageable social risks can cause reputational damage or operational disruption, while opportunities contribute to stronger partnerships and increased social value. [ESRS 2: SMB-3_48 ci]

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Impact of Activities and Business Relationships

The environmental and social impacts associated with the Company's operations and business relationships may manifest as financial risks or opportunities, impacting the Company's operational performance and cash flow. [ESRS 2: SBM-3_48 c i, ESRS 2: SBM-3_48 civ]

Tightening environmental and other regulatory requirements is a key source of financial risk, as it may require additional compliance investments, temporarily putting a strain on the Company's financial position. In addition, potential deviations from the regulatory framework could result in fines, legal consequences, or adverse effects on the Company's reputation. In line with new environmental requirements, they may be impaired, while increased environmental remediation obligations may lead to the recognition of new provisions. [ESRS 2: SBM-3_48 d]

As part of its strategy, the Company is making investments in sustainable technologies and green infrastructure, which have contributed to enhancing the value of its fixed assets. Although the implementation of these investments implies a temporary increase in liabilities and short-term cash flow pressures, it is expected to pay off in the long term through the reduction of operating costs. The adoption of energy-efficient solutions and the utilization of renewable energy sources support improving profitability while reducing the environmental footprint. [ESRS 2: SBM-3_48 ci]

At the same time, the transition to more sustainable practices creates significant opportunities, such as further improving energy efficiency, containing operating costs and developing partnerships with environmentally responsible stakeholders.These developments strengthen the port's competitive position and support the diversification of the Company's revenues [ESRS 2: SBM-3_48 c, iv]. In addition, participation in innovative partnerships, EU programs and improved transparency promote competitiveness and strengthen the Company's strategic direction. (ESRS 2: SBM-3_48 c i]

Resilience of the Strategy and Business Model [ESRS 2: SMB-3_48f]

Risk management plays a central role in decision-making and, together with strategic and executive management, supports the Company's transition from traditional risk and crisis management to enhancing organizational resilience. As part of its sustainability strategy, the Company plans to conduct a resilience analysis aimed at enhancing its ability to address significant impacts and risks, while identifying and capitalizing on significant opportunities. Upon completion of this analysis, the Company will be able to further assess the resilience of its strategy in relation to the significant risks and opportunities in the next reporting period.

Changes in IROs compared to the previous reporting period [ESRS 2: SMB- 3_48g]

In 2024, impacts, risks, and opportunities were identified and revised in 2025. In this context, no new double materiality assessment was carried out in 2025. Instead, changes were made to the IROs to ensure a clearer and more accurate representation of topic materiality, including separations, renamings, and new additions.

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(amounts in Euro unless stated otherwise)
(amounts in Euro unless stated otherwise)

The table below shows the relevant changes: it includes the title of each IRO as disclosed in 2024 and its alignment with the 2025 IROs, where the individual changes are reflected.

ESRS Subtopic 2024 Materiality Status Change 2025 Materiality Status
Impacts, Risks, and Opportunities
E2 Noise Pollution Renaming Noise Management (Company-specific topic)
E1 Energy Mix Split Energy Dependence (Risk) Transition to Renewable Energy Sources / Energy Mix Improvement (Opportunity)
E1 Climate Change Adaptation Renaming Physical risks due to Climate Change (Risk)
E1 Climate Change Mitigation Renaming Climate Change Transition Risks (Risk)
E1 New Addition Participation in EU Climate Funding Programs (Opportunity)
E1 New Addition Use of Artificial Intelligence Platforms (Opportunity)
S1 Health, Safety and Well-being Split Work-Life Balance and Well-Being (Impact)
Occupational Health and Safety (Impact)
Employee Health and Safety Incidents (Risk)
S1 Employee engagement and social dialogue Renaming Employee Engagement and Social Dialogue (Impact)
S1 Training and skills development in new technologies Split Skills Shortage and Technological Readiness (Risk)
Upskilling - Technological Skills of the Workforce (Opportunity)
S1 New Addition Attraction of a Diverse Workforce (Opportunity)
S3 Community impacts related to pollution affecting health and quality of life. Renaming Impacts of pollution on the community in relation to quality of life (Impact)
S4 Safety and Security in Passenger Terminals (Impact) Renaming and Splitting Safety and Protection of passengers during port operations (Company-specific) (Impact)
Accidents and Safety Incidents (Risk)
G1 New Addition Stakeholder Trust (Impact)
G1 Governance Structure and Composition Renaming Robust Governance and Risk Management (Opportunity)
G1 Economic growth and organizational digitalization Split Cybersecurity Threats (Risk)
Operational Procedures and Controls (Opportunity)
G1 Environmental Management System (Company-specific topic) Renaming Competitive Advantage and Regional Leadership (Opportunity)
G1 Corruption and Bribery Merged into another IRO Robust Governance and Risk Management (Opportunity)
G1 Whistleblower Protection Merged into another IRO
G1 New Addition Access to Green Financing (Opportunity)
G1 New Addition Geopolitical Externalities and Domestic Political Environment (Company-specific topic), (Risk)
G1 New Addition Supplier/Contractor Selection

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Disclosure requirements in the European Sustainability Reference Standards (ESRS) covered by the company's Sustainability Report [ESRS 2: IRO-2_56]

The table below provides an overview of the data points derived from the ESRS, which are derived from other European legislation, as well as information on where they can be located.

General disclosures ESRS Disclosure Requirements Section of the ESRS 2 Report Report Page
BP-1 General basis for the preparation of the Sustainability Report General Disclosures 115
BP-2 Notifications in relation to special circumstances Time Horizon, Indicators and Uncertainty Framework 116
GOV-1 The role of administrative, managerial and supervisory bodies Governance Structure and Sustainability Oversight 184
GOV-2 Information received and sustainability issues examine the administrative, management and supervisory bodies of the undertaking Governance Structure and Sustainability Oversight 184
GOV-3 Integrating performance-related sustainability in incentive schemes GOV-3 - Integrating Sustainability-Related Performance into Incentive Schemes 189
GOV-4 Due diligence statement GOV-4 - Due Diligence Statement [ESRS2. GOV-4_30; 32] 190

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ESRS Disclosure Requirements Report Page
GOV-5 Risk management and internal controls in relation to sustainability reporting GOV-5 Risk Management and Internal Control System on Sustainability Reporting
SBM-1 Strategy, business model and value chain Strategy, Business Model & Value Chain
SBM-2 Interests and views of interested parties Stakeholder Engagement
SBM-3 Significant impacts, risks and opportunities and the interaction with strategy and business Model Impact of Activities and Business Relationships
IRO-1 Description of the process for identifying and assessing material impacts, risks and opportunities The DMA methodological approach
IRO-2 Notification requirements under the ESRS covered by the company's Sustainability Report Disclosure requirements under the European Sustainability Reporting Standards (ESRS) covered by the company's Sustainability Report

Environment

European Sustainability Reporting Standards (ESRS) Disclosure Requirements ESRS Report Section Report Page
Climate Change E1. GOV-3 Integrating sustainability-related performance into incentive schemes Table "Environmental Policy" 213
E1-1 Transition Plan for Climate Change Mitigation Climate Change Adaptation Actions, Planning and Ongoing Initiatives 218
E1. SBM-3 Significant impacts, risks and opportunities and the interaction with the strategy and the business Model European Taxonomy 194
E1. IRO-1 Description of the procedures for identifying and detecting assessment of the significant impacts, risks and climate-related opportunities European Taxonomy 194
E1-2 Policies related to climate change mitigation and adaptation Table "Environmental Policy" 213
E1-3 Actions and resources related to climate change policies Climate Change Adaptation Actions, Planning and Ongoing Initiatives 218
E1-4 Climate change mitigation targets and adaptation to it Climate Change Management, Energy and Greenhouse Gas Emissions 220

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ESRS Report Section Report Page
E1-5 Energy Consumption and Mix Actions Related to Own Activities 224
E1-6 Mixed emissions of scope 1, 2, 3 and total greenhouse gas emissions Energy Efficiency and Carbon Footprint 228
Polluon
E2-1 Pollution-related policies Table "Environmental Policy" 213
E2. IRO-1 Description of the procedures for identifying and detecting assessment of material impacts, risks and opportunities associated with pollution Pollution 235
E2-2 Pollution-related actions and resources Actions, performance and measurement indicators 239
E2-3 Pollution targets Targets and actions for pollution prevention and reduction 236
E2-4 Air, water and soil pollution Actions, performance and measurement indicators, Air Quality Monitoring Program 245
E2-5 Substances of concern and substances of very high concern Actions, performance and indicators Measurement Indicators 239
Water and marine resources
E3. IRO-1 Description of the procedures for identifying and detecting assessment of material impacts, risks and opportunities associated with water and marine resources Water Management 248
Biodiversity and ecosystems
E4. IRO-1 Description of the procedures for identifying and detecting assessment of significant impacts, risks, dependencies and opportunities related to the Biodiversity and ecosystems Biodiversity 252

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Resource Use and Circular Economy
E5. IRO-1 Description of the procedures for identifying and detecting an assessment of the use of material resources and the impact; risks and opportunities related to the circular economy Circular Economy 249
E5-5 Resource outflows Circular Economy 249
General disclosures European Sustainability Reporting Standards (ESRS) Disclosure Requirements Section of the Report Report Page
The Company's workforce S1. S3, S4
S1. SBM-2 Interests and views of interested parties Interests and Opinions of Stakeholders 253
S1.

Significant impacts, risks and opportunities related to the workforce and their interaction with the strategy and business model

Section Topic Page
S1-1 Policies regarding the workforce concerned Policies regarding the Company's workforce 254
S1-2 Procedures for engaging with the workforce concerned and workers' representatives on impacts Procedures for cooperation with the Company's workforce and employee representatives 257
S1-3 Procedures for remedying negative impacts and channels for concerns from the workforce concerned Procedures for the remediation of negative impacts and channels for submission of concerns by the Company's workforce 268
S1-4 Taking action in relation to material impacts on the own workforce and approaches to mitigate material risks and seize material opportunities in relation to the own workforce, as well as the effectiveness of these actions Taking action on the significant impacts and approaches to mitigate significant risks and seize significant opportunities in relation to the Company's workforce and the effectiveness of these actions and approaches 271

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Section Topic Page
S1-6 Characteristics of the company's employees The Company's workforce, Equal Opportunities, Attracting diverse talents 253,278,282
S1-8 Coverage of collective bargaining and social dialogue Employee Interaction and Social Dialogue 277
S1-9 Diversity measurement indicators Attracting Diverse Talent, Equal Opportunities 282,278
S1-12 People with disabilities Equal Opportunities 278
S1-13 Training and skills development metrics Education, skills and technological readiness 285
S1-14 Health and safety metrics Employee Health & Safety Incidents 274

Affected communities

Section Topic Page
S3. SBM-2 Interests and views of interested parties Interests and Views of Stakeholders 291
S3. SBM-3 Significant impacts, risks and opportunities and their interaction with the strategy and business model Significant impacts, risks and opportunities and their interaction with the strategy and business model of the Piraeus Port Authority 291
S3-1 Policies Regarding Affected Communities Policies of PPA SA related to the affected communities 293
S3-2 Procedures for working with affected communities in relation to impacts Procedures for interacting with affected communities regarding impacts 295
S3-3 Procedures for remedying negative impacts and channels for concerns from affected communities Procedures for remedying negative impacts and channels for concerns from affected communities 296
S3-4 Taking action on the significant impacts on affected communities and approaches to managing the significant risks and seizing the significant opportunities in relation to the affected communities and the effectiveness of these actions Actions and approaches on significant impacts for affected communities 298
S3-5 Objectives related to the management of significant negative impacts, the promotion of positive impacts and the management of significant risks and opportunities Targets established in 2024 and progress 302

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Consumers and end-users

Section Topic Page
S4. SBM-2 Interests and views of interested parties Interests and Views of Stakeholders 304
S4. SBM-3 Significant impacts, risks and opportunities and their interaction with the strategy and business model Important IRO Issues and Their Interaction with Strategy and Operations 304
S4-1 Consumers and end-users policies Policies in relation to Consumers and End-Users 306
S4-2 Procedures for engaging with consumers and end- users regarding impacts Processes for engaging with consumers and end-users regarding impacts 311
S4-3 Procedures to remediate negative impacts and channels for consumers and end-users to raise concerns Processes for the remediation of negative impacts and channels for consumers to raise concerns on behalf of end-users 312
S4-4 Actions taken to address material impacts on consumers and end-users and approaches to manage material risks and seizing material opportunities in relation to consumers and end-users, as well as the effectiveness of these actions Measures taken in relation to material impacts on consumers and end-users, as well as approaches to manage material risks 315

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Section Topic Page
S4-5 Targets related to the management of material negative impacts, the promotion of positive impacts and the management of material risks and opportunities Targets related to the management of material negative impacts, the promotion of positive impacts and the management of material risks and opportunities 317

General disclosures Governance Section of the G1 Report

Section Report Page
G1. GOV-1 The role of administrative, supervisory and management bodies Business Conduct
G1. IRO-1 Description of the procedures for identifying and detecting assessment of the significant impacts, risks and opportunities Policies related to business conduct and corporate culture
G1-1 Business conduct policies and corporate governance Culture Policies related to business conduct and corporate culture
G1-2 Managing Supplier Relationships Managing Supplier Relationships
G1-3 Prevention and detection of corruption and bribery Prevention and Detection of Corruption and Bribery
G1-4 Confirmed cases of corruption or bribery Incidents of Corruption or Bribery
G1-5 Political influence and representation activities interests Political Influence and Lobbying Activities
G1-6 Payment practices Payment Practices

Goals, targets and progress

Following the ESRS framework and guided by the outcomes of the DMA, PPA has established focused objectives addressing its most significant sustainability impacts, risks, and opportunities. These objectives reflect the Company’s commitment to continuous improvement and responsible port management, specifically putting forward efforts to progressively reduce negative environmental impacts ensuring employee welfare, achieving stakeholder engagement, and boosting economic

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growth. Each objective is linked to a material topic and supports PPA’s long-term value creation, aligned with EU sustainability expectations. In the current statement these objectives are reviewed, next steps are outlined and planned actions are described. These are all summarized in the table that follows

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CLIMATE CHANGE

IRO Actions [MDR-A_68a] Target [MDR-T_ 80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR- T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j] Q1
Consumption energy and Broadcasts gases of the greenhouse Action Plan to Mitigate Greenhouse Gas Emissions Greenhouse gas mitigation 2025 In progress/ Completion 85% of the target Redening Target for 2026
Shore/Onshore Electrification (OPS) 2030 In progress/ Completion 3% of the target According to the plan
Preparation for the provision of LNG fuel supply services to cruise ships 2026 Ongoing/ Completion 80% of the target According to the plan
Calculation of Scope 3 emissions 2026 In progress/ Completion 70% of the target According to the plan
Climate Change Mitigation Transition Plan (in accordance with the requirements of the European Sustainability Reporting Standards (ESRS) (ESRS Requirement E1-1_17: In the absence of a transition plan, the Company must notify whether a transition plan will be adopted.) 2028 In progress According to the plan

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IRO Actions [MDR-A_68a] Target [MDR- T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR- T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j]
Energy Mix Installation of a solar panel system with a capacity of 1000kWh, corresponding to a reduction in greenhouse gas emissions by 4%. 2030 In progress/ Completion 70% of the target
Adaptation to climate change (Natural and Transitional Hazards) Preparation of a "Vulnerability and Adaptation to Climate Change Study" - Finalize and share with the entire organization & - Design of a resilience action plan (natural hazards) 2025 -- 100% achieved
2028 In progress
Implementaon of the resilience acon plan (approved resilience measures) 2030

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POLLUTION

IRO Actions [MDR-A_68a] Target [MDR- T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR- T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j] Q2
Air Pollution Air pollution monitoring programme (in line with ambient air quality guidelines) Ongoing Keeping concentrations below legislative limits.

PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Metric Target/Scope Year KPI Progress in 2025
SO2 average daily limit < 125 μg m 3 SO2 Concentration Ongoing Q2 Electronic platform for the electronic monitoring of data and measurement results 2025
Coastal pollution, of the water column and of sediment (company-specific) Implementation of contingency plans for spills at sea and on land Ongoing Number of pollution incidents 100% achieved Q2
Annual exercise (emergency exercise) to deal with spills at sea and on land At least one exercise per year Ongoing Number of exercises 100% achieved

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Metric Target/Scope Year KPI Progress in 2025
Marine Water and Sediment Monitoring Programme Annual reports Ongoing Number of reports 100% achieved Q2
Noise pollution Management (for the company) Noise monitoring program for the entire port area Ongoing Annual reports - Lden noise level limit = 70 dB Number of reports
Container Terminal Noise Action Plan Submitted and Approved by the Ministry of Environment 2028 -Construction of sound barriers in accordance with the approved Action Plan for the Noise of the Containers Passenger Terminal. -Reduction of noise levels in the area covered by the sound barriers, after their construction. Curtain wall effectiveness: Lden reduction of at least 2 dB by making sound barriers In progress/ Completion

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OWN WORKFORCE

IRO Actions [MDR-A_68a] Target [MDR-T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR-T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j]
S1 Health, Safety & Wellbeing
Gradual implementation of the ISO 45001 management system Improving health and safety management 2027 Number Accidents In progress/ Completion 5% of the target
Installation of weather stations to measure conditions affecting employee safety and provide real-time alerts Prevenive approach to maintaining health and safety of workers (Ensuring health and safety for all the sectors of PPA S.A.) 2026 In progress/ Completion 30% of the target
IRO Actions [MDR-A_68a] Target [MDR-T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR-T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j]
S1 Employee Interaction and Social Dialogue
Employee satisfaction survey - Design and implementation - KPI tracking Meeting the needs and expectations of employees 2026 % Survey Completion No progress was made
Developing an action plan based on The results of the survey - Design and implementation 2028 Satisfaction rates and the indicators performance will depend on from The Action Plan No progress was made

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IRO Actions [MDR-A_68a] Target [MDR-T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR-T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j]
S1 Equal opportunities (Diversity & Inclusion)
DEI Action Plan Assessing diversity - Design and implementation Promoting diversity, equity and inclusion in the Company 2025 Percentage of people with disabilities 100% achieved
Working with organisations that support the inclusion of people with disabilities in the workforce Creation of relevant benefits in contracts for persons with disabilities 2026 Number of trainings provided 100% achieved
S1 Education and skills development for new Technologies
Offer training to upskill and retrain the workforce Achieve 1.6 number of hours per employee 2026 Number trainings provided 100% achieved
Achieve 1,500 number of hours of training in new technologies Number of participants In progress/ Completion 50% of the target
ESG Education
Achieve 200 number of employee attendance 2026 Number of participants In progress/ 66 entries

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AFFECTED COMMUNITIES

IRO Actions [MDR-A_68a] Target [MDR-T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR-T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j]
S3 Corporate Social Liability (special issue for the Company)
Continuing to engage with local stakeholders Annual budget to support local communities Annually Number of projects Budget made available 100% achieved
Port users / Stakeholder Council Improve the stakeholder management framework and achieve open communication with all port users/stakeholder groups Semi-annual List of active users Percentage of users/stakeholders participating in the Port Users' Council Number of requests/complaints received and resolved within a specified timeframe 100% achieved
New model park in the cruise port area (12.5 acres) Strengthening relations with the local community and the Municipality of Piraeus 2027 Community Satisfaction Rate In progress/ Completion 15% of the target

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IRO Actions [MDR-A_68a] Target [MDR-T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR-T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j]
Strengthening the presence of the Company S.A. in society and social dialogue Monitoring of the Company's social media accounts 2025 Number of posts/press releases of the following 100% achieved
Participation of the Company S.A. in trade associations and trade unions Strengthening the active role of the Company 2025 100% achieved

CONSUMERS AND END-USERS

IRO Actions [MDR-A_68a] Target [MDR-T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR-T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j] Next steps
S4 Security & Passenger protection (Special issue for the Company)
-Conduct an accessibility assessment for people with reduced mobility. -Development of an action plan based on the results Conduct an accessibility assessment for people with reduced mobility. Improving accessibility for disabled groups across the port 2027 Percentage of disabled end-users In Progress/ Completion 10% of the target - Reconstrucon of concrete stairs
Enhancing security Continuous 2025 N/A 100% achieved

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IRO Actions [MDR-A_68a] Target [MDR-T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR-T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j] Next steps
-Installation of steel stairs and LED solar lighting with poles on the walls of the main port dock -Traffic management at cruise terminals to reduce traffic congestion and the risk of accidents -Restructuring of parking lots Proactive approach to maintain the health, safety and security of all visitors to the port of Piraeus 2027 N/A In Progress/ Completion 10% of the target
Eco-buses Transportation of passengers within the port, with zero emissions 2028 Reducing carbon equivalence In progress/ Completion 5% of the target
Interaction with End Users
Collaborations with direct customers to collect feedback from end users 2028 Number of participating companies No progress was made
Updating the website to provide information (passenger rights, complaint form, useful telephone numbers) to end-users on ships, such as those provided to cruise ship passengers 2025 List Feedback Categories end users 100% achieved

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IRO Actions [MDR-A_68a] Target [MDR-T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR-T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j]
UN Human Rights Assessment
Integration of human rights risk into the Risk Register 2027 Number of human rights violations Number of human rights complaints Number of organisational functions at risk of human rights violations 100% achieved
Review and update policies based on human rights assessment and risk integration 2027 - 100% achieved
Participation in the Global Compact Greece 2027 - No progress was made

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BUSINESS CONDUCT

IRO Actions [MDR-A_68a] Target [MDR-T_80b] Year [MDR-A_68c/ MDR-T_80e] KPIs [MDR-A_68e/ MDR-T_80b/ MDR-M_75] Progress in 2025 [MDR-A_68e/ MDR-T_80j]
G1 Improving the governance structure
Strengthening frameworks Expanding Cybersecurity Monitoring Capabilities 2028 No progress was made
Linking managers' remuneration to ESG criteria 2027 No progress was made
BoD Seminars in ESG 2025 100% achieved
Corruption and bribery
Training of officials in critical positions on corruption and bribery issues Identification of functions at risk of corruption and bribery 2026 Number of operations and business processes at risk No progress was made
Zero incidents of bribery and corruption Continuous Annual Number of employees trained per year 100% Achieved - In Progress
Handling all complaint incidents in accordance with the breach reporting policy Manage all incidents Continuous Annual Number of training courses completed No progress was made- In progress
Manage all incidents No progress made - In progress
Responsible supply chain
Evaluating key suppliers with ESG criteria Definition of specific criteria 2028 Number of suppliers evaluated In progress
ESRS Objectives
Integration of the Sustainability Strategy into the Corporate Strategy 3 Objectives per ESG Pillar 2025 3 Objectives 100% achieved
ESRS Objectives
Preparation of the Net Zero Strategy for PPA S.A.

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Governance Structure and Sustainability Oversight [ESRS2.GOV-1, ESRS2.GOV-2]

PPA S.A. maintains a structured and transparent governance framework designed to ensure effective oversight, accountability and the integration of sustainability considerations into strategic and operational decision-making. This framework is aligned with the Hellenic Corporate Governance Code (June 2021), adopted by decision of the Board of Directors in accordance with Article 17 of Law 4706/2020, and operates through clearly defined mandates, documented responsibilities and specialised bodies that supervise both financial and non-financial information.

Administrative and supervisory bodies of the Company

The General Assembly of Shareholders is the supreme governance body responsible for approving the financial and sustainability statement, for electing the Board of Directors, for approving the Remuneration Policy and the Suitability Policy, and finally for endorsing matters relating to the Company’s sustainability strategy when required. Resolutions put forward by the Shareholder Assembly bind all shareholders [ESRS2.GOV-1_22a].

The Board of Directors (hereinafter BoD) exercises management and oversight over the full range of the Company’s activities, including strategic direction, major transactions, monitoring of material impacts, risks and opportunities, and ensuring compliance with regulatory and corporate governance requirements. The BoD safeguards the completeness and reliability of financial and non-financial information in line with Article 151 of Law 4548/2018 [ESRS2.GOV- 1_22a, 22c].

The current BoD consists of nine members, three Executive (33%), six Non-Executive (67%) and three Independent Non-Executive, corresponding to an independence ratio of 33%, in accordance with Article 4 of Law 3016/2002 and Article 9 of Law 4706/2020 [ESRS2.GOV- 1_21a], [ESRS2.GOV-1_21e].

Full Name Position on BoD Independence
HAN Chao Chairman – Executive Member
ZHU Changyu Vice Chairman – Non - Executive Member
SU Xudong CEO – Executive Member
LI Jin CFO – Executive Member
ZHANG Xueyan Non-Executive Member
POLITIS Dimitrios Non-Executive Member

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Full Name Position on BoD Independence
ZHOU Zhonghui Non-Executive Member
LIN Lan Non-Executive Member
Zarakeli Andriana Non-Executive Member

Gender representation is ensured by the participation of three women in a total of nine members of the BoD (33%), fully meeting the minimum threshold of Law 4706/2020 and reflecting the effective implementation of the Company's suitability and diversity policy. Diversity is also demonstrated through citizenship, with six members of Chinese nationality (67%), two of Greek citizenship (22%) and one member of American citizenship (11%), which is consistent with the international ownership structure, the business profile of the Company and extroversion [ESRS2. GOV-1_21d]. This compliance is already confirmed in the Special Annual Report in accordance with article 3 of Law 4706/2020 (2025), demonstrating that the Company has achieved the legal requirement of at least 33% representation of the underrepresented sex in all categories of the Board of Directors well before the imposition date of June 30, 2026.

The average age of the members of the BoD is 58.3 years (reference date 31.12.2025), while the average tenure is 1.7 years, ensuring an effective blend of continuity, institutional knowledge and renewal. The BoD exhibits a high level of professional diversity, collectively possessing extensive international experience and specialized expertise in areas such as shipping, port operations, logistics, finance, accounting, corporate governance, and strategic management. Several members have served as senior executives of China COSCO SHIPPING or its global subsidiaries, possessing extensive knowledge of container shipping, port development, large-scale infrastructure planning and international market dynamics. Additional members contribute a strong background in financial management, investment supervision, and auditing, ensuring sound decision-making on issues related to financial performance, compliance, capital allocation, and operational resilience. [ESRS2. GOV-1_21c].

In 2025, the BoD further strengthened its sustainability capabilities through the attendance and completion of an ESG seminar on "ESG Key Concepts for Board Members and Senior Management", held on 08/10/2025 and supported by the Greek Corporate Governance Council The seminar enhanced the understanding of the new sustainability frameworks, regulatory developments and governance expectations. Complementing internal expertise, the ESG Committee actively supports the BoD in overseeing sustainability issues, examining significant ESG risks and opportunities, and ensuring the integration of sustainability principles and objectives into strategic planning.

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The Company is additionally supported by a dedicated external team of sustainability consultants, which contributes with expert guidance in the assessment of Double Materiality and helps in the formulation of ESG objectives aligned with operational priorities and regulatory obligations, as well as in the completion of the annual Sustainability Report [ESRS2. GOV-1_23, 23a, 23b]

The views of the workers are incorporated through five recognized trade unions: the Union of Permanent Employees, the Union of Technicians and Operators, the Union of Port Workers, the Union of Supervisors, and the Federation of Employees of Greek Ports. These unions engage in a structured, institutionalized dialogue with senior management, contributing to the knowledge of the workforce on working conditions, labor relations, operational issues and emerging needs of employees. The Company maintains bilateral relations, meaning that engagement is carried out exclusively between employee representatives and management, thus ensuring transparent and balanced consultation processes that effectively inform governance and strategic decision-making [ESRS2. GOV-1_21b]

In addition, the BoD is supported by specialised committees in accordance with Law 4706/2020. The Audit Committee, composed of three non-executive members of the BoD (two of whom are independent), oversees financial and sustainability reporting, internal controls, risk management and regulatory compliance, including matters related to sustainability disclosures and due diligence. [ESRS2.GOV-1_22a, ESRS2.GOV-1_22b, ESRS2.GOV-2_26a]

In 2025, the BoD met thirteen times to review the annual and interim financial statements, the results of the audit, to approve the annual compliance and risk management reports, to assess the effectiveness of the internal control system, to make recommendations on the appointment of external auditors, to approve the Annual Budget for Donations and Grants, the Investment Plan and the Asset Allocation Plan, to approve the Company's Strategic Business Plan, to approve the work related to Mandatory Investments, transactions with related parties, as well as to approve internal operating regulations. This approach provides systematic oversight of sustainability-related policies, actions and controls [ESRS2.GOV-1_22a, ESRS2.GOV-2_26a]

The Nomination Committee shall ensure the suitability, independence, diversity and competence of the members of the BoD in accordance with Articles 10 and 12 of Law 4706/2020. It met six times in 2025, reviewing the evaluation of BoD and the committees carried out by an external consultant and preparing recommendations for the election of the new BoD by the next General Meeting. [ESRS2.GOV-1_22a, ESRS2.GOV-1_22b, ESRS2.GOV- 1_23, ESRS2.GOV-1_23a]

The Remuneration Committee oversees the remuneration framework, ensuring alignment with the company's strategic objectives and considering, on a future basis, the possible integration of sustainability-related indicators into executive compensation. The Remuneration Committee met ten times during the reporting period and prepared the Remuneration Report and related submissions to the General Meeting [ESRS2.GOV-1_22a, ESRS2.GOV-1_22d]

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The newly established (November 2025) Strategy Committee analyses, evaluates and advises the Management and the BoD of the Company, in accordance with the provisions of its Regulation of Operation, on issues related to the general strategy of the Company, as well as in particular on strategic issues related to sustainable development, as well as new technologies and innovation, including the Company's digital transformation and sustainability through innovative technologies. The goal of the Committee is sustainable development and optimization of the value of the Company.

The ESG Committee serves as the main internal governance body for sustainability issues. It coordinates the mapping of the value chain, the identification and assessment of material impacts, risks and opportunities, the development of sustainability targets and the monitoring of key performance indicators. The ESG Committee also reviews the Sustainability Report before submitting it to the BoD and ensures that sustainability initiatives are aligned with corporate risk management and due diligence.[ESRS2.GOV-1_22a, ESRS2.GOV-1_22d] The ESG Committee consists of sixteen members representing all key operational and support functions, such as Strategy and Development, Regulatory Compliance, Risk Management, Environmental Services, Port Security, Marketing and Quality, Human Resources, Finance, Procurement, Cruise and Coastal Shipping, Projects and the Secretariat of the Board. Its composition ensures the availability of appropriate expertise to monitor significant impacts, risks and opportunities, and supports the interoperable flow of information. There are four women on the Committee, representing a gender representation rate of 25%.

[ESRS2.GOV-1_21c, ESRS2.GOV-1_21d, ESRS2.GOV-1_23b] The day-to-day management is done by the Chief Executive Officer, who is supported by the Deputy and Assistant Chief Executive Officer and by specialized departments such as Internal Audit, Regulatory Compliance, Risk Management, Human Resources, Environmental Services, Legal Department, Quality Assurance, Operations and Strategic Planning. The reference lines from these functions to the BoD and its committees ensure the structured and timely flow of information on important sustainability issues. At the same time, the BoD oversees the definition of relevant targets related to material impacts, risks and opportunities and regularly monitors progress towards them, as further described in the section "ESRS 2 Objectives, Targets and Progress

[ESRS2.GOV-1_22c, ESRS2.GOV-1_22c(i), ESRS2.GOV-1_22c(ii), ESRS2.GOV-1_22c(iii), ESRS2.GOV-1_22d, ESRS2.GOV-2_26a] Page 189 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Organisational Chart of PPA S.A.

The Company invests in strengthening internal sustainability capabilities through targeted training programs and collaboration with external sustainability consultants. In 2025, employees and Management participated in sustainability-related training programs aimed at enhancing skills in regulatory compliance, impact assessment, and sustainability integration [ESRS2.GOV-1_23, ESRS2.GOV-1_23a].

The information provided to the governance bodies follows structured reporting procedures. The Board of Directors, the ESG Committee and other Committees receive regular updates on the identification and assessment of significant impacts, risks and opportunities, the implementation and effectiveness of sustainability-related policies and actions, the results of internal control, compliance with applicable legislation, including the European Sustainability Reporting Standards (ESRS), and progress towards sustainability objectives. All the above demonstrate the integration of sustainability considerations into organizational governance, risk management and strategic oversight [ESRS2.GOV-1_22a, ESRS2.GOV-1_22d, ESRS2.GOV-2_26a, ESRS2.GOV-2_26b].

It is noted that the table of significant impacts, risks and opportunities is presented in the section "Significant Impacts, Risks and Opportunities and their Interaction with the Company's Strategy and Business Model". [ESRS2.GOV-2_26c]

PPA S.A. implements business ethics policies and promotes a corporate culture based on integrity, transparency and responsible business conduct. The relevant framework of policies and procedures is presented in the section "Business Ethics and Corporate Culture Policies". [G1.GOV-1_5_a, G1.GOV-1_5_b]

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The administrative, management, and supervisory bodies supervise matters related to business ethics within the framework of the responsibilities formally assigned to them, as set out in the Internal Operating Regulations, the Rules of Procedure of the Board of Directors, and the approved policies of the Company. The oversight of ethical conduct, integrity, and compliance is exercised through the governance established by the Company, with responsibilities distributed among the Board of Directors, its Committees, and the competent internal Units, in accordance with the applicable legal and regulatory framework. Information related to business ethics is submitted to the governance bodies through established reporting procedures as outlined in the Company's internal regulations [G1.GOV-1_5a].

All bodies collectively, as well as each member participating individually, have the knowledge and expertise required to oversee the Company's significant impacts, risks and opportunities. Their responsibilities cover key areas such as port operations, maritime logistics, finance, regulatory compliance and corporate governance, as explicitly stated in the "ESRS 2 GOV" Governance Disclosures. The skills, background and professional experience of all members of the governance body are provided in the Corporate Governance Statement included in the current Annual Financial Report [G1.GOV-1_5b].

GOV-3 - Integration of Sustainability-Related Performance in Incentive Schemes

The Company applies a Remuneration Policy approved by the General Meeting in accordance with Article 110 of Law 4548/2018. The Policy sets out the structure of fixed and variable remuneration, the applicable contractual terms and safeguards that ensure independence, objectivity and alignment with the Company’s long-term interests [ESRS2.GOV-3_29a, G1.MDR-P_65a]. The Policy applies to members of the BoD and to Deputies and Assistants to the Chief Executive Officer and is valid for the financial years 2023 to 2026, unless amended by the General Meeting during this period [G1.MDR-P_65b].

Fixed remuneration consists of annual Board fees and, for Executive Members and senior executives, salary, relocation allowances and benefits in kind. Variable remuneration is available only to Executive Members and to the Deputies and Assistants to the Chief Executive Officer and may include short-term profit sharing and long-term incentive components linked to predetermined corporate and individual targets [ESRS2.GOV-3_29(a)]. These targets are primarily based on financial indicators, and therefore, no sustainability-related benchmarks are currently used ESRS2.GOV-3_29b, ESRS2.GOV-3_29c].

The Remuneration Committee oversees the performance assessment process and evaluates the achievement of performance targets related to variable remuneration [ESRS2.GOV-3_29e], [G1.MDR-P_65c]. The Committee operates independently, is composed exclusively of Non-Executive Directors, the majority of whom are Independent, and is mandated to propose performance criteria for Executives, to review the draft Annual Remuneration Report and to submit recommendations to the BoD [G1.MDR-P_65c].

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The Committee meets at least twice annually, always before the preparation or revision of the Remuneration Policy and the Remuneration Report. It has full access to all information and may invite senior executives for clarifications [G1.MDR-P_65e]. The Committee respects all requirements of the Greek corporate governance framework and the relevant provisions of Articles 109 to 114 of Law 4548/2018 [G1.MDR-P_65d].

In accordance with the requirements of the European Sustainability Reporting Standards (ESRS) issued under the CSRD framework, no sustainability-related performance indicators are currently included in the variable remuneration system, and therefore zero (0%) percent of variable remuneration is linked to sustainability-related targets or impacts [ESRS2.GOV-3_29c, ESRS2.GOV-3_29d]. Recognizing the increasing importance of sustainability for long-term value creation, PPA S.A. is considering the gradual integration of sustainability-related indicators into the remuneration structure within future review cycles and with a planning horizon up to 2027. This process considers evolving regulatory expectations, market practices and the Company’s material impacts, risks and opportunities. The Remuneration Policy is reviewed every four years or earlier if required. The Remuneration Committee submits proposals for approval to the BoD for any amendments prior to submission to the General Meeting. [ESRS2.GOV-3_29e]. The Policy is publicly available on the Company’s website and available to all stakeholders [G1.MDR-P_65f].

GOV–4 - Statement on due diligence [ESRS2.GOV-4_30;32]

Information on the due diligence processes can be found throughout the Statement as listed in the table below. This disclosure does not impose additional due diligence obligations nor alter the role of the administrative, management or supervisory bodies.

Due Diligence Basics Sections in the Sustainability Report
(a) Integrating due diligence into governance, strategy and business model GOV-1 & GOV-2- Governance Structure and Sustainability Oversight
ESRS 2-GOV-3 - Integrating Sustainability-Related Performance into Incentive Schemes
ESRS 2-SBM-3 - Significant Impacts, Risks and Opportunities and their Interaction with the Company's Strategy and Business Model
(b) Engaging with stakeholders at all key stages of due diligence GOV-1 & GOV-2- Governance Structure and Sustainability Oversight
ESRS 2- SBM-2 - Interests and Views of Stakeholders
ESRS 2-IRO-1 - The DMA Methodological Approach
E1-2 - Unified Management System of PPA S.A.
S1-1 - Company's Workforce Policies
S3-1 - Policies Related to Affected Communities
S4-1 - Consumer and End-User Policies

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(c) Identification and assessment of adverse effects
ESRS 2-IRO-1 - The DMA Methodological Approach
ESRS 2-SBM-3 - Significant Impacts, Risks and Opportunities and their Interaction with the Company's Strategy and Business Model

(d) Taking action to address these adverse impacts
E1-2- Unified Management System of PPA S.A.
E1-4 - Climate and Energy Targets
S1-1 - Company's Workforce Policies
S1-5 - Objectives related to the management of significant negative impacts, the promotion of positive impacts, and the management of significant risks and opportunities
S3-1 - Policies Related to Affected Communities
S3-5 - Targets established in 2024 and progress
S4-1 - Consumer and End-User Policies
S4-5 - Objectives related to the management of significant negative impacts, the promotion of positive impacts, and the management of significant risks and opportunities

e) Monitoring the effectiveness of these efforts and communicating
E1-4 - Climate and Energy Targets
S1-5 - Objectives related to the management of significant negative impacts, the promotion of positive impacts, and the management of significant risks and opportunities
S3-5 - Targets established in 2024 and progress
S4-5 - Objectives related to the management of significant negative impacts, the promotion of positive impacts, and the management of significant risks and opportunities

Information on the integration of climate-change related parameters into management remuneration is presented in the “Environmental Policy” Section [E1.GOV-3_13].

GOV-5 Risk Management and Internal Control System related to sustainability reporting

As previously stated in the statement, the Company operates an integrated Risk Management and Internal Control System that supports both financial and sustainability reporting. The system is based on the principles of the COSO ERM framework and covers operational, financial, compliance and ESG-related risks. It combines structured risk assessment processes, clearly defined roles and responsibilities, formal policies and procedures and dedicated internal control functions. All parameters collectively ensure the reliability, completeness, and consistency of the information disclosed in the sustainability statement and the financial statements.

The Internal Control System is periodically evaluated by an independent external assessor in line with Greek corporate governance legislation and the internal Policy for the Periodic Evaluation of the Internal Control System and implementation of Law 4706/2020. The latest evaluation, with reference date 31 December 2024, concluded that no material weaknesses were identified in the design and effectiveness of the Internal Control System [ESRS2.GOV-5_36a]. The scope of the Internal Control System at the company level covers all business units, corporate functions, and information systems that contribute to financial and non-financial reporting, including processes for collecting, validating, and consolidating sustainability data.

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The Internal Operating Regulation defines duties and responsibilities for all key positions and ensures an adequate segregation of duties, particularly in areas related to financial and non-financial reporting, procurement, risk management and compliance. The Internal Control System includes controls over the preparation of financial statements under IFRS as adopted by the European Union, as well as controls over the preparation of interim and annual reports, which are reviewed by the Audit Committee and approved in their entirety by the Board of Directors. The same governance and control environment is progressively extended to the ESRS sustainability reporting processes, using common definitions, documentation standards and approval workflows for quantitative indicators and qualitative disclosures [ESRS2. GOV- 5_36a, ESRS2. GOV-1_22c(ii), ESRS2. GOV-2_26a].

The risk management framework integrates the Company's risk appetite and applies to both business and ESG risks. For all identified risks, a dual assessment is carried out, consisting of an inherent risk assessment and a residual risk assessment that takes into account the existing controls, actions and mitigation measures. Risks are recorded in the central Risk Register, which is updated at least annually. The risk assessment uses a qualitative scale that classifies risks according to their severity and likelihood (low, medium, high, critical), supported by probability estimates and impact assessments. The methodology combines historical data, external market and environmental information and internal performance data. In addition, the Company applies Key Risk Indicators that are monitored on a quarterly basis and provide early warning signals on changes in the Company’s exposure to specific risk categories. These indicators are complemented by Key Opportunity Indicators that are used to monitor the material opportunities recorded in the Risk Register [ESRS2. GOV-5_36b].

The risk management framework covers a wide range of risk categories that are relevant to the long-term resilience of the Company, including risks related to weather and climate change, cyber and information security, regulatory and compliance developments, occupational health and safety, geopolitical developments, port-security and safety, financial risks and reputational risks. These risks are managed through documented Policies and Procedures, investment in infrastructure and technology, business continuity plans, employee training and targeted mitigation actions [ESRS2.GOV-5_36c, ESRS2.GOV-2_26b, ESRS2.GOV- 2_26c].

As far as sustainability is concerned, the main risks relate to data quality and completeness for ESG metrics, timely alignment with evolving regulatory requirements and the integration of ESG risks and opportunities into strategy and planning. These risks are mitigated by the establishment of dedicated ESG governance structures, formal documentation of methodologies for double materiality and KPI calculation, engagement of external sustainability advisors and the gradual integration of material sustainability topics into the Risk Register and the Internal Control System. For material ESG issues identified through the double materiality assessment but not yet recorded in the Risk Register, the Company incorporates those in the upcoming review cycle. [ESRS2.GOV-5_36c, ESRS2.GOV-5_36d, ESRS2.GOV- 2_26a, ESRS2.GOV-2_26b, ESRS2.GOV-2_26c].

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Findings through the risk assessment process and internal controls are systematically integrated into internal functions and decision-making. These results feed into the review and update of policies, procedures and the Internal Operating Regulation, the design of corrective actions and remediation plans, the setting of relevant targets and indicators and the allocation of resources to higher-priority risks. The outcome of the double materiality analysis for the current year is incorporated into the Risk Register and is used by management and the ESG Committee when defining the sustainability strategy, action plans, and the content of the sustainability statement.

The Internal Audit Department evaluates the Internal Control System, including the reliability of financial and non-financial information, and issues reports with findings, risk implications and recommendations. These reports are discussed with the audited units, and the agreed actions and timelines are monitored until closure [ESRS2.GOV- 5_36d, ESRS2.GOV-2_26a, ESRS2.GOV-2_26c].

The Company maintains dedicated governance and control functions to support the continuous operation and monitoring of the Internal Control System and the risk management framework. These include the Audit Committee, the Internal Audit Department, the Regulatory Compliance Unit and the Risk Management Unit, all of which operate in accordance with approved internal regulations and have direct reporting lines to Senior Management. Following the BoD’s reconstitution on 8 July 2025, the Audit Committee was also reconstructed with a new composition [ESRS2.GOV-1_22a, ESRS2.GOV-1_22c(ii), ESRS2.GOV-2_26a].

The Regulatory Compliance Unit is functionally independent and staffed with appropriately qualified personnel holding professional certifications and receiving ongoing training in relevant regulatory topics [ESRS2.GOV-5_36a, ESRS2.GOV-1_23a].

Risk management reports, including the Annual Risk Management Report, the Annual Report of the Audit Committee and the Annual Compliance Function Report, are submitted to the Audit Committee and subsequently to the BoD for review and approval. The Internal Audit Department submits quarterly reports to the Audit Committee, outlining significant findings, progress of remediation and any audit scope limitations. Τhe Audit Committee in turn reports these matters to the BoD. The results of the external evaluation of the Internal Control System and of the Corporate Governance System are presented to the Audit Committee and the Board and are summarised in the Corporate Governance Statement of the Annual Financial Report.In addition, risk-related reporting on ESG topics, including the evolution of material ESG risks and opportunities and progress on mitigation actions, is communicated to the ESG Committee and to the Board of Directors, supporting the oversight of the sustainability strategy and the preparation of the ESRS sustainability statement [ESRS2.GOV-5_36e, ESRS2.GOV-2_26a, ESRS2.GOV-2_26b, ESRS2.GOV-2_26c].

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Our Commitment to Environmental Responsibility

European Taxonomy

The Taxonomy of "environmentally sustainable" economic activities is the European Union's classification system for activities that can, under certain conditions, be considered environmentally sustainable or activities that facilitate the transition to an environmentally sustainable economy. Within the Taxonomy legislative framework, companies and organisations can attract investment to further expand and evolve their sustainable activities, provided they meet specific criteria.

Through the Taxonomy Regulation (EU) 2020/852, the EU has defined the criteria that determine the level of sustainability of eligible economic activities. Specifically, the European Union has established the following six environmental objectives, the achievement of which will promote sustainable development within the Union:

i. Climate change mitigation (CCM)
ii. Climate change adaptation (CCA)
iii. The sustainable use and protection of water and marine resources (WTR)
iv. The transition to a circular economy (CE)
v. Pollution prevention and control (PPC)
vi. The protection and restoration of biodiversity and ecosystems (BIO)

The Delegated Acts adopted in addition to the Taxonomy Regulation specify certain technical screening criteria that must be met to demonstrate Taxonomy alignment. At the time of this report’s publication, eligible activities under Taxonomy are described in two effective Delegated Acts.

In 2021, the EU adopted the first Delegated Act, the "Climate Delegated Act" (EU) 2021/2139, which presented activities and technical screening criteria for making a substantial contribution to the achievement of objectives I-II (as presented above), including criteria for Doing No Significant Harm ("DNSH") to the remaining objectives. Furthermore, in 2023, the second Delegated Act, known as the "Taxo 4" (EU) 2023/2486, was adopted and published regarding activities that contribute significantly to objectives III-VI (as presented above).

Alignment with one or more of the objectives implies that an economic activity can be considered "environmentally sustainable," "transitional," or "enabling" under the EU Taxonomy. Therefore, to be considered Taxonomy-aligned, an economic activity must fulfill all of the following criteria:

I. Make a substantial contribution to one or more of the environmental objectives set out in the Regulation and to comply with the technical screening criteria established by the Committee for each economic activity in order to achieve the environmental objectives of the EU Taxonomy.
II. Do no significant harm to any of the other environmental objectives set out in the Regulation.
III. Be carried out in compliance with the minimum safeguards laid down in the Regulation.

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PPA continuously monitors its alignment with these criteria and publishes the relevant data on an annual basis within the non-financial report of its annual financial statements. It should be noted that the Taxonomy Regulation is still under development (e.g., amendments to the first Delegated Act, variations in the presentation of KPI templates), which entails uncertainties during its phased implementation. In the coming years, the EU Taxonomy is expected to evolve into a comprehensive and more detailed framework. Accordingly, PPA strives to provide clear and accurate information in accordance with current provisions, taking into account clarifications from the European Commission, the European Supervisory Authorities (ESAs), and the Platform on Sustainable Finance, as published in the Official Journal of the EU.

The provisions of the Taxonomy framework in effect at the time of this report’s publication require companies within its scope to disclose the amount and percentage of activities that are eligible, non-eligible, and aligned with all six (6) objectives (including those described in the "Taxo 4" Delegated Regulation adopted in 2023) as a proportion of their total Turnover, Capital Expenditure (CapEx), and Operating Expenditure (OpEx), and to conduct relevant alignment assessments for all such activities. Finally, all quantitative information is accompanied by specific qualitative disclosures for all objectives (I to VI).

PPA has applied Regulation (EU) 2020/852, as supplemented by Commission Delegated Regulations (EU) 2021/2139, (EU) 2021/2178, (EU) 2023/2485, and (EU) 2023/2486, to identify eligible activities as of 31 December 2025. In future reporting periods, PPA will adjust its methodology accordingly, in line with applicable legislative requirements.

Piraeus Port Authority Activities

Having carefully reviewed the developments in the Taxonomy framework that came into effect in 2023 regarding amendments to existing Delegated Regulations, the introduction of new Delegated Regulations, and the publication of further clarifications in the Official Journal of the EU, PPA has reassessed its economic activities to present their eligibility.

Based on the above, the Company concluded that focusing its activities on the environmental objective of climate change mitigation provides a more representative view of its long-term climate approach. As a result, the Company has assessed the eligibility of its three (3) activities under the environmental objective of “Climate Change Mitigation” (CCM) for the financial year 2025.

I. 6.10. Sea and coastal freight transport, vessels for port operations and auxiliary activities.
II. 6.16. Infrastructure enabling low-carbon water transport.
III. 6.5. Transport by motorbikes, passenger cars and light commercial vehicles.

Following the eligibility assessment, PPA evaluated the relevant alignment criteria provided for by the Climate Delegated Act (EU) 2021/2139 and the Environmental Delegated Act (EU) 2023/2486. The results of this assessment are presented in the following section of this report.

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6.10. Sea and coastal freight transport, vessels for port operations and auxiliary activities

Taxonomy Activity Description: The activity includes acquisition, financing, chartering (with or without crew), and operation of vessels designed and equipped for the transport of freight or for the combined transport of freight and passengers in sea or coastal waters, whether scheduled or non-scheduled. It also includes the acquisition, financing, leasing, and operation of vessels required for port operations and auxiliary activities, such as tugs, mooring boats, pilot boats, salvage vessels, and icebreakers.

Description of Eligible Activity for PPA S.A.: PPA S.A. owns and operates three (3) floating docks (ship lifts), which are utilised in shipbuilding and ship repair processes as auxiliary equipment/infrastructure. These maritime structures play a critical role in shipbuilding and repair procedures, as they allow for the complete removal of vessels from the water to ensure the proper execution of relevant works. The floating docks operate on electricity and batteries, thereby significantly reducing direct exhaust emissions and contributing to overall greenhouse gas reductions from the repair process.

Alignment Assessment with the DNSH Technical Screening Criteria for the Environmental Objective of Climate Change Adaptation

  1. Substantial Contribution to Climate Change Mitigation (CCM)
    These auxiliary vessels have zero direct CO2 emissions and are used exclusively for supporting ship repair activities; consequently, they do not perform any activities related to fossil fuels.

  2. DNSH: Climate Change Adaptation (CCA)
    Specific details regarding the assessment of physical climate risks in relation to PPA S.A.’s activities are presented below, in the subsection “Physical Climate Risk Assessment (DNSH: Climate Change Adaptation)”.

  3. DNSH Sustainable Use and Protection of Water and Marine Resources (WTR)
    The auxiliary vessels, as part of the broader mechanism for the regular operation of port facilities, have been examined within the framework of the Environmental Impact Assessment (EIA) conducted for the port infrastructure. The EIA includes measures to address the identified climate risks, which have been implemented by PPA S.A. (among others) in the operations of the auxiliary vessels. Furthermore, these vessels neither intake nor discharge water from/to any water body.

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  1. DNSH Transition to a Circular Economy (CE)
    Given that the auxiliary vessels are utilised in ship repair operations, the volume of operational waste generated by the vessels themselves is minimal. The primary waste streams produced consist of sludge from tank cleaning, which is collected and transported to a specialised facility for recovery and alternative management (production of biogas and soil improvers).

5.# DNSH Pollution Prevention and Control (PPC)

Due to their nature and operational mode, the floating docks do not have direct atmospheric emissions, such as sulfur oxides, particulate matter, or nitrogen oxides. The regulatory obligation for such emissions applies to ships; therefore, this criterion is not applicable to auxiliary maritime structures. Furthermore, the floating docks do not discharge sewage, domestic wastewater, or other liquid waste (petroleum products, oils, etc.). Waste generated (sewage) categorised under MARPOL Annex IV from the vessels serviced within the docks is managed under the Port Waste Reception and Handling Plan, collected and processed by the port’s specialised waste contractor.

6. DNSH Protection and Restoration of Biodiversity and Ecosystems (BIO)

There are no ballast water discharges from the floating docks during their operation, as these structures are stationary. Consequently, the introduction of non-indigenous species via biofouling on the hulls of the floating docks is not possible. Discharges of liquid or solid ballast may occur only during repair or maintenance works on the dock itself. Even in such instances, the water originates from the same local area, as the floating docks remain in a fixed position. Noise and vibrations resulting from the operation of all PPA S.A. activities adhere to the limits established by the DAEC (Decision Approving Environmental Conditions). In accordance with this decision, a specific Noise Monitoring Programme is implemented at the outer boundaries of the facilities (boundaries between the port and the urban fabric and other uses outside the port).

6.16. Infrastructure enabling low-carbon water transport

Taxonomy Activity Description: The activity includes the construction, modernisation, operation, and maintenance of infrastructure required for the operation of vessels with zero tailpipe $\text{CO}_2$ emissions or for the port’s own operations, as well as infrastructure specifically intended for transshipment, modal shift, service facilities, safety, and traffic management systems. Economic activities in this category do not include the dredging of waterways. An economic activity in this category is considered an enabling activity, as referred to in Article 10(1), point (i) of Regulation (EU) 2020/852, provided that it meets the relevant technical screening criteria.

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Description of Eligible Activity for PPA S.A.: PPA S.A. owns and operates the Port of Piraeus, the largest port in Greece, as well as the surrounding area, including facilities and infrastructure for commercial purposes. Within the scope of its activities, PPA S.A. also undertakes the maintenance and modernisation of these facilities. The services provided to incoming maritime traffic include, among others, the provision of shore-side services to moored vessels, as well as the loading, unloading, and transshipment of goods.

Assessment of alignment with the DNSH (Do No Significant Harm) technical screening criteria regarding the environmental objective of Climate Change Adaptation.

1. Substantial Contribution to Climate Change Mitigation (CCM)

PPA S.A. aims to become a key stakeholder in sustainable maritime transport and, as such, participates in numerous major international programmes. Specifically, the action portfolio includes the MISSION project, concerning the development of a traffic management and port call optimisation system. Furthermore, the TRAVELWISE project connects PPA systems with air and rail operators to improve traffic management. This constitutes a modernization of the port's operational infrastructure, enabling more effective berthing management and reducing $\text{CO}_2$ emissions by minimizing waiting times. The Super-AlFuel programme aims to assess the risks associated with the use of ammonia, methanol, and hydrogen as alternative fuels. The TRIERES programme focuses on the use of green hydrogen for specific port activities, the GREENLIFE4SEAS programme involves the pilot application of a sustainable material mix for infrastructure repair, and the TREASURE programme focuses on developing a pollution reduction methodology. Regarding the Cold Ironing project, the Company completed the implementation studies and the Environmental Impact Assessment (EIA) conducted under the European CIPORT program. Leveraging the results of CIPORT and EALING, the Company is proceeding with the design and implementation of Onshore Power Supply (OPS) infrastructure at the cruise and ferry facilities, specifically for four cruise ship berths at the Themistokleous coast. Detailed information on the above is presented in the Environmental chapter of the ESG Report. However, since these projects will contribute to this criterion only upon completion, PPA S.A. has included as aligned only the turnover, capital expenditure (CapEx), and operating expenditure (OpEx) related to infrastructure and facilities intended for the transshipment of goods between transport modes: terminal infrastructure and superstructures for loading, unloading, and transshipment of goods (in accordance with Criterion 1(d)). Furthermore, the Company confirms that its infrastructure is not specifically intended for the transport or storage of fossil fuels.

2. DNSH Climate Change Adaptation (CCA)

Specific details regarding the assessment of physical climate risks in relation to PPA S.A.’s activities are presented below, in the subsection “Physical Climate Risk Assessment (DNSH: Climate Change Adaptation)”.

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3. DNSH Sustainable Use and Protection of Water and Marine Resources (WTR)

PPA S.A. monitors the achievement of good water status and ecological potential in accordance with Directive 2000/60/EC by implementing a specific Marine Water Quality Monitoring Programme across the port's entire jurisdiction, the results of which are assessed based on the provisions of said Directive. The Company ensures the daily cleaning of all marine areas under its responsibility from floating debris through a specialised crew. Finally, all relevant activities of PPA S.A. have been examined in the Environmental Impact Assessment (EIA) and are included in the Decision Approving Environmental Conditions (DAEC) of PPA S.A.

4. DNSH Transition to a Circular Economy (CE)

All non-hazardous construction and demolition waste generated by PPA S.A. during new projects, as well as the maintenance of existing port infrastructure, is prepared for reuse, recycling, or other forms of material recovery in accordance with applicable legislation. PPA S.A.’s Decision Approving Environmental Conditions (DAEC) encompasses all construction works undertaken by PPA S.A. and contains specific provisions and Best Available Techniques for the environmentally sound management of solid and liquid waste and the transition to a circular economy.

5. DNSH Pollution Prevention and Control (PPC)

As with waste management, the DAEC governing the construction works undertaken by PPA S.A. contains specific provisions for pollution prevention and control, particularly regarding the reduction of noise, vibration, dust, and gaseous pollutant emissions, etc. Regarding compliance with Appendix C, PPA S.A. falls within the relevant categories and belongs to the activities that do not lead to the manufacture, placing on the market, or use of the substances referred to therein. Compliance regarding usage is ensured through the provisions of the DAEC and the implementation of the National Climate Law (L. 4936/2022, Art. 20), with verified Greenhouse Gas (GHG) emissions calculated according to ISO 14064-1:2018, where the direct emissions category includes emissions from refrigerant gases.

6. DNSH Protection and Restoration of Biodiversity and Ecosystems (BIO)

PPA S.A. does not operate within or in proximity to any biodiversity-sensitive areas or environmentally protected zones. Relevant potential risks to ecosystems have been examined in the Environmental Impact Assessment of PPA S.A., and the Company implements a comprehensive environmental monitoring programme for the port aimed at protecting the biodiversity of the wider area, in accordance with its Decision Approving Environmental Conditions (DAEC).

6.5. Transport by motorbikes, passenger cars and light commercial vehicles

Taxonomy Activity Description: The activity includes the purchase, financing, renting, leasing, and operation of vehicles classified as categories M1 (passenger cars) and N1 (light commercial vehicles), which fall within the scope of Regulation (EC) No 715/2007 of the European Parliament and of the Council, or category L (two-wheel, three-wheel, and four-wheel vehicles).

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Description of Eligible Activity for PPA S.A.: PPA S.A. possesses both owned and leased vehicles of the aforementioned categories, which are assigned to authorised Company personnel to meet operational requirements. The use of these vehicles is deemed essential for ensuring the seamless daily operation of port facilities and the execution of necessary support tasks.

Assessment of alignment with the Technical Screening Criteria for Substantial Contribution and DNSH regarding the environmental objective of Climate Change Adaptation

Regarding this activity, no internal verification has been conducted to date concerning the achievement of the Technical Screening Criteria for Substantial Contribution, as defined in the Commission Delegated Regulation (EU) 2021/2139.Consequently, the Company has not proceeded with further assessment procedures regarding the relevant Do No Significant Harm (DNSH) criteria. This approach reflects the current maturity stage of data collection processes for this eligible and non-aligned activity, with the objective of further strengthening control mechanisms in future reporting periods.

Assessment of Physical Climate Risks (DNSH Climate Change Adaptation (“CCM”))

PPA S.A. systematically monitors physical climate risks to its operations, utilizing the most recent scientific sources. Given that all of its economic activities are carried out within the same narrow geographical area, Management has determined that a comprehensive Climate Risk and Vulnerability Assessment (CRVA), applied at the organisational level, sufficiently reflects the risks for individual activities, thereby fulfilling the EU Taxonomy disclosure requirements. The Company's climate risk analysis considers RCP 4.5 and RCP 8.5 scenarios from the IPCC report in its best effort to cover a wide range of probabilities. At the national level, the only comprehensive national climate change impact and vulnerability assessment report has been prepared by the Bank of Greece, and PPA S.A. has carefully reviewed its findings and recommendations. The Company designs and implements targeted measures in accordance with the proposals of the National Climate Change Adaptation Strategy (NAS), the Regional Climate Change Adaptation Plan (RCAP) for Attica, the National Strategy for the protection and management of the marine environment, and related documents. It is worth noting that the NAS and RCAP propose actions and measures based on the findings presented in the Bank of Greece report. Furthermore, the Company incorporates scientific models and forecasts into its risk analysis, such as reports from the Hellenic National Meteorological Service, in order to continuously improve the accuracy and reliability of its business plans, as well as to safeguard long-term successful and sustainable operations.

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PPA S.A. considers its existing climate and environmental risk registry to be sufficient for the technical screening criteria for climate change adaptation. The process implemented by PPA S.A. for identifying and addressing physical climate risks follows a series of distinct stages as presented below:

I. PPA S.A. examines and records climate and environmental risks and proposes technical solutions and actions through technical studies managed by the Property and Environment Department of PPA S.A., as described below
II. This information is fed to the Risk Analysis Officer of PPA S.A., who examines all economic activities that have the potential to be affected within a reasonable timeframe
III. Identified risks are categorized and prioritized utilizing, among other things, the technical data provided by the Property and Environment Department according to the likelihood and severity of their impact on economic activities
IV. The Risk Analysis Officer of PPA S.A. prepares an annual report detailing the actions to be taken and providing recommendations to Management
V. Based on the results of the risk report, PPA S.A. designs and implements countermeasures in accordance with national and international recommendations.

Through its existing procedures, PPA S.A. has identified a series of risks, including physical climate risks to its operations. Following a thorough review of the risk table provided in Appendix A of the Climate Delegated Regulation, PPA S.A. presents the physical climate risks within its current portfolio that correlate most directly with the following risks listed in the Taxonomy Annexes:
1. Changing wind patterns
2. Changing precipitation patterns and types (rain, hail, snow/ice)
3. Storms

As mentioned in the first section, the EU Taxonomy is a dynamic framework within which PPA S.A. is committed to regularly reassessing developments and its alignment with the relevant criteria. To this end, all of the Company's activities have been examined in the Environmental Impact Assessment (EIA) of PPA S.A., which led to the issuance of the new Decision Approving Environmental Conditions (DAEC) in September 2023. This decision aims to mitigate and offset all impacts of PPA S.A.'s activities on the climate and the environment through appropriate measures.

In compliance with the provisions of the DAEC (Decision Approving Environmental Conditions), PPA S.A. conducted a Special Climate Resilience and Adaptation Study for the Port of Piraeus in 2025, in collaboration with the Academy of Athens. This study includes:
* Specialization of findings from the Environmental Impact Assessment (EIA) regarding the climate vulnerability and adaptation needs of the port, based on current climate models.
* Examination of the consequences of climate change on the port.
* Ensuring compatibility with the Regional Climate Change Adaptation Plan (RCAP) for Attica.
* Identification of points requiring additional actions for the climate resilience of the project or the adjacent areas affected by it, along with corresponding proposals for adaptation measures.

On 22 May 2025, the Management of PPA S.A., in the presence of the Minister of Maritime Affairs and Insular Policy and the Deputy Minister of Climate Crisis and Civil Protection, presented the initial findings of the aforementioned study during a workshop titled “The Port of Piraeus and Climate Change”. The session highlighted the actions that establish the Port of Piraeus as a leader in climate change awareness and readiness. Additionally, a Greenhouse Gas (GHG) emission reduction plan is being developed for the entire port in compliance with the requirements of the National Climate Law. Finally, it is noted that since 2023, PPA S.A. has been participating in Project ARSINOE, an EU- funded programme aimed at creating climate-resilient ports through systemic solutions and innovations. Upon completion of all the aforementioned actions, PPA S.A. expects a significant upgrade of its existing climate risk portfolio, as well as the measures taken for the adaptation of its activities.

Based on the above, PPA S.A. is considered to fulfill the "Do No Significant Harm" (DNSH) criterion for the Climate Change Adaptation objective.

Minimum Safeguards (MS)

The Taxonomy criterion related to Minimum Safeguards is considered to apply at the Entity level rather than for each specific economic activity within an organisation. In the absence of a specific reporting methodology for the topics covered by Minimum Safeguards, PPA S.A. presents its structured approach to safeguarding social issues within the context of its operations and value chain. Having examined the Commission Notice (2023/C 211/01) on the interpretation and application of the provisions set out in Article 18 of the Taxonomy Regulation, as well as the Final Report on Minimum Safeguards by the EU Platform on Sustainable Finance referred to in said Notice, PPA S.A. reports the following information in compliance with the Minimum Safeguards.

Corporate Responsibility is part of PPA’s DNA. Building relationships of trust and cooperation with local communities is a priority for PPA’s Management, aiming to create a sustainable development model that emphasizes environmental protection, charitable activities, education, and support for athletic and cultural causes, within PPA’s capabilities. PPA recognizes that the cornerstone for achieving its goals is the effective utilization of its human resources. With understanding and respect for personnel needs and based on meritocratic criteria, PPA ensures the continuous training and development of its employees, taking into account the Company's needs and the protection of corporate interests.

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At PPA, we support the United Nations 2030 Agenda, as expressed through the 17 Sustainable Development Goals (SDGs). We intend to contribute actively to their achievement by promoting the prosperity and safety of the population, environmental protection, and the fight against poverty. Our priority is to achieve those goals directly linked to the activities and challenges of our sector, as well as all material topics arising from this report.

OECD Guidelines for Multinational Enterprises

In 2020, PPA S.A. established the “PPA S.A. Code of Conduct”, which was distributed to all personnel and members of Management and is available on its website. The PPA Code of Conduct has been developed based on the OECD Guidelines for Multinational Enterprises. At PPA, we consider our people to be our most valuable asset. Therefore, we invest in our human resources with the aim of maximizing efficiency, organization, and the services provided. We ensure excellent working conditions, benefits, opportunities, and educational and development opportunities for our employees. The PPA Code of Conduct was revised and updated by the Board of Directors in 2024. Additional details regarding the diversity of the Board of Directors are available in the “Governance Structure and Sustainability Oversight” section of the Sustainability Statement.

Responsible Risk Management

PPA aims to provide high-quality, high-performance port services safely, contribute to the local and national economy, and strengthen the port's position through sustainable development.Various factors, such as internal and external issues, and the needs and expectations of stakeholders, could be considered potential risks with an impact on PPA (e.g., reputational risk) in achieving its goals and strategy; therefore, it is necessary to identify and address them. PPA’s Management is committed to ensuring continuous efforts to address all risks associated with PPA’s operations and to taking all necessary preventive actions. PPA promotes risk-based thinking across all its departments to protect its values, resources, and reputation, and to effectively manage uncertainty arising from its internal and external environments. Within this framework, the risk of Human Rights violations is fully integrated. Each operational unit bears the responsibility for:
* Identifying and recording potential risks related to its activities.
* Assessing the probability of occurrence and the impact of each risk.
* Defining and implementing appropriate control and prevention measures.
* Monitoring and reviewing risks regularly.

The risk assessment for Human Rights Violations is conducted at least annually, and is coordinated and supported by the Human Resources Department. Simultaneously, the continuous monitoring and management of relevant risks are reinforced by the Whistleblowing Policy and the Anti-Harassment Policy, both already in force within the Organization. Integrating the risk assessment process into daily operations ensures continuous improvement, operational resilience, and compliance with the company's regulatory and strategic requirements.

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Respect for Human and Labour Rights

Respecting human rights as well as the rights of its employees, PPA S.A. complies with all relevant legislation. To this end, the following matters are significant for PPA:

Employee Unions

A total of four (4) primary Unions operate within PPA S.A. (Permanent Employees’ Union, Technicians & Operators’ Union, Dockworkers’ Union, Supervisors-Foremen’s Union) and one (1) secondary Union (Federation of Port Employees of Greece). PPA’s Management maintains close cooperation with employee representatives to ensure the smooth operation of its services and to promote the common interest of both PPA and its employees.

Diversity, Equal Opportunities, and Non-Discrimination

PPA’s core principles include promoting equal opportunities and protecting diversity. PPA’s Management does not tolerate any form of discrimination in hiring or personnel selection, remuneration, training, assignment of work duties, or any other labour activities. PPA respects each employee's diversity and does not tolerate behaviors that may lead to discrimination in any form. At PPA, the experience, personality, academic background, qualifications, performance, and skills of each individual are the primary factors determining selection for more complex and demanding positions of responsibility. Characteristics related to gender, age, religion, origin, color, physical particularities, or beliefs are not grounds for preference or exclusion. In this way, we promote a climate of equality, rooted in respect for diversity and human dignity. Simultaneously, we have implemented three key tools for safeguarding equal opportunities and diversity. Furthermore, we provide our employees with a range of additional benefits, in accordance with the applicable Company Collective Labour Agreement (ECLA), to meet their medical and financial needs, thereby contributing to their health and well-being and that of their families. These benefits demonstrate our willingness to invest in our employees and our commitment to providing a quality work environment.

Occupational Health and Safety

At PPA, we recognize the importance of providing safe working conditions and environments for our personnel, as well as safe transit and traffic conditions for all stakeholders, associates, passengers, etc. Employee safety at work is a top priority and an essential prerequisite for our operations. As an employer, PPA is obligated to take all appropriate measures to protect the safety and health of employees in the workplace. At PPA, we ensure the hygiene and safety conditions for our employees and the areas under their responsibility. To this end, we establish health and safety rules through circulars, announcements, and instructions.

Stakeholder Engagement

As a business organization that priorites transparency and the continuous communication of its actions and initiatives, we interact systematically with our Stakeholders. We recognize as stakeholders those groups that, directly or indirectly, affect and are affected by our activity, belonging either to PPA’s internal environment (shareholders, employees) or to the external environment (suppliers, customers, Local Community representatives, NGO representatives).

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Our primary concern is maintaining continuous, open communication with our stakeholders to build mutual trust and excellent cooperation. Communication and dialogue with each of our key stakeholders are particularly important for identifying their needs and expectations, which are essential for PPA’s operations, and for continuously improving our relationship with them. Please find more information in the "General Disclosures" section and the "Stakeholder Engagement" subsection of the Sustainability Statement. In comparison, the "Our People" section contains more information regarding negative impacts on people, namely the Company's employees and affected communities.

Corruption

PPA demonstrates zero tolerance for corruption and continuously works to raise awareness among its employees regarding the minimization of corruption risks. Anti-corruption measures are primarily included in the "Anti-Corruption and Anti-Bribery Code," which all employees are required to follow. Furthermore, PPA has had zero incidents of non-compliance with anti-corruption legislation. For more information, please refer to the “RESPONSIBLE BUSINESS CONDUCT” section.

Taxation

Taxation is treated as a top priority and is overseen by the highest governing bodies of PPA S.A. To this end, we have implemented adequate tax risk management measures, as described in the OECD Guidelines covering taxation. Furthermore, PPA has had zero incidents of non- compliance with tax legislation. Finally, in accordance with applicable national legislation, PPA receives an annual Tax Certificate following a tax audit conducted by its appointed auditor during the statutory annual audit. More information on this topic is provided in the “Tax Compliance Report” section (Note 9).

Competition Rules

PPA S.A. and its Senior Management are committed to observing and promoting fair competition practices across all its activities and through the daily professional conduct of all its employees. The Internal Audit function ensures compliance with applicable national and international competition regulations throughout the Organisation. In contrast, the Compliance Department ensures compliance with applicable competition rules in the provision of our services. More information is presented in the Organisation’s annual Corporate Responsibility Report: https://www.olp.gr/en/corporate-responsibility/social- responsibility.

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Qualitative Information Accounting Policy

I. Proportion of Annual Turnover

The proportion of aligned and eligible economic activities in the total turnover was calculated based on the net turnover from the provision of services corresponding to Taxonomy activities (numerator), divided by the total net turnover (denominator), both referring to the 2025 financial year. Specifically, the total turnover of PPA S.A. is presented in the “Revenue” item of the “Statement of Comprehensive Income for the year ended 31 December 2025” in PPA’s “Annual Financial Report”.

II. Proportion of Annual Capital Expenditure (CapEx)

The proportion was calculated based on the capitalised expenditures incurred for additions to assets or processes associated with eligible and aligned economic activities. It includes Taxonomy-eligible and aligned capital expenditures (numerator) divided by total capital expenditures (denominator). Total capital expenditure includes additions to property, plant, and equipment, as well as intangible assets and right-of-use assets during the fiscal year, before depreciation and any impairment. Total capital expenditure is determined based on the Statement of Financial Position and is the sum of the following chapters of PPA S.A.’s "Annual Financial Report": the "Additions" line in "Property, Plant & Equipment" (Note 4), the "Additions" line in "Leases" (Note 5), and the "Additions" line in "Intangible Assets" (Note 7).

III. Proportion of Annual Operating Expenditure (OpEx)

The proportion was calculated from operating expenditures for the repair and maintenance of assets or processes associated with eligible and aligned economic activities. It includes Taxonomy-eligible and aligned operating expenditures (numerator) divided by total operating expenditures for repair and maintenance, as well as short-term leases of less than 12 months (denominator). The EU Taxonomy definition of operating expenditure includes research and development (R&D) costs, building renovation costs, maintenance and repair, and any other direct expenditures related to the day-to-day servicing of property, plant, and equipment.The accounting principles used for the preparation of the table presented above are described in Note 3 "Significant Accounting Policies" of the "Annual Financial Report" as of 31 December 2025. The financial report of PPA S.A. has been prepared in accordance with International Financial Reporting Standards (IFRS) as adopted by the European Union (EU). To avoid double- counting in the calculation of the numerator for the Turnover, CapEx, and OpEx KPIs, for activities that contribute substantially to more than one environmental objective, the relevant KPIs are allocated to only one objective.

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Relevant information

I. Regarding turnover

PPA’s eligible turnover for 2025 amounts to 60%, remaining essentially stable compared to the 60% reported in 2024. This eligibility stems primarily from floating docks and cargo handling activities. Of this total, 35% is considered Taxonomy-aligned, arising specifically from the operation of floating docks and cargo management that meet the Technical Screening Criteria for Climate Change Mitigation, compared with 36% in 2024. The steady ratio of aligned to eligible turnover indicates a consistent performance of the Company's sustainable activities. In contrast, the remaining eligible turnover (24%) represents infrastructure that is eligible but not yet aligned.

  • Analysis for 2025
  • Amount in ‘000€
  • Revenue from contracts with customers (in accordance with company regulation) • 88,633.59
  • Revenue from leases • 0.0
  • Other sources of income • 0.0

II. Regarding Capital Expenditure (CapEx)

Taxonomy-eligible capital expenditure showed a slight increase to 86% in 2025, compared to 83% in 2024. This change is attributed to expenditures on floating docks, which recorded a significant increase of approximately 2%, compared with the nearly zero alignment rate in 2024. The steady ratio of aligned to eligible CapEx indicates a balanced investment strategy in the Company’s sustainable activities, with the remaining eligible CapEx (82%) involving infrastructure that is eligible but not yet aligned.

  • Analysis for 2025
  • Amount in ‘000€
  • Additions to tangible fixed assets, installations and equipment • 5,370.53
  • Internally generated intangible assets (incl. combinations) • 0.0
  • Investments in real estate (acquired or recognized) • 0.0
  • Capitalized assets with right of use (RoU) • 0.0

III. Regarding Operating Expenditure (OpEx)

Taxonomy-eligible operating expenditure amounted to 49% in 2025, up from 45% in 2024, reflecting the operational costs of maintaining eligible port infrastructure and floating docks. Within this category, 22% of total operating expenditure is classified as aligned, compared to 15% in 2024, covering the maintenance of assets that already meet the Substantial Contribution and Do No Significant Harm (DNSH) criteria. The increase in aligned and the corresponding shift in eligible OpEx is directly linked to the maintenance needs and repair cycles required by the floating docks and infrastructure. Additionally, the 4% increase in eligible OpEx stems from maintenance performed on the Company’s eligible vehicles during the year.

  • Analysis for 2025
  • Total in ‘000€
  • Research and development (R&D) • 0.0
  • Building renovation measures • 0.0
  • Short-term leases • 0.0
  • Maintenance and repair • 403.47
  • Other direct costs of routine maintenance of fixed assets • 282.13

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(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

It is noted that during the current reporting period, a reclassification of amounts related to the Company's eligible activities was performed. This adjustment was deemed necessary for the more accurate allocation of economic sizes between Activity "6.10. Sea and coastal freight water transport, vessels for port operations and auxiliary activities" and Activity "6.16. Infrastructure enabling low-carbon water transport," due to an inadvertent data mapping error. This adjustment restores the accuracy of the KPIs (Turnover, CapEx, OpEx) per activity for the previous reporting year, ensuring the correct reporting of each activity's contribution based on the definitions of the Taxonomy Regulation. The information presented in this report complies with the requirements of the Regulation and the Delegated Acts issued up to 31 December 2025, without the application of the simplifications introduced by Regulation (EU) 2026/73.The relevant guidelines allow for some interpretation and are continually adapted to the needs of the process. Taking these factors into account, PPA S.A. pays close attention to relevant developments and adjusts its approach accordingly, based on the assumptions and applicable methodology.

Activities related to nuclear energy and mineral gases

PPA is not involved in any of the activities listed in the table above and, therefore, does not present any of the KPI tables in templates 2-5 of Annex XII to Regulation (EU) 2021/2178.

Example 1: Activities related to nuclear energy and mineral gases

Line Activities related to nuclear energy
1. The Company conducts, finances, or has interests in research, development, demonstration, and deployment of innovative power generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle. NO
2. The Company conducts, finances, or has exposure to the construction and safe operation of new nuclear facilities to produce electricity or industrial heat, including district heating or industrial processes, such as hydrogen production, as well as upgrades to their safety, using the best available technologies. NO
3. The Company conducts, finances, or has exposures to the safe operation of existing nuclear facilities that generate electricity or industrial heat, including district heating or industrial processes such as hydrogen production from nuclear energy, as well as upgrades to their safety. NO
Activities related to mineral gases
4. The Company conducts, finances, or has exposures to the construction or operation of power generation facilities that produce electricity using fossil fuels. NO
5. The Company conducts, finances, or has exposure to the construction, renovation, and operation of combined heat/cooling and electricity generation facilities using fossil fuels. NO
6. The Company conducts, finances, or has exposures to the construction, renovation, and operation of heat production facilities that generate heat/cooling using fossil fuels. NO

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Turnover KPI table
Financial year 2025

| Economic Activities (1) | Code (2) | Turnover (3) €000 | Proportion of Turnover 2025 (4) % | Climate Change Mitigation (5) Y; N; N/EL | Climate Change Adaptation (6) Y; N; N/EL | Water (7) Y; N; N/EL | Pollution (8) Y; N; N/EL | Circular Economy (9) Y; N; N/EL | Biodiversity (10) Y; N; N/EL | Climate Change Mitigation (11) Y/N | Climate Change Adaptation (12) Y/N | Water (13) Y/N | Pollution (14) Y/N | Circular Economy (15) Y/N | Biodiversity (16) Y/N | Minimum Safeguards (17) Y/N | Proportion of Taxonomy-aligned (A.1.) or -eligible (A.2.) turnover 2024 (18) % | Category enabling activity (19) | Category transitional activity (20) |
| :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- |
| A. TAXONOMY-ELIGIBLE ACTIVITIES | | | | | | | | | | | | | | | | | | |
| A.1. Environmentally sustainable activities (Taxonomy-aligned) | | | | | | | | | | | | | | | | | | |
| Sea and coastal freight water transport, vessels for port operations and auxiliary activities | CCM 6.10/ CCA 6.10 | 5.875,42 | 2% | Y | N | N/EL | N/EL | N/EL | N/EL | - | Y | Y | Y | Y | Y | Y | 3% | | |
| Infrastructure enabling low carbon water transport | CCM 6.16 | 82.758,16 | 33% | Y | N/EL | N/EL | N/EL | N/EL | N/EL | - | Y | Y | Y | Y | Y | Y | 33% | | |
| | Ε | 88.633,59 | 35% | 35% | 0% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 36% | | |
| | | 82.758,16 | 33% | 33% | 0% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 33% | | |
| | E | 0,00 | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 0% | | |
| T | | 149.620,90 | 60% | 60% | 0% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 60% | | |
| A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) | | | | EL; N/EL | EL; N/EL | EL; N/EL | EL; N/EL | EL; N/EL | EL; N/EL | | | | | | | | | |
| Infrastructure enabling low carbon water transport | CCM 6.16 | 60.987,31 | 24% | EL | N/EL | N/EL | N/EL | N/EL | N/EL | | | | | | | | 24% | | |
| Transport by motorbikes, passenger cars and light commercial vehicles | CCM 6.5 / CCA 6.5 | 0,00 | 0% | EL | EL | N/EL | N/EL | N/EL | N/EL | - | | | | | | | | |
| | | 60.987,31 | 24% | 24% | 0% | 0% | 0% | 0% | 0% | 0% | | | | | | | 24% | | |
| A. Turnover of Taxonomy-eligible activities (A.1+A.2) | | 149.620,90 | 60% | 60% | 0% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 60% | | |
| B. TAXONOMY-NON-ELIGIBLE ACTIVITIES | | 101.164,89 | 40% | | | | | | | | | | | | | | | |
| Total | | 250.785,79 | 100% | | | | | | | | | | | | | | | |

Year Substantial contribution criteria DNSH criteria (“Does Not Significantly Harm”) Turnover of environmentally sustainable activities (Taxonomy- aligned) (A.1) Of which enabling Of which transitional Proportion of turnover/Total turnover Taxonomy-aligned per objective Taxonomy-eligible per objective
CCM CCA
35%

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Table KPI of Capital Expenses

Proportion of CapEx/Total CapEx Taxonomy-aligned per objective Taxonomy-eligible per objective
CCM CCA WTR
5%

Financial year 2025

| Economic Activities (1) | Code (2) | CapEx (3) | Proportion of CapEx 2025 (4) | Climate Change Mitigation (5) | Climate Change Adaptation (6) | Water (7) | Pollution (8) | Circular Economy (9) | Biodiversity (10) | Climate Change Mitigation (11) | Climate Change Adaptation (12) | Water (13) | Pollution (14) | Circular Economy (15) | Biodiversity (16) | Minimum Safeguards (17) | Proportion of Taxonomy-aligned (A.1.) or -eligible (A.2.) CapEx 2024 (18) | Category |
| :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- |enabling activity (19) | Category transitional activity (20) | €000 | % | Y; N; N/EL | Y; N; N/EL | Y; N; N/EL | Y; N; N/EL | Y; N; N/EL | Y; N; N/EL | Y/N | Y/N | Y/N | Y/N | Y/N | Y/N | Y/N | % | E | T | A. TAXONOMY-ELIGIBLE ACTIVITIES | | | | | | | | | | | | | | | | | |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| A.1. Environmentally sustainable activities (Taxonomy-aligned) | | | | | | | | | | | | | | | | | |
| Sea and coastal freight water transport, vessels for port operations and auxiliary activities | CCM 6.10/ CCA 6.10 | 2.009,69 | 2% | Y | N | N/EL | N/EL | N/EL | N/EL | - | Y | Y | Y | Y | Y | Y | 0% | | |
| Infrastructure enabling low carbon water transport | CCM 6.16 | 3.360,84 | 3% | Y | N/EL | N/EL | N/EL | N/EL | N/EL | - | Y | Y | Y | Y | Y | Y | 3% | | |
| Ε | | 5.370,53 | 5% | | | | | | | | 5% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 3% |
| | | 3.360,84 | 3% | | | | | | | | 3% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 3% |
| | | 0,00 | 0% | | | | | | | | 0% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 0% |
| T A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) | | | | EL; N/EL | EL; N/EL | EL; N/EL | EL; N/EL | EL; N/EL | EL; N/EL | | | | | | | | | |
| Infrastructure enabling low carbon water transport | CCM 6.16 | 91.848,90 | 81% | EL | N/EL | N/EL | N/EL | N/EL | N/EL | | | | | | | | 80% | | |
| Transport by motorbikes, passenger cars and light commercial vehicles | CCM 6.5 / CCA 6.5 | 217,01 | 0% | EL | EL | N/EL | N/EL | N/EL | N/EL | - | | | | | | | 92.065,91 | 82% | 82% | 0% | 0% | 0% | 0% | 0% | 80% |
| | | 97.436,44 | 86% | | | | | | | | 86% | 0% | 0% | 0% | 0% | 0% | | | | | | | 83% |
| B. TAXONOMY-NON-ELIGIBLE ACTIVITIES | | 15.343,69 | 14% | | | | | | | | | | | | | | | |
| TOTAL | | 112.780,13 | 100% | | | | | | | | | | | | | | | |
| CapEx of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) (A.2) | | | | | | | | | | | | | | | | | | |
| A.CapExofTaxonomy-eligibleactivities(A.1+A.2) | | | | | | | | | | | | | | | | | | |
| CapEx of Taxonomy-non-eligible activities | | | | | | | | | | | | | | | | | | |
| CapEx of environmentally sustainable activities (Taxonomy- aligned) (A.1) | | | | | | | | | | | | | | | | | | |
| Year | Substantial contribution criteria | DNSHcriteria(“DoesNotSignificantlyHarm”) | Of which enabling | Of which transitional | | | | | | | | | | | | | | |
| | (1) | Code(2) | OpEx (3) | Proportion of OpEx 2025 (4) | Climate Change Mitigation (5) | Climate Change Adaptation (6) | Water (7) | Pollution (8) | Circular Economy (9) | Biodiversit y (10) | Climate Change Mitigation (11) | Climate Change Adaptation (12) | Water (13) | Pollution (14) | Circular Economy (15) | Biodiversit y (16) | Minimum Safeguards (17) | Proportion of Taxonomy-aligned (A.1.) or -eligible (A.2.) OpEx 2024 (18) | Category enabling activity (19) | Category transitional activity (20) |
| €000 | % | Y; N; N/EL | Y; N; N/EL | Y; N; N/EL | Y; N; N/EL | Y; N; N/EL | Y; N; N/EL | Y/N | Y/N | Y/N | Y/N | Y/N | Y/N | Y/N | % | E | T |
| A. TAXONOMY-ELIGIBLE ACTIVITIES | | | | | | | | | | | | | | | | | |
| A.1. Environmentally sustainable activities (Taxonomy-aligned) | | | | | | | | | | | | | | | | | |
| Sea and coastal freight water transport, vessels for port operations and auxiliary activities | CCM 6.10/ CCA 6.10 | 403,47 | 13% | Y | N | N/EL | N/EL | N/EL | N/EL | - | Y | Y | Y | Y | Y | Y | 9% | | |
| Infrastructure enabling low carbon water transport | CCM 6.16 | 282,13 | 9% | Y | N/EL | N/EL | N/EL | N/EL | N/EL | - | Y | Y | Y | Y | Y | Y | 5% | | |
| Ε | | 685,60 | 22% | | | | | | | | 22% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 15% |
| | | 282,13 | 9% | | | | | | | | 9% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 5% |
| | | 0,00 | 0% | | | | | | | | 0% | 0% | 0% | 0% | 0% | 0% | Y | Y | Y | Y | Y | Y | 0% |
| T A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) | | | | EL; N/EL | EL; N/EL | EL; N/EL | EL; N/EL | EL; N/EL | EL; N/EL | | | | | | | | | |
| Infrastructure enabling low carbon water transport | CCM 6.16 | 670,31 | 22% | EL | N/EL | N/EL | N/EL | N/EL | N/EL | | | | | | | | 30% | | |
| Transport by motorbikes, passenger cars and light commercial vehicles | CCM 6.5 / CCA 6.5 | 138,09 | 4% | EL | EL | N/EL | N/EL | N/EL | N/EL | - | | | | | | | 808,39 | 26% | 26% | 0% | 0% | 0% | 0% | 0% | 30% |
| | | 1.494,00 | 49% | | | | | | | | 49% | 0% | 0% | 0% | 0% | 0% | | | | | | | 45% |
| B. TAXONOMY-NON-ELIGIBLE ACTIVITIES | | 1.582,29 | 51% | | | | | | | | | | | | | | | |
| TOTAL | | 3.076,29 | 100% | | | | | | | | | | | | | | | |
| OpEx of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) (A.2) | | | | | | | | | | | | | | | | | | |
| A.OpExofTaxonomy-eligibleactivities(A.1+A.2) | | | | | | | | | | | | | | | | | | |
| OpEx of Taxonomy-non-eligible activities | | | | | | | | | | | | | | | | | | |
| OpEx of environmentally sustainable activities (Taxonomy- aligned) (A.1) | | | | | | | | | | | | | | | | | | |
| Year | Substantial contribution criteria | DNSHcriteria(“DoesNotSignificantlyHarm”) | Of which enabling | Of which transitional | | | | | | | | | | | | | | |

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Operational Expenses KPI table

Proportion of OpEx/Total OpEx Taxonomy-aligned per objective Taxonomy-eligible per objective
CCM CCA WTR CE PPC BIO CCM CCA WTR Pollution Circular Economy Biodiversity
Financial year 2025 % % % % % % % % % % % %
Economic Activities (1) Code (2) OpEx (3) Proportion of OpEx 2025 (4) Climate Change Mitigation (5) Climate Change Adaptation (6) Water (7) Pollution (8) Circular Economy (9) Biodiversity (10) Climate Change Mitigation (11) Climate Change Adaptation (12) Water (13) Pollution (14) Circular Economy (15) Biodiversity (16) Minimum Safeguards (17)

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

ESRS E1 & E2– Climate Change & Pollution

Our Environmental Management Approach

Environmental responsibility remains a fundamental pillar of PPA S.A.’s operations, as the Port of Piraeus constitutes a strategic reference point for commercial and passenger flows in the southeastern Mediterranean. Since publishing its first Sustainability Report, under CSRD framework, in 2024, the Company has continued to strengthen its environmental governance mechanisms and enhanced its processes for assessing impacts, risks and opportunities, supporting the transition toward improved environmental performance and climate resilience. In 2025, the Double Materiality Assessment was updated and refined. As a result of this process, the Company identified the most material environmental impacts, risks and opportunities (IROs) and integrated relevant action into the annual environmental plan.

ESRS E1 – Climate Change
* Negative Actual Impacts: Energy Consumption and GHG Emissions
* Risks: Dependency on Energy
* Climate Change-Induced Physical Risks
* Climate Change Transition Risks
* Opportunities: Renewable Energy Transition / Energy Mix Improvements, Participation in EU Climate-Related Funding, Use of AI-based Platforms

ESRS E2 – Pollution
* Negative Actual Impacts: Pollution of Air, Pollution of Coasts, Water Column and Sediments (Company Specific), Noise Pollution Management (Company Specific)

To support the effective implementation of its environmental commitments, PPA S.A. maintains an integrated management system for quality, environmental, energy and emissions management system certified to:
* ISO 9001:2015 (Quality Management)
* ISO 14001:2015 (Environmental Management)
* ISO 50001:2018 (Energy Management)
* ISO 14064-1:2018 (Emissions Management)

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PPA S.A.’s Integrated Management System

In line with Law 4936/2022, the Company’s Scope 1 and Scope 2 GHG emissions are verified annually by an accredited independent body, ensuring the accuracy and transparency of disclosed data. Pollution-related measurements are conducted exclusively by certified contractors, ensuring the reliability and consistency of environmental information published by the Company.

Environmental Policy

In line with its ongoing commitment to responsible environmental management, PPA S.A. updated its Environmental Policy in March 2025, ensuring alignment with contemporary climate and regulatory requirements, as well as with the ESRS and the obligations of the National Climate Law (Law 4936/2022). This revision strengthened the Company’s action framework by setting clearer directions for reducing GHG emissions, improving energy efficiency, and preventing pollution across port operations. The Environmental Policy explicitly provides for the prevention of pollution incidents and emergencies and, should they occur, the implementation of appropriate measures to control them, limiting and reducing the impact on human health and the environment. This approach is implemented through the Company's Integrated Management System, which includes procedures for prevention, preparedness, and response to incidents of air, water, and soil pollution, in accordance with the Environmental Terms Approval Decision and applicable regulatory requirements. [E2-1_15_c]

The Policy reflects the Company’s commitment to identifying and managing significant environmental impacts, risks and opportunities (IROs), preventing pollution and integrating climate change adaptation into business planning. At the same time, the Company aims to reduce energy consumption and greenhouse gas emissions, enhance the use of renewable energy sources and ensure the continuous improvement of environmental and energy performance. [MDR-P_65_a, E1- 2_25, E2-1_15_a]. These commitments are implemented through the Integrated Management System, certified to ISO 9001:2015, ISO 14001:2015, ISO 50001:2018 and ISO 14064-1:2018. The Environmental Policy is fully aligned with these internationally recognized standards and initiatives, forming a robust and reliable environmental and energy management framework that supports the Organization’s ongoing improvement. [MDR-P_65_d]

The environmental policy applies to all port’s operations and to any stakeholder that uses or works on the premises. [MDR-P_65_b]

ISO 9001:2015 ISO 14001:2015 ISO 50001:2018 ISO 14064-1:2018

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The Manager of the Quality Control Department is the most senior level in the organization, accountable for the implementation of the Policy, while specific aspects of the Environmental Policy are also implemented by the Manager of the Environmental Department. [MDR-P_65_c]

The own workforce of PPA S.A. is actively engaged in the Company’s operations, and employee recommendations and feedback are taken into consideration during the revision of the Company’s Policy. Furthermore, as part of the Company’s DMA Principle, the interests of all stakeholders are assessed, and the Organization’s policies may be adjusted to reflect their needs and expectations when deemed appropriate.[MDR-P_65_e] The Environmental Policy is integrated in the company’s Quality, Environmental & Energy Policy, publicly available on PPA S.A.’s official website, at: https://www.olp.gr/en/quality-control/quality- environmental-energy-policy

[MDR-P_65_f] ESG and Sustainable Development Policy The ESG and Sustainable Development Policy is incorporated into the broader framework of the Company’s Sustainable Development Strategy, which defines the integration of environmental, social and governance (ESG) parameters into the Company’s operation and strategy. The Sustainable Development Policy supports the implementation of long-term sustainability targets and the achievement of climate-neutral and environmentally responsible port activities.

[MDR-P_65_a]. The Company is committed to systematically reducing its environmental footprint and contributing to climate change mitigation through:
* proactive measures to reduce environmental impact and greenhouse gas emissions
* adopting sustainable practices across all port operations
* investments in renewable and alternative forms of energy
* efficient use of natural and energy resources
* minimizing negative impacts on local ecosystems
* implementing the principles of the EU Taxonomy as a tool for defining sustainability targets and green investments

The Company aligns its policy with the principles of ESPO’s Green Guide, setting clear goals and targets for the continuous improvement of its environmental performance. At the same time, it strengthens cooperation with universities and research institutes with the aim of:
* developing and implementing environmental monitoring programs (ambient air quality, noise, water columns and sediments), and
* preparing climate change risk analyses for port projects, infrastructure and activities, to minimize climate-related impacts on the Company’s assets and operations.

The ESG and Sustainable Development Policy applies to all activities within the Port of Piraeus and is binding for all employees, contractors, partners and third parties operating at the Company’s facilities.

[MDR-P_65_b] The Policy is implemented within PPA S.A.’s Integrated Management System, certified to ISO 9001:2015, ISO 14001:2015, ISO 50001:2018 and ISO 14064-1:2018, which ensures the continuous improvement of quality, environmental performance and energy efficiency.

[MDR-P_65_d] The Policy was developed with the participation of all competent internal departments and stakeholders, within the framework of the Double Materiality Assessment and the Company’s integrated management system.

[MDR-P_65_e] The highest level of the Company responsible for the implementation of the ESG and Sustainable Development Policy is the CEO Board, while the ESG Committee supports the coordination, monitoring of implementation, communication and updating of the policy.

[MDR-P_65_c] The ESG and Sustainable Development Policy is publicly available on PPA S.A.’s website: https://www.olp.gr/en/

[MDR-P_65_f]
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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Our Approach to Manage PPA S.A. Material Impacts, Risks, and Opportunities (IROs)

Climate Change

Climate change affects the operational continuity, infrastructure performance and long-term resilience of PPA S.A. The port is exposed to physical hazards such as sea-level rise, extreme temperatures and intense rainfall, which may impact vessel servicing, cargo handling, critical infrastructure and the safety of employees and passengers. Recognizing that climate change is both an environmental and an operational/economic factor, the Company has conducted a comprehensive assessment of physical climate risks in line with the National Climate Change Law and the ESRS. The assessment supports strategic planning, future infrastructure design and long-term resilience.

Assessment of Physical Climate Risks

Climate change is an increasingly significant factor influencing port infrastructure and the daily operations of Piraeus Port. To fully understand the potential impacts, PPA S.A. completed in 2025 an updated resilience and vulnerability assessment covering all activities and critical assets of the port area, following the methodological requirements of the National Climate Change Law and the Regional Adaptation Plan for Attica (PeSPKA) [E1-IRO-1-AR-11c, E1_SBM- 3_19_a]. The analysis includes all of the Company's infrastructure and activities but does not include its value chain. [E1_IRO-1_20_b].

  • Identifying and mapping the interactions that PPA S.A.'s activities have with the environment
  • Engaging with PPA S.A. stakeholders
  • Determining material impacts the Company's operations may have on the environment
  • Determining material risks and opportunities that may result from the Company's business activities
  • Adopting policies that address material impacts, risks and opportunities
  • Developing processes to implement the commitments of the adopted policies
  • Adopt metrics that accurately represent PPA S.A.'s performance
  • Implement action plans that improve PPA S.A.'s performance
Identification Categorisation Commitment Continuous Improvement
Identifying and mapping the interactions that PPA S.A.'s activities have with the environment Determining material impacts the Company's operations may have on the environment Adopting policies that address material impacts, risks and opportunities Adopt metrics that accurately represent PPA S.A.'s performance
Engaging with PPA S.A. stakeholders Determining material risks and opportunities that may result from the Company's business activities Developing processes to implement the commitments of the adopted policies Implement action plans that improve PPA S.A.'s performance

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The assessment was conducted in the framework of the “Climate Change Vulnerability and Adaptation Study of Piraeus port” in collaboration with the Academy of Athens. The scope of the study is as follows:
* Analysing climate changes using models and scenarios aligned with the Attica Regional Climate Change Adaptation Plan (PeSPKA).
* Assessing short- and long-term impacts of climate change on port infrastructure and operations, using the latest climate data. Vulnerability is evaluated against key climate risks such as sea-level rise, wave action, flooding, strong winds, and extreme temperatures.
* Identifying areas requiring additional climate-resilience measures, proposing actions, estimating implementation costs, and exploring potential synergies with other stakeholders.
* Checking the compatibility of proposed measures with the Attica PeSPKA [E1_SBM-3_19_b].

The analysis incorporates climate parameters derived from internationally recognized climate models and the IPCC Representative Concentration Pathways (RCPs), combined with high-resolution projections tailored to the port’s geographical setting. Specifically, the analysis used the RCP4.5 scenario (an intermediate or mitigation scenario) and the RCP8.5 scenario (a scenario of drastic increase in GHG emissions or a no-action scenario).

Methodology

The assessment used seven EURO-CORDEX simulations of 11 km spatial resolution, subsequently downscaled to a finer grid of approximately 250 meters to capture localized climate dynamics. Projections covered the period 1970–2100, and mean values of climate variables and indices were calculated for four time horizons:
* 1986–2005 (baseline period)
* 2041–2060 (short term)
* 2061–2080 (medium term)
* 2081–2100 (long term) [E1_IRO-1_AR11_b, Ε1_SBM-3_AR7_b]

The Company's assets and business activities were reviewed to assess their exposure to climate risks across all the above time horizons. [E1_IRO-1_AR11_a] The analysis evaluated both chronic and acute climatic changes, focusing on temperature, humidity, precipitation, wind, wave height and sea-level rise. These parameters were assessed using a combination of:
* Quantitative analysis of climate model outputs to evaluate likelihood and magnitude
* Qualitative assessment of potential impacts on port infrastructure and operations
* Risk categorization, based on: 1. Likelihood (high, medium, low) 2. Impact severity (extreme, significant, moderate, minor) 3. Duration (short- or long-term effects)

The categorization process supports decision-making and helps prioritize adaptation measures. The climate scenarios used for the physical vulnerability analysis were: [Ε1_IRO-1_21]
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RCP8.5 Scenario

The RCP8.5 scenario is a high-emissions pathway characterized by rapidly increasing greenhouse gas concentrations, expanded fossil fuel use and accelerating land-use pressures. It represents a “worst-case” situation, with projects temperature increases of approximately 3.7°C for the period 2081–2100 compared with 1986–2005. [E1_IRO-1_AR11_d]

RCP4.5 Scenario

The RCP4.5 scenario is a stabilization pathway in which emissions peak around 2040 and decline thereafter, supported by reforestation efforts, increasing renewable energy use and reduced reliance on fossil fuels. The projected temperature rise is approximately 1.8°C by 2081–2100.

Key Physical Climate Risks Identified

PPA S.A.’s Specific Study on Climate Resilience highlights the Company's ability to adapt its strategy and business model to the impacts of climate change in the short, medium, and long term. In this context, specific climate change adaptation actions have been planned (see next paragraph), through which the continuous adaptation of PPA S.A.'s strategy and business model to changing climatic conditions is supported. In the short term, the Company integrates the findings of the Specific Study on Climate Resilience of PPA S.A. into operational planning, the monitoring of critical physical climate risks and the determination of immediate adaptation measures for its activities and infrastructure. In the medium term, the Company may adjust individual technical projects, infrastructure, operational processes and investment priorities, in order to limit exposure to physical climate risks and ensure business continuity.In the long term, the Company maintains the ability to revise planning, upgrade or redesign infrastructure and adapt the way port services are developed and operated, with the aim of maintaining the resilience of its business model under changing climatic conditions. [E1_SBM-3_AR8_b] For example, the action "Development of a cooperation network with academic and research institutions" provides for systematic cooperation with scientific and research bodies to monitor climate change developments, utilizing new scientific data and regularly updating individual adaptation actions. Through this process, the Company ensures the timely review and adjustment of its actions and planning, strengthening the long-term resilience of its activities and infrastructure to the impact of climate change. The section "Climate Adaptation Actions, Planning, and Ongoing Initiatives" presents the adaptation actions designed to strengthen the Company's ability to adapt, and where necessary, readjust its strategy and business model to climate change conditions in the short, medium, and long term. The results of the assessment indicate that the most significant climate-related risks affecting the Company are the following two physical climate risks (climate-related physical risks). PPA S.A.’s Specific Study on Climate Resilience examines only physical risks, while transitional risks will be assessed separately, to complete this assessment by 2028.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

According to the findings of the Specific Study on Climate Resilience, there is uncertainty regarding the likelihood of certain climate risks occurring due to the nature of climate projections and related scenarios. This uncertainty is addressed using expert judgement, based on the best available information and data, including statistics, event logs, simulations, and scientific studies, as well as knowledge gained from consultations with relevant stakeholders. For this reason, the study examines flexible and adaptive risk management measures, such as systematic monitoring of relevant phenomena and the implementation of technical measures when conditions exceed predefined critical thresholds. [E1_SBM-3_18, E1_SBM-3_19_c]

  1. Increase of average summer temperature and increase of heatwaves, leading to higher energy and water consumption, challenging outdoor working conditions, reduced service capacity during peak passenger periods and additional strain on electromechanical equipment. Milder winters, however, may reduce heating demand and improve working conditions.
  2. Rise of average sea level, which may cause damages to port infrastructures and pose challenges for berthing operations.

All risks appear under both RCP4.5 and RCP8.5, though their intensity becomes significantly more pronounced under RCP8.5 toward the end of the century. According to the results of the Climate Change Study, the likelihood and timing of certain physical climate risks remain uncertain, particularly in the medium and long term. The analysis is based on climate model scenarios and available scientific data, but future developments may differ due to uncertainties related to global emissions, technological developments, and macroeconomic conditions. To address these uncertainties, the Company adopts an adaptive approach, which includes continuous monitoring of critical indicators, regular updating of the analysis, and implementation of adjustment measures when predetermined risk thresholds are exceeded. Assets and business activities that are considered to be exposed to significant natural climate risks are taken into account in the Company's strategic planning, in infrastructure investment planning and in the definition of existing and future mitigation and adaptation measures, as described in the section “Climate Adaptation Actions”. [E1_SBM-3_AR8_a]

Climate Adaptation Actions, Planning and Ongoing Initiatives

In 2024, no specific adaptation measures had yet been identified in the context of the climate resilience study. Following the completion of the “Specific Study on Climate Resilience" in 2025, PPA S.A. formulated for the first time a targeted set of adaptation actions aimed at ensuring adequate resilience to extreme and chronic climate events. Strengthening the port's resilience is considered critical for both its continued smooth operation and the protection of its critical infrastructure.

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At the same time, PPA S.A., as part of its overall strategy for decarbonization and reduction of greenhouse gas (GHG) emissions, is developing a special "Action Plan for the Reduction of Greenhouse Gas Emissions" that will cover the entire port area. This plan is currently in its final stages of development and is expected to be completed and published in 2026. In the context of the preparation of the above-mentioned Action Plan measures and specific targets for greenhouse gas emissions in the port area are being examined; however, they have not yet been finalized and remain under development. [E1 IRO-1, AR 11 (c)] Indicatively, among the initial directions that have been proposed are the upgrading of the energy efficiency of the facilities, the prioritization of interventions in the building stock, the replacement of conventional lighting with LED lighting, the integration of renewable energy solutions and smart energy management systems, as well as the improvement of the energy management of building and electromechanical infrastructure. These measures are at a stage of further specification and will be incorporated into the final Action Plan after its completion. [E1-1_16, E1-1_AR18] The actions presented in this section primarily concern the adaptation of the port to climate change. However, some of them are also expected to contribute indirectly to reducing greenhouse gas emissions, while supporting the Company's broader goals of reducing its carbon footprint. [MDR-A_68_a]

The short-term actions to be implemented between 2027 and 2035 include: [E1_SBM- 3_19_c, MDR-A_68_c]
* Development of a cooperation network with academic and research institutions
* Creation of a database of port infrastructure in a GIS environment
* Energy-efficiency upgrade specifications
* Prioritisation of building stock upgrades
* Outdoor area interventions
* Replacement of conventional lighting with LED
* Maintenance manual for air conditioning and electromechanical networks
* Integration of renewable energy solutions and smart energy-management systems.
* Installation of water tanks
* Improvement of rainwater management
* Emergency plans and Crisis response
* Cooperation framework with neighbouring municipalities
* Smart monitoring and early-warning systems
* Maintenance and Construction Manual for Port Works with Integration of Climate Parameters

The “Climate Change Vulnerability and Adaptation Study” is the main action implemented and completed by the Company in 2025 in relation to climate change. At this stage, the study has been submitted to the Ministry of Environment and Energy for review. The study examines the climate-related impacts, risks, and opportunities that may affect the Company’s port facilities and was completed and submitted to the Ministry of Environment in 2025.

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Mitigation and adaptation actions are planned across short, medium and long-term horizons. PPA S.A. has already committed €169,000 to support the implementation of the study. As of the reporting date, these committed resources pertain exclusively to the support of the Study. The above expenditure relates exclusively to the preparation and support of the “Climate Change Resilience and Adaptation Study” and, as at the reporting date, is not associated with implemented investments or physical adaptation projects. As such, the relevant expenditure concerns the current stage of preparation and assessment and is linked to the relevant operating expense items / fees and third-party expenses, as presented in the Financial Statements for the year [E1-3_29_c_i]. As at the reporting date, the above expenditure does not correspond to an implemented investment project or eligible technical intervention and, therefore, is not directly linked to the key performance indicators (KPIs) required under Commission Delegated Regulation (EU) 2021/2178. Any future linkage with relevant CapEx or OpEx indicators will be assessed at the stage of specification and implementation of the individual actions foreseen by the Study. [E1-3_29_c_ii] The future financial instruments for implementing the adaptation actions proposed by the Study will be specified after the completion of the Study's evaluation by the Ministry of Environment and Energy and the examination of each action separately in terms of its budget and financing. [MDR-A_69_c, MDR-A_68_b, MDR-A_69_b, E1-3_AR21, E1-3_29_c_i, E1- 3_29_c_i].

To ensure continuous monitoring of such climate-related developments, PPA S.A. participates in the EU-funded project ARSINOE (Climate-resilient regions through systemic solutions and innovations). The project identifies climate-related risks and opportunities and examines measures that can enhance the port’s resilience to the impacts of climate change.

Climate Change Management, Energy, & GHG Emissions

Energy management and GHG emissions constitute a key priority for PPA S.A. In this context, the Company implements a certified ISO 50001:2018 Energy Management System and, in accordance with the National Climate Law, calculates its Scope 1 and Scope 2 emissions based on ISO 14064-1:2018 since 2022. In 2025, the Company also calculated the significant categories of Scope 3 emissions in accordance with ISO 14064-1:2018.[E1_IRO-1_20_a] As part of the Double Materiality Assessment process and the annual emissions inventory, the Company conducts systematic screening of all its activities, facilities, and business plans, with the aim of identifying existing and potential future sources of greenhouse gas emissions in its activities and along the value chain. The process includes recording direct emissions from fuel consumption and equipment operation, indirect emissions from purchased electricity (Scope 2), and an assessment of relevant Scope 3 categories associated with moored vessels, employee commuting, and business travel. [E1_IRO-1_20_a] The assessment of actual and potential impacts on climate change is based on the quantitative calculation of total greenhouse gas emissions (tCO₂e), the analysis of the main sources of emissions, and the assessment of each category's contribution to the Company's total carbon footprint.

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Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

This process identifies the areas with the largest contribution to emissions, which are taken into account when designing reduction and energy optimisation measures. This assessment focuses mainly on physical risks, which are examined in the context of the Company's Climate Change Study. As the dedicated climate resilience study of PPA S.A. was completed at the end of the reporting period and is under evaluation by the Ministry of Environment, the critical assumptions related to climate are not currently reflected in the financial statements [E1 IRO- 1, AR 15]. During the reporting period, the Company has not yet completed a distinct assessment of transition risks related to climate change (transition risks), such as risks associated with regulatory developments, technological changes, changes in the market or demand and other factors related to the transition to a low-carbon economy. The assessment of these transition risks is expected to be examined separately at a later stage, with a completion horizon up to 2028.

[E1_IRO-1_AR9_a], [E1_IRO-1_AR9_b] Regarding alignment with the EU Taxonomy criteria, the Company discloses the relevant financial indicators as required by Regulation 2021/2139. However, a specific capital expenditure or operational expenditure plan for full activity alignment with the Taxonomy criteria has not been developed for the current period. [E1-1_16_e] At the same time, the Company is in the final stage of preparing the “Action Plan for the Mitigation of Greenhouse Gas Emissions” for the entire port area with the goal to reduce the overall GHG emissions of the Company’s activities. The analysis is centered around measures and actions that reduce GHG emissions, such as energy efficiency, electrification, fuel switching, and use of renewable energy etc., by 2030. The Company does not fall under the exemptions of Regulation (EU) 2020/1818 and is assessed based on the European alignment indicators with the Paris Agreement. [E1_1_16_g] To ensure data reliability and process alignment a uniform methodology for both carbon footprint measurement and target setting for reducing emissions is applied. During the reporting period, quantitative greenhouse gas emission reduction targets are being developed and will be finalized after the completion and approval of the Action Plan for the Reduction of Greenhouse Gas Emissions. Once finalized, the targets will be disclosed in absolute values (tCO₂e and/or as a percentage of the base year) and, where applicable, in terms of intensity, and will be specified for Scope 1, Scope 2 and Scope 3, either separately or in combination. [E1-4_34_a, E1-4_34_b] Additionally, a climate transition plan has not yet been developed, therefore locked-in emissions are not calculated or reported [E1-1_16_d]. The emission targets set to date are not based on a pathway that limits global warming to 1.5°C [E1-4_34_e], nor was climate scenario analysis used to determine them [E1-4_AR30_c]. The Company has set 2028 as the reference year, when it will assess the possibility of developing a formal transition plan [E1-1_17]. During the reference year, the Company did not make any CapEx investments related to coal, oil, natural gas, or energy production activities (NACE B.05, C.19, D.35.1, D.35.3, G.46.71) [E1- 1_16_f].

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Climate and Energy Targets

The Company is developing specific targets for the reduction of greenhouse gas emissions and the improvement of energy efficiency, which are consistent with the material impacts identified in the context of the climate change assessment. During the reporting period, the quantitative targets for the reduction of greenhouse gas emissions have not yet been finalized and are under development, while they will be further specified after the completion and approval of the “Greenhouse Gas Emissions Reduction Action Plan”. [E1-4_33, E1-4_34_a, E1- 4_34_b]

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(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

CLIMATE CHANGE IRO Actions

[MDR-A 68a] Target [MDR- T- 80b] Year [MD R-A 68c/ MD R-T 80e] KPIs [MDR-A 68e/ MDR-T 80b/ MDR – M- 75] Progress in 2025 [MDR-A 68e/ MDR- T- 80j] Next Steps
Ε1 Energy Consumption and GHG Emissions Action Plan for GHG Emissions mitigation Mitigation of greenhouse gases 2025 In progress / 85% of the target achieved Re-setting the target for 2026
Cold Ironing / onshore power supply (OPS) 2030 In progress / 3% of the target achieved According to planning
Preparaon of LNG bunkering for cruise vessels 2026 In progress / 80% of the target achieved According to planning
Calculation of Scope 3 emissions 2026 In progress / 70% of the target achieved According to planning
Transition plan in the frame of climate change mitigation (acc. to ESRS requirements) (ESRS Requirement E1-1_17: If the undertaking does not have a transition plan in place, it must indicate whether it intends to adopt one and, if so, when.) 2028 In progress According to planning
Energy Mix Installation of 1000 kWh solar system corresponding to a 4% reduction of GHG emissions 2030 In progress / 70% of the target achieved According to planning

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(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Climate change adaptation (Physical & Transition Risks)

Action Year Progress in 2025 Next Steps
Preparaon of “Climate Change Vulnerability and Adaptaon Study” -Finalised and communicated throughout the organisaon & -Design of a Resilience Acon Plan (physical risks) 2025 -- 100% achieved - Enhancement of the study to include Transition (financial) risks in accordance with ESRS requirements
Implementation of the Resilience Acon Plan (approved resilience measures) 2028 In progress According to planning
2030 In progress According to planning

During the reporting period, PPA S.A. has not yet finalized measurable, outcome-oriented and time-bound targets for the reduction of greenhouse gas emissions and the improvement of energy efficiency. The relevant targets are under development and will be further specified following the completion and approval of the “Greenhouse Gas Emissions Reduction Action Plan”, from which both the base year and the corresponding quantitative targets, as well as the individual actions for their achievement, are expected to be derived. As a result, during the current reporting period, the disclosure requirements relating to specific quantitative characteristics of targets are not yet applicable, as no final, measurable, outcome-oriented and time-bound targets have been set. [MDR-T_81_b_i, MDR-T_81_b_ii, MDR-T_80_h]

Actions Related to Own Operations

PPA S.A. implements a series of energy actions focused on the gradual increase of renewable energy participation in the Company’s energy mix, the reduction of electricity consumption and the improvement of overall energy performance. These initiatives fall within the framework of the ESRS obligations and the requirements for climate change mitigation. [MDR- T_80_a, E1-3_29_a, E1-4_34_f]

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(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

The Company operates a 430 kWp photovoltaic plant within the Container Terminal, which channels the electricity generated to the Hellenic Electricity Distribution Network. The electricity generated by this station contributes to increasing the production of electricity from renewable sources in the national energy system. For the existing installed capacity, the estimated annual renewable energy production corresponds to emissions avoidance of 232 t CO₂e according to location-based factors and 171 t CO₂e according to market-based factors, at the level of the electricity system. Production capacity is expected to increase by 2030 through the expansion of the existing facility, which will provide an additional 1,000 kWp of capacity, bringing the total to 1,430 kWp. The provision is currently under study. The facility is expected to generate around 2,030 MWh of electricity per year, thereby strengthening the contribution of renewable energy sources to the energy system. [MDR-A_68_a, MDR-A_68_b, MDR-A_68_c]

Based on estimates, the total installed capacity of 1,430 kWp could correspond to the avoidance of approximately 770 t CO₂e per year according to location-based factors and 568 t CO₂e according to market-based factors, at the level of the electricity system.The additional contribution attributable exclusively to the 1,000 kWp expansion is estimated at 538 t $\text{CO}_2\text{e}$ (location-based) and 397 t $\text{CO}_2\text{e}$ (market-based) according to the Ministry of Environment and Energy's latest emission factors. [E1-3_29_b] The above estimates take into account both existing electricity production from the 430 kWp photovoltaic system and the planned installation of a new system by 2030. These calculations are based on the assumption of stable electricity consumption and emission factors for imported energy throughout the reporting period. [MDR-T_80_f] The electricity generated by PPA SA's photovoltaic systems is fed into the national electricity grid and is not consumed by the Company itself during the reporting period. During the same period, the Company did not consume energy from nuclear sources; therefore, total nuclear energy consumption was zero (0). In addition, during the reporting period, the Company did not consume renewable energy or other forms of energy beyond those reflected in the relevant table in section E1-5. Information on the energy mix and energy consumption is presented in detail in section E1-5 of this Report. Furthermore, PPA S.A. does not implement projects involving the removal, capture or storage of greenhouse gases (E1-7), nor does it apply an internal carbon pricing system (E1-8). [E1-5_37_b, E1-5_37_ci, E1-5_37_ciii, E1-5_AR_34]

430 kWp Installed PV Plants
1430 kWp Planned PV Plants

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In parallel, the Company is preparing the “Action Plan for the Mitigation of Greenhouse Gas Emissions”, which covers all port facilities and aims to define coherent measures for reducing emissions by 2030. [MDR-A_68_a], [MDR-A_68_b] The study incurred operating expenses totaling €25,500, as presented in the “Expenses” table [MDR-A_69_a], [MDR-A_69_b]. Given that the ”Action Plan for the Mitigation of Greenhouse Gas Emissions” is still under preparation, as the reporting date it is not yet possible to estimate reliably the amount of future financial resources that will be required for the implementation of the proposed actions. The relevant cost and funding estimates will be determined after the implementation and finalization of the plan and of the individual measures to be proposed. [MDR-A_69_c]. The Action Plan examines a series of decarbonization initiatives, such as energy efficiency, electrification, transition to other types of fuels and the expanded use of renewable energy sources. The Action Plan is expected to be completed within the first half of 2026. Through the Action Plan specific targets for the reduction of greenhouse gas emissions and specific actions for achieving those targets will be defined. During the reporting period, there is not yet any available quantified estimate of the amount of future financial resources that will be required for the implementation of the actions under the “Action Plan for the Reduction of Greenhouse Gas Emissions”, which is still under preparation. The relevant estimate will be made after the completion and finalization of the Plan and of the individual measures to be proposed. [MDR-A_69_c] Moreover, PPA S.A.’s Masterplan (Government Gazette 32D/2023) provides for the design and renovation of building infrastructure in accordance with energy efficiency and green building standards (LEED, ELGBC, DGNB), which will further contribute to the reduction of Scope 2 emissions and improve the Company’s overall environmental performance. [MDR-A_68_a], [MDR-A_68_b] Given that the “Action Plan for the Mitigation of Greenhouse Gas Emissions” is still under preparation, there are currently no available estimates regarding the amount of future financial resources that will be required for the implementation of the proposed actions. The relevant cost estimates will be determined after the completion and finalization of the plan and of the individual measures to be proposed. [MDR-A_69_c]

2024 2025
Annual electricity production from renewable sources (MWh) 686.3 579.68

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With regard to the completion time horizons of the main actions, it is noted that:
I. the “Action Plan for the Reduction of Greenhouse Gas Emissions” is expected to be completed within the first half of 2026,
II. the interventions arising from the Masterplan will be implemented gradually, depending on the maturity and approval of the individual projects,
III. the existing operational optimization actions are already being implemented and continue on an ongoing basis, and
IV. the actions related to the potential use of artificial intelligence tools are under evaluation and, if approved, will be included at a later stage of implementation. [MDR-A_68_c]

At the operational level, PPA S.A. implements a range of energy- and fuel-saving practices, including algorithmic optimization of container-terminal operations (CATOS), the gradual replacement of lighting with LED fixtures and the procurement of energy-efficient equipment where technically feasible. In addition, the Company is examining the potential use of digital and AI-supported tools to enhance operational and energy performance. Such technologies may support improved monitoring of equipment efficiency, optimization of terminal operations and the early identification of “abnormal”/elevated consumption patterns. These initiatives are intended to complement PPA S.A.’s broader actions under its GHG Mitigation Plan. The Company also supports emission reductions beyond its own boundaries through actions that support port users in their own efforts to reduce emissions. In this context, the Company, through its participation in an EU-co-funded project (CIPORT) has prepared technical, environmental and financial studies for five passenger-ship berths and four cruise berths. OPS infrastructure is expected to significantly reduce fossil fuel consumption and emissions during berth periods and contribute to the mitigation of the port’s GHG and air pollutant emissions. [E1-3_29_a] Project financing is covered by both EU and Company funds, with PPA S.A. contributing approximately 50% of eligible costs. PPA S.A.’s budget allocation amounts to €170,000 for the CIPORT project, with the Company covering 50% of eligible expenditures. [MDR-A_69_a], [MDR-A-69_b], [MDR-A_69_c, E1-3_AR21] The implementation of the above initiatives is subject to the availability and allocation of appropriate financial and technical resources, as well as the integration of the relevant technological solutions into the Company's existing operational framework. In addition, the Company is working on the development of liquefied natural gas (LNG) bunkering services for cruise vessels, as a first step towards providing alternative fuel bunkering services to vessels [MDR-A_68_b, E1-3_29_a].

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This action is expected to support the gradual transition of the port towards lower-carbon solutions and to contribute to the Company’s broader goals for reducing greenhouse gas emissions. Liquefied Natural Gas is considered a transitional fuel towards decarbonization, and its bunkering requires research and the implementation of specific procedures to ensure safe operation. The timeline for decision-making on related actions is expected within 2026. [MDR- A_68_c]

Energy Efficiency and Carbon Footprint

PPA S.A. relies on actual electricity and fuel consumption data, drawn from supplier invoices and from available measuring equipment installed within the facilities. These data are used to record and distinguish consumption by facility, operation and type of equipment, ensuring accuracy in data collection and subsequent processing. For the conversion of fuel consumption into energy and GHG emissions, the official emission factors and the relevant methodologies issued by the Ministry of Environment and Energy are applied, aligned with the framework of the national climate change law. The emission factors used for the following calculations of Scope 1 and Scope 2 emissions are based on the published factors of the Ministry of the Environment and Energy for the year 2024. These calculations will be updated after the publication of the corresponding factors for the year 2025 by the Ministry of Environment and Energy and will be subject to external verification in accordance with ISO 14064-1. It should be noted that, as part of this process, there may be minor differences in the initially estimated results due to the updating of emission factors or improvements in the available activity data. Upon completion of the external verification, the updated data will be reflected in the Company's subsequent Report. [E1-6_AR_39_b], E1-6_AR_46_h [E1-6_AR_46_h], [MDR-M_77_a] [MDR-M_77_a]

In the tables below, the 2024 figures show minor deviations compared to those published in the 2024 Annual Financial Report, as detailed in the section ‘Changes in the preparation and presentation of sustainability information compared to the previous reporting period’ of ESRS 2. The revised calculations for 2024 correspond to figures that have already been externally verified in accordance with ISO 14064-1.Page 230 από 437

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Energy Consumption (MWh)

Category 2024 (Published) 2024 (Revised) 2025
Gasoline 562.88 562.88 604.88
Diesel 10,847.11 11,023.5 12,116
Fuel consumption from crude oil and petroleum products 11,409.99 11,586.38 12,720.88
Consumption of purchased/ acquired electricity, thermal energy, steam & cooling from fossil fuels 18,979.23 19,407.52 19,783.17
Total non-renewable energy consumption (fossil fuels) 30,389.22 30,993.90 32,504.05
Percentage of non-renewable energy sources (fossil fuels) in total energy consumption (%) 100% 100% 100%
Consumption of purchased/acquired energy (electricity, heat, steam, cooling) from RES 0 0 0
Total renewable energy consumption 0 0 0
Share of renewable sources in total energy consumption(%) 0% 0% 0%
Total energy consumption 30,389.22 30,993.90 32,504.05
Energy intensity (MWh/million € net revenue) 132.38 134.20 129.60
Annual electricity production from RES for sale (MWh) 686.30 686.30 579.68
Electricity Percentage (%) 62.50% 62.5% 60.9%

[E1-5_37], [E1-5_37_a], [E1-5_37_c], [E1-5_37_cii], [E1-5_AR_34], [E1-5_38_b], [E1- 5_38_e], [E1-5_AR_34], [E1-5_39], [MDR-M_75]

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For the calculation of energy intensity, the Company distinguishes revenue streams associated with climate-related activities, in line with ESRS requirements. [E1-5_40, E1-5_41, E1-5_42, E1-5_43]. This distinction allows for a more accurate association between energy consumption and relevant economic activity, enhancing transparency and comparability among indicators. PPA operates in NACE sectors C, E, and H, which have been classified as high climate impact, while all other revenue from low climate impact sectors relates to foreign currency fluctuations, which do not involve any energy consumption. [E1-5_43_ΑR_38] Scope 1 and Scope 2 emissions are calculated and disclosed based on the level of operational control exercised by PPA S.A. over the relevant activities, [E1-6_48_a_AR43] , [E1-6_49_a, E1- 6_44, 52_b_AR45_AR47, E1-6_44, 52_a_ AR45_AR47] in accordance with ESRS requirements and boundaries applied remain consistent, ensuring comparability with previous reporting periods and in compliance with ISO 14064-1 standard.

Revenue (million € net revenue) [E1-5_43_ΑR_38]

Category 2024 2025
Net revenue from activities in high climate impact sectors (used for calculating energy intensity 229.56 249.52
Other income – Regarding exchange rate fluctuations 1.43 1.44
Total revenue as presented in the financial statements 230.99 250.96

All renewable electricity generated through the PV panels of the Company is fed into the national grid and at present no other renewable or non-renewable energy is produced or consumed. [E1-5_39, E1-5_37_ci, E1-5_37_ciii, E1-5_37_b, E1-5_AR_34] The Company does not use coal, coal products, natural gas or other fossil fuels beyond those shown in the table above. [Ε1-5_38_a, E1-5_38_c, E1-5_38_d]

2024 2025
Specific Energy Consumption (MWh/million € Turnover) 134.17 129.60

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The Company also reassessed its Scope 3 emissions for the current reporting year in compliance with ISO 14064-1:2018. The most material source of Scope 3 emissions relates to vessels berthed at the port’s facilities. In accordance with ISO 14064-1:2018, the Company continues to quantify the following Scope 3 categories, which have been identified as relevant to its operational profile:
* Category 3.3: Emissions from business travel
* Category 3.5: Emissions from employee commuting
* Category 5.1: Emissions or removals from the product use stage

These categories were calculated for both 2024 and 2025, remaining essentially unchanged in terms of their scope. However, for 2025, the Company adjusted the coding of emission categories, switching from the GHG Protocol classification to the corresponding coding provided for in ISO 14064-1:2018. During the current reporting period, PPA SA focused mainly on updating and improving the quality and completeness of the data used for the calculation of Scope 3 emission categories. The remaining Scope 3 emission categories were assessed as not relevant, primarily based on qualitative assessment and documented professional judgment, taking into account PPA S.A.’s operational profile, the nature of its activities, and the relevance of each category to port operations. This assessment was not based on a full quantitative estimation for all other categories. [E1-6_AR_46_i]

GHG emissions (t CO₂e)

2024 (Published) 2024 (Revised) 2025
Stationary combustion 176.21 223.32 264.05
Mobile combustion 3,081.42 2,856.38 3,117.12
Fugitive emissions 188.29 325.45 107.97
Total Scope 1 3,445.92 3,405.15 3,489.15
Scope 2 – Market-based 6,909.52 5,288.26 5,390.61
Scope 2 – Location-based 9,482.06 4,518.79 4,606.25
Total Scope 1 & 2 (market-based) 10,355.44 8,693.41 8,879.76
Total Scope 1 & 2 (location-based) 12,927.98 7,923.94 8,095.40

Scope 3 Emissions (t CO₂e)

Category 2024 (Published) 2024 (Revised) 2025
Category 3.3: Business travel 125.84 125.84 147.71
Category 3.5: Employee commuting 1,025.64 1,025.64 851.28
Category 5.1: Emissions or removals from the product use stage 44,549.10 232,174.11 244,970.93
Total Scope 3 Emissions 45,700.59 233,325.59 245,969.93

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Total Emissions (Scope 1-2-3) (t CO₂e)

2024 (Published) 2024 (Revised) 2025
Total emissions – Market-based 56,056.03 242,019.00 254,849.69
Total emissions – Location-based 58,628.57 241,249.53 254,065.33
Total emissions intensity index (t CO₂e / million €) – Market based 242.68 1,047.75 1,016.15
Total emissions intensity index (t CO₂e / million €) – Location based 253.82 1,044.42 1,013.02

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The GHG emissions calculations were carried out in accordance with ESRS requirements and ISO 14064-1:2018. [E1-6_44, E1-6_48_a, E1-6_49_a, E1-6_49_b, E1-6_50, E1-6_51, E1- 6_52_a, E1-6_52_b, E1-6_AR_41, E1-6_AR_46_d, E1-6_AR_50, E1-6_53, MDR-T_80_j, MDR- M_75]. The Company does not participate in regulated emissions trading schemes [E1-6_48_b], nor does it use guarantees of origin or other conventional means for Scope 2 emissions. [E1- 6_AR_45_d] No biofuels are used in the Company’s activities or in the reported Scope 3 categories, therefore biogenic emissions are considered insignificant. During the reporting period, there were no significant changes in the definition of the reporting entity or in the scope of the upstream and downstream value chain of the Company compared to the previous reporting period. Therefore, there are no effects from "subsequent significant events or changes in circumstances" between the reporting dates of the entities in the value chain and the date of approval of the financial statements of the Company for the purposes of calculating emissions. However, in 2025, the Company undertook a significant methodological review of the calculation of category 5.1 emissions in order to improve accuracy. The new approach includes the use of more detailed calculation methods, improved data collection and analysis, and the identification of new parameters relating to the specific conditions of vessels and their activities. These changes have led to a change in the results compared to the previous reporting period, enhancing the consistency and continuous improvement of the methodological calculation approach. As a result of the methodological review and the adaptation of the coding of emission categories to the ISO 14064-1:2018 standard, differences arose in the results for the 2025 period compared to the previous reporting period. For comparability purposes, the corresponding 2024 data were recalculated according to the new methodological approach and the comparative figures were updated accordingly. [E1-6_47, E1-6_AR_43_c, E1-6_AR_45_e, E1-6_AR_46_j, E1-6_47, E1-6_AR_42] Scope 2 location-based emissions were calculated with the country’s unified energy mix, while market-based emissions were calculated using the supplier’s energy mix. The CO₂e conversion factors were obtained from DAPEEP, while CH₄ and N₂O factors were applied based on the National Climate Law (4936/2022). [E1-6_AR39_b]

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Category 3.3 Emissions from Employee Travel includes the daily commutes of the organisation's staff to and from work, using private cars, public transport, or alternative means (such as bicycles, scooters, walking, etc.). Employees and senior management who use company vehicles are excluded from the calculation, as emissions related to company vehicles are included in the organisation's Scope 1 emissions. It should be noted that no teleworking model is applied, so this parameter is not examined. For quantification purposes, a travel survey was conducted with a 46% response rate, and the results were extrapolated to the entire workforce (excluding those who travel in company vehicles). Emissions were calculated based on distance traveled and the latest emission factors per mode of transport from the UK Department for Environment, Food and Rural Affairs (DEFRA).To estimate the number of trips per employee, the five-day working week, public holidays, and an average number of vacation days per employee were taken into account, in accordance with national legislation. [E1- 6_AR_46_g].

Category 3.5 Emissions from Business Travel

Includes domestic and international travel undertaken by staff for business purposes. The scope includes air travel and overnight stays in accommodation for business purposes, regardless of whether the trip was organised through a contracted travel agency or directly by the employee.

Emissions from air travel were calculated based on distance traveled (distance-based approach). Flights were categorised by type (domestic, short-haul, long-haul) and seat class (economy, business, average), and the most recent DEFRA emission factors available for the corresponding reference year were applied.

Emissions from hotel stays were estimated based on the total number of overnight stays per country. Country-specific emission factors, as published by DEFRA and the GREENVIEW tool, were used for the calculation, taking into account variations in the energy mix and average energy intensity of the hotel sector in each country. The methodology was applied based on available primary data (distances, number of overnight stays) and secondary emission factors from internationally recognised sources, ensuring consistency and comparability between reporting periods.

Section 5.1 Emissions or removals from the product use stage

Includes vessels moored at the organisation's port facilities. The scope includes vessels operating at the Container Terminal, the Ro-Ro Terminal, the Coastal Shipping Lines (including Argosaronic, Perama ferry terminal and G1), the Ship Repair Zone and other repair areas, as well as the vessel service areas of AGET, CORAL, foreign cargo ships, and small vessels operating within the port.

Emissions were calculated using the bottom-up methodological approach of the Fourth IMO GHG Study 2020, based on the operation of main and auxiliary engines during berthing. The following were used to determine emissions:
* arrival and departure times (where available from the Agency and/or the competent Port Authority),
* vessel type and size data,
* technical characteristics (engine power, year of manufacture),
* typical fuel consumption values.

The technical data were obtained either from available internal information or from recognised external databases (Fourth IMO GHG Study 2020, EQUASIS, MarineTraffic).

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In cases of insufficient data (e.g., unavailable precise data on berthing times or vessel technical characteristics), documented assumptions were applied regarding average dwell time and engine operation. Where critical technical data (e.g., year of manufacture) were missing, a conservative approach was adopted, selecting the most unfavorable technological scenario to avoid underestimating emissions. The CO₂, CH₄, and N₂O emission factors per fuel type were taken from the Fourth IMO GHG Study 2020 and converted to CO₂e based on the corresponding global warming potential (GWP) values. The calculation took into account the regulatory framework governing the use of fuels within European ports, in accordance with applicable European and national legislation[E1-6_AR_46_h, E1-6_AR_39_b]

Greenhouse gas emission intensity indicators are calculated as tons of CO₂e per million euros of turnover (tCO₂e/€ million). The revenue used to calculate the specific indicators corresponds to the net revenue of PPA S.A., as presented in the published financial statements for the reporting period. No adjustment or exclusion of revenue is made for the calculation of the intensity indicator, and therefore the net turnover used to calculate the emission intensity is fully consistent with the net revenue in the financial statements, without any differentiation or balance of revenue that is not taken into account. [E1-6_55, E1-6_AR_55, E1-6_55, E1- 6_AR_55]

Pollution

Within the framework of the Double Materiality Assessment and in accordance with the requirements of the European Sustainability Reporting Standards (ESRS), PPA S.A. carried out a systematic screening of all port facilities, activities and operational areas, with the objective of identifying actual and potential impacts, risks and opportunities related to pollution. [E2_IRO-1_11_a]

During the assessment, a stakeholder consultation process was conducted, involving shipping companies, employees, port service providers and local communities affected by port operations, in line with the engagement process described in the relevant chapter of this Report. [E2_IRO-1_11_b]

The screening process for pollution issues was based on the approved Environmental Impact Study (EIS) and the applicable Decision on the Approval of Environmental Terms (AEPT), which specify the relevant sources of pollution, monitoring requirements, and prevention and mitigation measures for port activities. At the same time, the results of the Environmental Monitoring Programme (seawater, sediments, air pollution, noise) were taken into account, as well as the Company's procedures and actions for the prevention and management of pollution incidents. The basic assumptions of the assessment were the full coverage of the facilities and activities controlled by PPA S.A., the examination of both actual and potential impacts, and the use of measurement data where available. [E2_IRO-1_11_a]

The results revealed that material impacts are primarily linked to activities within the port value chain, including berthing, vessel operations, loading/unloading activities and fuel handling, which may result in leaks of lubricants or fuels and local air quality degradation. [E2- IRO-1_AR9]

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Within the screening process, the Company identified areas and activities where pollution constitutes a material topic:
(a) Operational locations where pollution is a potential impact
* Cruise Terminal
* Container Terminal
* Car Terminal
* Ship Repair Zone and Dry Docks
* Land-based support facilities (auxiliary & bunkering zones)
(b) Business activities associated with significant pollution impacts
* Vessel berthing and dwell
* Loading and unloading operations
* Bunkering, transport and handling of fuels
* Maintenance and repair activities
* Operations of service providers and contractors

Targets and Actions for Pollution Prevention and Reduction

Although the activities of PPA S.A. do not involve the discharge of pollutants into the environment, the Company has established a structured framework of objectives and preventive measures aimed at minimizing the risk of any small-scale leaks or pollution incidents that may occur. The Company systematically monitors and evaluates the impact of its activities and remains committed to their continuous reduction, in full alignment with its Integrated Management System, the Environmental Terms Approval Decision, and the European Sustainability Reporting Standards (ESRS). The relevant targets cover all activities of PPA S.A. within the port area and are monitored at company level, with 2024 as the base year, unless otherwise stated in the relevant table [MDR-T_80_a], [MDR-T_80_b], [MDR-T_80_c], [MDR-T_80_f], [MDR-T_80_g]

To address marine and land-based pollution, the Company implements approved Emergency Response Plans and programmes for monitoring the quality of seawater and sediments, which are supported by annual preparedness exercises, with the aim of ensuring an immediate and effective response in the event of an incident. [MDR-T_80_b], [MDR-T_80_c], [MDR-T_80_d], [MDR-T_80_e], [E2-3_23_b]

In terms of air quality, the Company operates atmospheric quality monitoring stations and a digital data management platform to ensure that pollutant concentrations remain within the applicable legal limits. [MDR-T_80_b], [MDR-T_80_c], [MDR-T_80_d], [MDR-T_80_e], [E2- 3_23_a]

All pollution-related objectives and actions have been developed following consultation with employees and stakeholders, in line with the requirements of the Management System and the environmental permits framework. [MDR-T_80_h]

The Company’s objectives, actions and monitoring indicators are presented on the table below.

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POLLUTION IRO Acons [MDR-A 68a] Target [MDR-T- 80b] Year [MDR-A 68c/ MDR- T 80e] KPIs [MDR-A 68e/ MDR-T 80b/ MDR – M- 75] Progress in 2025 [MDR-A 68e/ MDR-T- 80j]
Ε2 Air Polluon Air polluon monitoring programme (in accordance with the Air Quality Guidelines) Ongoing Maintain concentraons below legal limits. – Daily average SO 2 limit<125 μg/m 3 SO 2 concentraon Ongoing
Ε2 Digital plaorm for online monitoring of measurements and results 2025 100% achieved Ε2
Polluon of Coasts, Marine Water and Sediments (Company- Specic) Implementaon of Emergency Response Plans for sea and land polluon incidents Ongoing Number of polluon incidents 100% achieved Ε2
Ε2 Annual drill (emergency drill) for responding to spills at sea and on land Ongoing Minimum one drill per year Number of drills 100% achieved Ε2
Ε2 Sea water monitoring programme & sediment monitoring programme Ongoing Annual reports Number of reports 100% achieved Ε2
Noise Management (Company-Specic) Noise monitoring programme across the enre port area Ongoing Annual reports - Noise level limit Lden = 70 dB Number of reports 100% achieved

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A noise action plan for the container terminal was submitted to andapproved by the Ministry of the Environment 2028 - Installation of noise barriers in accordance with the approved Action Plan for Noise at the E/T Container Terminal. - Reduction of noise levels in the area covered by the noise barriers after their construction Effectiveness of noise barriers: Reduction of Lden by at least 2 dB with the construction of noise barriers Ongoing/ 30% of target achieved Page 240 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

The above objectives are linked to the prevention and control of air pollution through the monitoring of pollutant concentrations and compliance with the applicable limit values [E2-3_23_a], and to the prevention and control of emissions/discharges into the aquatic environment through the implementation of marine water and sediment monitoring programmes and the implementation of Emergency Response Plans [E2-3_23_b], as well as by limiting incidents of land-based pollution through control and operational readiness procedures [E2-3_23_c]. During the reporting period, targets are monitored mainly through compliance indicators (concentration limit values, number of exceedances, number of incidents and exercises), without quantified targets being set at the level of “specific loads”. The targets related to the prevention and reduction of pollution derive from the obligations set out in the applicable Environmental Terms Approval Decision (AEPO) of PPA S.A. and therefore, are of a mandatory nature. [E2-3_25] The implementation of Emergency Plans and the relevant operational readiness are carried out in accordance with the applicable regulatory framework (indicatively: OPRC90 Convention, Law 743/1977, Presidential Decree 55/1998, Presidential Decree 11/2002, and HNS Protocol 2000). [MDR-T_80_f], [MDR-T_80_g]

Actions, Performance and Measurement Indicators

To quantify performance and monitor progress against the commitments of both the Environmental Policy and the approved targets and in alignment with the provision of the port Environmental Approval Decision, the Company implements integrated monitoring and control programmes. These programmes allow the timely identification of deviations and the adoption of additional, or emergency measures where required.

Within the Double Materiality Assessment, pollution has been identified as an actual negative environmental impact for PPA S.A. However, the Company is not subject to Regulation (EC) 166/2006 (E-PRTR), as its activities do not fall within the scope of the regulation. Therefore, PPA S.A. is not required to submit pollutant release and transfer reports. [E2-4]. Furthermore, the Company does not produce, use, procure, or release any substances classified as substances of concern or substances of very high concern (SVHCs) under applicable EU chemicals legislation. Consequently, no such substances arise as emissions or outputs from its operations. [E2-5]

In the event of a significant pollution incident affecting the local community or the marine environment, PPA S.A., together with the responsible party (e.g. the polluting vessel), is committed to cooperating with affected stakeholders to provide support and ensure the restoration of any related impacts, in accordance with applicable legislation and environmental terms. [MDR-A_68_d], [E2-2_AR_13]

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Emergency Response

PPA S.A. applies approved Emergency Response Plans for marine and land-based pollution incidents, developed in accordance with the OPRC 90 Convention, Law 743/1977, Presidential Decree 55/1998, Presidential Decree 11/2002 and the 2000 HNS Protocol. [MDR-A_68_a], [MDR-A_68_b]

These Plans define the required procedures for responding to oil spills or hazardous substance releases within the areas under the Company’s responsibility. To ensure operational readiness, the Company conducts one pollution-response drill annually, rotating between different operational areas. [MDR-A_68_c]

Following the Company's stated objectives for the prevention/response to incidents of marine and land pollution, and in particular the objective of conducting at least one (1) drill per year, the Company conducted its annual drill on 26/11/2025 at the Central Port of Piraeus (Gate E7 – Cyclades). Consequently, the annual drill objective for 2025 was achieved. The exercise was evaluated based on the procedures of the Emergency Plans and recorded the effectiveness of coordination between the parties involved (Company, specialised contractor, Coast Guard), as well as any necessary improvement/corrective actions that are incorporated into the Company's preparedness programme. [MDR-T_80_j], [E2-2_AR_13]

[MDR-T_80_j] Oil spill response drill at the Central Port of Piraeus

During the drill and the activation of the relevant contingency plans, coordination between the Hellenic Coast Guard and the polluter (e.g. vessels) is closely monitored and maintained to simulate the mitigation of the potential negative impacts. [E2-2_AR_13]

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In the present case, no revenues arise from products or services that are or contain substances of concern or substances of very high concern. The Company cooperates with a specialized contractor for the activation and implementation of its Emergency Response Plans, when required. For 2025, the related cost amounted to €45,518.40 excluding VAT. These costs are recorded under the Company’s operating expenses in the “EXPENSES” table, while no relevant capital expenditures were incurred during the reporting period. [MDR-A_69_a], [MDR- A_69_b] A slight increase is anticipated for the following year. [MDR-A_69_c], [E2-6_40_b]

The activation of the emergency response plan is assessed in accordance with the applicable legislation and is used to evaluate PPA S.A.’s performance on likely impacts of coastal and marine pollution. It should be noted that the Coast Guard is responsible for approving the emergency plan and all the procedures it provides for. In cases where the Emergency Plan is activated, the competent Port Authority is immediately notified and all intervention work is carried out under its coordination, in accordance with the applicable regulatory framework. [MDR-M_75], [MDR-M_77_a]. The measurement of the indicator (number of Emergency Plan activations) is based on internally recorded operational data and is not subject to validation by an external body other than the provider of the Assurance Report. [MDR-M_77_b]

As illustrated in the chart below, in 2025 the emergency plan was activated eight (8) times for marine pollution incidents and 23 times for land-based pollution incidents. It is important to note that 12 of the 23 land pollution incidents were extremely minor (spill less than 5 m 2 ), while all incidents were effectively dealt with based on PPA S.A.'s Emergency Response Plans.

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Environmental Monitoring Programmes

The Company implements a comprehensive Environmental Monitoring Programme that covers all critical operational areas of the port, in order to monitor the impacts of PPA S.A.’s business activities on the natural environment. The programme includes:
* Noise monitoring programme
* Air quality monitoring programme
* Marine water monitoring programme
* Marine sediment monitoring programme

Measurements and analyses are carried out by specialized external partners and scientific bodies (including the National Technical University of Athens), using internationally recognized laboratory and instrumentation methods and applying quality assurance procedures.

In summary, the measurement methodologies include:
* Seawater quality: periodic sampling (summer and winter) is carried out at representative locations. The samples are analyzed for basic physicochemical parameters, nutrients, heavy metals, microbiological indicators, and selected organic pollutants in order to assess the condition of the water column and identify any trends or deviations.
* Marine sediments quality: periodic sampling is also carried out at targeted locations of interest. Samples are prepared and analyzed for heavy metals and key organic pollutants (such as PAHs/PCBs), as well as for indicators related to the organic composition of sediments, supporting the assessment of potential pressures from port activities.
* Air pollution: Permanent monitoring stations operate within the port area, systematically recording key atmospheric pollutants (e.g. nitrogen oxides, sulfur dioxide, particulate matter, ozone, carbon monoxide, and/or volatile organic compounds—per station). The operation of the stations is supported by a programme for monitoring and ensuring the quality of measurements.
* Noise: the acoustic environment is monitored by taking 24-hour measurements at specific locations every quarter, as well as by utilizing data from permanent continuous recording stations. The assessment is based on established noise indicators and the relevant regulatory framework.
* Traffic load: 24-hour measurements are carried out at selected cross-sections of the road network serving the port, in order to correlate changes in traffic load (including heavy vehicles) with the observed pressures on the acoustic and atmospheric environment.[E2- 4_30_b], [E2-4_30_c], [MDR-M_77_a] [E2-4_30_b], [E2-4_30_c], [MDR-M_77_a] Page 244 από 437

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(amounts in Euro unless stated otherwise)
(amounts in Euro unless stated otherwise)

The measurement of indicators is based on data collected by specialized external partners and scientific bodies. The data is not subject to separate validation by an external body. [MDR-M_77_b]

To enhance the effectiveness of the Environmental Monitoring Programmes, PPA S.A. developed in 2024 an electronic platform for the consolidation of monitoring data and observations. The platform provides:
* direct access to observations and data for each monitoring station
* the ability to identify data points that require investigation or corrective actions
* detection of potential sensor malfunctions
* automatic generation of charts and comparative visualizations
* data export for reporting or internal evaluation.

Noise Pollution

Noise Monitoring Programme

PPA S.A. in cooperation with a specialised licensed partner implements the Noise Monitoring Programme to assess the impacts, risks and opportunities related to noise from port activities. [MDR-A_68_a], [MDR-A_68_b], [MDR-A_68_c]

Image Measurement position of Environmental Monitoring Programmes (noise, air quality, water, sediments) for 2025

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The Programme covers the main operational sectors of the port (commercial, passenger, repair etc.) and includes:
* Recording Lden and Lnight indicators at eight (8) locations, with 24-hour noise measurement
* Joint assessment of measurements from three (3) continuously operating Permanent Noise Monitoring Stations
* Traffic load measurements at four (4) high-load points

All measurements follow the methodology of the national legislation ($\text{KYA } 211773/2012$) and include the recording of percentile indicators ($\text{L1, L10, L50, L95, L99}$), maximum and minimum values ($\text{Lmax, Lmin}$), $\text{LAeq}$ (day-night, 24h), and $\text{Lden/Lnight/Lday/Levening}$ indicators.

Noise measurements for 2025 were carried out in four quarterly cycles, lasting two days per location, during the following periods:
* 24/02/2025 - 28/02/2025
* 12/05/2025 - 16/05/2025
* 14/07/2025 – 18/07/2025
* 03/11/2025 – 07/11/2025

Key Monitoring Results for 2025

Assessment of the 2025 measurements revealed that:
* Noise levels are in general within PPA S.A.’s targets and the permitted limit of the regulations as well as the Environmental Approval Decision of port.
* Road traffic noise is a major contributor to the overall noise levels at the port (commercial and central port)
* Port operations make a notable contribution to noise levels in the area of the Container Terminal.

Noise Action Plan

Based on the findings of the Noise Monitoring Programme and having as priority the mitigation of the noise impacts linked with port operations, in 2024 PPA S.A., prepared a comprehensive Noise Mitigation Action Plan for the Container Terminal which was approved by the Ministry of Environment. In this context in 2025 the Specific Acoustic Calculation and Implementation Study ($\text{EAMYE}$) for Noise Barriers in the Container Terminal was elaborated and approved by the Ministry of Environment. The implementation of the proposed measures is in progress and will be implemented gradually by 2028. [MDR-A_68_a], [MDR-A_68_b], [MDR-A_68_c]

The cumulative cost for implementing the Noise Monitoring Programme and for EAMYE study in total in 2025 was €27,500 plus VAT and has been recorded in the Company’s operating expenses [MDR-A_69_a], [MDR-A_69_b]. There are currently no estimates available regarding the amount of future financial resources that will be required for the continuation and further development of the relevant actions, as the relevant needs will be determined in the context of the annual planning and updating of the Company's environmental actions. [MDR-A_69_c]

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(amounts in Euro unless stated otherwise)

Air Quality Monitoring Programme

The integrated Air Quality Monitoring Program, which has been carried out since 2009 in cooperation with the National Technical University of Athens, was still active throughout the year. The aim of the Programme is the continuous recording, assessment and quantification of air pollutants associated with port activities, as well as the development of appropriate techniques and measures to protect and improve air quality in the port and neighbouring areas. [MDR-A_68_a], [MDR-A_68_b], [MDR-A_68_c].

The air quality monitoring programme is based on a network of 5 permanent air-quality monitoring stations located within the Company’s area of responsibility. The concentrations of the following parameters are monitored: [E2-4_30_b], [E2-4_30_c]
* nitrogen oxides ($\text{NOx}$),
* sulfur dioxide ($\text{SO}_2$),
* carbon monoxide ($\text{CO}$),
* ozone ($\text{O}_3$),
* particulate matter ($\text{PM}10$ and $\text{PM}2.5$),
* hydrocarbons ($\text{BTEX}$).

The total operating and monitoring and evaluation costs for the reporting year including the operation of the digital monitoring platform is €34,000 plus VAT, are recorded as operating expenses and disclosed in line with ESRS requirements. The relevant cost estimates will be determined at a later stage [MDR-A_69_a], [MDR-A_69_b], [MDR-A_69_c].

Positions of permanent Air quality monitoring stations

According to the 2025 Annual Report, the results show no significant deviations from previous periods and are consistent with the 2024 values; they are summarized in the following charts [E2-4_30_a] [E2-4_30_a].

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None of the values of the remaining parameters ($\text{NO}_2$, $\text{SO}_2$, $\text{CO}$, $\text{O}_3$) exceeded the limits during 2025. With regard to the target set for maintaining the average daily concentration below the limit of $125 \ \mu\text{g/m}^3$, as shown in the chart below, it is fully complied with and no exceedances are observed [MDR-T_80_j], [MDR-M_75] [MDR-T_80_j]

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Although, all $\text{SO}_2$ measurements for the reporting year remain within the permitted limits, PPA S.A. continues to systematically monitor this specific pollutant due to its connection to ship activity. The expected operation of expanded measures for supplying electricity to berthed ships from shore (cold ironing) is estimated to further contribute to reducing the related air pollution loads.

All measurement data are submitted to the Ministry of Environment in accordance with the requirements of the Environmental Approval Decision of PPA S.A. and are summarised in PPA S.A.’s Annual Environmental Report, which is publicly available on the Company’s website $\text{https://www.olp.gr/el/prostasia-perivallontos/prostasia-perivallontos-prasino-limani}$.

Seawater and Sediments Monitoring Programmes

PPA S.A.’s Seawater Monitoring Programme and Sediments Monitoring Programme remained active and in effect in 2025 and were run in cooperation with the Laboratory of Sanitary Engineering Technology of the School of Civil Engineering at the National Technical University of Athens. The aim of the Programmes is the integrated assessment of the state of the marine environment and the formulation of proposals for its improvement, within the requirements of $\text{DAEC}$ and the Company’s Integrated Management System. [MDR-A_68_b], [MDR-A_68_a]

For the implementation of the seawater and sediments monitoring activities in 2025, PPA S.A. allocated a total amount of € 40,000 excluding VAT. These expenses are recorded in the Company's operating expenses in the “EXPENSES” table. The relevant cost estimates will be determined at a later stage. [MDR-A_69_a], [MDR-A_69_b]

Seawater Monitoring Programme

In 2025, two monitoring campaigns of the water column were carried out:
* Summer sampling: on 24/06/2025
* Winter sampling: on 10/12/2025

During these campaigns, 20 seawater samples were collected each time from selected representative locations across the port area, including the passenger port, commercial port, and ship-repair zone. [MDR-A_68_c]

The samples were analysed for:
* general physicochemical parameters (temperature, pH, salinity, conductivity, total dissolved solids, dissolved oxygen, turbidity, transparency, coloration, suspended solids),
* nutrients (orthophosphates, ammonium nitrogen, nitrite nitrogen, nitrate nitrogen),
* heavy metals (nickel, lead, copper, iron, chromium, zinc, cadmium, mercury, arsenic),
* microbiological parameters (total coliforms, E. Coli, enterococci),
* organic pollutants (hydrocarbons and TBT), ensuring a complete and accurate assessment of the marine water quality.

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Sediment Monitoring Programme

Sediment monitoring was carried out through the collection of 10 sediment samples from key points within the port basin, including the passenger port, commercial port, and ship repair zone. Sampling was conducted:
* Summer sampling: on 24/06/2025
* Winter sampling: on 10/12/2025

Samples were analysed for:
* heavy metals (nickel, lead, copper, iron, chromium, zinc, cadmium, mercury, arsenic, manganese),
* $\text{PCBs}$ (polychlorinated biphenyls) related compounds),
* $\text{PAHs}$ (polycyclic aromatic hydrocarbons),
* $\text{TBT}$ compounds,
* $\text{TOC}$ (total organic carbon).

Due to the large number of measurements and the wide range of parameters examined, the results of the laboratory analysis are not presented in this report.As foreseen, the full technical reports have been submitted to the Decentralized Administration of Attica and are included in PPA S.A.’s annual Environmental Report, which is published on the Company’s website https://www.olp.gr/en/environmental-protection/environmental-protection. [MDR- A_68_ d].

Water Management

PPA S.A.’s water impact mainly concerns the use of freshwater which is supplied through the public network. The Organisation’s business activities do not extract marine resources either biological or non-biological [E3_IRO-1_8_a] [E3_IRO-1_8_b]. The value chain analysis and Double Materiality Principle did not conclude in the materiality of either impact to the freshwater resources or the marine ecosystem. This was reinforced through specific consultation with stakeholders, which confirmed that water use and water quality do not constitute a material environmental issue for PPA S.A.’s operations.

With regard to freshwater withdrawal related to the PPA's business model, water is drawn exclusively from EYDAP and is divided into three uses to meet the needs of: PPA S.A.'s own facilities, third-party land sub-concessionaires, and ships. However, most of the fresh water is supplied to ships to meet their drinking water needs, as well as for hygiene, equipment washing, cooling, firefighting systems, etc. As the volume of water consumed depends largely on ship traffic which varies annually depending on the number and type of ships calling at the port water demand cannot be reliably predicted or stabilized.

In 2025 PPA S.A. continued to systematically monitor water consumption in all operations. This monitoring helps to identify potential changes that could affect the materiality of the issue in the upcoming reporting periods and to plan responsible resource-use practices for the future. Customary annual quality testing of the supplied water was carried out, to ensure full compliance with EYDAP specifications for drinking water and its safe provision to third parties within the port zone.

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Water consumption data for 2025 are presented in the table below. In the table below, the 2024 data show minor deviations compared to those published in the 2024 Annual Financial Report, as detailed in the section “Changes in the preparation and presentation of sustainability information compared to the previous reporting period” of ESRS 2.

Water Use ($\text{m}^3$) 2024 (Published) 2024 (Revised) 2025
Water withdrawn from the network for use in PPA S.A. facilities ($\text{m}^3$) 225,520.00 319,582.00 316,067.00
Water consumption intensity ($\text{m}^3$ / million € turnover) 976.34 1,383.47 1260.24
Water drawn from the network for use by land concessionaires ($\text{m}^3$) This category had not been calculated 22,115.00 20,287.00
Water drawn for the supplying ships berthed at port facilities ($\text{m}^3$) 649,295.70 595,086.00 655,456.00

Circular Economy

Waste Management in the Port Zone

Within the framework of the Double Materiality Principle and stakeholder consultations, the topic of Circular Economy was reassessed and again deemed non-material for PPA S.A. [E5_IRO-1_11_a]. This conclusion is consistent with the previous period, as the Company’s business model is based on providing port services and does not include a production process or the use of raw materials in significant volumes. In addition, PPA S.A. does not produce products or materials, while the resource inputs required for its activities are limited and are analysed in the “Value Chain” in chapter “Business model and Value Chain” [E5-4_30]. Consequently, no significant resource outflows linked to products, packaging or residual flows were identified in line with ESRS E5-5_35 requirements. [E5_IRO-1_11_a], [E5_IRO-1_11_b]

Although no material IROs for the topic of Circular Economy have been identified, PPA S.A. ensures the lawful and proper management of waste generated within the port zone through licensed and specialised contractors. Waste flows are classified into two main categories:

  1. Ship-generated waste
    Ship-generated waste is managed in accordance with the Ship Waste Management Plan, which has been approved by the competent Ministry. In accordance with the Plan, PPA S.A. implements a port reception system for the collection and management of solid and liquid ship waste by licensed, qualified contractors, giving priority to recovery and recycling.

  2. Waste generated from port operations and facilities
    This category includes waste generated from PPA S.A.’s activities and infrastructure, distinguished as:

  3. Waste from the port’s regular operational activity (daily port operations)
  4. Waste from emergency works$^7$, such as excavations, constructions, and dredging operations.

$^7$ The quantities in this category are not directly comparable between years due to the nature of the works.

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The table below presents the total quantities of waste generated by the port, by type of waste and management method. In addition, the quantities resulting from regular port operations (from regular operations only) are shown separately, as they are considered representative for comparisons between years.

Table: Total port waste generated (tn)

Waste Category (tn) 2024 Total port waste 2025* Total port waste 2024 From regular operations only 2025 From regular operations only
Hazardous Waste
Hazardous Solid waste 95,654 185,142 8 9
Hazardous Liquid waste sent for recovery 398 405 390 405
Total hazardous waste 96,052 185,547 398 414
Non-Hazardous Waste
Paper, plastic, metal, glass, wood etc. / Recycling 336 265 245 265
Mixed household waste / Disposal 766 708 766 708
Operational waste sent for recovery / Recovery 152,390 143,832 361 152
Total non- hazardous waste 153,492 144,805 1,372 1,125
Total port waste (hazardous & non-hazardous) 249,545 330,352 1,770 1,539

The waste data for the year 2024 are finalised by registering the annual Waste Report of 2024 to the Electronic Waste Register (HMA) of the Ministry of Environment and Energy. It is noted that the waste data for 2024 as published in the “Annual Financial Report 2024” of PPA SA were based on internal company data, because the Waste Report 2024 was not submitted at that time.

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This is the reason for the slight differences between waste quantities of 2024 in the two reports. In 2025 (as in 2024), high amounts of waste are observed due to dredging works implemented in the main port, as well as other maintenance works, which are classified as "Waste from emergency works" (WEEW). Waste in this category is classified as Excavation, Construction, and Demolition Waste (ECDW) and is intended for recovery, while part of it is classified as hazardous solid waste.

The table below shows the individual amounts of waste delivered to Alternative Management Systems for the years 2024 and 2025 and are included in the category "Operational waste for recovery/ Recovery," as reflected in the above table of total port waste.

Table: Waste to Alternative Management Systems (tn)
(This waste is included in "Operational waste for recovery”)

Waste Category 2024 (tn) 2025 (tn)
Used Tires 11.16 19.98
Waste Electrical & Electronic Equipment (WEEE) 4.73 2.48
Vehicle Battery Waste 3.88 5.12
Waste Potable Batteries 0.15 0.14
Waste Lubricating Oils 19.22 13.87
Excavation, Construction, and Demolition Waste (ECDW) 152,027.86 143,636.89

When comparing the amounts of waste delivered to Alternative Management Systems for the years 2024 and 2025, it can be observed that there is no significant change and that, in general, the amounts are small, with the exception of Excavation Waste, Construction and Demolition Waste (CDW), which is attributed to the emergency dredging works in the main port.

  • Waste volumes for 2025, compared to 2024, show that the amounts of waste generated by normal port operations (hazardous and non-hazardous) remain at similar levels, indicating stability in the port's daily operations.

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Biodiversity

PPA S.A. operates within the coastal and marine environment. The port zone is classified as an Artificially Modified Water Body under the EU Water Framework Directive. This classification is taken into account when assessing the potential environmental impacts of PPA S.A. on the marine and coastal environment. Furthermore, the Company’s facilities are neither located in nor in close proximity to protected areas or zones of high biodiversity value [E4_IRO-1_19_a].

As part of the Double Materiality Assessment, the Company examined potential impacts, dependencies, risks, and opportunities related to biodiversity. The assessment concluded that biodiversity was not a material topic during the reporting period, considering the nature of the Company’s activities, the location of its facilities, and the existing environmental monitoring and control measures [E4_IRO-1_17_a]. The Company does not use raw materials in a production process, as its activities are primarily operational and service-based rather than industrial [E4_IRO-1_17_e_i]. Nevertheless, the Company operates within and depends on the coastal and marine environment and therefore maintains functional interactions with ecosystems that may be affected by port-related activities [E4_IRO-1_17_b].During the assessment of impacts, risks, and opportunities related to biodiversity, the Company also considered potential systemic risks associated with cumulative environmental pressures on the coastal and marine ecosystem, including possible interactions among atmospheric emissions, marine water quality, sediments, and noise. Based on the nature and scale of the Company’s activities, the location of its facilities, and existing monitoring and control mechanisms, these factors were not considered a material biodiversity issue during the reporting period. Additionally, according to the Environmental Impact Study of PPA S.A., approved by the Ministry of Environment and Energy, the impacts of the Company’s operations on the natural environment (ecosystems, flora, and fauna) are assessed and documented as non-significant [E4_IRO-1_17_d]. Environmental pressures related to air emissions, marine water quality, sediments and noise are monitored through the Integrated Environmental Monitoring Program, implemented in accordance with the Environmental Approval Decision of port operations and applicable legislation. During the double materiality assessment, a consultation with stakeholders was conducted to assess potential impacts, risks and opportunities [E4_IRO-1_17_c], [E4_IRO-1_17_e, E4_IRO-1_17_e_ii], as described in the section “Stakeholder engagement”.

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Our People

ESRS S1 – Own Workforce

ESRS S1- Own workforce Stakeholders' Interests and Opinions [S1.SBM-2 12]

The Company recognizes its workforce as a key stakeholder group and integrates their views, expectations, and rights into the formulation of its strategy and business model. Through established engagement mechanisms and communication channels such as internal platforms, employee engagement surveys, and grievance mechanisms feedback is gathered on material issues including working conditions, Occupational Health and Safety, professional development, equal opportunities, and fair treatment. This information is evaluated by Management and incorporated into decision-making processes, contributing to the development of policies and practices that promote a safe and fair work environment, as well as the respect for human rights within the framework of the Company’s overall strategy and responsible operations. PPA S.A. places its workforce at the core of its strategy and business model, recognising it as the foundation for the port's safe, efficient, and resilient operation. Due to the nature of port activities, including 24/7 operations, the use of heavy machinery, and continuous service provision, actual and potential impacts on employees stem directly from and are closely linked to the Company’s strategic objectives, such as operational excellence, digital transformation, and sustainable development, as well as its operating model.

[S1.SBM-3 13 a (i)]

The Company’s commitment to responsible employment practices, equal opportunities, and continuous development is reflected in its mission and values, and is further reinforced by stable employment structures, such as the universal application of full-time employment (100%). As of the end of the 2025 reporting period, PPA S.A. employed a total of 1,058 employees. The workforce consists exclusively of employees operating within the Organisation’s facilities in Greece. PPA S.A. also engages one self-employed employee, who is not included in the Company’s total number of employees. All workforce-related data presented in this Report have been calculated using the headcount methodology as of 31 December 2025.

Number of Employees by Gender [S1-6_50(a)], [S1-6_50 b]

KPI 2024 2025
Male 872 898
Female 152 160
Total 1024 1058

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S1.SBM-3 – Material impacts, risks and opportunities related to own workforce and their interaction with strategy and business model

The actual and potential impacts identified through the Double Materiality Assessment inform the Company’s strategic choices, particularly in strengthening occupational health and safety systems, enhancing professional development and maintaining stable labour relations. These data support the adaptation of PPA S.A.’s strategy to evolving workforce needs, sectoral trends and applicable regulatory requirements.

[S1.SBM-3 13 a (ii)]

Through the Double Materiality Assessment, PPA S.A. identified material impacts affecting its own workforce, risks and opportunities, informed by input from employees, unions and management representatives.

[S1.SBM-3 13 a (ii)]

The process highlighted that employees are the most affected by working conditions, especially health and safety matters in high-risk port areas, equal treatment and inclusion, employee engagement and the need to build capabilities for new technologies. These insights feed into decision-making processes and shape ongoing and future strategic initiatives, as indicatively, the development of an occupational health and safety management system (in accordance with ISO 45001 standard) and extensive training programs for upskilling and reskilling.

[S1.SBM-3 13 a (ii)], [S1.SBM-3 13 b]

To fully understand how the Company’s activities may impact its people, the assessment covered the entirety of the Company’s workforce. Consequently, all employees who may be materially affected by the Company’s operations are included within the reporting scope of the assessment, in full compliance with the requirements of the European Sustainability Reporting Standards (ESRS).

[S1.SBM-3 14]

The Organisation’s workforce consists of 1,058 full-time employees, comprising both permanent staff (1,000 employees) and temporary staff on fixed-term contracts (58 employees). Additionally, the Company engages one self-employed employee.

[S1.SBM-3 14 a]

The Double Materiality Assessment identified nine (9) material IROs:
Actual Positive Impacts
* Work-life Balance & Well-being
* Equal Opportunities
* Employee Engagement and Social Dialogue
Potential Positive Impacts
* Training and Skills Development for New Technologies (Company Specific)
Actual and Potential Negative Impacts
* Occupational Health and Safety Risks
* Employee Health and Safety Incidents
* Skill Gap and Technological Readiness
Opportunities
* Diverse Talent Attraction
* Upskilling – Technological Capabilities of Workforce

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The Double Materiality Assessment for 2025 identified Occupational Health and Safety as an actual and potential negative impact on its workforce, due to the nature of port activities and the possibility of isolated workplace incidents. This impact is not characterised by a systemic or broad-scale effect but is associated with individual occurrences, which are systematically monitored. The Company implements extensive preventive and mitigatory measures aimed at limiting associated risks and continuously improving working conditions, while acknowledging that, given the nature of its operations, such risks cannot be entirely eliminated.

[S1.SBM-3 14 b]

Furthermore, the assessment confirmed the existence of significant positive impacts stemming from the Company’s established employment practices and its long-term commitments. PPA S.A. provides stable and quality employment, supported by a full-time workforce and Human Resources management processes that promote fairness, equal opportunities, and inclusion. These positive impacts are further enhanced by the Organisation’s robust social dialogue framework, which includes active trade union representation and multiple channels for employee communication and engagement, contributing to a constructive work environment. Simultaneously, the Organisation systematically invests in workforce development through structured training programs and continuous learning initiatives, strengthening professional growth and workforce adaptability as technologies evolve and industry demands increase. These practices generate actual and potential positive outcomes for employee well-being, engagement, equal treatment, and long- term skills development.

[S1.SBM-3 14 c]

The material risks and opportunities identified for the Company regarding its impacts and dependencies on its own workforce primarily relate to performance in Occupational Health and Safety, staff competencies in adopting new technologies, and the acquisition of diverse talent. Due to the nature of port activities involving heavy equipment, vessel movements, and operations in high-security zones, there is an inherent risk of isolated occupational incidents. This risk is addressed through structured preventive measures, systematic monitoring, and emergency management procedures, as well as the phased development of a certified Occupational Health and Safety Management System in accordance with the ISO 45001 standard, aiming for the continuous improvement of working conditions. Furthermore, in an environment where the maritime sector is dynamically evolving toward more digitalised and technologically advanced operations, the Company systematically invests in upskilling and reskilling initiatives. These actions aim to enhance the readiness and adaptability of the workforce, supporting the effective utilisation of emerging technologies and modern operational practices.

[S1.SBM-3 14 d]

Beyond the risks associated with the Company’s workforce, the assessment also identified opportunities arising from its ability to leverage existing human capital strengths.These opportunities include attracting diverse talent through the Company’s equal opportunity framework and inclusive recruitment practices, as well as enhancing technological competencies through continuous professional development. Maintaining robust social dialogue structures and stable employment practices, the Organisation is well-positioned to transform these opportunities into long-term value for both the Company and its people. [S1.SBM-3 14 d] The maritime sector's transition toward digitalization, automation, and low-carbon technologies was assessed as material to the Company’s workforce, as it creates both potential impacts and dependencies that require management. Within the context of the assessment, no significant negative impacts were identified regarding the Company’s transition efforts, as no restructuring, job losses, or adverse changes in employment conditions are anticipated. Conversely, the transition presents a significant opportunity for the Organisation linked to the need for upskilling and reskilling for new technologies; the Company’s ability to adapt to future alternative fuel systems and digital port operations depends on having a workforce with the appropriate competencies. This dependency is reflected in the Company’s long-term commitment to continuous education and professional development, supported by structured learning programs and technological skill enhancement initiatives already in place. [S1.SBM-3 14 e] The transition also entails challenges associated with the potential emergence of a skills gap, should the workforce be insufficiently prepared for the technological evolution of port operations. This risk impacts productivity, safety, and long-term competitiveness, and is mitigated through the strengthening of internal training systems and the implementation of targeted upskilling and reskilling initiatives. [S1.SBM-3 14 e] The Company implements a comprehensive framework of internal policies and regulations, which ensures the protection of labour rights and guarantees that all employment practices are grounded in respect, fairness, and protection against misconduct. This framework aims to prevent any potential labour rights violations and to promote a safe and non-discriminatory working environment. As part of the Company’s Human Rights Due Diligence, the Organisation assessed the potential risk of forced or compulsory labour within its operations and identified no such risk, given that the Company operates exclusively in Greece and complies with the applicable national and European regulatory frameworks for the protection of employees' rights. [S1.SBM-3 f (i)] The Company does not engage in any activities that could pose a significant risk of human rights violations, including forced or compulsory labour, and no such incidents have been recorded within its operations. Correspondingly, the risk assessment identified no operational activities or geographic locations involving a significant risk of forced or compulsory labour. [S1.SBM-3 f (ii)] The Company also assessed the potential risk of child labour within the scope of its operations. The assessment identified no such risk, as the Company operates exclusively in Greece—a jurisdiction with a stringent regulatory framework for employee protection and the enforcement of the minimum age for employment—and maintains no operations in countries or regions where child labour is prevalent. The Company implements a comprehensive internal policy framework that safeguards human and labour rights and establishes clear protocols for fair and safe working conditions. In alignment with this framework, no incidents related to child labour or other material human rights violations were recorded during the reporting period. [S1.SBM-3 g (i)] Consequently, no type of operational activity or geographic region within the Company’s scope has been identified as posing a significant risk of child labour. [S1.SBM-3 g (ii)]

Within the framework of the Double Materiality Assessment, the Company examined how different segments of its workforce may be exposed to risks or benefit from emerging opportunities. The analysis accounted for the specific nature of duties performed across the port, recognizing that employees in high-risk operational areas, such as the Container Terminal and the Ship Repair Zone, are exposed to heightened occupational health and safety risks due to their working environment. Concurrently, the assessment integrated characteristics protected under the Company’s Diversity, Equity, and Inclusion Policy, the Policy for the Prevention and Combating of Violence and Harassment at Work, the Internal Grievance Mechanism for Incidents of Violence and Harassment, and the Code of Conduct. Indicatively, factors such as gender, age, and disability were examined to guide the Organisation in identifying vulnerable groups or cohorts requiring additional support or enhanced workplace protection measures. [S1.SBM-3 15] The assessment also highlighted that certain material risks and opportunities pertain to specific workforce segments. For instance, the potential risk of a skills gap primarily affects employees in technical and operational roles, who are more directly impacted by the technological evolution of port operations; this is addressed through targeted training and capacity-building programs. Similarly, the opportunity to attract and retain diverse talent is supported by the Company’s Inclusion Policy, specifically focusing on groups such as women and employees with disabilities. Insights derived from ongoing social dialogue with employees and labour unions enhance the Company’s understanding of these groups' needs and provide actionable guidance for designing initiatives that ensure safe, equitable, and supportive working conditions for all. [S1.SBM-3 16]

S1.1 – Policies related to Own Workforce

ESG and Sustainability Policy

The ESG and Sustainability Policy sets the overarching framework that guides the Company in operating responsibly, ethically and sustainably, acting as a reference point for integrating environmental management, social responsibility and sound governance into its business practices. Its stated purpose, as explicitly described in the Policy, is to ensure that the Company not only complies with applicable legislation but also takes steps to address stakeholder expectations, mitigate environmental and social risks, enhance social dialogue, promote human rights and maintain ethical business conduct. Through this framework, the Company aims to reinforce its long-term value, build a resilient business model and contribute positively to society and the environment. [S1.MDR_P_65 a]

In relation to the Company’s own workforce, the Policy underpins several material IROs identified in the Double Materiality Assessment, including:
* Work-life Balance & Well-being
* Equal Opportunities
* Employee Engagement & Social Dialogue
* Training and Skills Development for New Technologies
* Upskilling – Technological Capabilities of Workforce
* Employee Health & Safety Incidents
* Skill Gap and Technological Readiness [S1-1_17]

Within the framework of the Corporate Social Responsibility pillar, the Policy commits the Company to creating an inclusive and diverse working environment that supports employee development and promotes work-life balance. It also affirms that the Company does not tolerate any form of discrimination, and that advancement is based solely on performance, efficiency, skills and qualifications. These commitments form a high-level policy basis for managing workforce-related Impacts, Risks & Opportunities, later operationalised through more specific internal policies. [S1-1_18]

The ESG & Sustainability Policy applies to all activities of PPA S.A. and is to be followed by all employees, contractors, partners and third parties collaborating with or operating on behalf of the Company, with no exceptions mentioned. [S1.MDR_P_65 b], [S1-1_19]

The Policy also relates to the two workforce-related risks identified in the assessment. Its aim is to maintain a safe, healthy and respectful work environment, and compliance with ILO conventions on occupational health and safety, supporting the management of the Employee Health & Safety Incidents risk. Its emphasis on continuous learning and employee capability-building provides a policy foundation for addressing the Skill Gap and Technological Readiness risk linked to technological evolution. The ESG Committee is responsible for the publication of the latest version of this Policy and for ensuring its dissemination to all employees. [S1.MDR_P_65 a] The Committee is also responsible for the supervision of the implementation and the review of this Policy.. [S1.MDR_P_65 c]

The Policy is publicly available on the Company’s official website (https://www.olp.gr/en/) in both English and Greek, ensuring accessibility for all employees, partners and other stakeholders. [S1.MDR_P_65 f]

The Policy undergoes reviews on an ad hoc basis as needed. Revisions are driven by legal and regulatory changes, the identification of risks or adverse impacts, ATHEX ESG scoring, opportunities for improvement, updates in the Company’s strategic direction and broader stakeholder awareness. This ongoing review process helps ensure alignment with evolving sustainability and workforce priorities. [S1.MDR_P_65 e]

The Policy explicitly states that the Company adheres to the UN Global Compact’s Ten Principles and supports the UN Guiding Principles on Business and Human Rights.It also confirms compliance with International Labour Organisation (ILO) conventions, including those on working conditions, freedom of association and occupational health and safety. [S1.MDR_P_65 d], [S1-1_20], [S1-1_20 a], [S1-1_21] Through these commitments, the Policy sets out the Company’s human rights and labour rights expectations for its workforce, including respect for dignity, equal treatment, safe working conditions and effective social dialogue. [S1-1_22]

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Code of Conduct

The Company’s Code of Conduct (hereinafter “the Code”) sets out the Company’s fundamental principles, values and rules of professional behavior, ensuring that all members of staff and the Board of Directors act with integrity, honesty and respect in full alignment with applicable legislation relating to human rights, labour, the environment and anti-corruption. The Code serves as a reference framework that guides employees in managing ethical dilemmas and in applying responsible business conduct across daily operations and interactions with colleagues, customers, suppliers and other stakeholders. [S1.MDR_P_65 a], [S1-1_18]

The scope of the Code clearly covers the total number of employees, as well as all members of the Board of Directors, both inside and outside Greece. It defines expectations for behavior, communication, confidentiality, fair treatment, equal opportunities, and professional responsibility. These principles apply across all organizational levels and business activities. [S1.MDR_P_65 b], [S1-1_19]

Responsibility for applying and upholding the Code is shared across the Company. Managers are required to set an example, ensure that their teams understand and comply with the Code, foster transparency, and respond promptly when concerns are raised. Employees are responsible for demonstrating moral values, reporting potential violations, remaining up to date with ethical standards and performing their duties in accordance with Company policies and the law. [S1.MDR_P_65 a], [S1.MDR_P_65 c]

The Code is approved and periodically updated by the BoD and is made publicly available on the Company’s official website (https://www.olp.gr/en/), ensuring full transparency, accessibility and consistent communication to all employees and external stakeholders. [S1.MDR_P_65 f]

The Code of Conduct contains explicit provisions relevant to workforce-related impacts and opportunities identified in the Double Materiality Assessment, including:
* Equal Opportunities
* Diverse Workforce Attraction
* Interaction with employees & Social Dialogue
* Work-life Balance & Well-being [S1-1_17]

Equal Opportunities Policy (Article 14 of the Code)

Furthermore, the Code sets a clear commitment to equality, personal rights and diversity, covering both visible characteristics (age, sex, race, ethnicity, disability) and non-visible ones (culture, religion, marital status, experience, opinion). The Company explicitly prohibits any form of discrimination, harassment or retaliation, requiring full compliance with legislation on equal treatment in the workplace. [S1-1_20 a], [S1-1_24 a], [S1-1_24 b]

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Forced and Child Labour (Article 15 of the Code)

The Code states that the Company does not use any form of forced labour and does not employ individuals below the legal minimum age. Child labour is defined as employing any person under the legal working age in Greece. [S1-1_22]

Violence and Harassment in the Workplace (Article 16 of the Code)

The Code defines violence and harassment as any act or threat that may cause physical, psychological, sexual or economic harm or violate a person’s dignity. All forms of violence and harassment are strictly prohibited. The Code explicitly references the dedicated “Policy on preventing and combating violence and harassment at work & the management of internal complaints about incidents of violence and harassment,” establishing a formal link to the Company’s internal complaint mechanisms. [S1-1_20 a], [S1-1_24 a], [S1-1_24 d]

The Code requires staff to report violations or concerns regarding ethical issues through designated internal channels, including:
* the whistleblowing email address ([email protected])
* internal complaint boxes located in Company facilities

It states that all complaints are treated impartially, confidentially and in accordance with the Whistleblowing Policy and other compliance mechanisms. These provisions contribute to the Company’s overall remediation framework for addressing workplace concerns. [S1-1_20 c]

Compliance with the Code is monitored through various mechanisms and policies, including the Whistleblowing Policy, conflict of interest procedures, the recruitment process, and the Policy to Prevent and Combat Violence and Harassment. Reviews are undertaken by the Regulatory Compliance Unit and/or the Internal Audit Department. [S1.MDR_P_65 a], [S1-1_20 c]

Diversity, Equality, and Inclusion (DE&I) Policy

The Diversity, Equality & Inclusion (DEI) Policy sets out the Company’s commitment to promoting a respectful, fair and inclusive working environment, where every employee is treated with dignity and without discrimination. Diversity, as defined by the Policy, encompasses visible characteristics such as age, gender, race, nationality and physical ability, as well as non-visible characteristics such as culture, religion, marital status, experience and opinion. The Policy affirms zero tolerance for discrimination, harassment and retaliatory behavior, and emphasizes that differences of opinion are valued as a source of constructive dialogue and continuous improvement. [S1.MDR_P_65 a], [S1-1_24 a], [S1-1_24 b]

The Policy applies to all individuals employed or engaged by the Company, irrespective of employment status, including dependent employees, independent service providers and individuals working under salaried mandate arrangements. It covers all aspects of the employment lifecycle; recruitment, compensation, development, training, promotion and career progression, without exclusions. [S1.MDR_P_65 b], [S1-1_19]

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The DEI Policy is adopted through a formal decision of the competent corporate body and is publicly available on the Company’s official website (https://www.olp.gr/en/), ensuring visibility and accessibility for employees and external stakeholders. [S1.MDR_P_65 f]

By requiring equal opportunities and fair treatment, the Policy supports the Company’s workforce-related material impacts and opportunities and forms part of the foundational policy framework for managing issues related to:
* Equal Opportunities
* Diverse Workforce Attraction

These commitments promote merit-based career development, ensuring that skills, qualifications and performance are the sole criteria for advancement. [S1-1_17], [S1-1_18], [S1-1_24 b], [S1-1_24 c]

The Policy also sets clear expectations for employee behavior: staff must behave with respect and tolerance toward colleagues, participate in relevant training and report incidents of discriminatory or inappropriate behavior. Any concerns can be raised through the complaint procedure established in the Policy to Prevent and Combat Violence and Harassment at Work and for the Management of Internal Complaints about Incidents of Violence and Harassment, ensuring a structured, confidential and responsive mechanism for addressing issues. [S1-1_24 d]

Furthermore, the Policy emphasizes the Company’s commitment to diversity and inclusion at the highest levels of leadership. The selection of Board members and senior managers must reflect diversity criteria, including gender, race, sexual orientation, religion, political opinions, social origin, disability and age. This approach aligns leadership appointments with principles of equal opportunity and contributes to the Company’s ability to attract and retain diverse talent, a significant impact according to the Double Materiality Principle. [S1-1_24 c]

Overall, the DEI Policy reinforces the Organisation’s broader human-rights commitments by promoting equality, prohibiting discrimination and embedding inclusion throughout the Company’s operations. It complements the Code of Conduct and the Policy to Prevent and Combat Violence and Harassment at Work, forming an integrated framework that supports employee dignity, well-being and a culture of respect.

Policy to Prevent and Combat Violence and Harassment at Work and for the Management of Internal Complaints about Incidents of Violence and Harassment

The Policy to Prevent and Combat Violence and Harassment at Work and for the Management of Internal Complaints about Incidents of Violence and Harassment sets out the Company’s commitment to ensuring a workplace where every person is treated with dignity and respect. Its purpose is to prevent, address and eliminate behaviors that may cause physical, psychological, sexual or economic harm, or that violate an individual’s dignity, in full alignment with the definitions and obligations established by Greek Law 4808/2021. [S1.MDR_P_65 a], [S1-1_20 a]

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The Policy applies to all the Company’s employees, regardless of their employment relationship, and to any individual present in or connected to the work environment.It covers conduct occurring at Company premises, during work-related travel or events, and in any context linked to the employment relationship, ensuring that protection extends across all workplace settings. [S1.MDR_P_65 b] [S1-1_19] Responsibility for implementing the Policy lies with specifically designated internal bodies. The Violence and Harassment Incidents Reference Person (the Secretary of the Disciplinary Board) acts as the first point of contact for the receipt of internal complaints. The Complaint Management Team, comprised of the Regulatory Compliance Manager, the HR Manager and the Deputy HR Manager, examines and assesses complaints, ensuring impartiality, confidentiality and timely handling. Depending on the severity of the incident, cases may be escalated to the Disciplinary Board, which determines corrective or disciplinary actions. The Policy is also made publicly available on the Company’s official website (https://www.olp.gr/en/) to ensure transparency and accessibility for employees and external stakeholders. [S1.MDR_P_65 c], [S1.MDR_P_65 f] In relation to PPA’s own workforce, the Policy supports several material impacts identified in the Double Materiality Assessment. By promoting dignity, respect, non-retaliation and a safe working environment, it contributes directly to the Company’s commitments to workforce well-being and constructive internal communication. [S1-1_18] Specifically, the Policy is linked to the following material impacts:
* Work-life Balance & Well-being
* Interaction with employees & Social Dialogue [S1-1_17]

A core feature of the Policy is its internal complaints mechanism, which provides employees with secure and confidential channels for reporting incidents of violence or harassment. Complaints may be submitted in writing to the Reference Person, the HR Department or through the communication channels specified in the Policy. The procedure outlines the steps for receiving, assessing and addressing complaints, while ensuring confidentiality and protection for complainants throughout the process. This framework strengthens the Company’s broader human-rights approach by offering employees reliable avenues to seek support and remedy. [S1-1_20 c] [S1-1_24 d] [S1- 1_AR 17 g] The Policy also clarifies the responsibilities of employees, who are expected to refrain from behavior that may harm the dignity or safety of others and to report any incidents they witness or experience. Awareness-raising and training initiatives, coordinated by the Human Resources Directorate and other responsible functions, help reinforce a shared understanding of acceptable conduct, promote respect in the workplace and prevent inappropriate behavior before it occurs. [S1.MDR_P_65 a] [S1-1_18]

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Health & Safety Regulation of Container Terminal

The 'Occupational Health and Safety Regulation for Pier I – Container Terminal' constitutes the Company’s official regulatory framework for managing health and safety issues within the Pier I workspaces. Its purpose is the prevention of occupational accidents and diseases, the identification and assessment of occupational risks, and the implementation of appropriate measures to protect the life and health of employees. The core content of the Regulation includes the documentation of the obligations of the Company, employees, and supervisors; the description of risk prevention and control procedures; and detailed instructions for the use of Personal Protective Equipment and the safe execution of stevedoring and technical operations. Compliance is monitored through audits, inspections, staff training, and collaboration with the Safety Technician and the Occupational Physician, as provided for by the Regulation.

The Regulation aims to manage material health and safety issues associated with Container Terminal (CT) operations, covering risks arising from the use of heavy machinery, container handling, loading and unloading activities, as well as technical works. It outlines preventive measures, the obligation to provide training and induction, and the mandatory compliance with safety protocols. [S1.MDR_P_65 a]

The scope of application of the Regulation extends to all activities conducted at Pier I – Container Terminal and covers the entirety of the workforce operating within the facilities, including stevedores, equipment operators, and technical personnel. No explicit exclusions are cited regarding activities or geographic areas outside the Container Terminal facilities. [S1.MDR_P_65 b]

The BoD holds ultimate responsibility for the approval and updating of the Regulation, which is formally signed by the Chairman of the Board. Concurrently, the responsibility for implementation lies with the relevant executive management, department heads, and site supervisors, who are mandated to ensure strict adherence to the prescribed measures within the workplace. [S1.MDR_P_65 c]

The framework for the development and implementation of the Regulation provides for employee information, training, and consultation, with employees being required to adhere to safety measures and report hazards or deficiencies. Their participation in the prevention process, alongside their cooperation with the Safety Technician and the Occupational Physician, reflects the integration of employees' needs and protection into the Company's safety culture. [S1.MDR_P_65 e]

The Regulation is made available to employees through induction and training sessions, while the Company is mandated to provide the necessary instructions and protective equipment. While there is no specific protocol for public disclosure to external stakeholders, the implementation of the Regulation directly concerns all individuals operating within the Container Terminal facilities. [S1.MDR_P_65 f]

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Personnel Training Policy

The Personnel Training Policy establishes the framework for the continuous development of employees’ skills at the Company, ensuring that all training activities support the strategic needs of the Company and contribute to maintaining a high-performing and compliant workforce. Its purpose is to define the principles and procedures governing employee training and to promote continuous learning as a core element of operational excellence. [S1.MDR_P_65 a]

The Policy applies to all staff of the Company, including fixed-term employees, providing equal access to training and professional development opportunities across all employment categories. [S1.MDR_P_65 b], [S1-1_19]

Responsibility for implementing, coordinating and reviewing the Policy lies with the Human Resources Department. Its duties include identifying training needs, preparing the Annual Training Plan, evaluating training proposals, coordinating approvals and overseeing participation and evaluation procedures. The Policy is approved by Company management and may be revised whenever necessary to reflect operational requirements or changes in legislation. [S1.MDR_P_65 c]

The Policy sets out four core objectives, which reflect the Company’s commitment to workforce development:
* Skills Development: enhancing existing skills and acquiring new ones.
* Performance & Productivity: improving work efficiency through targeted training.
* Compliance & Ethics: ensuring adherence to Company rules, internal procedures and legal requirements
* Professional Development: supporting employees’ long-term career growth

These objectives directly support several workforce-related material impacts, risks and opportunities identified in the Double Materiality Assessment, including:
* Training & Skills Development for New Technologies
* Upskilling – Technological Capabilities of Workforce
* Equal Opportunities
* Interaction with employees & Social Dialogue
* Skill Gap & Technological Readiness [S1-1_17], [S1-1_18], [S1-1_AR17 h]

Training needs are identified through four structured processes:
* the Annual Training Plan, compiled based on needs submitted by Department Heads
* ad hoc needs, arising from new challenges or operational changes
* performance evaluation results, which reveal skills gaps and areas for improvement
* certification or qualification needs, in line with the Regulation for the Coverage of Certification and Educational Qualification Costs

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Once a training request is approved, the Human Resources Department evaluates training programmes available, liaises with providers, and finalizes participation arrangements. Participation in approved programs is mandatory, and certificates of attendance or successful completion are recorded in each employee’s personal file. [S1.MDR_P_65 a], [S1-1_AR17 f]

The Policy is supplemented by the Regulations Governing the Reimbursement of Expenses for Certifications and the Acquisition of Educational Qualifications for Company Employees, which provides fair and transparent procedures for financial support to employees seeking job-related certifications or degrees. This Regulation supports equal access to development opportunities and strengthens the Company’s framework for continuous learning.

Training effectiveness is monitored through structured tools. Participants complete the Training Program Assessment Form, evaluating content relevance, usefulness and overall satisfaction. Departments complete the Training Program Effectiveness Assessment, which assesses whether newly acquired skills are being applied, contributing to improved performance, problem-solving and employee engagement. These tools provide a systematic mechanism for monitoring outcomes and implementing improvements in the training process.[S1.MDR_P_65 a], [S1-1_AR17 f] Whistleblowing Policy

The Whistleblowing Policy establishes the framework through which the Company enables employees and other individuals working under its supervision to report concerns or suspected violations safely, confidentially and without fear of retaliation. Its purpose is to promote integrity, ethical behavior and compliance across the Organisation by providing structured and secure reporting channels, in line with the requirements of Directive (EU) 2019/1937 and Greek Law 4990/2022.

[S1.MDR_P_65 a] The Policy applies to all employees, members of the BoD and Top Management, as well as to external collaborators, contractors, suppliers, customers, users and any third parties who work with or provide services to the Company. This broad scope ensures that anyone who becomes aware of misconduct or potential violations is able to report them.

[S1.MDR_P_65 b] [S1-1_19] Reports may concern breaches of EU or national legislation, violations of Company policies or procedures, issues related to corruption, bribery, fraud, conflicts of interest, financial irregularities, data protection breaches, or/and other forms of unethical or improper conduct. The Policy describes the available communication channels, which include:
* a dedicated email address ([email protected])
* postal submissions addressed to the Whistleblowing responsible and marked “Confidential”
* physical report boxes located at designated points across PPA S.A. facilities

All channels guarantee confidentiality, secure handling of information and the protection of the whistleblower’s identity. Retaliation against any person who reports a concern in good faith is strictly prohibited under the Policy and in accordance with Article 17 of Law 4990/2022.

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Responsibility for receiving and monitoring internal reports lies with the Whistleblowing responsible, who is the Manager of the Risk Management Unit. The Whistleblowing responsible registers incoming reports, ensures confidentiality and independence, and forwards cases requiring investigation to the Reports Management Committee (Whistleblowing Committee). This three-member Committee, comprised of the Managers of the Regulatory Compliance Unit and the Human Resources Department, and the Deputy Manager of the Legal Department, with the support of the DPO, conducts investigations following a structured and impartial procedure. At its discretion, the Committee may request additional information, invite the whistleblower or the reported party to interviews, consult relevant Departments and issue a final investigation Report.

[S1.MDR_P_65 c] [S1-1_18] [S1-1_AR 17 g] The Policy is communicated internally to employees, executives and external collaborators through email, the Company portal and other internal channels. It is also publicly available on the Company’s website (https://www.olp.gr/en/), ensuring transparency and accessibility for all stakeholders.

[S1.MDR_P_65 f] In relation to the Company’s own workforce, the Policy supports several material impacts identified in the Double Materiality Assessment. By providing safe and trusted channels for raising concerns, it promotes fairness, well-being and open communication in the working environment. Specifically, it contributes to:
* Work-life Balance & Well-being
* Interaction with employees and Social Dialogue
* Equal Opportunities

[S1-1_17] The Policy also sets out a clear procedure for the management of reports and complaints. This includes timelines for acknowledging reports, safeguarding confidentiality, establishing impartial assessment of facts, preserving evidence, and informing whistleblowers of the outcome, in line with the requirements of Law 4990/2022. These elements ensure that employees have reliable and effective avenues to seek remedy when observing or experiencing misconduct, reinforcing the Company’s broader commitment to responsible conduct and the protection of human and labour rights.

[S1-1_20 a], [S1-1_20 c] Staff Promotion Policy

The Staff Promotion Regulation governs the framework through which the Company ensures that positions of responsibility are filled by competent personnel and that employees who demonstrate high performance, skills and professional behavior are recognised and advanced within the Company.

[S1.MDR_P_65 a] Its stated purpose is to promote a culture of meritocracy, motivation and continuous development, ensuring that professional progression aligns with organisational needs and supports long-term workforce stability and engagement. The Regulation applies to all the Company’s staff employed under an open-ended employment relationship, excluding only top management executives who fall under

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separate governance frameworks. All eligible employees are provided with equal opportunities for professional development and advancement.

[S1.MDR_P_65 b], [S1- 1_19] Responsibility for implementing the Regulation lies primarily with the Human Resources Department, in collaboration with Department Heads, Deputy CEOs and ultimately the CEO, who provides final approval for senior-level promotions. This governance structure ensures that decisions are properly reviewed, documented and aligned with organisational needs.

[S1.MDR_P_65 c] Promotional decisions are based on clear, predefined criteria, including length of service, performance assessments, skills and competencies required for the target position and demonstration of values consistent with the Company’s culture. These criteria ensure that qualifications, skills and experience serve as the basis for advancement, in line with the expectations of internationally recognised good practices for equal treatment. .

[S1-1_AR 17 a] Responsibilities for the promotion process are assigned to management-level roles, supporting accountability and consistency across departments.

[S1-1_AR 17 b] The Regulation supports several workforce-related IROs by strengthening the Company’s merit-based career development framework:
* Equal Opportunities
* Interaction with employees and Social Dialogue
* Diverse Workforce Attraction
* Upskilling - Technological Capabilities of Workforce

[S1-1_17], [S1-1_18] The Regulation also includes structured procedures for announcing vacancies, submitting candidacies, conducting interviews and issuing approvals, with HR maintaining the corresponding documentation and records. This supports transparency and provides a clear view of employee progression within the Company.

[S1-1_AR 17 f] Moreover, newly promoted employees receive the necessary induction and role-specific training to support a smooth transition into their new responsibilities, thereby promoting access to skills development and long-term employability.

[S1-1_AR 17 h] In addition to the above policies, the following are of significant importance for managing matters related to the Company’s workforce:
* the Operating Regulation (further information is provided in Chapter G1- 1 Business Conduct)
* the Recruitment Process, the Regulation for the granting of short-term leaves to the employees of the Company due to extraordinary circumstances or special needs beyond the provisions of the General Staff Regulation
* the Terms and Conditions for the granting of interest-free personal loans to the Company personnel
* the Procedure for Internal Transfers of the Company personnel,
* the Age-Completion Compulsory Retirement Regulation for the Company personnel

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S1.2 – Processes for engaging with own workforce and workers’ representatives

The Company places strong value on maintaining an open and constructive relationship with its people. Interaction with employees and social dialogue form an essential part of how the Company understands and manages its impact on its workforce and reflects the importance of Employee Engagement and Social Dialogue as a material impact area. Employees are represented by organised bodies that participate in discussions on workplace practices and employment conditions, ensuring that their views are heard and considered 8. [S1-2_27 a]

Engagement takes place through several processes across the year. Under the Personnel Training Policy, Department Heads identify training needs as part of the Annual Training Plan and through ad-hoc requests arising from the operational requirements. Employees then provide structured feedback through Evaluation Forms after each training program, enabling them to express views on content, relevance and areas for improvement. At the same time, employees and their representatives contribute to the Double Materiality Assessment, providing information on topics such as working conditions, equal opportunities and skills development. These practices support continuous dialogue and help strengthen active participation across the workforce. [S1-2_27 b]

The effectiveness of engagement is supported by structured procedures. The Whistleblowing Policy outlines the steps for acknowledging reports, reviewing concerns, following up and providing feedback where appropriate. The Policy to Prevent and Combat Violence and Harassment at Work and for the Management of Internal Complaints about Incidents of Violence and Harassment sets out a clear process for submitting, examining and resolving internal complaints, ensuring confidentiality and support for affected individuals. Training processes include evaluation forms and effectiveness assessments, enabling the Company to monitor whether programs meet employees’ needs and to adjust future actions accordingly.When identifying and assessing material impacts, risks and opportunities, the Company considers the perspectives of employees who may be more exposed to impacts. The Double Materiality Assessment examined the conditions of employees working in high-risk operational areas, such as the Container Terminal and the Ship Repair Zone, and also considered characteristics including gender, age, disability and multicultural background. This approach supports the Company’s ability to understand diverse workforce perspectives and ensures that engagement practices remain inclusive, informing material areas such as Employee Engagement & Social Dialogue, Equal Opportunities and Training and Skills Development. In 2025, as part of the reassessment of the Company’s material matters, a 8 For more information on channels of communication with employees, please refer to the Stakeholder Engagement Table on page 311

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materiality questionnaire was distributed to employees to solicit their perspectives for the prioritization process of material topics related to the workforce.

S1.3 – Processes to remediate negative impacts and channels for own workforce to raise concerns

During the reporting period, the Company identified one actual and potential negative impact regarding occupational health and safety, which is inherently linked to the nature of port operations. Although the Company maintains overall low incident rates, the possibility of isolated occurrences is recognised. To this end, the Company prioritizes the strengthening of a prevention culture, while implementing structured procedures and ensuring full compliance with the prevailing national and European regulatory frameworks. This approach aims for the continuous improvement of working conditions and the effective management of any potential impacts.

In accordance with applicable Greek and EU health and safety legislation, the relevant International Labour Organisation (ILO) conventions, and internal regulations, the Company implements a structured remediation process for every work-related incident or identified hazardous situation. When an incident impacts an employee's health or safety, immediate remediation measures include the provision of first aid or medical treatment, facilitated access to external healthcare providers, and coverage via the Company’s private health insurance, as well as the adjustment of working conditions where necessary. In the long term, remediation may involve temporary or permanent modification of duties, ergonomic improvements, engineering controls, or additional training and supervision. These measures both aim to restore, to the extent possible, the well-being of the affected employee and to prevent the recurrence of similar incidents. The Company conducts occupational health and safety risk assessments for all core activities and workspaces; these are reviewed whenever significant changes occur to proactively identify and control hazards, and to provide data for both preventive and corrective measures.

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All incidents are recorded and systematically investigated by the relevant internal bodies (such as the Safety Department, the Human Resources Department, and Department Heads), with the participation, where applicable, of employee representatives through the Health and Safety Committee. Accidents are reported on the SEPENET electronic platform. The accident investigation procedure is defined by the relevant internal procedure SOP-28-01. Findings from these investigations are utilised to update and revise procedures and to enhance technical and organisational controls, thereby strengthening the overall health and safety management system.

The Company maintains formal grievance mechanisms through:
* the Whistleblowing Policy, covering violations of EU and national legislation, internal regulations, ethics breaches, data protection, conflicts of interest, environmental concerns, and other misconduct; and
* the Violence & Harassment Policy, covering incidents of discrimination, violence, harassment (including gender-based harassment) and domestic violence affecting employees in the workplace context.

Both mechanisms are fully compliant with relevant Greek legislation (Law 4990/2022 and Law 4808/2021) and provide clear, secure pathways through which employees can seek remedy.

The Company provides multiple dedicated channels that allow employees to raise concerns safely, confidentially and, when preferred, anonymously. These include:

Whistleblowing channels:
* A dedicated email: [email protected]
* Postal submissions marked “Confidential”
* Physical report boxes at:
* Internal Audit Department (Company HQ)
* Container Terminal Building
* Car Terminal Building
* Direct submission to the Whistleblowing responsible

Channels for violence and harassment complaints:
* Email to [email protected]
* Submission by post to the “HR Department, Reference Person”
* Direct communication with the Violence & Harassment Incidents Reference Person
* Access to the Complaint Management Team for guidance and support

The Company therefore maintains two fully independent and complementary grievance structures; each tailored to specific categories of incidents but fully aligned in terms of procedural safeguards.

The Company actively supports awareness and availability of these mechanisms through:
* posting the policies on the Company’s website: olp.gr - POLICIES
* internal communication via email and bulletins
* direct guidance from HR and the Reference Person
* training and awareness-raising actions coordinated with the HR Department
* open door culture

The Company also ensures that employees can submit reports without fear, and that they are informed about the process, their rights, and the protection measures available.

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The Company maintains an open and regular social dialogue with trade unions and elected employee representatives, who play a material role as feedback and escalation channels on health and safety, working conditions and broader employment issues. Through regular meetings, joint committees and consultation processes, union representatives are able to convey employees’ concerns regarding occupational risks, incidents, near-misses or perceived deficiencies in preventive and remedial measures. They participate, where appropriate, in discussions on incident investigations and necessary corrective actions, contribute to the review of health and safety risk assessments, and monitor the implementation of agreed improvements. This continuous interaction ensures that remediation processes are not only compliant with legislation and internal procedures, but also informed by the practical experience and expectations of the workforce, reinforcing trust in the effectiveness and fairness of the Company’s mechanisms.

The Management Committee keeps complete records of all reports, investigations and actions taken, and provides quarterly updates to Top Management, including the CEO, Deputy CEOs and the Audit Committee. The Violence & Harassment Policy similarly requires the Complaint Management Team to investigate, document and communicate outcomes within defined deadlines, ensuring transparency and accountability. Regular monitoring allows the Company to evaluate systemic issues, identify recurring patterns and implement targeted improvements.

Furthermore, the Company’s policies explicitly prohibit any form of retaliation against individuals who report concerns in good faith. Confidentiality of both whistleblowers and reported people is strictly safeguarded, and employees are informed of their rights through internal communications and accessible policy documents. The Violence & Harassment Policy further ensures that complainants receive support, can access administrative or judicial authorities, and may request protective work arrangements when needed. These provisions contribute to employee trust in the integrity and safety of the mechanisms.

S1.4 – Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

Occupational Health and Safety

The Company operates within a complex port environment, where employees may be exposed to risks associated with vessels movements, heavy machinery, and demanding operational procedures. Given the nature of these activities, the Company has developed a structured occupational health and safety framework, focused on prevention, risk control, and the continuous improvement of working conditions, aiming to mitigate incident rates and foster a robust safety culture across its port facilities. A core component of this framework is the Occupational Risk Assessment Study, which covers all job positions and is regularly updated to reflect changes in operations and working conditions. Through this process, risks are systematically identified and assessed, and appropriate preventive measures are determined to limit potential adverse effects on the workforce.

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The Company implements structured procedures and internal regulations governing port operations that facilitate the management of occupational risks.At the same time, Standard Operating Procedures (SOPs) and preventive controls are implemented, while emergency response plans are maintained for incidents such as fire, earthquakes, natural disasters, or hazardous spills. These plans are validated through scheduled readiness drills, enhancing operational resilience and mitigating potential impacts on the health and safety of the workfoce. Employee participation is a key element of the Company's approach. The Health and Safety Committee, which consists of employee and management representatives, meets regularly to review working conditions, monitor compliance with safety measures, and make proposals for improvement. Furthermore, the Company is notified upon the introduction of new equipment, materials, or installations that may impact safety, facilitating the timely integration of preventive measures into operational planning. Employees also participate in safety training and awareness initiatives, while role-specific safety instructions and targeted actions reinforce a culture of prevention and vigilance in the workplace. In the event of an incident, the Company follows a structured investigation process to identify root causes and determine corrective and preventive actions. Where employees are affected by health and safety incidents, the Company ensures the provision of appropriate support and the remediation of working conditions, while corrective measures are implemented to prevent recurrence. The conclusions are incorporated into updated procedures or operational adjustments, ensuring the continuous improvement of safety practices. [S1-4_38 a], [S1-4_38 b] At the same time, employee representatives actively participate through the Health and Safety Committee, helping to identify and assess negative impacts and plan preventive actions. The effectiveness of the measures is monitored through health and safety indicators and internal audits, the results of which are used for the evaluation of the actions' effectiveness and the continuous improvement of the procedures. The monitoring mechanisms include, among others:
* monitoring work-related incidents and health and safety issues,
* conducting regular inspections of workplaces,
* assessing the adequacy and use of Personal Protective Equipment (PPE), Health and Safety Framework Standard Operating Procedures (SOPs) Checklists Emergency Plans

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* the operational readiness of support infrastructure (e.g., 24/7 ambulances) [S1-4_38 d]

The Company has adequate human, organisational, material, and financial resources to manage and mitigate the material impacts related to its workforce, with a particular focus on occupational health and safety. At an organisational level, the Human Resources Department supports the implementation of relevant policies, while Health and Safety officers actively contribute to the prevention of occupational risks and the monitoring of relevant procedures. At an operational level, the Company systematically invests in means of prevention and response to incidents, providing appropriate Personal Protective Equipment (PPE) to staff, depending on the nature of the work. At the same time, two ambulances with trained personnel are on standby 24 hours per day (24/7) to respond immediately to emergencies, while defibrillators have been installed and are operational in critical work areas. In addition, a budget is available for health and safety actions, staff training, and equipment for the prevention and management of emergencies. [S1-4_43]

Finally, one of the Company’s fundamental principles is to give priority to the protection of the health, safety and rights of employees over operational or financial pressures. In cases of conflict between operational objectives and the need for the prevention of adverse effects on the workforce, the Company prioritises the protection of employees and takes the necessary adjustment measures, such as redistributing tasks or adjusting schedules. [S1-4_41]

Employee Health & Safety Incidents

Employee health and safety issues are linked to operational risks for the Company, given that port activities involve vessel movements, the use of heavy equipment, and complex operational procedures. Potential work-related injuries or occupational health issues may adversely affect employee well-being and business continuity, while also carrying the potential for legal liabilities or reputational damage. The Company implements a structured set of procedures and Standard Operating Procedures (SOPs) governing port activities in order to manage and mitigate the relevant risks. These procedures incorporate preventive controls into daily operations and are supported by training and awareness-raising activities, as well as safety guidelines for each job role. Incidents are recorded, monitored, and analysed systematically in order to identify root causes and implement corrective and preventive measures. The findings are communicated to the relevant departments, reinforcing the prevention and safety culture. [S1-4_40 a]

In the context of strengthening prevention and early warning, the Company is in the process of developing an ISO 45001-certified Health & Safety Management System, planned for full implementation by 2027, which will provide a more comprehensive and standardised framework for managing occupational risks. In parallel, the installation of weather stations by 2026 for the monitoring of real-time meteorological conditions and for the issuing of alerts on wind or weather phenomena that could affect workforce safety. These initiatives are expected to further enhance resilience and reduce both the likelihood and severity of incidents.

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Governance and oversight mechanisms also support the management of this risk. The Health & Safety Committee, comprising employee representatives and management, meets regularly to examine working conditions, discuss incidents and propose improvements. At a strategic level, the ESG & Sustainability Policy includes commitments to safe and healthy working conditions and alignment with international standards. Management bodies review key performance indicators and significant incidents as part of the broader risk-management framework, ensuring appropriate supervision and continuous improvement. [S1-4_40 a]

Health and Safety Indicators KPIs

2024 2025
Percentage of people in its own workforce who are covered by PPA’s health and safety management system based on legal requirements and/or recognised standards or guidelines [S1- 14_88 a] The Company is in the process of developing a Health and Safety Management System in accordance with ISO 45001. In the reporting period, the system has not yet been certified, and therefore, no coverage rate of the workforce based on a certified framework is available. At the same time, organised health and safety procedures are implemented in accordance with the applicable legal requirements. The Company is in the process of developing a Health and Safety Management System in accordance with ISO 45001. In the reporting period, the system has not yet been certified, and therefore no coverage rate of the workforce based on a certified framework is available. At the same time, organised health and safety procedures are implemented in accordance with the applicable legal requirements.
The number of fatalities in own workforce as result of work-related injuries and work- related ill health [S1-14_88 b] 0 0
The number of recordable work- related accidents [S1-14_88 c] 14 14
Recorded work- related accidents indicator [S1- 14_88 c] 9 7.19
The number of cases of recordable work-related ill health of employees [S1- 14_88 d] 0 0
The number of days lost to work-related injuries and fatalities from work-related accidents, work- related ill health and fatalities from ill health related to employees [S1- 14_88 e] 454 784

The workplace accident indicator is calculated by dividing the number of recorded incidents by the total number of hours worked by the Company’s staff and multiplying the result by 1,000,000.

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Work-life balance and Well-being.

Work-life Balance and well-being have been identified as a material actual positive impact for the Company’s own workforce. The Company provides safe and fair working conditions through a structured internal framework of corporate regulations and collective agreements, which define clear rules on career development, working conditions and employee participation. This framework contributes to a transparent working environment where employees feel secure and valued while the Company confirms that all its employees are paid an adequate wage, in accordance with the applicable legislative and regulatory frameworks and the relevant benchmarks, as defined by national legislation and collective labor agreements. [S1-10_69]

Within this framework, the Staff Promotion Regulation sets out transparent criteria for promotions and internal moves and clarifies rights and obligations relating to working time, remuneration and participation in decision-making. The ESG & Sustainability Policy complements the Regulation, the Code of Conduct, the Diversity, Equality & Inclusion Policy and the Policy to Prevent and Combat Violence and Harassment at Work, which together promote respect, non-discrimination, equal opportunities and protection from inappropriate behavior, thereby supporting employees’ physical and mental well-being.The Company maintains open communication channels with trade unions and employee representatives, including regular consultation on matters related to working conditions, well-being and work-life balance. Social dialogue, participation of workers’ representatives in health and safety matters and structured feedback mechanisms through training, complaints and engagement processes strengthen trust, transparency and mutual understanding between management and staff. [S1-4_38 c], [S1-4_39] In addition, the Company offers a range of health-related employee benefits that directly support employees’ well-being and their ability to balance professional and personal responsibilities. These include discounted health diagnostic packages for employees and their immediate family (screening and consultation with experts), a Life and Health Insurance Program covering hospital and out-of-hospital care, accidents and pharmaceutical expenses, as well as access to interest-free health-related loans. Together with access to preventive medical services and family-oriented leave provisions, these benefits enhance employees’ sense of security and help them manage unexpected health-related costs. [S1-4_38 c] The effectiveness of the Company’s actions on work-life balance and well-being is reflected in the outcomes of the Company’s Double Materiality Assessment and in workforce indicators. The Company maintains a highly stable workforce with strong employee engagement and trust in management, consistently recording low levels of absenteeism and work-related incidents relative to the nature of port activities. [S1-4_38 d]

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Key Performance Indicator (KPI) 2025 Women Men Total
Percentage of employees entitled to take family-related leave [S1-15_93 a], [S1-15_94] 100% 100% 100%
Percentage of employees entitled that took maternity leave 2.5% - 0.4%
Percentage of employees entitled that took paternity leave - 1.5% 1.3%
Number of entitled employees that took family-related leave [S1-15_93 b] 66 91 157
Percentage of eligible employees who took family-related leave 41,3% 10.1% 14.8%
Percentage of employees that are entitled to and make use of carers’ leave from work [S1- 15_93 b] 8.4% 34.4%% 12.9%
Percentage of employees that are entitled to and took parental leave 4.4% 0.2% 0.85%

Employee Engagement and Social Dialogue

The Company maintains a long-standing tradition of structured social dialogue and constructive engagement with its workforce. This has resulted in a positive material impact on labour relations, organisational stability and employee trust. As one of the largest port organisations in Greece, the Company operates in a labour-intensive environment where collaboration between management and employee representatives is essential for ensuring operational continuity and a stable working climate. The percentage of employees that are covered by collective bargaining agreements is 100%, while all the employees (100%) are covered by social protection. [S1-8_60 a], [S1-4_38 c]

Furthermore, all employees are covered by social protection schemes, either through the national public social security system or through supplementary benefits provided by the Company, against loss of income resulting from major life events. Specifically, employees are covered in relation to:
* sickness [S1-11_74 a]
* unemployment [S1-11_74 b]
* occupational accident and acquired disability [S1-11_74 c]
* parental leave [S1-11_74 d]
* retirement [S1-11_74 e]

in accordance with applicable Greek legislation and the Company’s additional benefits framework. Furthermore, all the PPA S.A. employees receive adequate remuneration in accordance with the applicable legislative and regulatory frameworks and benchmarks, as defined by national legislation and collective labour agreements [S1-10_69]

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Regular interaction between management and employees, including formal meetings with unions, day-to-day exchanges and ongoing consultation on employment matters, supports an environment in which employees feel encouraged to express their views, raise concerns and contribute to discussions that influence decision-making. This continuous engagement allows workplace issues to be identified and addressed early, helping prevent escalation and reinforcing transparency and mutual understanding. Employee unions play a central role in this positive impact. PPA S.A.’s employees participate actively through four primary unions (Permanent Employees, Technicians & Operators Union, Dockworkers Union and the Association of Supervisors-Foremen) and one secondary union (Federation of Employees of Greek Ports). Union participation covers nearly the entire workforce. In 2025, 1031 employees were union members, including 884 men and 147 women. This high level of representation contributes to structured communication, promotes trust and strengthens collective representation. The Company maintains regular communication with union representatives on key topics such as working conditions, health and safety, training, staffing needs and organisational changes, helping maintain predictable labour relations and reducing the risk of conflict or operational disruption.

Furthermore, the Company's unions are actively involved in European representative bodies. Specifically, there is representation on the European Dockworkers Council (EDC), which strengthens the international dimension of trade union action and the connection with European ports. The Permanent Employees Union and the Technicians and Operators Union participate in the EDC through the Federation of Greek Port Employees (OMYLE), while the Dockworkers Union is also a member of the EDC. This participation strengthens the institutional representation of workers at European level, facilitates the exchange of know-how and good practices, and contributes to the formation of common positions on issues relating to labour relations and employment conditions in the port sector. [S1-8 63 b]

In addition to union engagement, the Company facilitates open communication through various channels that allow employees to express their views, seek information and provide feedback. These include:
* internal announcements
* email communication
* the Office Automation (OA) system for processing requests
* direct dialogue with management under the Company’s open-door approach

Feedback is also collected through structured mechanisms such as targeted compliance surveys, OA platform assessments and exit interviews. These tools help the Company monitor employee sentiment, identify areas for improvement and evaluate the effectiveness of its engagement actions. [S1-2_27 a], [S1-2_27 b], [S1-2_27 c], [S1-2_27 e]

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As a result of these engagement mechanisms, employees experience a stronger sense of representation and greater confidence in influencing matters that affect their work environment. At the same time, the Organisation benefits from smoother day-to-day operations, reduced labour-related risks and a more cohesive organisational culture. Social dialogue contributes to workforce stability, supports retention and reinforces long-term organisational performance.

Equal Opportunities

PPA S.A. fosters an inclusive, fair and non-discriminatory working environment, generating an actual positive social impact on its workforce. The Company implements structured Diversity, Equity and Inclusion (DEI) practices that promote equal treatment in employment, recruitment, training and professional development. The Company’s commitment to equal opportunities is embedded in its DEI Policies, the Code of Conduct and all HR procedures, ensuring transparent and objective decision-making across the employee lifecycle

The Company has an approved Diversity, Equality & Inclusion (DEI) Policy covering all employees, regardless of employment status or nationality. In addition, diversity criteria for members of the Board of Directors are further specified in the Company’s separate Diversity Policy for BoD Members. The Company already meets the 33% gender representation requirement for Boards under National Law 5178/2025, achieving compliance ahead of the 2026 legal deadline. This demonstrates PPA S.A.’s early integration of EU DEI principles and its strong governance on diversity.

Distribution in Number and Percentage at Top Management level by Gender [S1-9_66 a]

KPI 2024
Number Percentage
Male Female Male Female
Senior Management 5 1 83.33 16.67

Remuneration practices follow the principle of equal pay for equal work, without differentiation based on gender or nationality, supporting workplace equity and fairness. Inclusive recruitment and transparent promotion criteria further reinforce the Company’s position among Greece’s leading port organisations in applying DEI standards.

Distribution in Number and Percentage at Top Management level by Gender [S1- 9_66 a]

KPI 2025
Number Percentage
Male Female Male Female
Senior Management 7 1 87.50% 12.50%

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The Company monitors and evaluates the implementation and effectiveness of relevant actions and initiatives through specific mechanisms and procedures. In particular:
* Compliance with regulations and policies is monitored by relevant organisational units, in addition to the Human Resources Department, such as the Regulatory Compliance, Risk Management, and Internal Audit, which contribute to ensuring compliance and evaluating the effective implementation of relevant procedures.• The Company maintains reporting channels through which reports or complaints regarding unequal treatment or policy violations can be submitted. To date, no cases of unequal treatment have been recorded.
• The Company's operations are aligned with the country's current institutional framework, such as Law 5178/2025 on gender balance on the BoD, which also serves as a basis for monitoring the implementation of equality principles.
• The presence and operation of employee unions for various staff categories serves as an additional communication channel and mechanism for raising issues related to human resources. Through the above mechanisms, the Company systematically monitors the implementation of relevant policies and evaluates the effectiveness of actions and initiatives aimed at ensuring equal treatment and equal opportunities for its workforce. These practices create a workplace where equal treatment is embedded in daily operations, supporting Equal Opportunities on the Company’s material IRO and contributing to a fair and inclusive working environment. [S1-1_18], [S1-4_38 c], [S1-4_38 d]

In 2025, PPA SA employed 11 people (1.03% of the total number of employees) with disabilities, of whom 5 (0.55% of the total number of employees) are men and 6 (3.75% of the total number of employees) are women, promoting inclusion and providing access to jobs for underrepresented groups. [S1-12_79, S1-12_80] The disclosure of information relating to persons with disabilities is carried out in accordance with the applicable national legal and regulatory framework. The data is sourced from internal human resources records and is based on available and legally processable information. Given that the Company operates exclusively in Greece, there are no implications arising from differences in the legal definitions of persons with disabilities between different countries. [S1-12_AR76]

Distribuon of employees by gender and age [S1-9_66 b]

KPI 2024 2025
Male Female Total Male Female Total
<30 61 9 70 75 18 93
30-50 347 75 422 380 74 454
51+ 464 68 532 443 68 511

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10 It should be noted that for the current reporting year, the staff classification has been revised into three groups (Senior Management, Department Heads, Employees), compared to the previous year, when staff were presented as Senior Management, Supervisors, Office Employees, Technical Staff, Dockworkers, and Foremen. Under the new scheme, Senior Management corresponds to the same category, Supervisors are included in the Department Heads category, and all other categories fall under Employees.
11 The gender pay gap is calculated as the difference between the average gross hourly earnings of men and women, divided by the average gross hourly earnings of men and expressed as a percentage. The result is −5.06%, which indicates that women have an average higher gross hourly earnings than men.
12 The ratio of the highest-paid individual's total annual compensation is calculated by dividing their total annual compensation by the median total annual compensation of employees, excluding the highest-paid individual. [S1- 16_97 c]

Distribuon of employees by gender and leven of hierarchy [ S1-9 _66 a]

KPI 2024
Number Percentage
Male Female Male Female
Senior management 5 1 83% 17%
Department managers 41 24 63% 37%
Employees 826 127 87% 13%

Employees by gender and contract type [S1-6_52 a], [S1-6_52 b]

KPI 2024 Total 2025 Total
Male Female Male Female
Number of Employees 872 152 1,024 898 160 1058
Number of Permanent Employees 865 150 1,015 853 147 1000
Fixed Term Employees 7 2 9 45 13 58
Number of employees with non-guaranteed working hours 0 0 0 0 0 0
Full Time Employee 872 152 1,024 898 160 1,058
Part Time Employees 0 0 0 0 0 0

Distribuon of employees by gender and hierarchical level

KPI 2024
Number Percentage
Male Female Male Female
Directors 7 1 88% 12%
Managers (Senior Sta) 33 20 62% 38%
Oce Employees 858 139 86% 14%

Remuneraon metrics

Gender Pay Gap [S1-16_97 a] -5.06% 11
Pay rao between the highest-paid individual and the median employee remuneraon [S1-16_97 b] 7.8 12

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During the reporting period, there were no complaints, incidents or grievances related to social issues or human rights violations and consequently no fines, penales or compensaon for damages were imposed in relaon to the above. All data regarding employee relaons have been collected in accordance with the usual internal reporng pracces, without any special incidents having occurred. Regarding the 4 complaints, all of the submissions received concerned the General Sta Regulaons as well as the General Conduct among employees. For these complaints, the prescribed internal procedure was followed with the closure of the complaints in their enrety without any ne or convicon for the Company. Therefore, no amounts related to nes, penales or compensaon for such maers are presented in the nancial statements.

Incidents of discrimination, human rights violations, and related sanctions

Number of discrimination incidents [S1-17_103 a] 0
Number of harassment incidents 0
Number of complaints submitted through channels for the Company's workforce [S1-17_103 b] 4
Fines, penalties, and compensation for damages resulting from incidents of discrimination, including complaints and harassment [S1-17_103 c] 0€
Number of complaints filed to the National Contact Point for OECD Multinational Enterprises 0
Number of serious human rights violations and incidents related to the Company's workforce [S1-17_104 a] 0
Number of serious human rights violations and incidents related to the Company's workforce that constitute non-compliance with the United Nations Guiding Principles and the OECD Guidelines for Multinational Enterprises [S1- 17_104 a] 0
Non-serious human rights issues and incidents related to the Company's workforce [S1-17_104 a] 0
Fines, penalties, and damages for serious human rights issues and incidents related to the Company's workforce [S1-17_104 b] 0€

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Incidents of discrimination, human rights violations, and related sanctions

Number of discrimination incidents [S1-17_103 a] 0
Number of harassment incidents 0
Number of complaints submitted through channels for the Company's workforce [S1-17_103 b] 4
Fines, penalties, and compensation for damages resulting from incidents of discrimination, including complaints and harassment [S1-17_103 c] 0€
Number of complaints filed to the National Contact Point for OECD Multinational Enterprises 0
Number of serious human rights violations and incidents related to the Company's workforce [S1-17_104 a] 0
Number of serious human rights violations and incidents related to the Company's workforce that constitute non-compliance with the United Nations Guiding Principles and the OECD Guidelines for Multinational Enterprise [S1- 17_104 a] 0
Fines, penalties, and damages for serious human rights issues and incidents related to the Company's workforce [S1-17_104 b] 0€

Diverse talent attraction

The Company operates in a traditionally male-dominated sector where diversity across age, gender and cultural background remains limited nationally and internationally. This creates a significant strategic opportunity for the Company to strengthen its position as an inclusive employer and attract a broader range of talent. To capitalise on this opportunity, the Company implements specific policies and practices that promote inclusion and equal treatment in the workplace. Specifically, the Company implements a Diversity, Equality, and Inclusion Policy, and maintains an established and transparent promotion process through its Staff Promotion Regulations, ensuring equal career advancement opportunities for all employees. At the same time, it implements collective bargaining agreements that guarantee fair employment terms. As part of its efforts to attract new talent, the Company participates in university career days and career fairs, while job postings are published in a manner that is open and accessible to all candidates, without discrimination. Through these and other initiatives, the Company seeks to strengthen its position as an inclusive employer and attract a broader and more diverse range of talent. [S1-4_40 b]

The Company’s workforce already reflects a mix of professional backgrounds, age groups and functional roles. Women currently represent 15% of total employees, while employees under 30 constitute a smaller share of the workforce, consistent with wider sectoral dynamics. [S1-6_50 a], [S1-9_66 b] Representation varies across hierarchical levels: administrative roles show comparatively stronger gender balance, whereas technical and dockworker roles remain predominantly male. These patterns highlight the potential to broaden the candidate pool and strengthen diversity over time.

Employees Recruitments by Gender and Age

KPI 2024 Total 2025 Total
Male Female Male Female
Recruitment 96 7 100 145 19 164

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The Company’s employment model is characterised by 100% full-time positions, transparent recruitment and promotion processes, continuous training pathways and structured social dialogue, which creates an attractive working environment for diverse talent groups.The Personnel Training Policy, the Staff Promotion Regulation and regular performance assessments support predictable career development and reinforce equal access to advancement opportunities. By enhancing representation across genders, age groups, cultural backgrounds and people with disabilities, the Company can expand its skills base, strengthen organisational adaptability and improve decision-making. This opportunity supports long-term competitiveness in a rapidly evolving labour market and aligns with emerging EU expectations on inclusion and social sustainability [S1-4_40 b] The effectiveness of these practices is reflected in the Company’s stable workforce structure, its transparent career-development framework and its consistently high levels of employee retention and engagement. [S1-4_38 d] During the reporting period, a total of 58 employees departed from the Company, consisting of 52 men and 6 women. The employee turnover rate for the reporting period stood at 5.48%.

Employee turnover

KPIs 2024 2025
Voluntary 7 5
Dismissals 0 0
Retirements 61 53
Work-related fatalities 0 0
Total 68 58
Employee departure rate (%) 6.64 5.48

Employee turnover by gender KPIs

KPIs 2024 2025
Male Female
Voluntary 5 2
Dismissals 0 0
Retirements 55 6
Deaths in service 0 0
Total 60 8
Employee departure rate (%) 6.88 5.26

Attrition data were calculated based on headcount. The employee turnover rate was calculated as the ratio of the total number of departures (voluntary resignations, dismissals, retirements, and work-related fatalities) during the reporting period to the total headcount for the same period. [S1-6_50 d] Compared to the previous reporting period, during which 68 employees departed from the Company, a decrease in the number of departures was recorded. [S1-6_50 e]

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The number of employees used for calculating the turnover rate is consistent with the number of staff presented in the Company's Financial Statements for the corresponding period 13 . [S1-6_50 f]

Training, Skills and Technological Readiness

The Company places strong emphasis on continuous learning and capability building, recognising that the port sector is undergoing rapid technological, digital and environmental transformation. To support workforce readiness and maintain operational excellence, the Company implements a structured and comprehensive training framework, governed by the Personnel Training Policy, which ensures equal access to development opportunities for all employees, including fixed-term staff. [S1-4_38 c] Training needs are identified through the Annual Training Plan, ad-hoc departmental requests, performance evaluations and certification requirements. The Human Resources Department coordinates all training processes (needs identification, provider selection, approvals, scheduling and monitoring), as well as the documentation of training participation and outcomes. [S1-4_39]

Participation in approved training programs is mandatory, and all certificates or proof of successful attendance are recorded in employees’ personal files. During the reporting period, employees participated in a diverse range of training programs covering sustainability, compliance, health and safety, digital skills, operational procedures, specialised technical skills. In total, 16,237 training hours were delivered in 2025 (2024: 11,524). Training subjects included:

  • Board of Directors Training (ESG Core Principles)
  • Risk Management
  • Internal Audit Issues
  • Occupational Health and Safety Management System (ISO 45001)
  • MS Office Training
  • Data Protection and GDPR Regulation
  • Port & Container Terminal Training
  • Corporate Governance
  • Tax & Financial Training
  • Legal & Regulatory Compliance Training
  • Labour & Social Security Training
  • Diversity, Equality & Inclusion Policy
  • ISPS Code (International Ship and Port Facility Security Code)
  • Services for People with Disabilities
  • Security Personnel Training
  • Occupational Health & Safety
  • Forklift Truck Operation (Clark)
  • Artificial Intelligence & ChatGPT
  • IT Trainings
  • ESG Sustainability Issues

13 See Annual Financial Statements 2025, Notes to the Financial Statements, Note 1 "Company Structure and Activities"

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  • Prevention of Violence & Harassment in the Workplace
  • Fire Safety
  • Human Resources
  • Induction Training
  • Training in the IMO IMDG Code (Dangerous Goods)
  • Procurement Regulations
  • Administrative / Leadership Training
  • Staff training hours on anti-corruption and anti-bribery issues
  • Customs Issues

The Company’s commitment to life-long learning is further supported through the Regulation for Certification Costs, which provides financial coverage for employees pursuing professional certifications or academic qualifications relevant to their roles. The average training hours per employee for 2025 stood at 15.35, with female employees recording 23.31 hours and male employees 13.91 hours. [S1-13_83 b] Training progress and completion are monitored via a Continuous Education Checklist, while induction training is mandatory for all new hires and includes safety protocols, internal regulations, corporate policies and standard operational procedures. [S1-4_38 d]

Employee Average Training Hours

2024 2025
Male 17.39 13.91
Female 10.18 23.31
Total-Average 11.25 15.35

To support structured professional development, a Competency Model and Managers’ Assessment framework has been implemented, enabling annual evaluation of skills, performance and capability gaps. These processes help identify areas where upskilling is required and enhance alignment with technological and operational needs. [S1-4_83 a]

Training & Skills Development for New Technologies

Technological and environmental transitions in global shipping (e.g. automation, digitalisation, alternative fuels and new energy systems) require employees to acquire new skills to safely and efficiently operate evolving port infrastructure. The Company is actively preparing its workforce through targeted training, induction, certifications and collaboration with external institutions. Although most initiatives are still expanding, the Company already provides structured learning on ESG issues, specialised technical training, Code of Conduct training and continuous on-the-job development. These efforts help ensure that employees can adapt to new technologies, improving operational safety, efficiency and readiness for future regulatory and technological changes. [S1-4_38 a]

Skill Gap and Technological Readiness

The accelerated automation and digitalisation of port operations create a significant risk if the workforce is not adequately prepared. Insufficient familiarity with new systems could lead to lower productivity, operational errors, higher safety risks and reduced competitiveness versus technologically advanced ports. The Company mitigates this risk through the structured Training Policy, annual skill assessments and department-level evaluations that identify training needs and areas where upskilling is essential. These processes form the basis for training roadmaps that support workforce readiness and prevent capability gaps. [S1-4_40 a], [S1-4_40 b]. Failure to address these gaps could hinder the Company’s transition toward more efficient and sustainable operations, increase operational costs and delay innovation.

Upskilling – Technological Capabilities of Workforce

As ports internationally shift toward digital, automated and low-carbon operations, the Company has a strategic opportunity to enhance its competitive position by investing in technological upskilling. Strengthening digital literacy, operational capabilities, and knowledge of new technologies can:

  • improve efficiency and accuracy in port operations
  • enhance safety and reduce incident likelihood
  • support faster adoption of alternative fuels and greener operations
  • attract high-calibre talent aligned with future port needs
  • reinforce the Company’s position as a leading Mediterranean port embracing innovation

By building a tech-ready workforce, the Company increases its resilience and its long-term ability to respond to global maritime shifts [S1-4_40 b]. Effectiveness is reflected in training participation levels, skill-development outcomes and the ability of employees to adapt to new technological and operational demands [S1-4_40 a].

Employee evaluation

The percentage of employees who participated in regular performance and professional development evaluations totalled 97.5% of the workforce (1,032 employees out of a total of 1,058). The breakdown of this percentage by gender is 97.77% for male employees and 96.25% for female employees. [S1-13_83 a]

The Company has adequate human, financial, and organisational resources to manage the material impacts related to its human resources. The implementation of the relevant policies, procedures, and actions is mainly supported by the Human Resources Department, in collaboration with other relevant functions of the Company, such as the Occupational Health and Safety function. The implementation of the relevant policies, procedures, and actions is mainly supported by the Human Resources Department, in collaboration with other relevant Company functions, such as the Occupational Health and Safety function.

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The Company allocates resources for the implementation of training and skills development programs, initiatives for employee health and safety, as well as actions that promote employee well-being and professional development. To support these actions, internal human resources management systems are utilised and, where necessary, collaborations with external specialised partners, such as training providers and health and safety consultants is used. These resources contribute to the effective implementation of relevant policies and procedures and to the management of material impacts related to the Company's human resources. [S1-4_43] Further information on the actions defined by PPA S.A. is presented in the “Targets and Actions Table” in section S1.5.

S1.5 – Targets related to managing material negative impacts, advancing positive impacts and managing material risks and opportunities

Regarding the targets, the base year has been set as 2024 [MDR-T 80(d)]. Specifically, for the target “Number of accidents,” the base year is 2022. The methodology applied for defining and monitoring the targets is based on tracking relevant performance indicators (KPIs) [MDR- T 80(d)]. The Company has established specific targets, with corresponding actions, for some of the material topics it has addressed, as presented in the table below. These targets are not quantified [MDR-T 80(b)], [MDR-M 75], [MDR-M 76], [MDR-M 77(c)]. Furthermore, no specific methodologies or significant assumptions have been used in the development of the targets [MDR-T 80(f)], and there is no structured stakeholder engagement process in their definition [MDR-T 80(h)]. Scientific evidence was not taken into account for target setting [MDR-T 80(g)]. Finally, no changes have been made to targets, methodologies, or assumptions, as the related processes are still at an early stage of development and maturation [MDR-T 80(i)]. No targets have yet been set for the impact “Work–Life Balance and Wellbeing,” as the Company plans to develop the relevant targets in the coming years [MDR-T 81].

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Targets and Actions Table

HEALTH AND SAFETY ENHANCEMENT

IRO Acons [MDR-A 68a] Target [MDR-T- 80b] Year [MDR-A 68c/ MDR-T 80e] Scope of Coverage [MDR-A 68b/ MDR-T 80c] KPIs [MDR-A 68e/ MDR-T 80b/ MDR – M- 75] Progress by 2025 [MDR-A 68e/ MDR-T- 80j]
S1 Occupaonal Health and Safety, Employee Health and Safety Incidents Gradual implementaon of the ISO 45001 Management System 2027 Own operaons Improvement of health and safety issues management Ongoing / 5% of target achieved
Installaon of weather staons to measure condions aecng worker safety and provide real-me alerts Prevenve approach to maintaining employee health and safety (ensuring health and safety in all areas of PPA S.A.) 2026 Own operaons Number of accidents Ongoing/ 30% of target achieved

STRENGTHENING EMPLOYEE ENGAGEMENT AND IMPROVING PERFORMANCE

IRO Acons [MDR-A 68a] Target [MDR-T- 80b] Year [MDR-A 68c/ MDR-T 80e] Scope of Coverage [MDR-A 68b/ MDR-T 80c] KPIs [MDR-A 68e/ MDR-T 80b/ MDR – M- 75] Progress by 2025 [MDR-A 68e/ MDR-T- 80j]
S1 Interacon with Employees and Social Dialogue Employee sasfacon survey - Design and implementaon - KPI monitoring 2026 Own operaons Meeng the needs and expectaons of employees % of Research Compleon No progress has been made
Developing an acon plan based on the results of the survey - Design and implementaon 2028 Own operaons Sasfacon rates and performance indicators will depend on the acon plan. No progress has been ma

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IRO Acons [MDR-A 68a] Target [MDR-T- 80b] Year [MDR-A 68c/ MDR-T 80e] Scope of Coverage [MDR-A 68b/ MDR-T 80c] KPIs [MDR-A 68e/ MDR-T 80b/ MDR – M- 75] Progress by 2025 [MDR-A 68e/ MDR-T- 80j]
S1 Equal Opportunies DEI Acon Plan Diversity Assessment - Design and Implementaon 2025 Own operaons Promong diversity, equality, and inclusion in the Company Percentage of people with disabilies Achieved 100%
Cooperaon with organisaons that support workforce inclusion for people with disabilies Inclusion of relevant provisions in contracts for persons with disabilies 2026 Own operaons Number of training courses provided Achieved 100%
S1 Training and skills development for new technologies Training oer for skills upgrading and retraining of the workforce -1.6 hours per employee 2026 Own operaons Number of training sessions provided Achieved 100%
- X hours of training in new technologies Own operaons Number of parcipants Ongoing/ 50% of the target achieved
ESG Training 200 parcipants 2026 Own operaons Number of parcipants Ongoing / 66 parcipaons

At the indicator level, no specific methodologies or assumptions have been applied [MDR-M_77 (a)], and no external party, has been involved in validating the metrics used [MDR-M 77 (b)]. The budget for these actions is estimated at €208,000, of which €102,000 is CAPEX and €106,000 is OPEX. During the reporting period, €48,000 has been implemented, while the remaining actions will be completed in the future according to the planned schedule [MDR-T 69 (a), (b)]

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ESRS S3- Affected Communities

S3.SBM-3 – Material impacts, risks and opportunities and their interaction with PPA’s strategy and business model

Stakeholder’s Interests and Opinions [S3. SBM-2 7]

The Company identifies the local and regional communities affected by port activities as a key stakeholder group, incorporating their interests, perspectives, and rights into its strategy and business model. Through stakeholder engagement processes and communication channels, the Company gathers feedback regarding the social and environmental impacts of the port operations, which is evaluated by management and incorporated into the sustainability strategy and decisions concerning the operation and development of the port, with the aim of ensuring responsible business conduct and the protection of human rights. Ports worldwide act as major economic engines, supporting and stimulating local, regional and national economies through job creation and the movement of goods. At the same time, neighbouring communities are mainly affected by environmental pressures arising from port operations and related transport networks. As a result, ports face the ongoing challenge of creating local value while maintaining the support and acceptance of neighbouring communities. These impacts arise directly from the Company’s business model and operational strategy and are taken into account in their planning and adjustment through the integration of mitigation measures and related initiatives, as well as by leveraging feedback from affected communities and other stakeholders [S3.SBM-3_8].

In the case of the port of Piraeus, the affected communities include residents, businesses and workers who operate or reside in areas adjacent to the port's operating zones, specifically in the following areas:
* Piraeus
* Perama
* Keratsini–Drapetsona
* Salamina [S3.SBM-3_9 a (i)]

These communities interact daily with port operations and are exposed to both positive socio-economic benefits and environmental pressures associated with maritime and land-based activity. The vicinity of ship repair, cruise operations, ferry terminals and logistics corridors creates a particularly close port–city relationship. Furthermore, due to the geographically concentrated nature of the Company’s operations and the absence of significant evidence of community-level impacts beyond the port’s immediate operating area, value-chain communities were not identified in the assessment.

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Although the affected communities within the value chain are considered in the Company's double materiality assessment, they do not present significant risks or challenges that would justify their presence in the Company's sustainability report for the reporting period. [S3.SBM- 3_9 a (ii)], [S3.SBM-3_9 a (iii)]

In the 2025 Double Materiality Assessment review, S3- Affected Communities chapter remained a material issue for the Company,which strives to minimise operational negative impacts on the wider community, to progressively mitigate them where possible, and to implement targeted community-focused initiatives that offset, to the greatest extent possible, any remaining impacts. In the 2025 Double Materiality Assessment review, S3- Affected Communities chapter remained a material issue for the Company, which strives to minimise operational negative impacts on the wider community, to progressively mitigate them where possible, and to implement targeted community-focused initiatives that offset, to the greatest extent possible, any remaining impacts.

The Double Materiality Assessment identified 3 material Impacts.:

Actual Positive Impacts
* Job Creation and Economic Growth (Company specific)
* Corporate Social Responsibility (Company specific)

Actual Negative Impacts
* Pollution Related Community Effects in Relation to Health & Quality of Life (Spills, Noise, Emissions, Waste, Traffic)

The Company contributes substantially to the local and national economy by generating employment opportunities and supporting the global logistics chain, while through its operations it directly facilitates trade and indirectly supports industry and service sectors. Job creation and economic development extend beyond Greece, given the Company’s strategic geographical position.As one of the major European ports in the Eastern Mediterranean, located at the crossroads of Asia, Africa and Europe, it provides the infrastructure required to serve significant volumes of transit trade. Furthermore, the Company, as a major gateway in global trade, generates positive impacts for affected communities through its responsible business operations and its structured Sustainability approach. By committing to safe working conditions, the protection of human rights throughout its value chain, to the level possible, the transparent stakeholder engagement and the continuous minimisation of environmental impacts, the Company strengthens trust with residents, public authorities and business partners contributing to a stable social licence to operate and enhancing the long-term reputation of the port in the regions it operates. Through its CSR initiatives, the Company supports education, culture, social inclusion and local development in the wider Piraeus area, benefiting communities in Piraeus, Drapetsona– Keratsini, Perama and Salamina. Partnerships with educational institutions, support to cultural and sports activities and contributions to local social programmes foster community well- being, strengthen local capabilities and promote cohesion in a dense urban environment

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S3.1 – PPA S.A.’s Policies related to affected communities

The Company has established a comprehensive policy framework aimed at preventing, mitigating, and, where necessary, remediation of the potential impacts of its operations on affected communities, while maximising the positive socio-economic value created through the Port of Piraeus. These policies guide responsible business conduct, environmental and corporate social responsibility, stakeholder engagement and transparent reporting. They apply across all the Company activities and form the basis for managing the material impacts regarding the “Affected Communities” section as identified in the 2025 Double Materiality Assessment, namely:
* Job creation and Economic Growth and
* Corporate Social Responsibility [S3-1_12]

The set of interrelated policies that collectively ensure a responsible, ethical and sustainable approach to operations are as follows and additional details may be found in the relevant section of the current Statement the ESG & Sustainability Policy,
* the Quality, Environmental & Energy Policy,
* the Code of Conduct, and
* the Whistleblowing Policy and Procedure for Managing Reports and Complaints.

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They are embedded into the Company’s day-to-day operations and apply to all employees, contractors, partners and third parties acting on behalf of the Company. [S3-1_14], [S3.MDR_P_65 a]

The ESG and Sustainability Policy provides the overarching framework for integrating environmental & corporate social responsibility, as well as good governance practices, into business processes. It sets out the Company’s objective of responsible operations, minimizing environmental impacts, enhancing social dialogue and contributing positively to society. It outlines key commitments related to climate change mitigation, environmental performance, stakeholder collaboration, and human rights, and is aligned with internationally recognised standards including the UN Global Compact, the UN Guiding Principles on Business and Human Rights, relevant International Labour Organization (ILO conventions), ISO 9001:2015, ISO 14001:2015, ISO 50001:2018, and ISO 14064-1:2018. [S3-1_17, MDR-P_65 d] Oversight is assigned to the ESG Committee, which acts as the policy owner and ensures proper implementation and alignment with the Company’s strategic direction. [S3.MDR_P_65 c, S3- 1_16]

Through its ESG and Sustainability Policy, the Company recognises the importance of stakeholder engagement and collaboration with local communities, governmental agencies, NGOs and industry partners to co-develop solutions that balance economic development and environmental protection. The Company maintains open communication channels and participates in processes requiring public consultation, thereby integrating community feedback into decision-making and environmental management practices. [S3-1_16 b]

However, through the Code of Ethics, the Company is committed to respecting human rights, which are taken into account within the broader approach to sustainable development, corporate governance, and compliance with the applicable regulatory and institutional framework. [S3-1_16]

In addition, the Quality, Environmental & Energy Policy defines the Company’s commitment to identifying and managing significant environmental impacts across its operations and value chain. This Policy emphasises prevention and mitigation of pollution, enhancement of resource efficiency and operation under a certified Integrated Management System aligned with ISO 9001:2015, ISO 14001:2015, ISO 50001:2018 and ISO 14064-1:2018. These systems support continuous improvement, effective operational control and transparent communication with interested parties. At the same time, the Policy provides for the implementation of documented procedures, monitoring mechanisms, and targeted action plans, which are implemented under the Company’s Integrated Management System, ensuring that environmental commitments are consistently translated into practice. [S3- 1_17], [MDR-P_65d]

The Company places particular emphasis on maintaining secure and reliable communication channels for reporting problems by individuals and communities. The Whistleblowing Policy establishes a structured and confidential mechanism for identifying and addressing potential illegal, irregular or unethical activities, including those that may relate to community impacts. The policy further outlines clear reporting channels, defines responsibilities, and enables corrective actions that strengthen transparency, risk mitigation and accountability.

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Whistleblowing Committee, appointed by Top Management, includes representatives from the Regulatory Compliance Unit, the Human Resources Department and the Legal Department, with the support of the Data Protection Officer. The Policy is fully aligned with Law 4990/2022, which incorporates Directive (EU) 2019/1937 and complies with GDPR and national data-protection requirements. [S3-1_16 c], [S3-1_17]

Collectively, these Policies form a coherent and integrated framework that supports the management of the Company’s impact on affected communities, aligns with applicable standards and regulations and strengthens the Company’s contribution to sustainable development. More Information about the policies can be found on the chapters E1-Climate Change, S1-Own Workforce, and G1-Business Conduct.

S3.2 - Processes for engaging with affected communities about impacts

The Company recognises the importance of understanding the perspectives of local communities and maintaining open and accessible channels through which concerns, comments and observations can be raised. Engagement with affected communities takes place directly, primarily through the corporate email address published on the Company’s website, which is available for residents and other interested parties to submit queries or feedback. In addition, the Company maintains regular and direct communication with local Municipalities on various issues that may arise, ensuring timely coordination and effective resolution of matters of local relevance.This communicaon is conducted in person and by telephone and occurs frequently, reecng the Organisaon’s commitment to maintaining transparent and cooperave relaonships with municipal authories. No engagement through intermediaries, proxies or formal community representaves has been idened within the current reporng framework. [S3-3_21 a] Engagement occurs on an ongoing basis, as the communicaon channels remain connuously accessible. The nature of engagement mainly consists of wrien exchanges, enabling members of the community to contact the Company whenever an issue arises relang to their interests or well-being. Similarly, interacons with Municipalies take place whenever operaonal, social or environmental maers require coordinaon, with discussions held directly and oen informally to ensure the mely and ecient handling of the issues arising. This process allows the Company to receive input on a regular basis and to respond to potenal issues where necessary. Apart from this connuous communicaon mechanism no addional structured stages or forms of engagement have been reported. [S3-3_21 b] Responsibility for ensuring that engagement with local communies takes place while the insights collected through the relevant communicaon channels are incorporated in the Company’s decision-making through the management structure. The CEO holds the most senior responsibility for social engagement maers, overseeing community-related issues and approving relevant social iniaves. Community input and comments received through the Company’s communicaon channels are escalated through internal processes that ensure all relevant maers are brought to the aenon of senior leadership when necessary.

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Similarly, feedback originang from the collaboraon and discussions with Municipalies is assessed internally, with signicant maers are forwarded to senior management to ensure alignment with the Company’s strategic and operaonal planning. [S3-3_21 c] The eecveness of this engagement is supported through the Company’s established process for receiving, registering and managing comments and complaints submied via the corporate website and email. Submissions are handled in accordance with the Company’s internal Complaints & Comments Management Procedure, which ensures condenal treatment in compliance with GDPR and provides a structured process for reviewing and responding to concerns. While this mechanism applies to individual submissions, issues raised through ongoing communicaon with Municipalies are also recorded and monitored where relevant, supporng coordinated follow-up and shared problem-solving. This mechanism allows the Company to track any issues raised, ensure follow-up where required and integrate relevant feedback into its connuous improvement eorts. [S3-3_21 d]

S3.3 - Processes to remediate negative impacts and channels for affected communities to raise concerns

Remediation and Channels for Raising Concerns

All residents and members of the wider community are able to submit their comments, complaints or any maers of concern through the Company’s corporate email address, which is publicly available on it’s website. The Markeng and Quality Control departments receive complaints or posive feedback via [email protected]. The Markeng department forwards the complaint to all involved departments and to [email protected] requesng feedback (provision of informaon) from the Directors of the responsible departments as soon as possible, and no later than three (3) business days. In the case of cruise or ferry passenger complaints falling under Greek Law 3709/2008 (FEK 213A/14−10−2008) regarding terminal management operators, as amended, or Regulaon (EC) No 1177/2010, PPA S.A. must nofy the passenger in wring within one (1) month of receipt of the complaint whether it was upheld, rejected, or is sll under review. The me required to provide the nal wrien response will not exceed two (2) months from receipt of the complaint. The Markeng and Quality Control departments monitor the response process to ensure that all the accusers receive a reply and maintain the relevant stascal records. Understanding community concerns enables the Company to idenfy weaknesses and incorporate relevant perspecves into its strategy. These communicaon channels also contribute to mely addressing issues that may require correcve acon. [S3-3_27 a, S3-3_27 b] All feedback received from stakeholders is treated condenally and is managed in accordance with the Company’s Complaints & Comments Management Procedure, which is fully compliant with GDPR requirement [S3-3_28] In 2025, zero incidents or issues related to human rights violations have been reported. [S3-4_36]

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As part of its due diligence processes, the Company has designated the Head of the Risk Management Unit as the Ocer Responsible for the Receipt and Monitoring of Reports. The Company’s Whistleblowing Policy ensures that concerns can be expressed safely and transparently through mulple communicaon channels, including:
* Email: [email protected]
* Postal mail addressed to the Ocer Responsible for the Receipt and Monitoring of Reports with the indicaon “Condenal”.
* Physical reporng boxes located at Company facilies

The relevant boxes for reports/complaints are located at the following points within the Company’s facilies:
* Outdoor area of the Internal Audit Department Oce (PPA central building)
* Container Terminal Building (ground oor next to the elevator)
* Car Terminal Building (ground oor next to the main entrance)

In any case where a report/complaint is submied to a dierent corporate email and not to [email protected], it must be forwarded to this address by any recipient, so that the Compliance Ocer is noed and can take appropriate acon. Given that the procedure is governed by condenality regarding all collected and analyzed data, personnel are encouraged to submit each report/complaint openly to facilitate proper, faster review, evaluaon, and invesgaon. The management of reports/complaints is based on the following characteriscs considered to constute/ensure an eecve dispute resoluon plan:
* Accessibility: The Policy and Procedure for managing reports/complaints is easy to understand and use.
* Condenality: Informaon regarding a report/complaint is provided only to those designated to know about it, in order to take proper acons to resolve it.
* Independence: The Compliance Ocer and the Reports Management Commiee operate independently in carrying out their dues from both the reporng person and the reported person. [S3-3_27 c]

In addion, the monitoring of reports and complaints submied by stakeholders is further supported by the Data Protecon Ocer (DPO), who ensures compliance with personal data protecon regulaons. These mechanisms reect commitment to responsible business conduct by integrang reporng channels into its broader due diligence framework. The structured reporng system enables the mely and appropriate handling of issues, strengthening transparency and accountability across the Company’s operaons. All the above procedures and mechanisms are described in the Reports/Complaints Management Policy and Procedure, which is posted on the Company’s ocial website (hps://www.olp.gr/el/o- organismos/etairiki-diakivernisi/polikes). [S3-3_28] For issues such as trac, air polluon and the overall safety of the port and surrounding communies, the Company collaborates with local authories and government bodies to address these maers collecvely and enhance posive outcomes. [S3-3_27 d] Through its reporng mechanisms, communicaon channels and connuous cooperaon with local municipalies, any issues or complaints that arise are addressed either through policy review or through immediate acons aimed at reducing negave impacts, depending on the nature of each case.

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The Company’s CEO ulmately holds full responsibility for acons related to the protecon and support of aected communies. The CEO oversees social contribuon iniaves and due diligence processes maintaining a consistent overview of the maers aecng the community. All social iniaves and support programs are subject to the CEO’s approval, ensuring alignment with the Company’s strategic priories and commitments to sustainable development. [S3-2_21 c]

S3.4– Actions and approaches regarding material impacts on affected communities

Job Creation and Economic Growth

The Company plays a key role in generang local jobs, driving naonal economic growth and enabling internaonal trade. The port of Piraeus has a tangible posive impact on employment and economic development both in the communies surrounding the port and across the naonal economy. Enhancing employment opportunies has consistently remained a priority for the Company. By creang job opportunies, the Company contributes to social well-being and helps reduce unemployment at both the local and naonal level. Increased employment also strengthens the purchasing power of the workforce, smulang economic acvity in the wider Piraeus region, while supporng strategic objecves related to the port’s sustainability, reputaon and social contribuon.Port’s operations also support a diverse value chain, engaging local suppliers and businesses in sectors such as logistics, ship repair, transportation and other port-related services, thereby reinforcing the economic vitality of neighbouring municipalities. As a major gateway for trade in the Eastern Mediterranean, the Company plays a significant role in Greece’s GDP by facilitating trade, investment and industrial activity. Port’s strategic role enhances the country’s competitiveness, strengthens supply chains and ensures long-term economic resilience for both local communities and businesses. As a result, the Company’s presence generates sustained employment, income opportunities and economic circulation in Piraeus and beyond, strengthening both the regional economy and the broader social fabric of the communities that depend on the port. The Company reinforces its commitment to job creation and contribution to national GDP through initiatives such as:
* Providing reduced duties for exporting cargo to support the national economy and the balance of payments
* Operating the largest coastal passenger terminal in Europe, which promotes national cohesion and supports the economic development of the islands, with port fees remaining unchanged since 2016 to enable low-cost coastal connections
* Offering special pricing policies for vessels serving remote island routes
* Achieving high-performing economic indicators (KPIs) reported in the annual financial statements.
* Establishing actions and performance indicators specifically related to the Company’s contribution to national GDP. [S3-4_31 b]

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Impacts of Pollution on Local Communities in Relation to Quality of Life (Traffic Congestion) (Material Topic for the Company)

Communities surrounding the Port of Piraeus are exposed to environmental pressures associated with the Company’s port and shipping activities, the most significant being traffic congestion caused by vehicle circulation, port operations, and the concentration of transport flows in the wider area. Increased traffic congestion may negatively affect the daily lives and quality of life of residents in neighboring areas, as it is associated with higher noise levels, deterioration of air quality, travel delays, and general stress on the urban fabric. At the same time, some external impacts, such as traffic congestion and environmental burden, are addressed through structured mechanisms led by the State, designed to balance port activities with broader societal needs. [S3-4_33 a, S3-4_33 b, S3-4_35]

Mitigation of such external impacts is part of national policy and, therefore, is not solely at the discretion of private entities like Piraeus Port Authority S.A. [S3-4_32 d]

Where negative impacts cannot be fully avoided, the Company provides or enables remediation through compensation mechanisms established under the Concession Agreement with the Hellenic Republic. Within this framework, the Company indirectly makes financial compensatory contributions to the neighboring municipalities of Piraeus, Drapetsona-Keratsini, Perama, and Salamina, as provided in the Concession Agreement. In 2025, the amount paid to the Hellenic Republic reached €9,000,000 [S3-4_38], supporting local development, public infrastructure, and essential community services. Additionally, specific land areas within the port’s terrestrial zone have been allocated for public interest purposes, including healthcare facilities and other essential public services, as well as the construction of a recreational park, enhancing community resilience and social well-being. [S3- 4_32 b]

The Company identifies appropriate measures to address negative impacts through environmental monitoring systems, environmental assessments, and public consultation processes linked to environmental permits (EPE, AEPO, MPE), which ensure regulatory compliance and provide opportunities for stakeholder participation. [S3-4_33 c] Furthermore, the Company has completed a strategic resilience assessment and plans to implement shore-to-ship electrification infrastructure (cold ironing), allowing vessels to connect to the local electricity grid while docked. [S3-4_31 a, S3-4_32 a, S3-4_33 b, S3-4_35]

Decisions regarding preventive or corrective measures reflect combined information from monitoring results, public feedback, and regulatory trends (including Med SECA and EU emissions directives), ensuring that actions remain relevant, proportionate, and aligned with broader environmental objectives. [S3-4_33 a] The effectiveness of the Company’s actions is monitored through continuous reporting, defined sustainability targets, structured control programs, consultation requirements, and maintenance of communication channels with communities. [S3-4_32 d] These systems enable Piraeus Port Authority S.A. to track progress, identify areas needing further intervention, and ensure that environmental and compensatory measures achieve the expected outcomes. Overall, the Company’s structured compensatory and environmental management frameworks contribute to long-term community resilience and environmental protection.

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Corporate Social Responsibility (Company Specific)

The Company, being a critical node in global trade, is expected to operate responsibly, ensuring safe working conditions, protecting human rights in the value chain, minimising pollution, and engaging transparently with stakeholders. The Company’s CSR approach enhances the community’s and business partners’ trust, thus contributing to the Company’s operational efficiency and long-term reputation. Through its CSR initiatives, PPA S.A. creates tangible positive impacts on local communities by supporting education, culture, social inclusion, and local development in the wider Piraeus area. CSR actions, such as partnerships with schools and universities, sponsorship of cultural and sport activities, and donations to local social programs, strengthen community well-being, foster local skills and opportunities, and promote cultural cohesion in an urban environment directly influenced by port operations. In 2025, the Company contributed over €730,000 in donation and sponsorships. [S3-4 31 b]

Sponsorship Programme

The Company has launched a new Scholarship Program for the 2025-2026 academic year, underscoring its commitment to supporting local communities through educational initiatives. The program allocates a total of €30,000 in funding, providing ten scholarships of €3,000 each to outstanding first-year university students from the broader Piraeus region. Through this financial contribution, the Company supports the reduction of economic barriers to higher education, rewards academic excellence, and invests in the development of the next generation. The initiative reflects the organisation’s broader corporate social responsibility strategy, fostering long-term social value and strengthening its ties with the communities it serves. [S.3- MDR-A_68 a, S.3- MDR-A_68 b, S.3- MDR-A_68 c, S.3- MDR-A_69 b, S3-4_32 c]

Community park at the cruise terminal

In cooperation with COSCO SHIPPING and within the framework of CSR and enhanced engagement with local communities, the Company has undertaken the responsibility of creating a new, modern public park for the Municipality of Piraeus. The initiative includes a modern playground and a dedicated bicycle lane within the port’s cruise-terminal area. The project aims to enhance relations with the local community and the Municipality of Piraeus, while providing a significant environmental and social benefit. The planned 125-hectare green space is expected to help mitigate negative environmental impacts, particularly air pollution and noise, by acting as a natural buffer and contributing to air filtration. The total budget for the park remains estimated at €4.4 million.

The Company will continue tracking community satisfaction, the timely resolution of community complaints and the number of training courses conducted on effective complaint-handling processes, through the communication channels defined above. [S.3- MDR-A_68 a, S.3- MDR-A_68 b, S.3- MDR-A_68 d, S.3- MDR-A_69 a, S3-4_32 c , S3-4_32 d]

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Port Users/Stakeholders Council

In 2024, the Company launched the establishment of a Port Users/Stakeholders Council, which is planned to meet on a semi-annual basis. This initiative aims to strengthen the Company’s stakeholder-management framework and enhance open communication with all port users and stakeholder groups. Throughout 2025, the Company monitors participation levels in the Council, the number of active users involved, and the number of requests and complaints submitted and resolved within the defined response timeframe. [S.3- MDR-A_68 a, S.3- MDR- A_68 b, S.3- MDR-A_68 c,S3-4_32 c, S3-4_32 d]

Participation in Trade Associations and Unions

In 2025, the Company also began actions to expand its participation in trade associations and unions to reinforce its active role within the local community and the wider maritime sector. As part of promoting social dialogue, the Company is monitoring its social-media accounts and tracking outreach activities and engagement metrics throughout the year.[S.3- MDR-A_68 a, S.3- MDR-A_68 b, S.3- MDR-A_68 c, S3-4_32 c, S3-4_32 d] Distribution of Christmas gift vouchers to children in the neighbouring municipalities Every Christmas season the Company distributes through the local authorities more than 5,000 Christmas gift vouchers for children in the neighbouring municipalities, as well as families of workers in the ship repair sector, providing essential support to local communities during the holiday season. This initiative forms part of the Company’s broader social programme, which focuses on supporting vulnerable groups and promoting actions with a substantial social footprint. The nominal value of the vouchers for the year 2025 was over 200,000 euros. [S.3- MDR-A_68 a, S.3- MDR-A_68 b, S.3- MDR-A_68 c, S.3- MDR-A_69 b, S3-4_32 c, S3-4_32 d] More information regarding the actions defined by Piraeus Port Authority S.A. is presented in the table “Targets and Actions” in section S3.5. For the material topics “Job Creation and Economic Development” and “Impacts of Pollution on Local Communities in Relation to Quality of Life (Traffic Congestion),” there are no specific actions yet, as their gradual integration is currently in progress. [MDR-A 62]

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S3.5– Targets set in 2024 and progress

Regarding the targets, the base year has been set as 2024 [MDR-T 80 (d)], while the methodology applied for their identification and monitoring is based on internal tracking of relevant performance indicators (KPIs) [MDR-T 80 (f)]. Furthermore, there is no structured stakeholder engagement process in defining them [MDR-T 80 (h)], no changes in targets, methodologies, or assumptions have been reported [MDR-T 80 (i)], and no scientific evidence has been used for their creation [MDR-T 80 (g)], as the related processes are still in an initial stage of development and maturation.

In addition, the table of actions and targets currently covers selected material topics, specifically the topic (“Corporate Social Responsibility – Special Topic for the Company”), while other material topics (“Job Creation and Economic Development” and “Impacts of Pollution on Local Communities in Relation to Quality of Life (Traffic Congestion) – Special Topic for the Company”) are not yet fully represented, with the gradual integration of targets for all material topics ongoing [MDR-T 81]. The targets included in the table below are not quantified [MDR-T 80 (b), MDR-M_75, MDR- M_76, MDR-M 77 (c)].

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Table of Targets and Actions Ensuring Corporate Social Responsibility

IRO Actions [MDR-A 68a] Target [MDR-T- 80b] Year [MDR-A 68c/ MDR-T 80e] Scope of Coverage KPIs [MDR-A 68e/ MDR-T 80b/ MDR – M- 75] Progress by 2025 [MDR-A 68e/ MDR-T- 80j] [MDR-A 68b/ MDR-T 80c]
S3 Corporate Social Responsibility (Company Specific) Continuing its cooperation with local stakeholders Annual budget for local community support Annually Downstream Number of projects 100% achieved
Budget allocated Port users / Stakeholder Council
Improving the stakeholder management framework and achieving open communication with all port users/stakeholder groups Quarterly Downstream List of active users 100% achieved Percentage of users/stakeholders participating in the Port Users Council
Number of requests/complaints received and resolved within a specified time frame
New model park in the cruise port area (12.5 acres)
Strengthening relations with the local community and the Municipality of Piraeus 2027 Downstream Community satisfaction rate In progress/15% of target achieved
Strengthening the presence of the Company in the community and in social dialogue Monitoring the Company's social media accounts 2025 Downstream Number of posts/press releases by followers 100% achieved
Participation of the Company in trade associations and unions Strengthening the Company's active role 2025 Downstream 100% achieved

At the level of indicators, no specific methodologies or assumptions have been used [MDR-M_77 (a)], and no external party has been involved in validating the metrics employed [MDR-M_77 (b)]. The budget for the above actions is estimated at €5,280,000, of which €4,550,000 is CAPEX and €730,000 is OPEX. For the reporting period, €1,030,000 has been implemented, while the remaining actions will be completed in the future according to the planned schedule. [MDR-A_69].

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Our Commitment towards our Customers

ESRS S4 – Customers and End-users Strategy Interests and Views of Stakeholders [ESRS 2: SBM 2]

PPA S.A. acts as a key hub of connectivity and accessibility, shaping its strategy around the interests, views and rights of its stakeholders. Its long-term approach is built on respect for human rights, health and safety, ensuring that consumers, users and all affected groups are heard and treated responsibly. PPA S.A. strives to maintain open and effective communication channels to build mutual trust and collaboration, enabling the organisation to identify and monitor stakeholder concerns, needs and expectations. Delivering high-quality processes and services remains a strategic priority, with stakeholder feedback serving as a core driver for continuous improvement. [S4: SBM2 8]

Material IROs and Their Interaction with Strategy and Businesses [S4: SBM3]

The business model of the Port of Piraeus integrates all impacts related to the safety, health, and security of its users to enhance accessibility and the overall user experience. Millions of travellers, passengers, and port visitors of all ages, including vulnerable groups such as people with disabilities, rely daily on the port’s infrastructure and services. The customers and end- users that are impacted by the activities of PPA S.A., are presented as Indirect Customers (Tier2) in the relevant stakeholder identification sector as presented in ESRS 2. [S4: SBM-3 10, SBM-3 10 a, SBM-3 11]

  • 17,213,513 Passengers at the Ferry Terminal (+1% compared to 2024)
  • 3,055,596 Vehicle traffic (+1% compared to 2024)
  • 1,092,697 Homeport passengers at Cruise Terminal (+8% compared to 2024)
  • 772,042 Transit passengers (+12% compared to 2024)
  • 864 Ship calls (+7% compared to 2024)

The management of safety and security maintenance of customers and visitors is a firm commitment embedded in every operational process of the port and has a significant effect on the decision-making process. PPA S.A. implements a strict risk management process and regularly monitors potential systemic threats through risk control systems. [S4: SBM-3_10d]

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Through safety reports, the risk assessment of the operational procedures and through regular communication with the ferry and cruise operators PPA S.A. receives insights on which consumers and end users could be negatively affected- by operations- and how. In this context, PPA S.A. has identified specific characteristics of consumers and end users that may increase the risk of harm. These include persons with disabilities or reduced mobility, elderly passengers, children, and passengers who are unfamiliar with the port environment, such as first-time users or tourists. These groups may be more exposed to safety and security risks due to mobility limitations, increased dependence on accessible infrastructure, or limited familiarity with port procedures. [S4: SBM3_11]

Further promoting constructive interaction with this stakeholder group, the port maintains an open channel of communication and builds trust by systematically monitoring customer and end-user complaints. This channel strengthens the timely identification of potential challenges, supports effective problem-solving, and enhances overall customer satisfaction, thereby fostering long-term, trust-based relationships with port users.

Through the Double Materiality Assessment according to ESRS-2 the Company identified Passengers Port Safety and Security as bearing a potential negative impact that might affect the people who interact with or depend on the port’s safe functioning. The Company’s risk outlined below, in relation to consumers and/or end users, arises from potential impacts rather than dependencies. [S4: SBM3_10d]

Based on the information collected through observations, complaints, and reports, PPA S.A. integrates these impacts on consumers and end-users into risk management and the prioritization of strategic investments, such as the upgrading of terminal facilities, parking areas, and accessibility infrastructure [ESRS 2: SBM-3_48b]. In this context, the Company takes measures to protect consumers and end-users by leveraging the results of the Double Materiality Assessment and the Risk Register to inform its strategy and business model. These measures include infrastructure improvements, staff training, revision of safety procedures, and strengthening communication channels with users, ensuring that actual and potential negative impacts on consumers and end-users are directly incorporated into strategic decisions and resource allocation [ESRS 2: SBM-3_48 ai, ii].

In the case of PPA S.A., potential negative impacts on passenger safety and security do not constitute a systemic risk, but mainly concern isolated incidents that may arise from operational failures or extraordinary events. These incidents are addressed through a comprehensive safety framework. At the same time, any impacts that may arise from collaborations with third parties (e.g.service providers or contractors) are managed through contractual compliance clauses, supervision, and inspections, ensuring that the required safety and security standards are met. [S4 SBM3 10b]

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The Company uses information on the impact on consumers and end users, as derived from comments, complaints, and stakeholder surveys, to adapt its strategy and business model, enhancing safety, security, trust, and the overall user experience, while relevant risks and opportunities are recorded and monitored in the Risk Register and through target setting. [S4: SBM3 9]

Due to the crucial role of the Port of Piraeus as a major transport and passenger hub, the negative impact on passenger safety and security is considered substantial. These include accidents and security incidents that may affect passengers, including vulnerable groups. Such risks can affect safe operation and may cause service interruptions or damage to the port's reputation. Therefore, continuous monitoring and management of these risks is essential for decision-making by the Company. [S4: SBM-3_10b]

Potential Negative Impact Passenger’s Port Operation Safety & Security (Company Specific) Risks
Failures and Safety Incidents

Policies Related to Consumers and End-Users

Quality, Environmental & Energy Policy

The Company’s Integrated Management System [MDR-P_65 a, b, d]

The Quality, Environmental & Energy Policy of PPA S.A. is a central element of the Company's business strategy and an integral part of its Integrated Management System. During the reporting period, the Policy was updated as part of the regular review of the Management System, without any substantial change in its scope or basic principles, confirming PPA's commitment to continuous improvement and the provision of safe, reliable, and high-quality services to all port users, with particular emphasis on customers and passengers at the passenger terminal. The Integrated Management System is externally audited and certified, with the latest standards certification renewed in 2025 for a three-year period. The Policy applies to all of the Company's activities and applies to business partners and end users, without restrictions on any specific groups. [S4: S4-1_AR9]

The implementation of the policy is achieved through planning, setting goals, continuous monitoring and reviews in compliance with ISO 9001, 14001, 50001 & 14064-1 standards and maintenance of relevant certifications. The company has developed and maintains PPA’s Integrated Management System as per ISO 9001, 14001, 50001 & 14064-1 standards. Companies’ processes and operations are subject to internal audits conducted at least once a year, with the results reviewed during the Management Review Report. These standards include:
* ISO 9001:2015 (Quality Management)
* ISO 14001:2015 (Environmental Management)
* ISO 50001:2018 (Energy Management)
* ISO 14064-1:2018 (Emissions Management)

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Adoption of these standards ensures a systematic, transparent, and responsible approach to port operations, which enables the company to be proactive, ensuring the provision of high-quality services to customers and end-users, while controlling and minimising any potential impact to the environment and effectively managing energy consumption and efficiency aiming at reduced operational cost and emissions.

Key Commitments of the Policy [MDR-P 65a]

The policy focuses on enhancing service quality, protecting the environment, and improving energy performance. Its core commitments that relate to safety, health and security are:
* delivering services that meet the needs and expectations of customers and port users,
* identifying, assessing, and managing environmental risks (air, water, soil),
* implementing measures that support the health and safety of passengers, employees, and partners,
* establishing robust procedures for emergency preparedness and response,
* raising awareness and providing ongoing training to employees and collaborators,
* promoting continuous improvement through monitoring, internal audits, and performance evaluation.

PPA’s Policy reflects the demands of a complex operational environment and ensures that safety and high-quality service remain central to its mission. As part of its continuous approach to improvement, the Company has set a strategic objective to integrate the ISO 45001:2018 standard into the Company’s Integrated Safety Management System. This future certification will further strengthen the Company’s capacity to manage health and safety issues and achieve continuous improvement of procedures and preventive measures.

Governance & Accountability [MDR-P 65c]

The Policy is approved by the Top Management and overseen by the Manager of the Quality Control Department of PPA S.A., who is responsible for:
* regularly reviewing and assessing the performance and effectiveness of the Integrated Management System as per the respective ISO standards,
* ensuring the availability of resources and mechanisms for compliance,
* setting, monitoring, and assessing quality, environmental, and energy objectives, in cooperation with PPA S.A.’s departments which are accountable for the implementation of the objectives set.

Compliance and continuous improvement are verified through external audits conducted by independent certification bodies, as well as structured internal audits.

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Stakeholder Engagement [MDR-P 65e, 65f]

The Policy is developed and updated by taking into account the expectations and needs of all key stakeholder groups. Since it addresses the safety and security of passengers, end users, and everyone who uses the port facilities, the Policy considers the requirements of passengers and customers, employees and contractors who contribute to daily operations. Special attention is also given to the guidelines and standards set by port authorities and regulatory bodies. Its public availability reinforces transparency and strengthens stakeholder trust in the Company’s commitment to responsible, high-quality, and safe operations.

Complementary Policies [S4: S4-1_15]

In addition to its core Quality, Environmental, and Energy Policy, PPA S.A. has implemented a set of complementary policies specifically addressing the safety and well-being of customers and end users. These policies cover areas such as corporate governance, ethics, social responsibility and privacy, and apply inclusively to all consumers and end-users, rather than targeting specific groups. Together, they create a comprehensive framework that enhances the protection, trust, and overall safety of all stakeholders interacting with the port. More details on the relevant policies can be found on the corporate governance structure section of the current Statement.

Policy Contribution to Health and Safety of Customers and End Users
Whistleblowing and Incident Reporting Policy Enables prompt reporting and resolution of safety concerns and incidents.
Anti-Harassment and Workplace Violence Policy Ensures a safe and respectful environment for all port users and employees.
Data Protection and Privacy Policy Protects customer data, fostering trust and security for port users
ESG and Sustainability Policy Promote responsible operations that support a safe and healthy port environment.
Code of Conduct Ensures ethical conduct, transparency, compliance — indirectly supporting safety, trust, fairness and responsible operations for all port users.

$^1$ The section on Policies relating to Business Conduct and Corporate Culture provides details on the MDR-P 65 a-f indicators.

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Human Rights Protection [S4: S4-1_16a, b, c], [S4:S4-1_17]

PPA S.A. aligns its operations with the United Nations Guiding Principles, OECD Guidelines, ILO Principles and the UN Consumer Protection Guidelines. These frameworks guide the Company’s commitment to protecting passenger rights, well-being and safety across all services. Existing policies already cover key aspects of protection, while the full integration of human rights and customer safety issues into all governance and operational processes is in progress. A Human Rights Assessment is planned to identify potential impacts on passengers and other users and to inform targeted updates to related policies and safeguards. Any case of non-compliance with international principles is promptly investigated, and relevant findings are incorporated into the corporate risk registry. Continuous monitoring and corrective actions ensure that risks to passenger safety and user protection are effectively managed under the established risk management framework.

Furthermore, PPA S.A. integrates end-users into its customer interaction process (see relevant paragraph for S4-20), utilizing available communication channels such as satisfaction surveys, online complaint forms, the corporate website, email, and telephone hotlines to identify actual or potential impacts on services. Finally, remediation procedures are implemented (see relevant paragraph S4-3 25), which include corrective actions, infrastructure upgrades, staff training programmes and policy revisions, ensuring the effective resolution of grievances and the continuous improvement of service quality, safety, and accessibility. Insights from risk assessments, stakeholder feedback and incident reviews are used to update related policies and strengthen security.This cycle of improvement reinforces PPA’s commitment to responsible operations and sustained enhancement of customer and passenger safety.

Legislative and Regulatory Controls and Mechanisms

The Company operates in full compliance with the established legal and regulatory frameworks governing the health, safety, and protection of passengers using its terminals. These frameworks include internationally-recognised safety standards, certified safety plans, and strict national regulations, which together ensure effective protective measures and comprehensive preparedness for responding to emergencies.

Holistic port security and preparedness for emergency situations

The Port of Piraeus strictly complies with the International Ship and Port Facility Security Code (ISPS) Code, an international regulation designed to protect ships and port facilities from security threats. Incorporated into European Regulation 725/2004, the ISPS Code ensures harmonised security standards across EU ports. No serious issues or incidents were reported regarding human rights related to end users. [S4: S4-4_35].

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Under the ISPS Code, PPA develops and maintains certified Port Facility Security Plans (PFSPs) tailored to each terminal. These PFSPs specify detailed measures for access control, surveillance, security staff training, and emergency response, ensuring robust and proactive management of security risks.

PPA S.A. also implements Sea and Land Pollution Emergency Plans aligned with international and national legislation (OPRC 90, Greek Law 743/1997, PD 11/2002, and the 2000 HNS Protocol). These plans include annual emergency drills to ensure rapid and coordinated response to incidents. Security personnel have undergone specialised training, including certification as drone pilots, supporting the Smart Port initiative to monitor security and detect potential spillages effectively. These combined measures ensure a proactive approach to safeguard passenger safety and port security.

Passenger Rights Regulation

PPA operates in full compliance with EU Regulation No. 1177/2010, which safeguards passenger rights and establishes rules for sea and inland waterway transport. [MDR-P_65_d, S4:S4-1_17] This regulation addresses key aspects such as:
* Information provision before and during the journey,
* Assistance in case of delay or cancellation,
* Rights of people with reduced mobility,
* Compensation and reimbursement procedures.

Through adherence to this regulation, PPA ensures that passengers receive clear information, fair treatment, and appropriate assistance, reinforcing safety, accessibility, and trust in port services.

  • Additional services supporting passenger welfare at the port include:
    • Customer service points and help desks,
    • Accessibility features and facilities for people with disabilities,
    • Safety and emergency medical services are available throughout passenger terminals.

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Processes for Engaging with Consumers and End-Users Regarding Impacts

Engagement Processes with Clients and Port Users [S4: S4-2 20]

PPA S.A. maintains a structured and systematic approach to engaging with clients and end-users, designed to ensure continuous feedback, identify expectations, and understand the actual or potential impacts associated with its services.

Engagement with end-users is carried out through multiple communication channels that enable continuous feedback collection, reporting of concerns, and dynamic interaction. These channels support the identification of risks to consumer welfare, accessibility, satisfaction, and safety, and ensure that issues are addressed in a timely and systematic manner.

The table below summarises the engagement framework of PPA S.A. describing the interaction and the outcome of this process.

Communicaon Channels [S4: S4-2 20b] Interests & Expectaons of Consumers / End- Users PPA S.A. response [S4: S4-2_20d] Impact [S4: S4-2 20d]
Customer Sasfacon Surveys • High-quality and reliable services • Well-maintained facilies • Improved passenger experience • Annual surveys • Systemac analysis of results • Integraon of ndings into service design • Operaonal planning • Service improvements based on user input. • Idencaon of emerging risks aecng consumer experience
Corporate Website • Transparent, accessible, up-to-date informaon • Clear guidance • Mullingual content • Regular updates • Accessible design • Downloadable documents from the Company’s ocial website • Equal access to informaon. • Informaon gaps could impact consumer understanding
Online Complaint Forms (Grievance Mechanisms) • Easy submission of complaints • Fair and mely resoluon • Clarity in procedures • Dedicated digital grievance mechanism • Categorisaon and tracking of complaints • Correcve measures implemented • Strengthened accountability & transparency • Complaints reveal areas needing improvement • Early detecon of consumer harm
Email Communicaon ([email protected] [email protected])/ Customer Service Phone Lines • Direct access to informaon • Personalised guidance • Quick response • Real-me informaon • Ecient crisis response • Connuous monitoring of email channels • Maintained response-me standards • Escalaon for complex cases • Dedicated support lines • Published emergency contacts • Enhanced accessibility and responsiveness • Avoidance of delayed responses that may aect sasfacon • Strengthened safety and user condence. • Possible delay if call volume is high

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The Company maintains continuous engagement with its stakeholders throughout the year via multiple communication channels. Engagement can take various forms, including consultation and information provision, with the frequency depending on the channel. The results of engagement are incorporated into key stages of risk management, such as risk identification, mitigation approach determination, and effectiveness assessment. [S4-2 20b]. The section “Policy and Complaints Management Procedures” describes the mechanism for submitting and handling complaints, as well as the stages of their processing. It also specifies the operational responsibility and oversight of the engagement process. [S4: S4-2_20 c]

To further enhance engagement, the Company operates a Port Users Council. This enables users to contribute to improving services by recording any needs and issues that arise. [S4-5 41 a, b, c]

Complementary Enabling Mechanisms

The Company also engages indirectly with clients, passengers and end users through its relationships with B2B / intermediary client companies (e.g., cruise operators, ferry companies, and other commercial partners), which act as intermediaries conveying the needs, expectations, and concerns of their passengers and end-users. This enables PPA S.A. to capture broader stakeholder perspectives, including those of client groups with limited direct interaction with the Company.

Further, PPA’ s S.A. clients have access to valuable information through annual surveys and assist in the identification, monitoring and understanding key concerns and expectations. [S4: S4-2 20a]

To strengthen structured and transparent stakeholder communication, the Company initiated one more communication channel by developing and conducting a comprehensive Stakeholder Engagement Questionnaire in 2024–2025. The survey is repeated for the 2025 – 2026 period similarly conveys the Company’s ESG material topics while gathering the perspectives, expectations, and concerns of various stakeholder groups. The insights collected are systematically integrated into decision-making processes, supporting strategic planning, ESG prioritisation, and continuous enhancement of stakeholder engagement.

Processes for Remediating Negative Impacts and Channels for Raising Concerns by Consumers on Behalf of End-Users

Complaints Management Policy and Procedures

Adherence to Regulation (EU) No. 1177/2010 is essential for ensuring the rights of passengers in maritime and inland waterway transport. This includes provisions for compensation, assistance, and effective complaint handling in cases of disruptions, discrimination, or accessibility issues. These measures are in place to protect cruise and ferry passengers by ensuring that any concerns are addressed appropriately. In the event of recurring problems or serious concerns, corrective measures such as infrastructure improvements, training programmes, and policy reviews are implemented to improve quality, safety, and accessibility. [ S4: S4-4 32b, S4: S4-3 26 AR23]

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PPA S.A. provides a comprehensive grievance mechanism that enables clients, end users, visitors, and the wider community to submit complaints, concerns, or issues directly. Complaints can be submitted via a dedicated email ([email protected]) or through an online complaint form specifically designed for cruise passengers, accessible via the corporate website. [S4: S4-3 25b]

The Code of Ethics of PPA S.A. supports the responsible management of business relationships, promoting transparency, accountability, and compliance with the Company’s policies, including complaint-handling procedures for clients and end users. [S4: S4-3_25c] This ensures an accessible, transparent, and user-friendly process for raising concerns related to port services, accessibility, safety, or other relevant matters.For complex cases requiring remediation or further action, the Deputy Chief Executive Officer is responsible for escalating the issue to the Risk Register, where it is assessed and addressed through the Company's due diligence procedures. [S4:S4-2 20c] The steps of the complaint handling process include [ S4: S4-3 25 a,b,c,d]:

BUSINESS

The Company ensures the confidentiality and anonymity of complaints through secure submission channels. [S4: S4-3 AR22] 34

Complaints recorded in 2025 [S4: S4-3 AR22]
* 97% used email as a communication channel
* 3% used social media

23.5% of complaints have been resolved Correcive actions are planned for 29.4% of the complaints 1 complaint relates to health issues and 3 to safety issues. Any complaints not resolved within the reporting period are under investigation and monitored until a resolution is found. The effectiveness of the mechanism is assessed on the basis of specific indicators, such as the complaint resolution rate, the average response and handling time, and the rate of implementation of corrective actions. [S4: S4-4 32c]

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Through these integrated mechanisms, the Company builds a transparent, accountable, and client-focused grievance management system that strengthens risk mitigation, enhances stakeholder trust, and ensures continuous improvement in addressing negative impacts on consumers and end-users.

Whistleblowing Policy for Safety and Operational Concerns [MDR-P 65a]

15 In addition to the standard compliance and complaints-management mechanisms described above, the Company also applies a dedicated “Whistleblowing Policy and Procedure for the Management of Reports/Complaints”, which enables the reporting of a broad spectrum of concerns, including operational irregularities, safety deficiencies, service -quality failures, unethical behavior, or any condition that may pose a negative impact or risk for passengers, port users or the wider environment. Through this policy and its reporting mechanism facilitated via (i) electronic submission channels, (ii) dedicated email contact, and (iii) the option for direct reporting to authorised officers, the Company ensures that all potential risks and adverse impacts are identified, assessed, and addressed promptly and effectively, while end-users are protected from retaliation, in accordance with the safeguards set out in the Policy. [MDR-A_68a]

The Company also regularly assesses that consumers and end users are aware of and trust the available reporting structures through awareness measurements, channel usage rates, customer satisfaction surveys, analysis of recurring complaints, and resolution rates within predetermined time limits. These assessments ensure that the reporting process is effective and supports the integrity of port operations. [MDR-A_68c]

Other negative impacts and risks: Customer Privacy Management Procedures

During the materiality assessment, the Company identified a potential negative impact related to customer privacy and data protection. However, this sustainability matter is not classified as material. For the Company privacy and data protection remain critical issues, as significant volumes of sensitive operational data are processed daily. The Privacy Policy of the Company reflects its commitment to continuous evaluation of its services. PPA S.A. complies with EU and national legislation, including the General Data Protection Regulation (GDPR), supported by a dedicated Data Protection Officer, compliance management practices, and Data Protection Impact Assessments (DPIA) across various activities. The Company remains dedicated to ongoing service assessments and maintains open communication channels to ensure the prompt handling of any emerging issues.

15 The section on Policies relating to Business Conduct and Corporate Culture provides details on the MDR-P 65 a-f indicators.

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The Company is committed to the management of customer privacy and data through its Privacy Policy, which is part of the Integrated Management System and is linked to other compliance policies, such as the Whistleblowing Policy and due diligence procedures. These policies ensure the continuous monitoring, evaluation, and improvement of data protection procedures, as well as the information and training of employees, customers, and partners on privacy rights and the proper use of personal data. Furthermore, the Policy is aligned with the due diligence procedures implemented for the safeguarding of customer rights and ensures the identification and effective mitigation of operational risks.

Taking action on material impacts on consumers and end- users, and approaches to managing material risks

PPA S.A. applies a holistic and systematic approach to safeguarding the health, safety and well-being of customers and end users. [MDR-A 68b] The Company’s prevention and mitigation framework is grounded in clear governance mechanisms, standardised procedures and dedicated operational practices. . [MDR-A_68a]

Governance and Systematic Controls

  • Code of Conduct setting principles for responsible behavior and the protection of stakeholder interests. [S4: S4-5 33a, MDR-A_68 a]
  • ISO 9001:2015-certified Quality Management System ensuring standardised processes, quality controls and continuous improvement. [S4: S4-5 33a, MDR-A_68 a]
  • Quality Policy integrating structured procedures for monitoring performance and implementing corrective actions. [S4: S4-5 _33 a, MDR-A_68 a, c]
  • Compliance framework and Whistleblowing Procedure enabling secure reporting, investigation and remediation of incidents that may negatively affect customers and end- users. [S4: S4-5_33 a, MDR-A_68 d]
  • Risks related to consumers and end-users, such as passenger safety and health, are incorporated into the Company's Risk Register as part of the Integrated Management System. This allows for the systematic identification, assessment, and monitoring of relevant risks, ensuring that any negative impacts on users are addressed in a comprehensive and consistent manner and that the results of monitoring shape strategic decisions and process improvements. [S4: S4-5 33a]
  • Training programmes for employees, including service standards, safety, accessibility and ESG-related consumer topics, enhancing the Company’s capacity to identify, prevent and address potential negative impacts. [S4: S4-5 34, MDR-A_68 a]
  • Targeted training on accessibility and assistance for vulnerable passenger groups, delivered in collaboration with the Institute of the National Confederation of Persons with Disabilities and Chronic Conditions (IN-ESAMEA), providing over 1,000 employees with specialised theoretical and practical training on serving passengers with disabilities, chronic conditions and reduced mobility.

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The programme strengthens employees’ capacity to prevent exclusion, service failures and safety risks, and supports the systematic integration of inclusiveness principles into daily operations. [S4: S4-5_34, MDR-A_68 a,c]
* Ensuring fair treatment, accessibility, and established mechanisms for compensation, assistance, and complaint handling, within the framework of the application of the Regulation on Passenger Rights (EU 1177/2010). [S4: S4-5 34, MDR-A_68 d]
* Internal and external audits verifying adherence to standards and supporting continuous enhancement of control and mitigation processes. [S4: S4-5 33a, MDR-A_68 e]

Operational Safety and Emergency Preparedness

PPA S.A. maintains approved Emergency Response Plans for marine and land pollution in alignment with OPRC 90, Law 743/1997, Presidential Decree 11/2002 and the 2000 HNS Protocol. Annual emergency drills are conducted to test readiness and ensure coordinated response in case of an incident. [MDR-A_68 a]

The Security Department has introduced system improvements to enhance the efficiency and safety of cruise passenger screening, including upgrades to X-ray equipment at the Cruise Terminal. [S4:4 31d, MDR-A_68 a, MDR-A_69a] Additional preventive measures include the installation of mobile warning signs to reduce accident risks and informational signage at ferry terminal entries to guide vehicles and passengers, reducing congestion and enhancing safety. [MDR-A_68 a, b]

Collaboration with the Piraeus Health Services continues to support preventive emergency readiness across port operations. [S4:4 31a, b] Security personnel have been trained as certified drone operators, strengthening monitoring, surveillance and early detection capabilities under the Smart Port initiative. In cooperation with local authorities, the Company also supports the safe relocation of homeless individuals to designated facilities, whenever a need arises during the year. [S4: 4 31c, MDR-A_68 a, c, MDR-A_69 a]

The Car Terminal operates on a 24/7 basis with trained staff and continuous security supervision, achieving an almost zero-damage rate. ISPS Code compliance, favourable operating conditions and the availability of specialised equipment support safe vehicle handling and effective response to customer needs. [MDR-A_68 a, MDR-A_69 a ,b]

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Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

PPA S.A. is responsible for determining the appropriate actions to address actual or potential negative impacts on consumers and end-users.This determination is made based on a combined assessment of the risk analysis, the results of the Double Materiality Assessment (DMA), and the identification of important issues in accordance with the Company’s ESG and Sustainability Policy, concerning safety and accessibility. [MDR-T_80a]. The aforementioned factors, when considered in conjunction with the objectives derived from the ISO 9001:2015, ISO 14001:2015, ISO 50001:2018, and ISO 14064-1: 2018 standards, the commitment to continuous improvement of the safety, protection, and sustainability of operations and taking into account the results of the annual stakeholder survey [MDR-T h], serve as a guide for the continuous adaptation of mechanisms, policies, procedures, and feedback and complaint management systems. In this particular context, specific actions and objectives are defined, with the aim of effectively addressing the identified impacts and improving the experience of all parties involved. [S4: S4-4 32a], [MDR-T_80 f]. The base year for these targets has been set as 2024. [MDR-T_80 (d)] Furthermore, no changes have been made to targets, methodologies, or assumptions [MDR-T 80 (i)], and no scientific evidence has been used for their creation [MDR-T 80 (g)], as the related processes are at an early stage of development and maturation. The Company did not set targets for the reporting period for the material topic ‘Failures and safety incidents’ as the integration of these targets is still in progress [MDR- T_81] Each department, aligned with ISO 9001:2015 and ISO 14001:2015 requirements, sets and monitors specific targets and KPIs. In a similar manner, improvement targets are set for energy management and emissions management within the framework of ISO 50001 and ISO 14064- 1:2018. The incorporation of these targets form part of PPA S.A.’s annual target-setting and strategic planning framework, through which the Company strengthens operational efficiency, mitigates material risks, and proactively addresses emerging challenges across all business units [MDR-T_80c]. Regarding the material issue of health and safety at the passenger port, the Cruise and Ferry Department oversees relevant targets and tracks performance to improve service quality, passenger experience, and operational safety. [S4: S4-4 32a, MDR-T_80j] The 2024 targets still active in 2025 include managing specified volumes of vessels, passengers, and vehicles, expanding infrastructure, and optimising operational flows. Planned upgrades involve new screening equipment, modernisation of weighbridges, mechanical system improvements, and facility enhancements. Additional measures in ferry areas focus on terminal upgrades, shelter installations, traffic management, and strengthened safety, lighting, and signage. Accessibility is prioritised through new parking spaces, facility upgrades, and an accessibility study. Internal processes are optimised by revising operational practices, enhancing staffing, and strengthening customer communication through regular meetings to collect feedback and promptly address issues. [S4: S4-4 31c, S4: S4-4 32b, MDR-T_80 d, e]

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To achieve the above, PPA S.A. is implementing an investment plan focused on strengthening operational capacity and enhancing health, safety and security conditions for customers and end users. In this context, the Company has planned the following key investments. [S4:S4-4 37]:
* Construon of a new cruise passenger terminal, with a budgeted cost of 55 m€. [MDR-A_69 a, MDR-T_80 i]
* Construon of two car-park buildings in the G2 area, with a budgeted cost of 27 m€. [MDR- A_69 a, MDR-T_80 i]

The financing and allocation of resources for these projects ensure the timely implementation of actions and the achievement of the Company’s objectives, as well as the continuous monitoring of their progress. [MDR-A_69 b, c]

In this context, the following table presents the corporate targets set in 2024, together with the performance achieved in 2025 [S4:S4-4 30]. When setting targets, the Company takes into account comments, recorded incidents and complaints. Furthermore, stakeholder surveys enable customers to provide recommendations and feedback regarding topics material to the Company and its management approaches. Progress toward achieving these targets is analytically presented within the annual sustainability reports, ensuring transparency. [MDR- T_80 j] The targets included in the table below are not quantified [MDR-T_80 b, MDR-M_75, MDR- M 76, MDR-M 77 (c)].

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Table of Targets and Actions

Passenger Safety IRO Actions [MDR-A_68 a] Target [MDR-T_80b] Year [MDR- A_68 c / MDR- T_80 e] Scope of Coverage [MDR-A 68b / MDR-T 80c] KPIs [MDR-A_68 e/ MDR-T_80 b/ MDR-M_75] Progress by 2025 [MDR-A_68 e / MDR-T_80 j]
S4 Passenger Safety & Protection (Company- specific topic) Conducng an accessibility assessment for persons with reduced mobility. Developing an acon plan based on the results. 2027 downstream Improving accessibility for groups with special needs throughout the port Percentage of end users with special needs In progress / 10% of the target completed
Reconstrucon of concrete stairs Ongoing Enhancement of safety N/A 100% achieved
Installaon of steel stairs and LED solar lighng with poles on the walls of the central port quay 2025 downstream N/A 100% achieved
Trac management at cruise terminals to reduce congeson and accident risk 2027 downstream Proacve approach for maintaining the health, safety, and protecon of all visitors to the Port of Piraeus N/A In progress / 10% of the target completed
Eco-friendly buses Passenger transport within the port, with zero emissions 2028 downstream Reducon of carbon footprint In progress / 5% of the target completed
Interacon with end users Collaboraons with direct customers to collect feedback from end users 2028 downstream Number of parcipang companies No progress recorded
Updang the website to provide informaon (passenger rights, complaint submission form, useful phone numbers) to end users for ships, similar to the informaon provided to cruise ship passengers. 2025 downstream List of feedback categories from end users 100% achieved
Human rights assessment by the UN Integraon of human rights risk into the risk register 2027 downstream Number of human rights violaons 100% achieved
downstream Number of complaints related to human rights
downstream Number of organizaonal funcons exposed to human rights violaon risk
Review and update of policies based on human rights assessment and risk integraon 2027 downstream - 100% achieved
Parcipaon in Global Compact Greece 2027 downstream - No progress recorded

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At the indicator level, no specific methodologies or assumptions have been used [MDR-M_77 (a)] and no external body has been involved to validate the metrics used [MDR-M 77 (b)]. The budget of the above actions is estimated at €5,255,000, of which €5,160,000 is CAPEX and €95,000 is OPEX. For the reporting period, €117,000 has been implemented, while the remainder of the actions will be completed in the future based on a schedule. [MDR-A_69]

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ESRS-G1 Business Conduct

ESRS G1-1 – Business conduct and corporate mindset policies, ESRS G1-2 – Management of supplier relationships, ESRS G1-3 – Prevention and detection of corruption and bribery, ESRS G1-4 – Incidents of corruption or bribery

G1-1 Policies related to business conduct and corporate culture

PPA S.A. maintains a comprehensive framework of business conduct policies that establish clear expectations for ethical behavior, integrity, and transparency across all levels of the Company. These policies include the Code of Conduct, the Anti-Corruption and Anti-Bribery Policy, the ESG and Sustainability Policy, and the Whistleblowing Policy and Procedure. Together, they form the foundation of the Company’s corporate culture and ensure responsible behavior consistent with legal obligations, international standards, and stakeholder expectations [G1-1_7],[G1-1_9]. Following the results of Double Materiality Assessment conducted for the year 2025, PPA S.A. identified updated material impacts, risks and opportunities (IROs) related to the topic of business conduct.As required by ESRS 2 IRO-1, the identification process considered all relevant criteria, including the nature of the Company’s activities, operational locations, sector characteristics and the structure of underlying transactions [G1.IRO-1 6] The Double Materiality Assessment identified twelve (12) material IROs: Actual Positive Impact Stakeholder Trust Risks in relation to business conduct matters Cybersecurity Threats Geopolitical Externalities & Domestic Political Environment (Company Specific) Supplier / Contractor Selection Risk Opportunities in relation to business conduct matters Operational Procedures and Controls Technology and Digital Transformation Access to Green Investment Competitive Advantage and Regional Leadership Robust Governance and Risk Management

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Each IRO is further discussed under the relevant subsection of this ESRS topical disclosure requirement through the lens of business conduct and corporate culture. The relevant description and strategic discussion of all PPA S.A.’s IRO is available in ESRS 2 segment of this Report.

Policies related to business conduct and corporate culture [ESRS2.GOV-1_22b, G1-1_7, G1-1_9, G1-1_10a, G1-3_18c]

Internal Operation Regulation

The Internal Operating Regulation of the company outlines the Company’s organizational structure, governance bodies, committees, internal control mechanisms, and key procedures required by laws 4706/2020, 4548/2018, 3016/2002 and the EU Regulation 596/2014. It sets objectives related to effective corporate governance, regulatory compliance, risk management, prevention of conflicts of interest, transparency in related-party transactions, proper handling of confidential information, and structured procedures for hiring, evaluating, and training senior executives [G1.MDR-P_65a]. It applies to all Company activities, departments and committees without stated exclusions, and is monitored through the BoD, the CEO, the Audit Committee, the Internal Audit Department, the Risk Management Unit, the Regulatory Compliance Unit and other standing committees, each reporting as required. [G1.MDR-P_65b,c]. The Regulation references third-party standards including MAR, IAS 24 and IAS 27, HCMC decisions, international internal audit standards and environmental terms issued by national authorities. [G1.MDR-P_65d]. Stakeholder interests are considered primarily through requirements relating to shareholders, regulatory authorities, investor relations, whistleblowing and environmental compliance, although no consultation process is explicitly described. [G1.MDR-P_65e]. The Regulation is made available internally and, where required, through the Company’s official website, supporting its dissemination to all responsible and affected stakeholders [G1.MDR-P_65f].

BoD Regulation

The BoD Regulation of the company defines the responsibilities, composition, operation and internal governance of the Board, in accordance with Laws 4548/2018, 4706/2020, 4449/2017 and other applicable provisions. It sets the roles of executive and non-executive members, including independent members, and outlines obligations relating to strategy-setting, financial information and sustainability reporting internal control, risk management, compliance, succession planning, and supervision of corporate functions. [G1.MDR-P_65a] The Regulation applies to all Board members and Board Committees without exclusions. It establishes the structure, mandate and obligations of the Audit Committee, the Remuneration Committee and the Nomination Committee, as explicitly defined in Article 16 of the Regulation. [G1.MDR-P_65b,c] References to third-party standards and bodies appear explicitly in the Regulation, including statutory audit requirements under Law 4449/2017, interactions with the Hellenic Capital Market Commission, and obligations relating to financial reporting and internal control as required by applicable legislation. [G1.MDR-P_65d]

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Stakeholder considerations are addressed exclusively through legally mandated interactions, including disclosures to shareholders, the General Assembly, the Hellenic Capital Market Commission and G.E.MI., as explicitly described in the Regulation. No consultation process with other stakeholders is provided for. [G1.MDR-P_65e] The Regulation becomes effective upon Board approval and amendments are made by Board decision, and is made available through the Company’s official website, ensuring access by all stakeholders. [G1.MDR-P_65f]

Audit Committee Regulation

The Audit Committee Regulation defines the operation of the Audit Committee as a committee of the BoD, established in accordance with laws 3016/2002, 4449/2017, 4706/2020, the relevant circulars of the Hellenic Capital Market Commission and decision 1/891/30.09.2020, setting out its role in supporting the BoD in overseeing statutory audit, financial reporting, the Internal Control System, Risk Management and Regulatory Compliance. It specifies the Committee’s objectives, including monitoring the statutory audit process, reviewing financial information procedures, assessing the adequacy and effectiveness of internal controls, ensuring the independence and performance of external auditors, supervising the Internal Audit Department, Regulatory Compliance and Risk Management functions, and submitting an Annual Activity Report to the General Assembly [G1.MDR-P_65a]. The Regulation applies across all activities of PPA S.A., with no exclusions [G1.MDR-P_65b], and grants the Committee unrestricted access to information, the ability to engage external advisors and the necessary resources to fulfil its responsibilities. Implementation responsibility lies with the Audit Committee itself, composed of at least three members of the Board of Directors, the majority independent, and chaired by an independent member with proven audit or accounting expertise, supported administratively by the Secretariat of the Board [G1.MDR-P_65c]. The Regulation explicitly references Law 3016/2002, Law 4449/2017, Law 4706/2020, Regulation (EU) 537/2014, Capital Market Commission circulars 1302/2017 and 1508/2020, and decision 1/891/30.09.2020 [G1.MDR-P_65d]. While no explicit stakeholder consultation is referenced, stakeholder interests are indirectly safeguarded through statutory compliance, internal control effectiveness and the integrity of financial reporting [G1.MDR-P_65e]. The Regulation enters into force upon approval by the Board of Directors and is made publicly available through publication on the Company’s official website [G1.MDR-P_65f].

Remuneration Committee Regulation

The Remuneration Committee Regulation sets out the role, scope, responsibilities, composition and operating procedures of the Remuneration Committee of PPA S.A., as approved by BoD decisions 31/16.07.2021 and 48/22.12.2022. The Regulation defines the Committee as an independent and objective body that assists the BoD in matters related to remuneration, including the Remuneration Policy and Remuneration Report under Articles 109–114 of Law 4548/2018, and outlines its duties such as submitting proposals on the Remuneration Policy, reviewing the annual Remuneration Report, recommending performance targets for variable remuneration, assessing stock option plans, and advising on improvements to remuneration processes [G1.MDR-P_65a]. The Regulation applies to all remuneration-related activities of the Company with no exclusions and grants the Committee full access to necessary information, as well as the ability to request external advisors through the BoD [G1.MDR-P_65b]. The Committee consists of three non-executive BoD members, the majority independent under law 3016/2002 and law 4706/2020, chaired by an independent non-executive member, and

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supported administratively by a designated Secretary, meeting at least twice per year or as required [G1.MDR-P_65c]. The Regulation refers to the applicable legal framework, namely law 4548/2018 and Law 4706/2020 [G1.MDR-P_65d]. While it does not provide for stakeholder consultation, it ensures transparency through obligations for minute-keeping, reporting to the BoD and informing shareholders at the Annual General Meeting [G1.MDR-P_65e]. The Regulation is published on the Company’s official website and may be amended only by decision of the Board of Directors [G1.MDR-P_65f].

Nomination Committee Regulation

The Nomination Committee Regulation defines the role, scope, responsibilities, composition and operating procedures of the Nomination Committee of PPA S.A., as approved by BoD decisions 29/16.07.2021 and 47/22.12.2022. The Regulation establishes the Committee as an independent and objective body that assists the BoD by ensuring lawful and effective composition, structure and operation of the BoD, by overseeing transparent nomination procedures, and by assessing the mix of knowledge, skills, experience, diversity and suitability of BoD Members. The Regulation outlines detailed responsibilities, including reviewing the Suitability Policy, preparing induction and training programmes, evaluating Board structure and effectiveness, assessing independence and conflicts of interest, maintaining a target profile matrix, monitoring diversity, reviewing succession planning for senior executives, assessing nomination processes, and recommending changes to the organizational chart [G1.MDR-P_65a].The Regulation applies fully across all nomination and suitability matters without exclusions and requires the Committee to have full access to information, to collaborate with relevant internal functions and other BoD Committees, and to request external advisors through the BoD when required [G1.MDR-P_65b].It specifies that the Committee consists of three non-executive BoD members, the majority independent under law 3016/2002 and law 4706/2020, chaired by an independent non-executive member, meeting at least twice annually or as needed, and supported by a designated Secretary keeping minutes [G1.MDR-P_65c]. The Regulation refers to the applicable legal framework, including Law 4706/2020 and Law 4548/2018 [G1.MDR-P_65d]. Transparency is ensured through minute-keeping, reporting to the BoD for Corporate Governance disclosures and compliance with internal rules [G1.MDR-P_65e]. Amendments may only be made by decision of the BoD, and the Regulation is published on the Company’s official website [G1.MDR-P_65f].

Strategy Committee Regulation

The Strategy Committee Regulation of PPA S.A. defines the role, scope, responsibilities, composition, and operating procedures, as approved by BoD 71/28.11.2025. The Regulation establishes the Committee as an independent and objective body that advises the Company's Management and BoD, in accordance with the provisions of its Regulation, on matters relating to the Company's general strategy, and specifically on strategic issues relating to sustainability, new technologies, and innovation, including the Company's digital transformation and sustainability through innovative technologies.

The Committee has a total number of members as determined from time to time by the Board of Directors. Members of the Company's BoD may be elected as members of the Committee and, by decision of the Board of Directors, the composition of the Committee may also include members of Senior Management (DCEO level). The Committee convenes at least twice a year, or more frequently as required, in order to fulfill its mission. The Regulation is available on the Company's official website and may only be amended by a decision of the BoD following a recommendation by the Committee. [G1.MDR-P_65a-f]

Diversity Policy of BoD Members

The Policy promotes diversity on the (BoD) by emphasising gender representation, professional qualifications, and skills balance, setting a minimum gender representation threshold of 33% in line with law 4706/2020, as amended by law 5178/2025, and specifically the provisions on gender balance on Boards of Directors [G1.MDR-P_65a]

  • It applies to the nomination, selection, and assessment of BoD members at PPA S.A. [G1.MDR- P_65b]
  • The Nomination Committee is responsible for monitoring compliance and proposing updates [G1.MDR-P_65c]
  • The Policy complies with Law 4706/2020, as amended by law 5178/2025, and follows international best practices for corporate governance [G1.MDR-P_65d]
  • Progress on diversity objectives is reported annually in the Annual Financial Statement, specifically in the Statement of Corporate Governance [G1.MDR-P_65e]
  • The Policy is publicly accessible and published on the Company’s official website [G1.MDR-P_65f]

Succession Planning Policy for BoD Members & Executive Officers

This Policy establishes a structured process for succession planning to ensure leadership continuity, covering the nomination, assessment, and replacement of BoD members and executive officers [G1.MDR-P_65a].

  • It applies to all BoD members and senior executive positions at PPA S.A. [G1.MDR-P_65b]
  • The Nomination Committee oversees the implementation and compliance with this Policy [G1.MDR-P_65c].
  • The Policy ensures transparency through regular assessments and reporting of leadership continuity practices [G1.MDR-P_65e].
  • The Policy is publicly accessible and published on the Company’s official website [G1.MDR-P_65f].

Suitability-Eligibility Policy of BoD Members

This Policy defines the principles and criteria for selecting, replacing, and assessing the suitability of BoD members, with a focus on ethics, diversity, and professional qualifications [G1.MDR-P_65a]

  • It applies to all BoD members at PPA S.A. [G1.MDR-P_65b], and its oversight and compliance are the responsibility of the Nomination Committee. [G1.MDR-P_65c]
  • The Policy aligns with law 4706/2020, as amended by law 5178/2025, the Hellenic Corporate Governance Code, and law 4449/2017 [G1.MDR-P_65d]
  • It is disclosed through the Annual Financial Statements in the Statement of Corporate Governance and is part of the official governance framework [G1.MDR-P_65e]
  • The Policy is publicly accessible and published on the Company’s website [G1.MDR-P_65f]

Training Policy for BoD Members and Senior Executives

[G1-1_10g] This Policy sets out the key principles, objectives and procedures governing the induction, orientation and continuous training of Board members and other Covered Persons involved in internal control, risk management, regulatory compliance and information systems, ensuring they possess the skills and competencies required to fulfil their responsibilities effectively [G1.MDR- P_65a]

  • The Policy applies to all members of the Board of Directors and designated Company Executives without exclusions, covering both newly appointed and existing members [G1.MDR- P_65b]
  • Oversight and accountability for the implementation of the Policy rest with the highest governance level, including the Board, its Committees and Senior Management [G1.MDR-P_65c]
  • The Policy is publicly available through the Company’s Internal Operation Regulation, which is available through the Company’s website [G1.MDR-P_65f]

Code of Conduct

The Code outlines the principles of integrity, transparency, anti-corruption, and fair business practices, ensuring compliance with laws and covering rules on gifts, conflicts of interest, and whistleblowing [G1.MDR-P_65a]

  • It applies to all employees, management, contractors, and business partners involved in PPA S.A.’s operations [G1.MDR-P_65b]
  • The Internal Audit Department and Regulatory Compliance Unit oversee implementation and adherence to the Code [G1.MDR-P_65c]
  • The Code aligns with Law 4706/2020 and the Hellenic Corporate Governance Code, which is adopted by the Company [G1.MDR-P_65d]
  • It is communicated through staff training, internal announcements, and disclosures available to stakeholders [G1.MDR-P_65e]
  • The Code is publicly accessible and published on the Company’s official website [G1.MDR-P_65f]

Code against Corruption and Bribery

The Code defines corruption and bribery and their various forms while outlining the Company’s expectations regarding compliance. Employees and associates must adhere to the Code’s anti-corruption and anti-bribery requirements, follow Company procedures, maintain due diligence in transaction recording, and ensure compliance with legal, confidentiality, and conflict of interest Policies [G1.MDR-P_65a]

  • The Code applies to all Company personnel, external associates, suppliers, and contractors, unless other relevant laws apply to the latter [G1.MDR-P_65b]
  • The Audit Committee first approved the Code, while the Board of Directors is responsible for its review [G1.MDR-P_65c]
  • The Code aligns with national legislation, the Treaty of the European Union on fighting corruption (EE C 195 of 25.6.1997, 0.1), the Council Framework Decision on combating corruption in the private sector (EE L 192 of 31.7.2003, 0.54), and internal regulations of PPA S.A. [G1.MDR-P_65d]
  • It is communicated to employees and external associates to ensure compliance [G1.MDR-P_65e] and is available on the Company’s intranet [G1.MDR-P_65f, G1-3_20]

Whistleblowing Policy and Procedure

The Whistleblowing Policy and Procedure establishes a structured internal reporting system for managing complaints related to violations of EU law and company policies, ensuring whistleblower protection, with a specific procedure set out in articles 11 and 12 of the Policy, and non-retaliation safeguards [G1.MDR-P_65a] [G1-1_10a] [G1-1_10c(i)[G1-1_10c(ii)]

  • It applies to all employees, members of the BoD, members of the Top Management, shareholders, clients, users, contractors, suppliers, and third parties who collaborate or provide services to the Company [G1.MDR-P_65b]
  • The Manager of the Risk Management Unit is responsible for receiving and monitoring reports/complaints (Whistleblowing responsible) and is supported by the Data Protection Officer [G1.MDR-P 65a] [G1.MDR-P_65c]
  • The Policy aligns with law 4990/2022, EU Directive 2019/1937, and the General Data Protection Regulation (GDPR) [G1.MDR-P_65d] [G1.G1-1_11]
  • It is communicated through internal channels, (either via email or via the corporate portal) to all employees, members of theBoD, members of the Top Management, shareholders, customers, users, contractors, suppliers and third parties, while training and clear instructions are provided on how to submit both named and anonymous reports [G1.MDR-P_65e] [G1-1_10c(i)][G1-3_20]
  • The Policy is publicly accessible and published on the Company’s official website [G1.MDR-P_65f]

ESG and Sustainability Policy

The ESG and Sustainability Policy guides PPA S.A. in operating responsibly, ethically and sustainably by integrating environmental stewardship, social responsibility and sound governance into its business practices. It confirms compliance with applicable regulations while addressing stakeholder expectations, mitigating climate and environmental impacts, strengthening social dialogue and upholding ethical conduct, thereby supporting long-term value creation, resilience and positive contributions to society and the environment [G1.MDR-P_65a]

The Policy outlines the Company’s sustainability principles, objectives and procedures and applies to all activities of the Port of Piraeus, binding employees, contractors, partners and third parties acting on behalf of PPA S.A.The ESG Commi ee serves as the Policy Owner, overseeing sustainability-related frameworks and compliance measures. The Policy aligns with international standards and initiatives, including the ILO, ISO 9001:2015, ISO 14001:2015, ISO 50001:2018 and ISO 14064-1:2018. Through the double materiality process, stakeholder perspectives are assessed to ensure that the Policy remains responsive to evolving needs and expectations. It further aligns with relevant third-party standards and initiatives and is publicly available on the Company’s official website.

Privacy Policy

The Privacy Policy of . (PPA S.A.) sets out the key principles governing the collection, use, protection and management of personal data, outlining the categories of data processed, the purposes and legal bases of processing, data retention periods, recipients, data subject rights and the security measures applied. The Policy applies to all personal data processed through PPA S.A.’s activities and online services without exclusions, covering website users, employees, contractors, suppliers and visitors. Responsibility for implementing the Policy rests with the highest level of governance through the Data Protection Officer and the Committee for supervising and ensuring compliance with the General Data Protection Regulation, which oversees and ensures compliance with it.

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The Data Protection Officer is appointed as Chair of the Committee and oversees compliance with the GDPR and applicable national legislation. The Policy is aligned with the GDPR, national port-related legislation, the guidelines of the Hellenic Data Protection Authority and recognized international best practices in data protection. Stakeholder interests, including the rights, expectations and needs of data subjects, are considered in defining the Policy’s provisions on transparency, lawful processing, security and the exercise of rights. The Policy is publicly available on the Company’s official website. For more information, data are available in Section ESRS2.GOV-1.

PPA S.A. maintains a comprehensive and formally approved framework of business conduct and ethics policies that articulate clear expectations for ethical behavior, integrity and transparency across the organization, forming the basis of a mature corporate culture that is aligned with national legislation, EU requirements and sectoral governance standards. This framework comprises among others, the Code of Conduct, the Code Against Corruption and Bribery, the Conflict-of-Interest Policy, the Whistleblowing Policy and Procedure, the Internal Operating Regulation, the General Staff Regulation, and the ESG and Sustainability Policy. These instruments apply to Board Members, executives, employees, external collaborators, suppliers and contractors, ensuring consistent behavioral standards and supporting the identification, assessment and management of material Impacts, Risks and Opportunities relating to business conduct matters.

Corporate culture is developed and promoted through formalized mechanisms embedded in the Company’s governance model, including mandatory induction programmes, continuous training, leadership behavior, transparent internal communication and the operation of structured reporting and investigation channels. Culture is also shaped through systematic supervision by Internal Audit, Regulatory Compliance, Risk Management and the executive leadership, each receiving relevant reporting as defined in the Internal Operating Regulation and the BoD’s Rules of Procedure, creating a transparent and well-governed environment for the oversight of business conduct matters.

Mechanisms for identifying, reporting and investigating concerns about unlawful behavior or behavior inconsistent with internal rules are explicitly defined in the Whistleblowing Policy and Procedure, which sets out internal confidential reporting channels accessible to all employees and external stakeholders. Reports are received by designated and trained employees, handled independently and objectively, and investigated in accordance with predefined procedures ensuring integrity, confidentiality and timely follow-up. These mechanisms enable early identification of emerging concerns across the Company’s operations, supporting the mitigation of material risks, including unethical practices, conflicts of interest and failures to comply with applicable regulations [G1-1_10a,G1-1_10c,G1-1_10e,G1-3_18a].

PPA S.A. has in place a Code Against Corruption and Bribery, approved by the BoD, which prohibits any act of bribery, undue influence or illicit advantage in commercial dealings.

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Although the Code does not refer explicitly to the United Nations Convention Against Corruption, it incorporates equivalent principles, including definitions, zero-tolerance provisions, expected behaviors, due-diligence obligations and disciplinary consequences. It is therefore fully operational and no timetable for further implementation is required [G1-1_10b,G1-3_18a]. Hence, the Company has established safeguards for whistleblowers, including protection against retaliation, confidential processing of reports, secure information handling and the right to report concerns anonymously, where permitted by law. PPA S.A. is subject to the national legal framework transposing Directive (EU) 2019/1937 on the protection of whistleblowers and has already implemented the required internal channels and procedures, and therefore no additional policy development or implementation plan is required [G1-1_10c,G1-1_11,G1-1_10d].

Apart from the whistleblowing procedures, the Company investigates business conduct incidents promptly, independently and objectively, with clear separation of responsibilities between the investigating functions and the operational departments, supported by Internal Audit, Regulatory Compliance and Legal, ensuring that all substantiated incidents are addressed in accordance with the Company’s disciplinary provisions and applicable laws [G1-1_10e,G1-3_18a,G1-3_18b].

Business conduct training is embedded across the organisation. During 2025, 1,140 employee participations were recorded across 13 training programmes covering ethics, anti-corruption, anti-bribery, conflicts of interest, regulatory compliance, cybersecurity, ESG matters, dangerous goods handling, internal audit principles and customer service for vulnerable groups. These programmes reinforce employees’ capacity to identify ethical risks, comply with internal rules, respond appropriately to emerging compliance challenges and uphold the Company’s culture of integrity. At the same time, training on business ethics is conducted in accordance with the established Education Plan, which will continue into 2026. Some training programmes are designed for all employees, while others are tailored to specific departments and roles. Furthermore, all employees are provided with training on ethics issues during onboarding and on an ongoing basis in accordance with the annual Education Plan [G1-1_10g,G1-3_AR7,G1-1_9].

While the Company has not yet formally designated any operational units as “high-risk functions” under its internal framework, it acknowledges the need to establish formal categorisation and targeted controls for high-risk functions and plans to further develop these measures within the context of its ongoing compliance enhancement activities [G1-1_10h,G1-3_19]. It is noted that due to the nature of PPA S.A.’s activities, it does not involve operations relating to animal welfare and therefore no such Policy is required or applicable [G1-1_10f].

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Material Impact Risks and Opportunities

Stakeholder Trust

The Double Materiality assessment identified Stakeholder Trust as a material positive impact for PPA S.A., driven by the maturity of its governance architecture and the systematic application of its business conduct framework. The Company’s integrated system of Codes, policies, internal regulations and control mechanisms fosters responsible behavior, regulatory compliance and organizational integrity, which together strengthen stakeholder confidence in the Company’s operations. This positive impact is further reinforced by a series of external recognitions in 2025. Specifically, PPA S.A.
* was named a “Growth Pioneer” at the 2025 Growth Awards organized by Eurobank and Grant Thornton, recognized as one of the 20 most dynamic companies in Greece, and received an award in the “Employees Involvement” category at the Health & Safety Awards for its initiative “A Strategic Health & Safety Training Program with universal appeal,”
* received the “Sector Leader – Port Authorities” award from the Direction Business Network for its contribution to the Greek economy based on its financial performance.
* it was recognized by the QualityNet Foundation as one of “The Most Sustainable Companies in Greece 2025” for its performance across the three ESG pillars, as well as with the Bravo Governance Award 2025 for practices related to co-funded European Research and Development projects.

In 2025, the Company also received three awards at the 2025 Compliance Awards, winning two gold awards and one bronze award for its compliance practices, while it was honored with a Gold Award at the 2025 Greek Accounting and Finance Awards in the “Top Financial Strategy Initiative” category.Furthermore, it received the True Leader Award 2024 from ICAP CRIF and the Leading ESG Company Award at the Diamonds of the Greek Economy Awards 2025, entering the DIAMONDS ELITE category for the first time. These distinctions reinforce the recognition of PPA S.A. by independent bodies for its performance in governance, financial strategy, sustainability, and compliance.

Risks

The Double Materiality assessment identified three risks related to business conduct.

The first relates to potential Cybersecurity Threats given the increasing digitalization of port operations and interconnected IT systems. Cyber incidents could disrupt operational continuity, compromise sensitive data or impair service delivery. The Company mitigates this risk by embedding cybersecurity safeguards into its digital transformation initiatives, including Terminal Operating System upgrades, EDI platforms and automation pilots, and by providing staff training on cybersecurity as part of the 2025 curriculum.

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The second risk, which is Company-specific, is Geopolitical Externalities and the Domestic Political Environment. Political or regulatory developments may affect trade flows, investment confidence or operational conditions. The Company mitigates this exposure by maintaining strict neutrality, reinforced by the explicit prohibition of political contributions in the Code of Conduct and by full compliance with Presidential Decree 15/2022, which prohibits all political donations by legal entities. This legal alignment reduces exposure to geopolitical sensitivities and supports operational stability.

The third and final risk relates to Supplier / Contractor Selection. This risk persists despite the implementation of high-level, optimized pre-qualification processes, technical specifications, and standards during the procurement and tendering stages. Potential weaknesses in the evaluation, monitoring, or compliance of partners could lead to regulatory breaches, contractual failures, or ethical issues, with potential impacts on the Company’s reputation and credibility. Nevertheless, this risk is mitigated through enhanced due diligence requirements, the incorporation of ESG criteria and anti-bribery clauses in contracts, the provision of data protection guarantees, as well as enhanced oversight, as further detailed in Section G1-2 “Management of Relationships with Suppliers”.

Opportunities

Following the conclusion of the Dual Materiality Assessment, a number of additional opportunities were identified that are directly linked to the maturity of the Company's governance.

Strengthening Operational Procedures and Controls was recognised as a material opportunity, as enhanced standardization and automation can improve efficiency, reliability and transparency. The Company’s governance architecture provides a stable foundation for scaling such procedural improvements.

Technology and Digital Transformation constitute another material opportunity. The combination of digital tools, real-time systems and automation enhances operational resilience and transparency. Strong conduct rules, data governance and cyber-controls ensure that digitalization advances are embedded responsibly and support both efficiency and regulatory compliance.

An additional material opportunity relates to Access to Green Financing. The Company’s sustainability performance and governance maturity strengthen its eligibility for EU funding programmes, innovation grants and sustainability-linked financial instruments. Participation in national and international initiatives, as well as repeated external recognition in the field of sustainability, further strengthens the Company’s position in terms of its access to green and sustainable financing.

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Moreover, Competitive Advantage and Regional Leadership were also identified as material opportunities. The alignment of strong governance, operational excellence and sustainability commitments positions PPA S.A. as a leading port in the Eastern Mediterranean. Key infrastructure investments, including the cruise terminal expansion, car terminal upgrades, ship repair zone revitalization and environmentally aligned dredging works, further reinforce this strategic positioning by integrating circular economy elements and environmental stewardship into core operations.

Robust Governance and Risk Management represent a strategic opportunity for the Company, as they ensure consistent and effective oversight, evidence-based decision-making, and a substantial reduction in exposure to corruption or regulatory non-compliance. The existence of a clear regulatory framework, defined accountability mechanisms, and robust internal controls strengthens the prevention of financial failures, regulatory violations, and reputational risks. At the same time, a comprehensive and dynamic risk management system enables the timely identification and mitigation of threats. This reduces the likelihood of operational disruptions or strategic deviations, enhancing the Company's long-term resilience and competitiveness.

G1-2 Management of Relationships with Suppliers

PPA S.A. manages its supplier relationships through a structured and fully documented procurement governance framework, as set out in the new Internal Procurement Procedures Manual, which applies to all suppliers registered in the Company’s Supplier Register. The framework ensures transparent, and competitive legal procurement agreements, incorporating detailed procedures for supplier selection, contract execution, monitoring, evaluation, classification and potential exclusion. Supplier assessments are based on multi-dimensional criteria, including contractual performance, quality, safety, innovation, governance, risk and sustainability. ESG-specific criteria, such as anti-corruption compliance, environmental certifications (including ISO 14001), carbon-reduction initiatives, waste-management practices and operational risk-management capabilities, form an integral part of this process and will also be included in the Supplier Code of Conduct, which is currently being developed during the reporting year [G1-2_15a,G1-2_15b]

Contracts and Sub-Concessions Regulation and Internal Procurement Procedures Manual

The Contracts and Sub-Concessions Regulation and the Internal Procurement Procedures Manual define PPA S.A.’s procurement and contracting framework as required by Articles 8 and 9 paragraph 1 and 12.2(a) of Law 4404/2016, setting the principles of transparency, equal treatment, impartiality and non-discrimination in all procurement activities [G1.MDR-P_65a,G1.MDR-P_65d] They establish the scope of contracts (construction works, operational equipment, services, supplies, studies, outsourcing, minor sub-concessions) and identify exclusions such as emergencies, specific direct awards and specialised expert services [ESRS2.MDR-P_65b]

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The Manual puts these rules into operation through structured procurement procedures (open bidding, selected bidding, non-bidding), centralised procurement, roles and responsibilities of Procurement, Controlling, User Departments and Internal Audit, and detailed steps for initiation, evaluation, negotiation and approval [ESRS2.MDR-P_65c] It further specifies the operation of the Contractors Register, supplier qualification and performance evaluation requirements, ensuring compliance with the Concession Agreement and applicable legislation. The framework provides clear processes, documentation requirements and internal controls for contract award, supplier management and sub-concession administration. The Regulation is publicly accessible and published on the Company’s website to ensure transparency for all stakeholders [ESRS2.MDR-P_65f]

Suppliers’ Personal Data Protection Policy

The Suppliers’ Personal Data Protection Policy sets out the principles and procedures governing the processing of personal data of suppliers who are natural persons, as well as of employees or representatives of supplier-legal-entities. The Policy defines the categories of data collected, the purposes of processing related to contract execution, regulatory compliance and the defense of legal claims, and the lawful bases applied. It identifies key data-protection risks and describes the safeguards implemented, including technical and organisational security measures, confidentiality obligations, internal procedures, employee training, retention rules and secure destruction [G1.MDR-P_65a] The Policy applies across all procurement-related activities and includes no exclusions [ESRS2.MDR-P_65b] Responsibility for implementation rests with PPA S.A. acting as Data Controller, supported by the Data Protection Officer [ESRS2.MDR-P_65c] The Policy aligns with GDPR (Regulation 2016/679), national legislation and internal regulations. Data subjects’ rights are clearly defined, with established processes for exercising them and the option to contact the Hellenic Data Protection Authority [ESRS2.MDR-P_65d,e] The Policy is publicly accessible and published on the Company’s official website and updated on a regular basis to ensure transparency for all stakeholders [ESRS2.MDR-P_65f]

The evaluation methodology includes weighted scoring ranges (5–30 percent) across key categories and results in annual supplier classification into Grades A–D. Grade A suppliers receive priority under equal-treatment conditions; Grade B remain fully eligible; Grade C suppliers enter a corrective-action phase with temporary suspension; and Grade D suppliers are removed from the contractors register for two years.The Supplier Exclusion Registry operates under principles of fairness, accountability, proportionality and transparency, with clear procedures for documenting breaches, approving exclusion decisions, notifying suppliers and enabling reconsideration when corrective measures have been implemented [G1- 2_15a],[G1-2_15b]

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Although PPA S.A. does not maintain a stand-alone policy specifically aimed at preventing late payments to SMEs, it embeds timely-payment safeguards through its procurement processes. These include contractually defined payment terms, internal verification workflows, compliance monitoring, cross-departmental coordination between procurement, controlling and finance, and ongoing contract-performance monitoring. While not SME-targeted, these mechanisms ensure fairness and minimise undue delays for all suppliers irrespective of size [G1-2_14]

The Company also implements the Suppliers’ Personal Data Protection Policy, which governs the processing of personal data belonging to supplier-physical-persons and to employees or representatives of supplier-legal-entities. The Policy defines the categories of data collected, the purposes of processing, the lawful bases applied, retention rules, technical and organisational security measures, confidentiality requirements and data-subject rights. The Policy aligns with GDPR and national law, applies across all procurement activities and is publicly accessible for transparency. This integrated procurement system generates a positive sustainability impact by promoting ethical practices, transparency, responsible sourcing and alignment with environmental and social standards across PPA S.A.’s supply chain. ESG performance criteria, documented evaluation processes, supplier improvement mechanisms and exclusion rules incentivize suppliers to enhance compliance, quality, safety and environmental performance, thereby strengthening the sustainability profile of PPA S.A.’s upstream operations. At the same time, these measures directly mitigate the material risk associated with supply-chain mismanagement, including the potential for unethical practices, non-compliance with environmental or labour standards, reputational harm, operational delays and legal exposure. Through annual ESG-inclusive scoring, supplier classification, stringent contract-compliance monitoring, risk-based exclusion policies and structured re-evaluation processes, PPA S.A. ensures that sustainability-related risks are identified, assessed and addressed in a consistent and controlled manner. These controls help maintain stakeholder trust, safeguard the Company’s social license to operate and uphold transparency across the supply chain.

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G1-3 Prevention and Detection of Corruption and Bribery

PPA S.A. maintains a structured and continuously evolving system to prevent, detect and address corruption and bribery risks, directly supporting the mitigation of the material risk “Incidents on Ethics and Integrity” and enabling the opportunity to strengthen “Operational Procedures and Controls”. The system is anchored in the Code of Conduct, the Code Against Corruption and Bribery, the Conflict-of-Interest Policy, the Whistleblowing Policy and Procedure, and the Internal Operating Regulation, all of which define prohibited practices, set due-diligence expectations and establish clear disciplinary consequences. These policies operate preventively through mandatory conflict-of-interest declarations, segregation of duties, procurement-specific controls, and systematic monitoring by Internal Audit, Regulatory Compliance, Risk Management and the Procurement Department [G1-3_18a]

Investigations of corruption or bribery-related allegations are carried out independently of the relevant management chain, ensuring impartiality and full access to information. Whistleblowing submissions are handled by trained case-handlers, while Internal Audit maintains the authority to review ethical risks across operations, including the monitoring of gifts above EUR 100. During 2025, the relevant audit confirmed zero reportable incidents, demonstrating the effectiveness of existing controls and contributing to the early detection and containment of integrity risks. Outcomes of investigations and systemic findings are reported through the established internal-reporting framework to senior management, the Board Committees and the Board of Directors, in line with the Internal Operating Regulation and the Rules of Procedure of the Governance Bodies [G1-3_18a,b,c]

To ensure that all personnel understand the Company’s expectations, PPA S.A. disseminates its anti-corruption and anti-bribery policies through induction programmes, targeted circulars, internal platforms [G1-3_20] During the first half of 2025, employees received extensive training on ethics, anti-bribery, anti-corruption and regulatory compliance. These programmes, which recorded 1,564 participations across 38 sessions, included specialised modules on bribery prevention, conflicts of interest, dangerous goods compliance, cybersecurity, ESG governance and internal controls, reinforcing employees’ capacity to identify and escalate concerns promptly [G1-3_21a]. Although the Company has not yet formally codified its list of “functions-at-risk”, processes involving procurement, contract management, port operations, finance, and high-value commercial engagements have been recognised internally as requiring higher vigilance. PPA S.A. is progressing towards a structured mapping of high-risk functions, with the aim of linking specialised training, control testing and monitoring mechanisms to the functions most exposed to corruption and bribery risks. This enhancement supports the Company’s continuous improvement and the opportunity to strengthen operational procedures and internal controls [G1-3_21b].

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Training for the administrative, management and supervisory bodies forms part of the mandatory training framework under the Internal Operating Regulation and includes sessions on ethics, anti-bribery, conflicts of interest, regulatory obligations and oversight responsibilities [G1-3_21c]. In parallel, PPA S.A. is advancing its compliance maturity by progressively aligning its Code Against Corruption and Bribery with the principles of the UN Convention Against Corruption. While the Code already incorporates equivalent prohibitions, due-diligence elements and disciplinary measures, future revisions will explicitly reflect UN-aligned provisions, reinforcing the Company’s approach to integrity management.

The Company’s preventive controls also extend to its business counterparties. The Preliminary Cooperation Agreement requires every supplier to declare the absence of conflicts of interest, commit to anti-bribery standards and comply with PPA S.A.’s integrity framework. Prospective suppliers must also submit an Anti-Commercial Bribery Commitment Statement, and PPA S.A. verifies anti-bribery and anti-corruption declarations during pre-contractual due diligence. Failure to comply constitutes a material breach, enabling contract termination. These mechanisms strengthen third-party governance and reduce exposure to ethical breaches across the supply chain [G1-3_18a],[G1-2_15a].

In 2025, further reinforcement came through the revised Contracts & Sub-concessions Regulations – Internal Procurement Procedures Working Manual, which explicitly integrates controls for bribery and corruption prevention. Employees involved in procurement processes received targeted training on the updated requirements, ensuring consistent understanding and implementation across the Company. Overall, these mechanisms reduce the likelihood and impact of integrity-related incidents, strengthen procedural resilience, support continuous improvement and reinforce stakeholder trust.

G1-4 Incidents of Corruption or Bribery

During the reporting period, PPA S.A. recorded no convictions, no fines, and no penalties relating to violations of anti-corruption or anti-bribery legislation. Internal reviews, monitoring activities, audits and the assessment of gifts above EUR 100 reported zero breaches, and thus no additional corrective actions or sanctions were required. [G1-4_24 a].

In line with voluntary ESRS disclosures, PPA S.A. confirms that during the reporting period:
* no confirmed incidents of corruption or bribery occurred,
* no dismissals or disciplinary actions were implemented in relation to corruption or bribery,
* no contracts were terminated or not renewed due to corruption- or bribery-related violations, and

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  • no new or pending legal cases involving corruption or bribery were recorded.

These results demonstrate the effectiveness of the Company’s preventive framework in mitigating the material risk of ethical and integrity breaches and reinforce the opportunity to enhance operational procedures, internal controls and compliance assurance mechanisms. [G1-4_25 a-d]

Corporate Governance Actions and Targets

High-Level Sustainability Targets approved by the BoD under the oversight of the Chief Executive Officer

As part of its management of material impacts, risks, and opportunities related to business conduct, the Company has established objectives and monitoring mechanisms linked to relevant governance, anti-corruption, and responsible supply chain management policies.These targets primarily cover the Company’s own activities and, where necessary, the upstream value chain, [MDR-T 80(a)], [MDR-T 80(c)] The effectiveness of these actions is monitored using specific key performance indicators (KPIs), which are evaluated annually and reported to the relevant governing bodies, supporting the monitoring of performance against the set targets. At the level of indicators, no external party has been involved for the validation of the metrics used. [MDR-M 77 (b)] Regarding the targets, the base year has been set as 2024 [MDR-T 80 (d)], while the methodology applied for their determination and monitoring is based on the internal tracking of relevant performance indicators (KPIs). [MDR-T 80 (f)] Furthermore, there is no structured process for stakeholder involvement in their definition [MDR-T 80 (h)] and no scientific evidence has been used for their creation [MDR-T 80 (g)] Finally, no changes have been made to targets, methodologies, or assumptions [MDR-T 80 (i)], as the related processes are at an early stage of development and maturation. The targets included in the table below are not quantified. [MDR-T_80 b] [MDR-M_75] At the level of indicators, no specific methodologies or assumptions have been used [MDR- M_77 (a)], and no external party has been involved in the validation of the metrics used [MDR- M 77 (b)]

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Business Conduct IRO Actions [MDR-A 68a]

Target [MDR-T- 80b] Year [MDR-A 68c/ MDR-T 80e] [MDR-A 68b/ MDR- T 80c] KPIs MDR-A 68e/ MDR-T 80b/ MDR – M- 75 Progress in 2025 MDR- A 68e/ MDR-T- 80j
G1 Improve Governance Structure
Strengthening of internal frameworks 2028 Expanding cybersecurity monitoring capabilities Own operations - No progress was made in 2025
Linking management remuneration to ESG criteria 2027 Own operations - No progress was made in 2025
BoD ESG seminars 2025 Own operations - 100% achieved in 2025
Corruption & Bribery
Identifying functions at risk of corruption and bribery 2026 Number of functions and business processes at risk Own operations No progress was made
Training of employees holding critical positions related to issues of corruption and bribery [G1-4_24 b] Ongoing annual monitoring Zero bribery and corruption incidents Own operations Number of employees trained per year 100% achieved in 2025
Handling of all whistleblowing incidents according to Whistleblowing Policy Ongoing annual monitoring Number of training seminars completed Own operations No progress was made in 2025 - In progress
Management of all incidents No progress was made in 2025 - In progress
Responsible Supply Chain
Evaluation of key suppliers with ESG criteria 2028 Setting specific criteria upstream supply chain Number of suppliers evaluated In progress in 2025

The budget for the above actions is estimated at €107,500, corresponding to OPEX. For the reporting period, €7,500 have been implemented, while the remaining actions will be completed in the future according to the schedule. [MDR-A_69]

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G1-5 Political Influence and Lobbying Activities [Non-Material]

PPA S.A. does not engage in political influence or lobbying activities and is legally prohibited from providing any financial or in-kind political contributions. In accordance with Presidential Decree 15/2022 (Greek Government Gazette Issue A 39/01.03.2022), Article 5 paragraph 6, all forms of financing or provision of benefits to political parties or coalitions are strictly prohibited for legal entities, including PPA S.A. This prohibition is embedded in the Company’s internal regulations and governance framework, and no exemptions or deviations are permitted [G1-5_29b].

Consistent with the outcome of the 2025 Double Materiality Assessment, political influence and lobbying were assessed as non-material for the reporting period. While non-material in 2025, the topic is monitored due to its connection with the identified Geopolitical Externalities Maintaining a strict prohibition on political contributions and avoiding lobbying activities functions as a risk-mitigation measure, ensuring independence from political influence, preventing exposure to political sensitivities, and safeguarding the Company’s neutrality in a highly regulated sector. This approach supports regulatory compliance, preserves stakeholder trust and reduces exposure to governance or reputational risks arising from external geopolitical or domestic political developments.

The Company does not engage in political lobbying, advocacy, or political influence, and its internal and external obligations strictly prohibit political contributions. PPA S.A. is legally prohibited from providing any financial or in-kind political contributions. In accordance with Presidential Decree 15/2022 (Greek Government Gazette Issue A 39/01.03.2022), Article 5 paragraph 6, legal entities—including PPA S.A.—are forbidden from financing or providing any benefit to political parties or coalitions. This restriction is fully embedded in the Company’s governance framework, without exceptions or discretionary application [G1-5_29b]. The Code of Conduct further formalizes this prohibition. Article 12 explicitly states that while the Company supports activities related to education, science, culture, corporate social responsibility, sports and environmental protection, The Code also prohibits bribery and the use of donations to gain commercial advantage, as well as donations to political figures or elected officials, and does not provide sponsorships beyond what is legally permitted, ensuring full alignment with the Company’s integrity framework and the Code Against Corruption and Bribery. Maintaining a strict prohibition on political contributions, combined with the absence of lobbying activities, serves as a risk-mitigation measure. It supports operational neutrality, prevents exposure to political sensitivities, and safeguards the Company’s reputation and compliance posture in a highly regulated sector.

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G1-6 Payment Practices [Non-Material]

Based on the results of the 2025 Double Materiality Assessment, payment practices were assessed as non-material for the reporting period. PPA S.A. maintains consistently timely settlement of obligations, with very few disputes or delays, and cooperates with a relatively limited number of SMEs, which reduces exposure to risks related to late payments. Although the topic is not material for 2025, the Company remains committed to legal, transparent and responsible payment practices as part of its broader supply chain governance. Other topics were determined to hold higher material significance for the Company and its stakeholders at this stage. Nonetheless, payment practices may become material in the future should operating conditions, stakeholder expectations or the structure of the value chain evolve. Further information on the materiality assessment methodology and results is provided in the ESRS 2 section of this Report.

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Annex 1: Mandatory disclosures of the European Sustainability Reporting Standards (ESRS) aligned with other EU legislation

Disclosure requirement and related data point SFDR Regulation Reference (1) Pillar 3 reference (2) Benchmark regulation reference (3) EU Climate Law reference (4) Material Section
ESRS 2 GOV-1 Gender diversity on the board, paragraph 21, point (d) Indicator No. 13, Table 1 of Annex Ι Commission Delegated Regulation (EU) 2020/1816(5), Annex (II) YES Governance Structure and Sustainability Oversight
ESRS 2 GOV-1 Proportion of board members who are independent Commission Delegated Regulation (EU) 2020/1816, Annex II YES Governance Structure and Sustainability Oversight
ESRS 2 GOV-4 Statement on due diligence-paragraph 30 Indicator No. 10, Table 3 of Annex I YES Statement on Due Diligence
ESRS 2 SBM-1 Involvement activities related to the fossil fuel sector, paragraph 40, point (d), sub-point (i) Indicator No. 4, Table 1 of Annex I Article 449a of Delegated Regulation (EU) No 575/2013 Commission Implementing Regulation (EU) 2022/2453: Table 1: Qualitative Information on environmental risk Table 2: Qualitative information related to social risk Commission Delegated Regulation (ΕU) 2020/1816, Annex (II) NO
ESRS 2 SBM-1 Involvement in activities related to the production of chemical products paragraph 40, point (d), sub-point (ii) Indicator No. 9, Table 2 of Annex I Commission Delegated Regulation (ΕU) 2020/1816, Annex (II) NO
ESRS 2 SBM-1 Involvement in activities related to controversial weapons, paragraph 40 point (d), sub-point (iii) Indicator No.

Page 343 από 43714, Table 1 of Annex I Commission Delegated Regulation (EU) 2020/1818(7), Article 12, paragraph 1, Commission Delegated Regulation (EU) 2020/1816, Annex (II) – NO ESRS 2 SBM-1 Involvement in activities related to cultivation and production of tobacco products paragraph 40 point (d), sub-point (iv) – – Commission Delegated Regulation (EU) 2020/1818, Article 12, paragraph 1, Commission Delegated Regulation (EU) 2020/1816, Annex (II) – NO

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ESRS E1-1 Transition plan for climate neutrality by 2050 paragraph 14 – – – Regulation (EU) 2021/1119, Article 2, paragraph 1 NO ESRS E1-1 Companies excluded from Paris-aligned benchmarks, paragraph 16, point (g) – Article 449a of Delegated Regulation (EU) No 575/2013 – Commission Implementing Regulation (EU) 2022/2453: Template 1: Banking book — Transition risk from climate change: Credit quality of exposures by sector, emissions and remaining maturity Commission Delegated Regulation (EU) 2020/1818 (Article 12, paragraph 1, point d) up to (g)and Article 12, paragraph 2 – NO ESRS E1-4 GHG emissions reduction targets paragraph 34 Indicator No. 4, Table 2 of Annex I Article 449a of Delegated Regulation (EU) No 575/2013 – Commission Implementing Regulation (EU) 2022/2453Template 3: Banking book – Transition risk from climate change – Alignment Measurement Indicators Commission Delegated Regulation (EU) 2020/1818, Article 6 – YES Climate and Energy-related Targets

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ESRS E1-5 Energy consumption from fossil sources broken down by source (high climate impact sectors only), paragraph 38 Indicator No. 5, Table 1 and Table 2 of Annex I – – – YES Energy Efficiency and Carbon Footprint ESRS E1-5 Energy consumption and mix, paragraph 37 Indicator No. 5, Table 1 of Annex Ι – – – YES Energy Efficiency and Carbon Footprint ESRS E1-5 Energy intensity associated with activities in high climate impact sectors paragraphs 40 to 43 Indicator No. 6, table1 of Annex Ι – – – YES Energy Efficiency and Carbon Footprint ESRS E1-6 Scope 1, 2, 3 gross emissions and total emissions (GHG), paragraph 44 Indicator No. 1 and 2, Table 1 of Annex I Article 449a of Delegated Regulation (EU) No 575/2013 – Commission Implementing Regulation (EU) 2022/2453: Template 1: Banking book — Transition risk from climate change: Credit quality of exposures by sector, emissions and remaining maturity Commission Delegated Regulation (EU) 2020/1818, Article 5 paragraph 1, Article 6 and Article 8 paragraph 1 – YES Energy Efficiency and Carbon Footprint

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ESRS E1-6 Gross GHG emissions, paragraph 53 to 55 Indicator No. 3, Table 1 of Annex I Article 449a of Delegated Regulation (EU) No 575/2013 – Commission Implementing Regulation (EU) 2022/2453 of the Commission, Template 3: Banking Portfolio – Transition Risk due to Climate Change: Alignment Measurement Indicators Commission Delegated Regulation (EU) 2020/1818, Article 8 paragraph 1 – YES Energy Efficiency and Carbon Footprint ESRS E1-7 GHG removals and carbon credits, paragraph 56 – – – Regulation (EU) 2021/1119, Article 2, paragraph 1 NO ESRS E1-9 Exposure of the reference portfolio to material climate-related risks, paragraph 66 – – Commission Delegated Regulation (EU) 2020/1818, Annex II & Commission Delegated Regulation (EU) 2020/1816, Annex II – NO ESRS E1-9 Article 449a of Delegated Regulation (EU) No 575/2013 – – NO

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Analysis of financial amounts by type and timing of material risk, paragraph 66, point (a) ESRS E1-9 Location of significant material assets exposed to significant material risk, paragraph 66, point (c) Commission Implementing Regulation (EU) 2022/2453, paragraphs 46 to 47 – Template 5: Banking book – Material climate change risk: Exposures subject to material risk. ESRS E1-9 Analysis of the carrying amount of its real estate by energy performance class, paragraph 67, point (c). Article 449a of Delegated Regulation (EU) No 575/2013 – Commission Implementing Regulation (EU) 2022/2453, paragraph 34: Template 2: Banking book — Transition risk from climate change: Loans secured by real estate — Energy performance of the collateral Loans secured by real estate — Energy performance of the collateral – NO ESRS E1-9 – – Commission Delegated Regulation (EU) 2020/1818 – NO

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Degree of exposure of the portfolio to climate-related opportunities paragraph 69 Regulation (EU) 2020/1818, Annex II ESRS E2-4 Quantity of each pollutant listed in Annex II of the EU PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water, and soil, paragraph 28 Indicator No. 8 Table 1 of Annex I, Indicator No. 2 Table 2 of Annex I, Indicator No. 1 Table 2 of Annex I, Indicator No. 3 Table 2 of Annex I – – – NO ESRS E3-1 Water and marine resources, paragraph 9 Indicator No. 7, Table 2 of Annex Ι – – – NO ESRS E3-1 Specific policy, paragraph 13 Indicator No. 8, Table 2 of Annex Ι – – – NO

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ESRS E3-1 Sustainable oceans and seas, paragraph 14 Indicator No. 12, Table 2 of Annex Ι – – – NO ESRS E3-4 Total water recovered, recycled and/or reused, paragraph 28, point (c) Indicator No. 6.2, Table 2 of Annex Ι – – – NO ESRS E3-4 Total water consumption in m³ per net revenue from own activities, paragraph 29 Indicator No. 6.1, Table 2 of Annex Ι – – – YES Water Management ESRS 2 – IRO 1 – E4, paragraph 16, point (a) sub-point (i) Indicator No. 7, Table 1 of Annex Ι – – – YES Biodiversity ESRS 2 – IRO 1 – E4, paragraph 16, point (b) Indicator No. 10, Table 2 of Annex Ι – – – NO ESRS 2 – IRO 1 – E4, paragraph 16, point (c) Indicator No. 1, Table 2 of Annex Ι – – – NO

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ESRS E4-2 Sustainable land/agriculture use practices or policies, paragraph 24, point (b) Indicator No. 11, Table 2 of Annex Ι – – – NO ESRS E4-2 Sustainable practices or policies for the oceans/ seas, paragraph 24, point (c) Indicator No. 12, Table 2 of Annex Ι – – – NO ESRS E4-2 Policies addressing deforestation, paragraph 24, point (d) Indicator No. 15, Table 2 of Annex Ι – – – NO ESRS E3-1 Water and marine resources, paragraph 9 Indicator No. 7, Table 2 of Annex Ι – – – NO ESRS E3-1 Specific policy, paragraph 13 Indicator No. 8, Table 2 of Annex Ι – – – NO

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ESRS E3-1 Sustainable oceans and seas, paragraph 14 Indicator No. 12, Table 2 of Annex Ι – – – NO ESRS E3-4 Total water, recycled, and reused, paragraph 28, point (c) Indicator No. 6.2, Table 2 of Annex Ι – – – NO ESRS E3-4 Total water consumption in m³ per net revenue from own activities, paragraph 29 Indicator No. 6.1, Table 2 of Annex Ι – – – YES Water Management ESRS 2 – IRO 1 – E4, paragraph 16, point (a) sub-point (i) Indicator No. 7, Table 1 of Annex Ι – – – YES Biodiversity ESRS 2 – IRO 1 – E4, paragraph 16, point (b) Indicator No. 8, Table 2 of Annex Ι – – – NO ESRS 2 – IRO 1 – E4, paragraph 16, point (c) Indicator No. 1, Table 2 of Annex Ι – – – NO

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ESRS E4-2 Sustainable land use/agriculture practices or policies, paragraph 24, point (b) Indicator No. 11, Table 2 of Annex Ι – – – NO ESRS E4-2 Sustainable practices or policies for the oceans/seas, paragraph 24, point (c) Indicator No. 12, Table 2 of Annex Ι – – – NO ESRS E4-2 Policies addressing deforestation, paragraph 24, point (d) Indicator No. 15, Table 2 of Annex Ι – – – NO ESRS E5-5 Non-recycled waste, paragraph 37, point (d) Indicator No. 13, Table 2 of Annex Ι – – – YES Waste Management in the Port Area ESRS E5-5 Hazardous waste and radioactive waste, paragraph 39 Indicator No. 9, Table 1 of Annex Ι – – – YES Waste Management in the Port Area

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ESRS 2 – SBM-3 – S1 Risk of forced labor incidents, paragraph 14, point (f) Indicator No. 13, Table 3 of Annex Ι – – – NO ESRS 2 – SBM-3 – S1 Risk of child labor incidents, paragraph 14, point (g) Indicator No. 12, Table 3 of Annex Ι – – – NO ESRS S1-1 Commitments on human rights policy, paragraph 20 Indicator No. 9, Table 3 and Indicator No.11, Table 1 of Annex Ι – – – YES Policies related to the Company’s workforce ESRS S1-1 Due diligence policies regarding issues addressed by the Fundamental Conventions of the International Labour Organization 1 to 8, paragraph 21 – – Commission Delegated Regulation (EU) 2020/1816, Annex ΙΙ – YES Equal Opportunities ESRS S1-1 Processes and measures to prevent human trafficking, paragraph 22 Indicator No. 11, Table 3of Annex Ι – – – NO ESRS S1-1 Workplace accident prevention policy or Indicator No. 1, Table 3 of Annex Ι – – – YES Occupational Health and Safety

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management system, paragraph 23 ESRS S1-3 Complaint / grievance mechanisms, paragraph 32 point (c) Indicator No. 5, Table 3 of Annex Ι – – – YES Procedures for addressing negative impacts and mechanisms for the Company’s workforce to raise concerns

ESRS S1-14 Number of fatalities and number and rate of work- related accidents, paragraph 88, points (b) and (c) Indicator No. 2, Table 3 of Annex Ι – Commission Delegated Regulation (EU) 2020/1816, Annex ΙΙ – YES Incidents Related to Employee Health and Safety

ESRS S1-14 Lost workdays due to injuries, accidents, fatalities, or illnesses, paragraph 88, point (e) Indicator No. 3, Table 3 of Annex Ι – – – YES Incidents Related to Employee Health and Safety

ESRS S1-16 Unadjusted gender pay gap, paragraph 97, point (a) (a) Indicator No. 12, Table 1 of Annex Ι – Commission Delegated Regulation (EU) 2020/1816, Annex ΙΙ – YES Equal Opportunities

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ESRS S1-16 Excessively high CEO pay ratio, paragraph 97, point (b) Indicator No. 8, Table 3 of Annex Ι – – – NO

ESRS S1-17 Incidents of discrimination, paragraph 103, point (a) Indicator No. 7, Table 3 of Annex Ι – – – YES Equal Opportunities

ESRS S1-17 Non-compliance with the UN Guiding Principles on Business and Human Rights and OECD Guidelines, paragraph 104, point (a) Indicator No. 10, Table 1 and Indicator No. 14, Table 3 of Annex Ι – Commission Delegated Regulation (EU) 2020/1816, Annex ΙΙ, Commission Delegated Regulation (EU) 2020/1818, Article 12, paragraph 1 – YES Equal Opportunities

ESRS 2 – SBM-3 – S2 Significant risk of child or forced labor in the value chain, paragraph 11, point (b) Indicators No. 12 and 13, Table 3 of Annex Ι – – – NO

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ESRS S2-1 Commitments on human rights policy, paragraph 17 Indicator No. 9, Table 3 of Annex Ι and Indicator No. 11, Table 1 of Annex Ι – – – NO

ESRS S2-1 Policies related to the labor value chain, paragraph 18 Indicators No. 11 and 4, Table 3 of Annex I – – – NO

ESRS S2-1 Non-compliance with the UN Guiding Principles on Business and Human Rights and OECD Guidelines, paragraph 19 Indicator No. 10, Table 1 of Annex Ι – Commission Delegated Regulation (EU) 2020/1816, Annex ΙΙ, Commission Delegated Regulation (EU) 2020/1818, Article 12, paragraph 1 – NO

ESRS S2-1 Due diligence policies regarding issues covered by ILO Fundamental Conventions1 to 8, paragraph 19   – – Commission Delegated Regulation (EU) 2020/1816, Annex ΙΙ – NO

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ESRS S2-4 Human rights issues and incidents related to the upstream and downstream value chain, paragraph 36 Indicator No. 14, Table 3 of Annex Ι – – – NO

ESRS S3-1 Commitments on human rights policy, paragraph 16 Indicator No. 9, Table 3 of AnnexΙ and Indicator No. 11, Table 1 of Annex Ι – – – YES Policies of Piraeus Port Authority S.A. relating to affected communities

ESRS S3-1 Non-compliance with the UN Guiding Principles on business and Human Rights and/or OECD Guidelines, paragraph 17 Indicator No. 10, Table 1 of Annex Ι – Commission Delegated Regulation (EU) 2020/1816, Annex ΙΙ, Commission Delegated Regulation (EU) 2020/1818, Article 12, paragraph 1 – YES Policies of Piraeus Port Authority S.A. relating to affected communities

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ESRS S3-4 Human rights issues and incidents, paragraph 36 Indicator No. 14, Table 3 of Annex Ι – – – YES Procedures for engagement with affected communities in relation to impacts

ESRS S4-1 Policies regarding consumers and end-users, paragraph 16 Indicator No. 9, Table 3 and Indicator No. 11, Table 1 of Annex Ι – – YES Policies in Relation to Consumers and End Users

ESRS S4-1 Non-compliance with the UN Guiding Principles on Business and Human Rights and OECD Guidelines, paragraph 17 Indicator No. 10, Table 1 of Annex Ι – Commission Delegated Regulation (EU) 2020/1816, Annex ΙΙ, Commission Delegated Regulation (EU) 2020/1818, Article 12, paragraph 1 – YES Protection of Human Rights

ESRS S4-4 Human rights issues and incidents, paragraph 35 Indicator No. 14, Table 3 of Annex Ι – – – YES Protection of Human Rights

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ESRS G1-1 UN Convention against Corruption, paragraph 10, point (b) Indicator No. 15, Table 3 of Annex Ι – – – NO

ESRS G1-1 Whistleblower protection of public interest, paragraph 10, point (b) Indicator No. 6, Table 3 of Annex Ι – – – YES Policies related to business conduct and corporate culture

ESRS G1-4 Fines for violations of legislative provisions concerning the fight against corruption and bribery, paragraph 24, poiont a) Indicator No. 17, Table 3 of Annex Ι – Commission Delegated Regulation (EU) 2020/1816, Annex ΙΙ – YES Prevention and Detection of Corruption and Bribery

ESRS G1-4 Standards for combating corruption and bribery, paragraph 24, point (b) Indicator No. 16, Table 3 of Annex Ι – – – NO

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

THIS REPORT IS A FREE TRANSLATION FROM THE GREEK ORIGINAL

Independent practitioner’s limited assurance report on Piraeus Port Authority S.A Sustainability Statement

To the shareholders of Piraeus Port Authority S.A

We have conducted a limited assurance engagement on the Sustainability Statement of Piraeus Port Authority S.A (hereinafter the “Company”), included in section “Annual Sustainability Statement” of the Annual Report of the Board of Directors (hereinafter the “Sustainability Statement”), for the period from 01.01.2025 to 31.12.2025.

Limited assurance conclusion

Based on the procedures we have performed, as described below in the paragraph “Scope of Work Performed”, as well as the evidence obtained, nothing has come to our attention that causes us to believe that:
* the Sustainability Statement is not prepared, in all material respects, in accordance with article 151 of L.4548/2018 as amended by L.5164/2024 and in effect, with which it was incorporated into Greek legislation the article 19(a) of EU Directive 2013/34/EU;
* the Sustainability Statement does not comply with the European Sustainability Reporting Standards (hereinafter “ESRS”), in accordance with Regulation (EU) 2023/2772 of the Commission of 31 July 2023 and Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022;
* the process carried out by the Company for the identification and assessment of material impacts, risks and opportunities (the "Process"), as set out in section “Double Materiality Assessment” of the Sustainability Statement, does not comply with "Requirement IRO-1- Description of the processes to identify and assess material impacts, risks and opportunities" of ESRS 2 "General Disclosures";
* the disclosures of section “European Taxonomy” of the Sustainability Statement do not comply with article 8 of EU Regulation 2020/852.

This assurance report does not extend to information for previous periods.

Basis for the conclusion

The limited assurance engagement was conducted in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised) “Assurance Engagements Other than Audits or Reviews of Historical Financial Information” (hereinafter “ISAE 3000 (Revised)”).

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The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed. Our responsibilities are further described in the “Practitioner’s Responsibilities” section.

Professional Ethics and Quality Management

We are independent from the Company throughout this work and have complied with the requirements of the Code of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants (IAS Code), the ethics and independence requirements of L.4449/2017 and EU Regulation 537/2014.Our firm applies the International Standard on Quality Management (ISQM) 1 “Quality Management for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services engagements”, and consequently maintains a comprehensive quality management system, which includes documented policies and procedures regarding compliance with ethical requirements, professional standards, and applicable legal and regulatory requirements. We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion.

Responsibilities of the Company’s Management for the Sustainability Statement

The Company’s Management is responsible for designing and implementing an appropriate Process to identify the information reported in the Sustainability Statement in accordance with the ESRS and for disclosing this Process in section “Double Materiality Assessment” of the Sustainability Statement. More specifically, this responsibility includes:

  • The understanding of the context in which the Company activities and business relationships take place and developing an understanding of its affected stakeholders.
  • The identification of the actual and potential impacts (both negative and positive) related to sustainability matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the Company’s financial position, financial performance, cash flows, access to finance or cost of capital over the short-, medium, or long-term.
  • The assessment of the materiality of the identified impacts, risks and opportunities related to sustainability matters by selecting and applying appropriate thresholds and
  • The making of assumptions that are reasonable in the circumstances.

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The Company’s Management is further responsible for the preparation of the Sustainability Statement, in accordance with article 151 of L.4548/2018, as amended with L.5164/2024 and in force, by which article 19(a) of EU Directive 2013/34 was incorporated into Greek legislation. In this context, the Company’s Management is responsible for:

  • The compliance of the Sustainability Statement with the ESRS.
  • The preparation of the disclosures in section “European Taxonomy” of the Sustainability Statement, in compliance with Article 8 of EU Regulation 2020/852.
  • The design and implementation of such internal controls that management determines are necessary to enable the preparation of the Sustainability Statement, that is free from material misstatement, whether due to fraud or error.
  • The selection and implementation of appropriate reporting methods and making assumptions and estimates about individual sustainability disclosures within the Sustainability Statement that are reasonable in the circumstances.

The Company’s Audit Committee is responsible for supervising the drafting process of the Company’s Sustainability Statement.

Inherent limitations in preparing the Sustainability Statement

In reporting forward-looking information in accordance with ESRS, the Company’s Management is required to prepare the forward-looking information on the basis of disclosed assumptions, about events that may occur in the future and possible future actions by the Company. The actual outcome is likely to be different since anticipated events frequently do not occur, as expected. As stated in section “Climate Change Management, Energy, & GHG Emissions” of the Sustainability Statement, the information incorporated in the relevant disclosures is based, among other things, on climate-related scenarios, which are subject to inherent uncertainty regarding the likelihood, timing or impact of potential future natural and transient climate-related impacts.

Our work covered the items specified in the “Scope of Work Performed” section to obtain limited assurance based on the procedures included in the Program, as this is defined in that section. Our work does not constitute an audit or review of historical financial information, in accordance with applicable International Standards on Auditing or International Standards on Review Engagements, and therefore we do not express any assurance other than those listed in the "Scope of Work Performed" section.

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Practitioner’s responsibilities

This limited assurance report has been drawn up based on the provisions of Article 154C of L. 4548/2018 and Article 32A of L.4449/2017. Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability Statement as a whole.

As part of a limited assurance engagement in accordance with ISAE 3000 (Revised), we exercise professional judgement and maintain professional skepticism throughout the engagement. Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:

  • Carrying out risk assessment procedures, including an understanding of the relevant internal control gaps, to identify risks related to whether the Process, followed by the Company to determine the information referred to in the Sustainability Statement does not cover the applicable requirements of the ESRS, but not for the purpose of providing a conclusion regarding the effectiveness of the internal controls on the Process and
  • Designing and carrying out procedures to assess whether the Process for identifying the information referred to in the Sustainability Statement is consistent with the description of the Process, as disclosed in section “Double Materiality Assessment” of the said Statement.

Moreover, we are responsible for:

  • Performing risk assessment procedures, including an understanding of the relevant internal control mechanisms, to identify those disclosures that are likely to be materially misstated, whether due to fraud or error, but not for the purpose of providing a conclusion on the effectiveness of the Company's internal control mechanisms.
  • Designing and carrying out procedures related to those disclosures of the Sustainability Statement, in which a material error is likely to occur.

The risk of not detecting a material misstatement arising from fraud is higher than that arising from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations or the circumvention of internal control barriers.

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Scope of Work Performed

Our work includes performing procedures and obtaining assurance evidence for the purpose of deriving a limited assurance conclusion and covers only the procedures provided for in the limited assurance program issued by the ELTE Board of Directors with decision number 262/22.01.2025, as it was formed for the purpose of issuing a limited assurance report on the Company's Sustainability Statement. Our procedures were designed to obtain a limited level of assurance on which to base our conclusion and do not provide all of the evidence that would be required to provide a reasonable level of assurance.

Athens, 31 March 2026

The Cered Auditor Accountant
Maria Chatziantoniou
SOEL R.Ν.: 25301

ERNST & YOUNG (HELLAS) CERTIFIED AUDITORS ACCOUNTANTS S.A.
Chimarras 8Β
151 25 Maroussi, Greece
Company SOEL R.N.: 107

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THIS REPORT IS A FREE TRANSLATION FROM THE GREEK ORIGINAL

Independent Auditor’s Report

To the shareholders of Piraeus Port Authority S.A.

Report on the Audit of the Financial Statements

Opinion

We have audited the accompanying financial statements of Piraeus Port Authority S.A. (the “Company”), which comprise the statements of financial position as at December 31, 2025, and the statements of comprehensive income, changes in equity and cash flows for the year then ended, and notes to the financial statements, including material accounting policy information.

In our opinion, the accompanying financial statements present fairly in all material respects, the financial position of Piraeus Port Authority S.A. as at December 31, 2025 and its financial performance and cash flows for the year then ended in accordance with International Financial Reporting Standards (“IFRS”), as endorsed by the European Union.

Basis for Opinion

We conducted our audit in accordance with International Standards on Auditing (“ISAs”), as incorporated in Greek Law. Our responsibilities under those standards are further described in the “Auditor’s Responsibilities for the Audit of the Financial Statements” section of our report. We remained independent of the Company throughout the period of our appointment in accordance with the International Ethics Standards Board for Accountants’ Code of Ethics for Professional Accountants (“IESBA Code”), as applicable to audits of public interest entities’ financial statements, together with the ethical requirements that are relevant to the audit of the financial statements in Greece, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA Code.We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the financial statements of the current period. These matters and the related risks of material misstatement were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. For each matter below, our description of how our audit addressed the matter is provided in that context. We have fulfilled the responsibilities described in the “Auditor’s Responsibilities for the Audit of the Financial Statements” section of our report, including in relation to these matters. Accordingly, our audit included the performance of procedures designed to respond to our assessment of the risks of material misstatement of the financial statements. The results of our audit procedures, including the procedures performed to address the matters below, provide the basis for our audit opinion on the accompanying financial statements.

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PIRAEUS PORT AUTHORITY S.A
Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Key Audit Matters How our audit addressed the Key Audit Matters
Measurement of tangible and intangible assets under construction In the course of its operations and in accordance with the obligations arising from the Concession Agreement, the Company undertakes the development, maintenance and exploitation of port infrastructure, which constitutes a significant portion of its total assets. As at 31 December 2025, the total amount of tangible and intangible assets under construction amounted to €222 million. During the year, the Company implemented significant capital investments amounting to €107 million. The accounting monitoring and measurement of these assets require the exercise of significant judgement by Management, particularly with respect to the distinction between capital and operating expenditures, as well as the identification of the point in time at which assets are available for their intended use. Furthermore, the nature, scale and duration of projects under construction, combined with exposure to regulatory approvals, tendering procedures and potential delays or cost overruns, together with the required monitoring analyses, increase the complexity of their monitoring and may indicate the existence of impairment indicators. We determined the measurement of tangible and intangible assets under construction as one of the Key Audit matters due to the materiality of the related balances, the level of judgement exercised by Management and the nature and extent of the audit procedures designed and performed. Disclosures related to tangible and intangible assets under construction are included in Notes “2.c.1(vii) Impairment of property, plant and equipment”, “3(a) Tangible Assets”, “3(c) Impairment of non‑financial Assets”, “3(f) Intangible Assets”, “4. Property, Plant and Equipment” and “7. Intangible Assets” to the financial statements.
The audit procedures we performed in this area included, among others, the following: • We obtained an understanding of the processes, policies and methodologies applied by Management for monitoring tangible and intangible assets under construction. • We evaluated Management’s judgements regarding the distinction between capital and operating expenditures. • We reviewed Management’s assessment of whether indicators of impairment existed for tangible and intangible assets under construction as at 31 December 2025. • We held meetings and discussions with the Company’s Management regarding the nature and current status of a sample of projects under construction. • We examined, on a sample basis, expenditures capitalized as tangible and intangible assets under construction, in relation to the relevant contracts, invoices and other supporting documentation, such as the Company’s analyses and engineers’ and constructors’ certifications. We also assessed whether these expenditures met the criteria for capitalization. Finally, we evaluated the adequacy of the related disclosures included in Notes “2.c.1(vii) Impairment of property, plant and equipment”, “3(a) Tangible Assets”, “3(c) Impairment of non‑financial Assets”, “3(f) Intangible Assets”, “4. Property, Plant and Equipment” and “7. Intangible Assets” to the financial statements.

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Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Key Audit Matters How our audit addressed the Key Audit Matters
Provisions for legal cases and contingent liabilities The Company is involved in a significant number of pending legal cases arising from the ordinary course of its operations, the total exposure of which amounts to €108.3 million, for which a provision of €14.7 million has been raised as at December 31, 2025. The Company’s portfolio of pending legal cases mainly relates to claims involving employees, the Greek State, neighboring municipalities, as well as other third parties. The recognition and measurement of provisions, as well as the disclosure of contingent liabilities, require the exercise of significant judgment and estimation by Management, particularly in relation to: • the likelihood of an unfavorable outcome of the cases, • the potential outflow of economic resources, and • the reliable estimation of the related amount. This process is based, among other factors, on Management’s assessments, on opinions provided by internal and external legal advisors, as well as on the interpretation of the applicable legislation. Due to the nature of the cases and the inherent uncertainty involved, such estimates are subject to change. We determined provisions for legal cases and contingent liabilities as one of the Key Audit Matters due to the significant number of pending legal cases and the materiality of the related amounts, as well as due to the need for extensive estimates and assumptions by Management in determining the amount of the related provision. Disclosures related to provisions for pending legal cases and contingent liabilities are included in Notes “2.c.1(ii) Provisions for legal cases and contingent liabilities”, “18. Provisions” and “32(a) Litigation and Claims” to the financial statements.
The audit procedures we performed in this area included, among others, the following: • We obtained an understanding of the processes, policies and methodologies applied by Management, in cooperation with the Company’s Legal Department, for monitoring pending legal cases and assessing the related provision. • We obtained a letter from the Company’s Legal Department, accompanied by a detailed schedule of all pending legal cases in which the Company is involved, prepared by the Company’s Legal Department, either as defendant or claimant, including the assessments of the Company’s legal advisors regarding their probable outcome and the corresponding provision. • We obtained letters from the Company’s external legal advisors, providing a detailed overview of the pending legal cases under their responsibility, including their assessments of the probable outcome. • We held meetings and discussions with representatives of the Legal Department and the Company’s Management regarding the nature and current status of a sample of pending legal cases. • We examined whether the pending legal cases and the related provisions, as presented in the financial statements, were supported by the underlying analyses with an assessment date of 31 December 2025. Finally, we evaluated the adequacy of the related disclosures included in Notes “2.c.1(ii) Provisions for legal cases and contingent liabilities”, “18. Provisions” and “32(a) Litigation and Claims” to the financial statements.

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Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise) (amounts in Euro unless stated otherwise)

Other Matter

The Company’s financial statements for the prior financial year ended 31 December 2024 were audited by another Statutory Auditor. For that financial year, the Statutory Auditor issued an audit report dated 31 March 2025 with an unmodified opinion.

Other information

Management is responsible for the other information in the Annual Financial Report. The other information, includes the Board of Directors’ Report, for which reference is also made in section “Report on Other Legal and Regulatory Requirements”, the Statements of the Members of the Board of Directors, and any other information either required by law or voluntarily incorporated by the Company in its Annual Financial Report prepared in accordance with Law 3556/2007, but does not include the financial statements and our auditor’s report thereon. Our opinion on the financial statements does not cover the other information and we do not express any form of assurance conclusion thereon. In connection with our audit of the financial statements, our responsibility is to read the other information identified above and, in doing so, consider whether the other information is materially inconsistent with the financial statements, or our knowledge obtained in the audit, or otherwise appears to be materially misstated. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report in this regard.# Responsibilities of the Management and Those Charged with Governance for Financial Statements

Management is responsible for the preparation and fair presentation of the financial statements in accordance with International Financial Reporting Standards as endorsed by the European Union, and for such internal control as management determines is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error. In preparing the financial statements, management is responsible for assessing the Company’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so. The Company’s Audit Committee (Article 44, Law 4449/2017) is responsible for overseeing the Company’s financial reporting process.

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Auditor’s Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs, as incorporated in Greek Law, will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

As part of an audit in accordance with ISAs, as incorporated in Greek Law, we exercise professional judgment and maintain professional scepticism throughout the audit. We also:

  • Identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.
  • Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Company’s internal control.
  • Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.
  • Conclude on the appropriateness of management’s use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Company’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may cause the Company to cease to continue as a going concern.
  • Evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and whether the financial statements represent the underlying transactions and events in a manner that achieves fair presentation.

We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.

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We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards.

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the financial statements of the current period and are therefore the key audit matters.

Report on Other Legal and Regulatory Requirements

1. Board of Directors’ Report

Taking into consideration that management is responsible for the preparation of the Board of Directors’ Report and the Corporate Governance Statement that is included therein, in accordance with the provisions of paragraph 1, citations aa, ab and b, of article 154C of Law 4548/2018, which do not include the sustainability statement, on which we have issued a limited assurance report dated 31/03/2026, based on International Standard on Assurance Engagements 3000 (Revised), we report that:

a) The Board of Directors’ Report includes a Corporate Governance Statement that contains the information required by article 152 of Law 4548/2018.
b) In our opinion the Board of Directors’ Report has been prepared in accordance with the legal requirements of articles 150 of Law 4548/2018, excluding the requirement of paragraph 5A of article 150 of the same law to submit a sustainability statement, and the content of the Board of Directors’ report is consistent with the accompanying financial statements for the year ended December 31, 2025.
c) Based on the knowledge we obtained during our audit, concerning Piraeus Port Authority S.A. and its environment, we have not identified information included in the Board of Directors’ Report that contains a material misstatement.

2. Additional Report to the Audit Committee

Our opinion on the accompanying financial statements is consistent with our Additional Report to the Audit Committee of the Company, in accordance with Article 11 of the EU Regulation 537/2014.

3. Provision of Non-audit Services

We have not provided in the Company any prohibited non-audit services per Article 5 of the EU Regulation 537/2014. Permissible non-audit services provided by us to the Company during the year ended December 31, 2025, are disclosed in Note 26 of the accompanying financial statements.

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4. Appointment of the Auditor

We were appointed for the first time as auditors of the Company pursuant to the resolution of the Annual Ordinary General Assembly of Shareholders dated 8 July 2025.

5. Rules of Procedure

The Company has in place Rules of Procedure, the context of which is in accordance with the provisions of article 14 of Law 4706/2020.

6. Reasonable Assurance report on the European Single Electronic Format

Subject Matter

We have been engaged to perform a reasonable assurance engagement in order to examine the digital file of Piraeus Port Authority S.A., prepared in accordance with the European Single Electronic Format (“ESEF”), which includes the financial statements of the Company for the year ended December 31, 2025 in XHTML format [549300UNB6JCR0XZT864-2025-12-31-en.xhtml] (the “Subject Matter”), and report about whether the Subject Matter is prepared in accordance with the Applicable Criteria.

Applicable Criteria

The Applicable Criteria for the European Single Electronic Format (ESEF) are defined in the EU Delegated Regulation 2019/815, as amended by the EU Delegated Regulation 2020/1989 of the European Commission (the “ESEF Regulation”) and the Interpretative Communication of the European Commission 2020/C 379/01 dated 10 November 2020, as required by Law 3556/2007 and the relevant communications of the Hellenic Capital Market Commission and the Athens Stock Exchange. The Applicable Criteria provide, among others, that all annual financial reports should be prepared in XHTML format.

Responsibilities of Management and Those Charged With Governance

Management is responsible for the preparation and submission of the financial statements of the Company for the year ended December 31, 2025, in accordance with the Applicable Criteria, and for such internal control as management determines is necessary to enable the preparation of the digital file that is free from material misstatement, whether due to fraud or error.

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Auditor’s Responsibilities

Our responsibility is to issue this report regarding the evaluation of the Subject Matter, based on the work performed, which is described below in the section “Scope of work performed”. We conducted our engagement in accordance with the International Standard on Assurance Engagements 3000 (Revised), "Assurance Engagements Other Than Audits or Reviews of Historical Financial Information” (ISAE 3000). ISAE 3000 requires that we plan and perform our engagement to obtain reasonable assurance for the evaluation of Subject Matter in accordance with the Applicable Criteria. As part of the procedures performed, we assess the risk of material misstatement of the information related to the Subject Matter.We believe that the evidence we have obtained is sufficient and appropriate to provide a reasonable basis for our conclusion.

Professional ethics and quality management

We remained independent of the Company throughout the period of this assignment, and we have complied with the requirements of International Ethics Standards Board for Accountants’ Code of Ethics for Professional Accountants (IESBA Code), the ethical and independence requirements of Law 4449/2017 and the EU Regulation 537/2014. Our audit firm applies the International Standard on Quality Management (ISQM) 1, “Quality Management for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services engagements”, which requires that we design, implement and operate a system of quality management including policies or procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.

Scope of work performed

The assurance engagement we performed is limited to the objectives included in the Decision 214/4/11-02-2022 of the Board of Directors of the Hellenic Accounting and Auditing Standards Oversight Board and the guiding instructions to auditors in connection with their assurance engagement on the European Single Electronic Format (ESEF) of public issuers in regulated Greek markets, as issued by the Institute of Certified Public Accountants of Greece on February 14, 2022, in order to obtain reasonable assurance that the financial statements of the Company prepared by management comply, in all material respects, with the Applicable Criteria.

Inherent limitations

Our work is limited to the objectives mentioned in the section “Scope of work performed” for obtaining reasonable assurance based on the procedures described. In this context, the work we performed could not guarantee that all issues that might be considered material weaknesses would be disclosed.

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Conclusion

Based on the procedures performed and the evidence obtained, we express the conclusion that the financial statements of the Company for the year ended December 31, 2025, in XHTML file format [549300UNB6JCR0XZT864-2025-12-31- en.xhtml] has been prepared and presented, in all material respects, in accordance with the Applicable Criteria.

Athens, 31 March 2026

The Certified Auditor Accountant
Maria Chatziantoniou
SOEL R.Ν.: 25301

ERNST & YOUNG (HELLAS) CERTIFIED AUDITORS ACCOUNTANTS S.A.
Chimarras 8Β
151 25 Maroussi, Greece
Company SOEL R.N.: 107

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ANNUAL FINANCIAL STATEMENTS
of PPA S.A. for the year January 1st – December 31st , 2025
In accordance with the International Financial Reporting Standards as adopted by the European Union

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STATEMENT OF COMPREHENSIVE INCOME FOR THE YEAR ENDED DECEMBER 31, 2025

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STATEMENT OF FINANCIAL POSITION AS AT DECEMBER 31, 2025

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STATEMENT OF CHANGES IN EQUITY FOR THE YEAR ENDED DECEMBER 31,2025

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CASH FLOW STATEMENT FOR THE YEAR ENDED DECEMBER 31,2025

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NOTES TO THE FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2025

1. ESTABLISHMENT AND ACTIVITY OF THE COMPANY

“Piraeus Port Authority S.A” (from now on “PPA S.A.” or “Company”) was established in 1930 as Civil Law Legal Corporation (C.L.L.C.) by Law 4748/1930, which was revised by L.1559/1950 and was ratified by L.1630/1951 and converted into a Societé Anonyme (S.A.) by Law 2688/1999. The Company is located at Municipality of Piraeus, at 10 Akti Miaouli street, TC 185 38. The Company’s main objective is to perform its obligations, conduct its activities, and exercise its faculties under or in respect of the concession agreement between the Company and the Hellenic Republic dated 13 February 2002 regarding the use and exploitation of certain areas and assets within the Port of Piraeus, as amended and in force. The Company may, by way of an illustrative but not exhaustive list, conduct and be engaged in the following activities:
- to use all rights assigned to the Company pursuant to the Concession Agreement and maintain, utilize, and exploit all concession assets in accordance with the Concession Agreement;
- provide services and facilities to vessels, cargo, and passengers, including ship berthing and cargo and passenger handling to and from the port;
- install, organize, and exploit all kinds of port infrastructure;
- undertake any activities related to the port and all other commercial activities associated with or reasonably incidental to the operation of the port of Piraeus;
- engage third parties to provide any kind of port services;
- award contracts for works;
- engage in such further activities as are prudent or customary for the proper conduct of its business and operations in accordance with the Concession Agreement; and
- engage in any activities, transactions, or operations of a type that are generally conducted by commercial corporations.

The main activities of the Company are anchoring services of vessels, handling cargo, loading and unloading services, as well as goods storage and car transportation. The Company is also responsible for the maintenance of port facilities, the supply of port services (water, electricity, telephone connection, etc.), for services provided to travelers (coastal and cruise ships), and for renting space to third parties. The Company is governed by the principles of L. 4548/2018, which replaced the Company Law 2190/1920 and the founding Law 2688/1999, as amended by Law 2881/2001 and Law 4404/2016. The duration period of the Company is one hundred (100) years from the effective date of Law 2688/1999. This period may be extended by special resolution of the shareholders' general meeting.

COSCO SHIPPING (Hong Kong) Limited controlled the 51% of the voting rights, with the date of transfer of such rights on 10 August 2016. COSCO SHIPPING (Hong Kong) Limited is 100% held by China Shipping Company Limited, which is 100% held by China COSCO SHIPPING Corporation Limited, a Chinese state-owned company. As a result, China COSCO SHIPPING Corporation Limited, by indirectly holding 100% of COSCO SHIPPING (Hong Kong) Limited, indirectly held 51% of the voting rights in PPA.

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On 6 October 2021, an over-the-counter transaction took place where COSCO SHIPPING (Hong Kong) Co., Limited acquired from Hellenic Republic Asset Development Fund S.A. an additional 16% of shares in PPA S.A. As a result, the percentage of voting rights of COSCO SHIPPING (Hong Kong) Co., Limited in PPA S.A. has increased from 51% to 67%. The above transaction has taken place under an Amended Share Purchase Agreement between COSCO SHIPPING (Hong Kong) Co., Limited as Purchaser and Hellenic Republic Asset Development Fund S.A. as Seller, following ratification of an Amendment to the Concession Agreement between the Hellenic Republic and PPA S.A. (Law 4838/2021, Government Gazette 180A/ 01.10.2021). As a result of the above transaction, China COSCO Shipping Corporation Limited indirectly holds 67% of voting rights in PPA S.A. The Company’s number of employees as of December 31, 2025, amounted to 1.058. At December 31, 2024, the respective number of employees was 1.024.

2. BASIS OF PRESENTATION OF FINANCIAL STATEMENTS:

(a) Basis of Preparation of Financial Statements

The financial statements have been prepared in accordance with International Financial Reporting Standards (IFRS) as adopted by the European Union. These financial statements have been prepared under the historical cost. All amounts presented in the financial statements are in euros. Any differences between the amounts included in the financial statements and the respective amounts included in the notes are attributed to rounding. The preparation of financial statements according to the IFRS requires estimates and assumptions to be made by the management, influencing the assets and liabilities amounts, the disclosure of potential receivable and liabilities as at the financial statements date, as well as the revenue and expenditure amounts, during the financial period. Actual results may differ from these estimations. The areas involving a higher degree of judgment or complexity, or areas where assumptions and estimates are significant to the financial statements, are disclosed in note 2(c).The Company's management observes closely and continuously the extended conflict in Ukraine, the war in the Gaza Strip, the turbulent situation in the Middle East, the prevailing situation, which results in the unsafe transit of cargo ships through the Suez Canal and Red Sea, and their effects on the macroeconomic and financial environment, such as the energy instability, the increase in energy costs and bank interest rates, the most intense inflationary pressures, and the most serious complications in international shipping and global trade, to ensure that all necessary actions and initiatives are undertaken to minimize possible consequences for the Company’s activities. Management believes that its strong capital position and liquidity, its activity in different sectors, its strong and dynamic Μanagement, the experienced human resources as well as the fact that until now the above conditions have not significantly affected its activities , will allow the Company to successfully overcome any period of uncertainty and has reached the conclusion that no additional impairment provisions of the financial and non-financial assets of the Company are required on December 31, 2025. The “Advances and other long-term receivables” account from the prior year was reclassified to ensure consistency and comparability with the corresponding account for the current year.

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(b) Approval of Financial Statements
The Board of Directors of the Company approved the financial statements for the year ended at December 31, 2025, on 31 March, 2026. The abovementioned financial statements are subject to the final approval of the Annual GA of the Shareholders.

(c) Significant Accounting Judgements and Estimates
The Company makes estimates and judgments in order to select the most appropriate accounting principles taking into consideration the future outcome of events and transactions. Estimates and judgments are continually evaluated and are based on historical experience and other factors, including expectations of future events that are believed to be reasonable under the circumstances. Estimates and judgments adopted in the preparation of the annual financial statements are consistent with those followed in the preparation of the annual financial statements for the year ended December 31, 2024. The significant estimates and judgments that have a risk of causing a significant adjustment to the carrying amounts of assets and liabilities within the next financial year are as follows:

c.1 Significant accounting estimates and assumptions

(i) Allowance for doubtful accounts receivable and legal cases:
Management periodically reassess the adequacy of allowance for doubtful accounts receivable following the simplified approach of IFRS 9 of calculating expected credit losses (‘ECLs’). The expected loss rate is assessed on the basis of historical credit losses adjusted to reflect current and forward-looking information. ECLs are based on the difference between the contractual cash flows due and all the cash flows that the Company expects to receive and taking into consideration reports from its legal department.

(ii) Provisions for legal cases and contingent liabilities:
The Company, in conjunction with its legal department and its external advisors who manage the cases, assesses the outcome of the litigation at the end of each financial year. Based on Management's judgment based on all available information, including the opinion of its legal advisors managing the cases, the Company evaluates the likelihood of an adverse outcome, as well as the amounts potentially payable to settle the cases, and makes the necessary provision or disclosure of contingent liabilities related to pending litigation. The above assessment is a complex process involving judgments about the potential consequences as well as interpretations of laws and regulations.

(iii) Income taxes:
Income tax expense consists of current and deferred tax. According to IAS 12, income tax provisions are based on estimations as to the taxes that shall be paid to the tax authorities and includes the current income tax for each fiscal year, the provision for additional taxes which may arise from future tax audits, and the recognition of future tax benefits. The final clearance of income taxes may be different from the relevant amounts that are included in these financial statements. Estimates on deferred tax arise in the process of recognition of deferred tax assets, which is performed to the extent that it is probable that future taxable profit will be available against which the deductible temporary differences and the carry forward of unused tax credits and unused tax losses can be utilized. In addition, the tax rates used for both deferred tax assets and liabilities are the ones that are estimated to be enacted in the following years, where the differences are expected to reverse.

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(iv) Depreciation rates:
The Company’s assets are depreciated over their estimated remaining useful lives. These useful lives are periodically reassessed to determine whether the original period continues to be appropriate. The actual lives of these assets can vary depending on a variety of factors such as technological innovation, maintenance programs and environmental imperatives due to climate changes.

(v) Provision for staff leaving indemnities:
The cost for staff leaving indemnities is determined based on actuarial valuations. The actuarial valuation requires management to make assumptions about future salary increases, discount rates, mortality rates, etc. Management, at each reporting date when the provision is re-examined, tries to give its best estimate regarding the above mentioned parameters.

(vi) Leases:
The Company made a significant estimate to determine the “incremental borrowing rate” that it used to recognize its lease contract with the Greek State because of its special nature. This contract is the Company's main lease agreement (Note 3 (s)).

(vii) Impairment of property, plant and equipment:
Cash flows generation units are tested for impairment when there are indicators that the carrying amounts may not be recoverable. When value in use calculations are undertaken, Management estimates the expected future cash flows from the asset or cash-generating unit, chooses a suitable discount rate and long-term growth indicators in order to calculate the present value of those cash flows. The subjectivity which is involved in the key assumptions that are used by Management in the check of impairment and the inherent uncertainty of these assumptions is high. The Company's Management, in the context of assessing impairment indicators, takes into account the broader macroeconomic and geopolitical environment. In particular, current geopolitical developments are examined, including the ongoing conflicts in Ukraine and the Middle East, as well as potential disruptions to international supply chains and maritime transport, such as those related to the passage of commercial vessels through the Suez Canal and the Red Sea region. Management assesses whether these developments may affect the Company's activities and constitute indications of impairment of the value of tangible fixed assets or the cash-generating units to which they belong. No indications of impairment of the Company's tangible fixed assets emerged during the current year.

(viii ) Contingent liabilities:
The existence of contingent liabilities requires from Management to make assumptions and estimates continuously related to the possibility that future events may or may not occur as well as the effects that those events may have on the activities of the Company.

c.2 Significant judgements on the implementation of accounting policies

Leases:
The Company made judgments as to whether the sub-lease agreements in which the Company is a lessor relate to operating or finance leases. The contracts to which the Company is a lessor relate mainly to the contract with Piraeus Container Terminal S.A. (Note 3 o(iii)) as well as contracts related to leased areas to ship repair zone. The management's judgment was based mainly on the duration of the leases.

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Concerning the contract with Piraeus Container Terminal S.A., in previous years, Management concluded that it is an operating lease due to its duration and because the lease does not substantially transfer the risks and rewards of the right of use. Concerning the concession agreement with the Greek State, the Company concluded that it falls under the provisions of IFRS 16 and not to the corresponding provisions of IFRIC 12, as the Company has control over the pricing of its services other than coastal shipping and therefore the contract is a contract lease.

3. MATERIAL ACCOUNTING POLICIES

The Company applies the following material accounting policies for the preparation of the accompanying financial statements:

(a) Tangible Assets:
Buildings, technical projects, and other building installations are valued at acquisition cost less accumulated depreciation and possible impairment provision. The privately owned land, machinery, and other equipment, acquired before PPA’s conversion into an S.A., 1.6.1999, were valued at deemed cost, arising from the Evaluation Committee of article 9 C.L. 2190/1920, while those acquired afterwards are valued at acquisition cost less accumulated depreciation and possible value impairment provision.The acquisition cost of a building installation or equipment consists of the purchase price include import duties, plus non-refundable purchase taxes, as well as any costs required for the asset to become operational. Repairs and maintenance are posted to the financial period in which they were incurred. Significant additions and improvements made at a later stage are capitalized in the relevant asset cost. Fixed assets constructed by the Company are posted to the self-construction cost, which includes subcontractors’ fees, materials, and technicians’ payroll costs involved in the construction (including relevant employer contributions) as well as part of the general administration expenses. Assets under construction include fixed assets under construction and are stated at their cost. Assets under construction are not depreciated until the fixed assets are complete and operational.

(b) Depreciation: Fixed assets are depreciated on a straight line basis according to the following useful lives per fixed asset category:

Fixed Asset Categories Useful Life (years)
Buildings, technical & port projects 25-40
Machinery & other equipment 10-30
Motor Vehicles 5-12
Floating transportation means 20-35
Furniture, fixture & fittings 5-10

The residual value, the useful life, and the depreciation method of the Company's assets are examined annually, and they are adjusted if necessary.

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(c) Impairment of non financial assets: Property, plant & equipment and intangible fixed assets shall be evaluated for possible impairment loss when there are indications that the asset’s book value is over its recoverable amount. In addition, the Company's Management considers that given the approved, received from the competent state bodies, decision of approval of environmental conditions (AEPO) Dec.YPEN/DIPA/94636/6224/15-9-2023 for its expantion projects and its operation, the current environmental legislation has no negative impact on the Company's activities and does not create circumstances indicating that the carrying amount of its non-financial assets is no longer recoverable. In this direction, all of the Company's activities have been examined in the Environmental Impact Study (EIS) of PPA SA, which led to the new Environmental Terms Approval Decision (EEPD) of PPA SA issued in September 2023, which aims to mitigate and offset all impacts of PPA SA's activities on the climate and the environment in general through appropriate measures. In the implementation of the AEPO's forecasts, the PPA is currently preparing a Special Climate Shielding Study, which includes:
* specialization of the findings of the Environmental Impact Study regarding the climate vulnerability and the port's adaptation needs to climate change,
* examination of the consequences of climate change on the port,
* ensuring compatibility with the Attica Regional Climate Change Adaptation Plan (PESPKA).

When an asset’s book value is over its recoverable amount, the respective impairment loss is posted to the period's financial results. An asset’s recoverable value is the greater amount between the fair value less the cost of disposal and the value in use. Value in use is based on the Company's projected cash flows, discounted to present value using a discount rate that reflects current economic considerations and risks associated with the particular asset or cash-generating unit. For the purpose of assessing impairment, assets are grouped at the lowest level for which cash flows can be identified separately (cash generating units). Impairment losses recognized in prior periods in non-financial assets are reviewed at each reporting date for any reversal.

(d) Investment property: Investment property that includes land and buildings is held by the Company for long-term rental yields and not for its own use. Investment property is measured at cost less depreciation and impairment. Land is not depreciated. The depreciation of buildings is calculated using the straight line method over the buildings’ useful life, which is 30 years. When the carrying amounts of the investment property exceed their recoverable amounts, the difference (impairment) is charged directly to the statement of comprehensive income. Transfers are made to investment property when, and only when, there is a use change, evidenced by the end of owner occupation.

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(e) Fixed Asset Subsidies: Government grants are recognised when there is reasonable assurance that the grant will be received, and all attached conditions will be complied with. Subsidies are considered as deferred revenue and are recognized as income at the same depreciation rate as the relevant subsidized fixed assets are depreciated. This income is deducted from the depreciation in the period financial results.

(f) Intangible Assets: Intangible assets include software purchase cost and any expenditure for software development. Software is carried at cost less accumulated amortization. Software depreciation is calculated on a straight line basis and its useful life of 3-4 years.

(g) Borrowing Cost: Borrowing costs are interest and other costs an entity incurs in relation to the borrowing of funds. Borrowing costs directly attributable to the acquisition, construction or production of an asset that necessarily takes a substantial period of time to get ready for its intended use or sale are capitalised as part of the cost of the asset. If the funds were generally raised and used for the construction of fixed assets, the portion of the borrowing costs capitalized is determined by applying a capitalization factor to the cost of acquiring the asset. All other borrowing costs are expensed in the period in which they occur.

(h) Financial Instruments: Initial recognition and subsequent measurement

A financial instrument is any contract that gives rise to a financial asset of one entity and a financial liability or equity instrument of another entity.

▪ Financial assets Initial recognition and measurement

Financial assets of the Company are classified, at initial recognition, as subsequently measured at amortised cost, fair value through other comprehensive income, and fair value through profit or loss. The classification of financial assets at initial recognition depends on the financial asset’s contractual cash flow characteristics and the Company’s business model for managing them. Cash and cash equivalents mainly include demand deposits and time deposits held with credit institutions and are part of the Company's cash Μanagement. These deposits are highly liquid and are readily convertible into specific amounts of cash without significant risk of loss of the invested capital. Time deposits may be liquidated at any time upon request of the Company without risk of loss of the principal. In the event of early termination, there may be a loss of part or all of the accrued interest. Interest is recognized in the results using the effective interest method. Except for trade receivables that do not contain a significant financing component or for which the Company has applied the practical expedient, the Company initially measures a financial asset at its fair value plus, in the case of a financial asset not measured at fair value through profit or loss, transaction costs. Trade receivables that do not contain a significant financing component or for which the Company has applied the practical expedient are measured at the transaction price as determined under IFRS 15.

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In order for a financial asset to be classified and measured at amortised cost or fair value through other comprehensive income, it needs to give rise to cash flows that are solely payments of principal and interest on the principal amount outstanding. This assessment is referred to as the ‘solely payments of principal and interest’ test and is performed at an instrument level. The Company’s business model for managing financial assets refers to how the Company manages its financial assets in order to generate cash flows. The business model determines whether cash flows will result from collecting contractual cash flows, selling the financial assets, or both. Purchases or sales of financial assets that require delivery of assets within a time frame established by regulation or convention in the marketplace (regular way trades) are recognised on the trade date, i.e., the date that the Company commits to purchase or sell the asset.

Subsequent measurement
For purposes of subsequent measurement, financial assets are classified in four categories:
* Financial assets at amortised cost (debt instruments)
* Financial assets at fair value through OCI with recycling of cumulative gains and losses (debt instruments)
* Financial assets designated at fair value through OCI with no recycling of cumulative gains and losses upon derecognition (equity instruments)
* Financial assets at fair value through profit or loss

During the current year, there are no financial assets measured at fair value through other comprehensive income or through profit or loss.

Financial assets at amortised cost (debt instruments)
This category is the most relevant to the Company. The Company measures financial assets at amortised cost if both of the following conditions are met:
* The financial asset is held within a business model to hold financial assets to collect contractual cash flows, and
* The contractual terms of the financial asset give rise on specified dates to cash flows that are solely payments of principal and interest on the principal amount outstanding.Financial assets at amortised cost are subsequently measured using the effective interest (EIR) method and are subject to impairment. Gains and losses are recognised in profit or loss when the asset is derecognised, modified, or impaired. The Company’s financial assets at amortised cost include trade and other receivables.

Derecognition of a financial asset

A financial asset (or, where applicable, a part of a financial asset or part of a group of similar financial assets) is derecognised when:
* The rights to receive cash flows from the asset have expired

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Or
* The Company tranfers a financial asset and the tranfer meets the requirements for write-off.

The Company transfers a financial asset if, and only if, it either:
* transfers the contractual rights to receive the cash flows of the financial asset
Or
* retains the contractual rights to receive the cash flows of the financial asset but assumes a contractual obligation to pay the cash flows to one or more recipients in an arrangement.

When the Company transfers a financial asset, it shall evaluate the extent to which retains the risks and rewards of ownership of the financial asset. In this case:
* if the Company transfers substantially all the risks and rewards of ownership of the financial asset, the entity shall derecognise the financial asset and recognise separately as assets or liabilities any rights and obligations created or retained in the transfer.
* if the Company retains substantially all the risks and rewards of ownership of the financial asset, the Company shall continue to recognise the financial asset.
* if the Company neither transfers nor retains substantially all the risks and rewards of ownership of the financial asset, shall determine whether it has retained control of the financial asset. In this case:
(i) if the Company has not retained control, it shall derecognise the financial asset and recognise separately as assets or liabilities any rights and obligations created or retained in the transfer.
(ii) if the Company has retained control, it shall continue to recognise the financial asset to the extent of its continuing involvement in the financial asset.

Impairment of financial assets

The Company recognise an allowance for expected credit losses for all debt instruments not held at fair value through profit or loss. Expected credit losses are based on the difference between the contractual cash flows due in accordance with the contract and all the cash flows that the Company expects to receive, discounted at an approximation of the original effective interest rate. The expected cash flows will include cash flows from the sale of collateral held or other credit enhancements that are integral to the contractual terms.

For trade and other receivables, the Company apply a simplified approach in calculating expected credit losses. Therefore, the Company does not track changes in credit risk, but instead recognises a loss allowance based on lifetime expected credit losses at each reporting date. For other financial assets, the ECL is based on the 12-month ECL.

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The 12-month ECL is the portion of lifetime ECLs that results from default events on a financial instrument that are possible within 12 months after the reporting date. It should be noted that no such case occurred during the fiscal year. However, when there has been a significant increase in credit risk since origination, the allowance will be based on the lifetime ECL.

The Company considered the risk of default, the days past due and the historical credit losses experienced adjusted to reflect current and forward-looking information per debtor to measure the expected credit losses for each individual trade and other receivable balance. At each reporting date, the Company assess whether the credit risk of a financial asset has increased significantly from the initial recognition. The Company consider a financial asset in default when contractual payments past due over the Company’s credit policy. However, in certain cases, the Company may also consider a financial asset to be in default when internal or external information indicates that the Company is unlikely to receive the outstanding contractual amounts in full before taking into account any credit enhancements held by the Company.

A financial asset is written off when there is no reasonable expectation of recovering the contractual cash flows.

Financial liabilities

Initial recognition and measurement

Financial liabilities of the Company are classified, at initial recognition, as financial liabilities at fair value through profit or loss. All financial liabilities are recognised initially at fair value and, in the case of loans and borrowings and payables, net of directly attributable transaction costs. The Company’s financial liabilities include trade and other payables, loans and borrowings including bank overdrafts.

Subsequent measurement

The measurement of financial liabilities depends on their classification, as described below:

Loans and borrowings

After initial recognition, interest-bearing loans and borrowings are subsequently measured at amortised cost using the effective interest rate method. Gains and losses are recognised in the statement of comprehensive income when the liabilities are derecognised as well as through the effective interest rate amortisation process. Amortised cost is calculated by taking into account any discount or premium on acquisition and fees or costs that are an integral part of the effective interest rate. The effective interest rate amortisation is included as finance costs in the statement of comprehensive income. This category generally applies to interest-bearing loans and borrowings. Loans and borrowings are classified as current liabilities unless the Group and the Company has the right to defer settlement for at least twelve months from the date of financial position date.

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Trade and other payables

Trade payables are obligations for goods or services that have been acquired in the ordinary course of business by suppliers. Accounts payable are classified as current liabilities if payment is due within one year or less. If not, they are presented as non-current liabilities. Trade account payables subsequent to the initial recognition are measured at amortized cost using the effective interest method.

Derecognition of financial liabilities

A financial liability is derecognised when the obligation under the liability is discharged or cancelled or expires. When an existing financial liability is replaced by another from the same lender on substantially different terms, or the terms of an existing liability are substantially modified, such an exchange or modification is treated as the derecognition of the original liability and the recognition of a new liability.The difference in the respective carrying amounts is recognised in the statement of comprehensive income.

Offsetting of financial instruments

Financial assets and financial liabilities are offset, and the net amount is reported in the consolidated statement of financial position if there is a currently enforceable legal right to offset the recognised amounts and there is an intention to settle on a net basis, to demand the assets and settle the liabilities simultaneously.

(i) Share Capital: The share capital includes the Company's ordinary shares that are included in equity. Upon acquisition of treasury shares, the consideration paid, including the related expenses, is shown as a deduction from equity (share premium). Expenses incurred for the issue of shares are recognized after deduction of the relevant income tax, net of the issue proceeds. Expenses related to the issue of shares for the acquisition of business are included in the acquisition cost of the business acquire. The Company considers as cash (apart from cash on hand) time deposits and liquid investments maturing in three months from the acquisition date.

(j) Provisions: Provisions are recognized when the Company has a present obligation (legal or constructive) as a result of a past event, it is probable that an outflow of resources embodying economic benefits will be required to settle the obligation and a reliable estimate can be made of the amount of the obligation. If the effect of the time value of money is material, provisions are measured by discounting the expected future cash flows at a pre-tax rate that reflects current market assessments of the time value of money and the risks specific to the liability. Where discounting is used, the increase of the provision due to the passage of time is recognized as a borrowing cost. Provisions are reviewed at each reporting date, and if it is no longer probable that an outflow of resources embodying economic benefits will be required to settle the obligation, they are reversed. Provisions are used only for expenditures for which they were originally recognized. No provisions are recognized for future operating losses. Contingent assets and contingent liabilities are not recognized.

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(k) Income Tax (Current and Deferred): Current and deferred income tax assessment are based on the relevant amounts of the financial statements, according to tax Laws effective in Greece. Current income tax concerns tax on the Company taxable profits, adjusted according to Greek tax Law and calculated using the current tax rate on the reference date.Deferred tax is assessed using the liability method in all temporary tax differences on the balance-sheet date between the tax base and the accounting value of assets and liabilities. The expected tax consequences from the temporary tax differences are assessed and stated either as deferred tax liabilities or as deferred tax assets. Deferred tax assets are posted to the financial statements for all allowable temporary differences and tax losses carried forward as far as it is likely to set off these allowable temporary differences against available taxable profits. The accounting value of deferred tax assets is revised at each balance-sheet date and it is reduced up to the point that it is not likely to have enough taxable profits, where part or all of the deferred tax assets may be set off against. Current income tax receivable and liabilities for current and previous financial years are valued at the amount expected to be paid to Tax Authorities (or be refunded by them), using the tax rates (and tax Laws) in force up to the balance-sheet date. Any differences resulting from tax audits are recorded in accordance with International Accounting Standard 12 "Income Taxes" in the "Income Tax" line of the Statement of Comprehensive Income, while the corresponding fines and surcharges are recorded in the "Other Operating Expenses" line of the Statement of Comprehensive Income in accordance with the provisions of IAS 37.

(l) Revenue Recognition: Revenue is the amount of consideration expected to be received in exchange for transferring promised services to a customer, excluding amounts collected on behalf of third parties (value-added tax, other sales taxes, etc.). The Company recognizes revenue upon the transfer of promising goods or services to customers, in amounts that reflect the reward to which the Company is expected to be entitled of these goods or services based on the following five-step approach:

Step 1: To identify the Contract or based on the applicable services described in the Company's tariffs and regulations.
Step 2: To identify the separate performance obligations within a Contract or regulations.
Step 3: To determine the transaction price.
Step 4: To allocate the transaction price to the performance obligations in the Contract.
Step 5: To recognize revenue when or as a performance obligation is satisfied.

The Company derives revenue from Cargo loading and unloading services, mooring services, storage of cargo services, income from passenger fees, income from vehicle passage , dry docking, and shipbuilding repair zones services, the provision of electricity and water to the vessels, environmental services which include a standard fee charged to each vessel approaching the port and fees related to the waste handling of the vessels and other supporting services to the vessels.

Page 391 από 437 PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

Revenue is recognized when (or as) a performance obligation is satisfied by transferring the control of a promised service to the customer. A customer obtains control of a service if it has the ability to direct the use of and obtain substantially all of the remaining benefits from that service. Control is transferred over time or at a point in time when the service is provided to the customer. Management has determined that for loading and unloading services, berthing and mooring services, passenger services, services relating to the provision of water and electricity, and for environmental services there is a single performance obligation which is the loading and unloading of the respective cargo (container, vehicles, bulk cargo), the berthing and the mooring of the vessel, the unboarding or boarding of passengers, the provision of water and electricity, the mooring of the vessel and the waste handling, respectively, and revenue is recognized at a point in time when the respective service is provided to the customer and the customer obtains the benefit of these services. For the storage services where the customer is charged with a daily charge for each day that the cargo remains in the warehouse and for dry-docking and shipbuilding repairs zone services where the customer is charged with a daily charge for each day that the vessel remains in the zone, the Company has determined that there is one single performance obligation which is to provide the customer with the required space and the related services. The Company has concluded that revenue from these services meets the criteria to be recognized over time because the customer simultaneously receives and consumes the benefits of the Company’s performance as the Company performs. Therefore, since the Company’s performance obligation is met evenly, revenue is recognized ratably for the period that the cargo actually remained in the warehouse and the period that the vessel actually remained in the zone, respectively. Prices for all services are fixed, based on stand-alone selling prices derived from price lists. A receivable is recognized when there is an unconditional right to consideration for the performance obligations to the customer that are satisfied. A contract asset is recognized when the performance obligation to the customer is satisfied before the customer pays or before payment is due, usually when services are transferred to the customer before the Company has a right to invoice. A contract liability is recognized when there is an obligation to transfer services to a customer for which the Company has received consideration from the customer (prepayments) or there is an unconditional right to receive consideration before the Company transfers a service (deferred income). The contract liability is derecognized when the promise is fulfilled and revenue is recorded in the profit or loss statement.

(m) Inventories: Materials and spare parts related to the Company mechanical equipment maintenance are valued at the lower of acquisition cost and net realisable value and their cost is determined on the weighted average cost basis. Materials are posted to inventories on purchase and recognized as expenditure on consumption.

(n) Defined benefit plan: The provision for staff termination indemnities recorded in the statement of financial position for the defined benefit plan is the present value of the liability for the defined benefit in addition to changes occurring from any other actuarial profit or loss and the past service cost.

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The discount rate is considered as the yield, at the balance sheet date, of high quality European corporate bonds which have a maturity which approaches the time period of the Company’s liability. The liability for this plan is determined using the projected unit credit method from an independent valuer and includes the present value of accrued services during the year, the interest on future liabilities, the prior service cost and the actuarial gains or losses. The cost of current employment of defined benefit plan, the past service cost and finance cost are recognized in the Statement of Comprehensive Income. Re-measurements, comprising of actuarial gains and losses, the effect of the asset ceiling, excluding net interest and the return on plan assets, are recognized immediately in the statement of financial position with a corresponding debit or credit to the actuarial differences reserve through other comprehensive income in the period in which they occur. Remeasurements are not classified to profit or loss in subsequent periods.

(o) Leases:
i. Company as lessee
Leases are recognised as a right-of-use asset and a corresponding liability at the date at which the leased asset is available for use by the Company. Each lease payment is divided between the lease liability and the finance cost. The interest on the lease liability for each period of the lease term is equal to the amount resulting from the application of a fixed periodic interest rate on the outstanding balance of the lease liability. The right of use asset is depreciated over the shorter period between the useful life of the asset and the lease contact duration. The assets and liabilities arising from the lease are initially valued at present value. Lease liabilities include the net present value of the following lease payments:
• fixed payments (including in-substance fixed payments),
• variable lease payment that are based on an index or a rate, which are initially measured using the ratio or interest rate at the date of commencement of the lease term
• amounts expected to be payable by the lessee under residual value guarantees,
• the exercise price of a purchase option if the lessee is reasonably certain to exercise that option, and
• payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that option.
The lease payments are discounted using the lessee’s incremental borrowing rate, being the rate that the lessee would have to pay to borrow the funds necessary to obtain an asset of similar value in a similar economic environment with similar terms and conditions. After their initial measurement, lease liabilities are increased by the finance cost and reduced by the lease payments. The lease liability is remeasured to reflect any reassessment or lease modifications or to reflect revised in-substance fixed lease payments.Page 393 από 437

PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

The Company elected to use the on-going recognition exemptions for lease contracts that, at the commencement date, have a lease term of 12 months or less and do not contain a purchase option (short-term leases), and lease contracts for which the underlying asset is of low value (low-value assets). Payments associated with short-term leases and leases of low-value assets are recognized on a straight- line basis as an expense in profit or loss. Finally, the Company chose not to separate the non-lease components from lease components, and instead account for each lease component and any associated non-lease components as a single lease component for all classes of underlying assets to which the right of use relates.

Right-of-use assets are measured at cost comprising the following:
* the amount of the initial measurement of lease liability,
* any lease payments made at or before the commencement date less any lease incentives received,
* any initial direct costs, and
* an estimate of costs to be incurred by the lessee in dismantling and removing the underlying asset, restoring the site on which it is located or restoring the underlying asset to the condition required by the terms and conditions of the lease, unless those costs are incurred to produce inventories. The lessee incurs the obligation for those costs either at the commencement date or as a consequence of having used the underlying asset during a particular period. The Company presents the rights of use of the assets of the assets, which are not investment properties, in the account "Right of use assets".

ii. Company as lessor
The leases in which the Company is a lessor relate solely to sub-leases and are classified as finance or operating. The Company's sub-lease agreements at 31 December 2025 and 2024 relate exclusively to operating leases. Revenue from rental income arising, from operating leases, is accounted for on a straight-line basis over the lease terms. The Company reflects the future tax impacts of leases and recognises deferred tax. When recognising deferred tax the Company has assessed the lease asset and lease liability together as a single or ‘integrally linked’ transaction and assessed the net temporary difference.

iii. Concession Agreement to PPA S.A.:
In persuasion of the 35th article of 2932/2001 Law, Greek Government and the Company signed on 13.2.2002 the Concession Agreement, by which the Greek State transfers its exclusive right of use and exploitation of port zone lands, buildings and facilities of Piraeus Port to the Company. This concession was agreed for fixed period initial duration of 40 years, beginning on the day the agreement and ending on 13.2.2042. The initial duration is possible to be extended once or several times by Law and a new written agreement and modification of the 4.1 article of the Concession Agreement.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

With the Common Ministry Decision (CMD) no. 8322/3-12-2008, published in Government Paper 2372/21-11-2008, the Concession Agreement duration has been modified from 40 to 50 years, beginning on the 13/2/2002 (initial signature date) and ending on the respective date of the year 2052.

Management has examined whether the contract for the concession of the exclusive right to use and exploit land, buildings and facilities at the Port of Piraeus Land Zone fall under the scope of the provisions of Interpretation 12. Management concluded that the concession does not fall under the scope of application of Interpretation 12, but meets the definition of a lease under IFRS 16. Therefore, the Concession Agreement is accounted for in accordance with the Company's accounting policies for leases where the Company acts as a lessee.

Government has received 1% of the Company’s consolidated annual income for each of the first 3 years of the concession. The above percentage has increased to 2% of the Company’s consolidated annual income after the 3rd year, on the same calculation basis. Based on the new Concession Agreement signed on 24.6.2016 the percentage to Greek State has increased to 3.5% of the Company’s consolidated annual income excluding finance income with fixed minimum fee amounted to € 3.5 million. As of 1/1/2019, following the adoption of IFRS 16, the minimum guaranteed consideration of the Concession Agreement is included in the calculation of the lease liability and the related right-of-use assets (Note 5). The variable part of the consideration, which is calculated as a percentage of the Company's annual consolidated revenues, is not included in the measurement of the lease liability and is recognized in the results of the period in which it arises.

The Company’ s most significant obligations arising from this agreement are:
* Constant rendering of port services
* Responsibility for the installation, improvement and maintenance of the security level in Piraeus Port
* Ensure fair deal to all port users
* Payment of maintenance expenditure for all the property included in the Concession Agreement.

The Concession Agreement was amended by Law 4838/2021, Government Gazette 180A/ 01.10.2021 and the main points are the following:
* non-imposition of liquidated damages for the non-time completion of the first mandatory enhancements under article 16 of the concession agreement par 5 (a) (i)
* extension of the first investment period for five (5) years
* possibility of suspension of the first investment period - establishment of an amicable settlement mechanism - possibility of replacing of the first investment period
* non-imposition of liquidated damages against PPA in case of suspension
* extension of the second investment period

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

  • introduction of a flexible procedure for the approval of final studies and non-mandatory PPA investments
  • extension of the grace for the partial achievement of minimum levels of services

(p) National Insurance Programs:
The obligation for main or supplementary pension provision is covered by the main National Insurance Department (EFKA- Social Insurance Institute) which concerns private sector and provides retirement, medical and pharmaceutical services. Each employee is obliged to contribute part of his salary to the National Insurance Department, while part of the total contribution is paid by the Company. On employee retirement the National Insurance Department is responsible for their pension payments. Therefore, the Company has no legal or presumed obligation for future payments according to this program. The employees of PPA are entitled upon retirement an allowance from the Unified Fund for Supplementary Benefits and Lump-sum Benefits (ΕΤΕΑΕP) according to the statutory provisions of the Fund and the Law N. 2084/92. For the two welfare sectors, dockworkers and employees of PPA, the granted amount is currently determined on the basis of the provisions of article 35 of Law N.4387 / 12-05-2016 (FEK 85A), considering the average of the total remuneration – without accounting holiday bonus - on which were calculated social insurance contributions for welfare for the five-year period 2009-2013 and with the employee's work year experience until 31/12/2013. To this amount is added the total of insurance contributions for welfare from 01/01/2014 and afterwards. Every employee is required to contribute a part of his monthly salary to the fund, while part of the total contribution is covered by the Company. This fund is a legal public company and is responsible for paying the above benefits to employees. Consequently, the Company has no legal or constructive obligation to pay future benefits under this plan.

(q) Earnings per Share:
Earnings per share are calculated by dividing the financial period net profit, corresponding to ordinary shareholders, by the weighted average number of ordinary shares issued. The accompanying financial statements did not include any profit decreasing bonds or other stock, convertible to shares. Consequently, diluted earnings per share were not calculated.

(r) Dividends:
Dividends are accounted for when receipt rights are finalized by the resolution of the shareholders general meeting.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

(s) Concession Agreement of Piers II and III:
The Law 3755/2009 ratified by the Parliament ruled the concession of use and operation of Piers II and III between the Company and COSCO Pacific Ltd. The contract term provided for 35 years. The Concession Agreement entered into force on 1/10/2009 and till 31/5/2010 the operation of Pier II was provided by the staff of the Company as a subcontractor. Within this period the project in Pier I, which was constructed by the Company, was completed and started its operation by providing services directly to Company’s clients. The Agreement B’ Modification of the original Concession Agreement (GG 52 / 30.03.2009) between the Company and Piraeus Container Terminal (PCT S.A.) following the 'Practical Process Amicable Settlement', has been published in the Government Gazette 269 / 24.12.2014. Under the Concession Agreement a payment of guaranteed consideration was foreseen, until 31.12.2021, which was replaced by the payment of Variable consideration that arises as a percentage on consolidated revenues of PCT SA from the previous contract year. In addition, it is envisaged by the Concession Agreement the calculation of fixed consideration I & II is adjusted regarding the length of exploitation and the corresponding sq.m (Note 25).The concession consideration is calculated and recognized in income for the period in accordance with the terms of the contract and considered as lease contract based on IFRS 16 (Notes 2c and 3o(iii)). The payment of Variable Consideration is performed on a monthly basis in arrears and the payment of the standard exchange every six months in advance (Note 26).

(t) Benefits that depend on the value of share and are settled in cash: The Company in accordance with IFRS 2 measures the services it obtains and the liability it undertakes at the fair value of the liability. Until the settlement of the liability, the entity shall remeasure the fair value of the liability at the reporting date as well as at the settlement date, and any changes in fair value are recognized in profit or loss for the period. The obligation is measured, initially and at each reporting date until the final settlement, at the fair value of the units on the increase in the share price from the grant date and the respective redemption date, with the application of a valuation model taking into account the terms and conditions under which the units have been granted. The fair value of the long-term reward plan was determined using the Binomial model taking into account the share price, the expected volatility of the share, the dividend yield as well as the free interest rate and the liability is recognized in other long-term liabilities.

(u) Foreign Currency Conversion: All the operations of the Company are all performed in Euro. Transactions made in foreign currencies are converted into Euro using exchange rates effective at transaction date. Receivable and liabilities in foreign currency are adjusted at the financial statements preparation date in order to state the exchange rates effective at that date. Gains or losses arising from these adjustments are included in the Statement of comprehensive income as foreign exchange gains or losses.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

Changes in accounting policies and disclosures

The standards/amendments that are effective and have been endorsed by the European Union

The accounting policies adopted are consistent with those of the previous financial year, except for the following IFRS Accounting Standard which has been adopted by the Group/Company as of 1 January 2025:

  • IAS 21 The Effects of Changes in Foreign Exchange Rates: Lack of Exchangeability (Amendments). The amendments are effective for annual reporting periods beginning on or after January 1, 2025. The newly adopted IΑS Accounting Standard did not have a material impact on the Group’s/Company’s accounting policies.

Standards that have been issued but are not effective in the current accounting period and the Company has not adopted earlier

Standards/amendments that are not yet effective, but have been adopted by the European Union

  • IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures - Classification and Measurement of Financial Instruments (Amendments). In May 2024, the IASB issued amendments to the Classification and Measurement of Financial Instruments which amended IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures and they become effective for annual reporting periods beginning on or after January 1, 2026, with earlier application permitted. Management has assessed that these amendments will not have a material impact.
  • IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures - Contracts Referencing Nature-dependent Electricity (Amendments). In December 2024, the IASB issued targeted amendments for a better reflection of Contracts Referencing Nature-dependent Electricity, which amended IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures and they become effective for annual reporting periods beginning on or after January 1, 2026, with earlier application permitted.
  • Annual Improvements to IFRS Accounting Standards – Volume 11. In July 2024, the IASB issued Annual Improvements to IFRS Accounting Standards – Volume 11. An entity shall apply those amendments for annual reporting periods beginning on or after January 1, 2026. Earlier application is permitted. The Company’s Management is currently assessing the potential impact of the implementation of the above standards, which at this stage are not expected to have a material impact.

Standards/amendments that are not yet effective and have not yet been endorsed by the European Union

  • IFRS 18 Presentation and Disclosure in Financial Statements. IFRS 18 introduces new requirements on presentation within the statement of profit or loss. It requires an entity to classify all income and expenses within its statement of profit or loss into one of the five categories: operating; investing; financing; income taxes; and discontinued operations. These categories are complemented by the requirements to present subtotals and totals for ‘operating profit or loss’, ‘profit or loss before financing and income taxes’ and ‘profit or loss’.
    It also requires disclosure of management-defined performance measures and includes new requirements for aggregation and disaggregation of financial information based on the identified ‘roles’ of the primary financial statements and the notes. In addition, there are consequential amendments to other accounting standards. IFRS 18 is effective for reporting periods beginning on or after January 1, 2027, with earlier application permitted. Retrospective application is required in both annual and interim financial statements. The standard has not yet been endorsed by the EU. In subsequent reporting periods, Management will analyze the requirements of this new standard and evaluate its impact.
  • IFRS 19 Subsidiaries without Public Accountability: Disclosures (including amendments) In May 2024, the IASB issued IFRS 19 – Subsidiaries that are not Public Interest Entities: Disclosures, while in August 2025 the IASB issued amendments to IFRS 19. IFRS 19 (including the amendments) is effective for annual reporting periods beginning on or after 1 January 2027, with earlier application permitted. The Company’s Management has assessed that these amendments will not have a material impact.
  • IAS 21 The Effects of Changes in Foreign Exchange Rates: Translation to a Hyperinflationary Presentation Currency (Amendments). In November 2025, the IASB issued amendments to Presentation of Transactions in Hyperinflationary Economies, which amend IAS 21 “The Effects of Changes in Foreign Exchange Rates”, and which are effective for annual reporting periods beginning on or after January 1, 2027, with earlier application permitted. The Company’s Management has assessed that these amendments will not have a material impact.
  • Amendment in IFRS 10 Consolidated Financial Statements and IAS 28 Investments in Associates and Joint Ventures: Sale or Contribution of Assets between an Investor and its Associate or Joint Venture. In December 2015, the IASB indefinitely postponed the effective date of this amendment, pending the outcome of its work on the equity method of accounting.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

4. PROPERTY, PLANT & EQUIPMENT

Property, plant and equipment are analysed as follows:

The Company’s property, plant and equipment are insured with various insurance companies. Insurance covers compulsory insurance of transport vehicles and machinery up to 30.11.2026 as well as general civil liability up to 15.03.2026, employer liability up to 13.11.2026, civil liability of executives until 30.07.2026, as well as property insurance up to 16.05.2026 and floating tanks insurance up to 15.03.2026.

During the year ended December 31, 2025 the total investment in property, plant and equipment amounted to € 110,860,524.51 (01.01.2024-31.12.2024 € 60,398,016.25) and related mainly to the purchase of machinery and other equipment as well as port infrastructure. In the current year, the Company made payments of € 110,569,889.10 (01.01.2024-31.12.2024: € 58,818,045.59) to suppliers relating to investments in tangible fixed assets. Fixed assets under construction amounting to € 220,389,951.40 mainly include projects in progress as part of the Company's mandatory investments. During the current year, the transfers to buildings and building facilities, vehicles/floating tanks, and other equipment from fixed assets under construction include an amount of € 2,595,608.66 relating to projects for upgrading of floating tanks and technological equipment, as well as € 619,019.96, which includes the construction of infrastructure for the improvement of building and mechanical equipment.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

During the previous year, transfers to buildings-buildings installations from assets under construction include an amount of € 23,422,919.03 relating to the project "Expansion of the Car Terminal (Herakleous)" which was delivered on January 16$^{th}$, 2024. During the current year, the Company capitalized the general borrowing cost which was related to loan interest and loan guarantee costs, amounted to € 255,319.98 and € 35,315.49 respectively (31.12.2024: € 1,371,961.68 and € 208,008.96 respectively), which are mainly included in the fund " Asset under construction " at the end of the year (note 3(g)). These amounts were calculated based on an average capitalization rate which corresponds to the weighted-average interest cost, which was 0.9% in 2025 (2024: 6.00%).Property, plant and equipment are tested for impairment when there are indicators that the carrying amounts may not be recoverable. (note 2.c.1(vii)& 24). During the current year, there were no indications of impairment of the tangible fixed assets and therefore the Company did not proceed with an impairment test. There is no property, plant and equipment that has been pledged as security.

5. RIGHT OF USE ASSETS – LEASE LIABILITIES

The recognised right-of-use assets and lease liabilities as at December 31, 2025 and December 31, 2024 are as follows:

As at 31.12.2025 As at 31.12.2024
Right-of-use assets
Cost 31,539,478.90 31,539,478.90
Accumulated depreciation (9,836,325.27) (8,989,571.27)
Net carrying amount 21,703,153.63 22,549,907.63
Lease liabilities
At present value 28,404,261.62 29,230,140.86

Regarding the recognized right of use assets from the concession of the Greek State, see accounting principle (3o(iii)).

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

The amounts recognized in the statement of comprehensive income and the movement of the right of use of assets and the lease liability from 1 January 2025 to 31 December 2025 as well as the corresponding period last year are as follows:

Movement of right-of-use assets Movement of Lease Liabilities
Year ended 31.12.2025 Year ended 31.12.2024
Carrying amount at beginning of year 22,549,907.63 23,512,187.26
Additions due to new leases - -
Additions due to modification - -
Amortization/Depreciation charge (846,753.64) (962,279.63)
Interest expense - -
Payments - -
Carrying amount at end of year 21,703,153.99 22,549,907.63

Lease expense less than 12 months for 2025 amounted to € 483,047.10 (31.12.2024: € 303,979.55) and is included in expenses and specifically in the lines “Payroll and employee related costs” and “Third- party services” (Note 26).

The most important contract signed by the Company is that with the Greek State for the concession of the exclusive right to use and exploit the land, buildings and facilities of the land port zone of the Port of Piraeus (“Greek State Concession”), until 13/2/2052, against a consideration calculated on the annual revenue of the Company, with a minimum annual consideration of € 3.5 million. The minimum annual consideration is accounted for in accordance with the requirements of IFRS 16. The Company's contractual obligation to pay consideration to the Greek State amounts to € 9,002,454.37 as of December 31, 2025 (31.12.2024: € 8,321,446.24) and was calculated as a percentage of 3.5% of the total revenue of the current period excluding financial income, and includes the proportion of the minimum annual consideration, as well as the variable amount of consideration in each reporting period (Notes 22 & 26).

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

6. INVESTMENT PROPERTY

The movement of investment property for ended December 31, 2025 and their balance as at 31.12.2025 was as follows:

Cost Accumulated Depreciation Net Carrying Amount
Balance at 01.01.2025 8,246,723.39 (2,143,863.64) 6,102,859.75
Additions - - -
Disposals - - -
Depreciation charge - (156,599.02) (156,599.02)
Balance at 31.12.2025 8,246,723.39 (2,300,462.66) 5,946,260.73

The movement of investment property for ended December 31, 2024 and their balance as at 31.12.2024 was as follows:

Cost Accumulated Depreciation Net Carrying Amount
Balance at 01.01.2024 8,246,723.39 (1,987,264.62) 6,259,458.77
Additions - - -
Disposals - - -
Depreciation charge - (156,599.02) (156,599.02)
Balance at 31.12.2024 8,246,723.39 (2,143,863.64) 6,102,859.75

Investment property includes seven land plots and two buildings (commercial spaces and schools) located in Athens and Piraeus. There is no investment property that has been pledged as security.

The fair value of investment property as at December 31, 2025 amounted to € 6.3 million (December 31, 2024: € 6.1 million) according to the valuation of an independent appraiser. The fair value measurement is based on the income approach method combined with the comparative sales and market approach method

The investment properties are leased with operating leases and the income from rent for the above investment property for the year ended December 31, 2025 and December 31, 2024 amounted to € 22,709.07 and € 21,162.08 respectively and is included in other operating income (Note 27).

For the years ended December 31, 2025 and 2024 there were no repair and maintenance costs for investment property.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

7. INTANGIBLE ASSETS

The movement of intangible assets for ended December 31, 2025 and their balance as at 31.12.2025 was as follows:

Cost Accumulated Amortization Net Carrying Amount
Balance at 01.01.2025 10,247,616.57 (1,917,385.89) 8,330,230.68
Additions 1,973,301.14 - 1,973,301.14
Amortization charge - (848,002.47) (848,002.47)
Balance at 31.12.2025 12,220,917.71 (2,765,388.36) 9,455,529.35

The movement of intangible assets for ended December 31, 2024 and their balance as at 31.12.2024 was as follows:

Cost Accumulated Amortization Net Carrying Amount
Balance at 01.01.2024 9,857,123.48 (1,069,383.42) 8,787,740.06
Additions 390,493.09 - 390,493.09
Amortization charge - (848,002.47) (848,002.47)
Balance at 31.12.2024 10,247,616.57 (1,917,385.89) 8,330,230.68

During the current year, the Company made payments of € 1,973,301.14 (01.01.2024-31.12.2024: € 390,493.09 ) to suppliers related to investments in intangible fixed assets.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

8. ADVANCES AND OTHER NON-CURRENT ASSETS

This account consists of the following:

31.12.2025 31.12.2024
Advances to suppliers 16,729,244.35 18,554,259.64
Other non-current assets 367,257.89 12,650.00
Total 17,096,502.24 18,566,909.64

The total "Advances to suppliers" refers to the unamortized balance of advance payments that have been given to suppliers for the construction of investment projects of significant value, which advance payments are reduced by the amount of the 5% withholding on the issued invoices related to the execution of their work, in accordance with the signed contracts.

The item is analyzed as follows:

  • Project " Expansion of the cruise Passenger Port"
    During 2020, an advance payment of € 5,147,718.36 was given to a supplier for the commencement of work for the project. On 31 December 2020, the amount of withholding amounted to € 394,632.51 and the respective receivable amounted to € 4,753,085.85. As of December 31, 2021, the amount of withheld on the issued invoices, amounted to € 840,996.55 and the balance of the receivable amounted to € 3,912,089.30. In previous year an amount of € 134,593.03 was withheld on the value of the invoices issued and the balance of the receivable amounted to € 3,777,496.27. In previous fiscal year, an additional advance of € 4,771,785.90 was given for the implementation of additional future works, which is not subject to withholding. Also, during the previous fiscal year, an additional advance payment of € 5,000,000.00 was given. During the current fiscal year, an amount of €394,901.14 was withheld from the value of the invoices issued, and the balance of the receivable amounted to €13,154,381.03.

  • Project " Improvement of Infrastructure of the Ship Repair Zone"
    During 2021, an advance payment of € 941,444.13 was given to a supplier for the commencement of work for the project. On 31 December 2021 the amount of withholding amounted to € 18,212.91 and the respective receivable amounted to € 923,231.22. In previous year an amount of € 30,149.32 was withheld on the value of the invoices issued and the balance of the receivable amounted to € 893,081.90. During 2023, an amount of € 225,121.52 was withheld on the value of the invoices issued and the balance of the receivable amounted to € 667,960.38. During the previous year an amount of € 86,666.94 was withheld on the value of the invoices issued and the balance of the receivable amounted to € 581,293.44. During the current fiscal year, an amount of €95,058.37 was withheld from the value of the invoices issued and the balance of the receivable amounted to €486,235.07.

  • Project “Underground road connection of Car Terminal with ex-ODDY "
    In previous year an advance payment of € 320,815.00 was given to a supplier for the commencement of work for the project. On 31 December 2022 the amount of withholding amounted to € 71,277.66 while the respective receivable amounted to € 249,537.34. During the previous year an amount of € 82,153.69 was withheld on the value of the invoices issued and the balance of the receivable amounted to € 167,383.65. During the previous year an amount of € 60,033.34 was withheld on the value of the invoices issued and the balance of the receivable amounted to € 107,350.31. During the current fiscal year, an amount of €55,816.45 was withheld from the value of the invoices issued and the balance of the receivable amounted to €51,533.86.

  • Project “Dredging of port”
    In previous year, an advance payment of € 306,416.23 was given to a supplier for the commencement of work for the project. During the previous year an amount of € 97,396.10 was withheld on the value of the invoices issued and the balance of the receivable amounted to € 209,020.13. During the current fiscal year, an amount of € 133,700.85 was withheld from the value of the invoices issued and the balance of the receivable amounted to € 75,319.28.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

9. INCOME TAX (CURRENT AND DEFERRED)

With Law 4799/2021 the income tax rate amounded to 22% for the financial income of the fiscal year 2021 and afterward.

The amount of income taxes which are reflected in the statements of comprehensive income are as follows:

31.12.2025 31.12.2024
Current income tax 23,175,256.55 23,283,750.52
Deferred income tax (3,725,768.30) (646,590.80)
Total income tax expense 19,449,488.25 22,637,159.72

The payments made for the income tax liability for the current year amounted to € 25,639,618.39 and concerns to the last two installments of the income tax declaration of the year 2022 amounted to € 8,088,404.23, six installments of the income tax declaration of the year 2024 amounted to € 17,551,214.16.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

The reconciliation of income taxes reflected in statements of income and the amount of income taxes determined by the application of the Greek statutory tax rate to pretax income is summarized as follows:

31.12.2025 31.12.2024
Profit before income tax 114,024,112.73 115,784,811.54
Income tax at statutory rate (22%) 25,085,304.80 25,472,658.54
Tax effect of permanent differences:
Non-deductible expenses 163,071.08 213,194.88
Tax exempt income (6,492,772.55) (7,119,677.14)
Deferred tax recognized on temporary differences (2,250,115.08) 1,130,983.44
Tax losses utilized (5,374,998.99) (1,059,300.00)
Income tax expense 19,449,488.26 22,637,159.72

Greek tax laws and regulations are subject to interpretations by the tax authorities. Tax returns are filed annually but the profits or losses declared for tax purposes remain provisional until such time, as the tax authorities examine the returns and the records of the taxpayer and a final assessment is issued. Tax losses, to the extent accepted by the tax authorities, can be used to offset profits of the five fiscal years following the fiscal year to which they relate.

Tax Compliance certificate: The Company has received tax compliance certificates with agreement from its statutory auditor for each fiscal year from 2011 to 2022 in accordance with Greek tax legislation (2011 - 2013 in accordance with the provisions of article 82 of Law 2238/1994 , 2014 - 2022 in accordance with the provisions of article 65A of Law 4174/2013 and for the years 2023 -2024 in accordance with the provisions of articles 78 and 83 par. 54 of Law 5104/2024.Unaudited fiscal years are analyzed below. It is noted that on 31.12.2025 the years up to 31.12.2019 were time-barred in accordance with the provisions of paragraph 1 of article 36 of Law 4174/2013. For the fiscal year 2025, the audit of the tax compliance certificate (in accordance with the provisions of articles 78 and 83 par. 54 of Law 5104/2024) is in progress and the Company’s Management estimates that no significant differences will arise from this audit. The audit is expected to be completed after the publication of the financial statements for this year.

Open tax years: With the numbers 444/2/1118 of December 14, 2021 and 445/1/1118 of October 9, 2021, the Company was notified of the partial and full audit order from the General Directorate of Tax Administration (Large Enterprises Audit Center) for the periods 1/1/2020-31/7/2021 and 1/1/2016-31/12/2019, respectively.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

Following the above audit orders, on December 29, 2022, the Company was served with the final act of corrective determination/imposition of an income tax fine for the tax year 2016, which resulted in additional income tax and fines of € 6,345,212.94 and € 3,172,606.47 respectively. In addition, relevant surcharges of € 3,057,123.59 were determined.

On December 19, 2023, the final deed of corrective determination/imposition of income tax fine and other taxes for the tax year 2017,2018 and 2019 was given to the Company (No 154,155,156,157,158,159,160 & 161 with issued date 19.12.2023), resulting in additional total income tax and fines amounting to € 5,213,169.54 and € 3,411,851.56 respectively. In addition, relevant surcharges amounting to € 2,424,132.62 were determined.

The Company, disputing the above final deed of corrective determination/imposition of income tax fine, proceeded to appeal against to the General Directorate of Tax Administration for all of the deeds, having previously paid and recognize in the income statement, the total additional income tax and fines, as well as the corresponding surcharges corresponding to the above acts.

The Company received the decisions of the Head of the Dispute Resolution Division of the Independent Authority for Public Revenue (AADE) with decision numbers 1423, 1424, 1425, 1426, 1428, & 1429 dated 14 May 2024, where it was decided to reject the claims filed on 18.1. 2024 and the ratification of the (original - as above) Final Corrective Determination Acts Taxes / Fines of the Head of the CEMEP, re-determining the final tax liabilities - amounts to be charged based on the present decisions, which resulted in a lower amount of fines of € 340.354,99.

The Company, continuing to challenge the entirety of the above decisions of the Head of the Dispute Resolution Division of the ADEA, has proceeded to file an appeal before the competent Administrative Courts for the entirety of these decisions within the legal deadline.

Regarding the income tax for the year 2016, the Administrative Court of Appeal of Piraeus (Decision A2225/2025) deemed it necessary to postpone the issuance of a final decision and obliged the Head of KEMEEP to submit to the Court Secretariat, within ninety (90) days from the performance of this decision (9/2/2026), additional supporting material for the relevant findings in order to ensure the unity and completeness of its judgment. Following this, the Court set a new hearing for the Company's appeal on September 18, 2026.

Regarding the Company's appeal for the stamp duties for the years 2018 and 2019, which was heard on the Administrative Court of First Instance of Piraeus during the trial on November 15, the aforementioned Court issued decision number 2456/2025, which referred the case to the Head of the Dispute Resolution Directorate (D.E.E.), in order for the competent audit bodies to conduct a re-audit and submit a new report to the Court Secretariat within a period of four (4) months from the issuance of the decision. A trial is expected to be for the re-discussion of the appeal.

Regarding VAT for the years 2017 and 2018, the Company's appeal was discussed on 11/2/2025 before the Administrative Court of First Instance of Piraeus and the issuance of the relevant decision is expected. Also, the Company's appeals regarding the income tax for the tax years 2017 and 2018 were discussed to the Administrative Court of First Instance of Piraeus on 28/5/2025 and the relevant decision is expected.

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In addition, regarding the income tax for the tax year 2019 as well as the time-barred dividends for the tax year 2017, the Company's appeals have been discussed on the Administrative Court of First Instance of Piraeus on 12/11/2025 and 10/12/2025 and the relevant decisions are expected.

Also a partial tax audit took place, based on the above audit order for the period 1/1/2020 – 31/7/2021, concerns the types of taxation: VAT, Other Taxes, Fees Contributions, Audit of Correct Bookkeeping and Issuance of Data, were submitted to the Company on February 28, 2024 by the General Directorate of Tax Administration (Large Business Control Center) the Reports of a Partial On-Site Audit for the above taxable items, where no difference was found.

Additionally, for the remaining unaudited fiscal years of the Company that ended on December 31, 2020 up to and including December 31, 2025 for the purpose of income tax, as well as the unaudited period 1/8/2021 – 31/12/2025 for the remaining items of taxation, the Company's Management also estimates that no significant fines and surcharges will arise.

It is noted that, in accordance with the provisions of paragraph 1 of article 36 of Law 4174/2013, as of 31.12.2025, tax years up to and including 31.12.2019 have expired. Nevertheless, the Company is subject to pending appeal proceedings before the competent authorities against corrective tax assessments and fines issued for the years 2016–2019, as above.

Deffered tax asset: The movement of the deferred tax asset is as follows:

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

The movement of deferred tax assets/liabilities as at December 31, 2025 and 2024 is as follows:

10. INVENTORIES

Inventories are analysed as follows:

Description 31.12.2025 (€) 31.12.2024 (€)
Raw materials 72,755.47 73,199.42
Finished goods 2,375,612.13 2,731,399.70
Total Inventories 2,448,367.60 2,804,599.12

Inventory consumption cost for the year ended December 31, 2025 and 2024 amounted to € 2,409,365.29 and € 2,709,330.25 respectively (Note 26). Inventories are valued at the lower value between their cost and net realizable value.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

11. TRADE AND OTHER RECEIVABLES

This account is analysed as follows:

Description 31.12.2025 (€) 31.12.2024 (€)
Trade receivables 14,793,778.53 16,166,375.33
Personnel loans 817,447.84 817,276.67
Other receivables 3,694,505.74 3,130,210.37
Grant receivable - 4,598,471.00
Interest receivable 360,948.00 407,151.22
Total Trade and Other Receivables 19,666,679.11 25,119,413.59
Less: Allowance for doubtful trade receivables (10,439,269.58) (10,887,977.22)
Net Trade and Other Receivables 9,227,409.53 14,231,436.37

Personnel loans: The Company provides interest-free loans to its personnel. The loan amount per employee does not exceed approximately € 3,000.00 and loan repayments are made by withholding monthly instalments from the employee salaries.

Other receivable: Other receivable is included a claim from the Greek State (VAT) of the amount of € 1,946,367.97 (31.12.2024: € 1,178,501.80) as well as various claims from third parties and the Municipality of Drapetsona amounting to € 1,762,906.20 (31.12.2024: € 1,951,708.57). For the claim of the Municipality of Drapetsona, a provision amounted to € 1,740,149.52 has been recorded, during the previous years.

Grant receivable: The grant receivable for the previous year concerns the outstanding balance from the Attica Regional Fund (Special Program Management Service "Attica") of the approved grant for the project "Expansion of the Passenger Port for cruise ship ”(Note 16), which was collected during the current year.

Interest receivable: Mainly concerns interest receivable by time deposits of the Company (Note 28).

The movement of the allowance for doubtful trade receivables is analysed as follows:

31.12.2025 (€) 31.12.2024 (€)
Opening balance 10,887,977.22 15,691,753.81
Reversals/(additions) - Net (448,707.64) (4,776,008.18)
Impairment recognized during the year - 649,084.75
Trade receivables written off - 3,066,449.78
Closing balance 10,439,269.58 10,887,977.22

Trade receivables are normally settled on 10 days’ terms. A single customer (Piraeus Container Terminal S.A.) represents 36,8% of the Company’s total revenue (31.12.2024: 35,7%). The outstanding amount of this customer as at December 31, 2025 amounted to € 0.01 million (31.12.2024: € 2.2 million) (Note 33).

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

For trade receivables and other receivables, the Company has calculated estimated credit losses (ECLs) based on lifetime expected credit losses. Taking into consideration that trade receivables are normally settled within 10 days from the issuance of the invoice, the risk of default and the expected loss rate of 0.52% (31.12.2024:0.67%) have been determined by management, based on historical data, for all balances that are outstanding for less than 10 days (no overdue balances). Regarding the outstanding balances above 10 days, the Company has considered the risk of default, the days past due and the historical credit losses experienced adjusted to reflect current and forward-looking information per debtor to measure the expected credit losses for each individual trade receivable balance. The provision used for the previous year relates mainly to the write-off of old customer balances of the Company following a decision of the Management in the total amount of € 4,843,776.59, which were impaired in previous years by € 4,776,008.18. The provision used for the current year mainly concerns write-off of old customer balances of the Company following a relevant decision by Management in the total amount of € 709,377.87, which had been impaired in previous years by an amount of € 649,084.75.The Company is actively monitoring the recoverability of trade receivables and ensures that the loss allowance recorded reflects, on a timely basis management’s best estimate of potential losses in compliance with IFRS 9. The ageing analysis of trade receivables (both gross and net of ECLs) for the year ended 31 December 2025 and 2024 is as follows:

Ageing Analysis of Trade Receivables (Gross) 31.12.2025 31.12.2024
Not Past Due 21,182,467.84 22,733,275.64
Past Due up to 90 days 3,784,333.79 2,941,696.22
Past Due 91 - 180 days 2,228,127.78 2,303,847.51
Past Due 181 - 365 days 2,823,131.53 2,681,913.37
Past Due more than 365 days 4,376,885.51 4,455,503.36
Total Trade Receivables 34,394,946.45 35,116,236.10
Less: Expected Credit Losses (ECLs) (6,591,802.12) (6,714,839.63)
Net Trade Receivables 27,803,144.33 28,401,396.47

The ageing analysis of receivables past due more than 365 days applies to claims for which and for their most part, the Company has filed appeals or taken actions for their collectability. The Company's Τop management and legal department review and reassess the relative cases periodically. There is no movement of the allowance for doubtful other receivables and advances to suppliers with a balance amounting to € 2,204,043.54.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

The net impairment losses on financial assets are analysed as follows:

Impairment Losses on Financial Assets 31.12.2025 31.12.2024
Trade Receivables (122,957.51) (192,309.57)
Other Receivables and Advances to Suppliers - -
Total Net Impairment Losses (122,957.51) (192,309.57)

12. PREPAID EXPENSES

Prepaid expenses of current year mainly includes an advance payment of the commission for the guarantee of the paid off loans during the fiscal year, that Company had, amounting to € 1,003,725.70 (31.12.2024: € 1,401,378.68), that is subject to a settlement agreement with the guarantor bank, as well as an advance payment of car/other wheeled vehicle, property and civil liability insurance premiums amounting to € 508,458.57 (31.12.2024: € 325,605.04).

13. CASH AND CASH EQUIVALENTS

Cash and cash equivalents are analyzed as follows:

Cash and Cash Equivalents 31.12.2025 31.12.2024
Cash at Banks 1,235,411.98 1,162,212.74
Short-term bank deposits 90,500,000.00 120,000,000.00
Total Cash and Cash Equivalents 91,735,411.98 121,162,212.74

The Company taking advantage of its strong liquidity and the favorable interest rate conditions that have been created, continued its short-term investments in time deposits with both domestic and foreign credit institutions, with a total value of € 90.5 million (31.12.2024: 120.0 million) with particularly favorable terms for it within the reference period.Cash at banks earns interest at floating rates based on monthly bank deposit rates. Interest earned on cash at banks and time deposits is accounted for on an accrual basis and for the year ended December 31, 2025, amounted to € 2,030,800.65 (31.12.2024: € 5,170,241.47). These amounts are included in the financial income (Note 28).

14. SHARE CAPITAL

Share capital amounts to € 50,000,000.00 is fully paid up and consists of 25,000,000 ordinary shares, of nominal value € 2.00 each. There are neither shares which do not represent Company’s capital nor bond acquisition rights.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

15. RESERVES

Reserves are analysed as follows:

Reserves 31.12.2025 31.12.2024
Statutory Reserve 16,666,666.67 16,666,666.67
Special Tax Free Reserve Law 2881/2001 61,282,225.52 61,282,225.52
Untaxed or specially taxed income reserve 8,197,177.53 8,298,136.83
Taxed reserves Article 72 N.4172/2013 6,087,915.56 6,087,915.56
Taxed reserve with the general provisions 188,760.09 188,760.09
Total Reserves 92,422,745.37 92,523,704.67

Statutory reserve: Under the provisions of Greek corporate Law, companies are obliged to transfer at least 5% of their annual net profit, as defined, to a statutory reserve, until the reserve equals the 1/3 of the issued share capital. The Company has covered the amount required by the law in the previous years. The reserve is not available for distribution throughout the Company activity.

Special tax free reserve Law 2881/2001: This reserve which is exempt from taxation, was created during the conversion of the Company to a Societé Anonyme. The total Company’s net shareholder funds (Equity) was valued, by the article 9 Committee of the Codified Law 2190/1920, at € 111,282,225.52, € 50,000,000.00 out of which was decided by Law 2881/2001 to form the Company share capital and the remaining € 61,282,225.52 to form this special reserve. The above Special Tax-Free Reserve is taxed under the conditions and to the extent provided for in the general provisions, i.e. in the event of its distribution or capitalization.

Untaxed or specially taxed income reserve: This is interest income which was either not taxed or taxed by withholding 15% tax at source. In case these reserves are distributed, they are subject to tax on the general income tax provision basis. Based on Article 72 par.11 of Law 4172/2013 those reserves are subject (from 1 January 2014) to an independent taxation at a rate of 19%. On December 30 th , 2014, the Company proceeded to the taxation of those reserves which amounted to € 1,428,029.58. After the tax deduction created the taxed reserves of Article 72 N.4172 / 2013 and the taxed reserve with the general provisions amounting to € 6,087,915.56 and € 188,760.09 respectively.

16. GOVERNMENT GRANTS

The movement of the account is analyzed as follows:

Movement of Government Grants Amount
Balance at 01.01.2024 39,436,355.79
Grants Received during 2024 19,578,373.83
Grants Amortised during 2024 (5,734,361.97)
Grants Cancelled/Adjusted during 2024 (1,403,824.54)
Balance at 31.12.2024 51,876,543.11
Grants Received during 2025 2,031,627.99
Grants Amortised during 2025 (6,370,759.84)
Grants Cancelled/Adjusted during 2025 (1,714,213.83)
Balance at 31.12.2025 55,823,197.43

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Grants received up to December 31, 2011 relate to the requirements of the Olympic Games of 2004 Olympic Games, amounting to €11,400,000.00, with an unamortized balance as of December 31, 2025 of €1,755,385.32, and, on the other hand, the construction of infrastructure for the creation by OSE S.A. a coastal railway station in the amount of €3,700,000.00, with an unamortized balance as of December 31, 2025, of €1,383,383.68

A grant of € 3,653,518.80 has been received in 2012 and is divided in a) € 2,536,168.80, which relates to the widening of the quay Port Alon and b) € 1,117,350.00 for the construction of new dock at the area of Agios Nikolaos in the central port of Piraeus, under the operational program “Improvement of accessibility-energy” of the Attica region. In accordance with the financial Correction Decision issued by the Special Management Service for the Operational Program of the Attica Region, it was decided during the 2017 to correct the amount of €13,735.39 to correct the grant for the project “Widening of the quay wall at Alon Port, Central Port of Piraeus” , with an unamortized balance as of December 31, 2025, of €1,622,715.36. Furthermore, in accordance with the financial Correction Decision issued by the Special Management Service for the Operational Program of the Attica Region, it was decided during the 2018 to correct the amount of €546,750.77 to correct the grant for the project “Widening of the new quay wall in the Agios Nikolaos area,” with an unamortized balance as of December 31, 2025, of € 437,586.18.

Also, a grant amounted to € 9,901,740.45 has been received in December 2013 and relates to the operational program “Support Accessibility” of the Ministry of Infrastructure, Transport and Network and in particular, in two projects which have been completed, with an unamortized balance as of December 31, 2025, in the amount of €5,797,715.62.

The project “Expansion of the Port of Piraeus to Support Cruise Ship Operations” involves the extension of the Themistocles Pier and the construction of a new pier on the southern side of the main port. This project was initially included by the Attica Regional Operational Program (ROP) in the “Attica 2014-2020” program, co-financed by the European Regional Development Fund, in accordance with Decision No. 403/11-2-2020. With decision A.D. 2580/ 18-10-2024 of the Region of Attica, the project was re-included in the "Attica 2021 - 2027" Program and in the Priority "Strengthening regional interconnection through the promotion of local and supra-local smart and safe mobility". The total approved grant for this project amounts to € 97,703,694.43.

For project “Expansion of the Port of Piraeus to Support the Cruise” under execution, in the previous year a grant of € 19,578,373.83 was approved and paid by the Regional Fund of Attica. As of December 31, 2024, a grant of a total amount of € 6,941,900.58 (Note 11) was pending for collection , which the Company received on 24/3/2025. During the current year, the Company has received a grant of € 2,031,627.99, in addition to the above amount that was outstanding as of 31/12/2024. The total grand regarding project “Expansion of the Port of Piraeus to Support the Cruise”, received as of December 31, 2025 amounted to €28,551,902.39, while no additional amounts were pending collection on the same date.

Grants are considered as future revenue and are recognized in revenue at the same rate at which the subsidized assets are depreciated (Note 29). Grants related to assets under execution are not amortized until the fixed asset is completed and available for its intended productive operation.

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17. RESERVE FOR STAFF LEAVING INDEMNITIES

The relevant provision movement for the financial year ended on December 31, 2025 and the financial year ended on December 31, 2024 is as follows:

Movement of Provision for Staff Leaving Indemnities 2025 2024
Balance at beginning of year 1,893,145.38 1,676,739.47
Expense recognized in P&L 1,050,810.43 299,826.47
Payments made (121,440.00) (93,420.56)
Balance at end of year 2,822,515.81 1,883,145.38

On 31 December 2025, the total cost of the provision for staff leaving indemnities amounted to € 2,821,515.81 (31.12.2024: € 1,893,145.38) and is included in personnel fees and expenses (Note 30). The principal actuarial assumptions used are as follows:

Actuarial Assumptions 31.12.2025 31.12.2024
Discount rate 2.50% 2.80%
Expected rate of salary increase 2.00% 2.00%
Expected rate of increase in social security contributions 0.00% 0.00%
Average employee remaining service period (Years) 11.15 12.43

The assumption of a wage increase concerns all employees, but it only affects the benefit provided for employees who are not included in the Collective Labor Agreements, as the benefit provided by the Collective Labor Agreements for the rest of the employees is independent of the pensionable salary at the time of the retirement.

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A quantitative sensitivity analysis for significant assumption as at December 31, 2025 and December 31, 2024 is as shown below:

Sensitivity Analysis (Impact on Provision) Change in Assumption 31.12.2025 31.12.2024
Discount Rate +0.25% (106,617.54) (98,595.83)
-0.25% 119,872.37 110,260.23
Salary Increase Rate +0.25% 67,495.70 63,025.73
-0.25% (67,495.70) (63,025.73)

The expected cash flows in the future years are analyzed as follows:

Expected Cash Flows 2026 2027 2028 2029 2030 Thereafter Total
Expected cash outflows 367,697.00 388,695.00 401,113.00 415,219.00 428,849.00 1,315,589.81 3,317,162.81

The average duration of the defined benefit plan obligation at the end of the year is 3,75years (2024: 4,0 years).

18. PROVISIONS

The Company has made provisions for various pending legal cases (Note 32) as at December 31, 2025 in total amounting to € 14,646,117.11 (31.12.2024: € 14,338,656.33 ).

Movement of Provisions 31.12.2025 31.12.2024
Provisions recognized in P&L 307,460.78 2,889,659.10
Provisions used (2,570.00) (210,243.00)
Reversals of previous years provisions - (2,890.00)
Re-measurement/Other changes (4,662.06) (72,989.76)
Closing Balance 14,646,117.11 14,338,656.33

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Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

19. LONG-TERM & SHORT TERM BORROWINGS

a) Long-term borrowings:

The long term portion of borrowings as at December 31, 2025 and December 31, 2024 respectively is as follows:

The table below shows the changes in liabilities resulting from financing activities:

The Company's Management decided and proceeded with the early repayment of the above loan obligations of the total amount of € 26,499,999.99 on 7/3/2025, aiming to avoid relevant financial expenses by taking advantage of its strong cash position.

The balance of the account during tle previous year related to the following loans between the Company and the European Investment Bank:

  1. Loan of € 35,000,000.00 for the construction of Container Terminal Pier I to N. Ikonio, issued on 30/7/2008. The balance of the loan ,both on the 7/3/2025 early repayment date and on as at 31 December 2024 amounted to € 8,166,666.59.
  2. Loan of € 55,000,000.00 for the construction of Container Terminal Pier I to N. Ikonio, issued on the 10/02/2010. The balance of the loan ,both on the 7/3/2025 early repayment date and on as at 31 December 2024 amounted to € 18,333,333.40 .

On September 26, 2017 a Guarantee Issuance Facility Agreement was signed between the Company and the ‘’Export Import Bank of China’’, in respect of the issuance of guarantees of an initial amount of € 75,074,999.99 to support the loans from the European Investment Bank outstanding debt. The guarantee bears an issuance fee of zero point six per cent (0.6%) of the relevant maximum guarantee amount, for a period of up to 5 years following the full repayment of the loan obligations.

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On 31 December 2025, the issuance fee amounted to € 397,649.96 (31.12.2024: € 208,008.96 .The above guarantee, in the part that concerns the period that the loans were active, amounted to € 35,315.49 (31.12.2024: € 208,008.96), is included in the general borrowing cost capitalized within the current year (Notes 4).

The total interest on long-term borrowings for the years ended December 31, 2025 and 2024 amounted, for the Company, to € 255,319.80 and € 1,579,970.64 respectively, and is also included in the general borrowing cost which was capitalized within the current year (Notes 4).

b) Short-term borrowings and loan commitments:

On 16.10.2025, an agreement was signed for the increase by €30,000,000.00 of the credit line held by the Company with the National Bank of Greece S.A., which currently amounts to €80,000,000.00 for the issuance of Letters of Guarantee, opening of Letters of Credit and/or financing for Working Capital purposes. The Company now has a credit limit of €53,000,000.00 for Working Capital purposes with the National Bank of Greece S.A., valid until 31 December 2026. The credit limit carries an annual floating interest rate of Euribor, plus margin, plus a contribution of 0.60%.

The Company proceeded to raise an amount of €10,000,000.00 under the Open Account Credit Agreement on 11.04.2025 and proceeded to fully repay the said amount on 30.05.2025. It is noted that the margin on the said available financing line was modified (reduced), effective from 09.05.2025.

On 17.09.2025, a Credit Agreement with an Open (Inter-Debt) Account of up to €50,000,000.00 for Working Capital purposes was signed with Eurobank S.A., valid until February 28, 2026. The credit line bears an annual floating interest rate based on Euribor, plus a margin, plus a 0.60% fee.

20. SUPPLIERS

The balance of suppliers during the current year amounted to € 36.2 million compared to € 27.9 million in the previous year, showing a significant increase of € 8.3 million or 29.7%. This increase is consistent with the Company's enhanced investment activity during the current fiscal year compared to the previous one (Notes 4 & 7), and is mainly due to pricing at the end of the current fiscal year for the "Dredging of the Central Port" project, as well as to other suppliers of construction projects.

21. DIVIDENDS

Dividends related to fiscal year 2024, paid in 2025:

The Annual General Meeting of the Company, which took place on July 8, 2025, approved the proposal of the BoD proposed for the distribution of dividend for the fiscal year 2024 amounted to € 48,000,000.00 or € 1.920 per share. The dividend is subject to withholding tax at the corresponding rate provided by income tax. The dividend for the fiscal year 2024 was paid on August 8, 2025.

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22. ACCRUED AND OTHER CURRENT LIABILITIES

This account is analyzed as follows:

Description 31.12.2025 (€) 31.12.2024 (€)
Taxes Payable
Concession Agreement Liability
Payment in advance
Accrued expenses

Taxes Payable:

Current period’s amount consists of: a) Employee withheld income tax € 2,462,783.78 (31.12.2024 € 1,889,438.75) and b) other third party taxes € 385,200.22 (31.12.2024: € 193,972.89).

Concession Agreement Liability:

The liability relates to the variable amount of annual fee with an equal debit in the expense account “Concession agreement fee” (Note 26) and excludes the fixed minimum annual fee for the current period of € 3,500,000.00. Regardless of the application of IFRS 16, the Company's contractual obligation to pay to the Greek State as at 31 December 2025 amounted to € 9,002,463.63 (31.12.2024: € 8,321,446.24 ) and was calculated as a percentage of 3.5% on the total revenue of the current year excluding financial income.

Payment in advance:

The Company receives payments in advance for services rendered on an ordinary basis, which are then settled on a regular basis. Customer payments in advance amounted to € 5,082,654.77 (31.12.2024: € 5,603,557.57).

Accrued expenses:

Accrued expenses include expenses and services that were provided during the reporting period but had not yet been invoiced. The change in this item mainly stems from accrued construction work of € 10,081,864.40 as of 31 December 2025 (31.12.2024: € 1,435,940.90), which are included in “Assets in progress”.

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23. DEFERRED INCOME

The deferred revenue is analyzed as follows:

Description Non-Current Current Total
As at 31.12.2025
PCT S.A. € 23,871,106.72 € 1,344,851.16 € 25,215,957.88
Fixed Annual Consideration € 0.00 € 3,713,907.78 € 3,713,907.78
Rentals € 0.00 € 84,677.57 € 84,677.57
Total as at 31.12.2025 € 23,871,106.72 € 5,143,436.51 € 29,014,543.23
As at 31.12.2024
PCT S.A. € 25,215,957.88 € 1,344,851.28 € 26,560,809.16
Fixed Annual Consideration € 0.00 € 3,567,277.63 € 3,567,277.63
Rentals € 0.00 € 126,600.79 € 126,600.79
Total as at 31.12.2024 € 25,215,957.88 € 5,038,729.70 € 30,254,687.58

The deferred revenue derives from the following:

a) On April 27, 2009 “PCT S.A.” paid € 50,000,000.00 as a one-off consideration for the use of port facilities of Piers II and III of SEMPO of PPA (N.3755/2009). From the aforementioned amount, € 2,930,211.41 was offset with the cost of supplies and parts provided by PCT S.A., while the remaining amount of € 47,069,788.59 is amortized over the concession period. The initial concession period was thirty (30) years, which was increased to thirty five (35) years, after the completion the construction of the port infrastructure on the east side of Pier III. Following the transfer of the cumulative amount € 21,853,830.71 on revenue of the years 2009 until 2025, in the income of the respective years, the new balance at December 31, 2025 amounted to € 25,215,957.88 (December 31, 2024: € 26,560,809.16 ), of which the short-term part amounts to € 1,344,851.16.

b) The Company receives Fixed Annual Consideration from PCT S.A based on the length and surface of the land under concession. Fixed Annual Considerations is invoiced in advance April and October of each fiscal year. As a result the company has recognized as deferred revenue of € 3,713,907.78, concerning a short-term part (which invoiced in advance in 2025 and relates to the period 1.1.2026-31.3.2026) and € 3,567,277.63 (which invoiced in advance in 2024 and relates to the period 1.1.2025-31.3.2025) as at December 31, 2025 and December 31, 2024 respectively.

c) Additionally as at December 31, 2025, deferred income includes an amount of € 84,677.57, concerning a short-term part (31.12.2024: € 126,600.79) which relates to the deferred income from rentals.

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24. SEGMENT INFORMATION

The Company operates in Greece, regardless of the fact that its clientele includes international companies. Additionally, the Company has no other commercial or industrial activities other than the provision of services solely in the Port area and does not have income or assets from foreign customers (based on the geographical area in which they operate). The port of Piraeus is a port complex activity, putting work in many areas of port activity, such as containers Car-terminal, shipping, cruise, ship repairing, environmental and logistics services. It is the main port of coastal connecting mainland Greece and the islands, the main cruise port service in the country, the main port container, the main car – terminal port of the country. PPA S.A.provides all the requested port services: water, solid and liquid slot tankers, jack residual oil, electricity, fiber optics and internet, victuals, repairs, environmental services and is fully connected to all activities with modern computer systems. The Company's Management considers that there is no market risk for the activities in question, due to the fact that these services are related to financial assets that do not have a risk of fluctuation due to changes in their prices, as they are not traded on the market within the meaning of IFRS 7. The Company does not own any derivative financial instrument related to the mentioned activities, whose value or future cash flows may fluctuate due to changes in market prices. The prices of the services are specific and determined by the respective price lists. The Management of PPA S.A. monitors at the level of results of the above activities and takes business decisions based on the implemented internal management information system. Based on the above and in accordance with the provisions of IFRS 8, the Company has determined to disclose the following segments:
* Container Terminal
* Consession Arrangement Pier II &III
* Car Terminal
* Coasting
* Cruise
* Ship repairing
* Other segments (water supply, space management, merchandise management)

The other segments include activities representing less than 10 % of total revenue and profit in all segments and therefore are not disclosed as separate operating segments. The Company level includes revenues and expenses that are not allocated by operating segment because management monitors them at entity level. The Company's Management regularly monitors the performance of each operating segment and makes business decisions based on the results. Management does not make business decisions and does not monitor periodically the assets and liabilities of the business sectors and for this reason does not make the relevant disclosures as required by the provisions of IFRS 8.

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The segment information for the years ended December 31, 2025 and 2024 is analysed as follows:

EBITDA is used to measure performance because management believes that this information is the most relevant in evaluating the results of the respective segments relative to the segments that operate in the same Company and is the primary measure reviewed by our Chief Operating Decision Maker. Of the Company’s total personnel compensation and expenses for year 2025, approximately 44% relates to the “Container Terminal” business segment.

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25. REVENUES

Revenues are analyzed as follows:

The increase in revenue for the current year compared to the same last year is mainly due to the increase in revenue of loading and unloading by € 7,770,060.35 or 17.4%, of cruise services-main activity by € 5,044,892.80 or 24.8%, as well as in revenue of mooring by € 2,922,536.60 or 17.2%. This increase was partially offset by a decrease in revenue of ferry services-main activity of € 3,375,844.02 or 36.9%, of storage services of € 2,073,685.28 or 10.0%, as well as of total revenues from the ship repair activity (Docking and Ship Repair Services) by € 1,145,882.55 or 7.2%.

The increase in revenue from loading/unloading is mainly due to the activities of the Container Terminal. Throughput at the Container Terminal, Pier I, for the year 2025 reached 664,581 TEUs, recording an increase of 17.9% compared to the corresponding year 2024 (563,725 TEUs). In particular, a significant increase was recorded in domestic cargo (imports and exports) from 232,252 TEUs in 2024 to 254,591 TEUs in 2025 (+9.6%), as well as transshipment cargo by 23.7% from 331,473 TEUs in 2024 to 409,990 TEUs in 2025.

Cruise ship arrivals in 2025 amounted to 862 compared to 810 in 2024, recording an increase of 6.42%. The total number of passengers recorded an increase of 9.68% (1,863,397 passengers) compared to 2024 (1,698,877 passengers). Specifically, compared to 2024, there was an 8.2% increase (1,091,364 passengers compared to 1,008,209 passengers) in homeport passengers and an 11.8% increase (772,033 passengers compared to 690,668 passengers) in transit passengers.

The increase in berthing revenues comes mainly from cruise ships due to an increased number of arrivals, recording an increase of 6.42% compared to the corresponding last year, but also due to a change in the berthing and mooring price (an increase of 15% from that in force in 2024).

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As well as from the increase in the number of RORO ship arrivals at the Car Terminal, recording an increase of 31.1% compared to the corresponding last year.

The decrease in revenue from ferry shipping is mainly because, from May 1, 2025, and for a period of one (1) year, the Company proceeded to reduce the fees for ships and passengers of Ferry Shipping by 50% in accordance with the relevant amendment of the Ministry of Shipping & Island Policy. The amendment has a significant impact on the revenue of the activity for the period of application of the current year, i.e. reduction by an amount of € 3.4 million compared to the corresponding period last year, as well as a decrease of € 1.1 million resulting from the mooring of coastal shipping and included in the "Mooring" item.

The decrease in storage revenues is mainly due to the Car Terminal sector, where despite the increase in cargo, both domestic (31.12.2025: 153,213 vehicles, 31.12.2024: 137,825 vehicles) and transshipment cargo (31.12.2025: 138,074 vehicles, 31.12.2024: 109,775 vehicles), the malfunction of the supply chain (domestic and international) during the previous year, has resulted in a significant increase in the time spent by cargoes at the Company's piers. The resolution of this emergency situation within the current year had a significant impact on in the revenues of storage which amounted to approximately € 11.2 million in 2025 (31.12.2024: € 14.8 million) more than covering the benefit from the increase in other revenues, and mainly the increased levels of handling, leading to the overall decrease in the segment's revenues (Note 24) and more generally the Company's storage revenues.

The decrease in revenues from Docking and Ship Repair Services is mainly due to the reduced overall dynamics of ship repair activity due to repair work on one of the floating docks of PPA that was in progress during the first half of 2025.

The significant increase in revenue from the Pier II + III concession agreement is mainly due to the increase in the variable consideration, which amounted to € 74,215,831.56 (31.12.2024: € 66,009,391.37). The concession consideration is calculated and recognized in income for the period in accordance with the terms of the contract and considered as lease contract based on IFRS 16.

The Company operates in sectors that are highly seasonal. In particular, the revenues of the Cruise sector are significantly concentrated in the third quarter due to increased tourist traffic. At the same time, the ferry shipping activity also shows increased activity during the third quarter, without its seasonality being considered significant in relation to the Company's overall results. It is noted that there is no seasonality in the Company's other activities.

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26. ANALYSIS OF EXPENSES

Expenses (cost of sales and administrative expenses) are analyzed as follows:

In Euro 2025 2024
Payroll and employee related costs 36,189,738.65 31,385,293.74
Third Party Services 7,148,758.06 5,248,580.00
Various Expenses 5,661,988.21 2,973,468.80
Depreciation and Amortization 13,447,114.76 13,300,731.60
Maintenance Costs 2,958,729.81 2,905,646.93
Utilities 3,837,774.51 3,687,845.88
Insurance Expenses 2,426,013.00 2,186,721.02
Leases Expenses 2,003,194.09 2,134,531.32
Audit and Tax Advisory Expenses 235,983.33 241,098.48
Other Expenses 4,948,256.00 4,371,192.34
Total Expenses 78,857,542.42 68,435,119.31

Payroll and employee related costs: The significant increase in payroll and employee related costs during the current year compared to the corresponding period last year is mainly due to the additional incremental increase in payroll of employees and dock workers according to the CBA in force from 1/8/2024 and 1/7/2024 respectively, the implementation from 1/4/2025 of the new Collective Bargaining Agreement of Supervisors & Foremen, as well as the increased employment (hourly wages) of dock workers to serve the organic growth presented in most of the Company's activity sectors in year 2025, as well as the increase in personnel during the current year compared to the previous year.

Third Party Services: The significant increase in third-party fees and expenses during the current year compared to the corresponding last year is mainly due to the increase in the use of external partners, mainly for loading and unloading services, by an amount of approximately € 1.8 million.

Various Expenses: The increase in various expenses during the current year compared to the corresponding last year is mainly due to the increase in cleaning port services expenses by approximately € 1.9 million, as well as in guard fee expenses by approximately € 1.0 million. Additionally, third party services include the fees of the companies “Ernst & Young (Hellas) and "KPMG Certified Auditors S.A." for the years 2025 and 2024 respectively, regarding the services provided related to the statutory audit fees for the financial statements (2025: € 154,000.00 and 2024: € 169,000.00), the tax audit certificate based on article 65A of Law 4174/2013 and POL 1124/18.06.2015 (2025: € 35,000.00 and 2024: € 25,000.00) as well as other non-audit services (2025: € 8,000.00 and 2024: € 47,000.00).

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27.OTHER OPERATING INCOME / EXPENSES

OTHER OPERATING INCOME
The amounts are analyzed as follows:
Rental income concerns land and building rents as well as the investment properties rent (Note 6).

OTHER OPERATING EXPENSES
The amounts are analyzed as follows:
During the current year, in the “Third-party compensation” are mainly included compensations to suppliers for differences which arose from their relevant project contracts with the Company.

28. FINANCIAL INCOME/EXPENSES

The financial income is analyzed as follows:
Interest income on bank deposits mainly concern provisions for interest of time deposits , accrued (Note 11) and finalized that have been concluded both in the previous and current year. This change is due to the decrease to the amount of the time deposits concluded, as well as the relevant interest rates.

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The financial income is analyzed as follows:

29. DEPRECIATION AND AMORTISATION

The amounts are analyzed as follows:

30. PAYROLL AND EMPLOYEE RELATED COST

The amounts are analyzed as follows:

31. EARNINGS PER SHARE

The earnings per share for the years 2025 and 2024 are as follows:

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32. COMMITMENTS, CONTINGENT LIABILITIES AND REQUIREMENTS

(a) Litigation and Claims:
On 31.12.25 the Company is currently involved in several legal proceedings and has various claims against it of a total amount of approximately € 108.3 million (31.12.2024: € 119.9 million), concerning mainly labour disputes and legal proceedings with municipalities around the port, arising in the ordinary course of business. Based on currently available information, Management and its legal department believe that the outcome of these proceedings will not have a significant effect on the Company’s operating results or financial position, except for the recorded provisions in Note 18. These claims concern mainly labour disputes of a total claimed amount of € 86.2 million (31.12.2024: € 86.4 million), disputes with the Greek State of a total claimed amount of € 3,9 million (31.12.2024: € 4.0 million) and disputes with suppliers and others of a total claimed amount of € 18.2 million (31.12.2024: € 29.5 million). The employee labour cases are pending litigations against PPA SA before the civil and administrative courts of all degrees and relate mainly with:
a) claims against PPA for additional compensation for the years 2010 and 2011 for the enforcement of the Agreement between PPA and the labour unions to ensure equal working conditions and renumeration of PPA ‘s employees following the concession of Pier II to PCT SA,
b) claims against PPA for salary reduction based to the laws 3833/2010, 3845/2010 and 4024/2011 cases before the privatization of PPA,
c) claims against PPA for salary reduction based to the laws 3833/2010, 3845/2010 and 4024/2011 cases according after the privatization of PPA SA ,
d) Few labor accidents and
e) various other (pay grade cases, dockworkers’ overtime cases before the privatization period).
Disputes with Greek State concern litigations before the administrative courts of all degrees, having to do with decisions, taxes, charges, fines from Municipalities, Prefecture, Public Service Decisions, Ministerial Decisions, Public Authorities’ Decision etc. The supplier/client dispute cases concern compensation/financial differences between PPA and its suppliers or customers arising in the normal course of business. All other kind of cases that cannot be included to the above two categories are characterized as “other”, for example non labour accident cases, compensation of third parties, real estate cases, lease differences etc. and additionally accounts payable to suppliers. Based on currently available information, Management and its legal department believe that the outcome of these proceedings will not have a significant effect on the Company’s operating results or financial position, except for the recorded provisions in Note 18.

(b) Liabilities arising from letters of Guarantee:
The Company has issued letters of guarantee amounting to € 15,560,341.00 (December 31, 2024: € € 15,560,341.00 ), of which € 495,829.00 (December 31, 2024: € 495,829.00 ) in favor of the General Directorate of Customs (E 'and F' Customs Office) of the Ministry of Economy for the operation of all warehouses for temporary storage of goods PPA S.A. Under the current concession agreement of 24.06.2016 between the PPA and the Greek Government, PPA has issued a letter of guarantee in favor of the Ministry of Finance General Secretariat of Public Property amounted to € 15,000,000.00.

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(c) Commitments for investments based on concession arrangement:
Pursuant to the provisions of the Concession Agreement signed between the Company and the Hellenic Republic dated on 24.06.2016, as ratified by Law 4404/2016 (Gov. Gazette A '126 / 08.07.2016), the Company has the contractual obligation for the implementation of investments in projects within the Port of Piraeus for the five years, August 2016 - August 2021 amounting to € 293.8 million. (First Investment Period) and for the five- year period August 2021–August 2026 amounting to € 56 million (Second Investment Period). The Concession Agreement included specific terms regarding the conditions for the imposition of penal clauses by the Greek State, in case of non-execution of mandatory investments as of August 2021. The possibility of imposing penalties under the Concession Agreement was assessed by Compamy Management during the previous period and was deemed remote, as the Company was able to prove that delays in the execution of mandatory investment projects were outside the Company's reasonable control and therefore fell within the exemption from the imposition of penalties in Article 16.5 (a) (i) of the Contract Concession. This assessment was verified with the agreement of 22/09/2021 Amendment the Concession Agreement between the Company and the Greek State as verified by Law 4838 / 1.10.2021 Government Gazette 180 A ' (Note 3 o(3)). The specific amendment, among others, extends the duration of the First Investment Period, as well as extends the obligation to start and complete the Second Investment Period by five years respectively. As at December 31, 2025, the mandatory investments comprise of and include price revisions:
• completed mandatory investments of € 96.2 million (31.12.2024: € 96.2 million),
• projects under construction € 210.0 million (31.12.2024: € 57.7 million) as well as prepayment for a mandatory investment of € 13.8 million (31.12.2024: € 14.4)

(d) Contractual commitments with creditors:
with regard to (d) above and other contracts signed, the outstanding balance of the contractual commitments with suppliers on significant infrastructure projects (construction, maintenance, improvements, etc.) at December 31, 2025 amounted to approximately € 164.2 million (December 31, 2024: € 154.0 million) of which approximately € 66.4 million relate to the project "Passenger Port Expansion - South Zone - Phase A ' (December 31, 2024: approximately € 68.4 million).

Special Contribution to Social Security Institute (IKA – ETAM):
On November 7, 2011 the Company notified the management of IKA its intention to stop paying the special contribution in favor of the supplementary fund of Company’s employees, since after the merger of IKA with IKA – TEAM Management of the Company considers that there is no further obligation. From October 2013, The Company decided to cease the payments to those institutions. The Management of the Company believes that this contingent liability could be settled without significant adverse effects on its financial position.

(e) Minimum Future Rents:
The minimum future concession and rental income receivable, arising from the existing rental agreements are as follows:

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33. RELATED PARTIES

The Company has transactions (provides and receives services) in the normal course of its business with certain companies controlled by its main Shareholders and considered related parties. The Company’s transactions and account balances with related companies, as these are defined in IAS 24 ,are as follows:

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

The revenues of € 90,511,252.16 (2024: € 81,706,669.33) (Note 25) from Piraeus Container Terminal S.A. are related to the fixed and variable revenue from the concession agreement (PIER II & III) and revenues of € 1,852,057.64 (2024: € 805,208.86 ) related mainly loading/unloading and mooring. The Company recharged energy costs to the related party under the concession agreement until January 14, 2025, amounted to € 376.064,88 (2024: € 9.169.250,06). After that date, the related party acquired its own electrical substation, and the re-billing process was therefore concluded.

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The transactions with COSCO SHIPPING LINES GREECE S.A. of the previous year mainly related to the supply of ship services (from loading/unloading and berthing), as well as the provision of car transportation services from China. In the current year, transactions mainly related to loading/unloading , berthing and storage services. The transaction with COSCO SHIPPING TECHNOLOGY Co. LTD relates to software support costs.The transactions with COSCO SHIPPING GLOBAL EXH relate to exhibition expenses. The transaction with COSCO SHIPPING TECHNOLOGY (Beijing) relates to software update. The transaction with COSCO (HONG KONG) INSURANCE BROKERS L.T.D. of the current and the previous period relates to the insurance coverage of PPA S.A. regarding third party liability, employer's liability, property and business interruption and directors and officers liability, according to article 17 of the Concession Agreement (Law 4404/2016).

Board of Directors Members Remuneration:

During the year ended December 31, 2025, were paid to the Board of Directors members. remuneration and attendance costs, amounted to € 1,185,793.99 (31.12.2024: € 1,395,877.64) Furthermore during the year ended December 31, 2025 emoluments of € 1,174,245.45 (31.12.2024: € 846,326.35) were paid to Managers / Directors for services rendered.

34. FINANCIAL INSTRUMENTS

Fair Value:

The carrying amounts reflected in the accompanying sheets of financial position for cash and cash equivalents, trade and other receivables, suppliers and accrued and other current liabilities approximate their respective fair values due to the relatively short-term maturity of these financial instruments. The fair value of variable rate loans and borrowings approximate the amounts appearing in the statements of financial position. The Company categorized its financial instruments carried at fair value in three categories, defined as follows:

Level 1: Quoted (unadjusted) values from active financial markets for identical negotiable assets or liabilities.
Level 2: Other techniques for which all inflows that have a significant impact on the recorded fair value are identified or determined directly or indirectly from active financial markets.
Level 3: Techniques that use inflows that have a significant impact on the recorded fair value and are not based on quoted prices from active financial markets.

Financial risk management:

The financial risks related to the Company and their respective management are as follows:

Credit Risk: The Company's Management estimates that its exposure to credit risk is limited towards the contracting parties, - as a matter of policy - it receives advances payments or letters of guarantee for most of its provided services. From the above applied policy are excluded customers who belong to the same group of companies, as mentioned in note 33 "Related Party Transactions". In addition, the transactional activity between the Company and its related party company, Piraeus Container Terminal SA, which is the Company's largest customer in terms of volume, is mainly covered by the terms of the concession agreement between them, which is under the supervision of the Greek State. It should be noted that despite the very significant amount and range of related parties transactions, no credit event has occurred until now that could raise a credit risk. In addition, the Company's cash at banks and time deposits are placed in bank financial institutions in Greece and generally in European Union, with the following ratings (Moody's credit rating):

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Foreign Exchange Risk: The Company is neither involved in international trade nor has any long term loans in foreign currency and therefore is not exposed to foreign exchange risk resulting from foreign currency rate variations.

Interest rate risk: The Company's bank lending concerns two loans in Euro and is subject to one fixed rate and the other to a variable interest rate (Note 19). The Company, during the year does not use bank borrowing and therefore there is no interest rate risk. Additionally, in the context of managing its assets as effectively as possible, as well as limiting any possible impact of increased borrowing interest rates on its results, the Company's Management, taking advantage of its strong liquidity, implements short-term reinvestments of these, expoiting the increased interest rates on term deposits. The table below presents and analyses the sensitivity of the result in relation to financial assets (cash on hand and in banks) and financial liabilities (loans) of the Company to the interest rate risk changes assuming a simultaneous change in interest rates by $\pm$ 100 basis points on the Company’s profit.

Liquidity risk: The effective management of liquidity risk is ensured by maintaining sufficient cash and the availability of financing in case of need. Corporate liquidity risk management is based on the proper management of working capital and cash flows.

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

The following table summarizes the maturity dates of the financial liabilities of 31 December 2025 and 2024 respectively, arising from the relevant contracts at unpaid prices.

The above table includes the interest on long-term loans, which were calculated until maturity according to the European Investment Bank quarterly information note for the 1st quarter of 2025.

  • Trade payables do not have interest and are settled in up to 60 days. Other payables also do not bear any interest and are settled in up to 12 months.

Capital Management

The primary objective of the Company's capital management is to ensure the maintenance of high credit rating, and healthy capital ratios in order to support and expand the Company's operations and maximize shareholder value. The Company's policy is to maintain leverage targets, according to an investment grade profile. The Company monitors capital adequacy using the ratio of total debt to operating profits, which should be lower than 9.80 based on the loan agreements (Note 19). The debt includes interest-bearing loans and lease liabilities, while the operating profit includes profit/(loss) before taxes, financing costs and depreciation.

Amounts of fiscal year 2025 Current portion
Less than 6 months 6-12 months 2 to 5 years >5 years Total
Borrowings - - - - - -
Lease liabilities 4.368,74 3.514.703,69 11.076,00 14.000.000,00 77.437.500,00 94.967.648,43
Trade and other payables* 23.710.719,51 26.084.597,02 12.857.973,91 - - 62.653.290,44
Total 23.715.088,25 29.599.300,71 12.869.049,91 14.000.000,00 77.437.500,00 157.620.938,87
Amounts of fiscal year 2024 Current portion
Less than 6 months 6-12 months 2 to 5 years >5 years Total
Borrowings - 3.443.636,38 3.389.257,92 21.828.157,50 - 28.661.051,80
Lease liabilities 8.718,00 3.543.657,00 19.148,00 14.000.000,00 80.937.500,00 98.509.023,00
Trade and other payables* 16.438.265,11 18.187.960,56 10.029.851,49 - - 44.656.077,16
Total 16.446.983,11 25.175.253,94 13.438.257,41 35.828.157,50 80.937.500,00 171.826.151,96

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PIRAEUS PORT AUTHORITY S.A Annual Financial Report for the year ended December 31, 2025 (amounts in Euro unless stated otherwise)

35. SUBSEQUENT EVENTS

The most significant events after December 31, 2025, are the following:

First Investment Period Duration

In accordance with the provisions of article 7.2 and Annex 7.2a of the Concession Agreement between PPA SA and the Hellenic Republic (the contracting parties), ratified by law 4404/2016, as amended (law 4838/2021), the identification and quantification of one or more Suspension Events, by the Independent Engineer, during the execution of the Mandatory Investment projects, results in a corresponding extension of the First Investment Period. The identification and quantification of the Suspension Events falls under the competence of the Independent Engineer and is recorded in the Reports that they submit to the contracting parties. In this case, the Independent Engineer has identified, quantified and recorded in his Reports, to date, Suspension Events of a total duration of 1177 days. Consequently, the First Investment Period, which was to expire on August 9, 2026, has been extended by the corresponding period, i.e. by 1177 days, with a new expiration date (as of this day and subject to any occurrence of new Suspension Events in the future) on October 29, 2029. The above is established and recorded in the most recent 35 th Quarterly Report of the Independent Engineer referenced to the last quarter of 2025, which has been duly notified by the Independent Engineer to both parties (PPA SA and the Greek State) on January 28, 2026.

Evolutions in the Middle East

Following the reporting date, and specifically during February 2026, an armed conflict broke out in Iran, forming part of the broader context of geopolitical instability in the Middle East. This development does not constitute an adjusting event in accordance with IAS 10 “Events after the Reporting Period”, as the relevant conditions did not exist at the reporting date. The Company’s Management closely monitors and continuously assesses the impact of the volatile situation in the Middle East on the macroeconomic and financial environment, such as potential energy instability and increase in energy costs, inflationary pressures, and severe disruptions in international shipping and global trade, in order to ensure that all necessary actions and measures are taken to minimize any potential effects on the Company’s operations. As part of the Company’s operations, cargo containers are transported either from or to ports in the countries involved or neighboring regions. These shipments for the 2025 fiscal year were not significant in relation to the Company’s overall operations. At the same time, in the context of developments in international shipping and trade flows in the wider region, certain changes and diversions in routes and cargoes towards to Piraeus have been observed so far.The nature of these changes is currently assessed as temporary, as the situation is evolving dynamically and is constantly being reassessed in light of geopolitical developments, both by the Company and by shipping providers. As of the date of approval of the financial statements, it is not possible to estimate any potential quantitative impact of this development on the Company’s results and financial position. Other than the above, there are no other significant events after December 31, 2025, that may have a material impact on the company's financial position.

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PIRAEUS PORT AUTHORITY S.A
Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise)

Piraeus, March 31, 2026

CHAIRMAN OF THE BOARD OF DIRECTORS CHIEF EXECUTIVE OFFICER FINANCIAL MANAGER
HAN CHAO SU XUDONG SERAFEIM MARMARIDIS
Passport No. PE3327142 Passport No. PE2263059 License No. Ο.Ε.Ε. 0110075

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PIRAEUS PORT AUTHORITY S.A
Annual Financial Report for the year ended December 31, 2025
(amounts in Euro unless stated otherwise)

WEBSITE PLACE OF UPLOADING THE FINANCIAL REPORT

The annual financial report of the Company, the independent auditor’s report and the Management Reports are available to the website www.olp.gr.