IMERYS ΒΙΟΜΗΧΑΝΙΚΑ ΟΡΥΚΤΑ ΕΛΛΑΣ ΑΝΩΝΥΜΗ ΕΤΑΙΡΙΑ

1. Στρατηγική, Ανάλυση & Δράση

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys respects the world in which it operates. Imerys is committed to play a role in society, to meet its obligations to the countries and communities within which it does business, and to act as responsible environment stewards and thereby contribute to sustainable development through its operations and portfolio of solutions. Its growth strategy takes into account its Corporate Social Responsibility (CSR), integrating the challenges and expectations of key stakeholders.

Since 2017, the Group CSR program has been overseen by a CSR Steering Committee which meets quarterly and is chaired by the Chief Executive Officer. The Board of Directors reviews the performance and progress made by the Group against its CSR program every year. In 2018, the Group announced the launch of its new CSR program SustainAgility. The SustainAgility program was developed taking into consideration a wide range of inputs from internal and external stakeholders, duly considering the 2030 Agenda for Sustainable Development and the international framework. The Group continues to develop and roll-out the SustainAgility program in an iterative fashion.

The SustainAgilty program is built around six pillars and 16 themes, which are in line with and contribute to the United Nations Sustainable Development Goals (SDG):

• Empowering our people: making sure employees and the people Imerys works with stay healthy and safe, nurturing talent, promoting diversity & inclusion, fostering social dialogue and safeguarding human rights;
  • Safety & Health : Occupational Safety Management, Occupational Health Management
  • Human Capital: Diversity and Inclusion
• Caring for our planet: protecting the environment, promoting non-energetic resources efficiency, preserving biodiversity, and acting on climate change;
  • Environmental Stewardship: Environmental Management, Biodiversity and Land Rehabilitation
  • Climate Change: Climate Change Strategy
• Building for the future: behaving ethically, operating fairly, ensuring responsible purchasing, engaging with communities and promoting sustainable products and technologies.
  • Business Conduct: Fair Operating Practice & Responsible Purchasing
  • Product Management: Product Sustainability

(See the graph attached)

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ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

• GRI 102-12 Disclosure: External initiatives

Imerys adheres to major international framework agreements, such as the United Nations Global Compact (UN GC), the United Nations Sustainable Development Goals (SDG), the United Nations Guiding Principles on Business and Human Rights, the Organisation for Economic Co-operation and Development (OECD) guidelines for multinational enterprises, and the International Labour Organization (ILO) Fundamental Conventions.

Imerys supports the ambitions of 17 Sustainable Development Goals (SDG) global program and has duly identified within the SustainAgility program the policies and practices within its operations that directly or indirectly contribute to the SDGs. The Company plays a positive role within

communities, both for local ecosystems and economies in the long term. The Group is firmly committed to the conservation of biological diversity and its restoration, communicating concrete actions through act4nature International and partnering with recognized scientific experts such as UMS Patrimoine Naturel. The Group continues to look for new ways to help employees and our local communities thrive, creating positive value through education and skills development.

Imerys Greece S.A. facilities are certified with ISO 9001:2015 Quality Management System (QMS), ISO 14001:2015 Environmental Management System (EMS) and ISO 45001:2018 Occupational Health and Safety Management System (OHSMS).

Based on the risk-based approach imposed by ISO 9001:2015, ISO 45001:2018 and ISO 14001:2015 Standards, Imerys Greece S.A. established a systematic and consistent methodology. This risk management methodology helped identify not only risks, but also opportunities per process and facility.

The process of risk management consists of the following successive steps:

• Identification of interested parties and their needs and expectations;
• Determination of the processes (e.g. mining, industrial, maintenance, sales, etc.) and their application/ interactions throughout facilities. Moreover, determination of the external issues (opportunities and threats) and internal issues (strengths and weaknesses) that are relevant to the purpose and strategic directions of the facilities;
• Identification and evaluation of potential risks and opportunities (risk and opportunity assessment), as resulted from external and internal issues identification;
• Determination of appropriate actions to reduce risks to acceptable level or to increase the opportunities above the acceptable level;
• Application of the criteria and methods needed to ensure the effective operation and control of these processes, through key performance indicators (KPIs) set and monitoring.

Main risks identified are related to Imerys business, regulation and legal risks, while main opportunities identified are related to new resources/ reserves, new financial markets and advanced human capital.

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2. Ουσιαστικότητα

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys material CSR challenges and opportunities are summarized below under the six SustainAgilty program pillars:

• Safety and Health

Ensuring the Safety & Health of Group employees as well as contractors is a core value and Imerys’ number one commitment. Being a safe place to work is a cornerstone of Imerys’ sustainability. Due to the inherent nature of industrial activities, Imerys employees, contractors, customers’ employees may be exposed to risks that, in the event of failings in the safety management hierarchy of controls, could result in a fatality, life-changing injury, occupational accident, or health effects. The highest risks activities managed through the “Serious 7” protocols are related to the risk of contact with hazardous energy, interaction with mobile equipment and machinery, working at heights, as well as ground control in surface mines. Occupational health risks in mineral mining and processing activities include ambient dust, noise and vibration. Limited quantities of chemicals are also used during industrial processes and in the laboratories for quality assurance and research and development. Certain jobs also involve manual handling or repetitive tasks with the potential to cause ergonomic problems.

• Human Capital

Imerys human capital is the most important Group asset, thus ensuring the respect of human rights and labor practices, implementing tools for talent and skills development, maintaining constructive social dialogue and ensuring a diverse and inclusive environment with equal opportunities for all are crucial to the Group’s long-term strategy. Possible issues in this regard are related to potential violations of the Group Code of Business Conduct and Ethics that could result in the risk of causing or being linked to salient right abuses. While in the 2018 materiality assessment, diversity and inclusion were not assessed as the most material, the promotion of diversity and inclusion is considered to be a long-term objective that needs constant focus as expressed through the employee engagement and other surveys. As such the CSR Steering Committee defined it as a key theme, with the development of the Group Diversity and Inclusion program set as a high priority in the mid-term.

• Environmental Stewardship

Imerys’ extractive activities have the potential to modify natural habitats. Group operations may have adverse impacts on local ecosystems and biodiversity, or on water resources in the event of accidental environmental incidents, which may for example, cause the release of discolored water or the release of dust. The techniques used for processing industrial minerals are primarily physical (crushing, milling, and sorting) but also include thermal processes such as calcination and fusion, which result in water consumption, waste and air emission generation. Through sound environmental stewardship, the Group ensures full compliance with environmental obligations, duly identifying environmental risks and mitigating impacts. Group operations are required to have an effective Environmental Management System (EMS) to identify and control significant environmental risks, optimize the use of mineral resources and processing of mineral and to identify solutions to limit the consumption of other non-energetic resources such as water, and preserve biodiversity.

• Climate Change

Imerys is conscious of the urgent, global, systemic and irreversible risks associated with climate change and is aware of the global trend towards an economy that is low carbon or carbon neutral. Group operations generate greenhouse gas emissions directly through consumption of energy generated from fossil fuels or production of emissions linked to industrial processes. Indirect emissions are generated through purchased energy as well as through various other activities within the value chain, in particular through transportation and purchase of materials. Imerys is committed to reducing the impacts of its activities on climate change. For the transformation of industrial minerals, this requires ensuring greater energy efficiency through new technologies and processes as well as integration of renewable energy sources. While potential climate change impacts linked to Group operations did not emerge amongst the most material topics in the 2018 materiality assessment, Imerys remains committed to its long-term objective to the elaboration and roll-out of the Group climate change strategy. As such the CSR Steering Committee included climate change as a material theme and shall continue to focus on this pillar as a high priority in line with the long-term emission reduction targets that have been set. The Group risk mapping exercise identified the potential long-term risk for the Group associated with climate change.

• Business Conduct

Ensuring ethical business conduct in a rapidly evolving global business environment is achieved through strong corporate governance, which is the foundation upon which the Group is built. Yet evolving regulations focusing on fair operating practices, and responsible purchasing require continual adaptation of Group systems and processes. Respect of the Group Code of Business Conduct and Ethics (“the Code”) has been an area of particular focus since 2017 and through the reinforcement of internal controls, this risk has been significantly reduced. Yet the risk of Group suppliers not identifying compliance risks and not preventing serious violations of human rights, fundamental freedoms, health & safety of people and environment in their organization and in their own purchasing is still considered material. Imerys also faces both challenges and opportunities in its interactions with the communities surrounding its sites, which need to be continuously identified, assessed and managed. More generally, Imerys contributes to a multitude of regional, national and international economies and through local employment and purchasing, it creates concrete socio-economic benefits to employees, to contractors and suppliers, thus, helping to fight poverty and contribute to sustainable development.

• Product Management

Imerys is fully aware of stakeholder expectations for the Group to reduce product environmental footprints while at the same time provide sustainable solutions aligned to global megatrends. Product management that incorporates environmental and societal criteria contributes to the development of sustainable business opportunities. The technological expertise within Imerys places the Group in an excellent position to continuously improve the process efficiency and production methods of its operations. At the same time, the Group’s innovation capacity together with its awareness of global megatrends enables the Group to harness opportunities for new product developments, duly considering sustainability drivers and stakeholders’ expectations.

Additionally, Imerys is mindful of major trend and sources of opportunities, the company offers solutions that anticipate needs and support fast changing markets given the emergence of:

• New lifestyles (urbanization, population aging, health and well-being, mobility, recycling etc.);
• New economic models (the collaborative economy, the sharing economy, automated manufacturing etc.);
• Technological progress (Internet of Things, renewable energy, 3D printing, etc.); and
• Changing expectations from stakeholders (sustainable development, transparency, ethical conduct, etc.)

With solutions used in a number of industries, Imerys has a central role to play at the heart of the substantial shifts the future will bring. Confronted with changing lifestyles, new economic models, accelerating technological progress and responsible development, the Group is ready to tackle the major challenges that will shape tomorrow’s world.

(See graph attached)

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ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

Materiality is about identifying the key issues, threats and opportunities that may negatively impact or have the capacity to create value for Imerys and its stakeholders.

By crossing all the data coming from different sources Imerys aims to get a better vision of the most material issues so to orientate its mid and long-term CSR program in an optimal way for the Group and its stakeholders. See graph attached for the results of the materiality assessment exercise. 

The results of the exercise indicated the most material issues were:

• Occupational safety management
• Occupational health management
• Environmental management
• Product sustainability
• Fair operating practices and responsible supply chain
• Climate change strategy
• Biodiversity and land rehabilitation
• Diversity and inclusion

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3. Στοχοθέτηση

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Based on the 2021 CSR objectives set by Imerys Greece S.A., individual measures are thereafter documented within the specific facilities and departments.

Based on the risk-based approach imposed by ISO 9001:2015, ISO 45001:2018 and ISO 14001:2015 Standards, Imerys Greece S.A. established a systematic and consistent methodology. This risk management methodology helped identify not only risks, but also opportunities per process and facility and apply, among other, criteria and methods needed to ensure the effective operation and control of these processes, through key performance indicators (KPIs) set and monitoring. Process effectiveness is checked through KPI monitoring in order continual improvement to be achieved.

The Group’s Key Performance Indicators (KPIs) on Corporate Social Responsibility have been defined and gradually evolved in accordance with pertinent international Standards and regulatory framework. For more information please also refer to criterion 7: Monitoring.

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ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

The 2021 CSR objectives of Imerys Greece S.A. are depicted in the following table.

E = Environment incl. Energy                     H & S = Health & Safety           Q = Quality

Take5 = “Take5” safety program is a pre-task risk assessment and reduction tool, which drives safety awareness to all employees, and is conducted both per employee (personal Take5) and per employees’ groups (Group Take5)

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4. Διαχείριση της Αλυσίδας Αξίας (value chain)

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys Greece S.A. follows specific processes for the selection and evaluation of providers and contractors. A relevant providers’/ contractors’ register is being kept and updated frequently. Based on that process, providers of critical materials and services have been recognized for Greece’s facilities, which are energy, extraction-exploitation contractors and soda (for bentonite activation).

Providers are separated in three categories: (1) minor, (2) moderate and (3) major/ critical based on the value of procurements per year. Specific criteria are set for the entry into the providers’ registry and for the evaluation of each provider, based on its categorization. Example of these criteria are, but are not limited to:

• Quality Management System (QMS) existence or application of quality assurance Standards;
• Environmental Management System (EMS) existence or application of environmental assurance Standards;
• Occupational Health and Safety Management System (OHSMS) existence and adherence to Health and Safety regulations;
• Safety and cleanliness of facilities;
• Adherence to Imerys protocols and fundamental safety rules.

All main (first tier) subcontractors have received Imerys ESG Standards. Alignment of Group contractors within Imerys Safety System (ISS) and safety cultural expectations is fundamental to achieve the Group safety goals. As such, the new Contractor Safety Management initiative, launched in 2017, outlines a common and systematic approach for the selection, monitoring and continuous improvement of the health and safety performance of contractors and sub-contractors.

Imerys Code of Business Conduct and Ethics (the Code) summarizes the principles of ethical behavior the Group expects from all of its employees, contractors, suppliers, and other partners. The Group expects its business partners and suppliers to adhere to the same principles as elaborated with the Group Code. As such in 2018, Imerys updated and launched new Supplier ESG Standards (the Standards). These Standards, are based on the Group Code and CSR Charter and are aligned with the SustainAgility program. The Standards, which must be formally acknowledged and complied with, are applicable to all suppliers and are considered a prerequisite for doing business with the Group, forming an important part of the Group Purchasing policy.

The purchasing policy requirements in terms of Supplier Environmental Social and Governance performance are based on the following principles:

1. Supplier Environmental, Social and Governance Standards

The Group is committed to build strong transparent relationships and mutual trust with its Suppliers. All Suppliers must acknowledge and accept to comply with the Imerys Supplier ESG Standards. The roll-out of these Standards shall continue over the next years. n 2021, the purchasing organization verified over 385 suppliers to ensure the effective cascade of the Supplier ESG Standards across all purchasing categories and geographies.

1. Supplier risk identification and assessment

The assessment of ESG performance of Suppliers starts during Supplier qualification and onboarding. Purchasing teams are responsible for carrying out reasonable controls before considering and accepting a Supplier, including in particular any Supplier that may be classified as higher risk (due to a country or category-related risk classification) during the Supplier onboarding process in order to make sure that Suppliers are able to demonstrate compliance with the Supplier ESG Standards. In 2021, the Group redefined the process to qualify, screen and monitor Suppliers environmental, social and governance performance. The process will be rolled out progressively and will require all new Suppliers to pass through a series of validations and third-party screening prior to being accepted as Suppliers for the Group. The new onboarding process has been designed to ensure that Suppliers are aware of and commit to comply with the Group ESG Standards, but also to support Suppliers development and continuous improvement in ESG performance. From mid-2020, within the responsible purchasing program the Group launched the deployment of a CSR rating scheme for Suppliers conducted together with EcoVadis. This comprehensive assessment covers environment, labor and human rights, ethics and sustainable procurement, with customized assessments based on the size of the company and type of activity. Purchasing teams have the responsibility to contribute to the identification and prioritization of Suppliers to review within the responsible purchasing program. The role of the program was launched in priority for Suppliers regions and categories that had been assessed as higher risk during the risk mapping process described above. At the end of 2021, 35% of Group Suppliers by spend have been assessed. These assessments cover over 800 suppliers and represent all categories of suppliers, including over 40% of raw material suppliers by spend and over 30% of suppliers within priority countries.

1. Risk reduction and prioritization

Risk reduction includes awareness and training. Awareness of and training on the requirements of the Group Code are provided to help managers and employees to understand and respect the Code. Employees are trained through digital learning courses, as well as through in-class training and internal expert presentations, which ensures the strong protection of all employees through the awareness of ethical issues.

In addition to the aforementioned e-learning, Imerys also punctually conducts training and workshops with the purchasing organization focused on the UN Guiding Principles on Business and Human Rights and their application within Imerys. The purpose of these workshop sessions is to train the purchasing teams on the fundamental elements of the Guiding Principles, helping them to recognize signs of potential violations and based on their knowledge of the Supplier panel, prioritize the Suppliers where additional risk reduction measures may be required. In 2019, the Group organized dedicated purchasing workshops that included approximately 62% of purchasing teams from across the different geographic areas. Unfortunately additional training could not be held in 2021 as a result of Covid-19 restrictions, thus a new digital course developed by the UN Global Compact Academy focusing on “How Procurement Decisions can Advance Decent Work in Supply Chains” was made available in the Learning Hub. The Supplier assessments conducted through EcoVadis likewise support risk management and reduction as the assessment results provide a detailed view on the specific areas where improvements are needed.

1. Supplier ESG audits

While Imerys is fully committed to support Supplier development and continuous improvement, Suppliers must be able to demonstrate that they can meet the minimum ESG criteria and where any gaps are identified, through formal or informal assessments or audits, Suppliers must be willing to develop a corrective action plan within an agreed timeframe. Imerys verifies alignment to the Supplier ESG Standards through the use of Supplier self-declaration, self-assessments, and assessments by Imerys teams as appropriate to the situation. In designated high-risk countries third-party audits may be conducted. The Group developed an ESG Supplier assessment checklist to monitor the existing Supplier’s operations and identify their performance according to the Group’s ESG Standards. For example, in India, the Group has focused on raw material suppliers, launching a Strategic Supplier Relationship (SSR) project aimed at improving operations of a set of strategic Suppliers. The project started with a study to categorize the suppliers based on the needs and resources for the strategic relationship of the Group. Based on the categorization criteria, critical suppliers have been selected to implement necessary strategic projects such as reducing the raw material consumption, increasing recycling, providing additional safety training and improving the work conditions of employees. The Group has likewise conducted a series of inspections and audits of other raw material suppliers in specific regions to verify compliance with the Group ESG Standards and develop improvement plans where gaps have been identified. The Group focuses in particular on assessments and audits of Suppliers ranked as “high risk” based on the Group risk mapping and evaluation process. In specific cases the Group may conduct additional due diligence or specialized external third-party audits prior to or after contract award.

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ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

• GRI 102-6 Disclosure: Markets served

Bentonite market

Imerys Greece S.A. is the largest bentonite producer in Greece and Europe and one of the largest companies in the world. In 2021, the largest volume of bentonite production was mainly exported to the European market and to North America (Canada).

Having a strong presence in international markets, bentonite is used in wide range of industrial applications and processes in the foundry and iron metallurgy market, in special applications (cat litter, papermaking), as well as in the construction industry, offering products and industrial solutions both in large infrastructure projects and in gas and oil drilling. 

Perlite Market

Imerys Greece S.A. is also the largest perlite producer in Greece, as well as one of the major suppliers of non-expanded perlite in the world. Perlite is widely used in building applications such as molded building materials (heat and sound insulation roof tiles and insulating filler materials) and provides industrial solutions to building materials, such as coatings, wall mortars and filtering media. Perlite is also used in cryogenic insulations, in agriculture, in foundries and as an improver additive in the production of phosphate fertilizers.

Inflation has clearly been a major topic in 2021: raw materials and logistic costs have reached unprecedented high levels, as well as energy, especially in Europe. The Group reacted rapidly and decisively to the new situation, while preserving the relationship with its customer base, and managed to deliver on profitability expectations also in such a difficult context.

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5. Υπευθυνότητα

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

The “go-to” reference source for all information about the Group’s internal control policies and procedures are grouped together in the Blue Book, which all employees can consult on the Group Intranet OneImerys. SD (Sustainable Development) charters, policies and manuals, included in the Blue Book, mainly consist of the following documents:

Business Conduct

• Code of Business Conduct & Ethics
• Corporate Governance Policy
• Ethics Committee Charter

Health & Safety

• H & S Charter
• Injury and Health reporting protocol
• EHS Audit Policy

Environment

• Energy, emissions & production reporting protocol
• Environmental reporting protocol

CSR

• Corporate Social Responsibility Charter
• Diversity & Inclusion Charter
• Child Labour protocol

Moreover, all Imerys Greece S.A. employees - from top management and senior executives to shop floor employees and technicians - are informed during their hiring process regarding (1) Occupational risk assessment of their job position, (2) Safety Cardinal Rules and protocols, (3) EHSQ Policy, (4) Imerys Code of Business Conduct and Ethics and (5) Anti-fraud and anti-bribery policy, thus being informed about ESG topics. Top management and senior executives are actively engaged into implementing Group SD policies.

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ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

• GRI 102-19 Disclosure: Delegating authority

Imerys Greece S.A. has active participation to the following organizations:

Environmental and Sustainability Organizations

• SEV Business Council for Sustainable Development

Imerys Greece S.A. is a founding member of this organization. Mr. Athanasios Kefalas, president of Imerys Greece S.A., is a board member. Mining Rights Manager, Mr. Yannis Karavelakis, is a member of the relevant working group.

Industry Organizations

• Industrial Minerals Associations for Europe (IMA-Europe)
• European Bentonite Association (EUBA) branch
• European Association of Mining Companies (Euromines)
• Greek Mining Enterprises Association (SME)

Imerys Greece S.A. is an enterprise – member of SME. Mr. Athanasios Kefalas, president of Imerys Greece S.A. is the president of Board of Directors, starting from 2015.

• SEV – Hellenic Federation of Enterprises
• Association of Industries & Exporting Enterprises of Milos

CSR Organizations

• CSR Europe
• CSR Hellas

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6. Κανόνες & Διαδικασίες

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys’ internal control policy is formally set out in the Code of Business Conduct and Ethics and the Corporate Governance policy, as well as in a number of charters (including the Board of Directors Charter, Corporate Social Responsibility Charter, Health & Safety Charter and Inclusion & Diversity Charter) that apply to the whole Group. Moreover, the Group’s policies developed by the central support departments (including Sales & Purchasing, Finance, Legal, Science & Technology and Information Systems) define the specific organization, responsibilities and operating and reporting principles for their respective areas of expertise. Lastly, the Group’s internal control manual defines the main internal control principles and the most important control activities to be carried out as part of the Group’s operating and financial processes.

The Group’s charters, policies and manuals are grouped together in the Blue Book, which all employees can consult on the Group Intranet OneImerys. This fundamental set of rules forms the framework for the Group’s operations. It applies to all Imerys’ activities and the companies it controls. Certain communications are subject to electronic certification, through which employees must certify they have read the information and pledge to enforce the internal controls in their area of responsibility.

A second set of rules applies to the Group’s operations and defines their specific procedures and reporting principles. Procedures are adapted to each setup, approach to mining, industrial and commercial management and related risks, in line with Group policies. They take into account specific requirements set out in applicable local laws and regulations.

Imerys Greece S.A. facilities are certified with ISO 9001:2015 Quality Management System (QMS), ISO 14001:2015 Environmental Management System (EMS) and ISO 45001:2018 Occupational Health and Safety Management System (OHSMS). Indicators connected with SD and CSR elements are also monitored in the context of the Integrated Management System (IMS). Imerys Greece S.A. follows a specific list of BU’s Procedures and local (GR) Instructions regarding quality, environment and health & safety issues, proving its compliance regarding the requirements of the 3 Standards that is externally certified for.

Based on the risk-based approach imposed by ISO 9001:2015, ISO 45001:2018 and ISO 14001:2015 Standards, Imerys Greece S.A. established a systematic and consistent. This risk management methodology includes, between others, KPIs set per business process, in order to address risks and opportunities. The KPIs set are monitored via a relevant KPI registry form.

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ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

• GRI 102-16 Disclosure: Values, principles, standards and norms of behavior

Imerys Code of Business Conduct and Ethics (the Code) summarizes the principles of ethical behavior the Group expects from all of its employees, contractors, suppliers, and other partners. The umbrella principles set forth in the Code are supported by a series of policies and protocols applying to both the general conduct of Imerys and the individual conduct of each employee. The subjects covered by the Code include compliance with laws and regulations, protection of environment and human rights, relations with local communities and trade unions, workplace safety and health, diversity and inclusion, confidentiality, prevention of fraud or corruption, prevention of insider trading and conflicts of interest, protection of the Group’s assets, fair competition, transparency, and integrity.

Imerys Greece S.A. facilities are included into an annual internal audit program. Internal audits are conducted according to its Integrated Management System (IMS), based on the status and importance of the processes and areas to be audited, as well as the results of previous audits. Audits are conducted by the use of generated checklists, procedures and interviews of personnel to determine compliance with quality, environmental, health & safety, customer, regulatory and other legal requirements. Internal audits are assigned to trained personnel (internal auditors), selected to ensure objectivity and impartibility of the audit process. Audit findings are communicated immediately, thus investigation, root causes found, corrective actions proposed and relevant action plan set should be in place. Audit findings are also reviewed at the management review meetings. Imerys Greece S.A. also utilizes outside consulting services to perform external audits in various auditing functions.

As defined EHS Auditing Procedure, Imerys conducts periodic audits of the Group's operating facilities to determine how well they comply with EHS laws and regulations and Imerys’ EHS protocols. Imerys’ EHS audits cover everything from internal Imerys protocols to local laws and regulations, expert verification for mineral solid storage facilities, and mine safety, which are covered by separate audits of the Group. Failure to comply results in an audit finding. These findings are rated with Red; if the risk attached to the failure is serious or very systemic, Orange; if the risk is important or somewhat systemic and Yellow; if the risk is less significant and isolated. Together with the plant management, an action plan for correcting any audit findings is established within 45 days. Completion of corrective actions is tracked in a dedicated database called MK Insight. Outstanding findings are regularly presented to the Executive Committee.

For Imerys SD charters, policies and manuals please refer to Criterion 5.

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7. Καταγραφή και παρακολούθηση (monitoring)

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

The Group’s Key Performance Indicators (KPIs) on Corporate Social Responsibility have been defined and gradually evolved in accordance with pertinent international Standards and regulatory framework, such as GRI’s Sustainability Reporting Guidelines (“Core” option), the UN Global Compact, the UN Guiding Principles on Business and, OECD Guidelines, International Organisation for Standardization (ISO) and the ILO Fundamental Conventions.

Imerys uses an intranet reporting tool entitled “Enablon”, through which safety data, environmental KPIs, environmental incidents, energy, CO2 and production data are being reported every month and reviewed quarterly. Injury and health reporting protocol sets out the rules for inputting Safety data in Enablon and designates the individuals responsible for enforcing them. It explains the input, validation and checking recommendations for the KPIs in the reporting tool. Environmental reporting protocol and Energy, emissions & production reporting protocol address the reporting of corresponding information.

Effective IT systems help ensure reliable and improved management of support and operating processes.

The Group’s policy consists of integrating and monitoring as much of its value chain (particularly sales, distribution, purchasing, inventory, fixed assets, production, supply chain and finance) with its enterprise resource planning (ERP) system. Imerys strives to use integrated ERP control systems to ensure an optimal level of control while meeting the specific requirements of how to best manage its operating activities.

Imerys uses several ERP systems that have been selected to create synergy between support and maintenance as well as satisfactory consistency, while taking into account the size of operations and the regions in which they are rolled out. The Group has launched a project to streamline and standardize Group operating processes under a single ERP system.

The Group uses a single software package in all its entities to report and consolidate its accounting and financial information.

In addition, tools for consolidating and monitoring the most important non-financial data have been set up across the Group. They help to:

• Gain a clearer view of the performance of the Group’s different operations, prevent or resolve difficulties and promote or measure improvement (e.g. reporting and consolidating HR or CSR indicators);
• Improve the accuracy of data processing and help monitor operational compliance with applicable legal or regulatory obligations, contractual commitments and Group rules (e.g. reporting and consolidating legal and administrative information related to the Group’s subsidiaries, equity interests and corporate officers as well as, managing and monitoring the approval and fulfillment of contractual commitments).

Imerys Greece S.A. facilities are certified with ISO 9001:2015 Quality Management System (QMS), ISO 14001:2015 Environmental Management System (EMS) and ISO 45001:2018 Occupational Health and Safety Management System (OHSMS). Indicators connected with SD and CSR elements are also monitored in the context of the Integrated Management System (IMS).

Based on the risk-based approach imposed by ISO 9001:2015, ISO 45001:2018 and ISO 14001:2015 Standards, Imerys Greece S.A. established a systematic and consistent methodology. This risk management methodology includes, between others, KPIs set per business process, in order to address risks and opportunities. The KPIs set are monitored via a relevant KPI registry form.

The group also has been building on the foundation of past year’s achievements and is actively tracking key indicators for its SustainAgility program. Imerys’ firm commitment to corporate social responsibility and adheres to major international framework agreements. The Group’s firm commitment to sustainable development has been recognized by the leading CSR rating agencies. The following table presents a selection of the non-financial ratings most recently achieved by Imerys.

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The CSR strategy and reporting approach is based on GRI’s Sustainability Reporting Guidelines (“Core” option).

The GRI disclosures used for the completion of the 20 criteria of Greek Sustainability Code are summarised in the following GRI context index:

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8. Πολιτικές Αμοιβών και κίνητρα για τη Βιώσιμη Ανάπτυξη

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys Group compensation and benefits systems and policies aim at ensuring both market competitiveness and internal consistency, while being driven by a clear pay-for-performance objective. In 2021, Imerys group developed a Position Evaluation System, in order to define roles in a systematic grading approach. Using common grades throughout the world, Imerys ensures internal consistency by providing equal pay for work of equal value and provides a rational basis for the maintenance of its pay structure. This process uses data to benchmark remuneration against the market, which helps drive Imerys principle of equal opportunities and drive transparency and consistency in compensation practices across Business Areas, Functions and Departments. Fixed compensations are reviewed on a yearly basis under the close coordination of the Human Resources function, supported by regular local and/or sectorial surveys, and conducted with strict financial discipline.

Short-term variable pay schemes include both individual and collective objectives, in order to reward both personal and financial collective performance. All top management and senior executives should include not only financial, but also health and safety objectives in their annual objectives. Achievement of the objectives is measured and observed annually by the upper tier employee. All Imerys employees are encouraged to include in their personal objective issues dealing with sustainable development, such as health & safety, environment, human resources development etc. The weigh factor of each objective depends on the area of expertise of every employee. Long-term compensation programs, based on Performance Shares, are fully aligned on the Group long term financial objectives. The Group endeavors to align its remuneration practices across the best international Standards.

Job descriptions issued by Imerys Greece S.A. Human Resources departments for executives’ job positions are descriptive of the relevant EHS responsibilities that newly hired and older executives should follow. Moreover, all employees in Imerys Greece S.A. facilities are encouraged to participate voluntarily in corporate CSR actions, internal and external health and safety trainings, environmental initiatives and initiatives of the organizations company is an active member (environmental and sustainability, industry and CSR organizations).

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• GRI 102-35 Disclosure: Remuneration policies

In accordance with articles L. 22-10-8 I and R. 22-10-14 I of the French Commercial Code, the compensation policy awarded to corporate officers set out below covers all components of fixed and variable compensation and explains the process by which the policy was developed, revised and implemented.

In general, the compensation policy of the corporate officers is agreed each year by the Board, based on proposals made by the Compensation Committee. Where necessary, it is reviewed mid-year. The Committee makes its recommendations to the Board based on assessments and comparisons conducted on a regular basis by specialist consultants. To avoid any conflict of interest, when the Board of Directors votes on components of compensation, the people concerned do not take part. This enables the Board of Directors, with support from the Compensation Committee, to ensure the compensation policy protects the Company’s corporate interest, contributes to its long-term success and reflects its business strategy. Therefore, the Board pays particular attention to:

• align the policy with the Group’s expectations regarding corporate officers’ performance and engagement, given their level of experience and expertise;
• align the policy, especially any components of variable and long-term incentive payments, with the Company’s performance as well as its strategy for the short, medium and long term;
• maintain competitive alignment with best practice applied by comparable listed French companies in the market and monitor recent changes; and
• ensure the policy remains appropriate with respect to the remuneration of Company employees. Therefore, the performance criteria applicable to variable compensation and long-term incentive plans of the executive corporate officers reflect those applicable to other Group employees eligible for this type of remuneration.

Pursuant to article L. 22-10-8 III of the French Commercial Code, the Company reserves the right in exceptional circumstances to depart from these compensation policies (for the Chairman of the Board, Chief Executive Officer and

corporate officers) on a temporary basis where necessary to protect the Company’s corporate interest or contribute to its long-term success or viability.

Accordingly, the Company’s Board of Directors would, in exceptional circumstances, have the option of making adjustments to the compensation policy previously approved by the Shareholders’ General Meeting, in respect of the variable compensation components and share-based payments to the executive corporate officers, provided that it maintains the alignment between these compensation components and the Company’s performance and upholds the principles laid down hereinabove.

The exceptional circumstances referred to could specifically include an event beyond the Company’s control affecting the markets or the Company’s activities and giving rise to material implications for it, a material change in the Group’s scope or a change in accounting method.

Use of this option needs to be explained and decided upon by the Board, upon recommendations from the Compensation Committee, which will report on it to the following Shareholders’ General Meeting.

Where necessary (in accordance with article R. 22-10-14 II para. 3 of the French Commercial Code), the 2022 compensation policies (Chairman of the Board, Chief Executive Officer and Board members) do not provide for any deferral period, nor the option to ask any corporate officer to return variable compensation.

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9. Διάλογος με τα Ενδιαφερόμενα Μέρη

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

The Group depends on the solid long-term relationships it develops with its key stakeholders; respecting the countries, communities and environments across the globe where its operations are located. As such Imerys considers itself accountable to a wide variety of stakeholders, both internal and external. Identifying stakeholders and gaining an understanding of their needs and expectations is a critical step to foster engagement.

In 2017 and in 2018, in the context of the definition and preparation of the Group’s CSR program, Imerys launched a materiality assessment in order to further integrate stakeholder expectations on Environmental Social and Governance (ESG) risks, threats and opportunities facing the Group within the definition of material CSR priorities. This process can be summarized in three phases: framing, engagement and analysis and validation.

The first phase of framing focused on the research and analysis required to identify and verify a list of potentially significant ESG issues, including but not limited to: the identification of megatrends potentially affecting Group business in the future, the 2030 Agenda for Sustainable Development, inputs from the 2050 Roadmap of the Industrial Minerals Association (IMA) Europe and other IMA forward-looking reports, an assessment of selected international companies CSR programs, operational risk related to CSR themes as well as a review of selected climate change, biodiversity, responsible purchasing, diversity and inclusion, and circular economy approaches. This research was supplemented by an assessment of external rating agencies indices, feedback on Imerys CSR performance in 2016 and a review of the Group 2017 senior leadership seminar takeaways and feedback to identify the perception of strengths and areas for improvement. As a result, a preliminary list of potentially significant issues was elaborated and validated by internal operational and functional experts.

A second phase of engagement with both external and internal stakeholders was then conducted. The Imerys global Employee Engagement survey launched in early 2017 was used to gain confidential and anonymous insights and feedback from across the Group. Consultation on the CSR themes was gained in 2018 through face-to-face engagement meetings held at various locations across the world. Over 140 senior managers and experts across the Group business and functions, as well as employee representatives were consulted. Feedback was gained from external stakeholders surveyed with the aim of achieving a representative mix in terms of types of organization (customers, investors, banks, suppliers, local community members, and associations) as well as geographic areas.

The third phase involved analysis and validation. Several interviews were conducted with Executive Committee members and senior management to structure the final results in 2018. The final assessment and the results were then presented and validated by CSR Steering Committee and Executive Committee.

At the end of 2019, the results of the materiality assessment were used to define mid-term CSR objectives. In 2021, in order to define the next 3-years mid-term objectives and targets, the first and second phases of the materiality assessment process were relaunched. The third phase is planned at the beginning of 2022.

For more information on the company’s most material issues please refer to Criterion 2: Materiality

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• GRI 102-40 Disclosure: List of stakeholder groups
• GRI 102-43 Disclosure: Approach to stakeholder engagement

The list of stakeholders’ groups with whom Imerys engages in various capacities across the globe includes: banks & brokers, business partners, competitor and peer companies, customers, employees, government authorities, local community members, media, non-governmental organizations, professional associations, shareholders and investors, and suppliers and subcontractors.

Based on the risk-based approach imposed by ISO 9001:2015, ISO 45001:2018 and ISO 14001:2015 Standards, Imerys Greece S.A. established a systematic and consistent methodology. This risk management methodology helped, between others, the identification of interested parties/ stakeholders and the identification of their needs and expectations. These interested parties were also correlated with Imerys Greece S.A. business processes.

Imerys Greece S.A. stakeholder groups and their specific engagement methods are:

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10. Προϊοντική Υπευθυνότητα και Καινοτομία

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys is committed to providing high-quality products to its customers, and indirectly, to end-users through sound, responsible product management. The Group’s commitment to sustainable product management and the development of technologies is a means to contribute to SDG 12 to ensure sustainable consumption and production patterns and to SDG 13 to take urgent action to combat climate change and its impacts. Imerys’ overarching goal is to identify and minimize the health, safety, environmental, and social impacts of all of Group products throughout their lifecycle, while maximizing their economic benefits and positive impacts to customers and their end consumers. Imerys is committed to the quality and safety of its products, which are assured through dedicated product stewardship programs.

In 2020, to continue to further strengthen the Group’s product stewardship program, a dedicated Product Stewardship Steering Committee, chaired by the Group CEO, was created.

The Group employs state-of-the art analytical methods, equipment, and testing to ensure that product assessments and associated decisions are driven first and foremost by sound science. The Group continually evaluates testing protocols and invests in innovation in health, safety, and sustainability across product ranges, locations, and production processes. These measures enable the Group to produce high-quality products, meet customers’ expectations and operate in a stringent, dynamic regulatory environment.

For certain minerals, the Group applies the Mine to Market Mineral Management (M4) program, both for owned and external deposits. Owned deposits are those the Group operates itself. Those deposits are thoroughly vetted for geological properties and employ careful mine planning. The Group may also source from a select number of high-quality external deposits. During the vetting stage, thorough preliminary testing is conducted to ensure the site meets the Group quality and safety standards. Thorough ongoing testing is then conducted before any material from these sites is accepted and materials that do not meet quality standards at any point are refused. In all cases, tests are regularly performed on finished products.

The Group product stewardship policy and supporting protocols, define the objectives, roles and responsibilities, guiding principles and specific requirements, as well as the continuous improvement process to be followed.

For products manufactured in (or imported into) Europe, the Group complies with the European Directive on “Regulation, Evaluation and Authorization of Chemicals” (REACH). Substances marketed by Imerys are frequently subject to risk studies to determine their properties (e.g., pursuant to the GHS/CLP Regulations in Europe). Imerys monitors these studies closely, and labels its products to appropriately reflect the results of these studies.

Going beyond compliance, Imerys is committed to developing materials and expertise to deliver relevant and innovative market-driven solutions to support the growth of the Group while at the same time delivering sustainable solutions to society. The capacity to quantify the environmental and social impacts and steer the Group’s product portfolio to ensure long-term product sustainability is a key theme within the Group SustainAgility program. The mid-term target is to assess Imerys Products in Application Combinations (PAC) according to CSR criteria to cover at least 40% of Imerys product portfolio (by revenue) and to ensure at least 50% of Group New Product Developments are scored as “SustainAgility Solutions” by the end of 2022. As of the end of 2021, 21% of the Group portfolio by revenue has been assessed. Within the innovation portfolio, 89% of the launched projects (in 2021) have been assessed as per the methodology and 70% have been rated as SustainAgility Solutions, in the top 2 categories ranked A+ and A. As such progress towards the mid-term targets is well on-track.

Imerys has launched its SustainAgility Solutions Assessment framework, which has been designed in line with the World Business Council for Sustainable Development (WBCSD) guidelines for Portfolio Sustainability Assessments (PSA), so as to objectively measure the sustainability of Imerys products and identify their environmental and social impacts. The SustainAgility Solutions Assessment framework provides a systematic, high quality, scientifically robust and transparent approach to review products and services based on several criteria, ultimately scored on two factors: Sustainable Value Creation – the balance between the economic value created and the environmental impact and Market Alignment – the level of sustainability-related benefits or challenges (based on an evaluation of public data and thorough review from key stakeholders).

In parallel with the definition of a larger framework to evaluate the Group products portfolio, Imerys has continued to calculate products’ environmental footprints or ecoprofiles from “cradle to-gate” (see graph attached), using a LCA methodology. The aim is to have covered the main product range by the end of 2022.

A 5-step systematic and scientific process is used:

1. Defining objectives, scope and process
2. Defining assessment segments
3. Detecting market Signals
4. Categorizing the portfolio
5. Reporting and using the results

In 2021, the Group assessed 36 products following the requirements of ISO 14040 & ISO 14044, bringing the total number of products ecoprofiles completed since 2018 to 113. A wide range of mineral and product families have been covered by such assessment (Kaolin, Refractory minerals, Talc, Perlite, Diatomaceous Earth, Mica, Carbonate, Wollastonite, Bentonite, Calcium aluminates, Tap hole clay, Refractory castables, steel casting flux).

Part of the innovation goal is to push the boundaries of Group products so that they are more effective in solving customers’ problems and providing over their lifetime more sustainable products in terms of their cost or environmental impact. Initiatives have accomplished both these goals through presenting which was also selected

The Group aims to help drive sustainable innovation in the specialty minerals industry, pushing the boundaries of Group products to meet customers’ needs while at the same time offering sustainable solutions that meet global environmental and social challenges. Recent innovations include:

• Imerys’ EcoBright solution: A stabilized slurry that is helping reduce the environmental impact of the paper industry’s bleaching processes. This sustainable innovative solution reduces the amount of hazardous chemicals used, the organic substances in effluents, the wood consumption and the carbon footprint of the chemical recipe.
• U-Technology project: The Refractory, Abrasives & Construction (RAC) France has presented new innovation of an ultra-reactive cement which allows a very significant reduction in cement content in rapid setting concrete and mortars while keeping the same level of performance and reducing the overall cost of the product. Thanks to U-Technology, the Portland cement content can be substituted, which leads to a reduction of the carbon footprint of the final product by 30-70%.
• TiO₂substitutes in Paint with low carbon footprint: Titanium dioxide (TiO₂), which provides opacity in paints, is one of the most important – but also one of the most expensive – materials used in paint formulations. Imerys carbonate, kaolin and talc already allow paint manufacturers to use less TiO₂ by up to 25%, while reducing their costs for the same opacity performance without altering the paint’s other properties. To go to next level of sustainable coatings, some paints producers have developed TiO₂, biocide and/or Volatile Organic Compounds (VOC) free formulations. Imerys has started to commercialize optimized mineral solutions for low and zero-TiO2 paints or biocide free-coatings (silicate paints) with a low carbon footprint.
• Lightweight foamed material (insulation, fire-resistant, no VOC): Mineral insulating foam is an emerging insulation technology progressing rapidly both in individual and collective housing.

Replacing organic insulation:

• It provides high fire resistance A1
• It is easy to transport and install
• It does not contain Volatile Organic Compounds (VOC)

Imerys’ mineral solutions notably reinforce the stability to the foam, improving the insulating performance as well as the ease of application

• Lightweight large ceramic tiles (slabs) with new mineral Formulations:Large format ceramic pieces (slabs) are growing quickly for countertops, facades and flooring, in many cases substituting natural stone or resin based composites
  • Consumers want quality and durability without compromising beauty
  • Soul of natural stone but without the hassle of sealing it
  • Produced locally, less long-range transportation
  • Down to few millimeters in thickness

Imerys formulations and products are specifically dedicated for lightweight large slabs

• to sustain stress related to its large size
• to lightweight and reduce material usage (makes installation easier)
• to use less firing energy during manufacture (-15%)

Imerys is actively developing new formulated solutions to make slabs even lighter and/or include waste construction materials

• Minerals for ETICS (External Thermal Insulation Composite System): ETICS is an external building insulation technique based on a cladding system that provides exterior walls with an insulated finished surface. In such “ready to use” systems, Imerys provide various mineral solutions for:
  • 15% lightweight renders, meaning: more comfort for the end-user (less weight to handle and easier to apply products) & lower environmental emission in their transportation
  • Pinholes and crack reduction of the finishing rendering topcoat, hence the resistance to water, better durability of the cladding and aesthetics
  • Lower thermal conductivity (better insulation properties)
  • Maintain fire resistance with mineral addition
• 30-50 year protection with Imerys calcium aluminate mortar:Imerys calcium aluminate based mortar is designed to protect sewer systems against biogenic corrosion, that cause damage and potential for serious collapse. Compared to Epoxy liners calling for repeated costly rehabilitation, Imerys solution offers an extended service life up to 50 years to be compared with 6 years with traditional epoxy and as a consequence:
  • Less consumption of raw materials reducing the utility owners CO₂footprint
  • Reduced labor and trucking needs reducing the utility owners CO₂footprint
  • Reduced asset down time increasing productivity and lowering the risk for untreated water to be released into the environment

Imerys mineral composition does not release any harmful solvent preventing worker exposure to toxic components

• Pozzolans as low CO₂additive in Hydraulic Binders: Imerys’ perlite and metakaolin may partially substitute Clinker with a lower CO₂ footprint in CEM II or CEM V pozzolanic cements. Perlite’s cementitious activity is natural thanks to its volcanic origin. Metakaolin requires a calcination step emitting up to 60% less CO₂ than clinker. For flooring application, Imerys Ultra Reactive Binder technology allow reduction of CO₂ emission up to 40% in the final application compared to a formulation based on 100% Ordinary Portland Cement. Imerys is developing new Geopolymer Technologies “Just Add Water” (new generation of low CO₂ binder using 0% clinker) for various applications with additional benefits:
  • Fireproof building material
  • No Volatile Organic Compounds (VOC) insulating boards
  • High chemical resistance & aesthetic geopolymer renders

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• GRI 302-4 Disclosure: Reduction of energy consumption

Imerys Greece S.A. facilities have set as energy efficiency target for 2021, 2% improvement on the 2020 baseline by the end of the year (please refer to criterion 3 for full list of 2021 Imerys Greece S.A. CSR Objectives). The energy efficiency for the facilities in 2021 was improved by 5.7% compared to 2020, significantly overshooting the goal set. This was achieved due to the increased hours of production in the facilities and additionally climatic conditions were more favorable for natural drying, with annual precipitation in 2021 being 295mm while in 2020 annual precipitation was 405mm.  Moreover, the company is trying multiple projects in order to reduce energy use. There is a concentrated effort to phase out heavy fuel in the plants. Natural gas, electrification and a variety of renewables are considered. Additionally, projects for better automation are ongoing which are expected to yield an improvement in energy efficiency.

In Milos facilities, FLU-ACE condensing flue gas economizer project in Bentonite plant was launched mid-2015 and after almost two years of research and development (R & D) studies and preparations, it was first implemented on May 2017. The system is an exclusively in-house project development and is considered an Imerys proprietary process. In 2017, 4 people have been occupied with the projects implementation and 400 hours have been spent, while the cost is estimated to approximately 208,000€. Net present value from the system’s operation is 124,000€ (depending on current oil prices). Target audience of this project is the local community and environment of Milos island.

The project’s goal is two-fold (1) to reduce energy (heavy fuel oil) consumption by an average of 6-7%, and (2) to produce 0,8 M³/hour water for industrial use. Specific numbers have as follows:

• An average of 310 kW of heat is recovered from the exhaust gases of the Tsigrado dryer.
• Around 0.8 M³/hour water for industrial purposes is produced by cooling the flue gas from approximately 70-80°C down to 40° The total production of water for 4,500 hours of operation is 3,600 M3.

The system is now also used in the Tsigrado plant. In total the project is reducing CO₂ emissions by a total of 1384 tCO₂e per year.

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11. Χρήση Φυσικών Πόρων

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys is committed to respecting regulations, to minimize negative environmental impacts associated with its operations and to ensure an environmental conservation approach. For this purpose, Imerys ensures it has identified and assessed the environmental risks related to its activities and implemented measures and controls to prevent and limit negative impacts. The efficient use of resources such as minerals and water are therefore at the core of the Group’s concern. In parallel, aware of the importance of maintaining functional ecosystems where it operates, Imerys places a special focus on biodiversity preservation. By efficiently exploiting the resources at its disposal and creating positive biodiversity value in the long term, Imerys is committed to SDG 6 to ensure availability and sustainable management of water, to SDG 12 to ensure sustainable consumption and production patterns and SDG 15 to protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and reverse land degradation and halt biodiversity loss.

Environmental Management

Imerys’ Environmental Charter, signed by the Group CEO and reviewed annually, forms the basis of the approach taken to the monitoring and continuous improvement with regards to the environment. Environmental stewardship rests upon the implementation of a robust Environmental Management System (EMS), which is a key factor to improve operating efficiency while reducing environmental impacts. Imerys requires each operation to have an effective EMS enabling it to identify and establish controls for significant environmental risks. The mandatory EMS requirements for all activities are covered by Group-wide environmental protocols, which include eight pillars aligned to the core elements of the international standards for environmental management systems: policy, aspects and impacts, legislative and regulatory requirements, objectives and targets, roles and responsibilities, training, emergency response, and auditing. The environmental protocols specify the internal requirements applicable to all operations. They define the responsibilities of site-level and senior managers and Group EHS personnel in managing and controlling potential exposures and risks in order to prevent adverse environmental impacts and to reduce the environmental footprint of operations. To continue to strengthen environmental management across the Group, a maturity matrix covering the critical elements of sound environmental management was developed. This maturity matrix which, as with the other continuous improvement matrices deployed across the Group, will be used to assess site level environmental performance and guide the development of action plans. To confirm compliance and conformity with regulations and Group protocols, Imerys operations are audited at regular intervals as per the Group auditing protocol. The mid-term environmental management target is for the Group to deploy the continuous improvement program and ensure that environmental audits are based on the defined maturity matrix. The Group has begun the roll-out of the environmental maturity matrix and while the number of Environmental Management System audits conducted in 2021 was impacted by Covid-19 restrictions, 90% of the environmental audits that were completed were based on the environmental maturity matrix. The audits that could not be completed in 2021 shall be carried-over into 2022.

In addition to implementation of mandatory EMS requirements, which are fully aligned with international standards, the Group encourages ISO 14001 and Eco-Management and Audit Scheme (EMAS) certifications. As of the end of 2021, 122 of 247 (49%) of Group operations are ISO 14001 or EMAS certified by external certification organizations.

Since 2018, the Group has been progressively deploying a new integrated solution to manage environmental legal compliance and regulatory monitoring. This new solution supports the development of updated environmental legal registers, with regular alerts, register updates and regulatory assistance by environmental legal specialists for each country. To date approximately 82/245 (33)% of Group sites, including France, China, Greece, Netherlands, Thailand, US and Brazil sites are covered by this news solution. In addition to the new solution developed at Group level, sites across Imerys use various other tools to support regulatory monitoring locally.

Wastewater Management

Wastewater discharge is managed and reviewed in the site-specific EMS in compliance with the corresponding regulatory limits. Any release of water that has a potential to create a nuisance is required to be reported into the Group environmental incident reporting platform described above. Each wastewater discharge incident is investigated as per Group protocol, and corrective action plans are followed until closure.

The Group continues to explore solutions to improve discharged water quality through the introduction of new technology. For example, at Imerys Doreys site in the United Kingdom, a partnership with Bournemouth University resulted in an ecological restoration initiative to improve the water quality in the toll bar stream and re-establish a naturally sustainable and balanced fish community. The initiative included the introduction of a multi-parameter monitoring, which measured improved water quality and reduced turbidity as a result of the program. Within the ecological restoration program local community representatives were consulted on the approach proposed as well as through various stages of the fish surveys. The local fish species that were selected for translocation were successfully reintroduced, creating a self-sustaining community of local fish species.

Waste Management

Imerys processes minerals using methods that are primarily mechanical and physical. As such the Group’s activities generate relatively small quantities of domestic and industrial wastes. The Group is nevertheless committed to reduce waste generation through prevention, reduction, recycling and reuse as a means to contribute further to SDG 12 on sustainable consumption and production patterns.

Overburden and unused mineral solids (e.g., tailings, off–specification materials, etc.) are usually stored on or near production areas at the quarries given their potential to be valorized in the future. Overburden and unused minerals are also used in many cases as backfilling or re-profiling materials in post-mining restoration work. As such, this material is not classified as waste.

In addition, Imerys’ commitment to sound mineral resources management, technological improvements and newly-developed applications makes it possible to transform low-grade materials or tailings into marketable resources. The Imerys ReMined TM products, for example, produced from calcitic white marble, are 100% certified as pre-consumer recycled materials and eligible for various green building credits in the United States (e.g., LEED® Program, National Green Building Standard, NSF/ANSI 140).

Non-Energetic Resources Efficiency

The technological know-how of Imerys, as a world leader in industrial minerals, enables the Group to be in an excellent position to improve the yield of its mineral resources. At the same time, the strength of the Group’s commercial network and strong innovation capacity maximize Group production value and capacity to optimize resource use efficiency across the globe, thereby contributing to SDG 12 to ensure sustainable consumption and production patterns. The Group is continuously improving the production processes by analyzing the environmental impacts associated with Group operations. In 2021, the Group conducted 36 “cradle to gate” Life Cycle Assessment, which provide a detailed inventory of non-energetic resources consumed during each phase of production of the products.

For more information on the product Life Cycle Assessments please refer to Criterion 12: Resource Management.

Biodiversity and Rehabilitation

The question of impacts on the living world arises during the entire life cycle of a quarry, whether for the choice of the site, its operation, its rehabilitation or its post-rehabilitation land use. Imerys activities cause direct and indirect impacts on biodiversity. Imerys has a major responsibility to operate without net biodiversity loss. Aware of this responsibility, Imerys has been committed to preserving biodiversity for many years. Given the serious global threat to biodiversity, Imerys is committed to further structure and harmonize its approach in order to continue mobilizing the Group and its teams around this major issue. Imerys has designed and implemented a biodiversity project, aligned with the main goals of the French National Biodiversity Strategy, to continue to contribute to SDG 15 to protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, halt and reverse land degradation and halt biodiversity loss.

Rehabilitation is integrated into the Life of Mine (LOM) plan of each quarry operation at Imerys and considered throughout the conduct of its activity until closure. Rehabilitation planning starts from the very initial phase of mine permitting as it is included in the environmental impact assessment of the projected site operations. As most countries define the regulatory framework for the preparation, submission, consultation and approval of environmental impact assessments for resource operational permits, in most cases rehabilitation plans are disclosed through a public consultation process prior to final approval.

Starting in 2017, the Group has carried out an assessment of the biodiversity issues associated with its operations, in collaboration with key stakeholders based on the EBEvie approach, which resulted in a program designed to respond to the identified challenges. To support the development and implementation of the program, Imerys entered into a three-year scientific partnership (2018-2021) with the UMS Patrimoine Naturel, an umbrella organization bringing together the French National Museum of Natural History (MNHN), the French Agency for Biodiversity and the National Center for Scientific Research (CNRS). In addition, Imerys has committed to act4nature initiatives that have been launched by “Entreprises pour l’Environnement” (EpE) and other partners with the aim of mobilizing businesses to protect biodiversity. The mid-term target is for the Group to achieve all objectives defined within Group act4nature commitment and renew engagement for an additional midterm cycle by the end of 2021. At the end of 2021, the Group has completed 100% of the objectives defined in 2018. At the end of 2020, as 93% of the objectives had already been achieved, Imerys anticipated the renewal of its commitment to act4nature International for a second phase (2021-2024) and likewise renewed the Group’s scientific partnership with UMS Patrimoine Naturel for an additional three-year cycle (2021-2024). Throughout 2022 and beyond, Imerys will work to fulfill its commitments under act4nature.

The act4nature partners have established ten common commitments to engage businesses to include biodiversity in their global development strategy. As a member of act4nature, Imerys signed the ten common goals and in 2018 articulated its own program in specific commitments linked to the act4nature engagements. Progress in the development of the program has enabled Imerys to improve technical and scientific knowledge on biodiversity and roll-out actions to address the identified challenges, as described below:

1. Design and deploy a global continuous improvement approach: the diversity of Imerys’ activities and geographic location translate into very diverse ecological, regulatory and maturity contexts depending on the site. This is why Imerys designed a maturity matrix that aims to support sites in the assessment of their environmental performance. In 2019 Imerys began collecting ecological data from its sites in France to assess the challenges and their ecological quality, as well as their potential to promote local fauna and flora. At the end of 2020, Imerys completed sensitivity mapping for 101 sites across the world using the World Database of Protected Areas. In addition, the French National Museum of Natural History is developing a multi-criteria tool to evaluate the sensitivity of Imerys' French sites at a territorial scale. Working together with partners UMS Patrimoine Naturel Imerys co-developed internal guidelines that outline the actions to be implemented to ensure the protection of biodiversity throughout the life of Group quarries.
2. Initiate and conduct studies and research on biodiversity knowledge and conservation: the French National Museum of Natural History carried out “Évaluation de l’équivalence écologique” (ECOVAL) analysis on two Group sites, as well as four biodiversity diagnostics in quarries in France and Brazil, which help to improve the quality of the Mitigation Hierarchy. Together with partners Imerys has begun to test an Ecologic Quality Index methodology on two sites in France. In addition, a scientific article was published in Espaces Naturels based on the rehabilitation efforts of Imerys in Milos, Greece. As a result of the studies undertaken, 1,807 data entries on biodiversity were published in The National Inventory of Natural Heritage. The mapping of biodiversity-related stakeholders was initiated, however this activity was postponed and will be taken up again at a later date.
3. Develop pilot projects: Imerys deployed three pilot projects sites in Brazil, Greece, and France to improve rehabilitation techniques in different ecological contexts. These pilot projects support the use of the Mitigation Hierarchy throughout the life cycle of a mine, provide support for existing initiatives and contribute to research on improving rehabilitation techniques.
4. Raise awareness, train and involve internal and external stakeholders: Imerys has implemented numerous activities with internal and external stakeholders to create greater awareness on biodiversity. The Group organized educational sessions on biodiversity with employees in Clérac, France and training sessions on the mitigation hierarchy for all site managers in France. The Group likewise launched a pedagogical film on biodiversity for Group employees to share details on the program and raise awareness on biodiversity. In 2020 an internal environmental community was created, which shall support the dissemination of good practices and biodiversity knowledge across the Group. Imerys has participated in numerous external forums dedicated to biodiversity together with other industrial actors and associations.

In parallel with the development of the Group biodiversity roadmap, sites across Imerys have continued to develop local initiatives aimed at supporting biodiversity and promoting innovative rehabilitation projects, both during and after mining activities.

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• GRI 301-1 Disclosure: Materials used by weight or volume

In 2021 Imerys Greece S.A. mined 1,215,030 MT of bentonite, 725,119 MT from Aggeria mine, 364,352 MT from Agia Irini mine, 60,460 from Koufi, 38,460 MT from Aspro Chorio and 26,639 MT from Zoulias mine. It also mined 451,934 MT of perlite, 336,481 MT from Tsigrado mine and 115,453 from Trachilas mine. 32,811 MT of sodium carbonate (Na2CO3) were also used in 2021 for bentonite activation.

• GRI 302-1 Disclosure: Energy consumption within the organization

Imerys has operational energy demand, especially in its mineral transformation processes that use thermal technologies and its quarrying activities that use heavy equipment. Energy efficiency improvement makes it possible to use less energy to achieve the same level of productivity and consequently to contribute to climate change mitigation efforts. The Group energy efficiency strategy is based on two pillars: efficiency, which consists of measuring, decreasing consumption, and recovering energy losses, and sourcing, which is based on using alternative energies, promoting renewables, and building sustainable industrial assets. Imerys is improving energy management and driving excellence through the Group “I-Cube” Program (a program designed to continuously improve its industrial processes and performance entitled Imerys Industrial Improvement).

The energy consumption per energy source in Milos facilities and Athens office premises, for 2021, is depicted in the following tables:

• GRI 306-2 Disclosure: Waste by type and disposal method

Total waste quantity per facility and per European waste code (type of waste) is depicted in the following table. All waste are managed outside Imerys Greece S.A. facilities by certified waste companies. Herein total waste quantities are depicted for the year 2021.

For information regarding Water withdrawal by source (GRI Disclosure 303-1) please refer to Criterion 12.

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12. Διαχείριση Πόρων

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys is committed to assess relevant environmental risks and continually improve control measures to reduce adverse environmental impacts, maximizing the efficient use of natural resources and conserving and creating biodiversity value.

Mineral Resources Optimization

Establishing and maintaining effective management of mineral resources is the core of what Imerys does. Mineral resources management is defined through a series of mining and resources planning policies, procedures and protocols, which are reviewed regularly. Each mining operation is required to have a Life of Mine Plan (LOM Plan) and create a detailed FiveYear Mine Plan. This approach enables the operations to maximize the efficient use of mineral resources.

In 2019, the Group updated the maturity matrices used to audit mineral assets. These matrices now focus on “Mineral Resources” and “Mineral Reserves” and are used to audit sites on a three to five year-cycle. As with other matrices in the “I-Cube” program are used to drive continuous improvement and the development of action plans. Imerys supports, has aligned its internal standards to and is continuously improving its operations in line with the Global Industry Standard on Tailings Management.

Opportunities to optimize mineral resource consumption are identified continuously during the implementation process of the “I-Cube” program and through other ongoing initiatives, including the Group SD Challenge. The Group is constantly seeking to develop ways to create a more sustainable, circular value chain and still produce high-performance end-product for customers. An example of this approach is demonstrated by four sites in the United Kingdom, which have recovered an estimated of 1.2ktpa by applying dust and clay recovery management techniques, or the Mica recovery beneficiation process created in Kings Mountain (US), which increased mica recovery from 66% in 2014 to 84% in 2020. Similar projects are being investigated in other areas across the Group.

The industrial minerals industry is working in partnership with downstream industries on processes to increase recyclability. In 2018, IMA-Europe published a report entitled “Recycling Industrial Minerals”, where they studied publicly available data on recycling of glass, plastic, concrete and paper and concluded that a total of 40% to 50% of all minerals consumed in Europe are recycled. While recycling rates of industrial minerals are relatively high, the Group is committed to continue to identify recycling opportunities and assess circular economy solutions, recognizing the global need to produce with less, for longer and smarter.

In addition, Imerys’ commitment to sound mineral resources management, technological improvements and newly developed applications makes it possible to transform low–grade materials, tailings and wastes into marketable resources. The Imerys ReMinedTM products, for example, produced from calcitic white marble, are 100% certified as preconsumer recycled materials and eligible for various green building credits in the United States (e.g., LEED® Program, National Green Building Standard, NSF/ANSI 140).

Water Management

Imerys aims to minimize the impact of its operations on the consumption of water resources. The Group is committed to ensure effective management of water resources by focusing on the following axes:

• optimizing water consumption by limiting withdrawal from natural environment; and
• developing recycling possibilities for process water.

Imerys classifies water withdrawals according to source, including groundwater, surface water and water from suppliers. Water moved from one zone to another without being used (water pumped for quarrying operations) is not quantified within this metric as the quality of this water is not altered.

Total water withdrawals reported in 2021 increased relative to 2020 due to a series of factors. Firstly an increase in production activities of 12.4% resulted in higher water consumption on certain sites. Furthermore, in 2021 several sites installed new water meters thereby extending the number of sites able to report on water withdrawal. The roll-out of the Group’s new environmental reporting protocol and associated reporting tool extended the scope of water consumption monitoring and reporting obligations with the aim to increase water consumption reporting accuracy, but this extension of reporting scope makes comparison with previous years difficult.

The top 10 water users in the Group account for approximately 50% of total annual water withdrawal. Site-specific water management plans have been established at these sites. The plans include a description of current water use, water balance analysis, water accounting, water risk assessment and pertinent action planning to manage high priority water issues.

In 2021 Imerys used the World Resources Institute (WRI) “Baseline Water Stress” indicator within the Water Risk Filter (WRF) to assess current exposure to water stress. The WRI’s “Baseline Water Stress” risk indicator measures the ratio of total annual water withdrawals to total available annual renewable supply, accounting for upstream consumption. Based on the baseline assessment results, the current risk of water stress linked to resource access concerns 75 Imerys sites. They are located on the West coast of America, in South Africa, India and around the Mediterranean basin. Among them, only 12 have medium (> 100,000 m3) to high (> 1 Mm3) water consumption. The sites have been defined as the priority for efforts to reduce water consumption. Furthermore, the Group roll-out of the new environmental reporting tool in 2021 will continue to improve monitoring and help reduce water consumption.

Imerys also reports the amount of water recycled by its operations as recycling water reduces the amount of water being removed from natural habitats, thereby reducing the Group’s water footprint. The Group is working towards the identification of innovative ways to reduce its water footprint. As an example, in Thabazimbi (South Africa), where water is essential for mineral processing but the operations are located in an area where water scarcity is an important challenge. The plant identified as a major improvement opportunity the implementation of a thickener that will enable the operation to recycle directly the water in the plant thereby preventing significant reduction of water loss from evaporation and seepage. An estimated 347,000 m3 of water has been saved since the project’s launch in 2020.

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• GRI 303-1 Disclosure: Water withdrawal by source
• GRI 303-3 Disclosure: Water recycled and reused

The total volume of water withdrawn by Milos facilities in 2021 is given with a breakdown in municipal water supplies, ground water and surface water. The amount of water recycled is also being reported, as recycling water reduces the amount of water being removed from natural habitats, thereby reducing Imerys water footprint. The consumption of water is reported quarterly.

The water consumption in Athens office premises, for 2021, has as follows:

Please refer to Criterion 11 for additional information regarding materials used by weight or volume (GRI Disclosure 301-1), energy consumption within the organization (GRI Disclosure 302-1) and waste by type, disposal method (GRI Disclosure 306-2) and to Criterion 10 for reduction of energy consumption (GRI Disclosure 302-4).

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13. Εκπομπές αερίων και Κλιματική Αλλαγή

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys recognizes that climate change is a major global challenge. In 2017, on the occasion of the international One Planet Summit, the Group became a signatory of the French Business Climate Pledge. In 2021 Imerys renewed its commitment within The French Business Climate Pledge. Through this Pledge, Imerys publicly affirms its engagement to contribute to the collective efforts, drawing up a roadmap compatible with the international commitments formulated in the Paris Agreement and work towards SDG 13 to take urgent action to combat climate change and its impacts.

Imerys has aligned its climate change strategy to a 2° C trajectory scenario committing to reduce Scopes 1 and 2 emissions by 36% relative to revenue by 2030 (from a 2018 base year) and for Scope 3 indirect emissions engaging with its suppliers to align with a science-based low-carbon trajectory by 2023. At the end of 2021, Scope 1 and 2 emissions relative to revenue decreased by 23% from the 2018 base year, while 26% of the Group suppliers have already confirmed science-based emission reduction targets based on the first phase of the Group’s supplier project initiated mid-2020.

Climate Change Strategy

Since the end of 2017, the Group has been working to address climate change as a priority CSR theme. The Group created a cross-functional working group to complete a comprehensive climate change benchmark, assess risks and opportunities as well as current CO₂ footprint of the Group, and define relevant KPI and targets. Imerys has likewise identified concrete levers for carbon reduction in the context of the long-term climate change strategy. The defined strategy will ultimately cover every domain: organization, equipment, methods, technology, supplies, transportation, and renewable energies. The Group has defined Scope 1, 2 and 3 emissions reduction targets, which have all been approved by the SBTi.

A preliminary identification of climate change risks to which the Group is exposed was conducted in 2018 following a “stress-test” methodology. In 2021 this initial study was updated, including a stress test and scenario analysis based on the

International Energy Agency’s 2019 World Energy Outlook Report. The risk and opportunity scenario analysis covered transitional risks (industrial risks, market-related risks and opportunities) as well as physical risks. These studies assessed the financial exposure of the Group versus a combination of three time horizons (2030, 2040 and 2050) and three International Energy Agency’s scenarios.

The Group has aligned its 2021 climate disclosure with the Recommendations of the TCFD. For the past 14 years, Imerys has participated in the CDP. The Group 2021 CDP performance score is ranked as Level B, which places the Group in the second highest band, corresponding to management of climate issues in a concrete and systematic way. Imerys’ comprehensive climate reporting through the CDP is publicly available.

Air Emissions Management

Several of the Group’s mineral conversion processes use calcination, which can emit nitrogen oxide (NO_X) and sulfur dioxide (SO₂).

The Group continues its efforts to reduce both SO₂ and NO_X emissions related to its operations through technological upgrades and investments, for example, through the conversion from coal to natural gas in the alkali melting and calcination phase, at Zhejiang site in China.

Scope 1 and 2 Strategy

The Group’s Scope 1 emissions considered as direct emissions are generated from energy-related emissions such as fossil fuels, diesel and process related emissions, and the Scope 2 emissions considered as indirect emissions are mainly related to purchased electricity consumption. Combined Scope 1 and 2 emissions represent approximately 45% of the Group’s total emissions. As such the strategy and action plans for both scopes are addressed principally through improving energy efficiency and increasing the use of renewable energy as well as investing in research to reduce process-related emissions.

Energy Efficiency

Imerys has operational energy demand, especially in its mineral transformation processes that use thermal technologies and its quarrying activities that use heavy equipment. Energy efficiency improvement makes it possible to use less energy to achieve the same level of productivity and consequently to contribute to climate change mitigation efforts. The Group energy efficiency strategy is based on three pillars from Group to plants level: management system, technical performance, and behavior. The management system structures the vision, objectives, performance tracking, policy and procedures. Technical performance is driven by asset optimization, operational performance as continuous improvement and technology change. Behavior is about awareness and the promotion of energy efficiency, which is reinforced with training, seminars, knowledge base sharing and dedicated energy efficiency community.

Initiatives are driven collaboratively between the different operational and functional groups at Corporate, Business Area and site levels, including operations, industrial management, environment, geology and mining. The Group Corporate energy team is responsible for supporting plants with a dedicated energy efficiency methodology, defining the analysis and reporting standards and providing the necessary training to ensure consistency and reliability of the reported results. Detailed energy efficiency analysis is disclosed in a quarterly energy report. This analysis, together with the improvement plans, is reviewed by the Group senior management.

Part of the Group variable performance-related components of compensation for concerned managers (energy managers, facility managers, process operation managers, etc.) has also been linked to performance against internal energy efficiency and CO2 emission reduction KPIs.

The overall change in energy consumption between 2020 and 2021 is linked to an increase in production, with a total volume increase of 12.4% year-on-year in 2021. While total energy consumption increased with increased production, the percentage of natural gas and other fossil fuel consumed within the Group’s total energy consumption continued to decrease in line with the Group’s decarbonization efforts.

In 2019, the Group launched the “I-Nergize” program to focus on evaluating sites energy performance and improve energy efficiency, with a particular focus on top 66 energy consuming sites representing 80% of Group consumption. This program is based on an assessment methodology covering six main items: vision, process, maintenance, purchasing, renewables, and Energy Management System. The outcome of this program is to define a three-year roadmap of energy actions for each plant in order to improve energy efficiency and reduce carbon emissions. While the possibility to complete the site energy assessments was impacted by Covid-19 travel restrictions, at the end of 2021, 19 sites have been assessed as of the end of 2021. These assessments have identified 60 kt of CO 2 that may potentially be saved.

Energy-related digital training modules are available within the Learning Hub to provide an overview of Imerys’ energy strategy as well as knowledge and awareness on energy efficiency. In addition, internal knowledge databases have been created on Dryers, Rotary Kilns, Motors and Ball Mills to promote the best practice of industrial energy efficiency on key equipment used in Imerys. The Group has also conducted three virtual classes with more than 330 attendees on various specific energy-related topics such as Flash Dryers, Brainstorming methodology and Knowledge base.

A dedicated energy community on the Group intranet serves as a platform to share knowledge, good practices and events related to energy.

Imerys Greece S.A. facilities have set as energy efficiency target for 2021, 2% improvement on the 2020 baseline by the end of the year. The energy efficiency for the facilities in 2021 was improved by 5.7% compared to 2020, significantly overshooting the goal set. This was achieved due to the increased hours of production in the facilities and additionally climatic conditions were more favorable for natural drying, with annual precipitation in 2021 being 295mm while in 2020 annual precipitation was 405mm.  There is a concentrated effort to phase out heavy fuel in the plants. Natural gas, electrification and a variety of renewables are considered. Additionally, projects for better automation are ongoing which are expected to yield an improvement in energy efficiency.

Renewable Energy Sources

The Group continues to support the transition to renewable energy and cleaner fossil-fuel technology where feasible, either with power from low-carbon sources or biomass waste. Through the Group’s low carbon electricity purchasing strategy, Imerys systematically assesses the options to supply Imerys operations with low carbon or renewable energy sources including solar, hydropower and wind power. Different business models have been developed to promote low-carbon electricity such as on-site Power Purchase Agreements (PPA), off-site PPAs, certificates, lease agreement and direct investment for small scale projects. In 2021, 150 kt of CO2 emissions were avoided in the eight different countries for Imerys sites that use low carbon power: United Kingdom, Brazil, United States, India, Australia, Belgium, Austria and Slovakia.

In addition to the low-carbon power described above, the Group also has 15 renewable energy installations on-site that have been developed across Group sites: seven in the United Kingdom, seven in France, one in United States, accounting in total for 60 MW installed. These on-site installations provide renewable electricity to the local grid. The produced renewable energy from these installations is not reflected in the reported energy or CO2 data consolidated.

Biomass waste is promoted within the Group to replace fossil fuels when it is feasible. Currently, five plants are consuming biomass waste such as wood chips, sawdust, animal waste, olive seeds and peanut hulls. The most recent project ongoing in Andersonville in the US, is introducing waste ground peanut shells as an alternative energy source. The objective of the project is to adjust the installation to modify the energy mix by integrating biomass waste as an energy source and thus significantly reduce fossil carbon emissions linked to operations. At the end of the project, the fuel mix will be modified, moving from a historical 100% fossil fuel supply to a ratio of 56% biomass fuel to 44% fossil fuels, which is expected to reduce around 3% of the Group’s total CO2 emissions per year. Similar feasibility studies have been launched for other sites.

Carbon Emissions Management

The majority of the Group greenhouse gas emissions are generated through the production of thermal energy from natural gas and fossil fuels. Alternatives to these energy sources, such as biomass and steam are increasingly investigated and used. Indirect emissions from the consumption of electricity are the second source of emissions. Some processes used in Imerys operations result in direct emissions of CO₂ (e.g. de-carbonation of raw materials). Measures to monitor and reduce GHG emissions are one of the principal means through which the Group contributes to SDG 13 to take urgent action to combat climate change and its impacts.

In 2021, a new energy and environmental reporting tool was deployed. This new tool was structured to facilitate the reporting of market-based greenhouse gas emissions as well as location-based greenhouse gas emission reporting. The new tool was also structured to facilitate increased data reporting accuracy for renewable energy. With the design and implementation of the new reporting system, all emission factors used for the calculation of greenhouse gasses were updated. The updated emission factors are based on the updated Environmental Protection Agency (EPA), International Energy Agency (IEA) and Emissions and Generation Resource Integrated Database (eGRID) databases each year from 2018 onwards. As a result of this update, and in line with the Group GHG Recalculation Policy, the change in calculation methodology triggered the recalculation of the 2018 base year. For 2018, 2019 and 2020, all the Scope 1 emissions for each year have been recalculated using the most recently available fuels emission factors from the EPA. The location-based Scope 2 emissions have been recalculated each year using the available emission factors at the start of that given year. For 2021 for the market-based reporting, the emission factor

provided by the supplier has been used.

For 2021 the Group Scope 1 and 2 CO2 emissions equaled 558 tCO2eq per million euros of revenue, which represents a 23% decrease since 2018 based on the recalculated base year. This decrease relative to previous years is the result of the increase in energy efficiency, the substitution of fossil fuels with biofuels as well as the improved accuracy of reporting of Scope 2 emissions in market based reporting and the integration of renewable electricity indicators.

Scope 3 Emissions

Scope 3 is considered an indirect source of emissions, which based on Imerys’ estimation as described below, represents about 57% of total Group emissions. Imerys is committed to address this challenge through science-based targets. The Group’s main source of Scope 3 emissions is generated from the purchase of goods. To mitigate this impact, Imerys defined a supplier engagement target to have 71% of suppliers (by spend) with science based targets by 2023, covering Scope 3 categories such as purchased goods and services, fuel and energy related activities (not included in Scope 1 or 2), upstream transportation and distribution, waste generated in operations and downstream transportation and distribution. These categories are estimated to represent around 95% of the Group’s total Scope 3 emissions. As of the end of 2021, 26% of the Group suppliers, representing approximately 450 suppliers, have science-based emission reduction targets.

Reliable emission data from Group suppliers is not readily available; as such the estimation of Scope 3 emissions does not yet represent a full calculation of all Scope 3 emissions linked with Imerys operations. However, in order to continue to improve the quantification and to identify potential levers to reduce Scope 3 emission, in 2021, Imerys launched a dedicated project to quantify the CO 2 emitted for goods and services purchased by the Group based on the GHG Protocol’s Corporate Value Chain (Scope 3) Accounting and Reporting Standard. This quantification methodology and exercise, which covered 86% of Group purchases of goods and services data, was subsequently audited by one of the Group Statutory Auditors.

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• GRI 305-1 Disclosure: Direct (Scope 1) GHG emissions
• GRI 305-2 Disclosure: Energy indirect (Scope 2) GHG emissions
• GRI 305-3 Disclosure: Other Indirect (Scope 3) GHG emissions

Every year about 1,000,000 MT of bentonite are mined on Milos Island and almost all of that quantity has to be dried to 15% on average. Significant energy saving is achieved by exploiting Milos island climatic conditions - high temperature and wind during summer - for the natural pre-drying of bentonite in open fields. This results in approximately 35% annual energy savings, compared to the energy that would be required if industrial drying was exclusively used. It is estimated that some 100,000 MT of water are evaporated on a yearly basis through this field drying process. This is equivalent to actual savings of about 7,500 MT of annual heavy fuel oil consumption, corresponding to CO2 emissions reduction in the range of 24,000 MT per annum.  Moreover, the company is trying multiple projects in order to reduce energy use. There is a concentrated effort to phase out heavy fuel in the plants. Natural gas, electrification and a variety of renewables are considered. Additionally, projects for better automation are ongoing which are expected to yield an improvement in energy efficiency.

Scope 1 emissions are direct emissions from sources owned or controlled by Imerys, while Scope 2 emissions are indirect emissions from the generation of purchased energy and finally Scope 3 emissions are the rest of indirect emissions.

Imerys is taking action to reduce Scope 3 emissions, focusing in particular on purchased goods and services, however, efforts also target other sources of Scope 3 emissions, for example the integration of an internal carbon price within capital expenditure (CAPEX) projects favors machines with greater fuel efficiency and the Group’s Industry 4.0 project will help to monitor and reduce non-productive engine idling generating additional reductions in fuel consumption.

• GRI 305-7 Disclosure: Nitrogen oxides (NOx), sulfur oxides (SOx), and other significant air emissions

Several of the Group’s mineral conversion processes use calcination, which can emit nitrogen oxide (NO_X) and sulfur dioxide (SO₂) (See table below for the emissions generated by the group). The Group continues its efforts to reduce both SO₂ and NO_X emissions related to its operations through technological upgrades and investments, for example, through the conversion from coal to natural gas in the alkali melting and calcination phase, at Zhejiang site in China. In Milos the facilities are focusing on phasing out heavy fuel completely.

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14. Εργασιακά Δικαιώματα

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys strives to promote mutual respect in all practices and dealings with its employees, and outside contractors. Imerys recognizes that management of relations with employees is critical to the creation of an environment in which all employees can excel. The Group is committed to comply with local legislation in force in the countries where it operates and to respect internationally-recognized human rights, as set out in the International Bill of Human Rights and provisions of the fundamental conventions of the International Labour Organization (ILO), particularly in terms of non-discrimination, privacy, child labor, forced labor, compensation and working hours. The Group is committed to respect human rights, avoid complicity in human rights abuses and provide access to remedy, in line with the UN Guiding Principles on Business and Human Rights. Imerys endeavors to have a positive impact through its employment practices upon the welfare of employees, which likewise has both indirect and induced positive impacts also on surrounding communities and thereby contribute to SDG 8 to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.

The Group Code of Business Conduct and Ethics spells out the fundamental principles and shared commitments to ethical behavior, including respect of human rights and labor practices. The Code applies to all Imerys employees, including those of its subsidiaries, as well as Imerys business partners. Managers at Imerys have a particular responsibility to ensure its daily application because of their roles and responsibilities with regards to Group operations. Imerys recognizes the right to freedom of association and the right to collective bargaining, which is clearly articulated within the Group Code as well as within the Group Employee Engagement Policy. Approximately 73% of Group employees are covered by Collective Bargaining Agreements (CBAs). These CBAs commonly include subjects such as health and safety, work organization and working hours, training, compensation and benefits, and equal opportunities.

Imerys is fully committed to taking effective measures to end discrimination and to eradicate child labor and forced labor. Compliance with the Code and protocols on human rights and labor practices, including preventing child labor and forced labor, is included within due diligence assessment for new projects and within the scope of internal auditing missions for the Group existing activities. Protocols on prohibition of child labor and forced labor have been in place since 2009.

Since 2019, the Group has organized training and awareness raising sessions on Human Rights based on UN Guiding Principles. The purpose of these sessions is to train groups of employees on human rights and the UN Guiding Principles and support the identification of any potential human rights risks in. Unfortunately additional in-person training sessions could not be conducted in 2021 as a result of Covid-19 restrictions, thus e-learning modules related to Human Rights were made available to employees. Dedicated sessions will be delivered in the future to progressively cover more countries and key functions.

The Group has developed a global and comprehensive program (Global Benefits Management) and has mapped all the healthcare, death and disability benefits provided to its employees to ensure that the corresponding levels of coverage are progressively harmonized across the Group, in line with local regulations and market practice and managed in a structured and efficient way.

The Group Pension Committee has reviewed and updated its governance principles, objectives and operating modes via the definition and publication of its terms of reference, applicable to all Imerys units.

To support mental health and well-being of employees during the unprecedented challenges of the pandemic, in 2021, the Group developed a new mental health guide for employees and for managers to help them support their teams.

In April of 2017, Imerys launched its first global employee engagement survey “Your Voice”. In 2021, the Your Voice survey was conducted again and extended to include deskless and remote workers in addition to the digital workers who were included in the 2017 survey. The survey was conducted confidentially and anonymously offering employees to express their position on a wide range of topics. The questionnaire, available in 26 languages, was shared with all employees across all Imerys countries and businesses. The global response rate reached 88% (over 13,000 employees), which provided the Group with clear signals on employee engagement levels and on Group strengths and areas for improvement. The results of the survey showed high levels of engagement and enablement across the Group (68% and 73% respectively), driven by a strong loyalty to Imerys (71%), which is 10% above the industria norm. When compared to the industrial benchmark of data collected from over 2.4 million employees in 90 organizations operating in the industrials sector, feedback from Imerys employees is above the benchmark for nearly all topics. The Your Voice results provide rich insights to help guide the development of global and local improvement action plans.

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• GRI 404-1 Disclosure: Average hours of training per year per employee

In 2021 Imerys Greece conducted a total of 8981.5 hours of training for their employees and contractors. More specifically for their employees Imerys conducted 3183 hours of Safety Training, 5141 hours of Job Training and 41.5 hours of Management Training for a total of 8391 hours of training whereas the contractors were trained for a total of 590.5 hours. Indicative training courses carried out during the year were:

• A variety of webinars concerning COVID 19 and mitigation strategies

When COVID 19 emerged, the company took every measure to ensure employee safety. When best practices were identified the company organized webinars in order to help safeguard employee health and the continued operations of the company. When new information and legislation came to light the company conducted additional training.

• Training occupational risks associated with work at height

The training included the analysis of the basic principles of safety when working at height as well as the proper use of personal protective equipment.

Based on the above-mentioned, commitment to continuous training is clearly identified. All Imerys employees are informed regarding health and safety issues, with specific and targeted training interventions, informative sessions on relevant corporate Standards and customized sessions based on specific risks identified.

• Safety Inductions for Everyone working in the facilities

Imerys conducts safety inductions to everyone, including contractors and out of site visitors. The inductions concern the correct use of PPE, the rules that Imerys has for each facility, the dangers present in the facilities and how to avoid them

Training of Imerys Greece S.A. employees for 2021 (total number of 275) per thematic category are depicted in the attached charts.

• GRI 405-1 Disclosure: Diversity of governance bodies and employees

Imerys Greece S.A. had a total number of 275 employees in 2021. The distribution of employees according to their gender, hierarchical scale, years of employment, age group and facility they are operating is depicted in the attached charts.

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15. Ίσες Ευκαιρίες

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys human capital is the most important Group asset, thus ensuring the respect of human rights and labor practices, developing tools for talent and skills management, maintaining constructive social dialogue and ensuring a diverse and inclusive environment with equal opportunities for all are crucial to the Group’s long-term strategy. The threats in these regards are related to potential violations of the Group Code of Conduct and Business Ethics that could result in potential risk of salient right abuses. While not assessed as a material risk at Group level, the promotion of diversity and inclusion is considered to be a long-term objective that needs constant focus as expressed through the employee engagement survey and as such the development of the Group program shall continue to be a high priority in the mid-term.

Safety and health are core values for all Imerys operations worldwide. The Group is committed to developing a proactive safety and health culture through partnerships among management, employees, contractors, suppliers, visitors and the communities in which it operates. The Group is likewise committed to continuous improvement cycle of safety and health performance, setting objectives and monitoring, reporting, auditing and reviewing. The personal involvement of each individual within Imerys is considered essential to achieving an incident-free workplace. This safety and health framework is fundamental to the Group's success and contributes to SDG 3 to ensure healthy lives and promote well-being for all at all ages and concrete contributes to SDG 8 to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.

The Group strives to build constructive, open dialogue with its employees and their representatives in accordance with local regulations and implements best practices in matters of workforce management. Establishing and maintaining this open dialogue is a means to contribute to SDG 10 to reduce inequality within and among countries.

Internal communication campaigns aim to provide all employees with information that can help them understand the Group’s strategy, environment and activities, build their sense of belonging and highlight the Group’s values to help strengthen its identity. Information is actively shared across the Group via various means, including through a collaborative digital platform “OneImerys”, which supports daily communication and collaboration. This platform hosts essential information, documentation and protocols, but also social feeds and workspaces, tools and business applications. The intranet is optimized to enable employees to use tools and resources in an agile way – including smartphone access to Group level applications. The intranet facilitates the sharing of projects, initiatives and successes throughout the Group. It is likewise a platform to share information and support discussion on specific topics within specialized communities.

“Communicate and collaborate” are one of Imerys leadership behaviors, and as such the Group privileges regular managerial face-to-face dialogue to share key information within teams. To complement this form of dialogue, the Group launched various video messages and question and answer sessions with the Group CEO to facilitate open exchange with employees during a year where travel was severely restricted.

The Group is also committed to promote a culture based on mutual respect and appreciation, where the value and contribution of each individual is welcomed and recognized. Imerys does not tolerate any discrimination and/or harassment of its employees, contractors, customers, suppliers or other stakeholder on the basis of gender, age, nationality, citizenship, ethnicity, religion, background, sexual orientation, disabilities, marital and parental status, or political affiliation or any other dimension of diversity. The Group recognizes that diversity and inclusion are long-term ambitions and while the Group has not yet reached its full ambition, it is fully committed to its accelerate efforts and as such contribute further to SDG 5 to achieve gender equality and empower all women and girls and SDG 8 to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.

The Diversity and Inclusion Charter, signed by the Group Chief Executive Officer, has been translated into 22 languages and is posted across Group sites. The Charter clearly articulates the shared commitment to achieving greater diversity, as well as inclusion across the Group. Since 2019, with broad participation from employees across functions and geographies, the Group has analyzed the key drivers and challenges and structured a 3-year diversity and inclusion program. The Group designated a Diversity and Inclusion Steering Committee, composed of four Executive Committee members as well as functional Senior Managers to ensure the program is successfully implemented and the objectives achieved. The Diversity and Inclusion Steering Committee is facilitated by the Group Diversity and Inclusion coordinator, who is responsible for the planning, coordination and implementation of the new program in close collaboration with Business Areas and functions. The Group’s mid-term Diversity and Inclusion specific and time-bound mid-term objective is two-fold: to increase the number of women in senior management to 30% and fully implement the Group Diversity and Inclusion program by the end of 2022. The program addresses areas for improvement centered around: decision process and governance, training and awareness, human resources policies, communication and offices and sites accessibility. The deployment of the 3-year program began in 2020. At the end of 2020, 26% of senior managers were female and 40% of the 3-year plan had been implemented, including the creation and animation of an internal network of Diversity and Inclusion Ambassadors and the launch of numerous communication and awareness campaigns across Group sites and offices.

The Group is committed to develop all its programs focused on achieving greater diversity as well as inclusion both at global and local levels and to respect and promote the principle of non-discrimination and equal opportunity, in particular with regards to human resources management. To this effect Group HR policies and practices are a key element of the diversity and inclusion plan and are regularly updated to include specific diversity and inclusion principles and requirements at the appropriate steps within each process. Diversity and inclusion requirements are likewise a key component of the Group Leadership Behaviors, the behavioral model against which the Group formal performance appraisals are conducted.

The Group is committed to develop programs focused on achieving greater diversity as well as inclusion both at global and local levels and to respect and promote the principle of non-discrimination and equal opportunity, in particular with regards to human resources management. To this effect Group HR policies and practices are a key element of the diversity and inclusion plan and are regularly updated to include specific diversity and inclusion principles and requirements at the appropriate steps within each process, ensuring that these updates are also reflected in country HR policies. Diversity and inclusion requirements are likewise a key component of the Group Leadership Behaviors, the behavioral model against which the Group formal performance appraisals are conducted.

To create a truly inclusive culture, the Group continues to work to eliminate barriers, to raise awareness on the effects of implicit and/or unconscious bias and to help employees develop effective strategies for ensuring that such biases do not undermine Group efforts to ensure a diverse and fulfilling workplace for all, which creates a sense of belonging. To this effect the Group focused considerable efforts on various trainings, from within the onboarding program for new employees, to the provision of additional resources and tools within the Learning Hub. For example, a training on anti-discrimination rolled out in November 2020 for all senior managers and people managers, was extended within 2021 to all our employees with access to Imerys Learning Hub and training on Unconscious Bias was also offered to the same employees in October 2021. The Group leadership programs were adapted to include dedicated sessions focusing on unconscious bias and conscious inclusion training sessions and 81% of senior managers completed a 3.5 hour inclusive Leadership training to support their capacity to drive inclusive leadership.

With the introduction of the new Purchasing policy, and in keeping with the commitments outlined in the Group Diversity and Inclusion Charter the Group has also articulated its ambition to ensure inclusive sourcing. Inclusive sourcing is the proactive business process of sourcing products and services from previously under-used suppliers, including but not limited to, local Small Medium Enterprises (SMEs), suppliers that are certified as at least 51% owned, operated and controlled by one or more minority, woman, LGBTQ+, veteran, person with a disability, aboriginal-indigenous person, or a historically underutilized business defined by the local country. This process helps to create competitive intelligence and advantage whilst sustaining and progressively transforming part of the Group supplier panel to quantitatively reflect the demographics of the community in which it operates by recording transactions with diverse suppliers. The intent of inclusive sourcing is not to promote positive discrimination towards diverse suppliers, but to ensure potential suppliers are identified and given the opportunity to compete to win based on merit on a level playing field.

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• GRI 403-2 Disclosure: Types of injury and rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities

The Group has an internal safety and health incident reporting process and associated database. Incident investigations are conducted and corrective actions are implemented at site level with follow-up at division level. Safety Alerts are issued whenever a Lost-Time Accident occurs to share root causes and lessons learned. Where appropriate, corrective actions identified through an incident investigation are directly integrated into the next update of Group safety protocols to reduce the risk of recurrence. In 2021, Imerys Greece SA delivered no safety alert to the Group.

Imerys tracks and analyses safety performance for both employees and contractors on a monthly basis using indicators for fatalities, life-changing injuries, lost-time and non-lost-time accidents at the Group level. All levels of the Group review recorded safety performance metrics every month. The progress on all the aforementioned key objectives and programs is reviewed quarterly. The Group is preparing for the deployment of a new tool to strengthen the management of incidents and introduce new leading indicators, such as inspections and site visit reports with KPI reporting and follow-up.

To prevent workplace-related illnesses and accidents, Imerys Greece S.A. facilities are certified with ISO 45001:2018 Occupational Health and Safety Management System (OHSMS). Imerys Greece S.A. operations also participate in the European Social Dialogue Agreement (SDA) on workers’ health protection through the good handling and use of crystalline silica and products containing it and have reported on specific aspects of their implementation through participation in a program organized by the European Network for Silica (NEPSI).

In 2021 there were 0 fatalities or life-changing injuries, 0 Lost Time Accidents (LTA), 1 Non Lost Time Accidents (Non-LTA), 12 first aid accidents, 0 near miss with big impact (which could have been a life-changing accident or fatality), 73 near miss incidents, 144 unsafe behaviors and 216 unsafe conditions reported on Imerys incidents’ database for Imerys Greece S.A. In all incidents relevant corrective actions were taken in order for similar incidents to be prevented.

In 2021 employees and contractors worked a total of 742,191 hours and only 1 non-LTA accident was reported in Imerys Greece S.A.

Health surveillance of workers is in compliance with Greek legislation in each facility. In all facilities, workers are given the possibility to obtain external general and specialized medical testing. In Milos facilities, audiometric and spirometry tests are carried out by the occupational physician periodically. There are also performed regularly measurement regarding noise, dust and vibrations from vehicles – equipment to all relating employees. Harmful factors’ measurements are also conducted within the office premises for office employees.

• GRI 403-4 Disclosure: Health and safety topics covered in formal agreements with trade unions

Each Imerys contractor during its work is required to provide not only compliance with Health & Safety requirements of the Greek Legislation, but also compliance with Imerys safety procedures and protocols. Specifically each contractor should:

• Comply with “Serious Seven” Safety Protocols
• Report any safety incident so as for the necessary corrective measures to be taken
• Submit a written risk assessment, taking into consideration all described safety measures and practices

Alignment of contractors within Imerys Safety System (ISS) and safety cultural expectations is fundamental to achieve the Group safety goals. As such, the new Contractor Safety Management initiative, launched in 2017, outlines a common and systematic approach for the selection, monitoring and continuous improvement of the health and safety performance of contractors and sub-contractors.

Imerys Code of Business Conduct and Ethics (the Code) summarizes the principles of ethical behavior the Group expects from all of its employees, contractors, suppliers, and other partners. The umbrella principles set forth in the Code are supported by a series of policies and protocols applying to both the general conduct of Imerys and the individual conduct of each employee. The subjects covered by the Code include compliance with laws and regulations, protection of environment and human rights, relations with local communities and trade unions, workplace safety and health, diversity and inclusion, confidentiality, prevention of fraud or corruption, prevention of insider trading and conflicts of interest, protection of the Group’s assets, fair competition, transparency, and integrity.

• GRI 404-1 Disclosure: Average hours of training per year per employee

The average hours of training per employee for 2021 was 30.51 hours.

• GRI 406-1 Disclosure: Incidents of discrimination and corrective actions taken

No incident of discrimination took place in 2021 at Imerys Greece S.A. facilities, thus there are not any incidents report and relevant corrective actions.

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16. Απασχόληση

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Human capital is at the heart of Imerys’ business success. Imerys seeks to create an environment that promotes employee’s development as a key element of growth and transformation. As such the Group HR policies and practices are based on fairness, openness and mutual respect. The long-term objectives of the Group are to identify, attract, select and retain talented people; develop and provide essential competencies; share ideas, projects, best practices across the organization; and ensure transparency and compliance with both legal requirements and Imerys’ policies and processes. Through constant engagement on these subjects the Group contributes to SDG 4 to ensure inclusive and equitable quality education and promote lifelong learning opportunities for all; to SDG 5 to achieve gender equality and empower all women and girls; and to SDG 8 to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.

Talent and skill management is essential to maintain an innovative, engaged and motivated workforce and to ensure strong long-term growth within the Group. The Group talent road map continues to improve Human Resources processes focusing on recruitment, employer branding, internal mobility, professional learning, development and retention. All of these processes contribute to the development of human capital in Imerys and thus work towards SDG 4 to ensure inclusive and equitable quality education and promote lifelong learning opportunities for all.

The Group aims to create opportunities for employees, empowering them within the organization, helping them to develop professional capabilities and benefit from diverse career paths. Supporting internal evolution and career moves across the Group is a priority. Imerys is committed to ensuring its employees’ development and specialized committees meet regularly to discuss internal mobility and promotions.

Imerys Leadership Behaviors, which were rolled out in 2016 and have become an integral part of the entire talent management cycle, including recruitment, onboarding, performance and potential assessment, development and succession plans. In order to develop leadership and managerial skills, annual reviews are now composed of a shared evaluation between employees and their line managers based on these principles.

To ensure that Imerys not only attracts the right people for the right positions, but also that the process generates a positive candidate experience, fosters diversity among our workforce and facilitates the integration within Imerys, the Group applies a global recruitment policy. This policy addresses five stages in the recruitment process: preparation, sourcing, selection, decision and onboarding.

The Group is committed to continuously diversify and increase the Group’s training program through a blended learning approach, enabling employees to actively lead their own development and learning experience. The Group’s entire learning offer was redeveloped in 2021 and is hosted on a new platform called the “Learning Hub”, which brings together all in-class training and digital learning courses. The Learning Hub is accessible to all Imerys employees with Imerys email accounts, which represents over 10,000 employees across the Group. In-class training and e-learning courses cover safety, environment, finance, management and leadership, project management, commercial excellence and industrial marketing, and basics of geology and mining amongst other topics. Learning resources are available in English and some are also available in other languages including French, Brazilian Portuguese, German and Chinese. In 2021, unfortunately the majority of planned in-person training had to be canceled or postponed due to Covid-19. However, the Group continued to invest in the development of multiple new digital courses. Traditional in-person training programs, such as those related to mining and resource planning, were also redesigned to be delivered in a virtual format. Global trainings that support fundamental topics of the Group Code of Conduct were rolled-out in 2021, including new training modules on environmental management, cybersecurity, and unconscious bias launched from September 2021. The unconscious bias and environmental training targeted all senior managers and people managers, as well as functional Environmental, Health and Safety experts in the case of the environmental training, while the cybersecurity courses were offered to over seven thousand employees. At the end of 2021, 62% of senior managers and people managers were trained on unconscious bias, 36% of senior managers, people managers and functional experts completed the training on environmental topics, and 58% of connected workers completed a series of cybersecurity courses. The Group likewise launched a new introductory sustainability digital course that was completed by approximately 1000 employees. Imerys became a member of the UN Global Compact Academy thereby enriching the training offering on numerous ESG topics for all the Group digital learners through the Learning Hub.

The Group is committed to continuously invest in its workforce and provide opportunities for its employees to develop new skills. The Group SD Challenge serves as an effective channel to strengthen the focus on talent and skill development and share best practices: a total of 22 new projects were entered into the 2021 SD Challenge in this category, including a structured well-being program in the UK, built to develop team skills to support employee mental health and well-being, that is inclusive of all employees and demonstrates a commitment to supporting workforce development beyond technical and managerial skills. Furthermore, specifically with regards to mental health and well-being, a pilot 4 hour training program was rolled-out in one Business Area focusing on the training of the senior management team to support the mental health of their teams, focusing on key tools to identify mental health issues, understanding how to have open conversations on mental health, and providing them with available resources for support.

Since 2020, the Group has used a digital global onboarding program to create global consistency for onboarding of new recruits, and offer a streamlined and supportive approach and a centrally managed process, which give each newly recruited employee clear knowledge about Imerys in their first 90 days. The onboarding program guides new recruits through valuable information including: Imerys’ organization and tools, markets, customers, mandatory training (including the Code of Business Conduct and Ethics, safety, diversity and inclusion, cybersecurity, sustainability) as well as Business Area, function, and country-specific content. This onboarding is linked to the Learning Hub training platform, with a dedicated workflow that ensures that all new connected workers receive key messages and information directly after arrival. In 2021, the Group likewise developed a new onboarding program for operational workers across the Group. This onboarding defines the minimum requirements to control health and safety risks related to the onboarding period for new operational workers for which Imerys has managerial authority, and/or can influence strongly and directly, at any Imerys industrial sites. The aim of the onboarding program is to ensure that all new workers are adequately trained and competent to safely perform their assigned tasks.

The Group likewise focuses on induction training for Imerys’ new plant managers to help them understand the Group’s approach to operational excellence and continuous improvement, covering topics such as safety, processes, finance, HR, sustainability, as well as I-Cube.

A global internal mobility policy provides a streamlined process to develop employees by exposing them to new challenges and new businesses within Imerys; to respond to employees’ aspirations to evolve; to facilitate the collaboration between all businesses; and contribute to reinforce the Group culture and mindset.

The Group compensation and benefits systems and policies aim at ensuring both market competitiveness and internal consistency, while being driven by a clear pay-for-performance objective. In 2021, Imerys group developed a Position Evaluation System, in order to define roles in a systematic grading approach. Using common grades throughout the world, Imerys ensures internal consistency by providing equal pay for work of equal value and provides a rational basis for the maintenance of its pay structure. This process uses data to benchmark remuneration against the market, which helps drive Imerys principle of equal opportunities and drive transparency and consistency in compensation practices across Business Areas, Functions and Departments.

Fixed compensations are reviewed on a yearly basis under the close coordination of the Human Resources Function, supported by regular local and/or sectorial surveys, and conducted with strict financial discipline. In order to reward both personal and collective financial performance, short-term variable pay schemes consist of both individual and shared objectives. In 2021 the Imerys CEO, all of the Executive Committee and most senior managers had individual objectives linked to the achievement of the Group’s eight mid-term sustainability objectives. Long-term compensation programs are fully aligned to the Group’s long-term financial objectives. The Group endeavors to align its remuneration practices across the world with international standards.

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ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

• GRI 401-1 Disclosure: New employee hires and employee turnover

Imerys Greece S.A. employees (Milos and Athens facilities) hiring and turnover is depicted in the following table. Employee turnover refer to employees who leave the organization voluntarily or due to dismissal, retirement, or death in service.

Imerys Greece S.A. employees receive additional education each year on job expertise, management and environmental, health and safety, with 8391 total training hours in 2021.

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17. Ανθρώπινα Δικαιώματα στην Προμηθευτική Αλυσίδα

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys is committed to respecting internationally-recognized human rights, as set out in the International Bill of Human Rights and the ILO’s Fundamental Conventions. The Group is committed to respect human rights and avoid complicity in human rights abuses, as stated in the UN Guiding Principles on Business and Human Rights, and provide access to remedy.

The Group operates in different geographies across the world, with its largest operational footprint in Europe (approximately 48%) and North America (approximately 20%). The Group has established a detailed process for mapping corruption, human rights, health, safety and environmental risks within its operations and those of its subsidiaries as well as those of its Suppliers in different geographical areas.

A series of dedicated interviews with key representatives of both businesses and support functions were conducted in 2017 to design the initial version of compliance risk framework, including potential risk scenarios. These interviews were complemented by additional consultations with external agencies and non-governmental organizations to collect feedback on the framework and process. The consolidated risk framework was presented to the Executive Committee and validated, and on this basis a first list of corruption and human rights, health, safety and environmental risk scenarios was developed.

The initial Group risk assessments for two first pilot geographic areas were conducted in 2018. These workshops brought together experts representing diverse functions, including but not limited to legal, operations, sales, purchasing, logistics, human resources, sustainability, and finance within the geographic area being assessed. These first assessments confirmed the validity of the risk assessment framework in addition to generating the assessment’s results. The second phase of geographic assessments were conducted in 2018 through questionnaires and interviews with business leaders from each of the remaining geographic areas where the Group operates. Between 2019 and 2020 additional risk assessment workshops were conducted to continue to reinforce the level of assessment done in the geographic areas initially covered by the expert reviews, thereby completing the full cycle of risk mapping for the five geographic areas (Europe, North America, Asia-Pacific, South America, and Middle East & Africa). In 2021 the risk assessment was updated for South America.

The purpose of these workshops is to review and update, if needed, the list of risk scenarios, assess the criticality (inherent impact and probability) of each risk scenario, assess the effectiveness of current mitigation measures and, in addition, for human rights, health, safety and environmental scenarios, identify the highest risks per purchasing categories (criticality). The risk assessment workshops systematically include a review and eventual update of the risk scenarios to ensure that the list is comprehensive. As of 2021 the corruption risk register includes a total of 25 potential risk scenarios, while the human rights, health, safety and environmental risk register includes 15 potential risk scenarios.

The Group risk assessment workshops of human rights, health and safety and environmental risks described above are covered in two parts: first, the assessment of mitigation effectiveness of Group operations and second, an assessment of criticality of human rights, health, safety and environmental risks for each main purchasing category.

In order to prioritize actions with regards to Imerys’ Suppliers, the criticality risk of each human rights, health, safety and environmental scenario was ranked by taking into account a “composite country index” (based on the Corruption Perceptions Index, Human Freedom Index and Environmental Performance Index and the economic weight of purchases to assess risk impact and exposure.

Based on the assessment of human rights, health, safety and environmental scenarios associated with Suppliers, and the composite country index, the Group has identified potential salient human risks within its value chain. The four salient risks identified include potential:

• impacts on Supplier workers exposed to occupational health or safety risks;
• impacts on Supplier workers related to labor practices, including wages, working time, general work conditions;
• increases in air or land pollution due to Supplier operations; and
• impacts on Supplier workers due to discriminatory practices.

Following the assessment of each purchasing category, for all the human rights, health, safety and environmental scenarios assessed, the risks evaluated as being highest are those related to the raw material Supplier category. The final Supplier risk ranking of low, medium or high determines the control measures to be put in place to eliminate or mitigate the potential risk.

The principles of the new Purchasing Policy are described in detail in the criterion 4: Management of value chain.

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ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

• GRI 412-3 Disclosure: Significant investment agreements and contracts that include human rights clauses or that underwent human rights screening
• GRI 414-1 Disclosure: New suppliers that were screened using social criteria

Please refer to criterion 4: Management of Value Chain for more information on the new Purchasing Policy and relevant ESG audits.

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18. Ενίσχυση Τοπικών Κοινωνιών

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys is committed to build positive relationship with communities around its sites and contribute to local social and economic development. During 2021 the following CSR projects were highlighted:

• Milos Mining Museum

The museum was founded in 1998 and is directed to the local community of Milos and the visitors of the museum from Greece and abroad and especially to the local educational community. He has been an active member of the European Museum Forum since 2001, and organization that promotes excellence in museums and their interactions with the public.

The museum has recently organized various events to highlight the operation of a mining museum and to keep the interest of the permanent residents of the island.

In 2021, the museum resumed operation since it had to close for some months of 2020. The museum ran one program called “Our Aphrodite” based on the literary narrative by Sofia Gialouraki “Aphrodite of Milos is crying”. The program was implemented in 29/9/2021 until 1/10/2021 and had 150 participants from the public schools of Milos.

• Milos vineyard

Imerys Greece S.A. transformed a rehabilitated perlite mine in Milos Island to a new financial activity via viticulture. Starting from February 2014, approximately 17,500 vines of Assyrtiko variety have been planted in a total area of 5 hectares. In February 2016 red varieties started to be planted in a total area of 1.35 hectares. 3000 vines of Maurotragano variety, 1700 vines of Mantilaria and 100 vines of Psarosiriko were planted. In August 2015 the first quality control vine harvest took place, while in August 2016, the first vine harvest was conducted at Milos’ Vineyard. 300 kilos of grapes were turned into wine and the first bottling of wine production took place in 2017. Bottles of wine were distributed to all Imerys Greece S.A. employees. In 2017 1434kg of Assyrtiko grapes were harvested and 800 bottles of wine were produced, in 2018 1580kg of grapes were harvested and 1100 bottles of wine were produced, in 2019 925kg of grapes were harvested producing 800 bottles of wine, in 2020 3000kg of grapes were harvested and 1800 bottles of wine were produced and in 2021 2540kg of grapes were harvested and 1500 bottles of wines were produced.

Through Vineyard initiative, environment is protected and preserved as organic cultivation method is applied. Moreover, irrigation water is recycled, which is an aspect of invaluable importance as water in the Cyclades Islands is in shortage. Four free training seminars with approximately 300 participants have already been provided to the local community, encouraging Milos’ residents to revive small family vineyards using organic agricultural methods. Education on the use of industrial minerals is also encouraged, as prominent examples of Milos’ minerals are used in viticulture and wine production. These minerals are sulfur, protecting the crop from disease in organic winegrowing, bentonite that is used for wine stabilization and perlite that is used in wine clarification. Finally, the activity will also contribute to “alternative” tourism on the island, attracting visitors interested in wine-making and wine-tasting.

• Milos bentonite drying

Every year around 1,000,000 MT of bentonite are mined on Milos Island and almost all of that quantity has to be dried to about 15% on average. Significant energy saving is achieved by exploiting Milos’ climatic conditions - that is high temperature and wind during summer - for the natural pre-drying of bentonite in open fields. This results in approximately 35% annual energy savings, compared to the energy that would be required if industrial drying was exclusively used. It is estimated that some 100,000 MT of water are evaporated on a yearly basis through this field drying process. This is equivalent to actual savings of about 7,500 MT of annual crude oil consumption, corresponding to CO₂ emissions reduction in the range of 24,000 MT per annum.

• Milos plant nursery and botanical pathway

Milos Plant Nursery and Botanical Pathway are both an environment rehabilitation and an educational destination. The nursery is consisted of 864 types of Milos plant species and a botanical pathway is created by cultivating these plants. The creation of Milos plant nursery dates back in 1994.

The Company’s nursery has a project where it collects rare, endemic and endangered seedlings of Milos, reproduces them and plants them in mine restorations to enrich the vegetation potential of the restoration.

Since 2017 eight of these species are used for restoration:

1. Dianthus fruticosus subsp. fruticosus: The plant is reproduced en masse (400 plants/year) and is used successfully on the mine terraces.
2. Hymenonema graecum: The company’s department of rehabilitation identified the species in 2009. In the nursery, a small number of specimens of the species are reproduced (100 plants/year) but it has been successfully planted in the rehabilitation of the Trachila and Tsigrado mines. In close cooperation with the Agricultural University of Athens, the company promotes the cultivation of the plant by farmers.
3. Silene cythnia: The company’s rehabilitation department identified the species in 2003. The nursery produces a small number of specimens of the species (100 plants/year) and is used at selected points in all of our mine restoration in Milos. Efforts are being made to create an “artificial” cluster of plants at an easily accessible point for supervision and seed collection.
4. Caroxylon aegaeum: The company’s rehabilitation department identified the species in 2000. The species is mass-produced in the nursery of Milos (1200 plants/year) and is used successfully in all the mine restorations of Imerys in the island. The use of seeds for aquaculture is also being investigated.
5. Dianthus diffusus: Identified in 2016. In the nursery, a small number of specimens are reproduced (100 plants/year) and are used successfully in selected mine rehabilitations in the island.
6. Crocus tournefortii: Identified in 2014. In 2017 we managed to collect seeds of the plants that were grown in large containers. We investigate the mode of germination and the appearance of vegetative dormancy. Reproduction of the plant is done on a small scale after the collection of bulbs from a specific area of the Imerys mine in Trachila (approximately 100 plants/year). Successfully used in selected mine rehabilitations on the island.
7. Helictocloa agropyroides: Identified in 2016. In the nursery it is reproduced from 2018 en masse (700 plants/year) and is used successfully in the mine rehabilitation on the island.
8. Centaurea laconica subsp lineariloba: Identified in 2016. A small number of specimens are reproduced in the nursery (100 plants/year) and are used successfully in selected rehabilitations on the island.

In 2021, the species Onopordum caulescens was reproduced and 25 plants were used for rehabilitation in the Trachila mine. The company’s research continues for the two (2) remaining rare and endemic plants: Allium pilosum, Sedum praesidis.

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• GRI 201-1 Disclosure: Direct economic value generated and distributed

Imerys Greece S.A. direct economic value distributed consists of facilities’ sponsorships and contribution to local society, as depicted in the attached chart. In 2021, Corporate Social Responsibility (CSR) sponsorships totaled 458,989€. This overall amount includes the mandatory municipal financial contribution to Milos, which amounts to 162,579€.

Contribution to Milos local society was carried out by:

• Direct contribution to local associations, infrastructure works and conservation of natural environment, such as bentonite drying, nursery and botanical pathway;
• Indirect contribution through various on-going initiatives that promote the cultural as well as the industrial heritage of each area, like activities of Milos Mining Museum (MMM) and Milos Conference Center (MCC);

Contribution to Athens local society was directed towards:

• Social grocery store of Kifissia municipality
• Red Cross initiative

• GRI 413-1 Disclosure: Operations with local community engagement, impact assessments, and development programs

Visitors at Milos Mining Museum (MMM) were 4709 and 198000 tourists for 2021 and the museum ran one action called “Our Aphrodite” which had 150 participants.

For 2021, annual institutions of the "ANASTASIA ANTONIADOU" Award (A.A.A.) and the "ANASTASIA ANTONIADOU" Scholarship (A.A.S.) were offered to local community participants. A.A.A. is addressed to both Imerys’ local employees and Milos residents in order to encourage actions and initiatives in the fields of social, cultural and voluntary contribution. A.A.S. is addressed to women graduates of the Milos or Kimolos islands senior high schools (Lyceums), who successfully stood the entrance examinations for one of the country’s Universities.

In 2021 Milos Conference Center (MCC) – George Eliopoulos was used for 26 days in total. The total number of participants in MCC events was more than 815.

Events that took place in MCC for 2021 are:

• 23/5/2021 examination in English by the Greek American Association with 50 student participants.
• In 27-31/5/2021 and in 24-27/6/2021the MCC was used by the QOS company for advertising of a clothing company
• 16/8/2021 the MCC was used for a music event dedicated to Mitropanos by the Milos association of arts. The event was attended by 500 people.
• In 4/9/2021 the Experimental Stage of Milos organized a theatrical performance in the courtyard which was attended by 120 people.
• In 19-23/7/2021 a conference was held in the B building with Professor Mr. Daglis from the University of Athens. 35 people participated.
• In 6-8/9/2021 the MCC hosted a meeting of about 10 Imerys Executives.
• In 9/9/2021 the MCC hosted a meeting of the LABA Executives.
• In 13-20-27/11/2021 and 4/12/2021 there were film screenings on the theme of the marine environment, which were organized by the Milos Mountain and Sea Group. In total, approximately 100 people attended the screenings.

In 2021 Milos employees participated in blood donation, which took place in 4-5/4/2021 with 47 participants and in 9-10/10/2021 with 42 participants.

In 2021 Athens employees supported:

• Social grocery store of Kifissia municipality;
• Collecting essentials for the fire victims of Evia and Attica

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19. Συμμετοχή σε Πρωτοβουλίες και Πολιτική Επιρροή

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

Imerys Greece S.A. has active participation to the following organizations:

Environmental and Sustainability Organizations

• SEV Business Council for Sustainable Development

Imerys Greece S.A. is a founding member of this organization. Mr. Athanasios Kefalas, president of Imerys Greece S.A., is a board member. Mining Rights Manager, Mr. Yannis Karavelakis, is a member of the relevant working group.

Industry Organizations

• Industrial Minerals Associations for Europe (IMA-Europe)
• European Bentonite Association (EUBA) branch
• European Association of Mining Companies (Euromines)
• Greek Mining Enterprises Association (SME)

Imerys Greece S.A. is an enterprise – member of SME. Mr. Athanasios Kefalas, president of Imerys Greece S.A. is the president of Board of Directors, starting from 2015.

• SEV – Hellenic Federation of Enterprises
• Association of Industries & Exporting Enterprises of Milos

CSR Organizations

• CSR Europe
• CSR Hellas

Imerys Greece S.A. does not receive any financial assistance from government agencies and is not subsidized by the Greek state budget.

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ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

• GRI 415-1 Disclosure: Political contributions

Imerys Greece S.A. has not donated to any political party during the reference year and did not contributed to them, either financially, or in any other way.

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20. Πρόληψη και Καταπολέμηση της Διαφθοράς

ΔΙΟΙΚΗΤΙΚΕΣ ΠΡΑΚΤΙΚΕΣ

The Group’s charters, policies and manuals are grouped together in the Blue Book, which all employees can consult on the Group Intranet OneImerys. This fundamental set of rules forms the framework for the Group’s operations. It applies to all Imerys’ activities and the companies it controls. These ethical values cover a spectrum of topics such as:

• environmental and human rights protection;
• local community relations;
• workplace diversity;
• safety and health;
• confidentiality;
• the prevention of fraud and corruption;
• insider trading and conflict of interest;
• fair competition;
• transparency and integrity.

Essential part of the Blue Book is the Anti-fraud and anti-bribery policy. Imerys has a zero tolerance policy on both fraud and bribery. Imerys’ Anti-fraud and anti-bribery policy confirms and summarizes the responsibilities applicable to all of the Imerys directors, officers and employees, persons purporting to act in that capacity or other persons or entities which perform services for or on behalf of Imerys. It also sets out the steps to be taken to prevent, detect and report fraud and bribery and describes the disciplinary actions to which those who engage in such conduct will be subject. This policy and its relevant procedures extend to conduct by third parties (e.g., joint venture partners, vendors, contractors, consultants and agents) whenever such conduct involves the misuse of Imerys funds or other Imerys property or could be attributed to Imerys. The program aims to comply with all relevant applicable laws; its baseline follows the OECD recommendations however its scope is wider: in addition to foreign bribery, it encompasses private bribery and fraud in general.

In 2016, Imerys became a signatory member of the United Nations Global Compact (UNGC) and has thus committed to base its business approach on the 10th Anti-Corruption Principle, between others, stating that “Businesses should work against corruption in all its forms, including extortion and bribery”.

Internal Audit is responsible for evaluating the internal controls that have been implemented and recommending any steps that may be needed to improve controls and thus mitigate risks. The risk assessments that are conducted by Internal Audit should provide the basis upon which audit plans are devised and against which internal controls are tested. Internal audits can serve simultaneously as a deterrence and detection mechanism. If Internal Audit becomes aware of possible fraud or bribery, a duly authorized representative of Internal Audit should notify the Group General Counsel immediately of the suspicions that have arisen.

Within the 2019 action plan validated by the Ethics Committee, the Group strengthened several procedures linked with the Code of Business Conduct and Ethics, including an update of the Group Antibribery policy and the issuance of new Gifts and Entertainment, Conflict of Interest, and Sponsorship and Charitable Donations procedures. All the aforementioned policies and procedures were created under the supervision of the Antitrust & Compliance General Counsel together with functional experts and clearly outline the process, reporting and necessary levels of control to ensure compliance with the procedures (operational, Corporate, Internal Audit).

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ΔΕΙΚΤΕΣ ΕΠΙΔΟΣΗΣ

• GRI 205-3 Disclosure: Confirmed incidents of corruption and actions taken

Within Imerys Group Blue Book, which is an online policies and procedures intranet, 2 fraud alerts were published during 2021. The alerts had to do with:

• Fraudster impersonating Imerys to request customer's invoice payment on a fraudulent bank account. An Imerys employee received an email which appeared to be from a legitimate and known customer contact, whereas it was sent by a fraudster (the only difference was that the email address domain from the customer is ".ma" when the fraudster email address was ".ml"). The email referred to a real sales order from a known customer. All communication from this point onwards was going through the fraudster who controlled the content of the communication between Imerys and the customer (customer received emails from "imerys.ml" instead of "imerys.com"). Impersonating the Imerys employee and the customer, the fraudster thereafter engaged in a series of email communications, requesting Imerys to send a paper invoice without any bank details in addition to the electronic invoice already sent which included the accurate bank details (claiming a custom issue). The paper invoice without bank details was sent by mail to the real customer who then contacted the fraudster (always replying to this fake email address) to inquire about the bank details. Fraudster then took the opportunity to communicate false banking information of a non-Imerys account and fraudulent payment instructions for EUR 261k (goods had been actually sent from Imerys to the customers). The customer wired the funds in accordance with the fraudulent payment instructions. The fraud was ultimately discovered when the Imerys employee contacted by phone the customer for late overdue invoice payment, breaking the e-mail communication loop with the fraudster for the first time (as Imerys engaged first the dunning process with the fraudster, still replying to the fake email address ".ml"). At this point, communication between the actual customer and Imerys was able to start, and the customer explained that the invoice had already been paid. Given the magnitude of the loss and the possible debate over the responsibilities, the Imerys entity recovered only 50% of the initial receivable and is still under negotiation for the 50% left.
• Internal reporting manipulation leading to significantly overstated stockpile. After having challenged the increase of the inventory as of 2019 end, the Business Area management alerted the Internal Audit department about a potential major discrepancy in the crude ore inventory volume and value reported. Indeed, the local operations team raised some doubts about the accuracy of the stockpile that they believed to be potentially overstated by approximately 600k tonnes (EUR 6-7m). The Internal Audit investigation confirmed a discrepancy of 645k tonnes of crude ore and EUR 7.6m in value as of December 31, 2019. This discrepancy was built over the years from 2016 to 2019, and the main reasons were coming from:
  • the consumption of crude ore deliberately under reported by the production supervisors,
  • a stockpile called “dead stockpile” that was written off in the financial books but still reported in the mining reports and as such valued,
  • some differences in crude ore density and the surveying of the stockpile base.

People involved in the mining operations were interviewed and confirmed that the topographies sent to the Finance department were forged and that the main reason for forging the consumption report was to reach the budgeted yield ratio. This confirmed the suspicion of fraud. No internal or external enrichment was evidenced.

The Group took the following immediate actions:

• Disciplinary actions were put in place against people who misconducted by forging data and against their direct manager.
• Internal control weaknesses raised by the investigation were corrected thanks to a new mining measurement and accounting process put in place locally (set-up of drone-based topographies, workflow of review defined in a local procedure, Group mining protocol setting up the main rules in terms of mining data accounting and reporting).

In every fraud alert, details are given for how the fraud is facilitated and the corrective action proposed in order not similar incidents to take place. There is also a constant reminder that reporting and communication are keys towards avoiding fraud acts.

The fraud alerts mentioned above occurred in the group. In Imerys Greece S.A. in 2020 and 2021 no fraud or corruption issues have been detected.

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