Maire SpA

The Maire Tecnimont Group's sustainability strategy extends across four clusters: the first is related to the climate, the circular economy and the environment; the second is related to our human capital; the third is related to innovation, and the fourth to the value we bring to the communities and territories where we operate in the world. [...] OUR STRATEGY HAS BEEN DEVELOPED IN LINE WITH OUR STRATEGIC INDUSTRIAL PLAN, WHICH HAS FOUR CLUSTERS AND AN IMPORTANT ROLE FOR GOVERNANCE, ACROSS ALL AREAS OF THE BUSINESS. [...] In 2021 we created the Technical Task Force dedicated to CO2 and initiated vertical working groups aimed at reducing our Group scope 1, 2 and 3 emissions; and to achieve our carbon neutrality objectives, we are developing action plans to make inroads on the various clusters of emission sources and launching many initiatives. [...] Specifically, a working group within the MeT Zero Task Force was set up in order to launch a structured process of engaging suppliers, both in terms of measurement methodologies and with regard to the best practices to be adopted in order to direct the supply chain towards the decarbonization objectives set by the United Nations. [...] The Maire Tecnimont Group has launched structured activities for the integration of environmental, social and governance (ESG) factors within its supply chain from supplier scouting to qualification process and post-order management. [...] In 2022, we are committed to significantly extending the coverage of suppliers assessed according to ESG criteria. At the same time, we are implementing a program to support suppliers in improving ESG criteria, including through best practice sharing initiatives. [...] The launch of a program of social audits by a third-party auditor on material suppliers in geographical areas with a low WGI (high risk areas concerning SA8000 requirements) is confirmed. In this first phase, 5 suppliers have been identified and will be audited on-site for their human rights compliance starting from the second quarter of 2022.

The Control Risk and Sustainability Committee is tasked among other things with assisting the Maire Tecnimont Board of Directors in evaluating all risks that are relevant to the sustainability of the long-term activities of the Company and the Group. Specifically, this Committee is in charge of: examining sustainability matters related to the business and to relations with stakeholders; examining the reporting and consolidation system for drafting the Group's Sustainability Report that includes the Non-Financial Statement as per Legislative Decree No. 254/2016 ("NFS"); examining the Maire Tecnimont Group's proposed Sustainability Plan, which is part of the multi-year Industrial and Strategic Plan, and giving an opinion prior to its approval by the Board of Directors; examining the Maire Tecnimont Group's Sustainability Report, which includes the NFS, and giving an opinion prior to its approval by the Board of Directors; supervising the sustainability activities of the Maire Tecnimont Group, including through specific information provided for this purpose by the competent Company and Group Functions; monitoring the position of the Company on sustainability topics and in particular on the ethics indicators of sustainability; giving opinions on sustainability topics if they are required by Board of Directors. [...] The Internal Sustainability Committee, a strategic advisory body for the Chief Executive Officer of Maire Tecnimont S.p.A., is tasked with assisting in the preparation of policies for the sustainable management of the business and of the related development programmes, guidelines and objectives including those on corporate giving, for monitoring their fulfilment, and for the analysis of interactions with stakeholders. [...] The Sustainability Reporting Function, which reports directly to the Chief Financial Officer, is responsible, with the support of the Group Sustainability Function, for preparing the Group's Sustainability Report containing the Non-Financial Statement referred to in Legislative Decree 254/2016 (NFS) in compliance with the laws and regulations in force. The Function is also responsible for the related preliminary activities and verifying the data collection and consolidation process and information contained therein. [...] The Group Sustainability Function, part of the Group Institutional Relations, Communication & Sustainability Function of the Company, is responsible for implementing the Group's sustainability strategy, in line with the Sustainable Development Goals (SDGs) defined by the aforementioned Internal Sustainability Committee, liaising with internal and external stakeholders through stakeholder engagement, as well as planning and monitoring sustainability initiatives. The Function is also responsible for managing the Group's philanthropy and cooperation initiatives, as well as contributing, with the project teams and the Region Vice Presidents, to the development of local social engagement plans and communicating social responsibility initiatives externally. [...] The Green Acceleration Advisory Board, which is made up of leading representatives from Industry, Finance and Academia and which serves the Chairman of the Board of Directors and the Company's Chief Executive Officer, assists these bodies in developing their knowledge of the energy transition process and in consolidating the Group's identity as a leading player in innovating the green chemistry sector.

In data 1° marzo 2023, il Consiglio – sentito il parere favorevole del Comitato Controllo Rischi e Sostenibilità – ha altresì approvato il "Bilancio di Sostenibilità" del Gruppo relativo all'esercizio 2022, contenente la "Dichiarazione consolidata di carattere non finanziario" di cui al D.Lgs. 254/2016 [...] Il Comitato Controllo Rischi e Sostenibilità, le cui riunioni sono debitamente verbalizzate, ha ricevuto nel corso dell'Esercizio informativa dall'Amministratore Delegato, Chief Executive Officer incaricato dell'istituzione e del mantenimento del sistema di controllo interno e di gestione dei rischi, dalla Responsabile Internal Audit e/o da rappresentanti della Funzione Internal Audit, dalla Responsabile della Direzione Group Corporate Affairs, Governance & Compliance, dal Responsabile della Funzione Group HSE&SA and Project Quality and Risk Management della Società (le cui competenze e responsabilità sono, ad oggi, confluite nella Funzione Group Risk, Special initiatives and Regions Coordination per quanto riguarda le attività di risk management del Gruppo e nella Funzione Group HSE&SA and Project Quality) e dal Responsabile Sustainability Reporting, nonché dal Group General Counsel circa l'identificazione, misurazione, gestione e monitoraggio dei principali rischi della Società e del Gruppo. [...] Il Presidente del Comitato Controllo Rischi e Sostenibilità ha sempre reso informativa in merito alle attività del Comitato e alle risultanze delle istruttorie dallo stesso svolte al primo Consiglio di Amministrazione utile.

The Maire Tecnimont Group's Tax Strategy, which applies to all Group companies, was approved by the Board of Directors of the parent company Maire Tecnimont S.p.A. on 19 December 2022 and by the Board of Directors of Tecnimont S.p.A. on 22 December 2022. [...] The implementation of the Tax Strategy within the Maire Tecnimont Group is subject to the following guidelines: → Managing relations with the tax authorities: the Group seeks to establish a collaborative, constructive and transparent dialogue with the tax authorities in accordance with principles of honesty, transparency, fairness and good faith, as well as clarity, completeness and timeliness, based on mutual trust and with the aim of strengthening long-term relationships and minimising any disputes. → Prevention of aggressive tax planning: the Maire Tecnimont Group forbids conduct and domestic or cross-border transactions which result in artificial arrangements contrary to the purposes or the spirit of tax provisions or the tax system in question, and which may lead to double deduction, deduction/ non-inclusion or double non-taxation. → Correct application of tax legislation: a commitment to operate in compliance with the applicable tax legislation, monitoring and identifying any new regulations – including via continuous dialogue with the competent institutions – and compliance with the tax laws of the countries in which the Group operates. The Maire Tecnimont Group also ensures timeliness and correctness in its management of tax obligations, as well as the accurate determination of taxes. → Management of tax risk: a culture based on the prevention of tax risk is encouraged at all company levels. Attention is paid to any tax implications – in ordinary and extraordinary business activities – and constant collaboration with the Fiscal Affairs function is encouraged, including via the establishment of specific information and control processes, to ensure timely identification, assessment and correct management of possible tax risks (for example: implementing the tools and control systems provided by the Tax Control Framework). → Management of inter-company transactions: Intragroup transactions are regulated, for tax purposes, on the basis of the arm's length principle, so that transfer prices and conditions are aligned as far as possible with those of the market. → Promotion of stakeholder value: the tax regulations of the countries in which Maire Tecnimont and the Group's subsidiaries operate must be taken into account when structuring commercial activities, in order to maximise the sustainable value generated for all stakeholders, including, among others, governments, employees and local communities.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]The processes in place to ensure that all direct and indirect activities that influence the policy are consistent with Maire Tecnimont global climate change strategy are, among
other things, the direct commitment of the CEO in the execution of these activities. An Internal Sustainability Committee, coordinated by Maire Tecnimont Chief Financial
Officer, represents a strategic advisory body for the Managing Director of the Parent Company Maire Tecnimont S.p.A.. The Committee is in charge of providing support in
the definition of the policies for the sustainable management of the Business and the related development programs, guidelines and objectives, monitoring their achievement,
and in the analysis of the interactions with the Stakeholders.
Consistency among the multiple engagement activities around climate change across business divisions and geographies is ensured by the work of the Sustainability
Reporting Department, in charge of managing, developing and coordinating Group long-term relationship on sustainability issues with key stakeholders. Moreover, the
Institutional Relations and Communication Department guarantees that all interactions that employees have in the name of the company or representing the company are
coherent with the image and message that the company itself wants to give to the outside world. For this purpose, a specific procedure has been issued to regulate the
institutional relations and external relations with Italian and foreign Public Administrations for all companies belonging to the Maire Tecnimont Group and an external
communication procedure has also been issued. In this framework specific attention is devoted to proper alignments of group external relations activities to climate change.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Maire Tecnimont is actively engaged in conducting a comprehensive analysis of its corporate carbon footprint and CO2 emissions. The objective is to develop an effective action plan aligned with the company's MET Zero initiative. To oversee this endeavor, a dedicated "Met Zero" Task Force was established in 2022, responsible for supervising and implementing the emission reduction strategies.