2025 Non financial statement

CONSOLIDATED NON - FINANCIAL STATEMENT

FINANCIAL YEAR 2025

CONTENTS

1. Contents

   Executive Summary 8

   SECTION I: Sustainability Information (CSRD) 15

   1. General Information 15

      1. 1.1 Basis for the preparation of the sustainability statement 15

         1. BP-1 General basis for the preparation of the sustainability statement 15

   1. BP-2 Information relating to specific circumstances 15

      (ESRS 2 BP-2: 9) 15

   2. Estimation of the value chain 16

   3. Sources of estimation and uncertainty 16

   4. Changes in the preparation of sustainability information 18

   5. Information on errors from prior periods 18

   6. Information derived from other legislation or generally accepted sustainability reporting frameworks 19

   7. Incorporation by reference 19

   8. Use of phase-in provisions in accordance with Appendix C of ESRS 1 19

   1. GOV-1 Role of the administrative, management and supervisory bodies 20

   2. GOV-2 Information provided to the administrative, management and supervisory bodies on sustainability matters and the supervision of the Company and sustainability matters addressed by them 23

   3. GOV-3 Integration of sustainability-related performance into incentive systems. 24

   4. GOV-4 Statement on due diligence 25

   5. GOV-5 Risk management and internal controls over sustainability reporting 26

   1. Strategy, Business Model and Value Chain 27

      1. SBM-1 Strategy, business model and value chain 27

      2. SBM-2 Stakeholder Interests and Views 31

      3. SBM-3 Material Impacts, Risks and Opportunities and Their Interaction with the Strategy and Business Model 33

   2. Management of impacts, risks and opportunities 37

      1. IRO 1 Description of the process for determining and assessing material impacts, risks and opportunities 37

      2. IRO 2 Disclosure requirements covered under the ESRS addressed in the Company's sustainability statement 39

      3. MDR-P Policies adopted to manage material sustainability matters 40

      4. MDR-A, MDR-M, MDR-T Actions and resources, metrics, and monitoring of the effectiveness of policies and actions in relation to material sustainability matters 40

2. Environmental Information 42

   1. Climate Change (E1) 42

      1. Integration of sustainability-related performance into incentive systems (ESRS 2 GOV-3) 42

      2. Transition plan for climate change mitigation (E1-1) 42

      3. Description of the processes for identifying and assessing climate-related material impacts, risks and opportunities (ESRS 2 IRO-1) 45

      4. Material impacts, risks and opportunities and their interaction with the strategy and business model (ESRS 2 SBM-3) 49

      5. Policies related to climate change mitigation and adaptation (E1-2) 52

      6. Actions and resources related to climate change policies (E1-3) 53

      7. Targets related to climate change mitigation and adaptation (E1-4) 54

      8. Energy consumption and energy mix (E1-5) 58

      9. Gross Scope 1, 2 and 3 GHG emissions and total GHG emissions (E1-6) 59

      10. GHG removals and GHG mitigation projects financed through carbon credits (E1-7). 62

      11. Internal carbon pricing system (E1-8) 62

      12. Anticipated financial effects of material physical and transition risks and potential climate-related opportunities (E1-9) 64

      13. Article 8 of the European Union Taxonomy 69

   2. Pollution (E2) 71

      1. Description of the processes for identifying and assessing material pollution-related impacts, risks and opportunities (ESRS 2 IRO-1) 71

      2. Policies related to pollution (E2-1) 74

      3. Actions and resources related to pollution (E2-2) 75

      4. Targets related to pollution (E2-3) 77

      5. Air, water and soil pollution (E2-4) 77

      6. Expected financial effects of pollution-related impacts, risks and opportunities (E2-6). 79

   3. Water resources (E3) 79

      1. Description of the processes for identifying and assessing material water and marine resources-related impacts, risks and opportunities (ESRS 2 IRO-1) 79

      2. Policies related to water resources (E3-1) 82

      3. Actions and resources related to water resources (E3-2) 83

         1. Water consumption (E3-4) 87

         2. Anticipated financial effects of impacts, risks and opportunities related to water resources (E3-5) 88

   4. Resource use and circular economy (E5) 89

      1. Description of the processes for identifying and assessing material impacts, risks and opportunities related to resource use and the circular economy (ESRS 2 IRO-1) 89

      2. Policies related to resource use and the circular economy (E5-1) 93

      3. Actions and resources related to resource use and the circular economy (E5-2) . 93

      4. Targets related to resource use and the circular economy (E5-3) 94

      5. Resource inflows (E5-4) 98

      6. Resource outflows (E5-5) 98

      7. Anticipated financial effects of impacts, risks and opportunities related to resource use and the circular economy (E5-6) 101

1. Social Information 102

   1. Own workforce (S1) 102

      1. Material impacts, risks and opportunities and their interaction with the strategy and business model (SBM-3) 102

      2. Policies related to own workforce (S1-1) 103

      3. Processes for engaging with own workforce and workers' representatives on impacts (S1-2) 105

      4. Processes to remediate negative impacts and channels for own workforce to raise concerns (S1-3) 106

      5. Actions taken in relation to material impacts on own workforce, approaches to mitigate material risks and leverage material opportunities related to own workforce, and effectiveness of such actions (S1-4) 107

      6. Targets related to the management of material impacts, the promotion of positive impacts, as well as risks and opportunities (S1-5) 109

      7. Characteristics of the Company's employees (S1-6) 113

      8. Characteristics of non-employee workers within the Company's own workforce (S1-7) 115

      9. Collective bargaining coverage and social dialogue (S1-8) 115

      10. Diversity metrics (S1-9) 116

      11. Adequate wages (S1-10) 117

      12. Social protection (S1-11) 117

      13. Persons with disabilities (S1-12)) 117

      14. Training and skills development metrics (S1-13) 118

      15. Health and safety metrics (S1-14) 118

      16. Work-life balance (S1-15) 118

      17. Remuneration metrics (gender pay gap and total remuneration) (S1-16) 119

      18. Incidents, complaints and severe human rights impacts (S1-17) 120

   2. Workers in the value chain (S2) 120

      1. Policies related to workers in the value chain (MDR-P) 121

      2. Actions and resources related to workers in the value chain (MDR-A) 121

      3. Parameters in relation to workers in the value chain (MDR-M) 122

      4. Monitoring the effectiveness of policies and actions through targets (MDR-T) 122

   3. 3.3 Affected groups (S3) 123

      1. Policies related to affected groups (MDR-P) 123

      2. Actions and resources in relation to affected groups (MDR-A) 124

      3. Parameters in relation to affected groups (MDR-M) and monitoring the effectiveness of policies and actions through targets (MDR-T) 124

1. Information on governance 126

   1. Business conduct (G1) 126

      1. The role of the administrative, management and supervisory bodies (ESRS 2 GOV-1) 126

      2. Business conduct policies and corporate culture (G1-1) 126

      3. Supplier relationship management (G1-2) 128

      4. Prevention and detection of corruption and bribery (G1-3) 128

      5. Cases of corruption or bribery (G1-4) 129

      6. Political influence and lobbying activities (G1-5) 130

      7. Payment practices (G1-6) 130

   2. Cybersecurity 134

      1. Policies adopted to manage material sustainability matters (MDR-P) 134

      2. MDR-A, MDR-M, MDR-T Actions and resources, parameters and monitoring of the effectiveness of policies and actions in relation to material sustainability matters 135

   3. Innovation 138

      1. Policies adopted to manage material sustainability matters (MDR-P) 138

      2. MDR-A, MDR-M, MDR-T Actions and resources, parameters and monitoring of the effectiveness of policies and actions in relation to material sustainability matters 138

SECTION II: Requirements of Law 11/2018 on Non-Finantial Statements (EINF) 142

SECTION III: ANNEXES 165

Annex I. Materiality analysis 166

Annex II. Disclosure requirements covered as set out in the ESRS 170

Annex III. Corporate policies 203

Annex IV. Supplementary sustainability information relating to non-material matters 216

Annex VI. Glossary of Terms 230

Table 1: Pillars of the Sustainability Plan 9

Table 2: (PILLAR 1) Main milestones achieved in 2025 10

Table 3: (PILLAR 1) Evolution of the main indicators 11

Table 4: (PILLAR 2) Main milestones achieved in 2025 11

Table 5: (PILLAR 2) Evolution of the main indicators 11

Table 6: (PILLAR 3) Main milestones achieved in 2025 13

Table 7: (PILLAR 3) Evolution of the main indicators 13

Table 8: (PILLAR 4) Main milestones achieved in 2025 14

Table 9: (PILLAR 4) Evolution of the main indicators 14

Table 10: Time horizons in climate risks and opportunities 16

Table 11: Estimates carried out 17

Table 12: Composition of the Board of Directors as at 31 December 2025 21

Table 13: Composition of the Management Committee as at 31 December 2025 21

Table 14: Cross-references to due diligence elements 25

Table 15: Sectors of application 27

Table 16: Employees by country 28

Table 17: Sales by market 29

Table 18: Strategic pillars and lines 29

Table 19: Value chain 31

Table 20: Stakeholders 32

Table 21: List of IROs and their linkage to Tubacex's value chain and strategy 36

Table 22: List of material topics 40

Table 23: ESG Plan: levers, targets and objectives 44

Table 24: Decarbonisation pathway ¡Error! Marcador no definido.

Table 25: Risks and opportunities related to climate change 45

Table 26: Risks and opportunities related to climate change and their associated impacts 50

Table 27: Adaptation and mitigation measures for the physical risk: Reduction in water availability for industrial processes 51

Table 28: Material IROs and associated commitments in relation to climate change ¡Error! Marcador no

definido.

Table 30: Reduction targets 54

Table 31: Table 25. Actions and targets in the field of climate change 56

Table 32: Energy consumption and mix 57

Table 33: Scope 1 and 2 carbon footprint of the Tubacex Group ¡Error! Marcador no definido.

Table 34: Scope 3 carbon footprint of the Tubacex Group 59

Table 35: Carbon footprint calculation methodologies 61

Table 36: Emissions of the Álava Steelworks compared to the Group total 63

Table 37: Financial effects associated with climate risks 65

Table 38: Financial effects associated with climate opportunities 66

Table 29: Financial resources of eligible activities ¡Error! Marcador no definido.

Table 39: Highest priority risks and opportunities related to pollution 72

Table 40: Highest priority risks and opportunities related to pollution 72

Table 41: Highest priority risks and opportunities related to pollution ¡Error! Marcador no definido.

Table 42: List of material IROs related to pollution and associated commitments . ¡Error! Marcador no definido.

Table 43: Atmospheric pollutants ¡Error! Marcador no definido.

Table 44: Water pollutants ¡Error! Marcador no definido.

Table 45: Highest priority risks and opportunities related to water resources 81

Table 46: List of material IROs linked to water resources and associated commitments 82

Table 47: Actions and targets in the field of water resources 85

Table 48: Water consumption ¡Error! Marcador no definido.

Table 49: Water consumption in water-stressed areas 87

Table 50: Risks and opportunities linked to resource use and circular economy 91

Table 51: List of IROs linked to resource use and circular economy and associated commitments 92

Table 52: Actions and targets associated with resource use and circular economy 96

Table 53: Waste generated 100

Table 54: Key aspects in the management of the Group's workforce 101

Table 55: Actions and targets related to own workforce ¡Error! Marcador no definido.

Table 56: Breakdown of employees by gender ¡Error! Marcador no definido.

Table 57: Breakdown of employees by country ¡Error! Marcador no definido.

Table 58: Breakdown of employees (FTE) by type of contract and gender ¡Error! Marcador no definido.

Table 59: Breakdown of employees (FTE) by type of contract and gender ¡Error! Marcador no definido.

Table 60: Employees leaving the company and turnover rate ¡Error! Marcador no definido.

Table 61: Employees covered by collective bargaining ¡Error! Marcador no definido.

Table 62: Employees in Senior Management (no.) 116

Table 63: Employees in Senior Management (%) 116

Table 64: Employees by age group 116

Table 65: Training hours per employee (no.) 117

Table 66: Occupational health and safety indicators 117

Table 67: Employees entitled to family-related leave 118

Table 68: Effective gender equality in remuneration parameters 119

Table 69: Actions and targets related to affected communities 124

Table 70: Payment practices ¡Error! Marcador no definido.

Table 71: Actions and targets in the field of governance 133

Table 72: Actions and targets related to cybersecurity 135

Table 73: Actions and targets related to innovation 141

Introduction

In a global context marked by the energy transition, industrial transformation and increasing regulatory and social demands, Tubacex consolidates in 2025 its sustainable growth model, integrating sustainability as a cross-cutting axis of its business strategy, its business model and its decision-making.

As an industrial group specialised in advanced tubular solutions in stainless steel and high-performance alloys, Tubacex operates in critical sectors where operational excellence, technological innovation and the responsible management of environmental, social and governance (ESG) impacts are determining factors for long-term competitiveness.

This Sustainability Report shows how Tubacex transforms environmental, social and regulatory challenges into levers for competitiveness, resilience and value creation, in alignment with the NT2 Strategic Plan.

Sustainability integrated into the strategy

The Tubacex Sustainability Plan constitutes the operational framework that translates the corporate strategy and the NT2 Strategic Plan into specific objectives, projects and indicators in the environmental, social and governance fields. The definition of strategic priorities in terms of sustainability is based on the annual double materiality analysis carried out in accordance with the European Sustainability Reporting Standards (ESRS), which makes it possible to identify the most relevant impacts, risks and opportunities both from the perspective of the environment and in terms of their potential financial effect on the Group.

This exercise, validated by the governing bodies and aligned with the corporate risk management model, covers upstream and downstream phases of the Tubacex value chain, from the sourcing of raw materials and energy to the sale and distribution phase of the products by customers. In this way, the Company obtains a comprehensive view of its main dependencies, regulatory exposures and value creation opportunities in a context of energy transition and industrial transformation.

This Plan is structured around four priority pillars, aligned with the main impacts, risks and opportunities identified in the double materiality analysis and with the priorities of the steel sector. The monitoring of the Sustainability Plan is carried out through a specific governance structure, under the supervision of the Board of Directors and its delegated committees, and with indicators integrated into internal control and incentive systems.

Relationship between the Sustainability Plan and the European Sustainability Reporting Standards (ESRS) resulting from the materiality analysis:

Table 1: Pillars of the Sustainability Plan

*The selection of SDGs has been made based on their material relevance to the Group's industrial activity and is not intended to cover exhaustively all the Sustainable Development Goals.

These areas have a cross-cutting impact on competitiveness, operational resilience and the ability to access markets and financing in an environment that is increasingly demanding in regulatory and reputational terms.

The systematic consideration of these factors in planning and decision-making processes enables Tubacex to anticipate physical and transition risks - including those associated with the evolution of the climate regulatory framework, energy volatility or traceability requirements in the supply chain - and, at the same time, to strengthen its positioning in lower-carbon and higher value-added technological segments.

In line with these material areas, Tubacex structures its strategic priorities around lines of action that respond in an integrated manner to the main impacts, risks and opportunities identified. The progressive decarbonisation of the business, the promotion of circular models, the development of technological solutions for the energy transition, the strengthening of human capital and the consolidation of a robust framework of ethics and good governance constitute the levers through which the Company articulates its strategic response. This approach ensures operational continuity with the conclusions of the materiality analysis, translating them into the management model and into the evolution of the business in the medium and long term.

Promoting circularity and climate neutrality

Decarbonisation constitutes one of the strategic pillars of Tubacex's sustainability model, in a context in which the steel sector faces significant challenges arising from its high energy and carbon intensity. The Group addresses this challenge through a Climate Transition Plan aligned with the Paris Agreement and with emissions reduction targets validated by the Science Based Targets initiative (SBTi), which cover scopes 1, 2 and 3, with a climate neutrality horizon set for 2050.

Tubacex's approach is based on a progressive strategy, combining the direct reduction of emissions in its industrial processes with the transformation of the energy mix and the promotion of circular models. The main decarbonisation levers are:

• Energy efficiency and improvement of industrial processes. The improvement of energy efficiency constitutes the main lever for the reduction of Scope 1 and 2 emissions. Tubacex has prioritised investments in its facilities with the greatest impact - particularly the steel mill - aimed at optimising furnaces, combustion systems, heat recovery, automation and advanced process control. These actions enable a structural reduction in energy consumption per unit of production, while at the same time reinforcing the Group's operational competitiveness.

• Transition of the energy mix towards renewable sources. The second key lever is the progressive decarbonisation of energy consumption through the increased use of electricity from renewable sources. The Group combines longterm power purchase agreements (PPAs), the expansion of green electricity supply across different geographies and the progressive replacement of higher-impact sources with renewable energy, adapting its strategy to the regulatory and market conditions of each country.

These levers enable Tubacex to reduce its energy and carbon intensity, safeguard its industrial competitiveness and anticipate the regulatory impact arising from the EU ETS, CBAM and the evolution of carbon pricing.

Decarbonisation is also managed from a financial and regulatory risk perspective. Tubacex integrates climate change-related risks - including those derived from the EU ETS, CBAM and the evolution of carbon prices - into its strategic planning processes, investment analysis and risk management, using tools such as an internal carbon price to guide decision-making.

The Company has also strengthened the control of other environmental impacts relevant to the sector, such as atmospheric emissions, water management in water-stressed areas and pollution prevention, relying on certified management systems, investments in best available techniques and continuous monitoring of regulatory compliance.

Main milestones achieved in 2025:

Table 2: (PILLAR 1) Main milestones achieved in 2025

Evolution of the main indicators:

Table 3: (PILLAR 1) Evolution of the main indicators.

Developing innovative solutions for the energy transition

The energy transition not only transforms industrial processes, but also the portfolio of products and services. In 2025, Tubacex has consolidated its positioning in key low-emission technologies, progressing towards a structural diversification of the business.

The Company actively participates in the development of solutions related to hydrogen, CO₂ capture and storage, alternative fuels and other emerging technologies, both to enable the future reduction of its own emissions and to support its customers in their decarbonisation processes.

Main milestones achieved in 2025:

Evolution of the main indicators:

Table 5: (PILLAR 2) Evolution of the main indicators

Caring for our people and the surrounding environment

Employees constitute one of Tubacex's main strategic assets. Their proper management is a critical factor for operational continuity and the execution of the Group's strategy in a highly specialised industrial environment.

In 2025, the Group has a global workforce of more than 2,700 people, diverse in geographical and cultural terms, and with a strong industrial component. Ensuring their safety, well-being and professional development is an absolute priority.

Occupational health and safety remains a critical management pillar, supported by advanced preventive systems, international certifications and clear objectives for reducing accident rates. At the same time, Tubacex has continued to promote continuous training, the reskilling of industrial profiles and talent development as key elements to address the technological and energy transition in a fair manner.

In terms of diversity, equality and non-discrimination, the Company has taken a significant step with the update in 2025 of its Equal Opportunities Policy, strengthening its commitment to reducing the gender pay gap, promoting female leadership and fostering the inclusion of underrepresented groups in a traditionally male-dominated sector. These commitments are integrated into people management processes and are monitored through specific indicators and action plans.

Tubacex's link with the territories in which it operates forms an essential part of its industrial identity. Beyond regulatory compliance and job creation, the Company promotes initiatives with a positive social impact through its Social Action Policy and, in particular, through the Tubacex Foundation, which channels projects in areas such as education, training, social inclusion and community development.

This commitment reinforces the Group's social licence to operate and contributes to the generation of shared value, especially in industrial environments where the Company's activity has a significant economic and social impact.

Main milestones achieved in 2025:

Table 6: (PILLAR 3) Main milestones achieved in 2025

Evolution of the main indicators

Table 7: (PILLAR 3) Evolution of the main indicators

*The indicator is calculated on a base of 100, with a target of a 75% improvement, the indicator representing the progress achieved.

Ethics and good governance

Sustainability at Tubacex is fully integrated into the corporate governance structure and into control and oversight systems. During 2025, the Company has strengthened this model through the consolidation of a system for the control and supervision of sustainability information, aligned with the requirements of the CSRD, which enhances the reliability of ESG data and reduces the risks associated with inconsistent or non-verifiable disclosure; and through the integration of ESG indicators into incentive systems.

A key element of this progress has been the review and update of the corporate sustainability policy framework in December 2025, providing the Group with a coherent, consistent framework aligned with international best practices in environmental, social and governance matters. This set of policies - which includes sustainability, environment, human rights, equality, ethics and compliance - constitutes the foundation upon which the responsible management of the business and accountability to stakeholders are built.

Main milestones achieved in 2025:

Table 8: (PILLAR 4) Main milestones achieved in 2025

Evolution of the main indicators

Table 9: (PILLAR 4) Evolution of the main indicators

Looking ahead

This Sustainability Report 2025 reflects an organisation undergoing a profound transformation, aware of the structural challenges facing the steel sector and committed to evolving towards a more efficient, circular, low-carbon and socially responsible industrial model.

In this context, Tubacex has initiated in 2025 a strategic review process, laying the foundations for a new phase of profitable growth, with sustainability as an integral pillar of the Group's transformation. 2026 will mark the beginning of a new strategic cycle aimed at leveraging the results already achieved and defining the next horizon of value creation, deepening its positioning in higher value-added segments, operational excellence, technological modernisation and the integration of ESG commitments as a competitive lever.

With a solid policy framework and a clear focus on delivering results, Tubacex is advancing towards a more efficient, low-carbon and technologically differentiated industrial model, convinced that sustainability constitutes a structural competitive advantage and a core element of long-term value creation.

1. General Information
   1. 1.1 Basis for the preparation of the sustainability statement

      1. BP-1 General basis for the preparation of the sustainability statement

         (ESRS 2 BP-1: 5 a-5b-5c-5d-5e)

         Tubacex, S.A. (hereinafter, "Tubacex" or the "Company") presents its Sustainability Report for the 2025 financial year, prepared in accordance with the guidelines established in Directive (EU) 2022/2464 of the European Parliament and of the Council, of 14 December 2022, on corporate sustainability reporting (hereinafter, CSRD). The provisions of Directive (EU) 2025/794, known as the "Stop-the-Clock" Directive, have also been taken into account.

         The application of this regulatory framework has entailed the adoption of the European Sustainability Reporting Standards (ESRS) as the main reference for the preparation of this report. This process has been carried out in accordance with Commission Delegated Regulation (EU) 2023/2772, as well as Delegated Act 4812/2025, known as the "Quick Fix".

         Given that the aforementioned European directives have not yet been transposed into the Spanish legal framework, the report additionally includes the disclosures required by Law 11/2018 of 28 December on non-financial information and diversity, which complement and reinforce the information presented in accordance with the European Sustainability Reporting Standards (hereinafter, ESRS), promoting alignment with the objectives of the European Green Deal and contributing to a more sustainable and responsible economy. Likewise, this document also includes the information necessary to comply with the disclosure requirements of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment.

         The information presented covers all companies within the Group's consolidation perimeter. The scope of this report is consistent with that of the published financial statements, with no exceptions or exclusions of any of the Group's subsidiaries.

         Furthermore, in preparing this document, only the available qualitative and quantitative information on the value chain has been included, considering the material impacts, risks and opportunities associated both with Tubacex's own operations and with its value chain, covering both direct and indirect business relationships in upstream and downstream stages of that chain.

         Tubacex has not considered it necessary to omit information on the grounds of intellectual property, know-how or classified or sensitive information. Nor has any data relating to imminent events or matters under negotiation been excluded, in accordance with the provisions of Articles 19a and 29a of Directive 2013/34/EU.

         1. BP-2 Information relating to specific circumstances

            (ESRS 2 BP-2: 9)

            The Timeframes used throughout the document have been established in accordance with section 6.4 of ESRS 1, distinguishing between short term (up to 1 year), medium term (between 1 and 5 years) and long term (more than 5 years). In the case of the assessment of climate-related risks and opportunities, the methodology used by Tubacex incorporates specific horizons for both physical risks and transition risks and opportunities, adapted to the nature and temporal impact of each type of risk:

            Physical risks	Transition risks and opportunities

            • Historical baseline (climate only): 2000-2019

            • Short term: 2020-2039

            • Medium term: 2040-2059

            • Long term: 2060-2099

            • Short term: 2024-2030

            • Medium term: 2031-2040

            • Long term: 2041-2050

            Table 10: Timeframes for climate-related risks and opportunities.

         2. Estimation of the value chain

            (ESRS 2 BP-2: 10)

            In applying the transitional provision and considering the delegated "Quick Fix" act related to the value chain, Tubacex has not included in this report detailed quantitative information on parameters associated with that value chain, due to the difficulty in obtaining such information with the level of reliability and accuracy required for use in the context of this document.

            Nevertheless, it has been possible to incorporate information relating to indirect greenhouse gas emissions (Scope 3). The calculation methodology and estimates made are documented in the corresponding section E1-6.

         3. Sources of estimation and uncertainty

            (ESRS 2 BP-2: 11a-11b)

            With regard to the quantitative parameters and monetary amounts disclosed, the Company reports that all measurements presented in this report are actual results, based on verifiable records. However, there are certain aspects subject to a high degree of uncertainty due to the nature of the assumptions and approximations used in the calculation of certain impacts, which mainly relate to the financial assessment of climate-related risks and opportunities.

            Similarly, forward-looking projections - including environmental impacts and Scope 3 emissions estimates - are subject to uncertainty arising from factors such as the variability of emission factors depending on the methodology or source used, and simplified logistical assumptions. All these assumptions are based on technical expertise and available best practices, although the Company acknowledges that such estimates inevitably entail a degree of uncertainty.

            The data included in the report that have been calculated on the basis of estimates are as follows:

            ESRS	Indicator	Plant	Comments
            E1 - Section 2.1.8 Energy consumption and energy mix	Electricity and natural gas consumption	Tubacex Services, S.L.,	Electricity consumption for the months of August to December and natural gas consumption for March, April, September and November have been estimated due to the lack of available readings.
            E1 - Section 2.1.8 Energy consumption and energy mix	Electricity consumption	NTS SAUDI	Electricity consumption for the period from August to December has been estimated following the identification of inconsistencies in the readings recorded during those months.

            ESRS	Indicator	Plant	Comments
            E1 - Section 2.1.9 Gross GHG emissions	GHG emissions Scope 3	All	Scope 3.4 (upstream transportation and distribution): the calculation has been estimated on the basis of an analysis of the origin of raw materials, applying a materiality criterion to select the plants with the highest purchasing volume as a reference. Emissions have been estimated according to distances, actual transport modes and the corresponding emission factors, prioritising the most relevant logistics flows. Scope 3.10 (processing of sold products): due to the diversity of the steel end-use sectors and the lack of specific emission factors, an internal benchmark has been used. This has been constructed based on the two largest own facilities that use this steel as a raw material, thereby obtaining a representative emission factor. Scope 3.12 (end-of-life treatment of sold products): the calculation has been carried out based on assumptions regarding the final destination of products and the scrap generated, defining representative transport routes. Based on these, an average tonne-kilometre factor has been obtained and applied to annual volumes, which have then been converted into emissions using the corresponding emission factors.
            E2 - Section 2.2.5 Air, water and soil pollution	Air pollutants	ACERALAVA TTI AMURRIO TTI LLODIO	Mass emission data for atmospheric pollutants have been estimated on the basis of the data corresponding to the most recent closed financial year (2024), as updated data were not available at the time of preparation of this report. The estimation has been carried out based on the variation in production volume between one financial year and the next.
            E3 - Section 2.3.5 Water consumption	Water consumption	ACERÍA DE ÁLAVA, S.A.U. TTI - AMURRIO TTI - LLODIO Tubacex Services, S.L.,	The reported water consumption includes estimated consumption for several months at the aforementioned plants, as real data for the 2025 financial year were not available due to errors or technical incidents affecting the measuring equipment. These estimates have been prepared using historical consumption data as a reference, as well as actual consumption recorded in other months of the financial year, in order to ensure the highest possible reliability of the reported information. Details of the estimated data are provided in the corresponding section of the Report.
            E5 - Section 2.4.5 Resource inflows	Resource inflows	All	The quantification of resource inputs is carried out on the basis of recorded purchase data. Although this indicator does not directly reflect the physical inputs into the production system, it constitutes a methodologically consistent approach and is considered a representative proxy of the organisation's overall inputs. As the calculation is based exclusively on purchases, overlap between the categories of reused and recycled waste is avoided, thereby mitigating the risk of double counting.

            Table 11: Overview of estimation methodologies.

         4. Changes in the preparation of sustainability information

            (ESRS 2 BP-2: 13)

            The information reported in accordance with the ESRS may be updated in future reporting periods as a result of improvements in internal data collection processes or potential revisions and simplifications of the standards themselves. Accordingly, certain metrics, calculation methodologies or scopes may be modified to ensure alignment with applicable regulations and best practices. Where possible, Tubacex will provide revised comparative information, indicating the differences between the original and updated data, thereby ensuring consistency, traceability and transparency.

            This report has incorporated, as changes to its structure, an executive summary of the disclosed information, as well as additional annexes to include more detailed and relevant information in the context of sustainability.

         5. Information on errors from prior periods

            (ESRS 2 BP-2: 14, E1-6: 48b-51, E3-4:28 b, E5-4:35. S1-9: 66b. S1-13: 83 b.), OpEx 2024)

            Where applicable, any misstatements, restatements or deviations identified in data from prior periods relating to material matters are disclosed in detail, indicating in each case their nature, the correction applied or, where relevant, the justification for the impossibility of correction. Accordingly, the following information is reported in relation to information disclosed in previous years:

            • The statement reported in 2024 is corrected from: "Tubacex does not generate Scope 1 GHG emissions arising from regulated emissions trading schemes" to: "Tubacex generates Scope 1 GHG emissions subject to regulated emissions trading schemes. In particular, the Álava steel plant (Aceralava) is included in the European Union Emissions Trading System (EU ETS), as its steelmaking processes meet the criteria for emission-intensive installations regulated under this system."

            • Data for the 2024 financial year have been updated by applying the MITERD emission factors for 2024 (version 31, published in 2025), for both Scope 1 and Scope 2. In addition, Scope 3 data for 2024 have been restated in order to:

              • Review and update the units of measurement for materials at the Álava steel plant, adjust conversion factors and incorporate gases into the reporting, with an impact on Scope 3.1

              • To Include Scopes 3.9 and 3.12, which were not included in the original 2024 report.

            • The indicator for water consumption in water-stressed areas for the 2024 financial year has been recalculated in order to use the same bibliographic source for determining areas of high water stress in both reporting periods. In 2024, the Climate Scale tool was used, whereas this report applies the WWF Water Risk Filter tool for current, 2030 and 2050 Timeframes.

            • The figure for raw materials used is corrected, with the accurate figure being 166,959 tonnes of materials purchased in 2024, replacing the previously reported figure of 166,438 tonnes.

            • Data for the 2024 financial year have been restated in terms of Headcount (HC), as they were originally reported in FTE (Full Time Equivalent), in order to ensure comparability with the 2025 financial year, for which indicators are calculated directly on an HC basis.

            • Data for the 2024 financial year have been restated in terms of Headcount (HC), as they were originally reported in FTE (Full Time Equivalent), in order to ensure comparability with the 2025 financial year, for which indicators are calculated directly on an HC basis.

         6. Information derived from other legislation or generally accepted sustainability reporting frameworks

            (ESRS 2 BP-2: 15)

            In addition to the information required by the European Sustainability Reporting Standards (ESRS), the regulatory framework applicable to the disclosure of sustainability information is complemented by various additional legislative provisions. In the case of the Company, the primary reference regulation is Law 11/2018, which governs the preparation of the Non-Financial Information Statement (NFIS) and establishes the minimum mandatory content in relation to non-financial information and diversity.

            In this context, the following regulatory provisions are applicable:

            • Law 11/2018, of 28 December, amending the Commercial Code, the revised text of the Capital Companies Act approved by Royal Legislative Decree 1/2010, of 2 July, and Law 22/2015, of 20 July, on Audit of Accounts, in relation to non-financial information and diversity. This law constitutes the basic and primary legal framework for the disclosure of the Company's sustainability information. While the CSRD and the ESRS address overlapping thematic areas, certain requirements of Law 11/2018 demand a greater level of detail or specific treatment. The specific required content is set out in Section 2. Requirements of Law 11/2018 - NFIS.

            • Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (European Taxonomy). This Regulation complements sustainability information through the identification and classification of the Company's economic activities according to their alignment with the environmental objectives of the Taxonomy, including, inter alia, climate change mitigation and adaptation and the sustainable use of water and marine resources.

            Furthermore, Table 1 in Annex II of this report includes other references to EU legislation associated with ESRS sustainability disclosure requirements.

         7. Incorporation by reference

            (ESRS 2 BP-2: 16)

            No information has been incorporated by reference in this report; therefore, no list of disclosure requirements established under the ESRS, nor of the specific data points required that have been incorporated through this method, is included. All information has been presented directly and in full within this document, ensuring its accessibility and traceability.

         8. Use of phase-in provisions in accordance with Appendix C of ESRS 1

         (ESRS 2 BP-2: 17)

         As Tubacex exceeds the threshold of 750 employees established in Appendix C of ESRS 1, it is required to report information in accordance with ESRS S1, S2, S3 and S4, in line with the results of its materiality assessment.

         With regard to sections S2 (Workers in the value chain) and S3 (Affected communities), the Company has applied the proportionality provisions introduced by Delegated Act (EU) 2025/4812, implementing the minimum disclosure requirements in a manner proportionate to the material risks and opportunities identified in these areas. Consequently, the information reported under S2 and S3 focuses on disclosure requirement BP-2, paragraph 17, as set out in Chapters 3.2 Workers in the value chain and 3.3 Affected communities of this report.

   2. Governance

      1. GOV-1 Role of the administrative, management and supervisory bodies

         Governance model and allocation of responsibilities

         (ESRS 2 GOV-1: 21a-21b-21c-21d-22a)

         Tubacex's governance system establishes a clear allocation of responsibilities between the Board of Directors, its delegated committees and the Management Committee, with the aim of ensuring appropriate oversight of the Group's strategy, risk management and overall performance, including environmental, social and governance aspects.

         Board of Directors and Committees. The Board of Directors is the body responsible for the overall supervision of the Company's strategy and management. Its functions include the approval of the main strategic guidelines, oversight of the internal control and risk, impact and opportunity management system, as well as monitoring compliance with regulatory, ethical and sustainability commitments. For the proper performance of its duties, the Board is supported by specialised committees that assist in its supervisory role:

         • The Audit and Compliance Committee oversees the integrity of financial and non-financial information, the functioning of the internal control system and the management of risks, impacts and opportunities, as well as compliance with legal and regulatory obligations.

         • The Appointments and Remuneration Committee is responsible for proposing and overseeing policies relating to the composition of the Board and Senior Management, as well as remuneration systems, in line with good governance recommendations.

         • The Sustainability and Good Governance Committee supports the Board in overseeing strategy and policies relating to sustainability, human rights, good governance and other relevant ESG aspects, ensuring their progressive integration into the Group's management.

         The Board is composed of 11 members, characterised by diversity and balance: 7 are independent, 1 executive, 1 proprietary and 2 external. The detailed composition is as follows:

         Name	Position	Status	Committees
         Manuel Moreu Munaiz	Chairman	Independent	-
         Ignacio Mataix Entero	Vice-Chairman	Independent	Appointments and Remuneration / Audit and Compliance Committee
         Josu Imaz Murguiondo	Chief Executive Officer	Executive	-
         Nuria López de Guereñu Ansola	Board Member	Independent	Audit and Compliance / Sustainability and Good Governance Committee
         Isabel López Paños	Board Member	Proprietary	Appointments and Remuneration Committee
         Iván Martén Uliarte	Board Member	Independent	Sustainability and Good Governance Committee
         José Toribio González	Board Member	Other external	Audit and Compliance Committee
         Gracia López Granados	Board Member	Other external	Sustainability and Good Governance Committee

         Elena Guede Vázquez	Board Member	Independent	Sustainability and Good Governance Committee
         Rafael Martín de Bustamante Vega	Board Member	Independent	Appointments and Remuneration Committee
         Xabier Sagredo Ormaza	Board Member	Independent	Audit and Compliance Committee
         Maider Cuadra Etxebarrena	Secretary to the Board (non-member)	-	All

         Table 12: Composition of the Board of Directors as of 31 December 2025

         Management Committee. The Management Committee, led by the Chief Executive Officer, is responsible for the day-to-day management and the implementation of the strategy approved by the Board of Directors. Within this framework, Management integrates ESG aspects into operational decision-making, risk management processes and the execution of corporate policies, periodically reporting to the Board and its committees on the evolution of performance and on the main impacts, risks and opportunities identified.

         The current composition of the Management Committee is set out below. It was redefined in 2026 to drive the Group's strategic priorities.

         Name	Position
         Josu Imaz	Chief Executive Officer
         Guillermo Ruiz-Longarte	Corporate Chief Financial Officer
         Antón Azlor	Corporate Chief Commercial Officer
         Ana López de Mendoza	Chief Risk and Internal Control Officer
         Iker Azkargorta	Managing Director of Special Components
         Diego Herrero	Corporate Director of Innovation
         Manuel Sarabia	Corporate Human Resources Director and Managing Director of Advanced Solutions
         Celestino Danis	Managing Director of Steel and Extrusion
         Juan Gómez-Cordobés	Managing Director for the Middle East
         Ajay Sambrani	Managing Director for Asia
         Javier Lorenzo	Managing Director for the Americas
         Olalla Montes	Corporate Director of Strategy and Transformation

         Table 13: Composition of the Management Committee as of 31 December 2025

         Employee representation and social dialogue

         (ESRS 2 GOV-1: 21b)

         Tubacex prioritises the promotion of an inclusive and participatory working environment, aligned with labour regulations and social dialogue practices applicable in each of the regions in which it operates. Employee representation is considered a key element in ensuring strong labour relations and open, constructive dialogue.

         At European sites, and in accordance with applicable labour legislation, formal representation mechanisms are in place to facilitate continuous interaction between management and employees. In the United States, where employee representation is optional in many sectors, Tubacex applies an approach tailored to each site. In Asia and the Middle East, the Group promotes alternative channels for direct communication and internal dialogue, in line with local regulatory and cultural frameworks.

         While these mechanisms enable the channelling of workforce participation and concerns, there is currently no direct employee representation within the Group's administrative, management or supervisory bodies.

         Composition, diversity and expertise of the Board of Directors

         (ESRS 2 GOV-1: 21c-21d-21e)

         The Board of Directors of Tubacex is composed of professionals with extensive backgrounds and experience in business areas related to the Group's activities, with particular emphasis on sectors such as engineering, energy and transport (naval, aerospace and automotive). This consolidated expertise enables a thorough understanding of the sectors, products and markets in which the Group operates globally.

         From a diversity perspective, the proportion of women on the Board stands at 36% (30% in 2024), and the proportion of independent directors is 64% (60% in 2024), in accordance with the provisions of the Board Regulations. In addition, the current ratio of women on the Board has increased to 0.56, compared to 0.43 in the previous financial year.

         Risk management and Policy

         (ESRS 2 GOV-1: 22b-22c-22d)

         Within the framework of its strategic reflection process, Tubacex periodically updates its corporate risk map with the aim of assessing the risks to which the organisation is exposed, analysing the underlying causal relationships and obtaining an overall view of its risk exposure.

         Risk identification is carried out through questionnaires and interviews with those responsible for the various business units and corporate areas, primarily members of the Management Committee. The risks identified are assessed based on their likelihood of occurrence and their impact on strategic objectives, and the projects defined within the strategic plan enable their mitigation and monitoring. This risk management system is aligned with UNE-ISO 31000:2018.

         The risk map is presented to the Board of Directors at least twice a year, one of which coincides with the annual review of the Strategic Plan. The Board performs a non-delegable supervisory role over risks, supported by the Audit and Compliance Committee, which in turn is assisted by the Internal Audit and Compliance functions, and in coordination with the Sustainability and Good Governance Committee on ESG-related matters.

         Tubacex's General Risk Control and Management Policy, which is approved by the Board of Directors, establishes the principles and criteria governing the Group's comprehensive risk control and management system. This policy is implemented through a structured framework based on a clear definition and allocation of roles and responsibilities, both at operational and supervisory levels, as well as on procedures, methodologies, supporting tools and information systems tailored to the different stages of the risk management process.

         The system is structured in accordance with a model in which the various bodies and functions assume clearly differentiated and complementary responsibilities, aimed at ensuring the proper management of the Group's material risks, impacts and opportunities:

         • The Audit and Compliance Committee periodically reviews internal control and risk management systems, including tax-related risks, in order to identify, analyse and ensure appropriate reporting of the main risks, impacts and opportunities. With regard to ESG-related risks and impacts, this work is carried out in coordination with the Sustainability and Good Governance Committee, in accordance with the provisions of the Board of Directors Regulations.

         • The Internal Audit function informs, advises and reports to the Audit and Compliance Committee on the effectiveness of the internal control system and the management of risks, impacts and opportunities, supporting functional areas in the identification, measurement and control of risks.

         • The Management Committee is responsible for carrying out the identification, management and control of risks, impacts and opportunities, integrated into business processes and decision-making, ensuring their proper incorporation into operational monitoring and strategy execution. It is also responsible for promoting a risk management culture within the Company and for establishing and/or delegating action plans to control and reduce exposure to such risks.

         Additionally, during the 2023 financial year, the Risk and Control function was formalised at Management Committee level, aimed at strengthening the monitoring and control of the Group's risk profile. Its responsibilities include ensuring that risks are managed within acceptable tolerance levels and guaranteeing appropriate reporting on risk management to the Management Committee, the Audit and Compliance Committee and the Board of Directors.

         In terms of sustainability, the oversight of impacts, risks and opportunities is actively carried out through the Sustainability and Good Governance Committee, in coordination with the Audit and Compliance Committee, thereby reinforcing the integration of ESG aspects into the Group's governance system.

         Knowledge and competencies of the Board of Directors

         (ESRS 2 GOV-1: 23)

         The Board of Directors of Tubacex possesses the knowledge and competencies required to oversee the Group's strategy, risks and impacts, including those related to sustainability and ESG factors, in line with the nature of its activities, the markets in which it operates and the complexity of its business environment.

         With regard to the maintenance and updating of these competencies, the Board relies on a combination of the professional experience of its members, the periodic information provided by Senior Management and specialised corporate functions, as well as the work of its delegated committees, in particular the Sustainability and Good Governance Committee and the Audit and Compliance Committee. In addition, the Board receives up-to-date information on regulatory trends, emerging risks and relevant sustainability and governance matters through dedicated sessions, supporting documentation and, where necessary, external advice.

         The Board also includes members who contribute relevant experience in areas related to sustainability, energy, governance and sustainable development.

         Ms Nuria López de Gereñu brings extensive experience in social sustainability and institutional development, promoting projects to improve access to clean energy in communities in sub-Saharan Africa and participating in business and equality forums; she has also held public responsibilities in the fields of the natural environment, infrastructure and transport, which enhances the Board's understanding of the management of environmental and social impacts.

         Mr Iván Martén Uliarte has more than 30 years of experience in the energy and environmental sector, having advised governments and regulators on matters related to the energy transition and sustainable development, providing a strategic perspective on regulatory and transition risks.

         Ms Elena Guede Vázquez, a Chemical Engineer with a PhD in Chemical and Environmental Engineering, has extensive international executive experience in the industrial sector and in the development of sustainability and decarbonisation strategies, contributing technical expertise to the Board in industrial processes, emissions reduction and the transition towards more sustainable production models.

         This diversity of profiles and professional backgrounds contributes to a comprehensive and analytical approach to the identification and oversight of the Group's material impacts, risks and opportunities.

      2. GOV-2 Information provided to the administrative, management and supervisory bodies on sustainability matters and the supervision of the Company and sustainability matters addressed by them

         Information flows and frequency

         (ESRS 2 GOV-2: 26a)

         The Sustainability function reports to the administrative, management and supervisory bodies on the identification and analysis of material impacts, risks and opportunities (IROs) at least once a year, within the framework of materiality assessment and risk management processes. In addition, the corporate risk map, which includes relevant sustainability matters in an integrated manner, is submitted to the Board of Directors twice a year.

         Furthermore, the Sustainability and Good Governance Committee receives quarterly information on the progress of the sustainability plan, including the monitoring of the effectiveness of the policies, actions, metrics and targets adopted, as well as the level of progress in the implementation of sustainability due diligence processes (DP 26 a).

         Integration of information into strategy and management

         (ESRS 2 GOV-2: 26b)

         The identified material impacts, risks and opportunities are actively considered by the administrative and management bodies in order to adapt and transform the Company's strategy, business model and processes in response to the needs of the environment and its stakeholders. This approach involves conducting periodic analyses of the operating environment, defining proactive action plans for risk management and identifying growth opportunities aligned with emerging sustainability trends.

         In this context, particular note should be made of the creation of a specific area to drive the "Low Carbon" segment, aimed at leveraging business diversification opportunities linked to decarbonisation, while at the same time mitigating risks associated with business models that are more intensive in higher-emission energy sources.

         Impacts, risks and opportunities addressed

         (ESRS 2 GOV-2: 26c)

         The material impacts, risks and opportunities subject to analysis and oversight by the administrative, management and supervisory bodies correspond to those described in section 1.2.2 SBM-3 - Material impacts, risks and opportunities and their interaction with the strategy and business model, where their nature, scope and relationship with the corporate strategy are detailed.

      3. GOV-3 Integration of sustainability-related performance into incentive systems

         Incentive systems, scope of application and governance

         (ESRS 2 GOV-3: 29ª-29b-29c-29d-29e)

         Tubacex has an incentive system that integrates sustainability-related performance into the variable remuneration of Senior Management. In particular, the Company has a Long-Term Incentive Plan 2024-2026 (renewed for 2025-2027), aimed at members of the Management Committee, including the Chief Executive Officer, as well as certain key executives. This plan allows its beneficiaries to receive, after a defined period, an incentive payable in Tubacex shares, conditional upon the achievement of multi-year strategic objectives.

         The calculation of the long-term incentive is based on the achievement of objectives focused on the creation of sustainable value for the Company and its shareholders. The structure of the plan allocates the weighting of objectives as follows:

         • Shareholder value creation: 50%

         • EBITDA (operating profit): 40%

         • ESG objectives (environmental, social and governance): 10% Within the ESG objectives, the following key parameters have been defined:

         • Low Carbon product sales: 5%

         • Promotion of equality: 5%

           Although the Incentive Plan has a three-year duration, its terms and conditions may be adjusted where necessary to preserve the equivalence and purpose of the plan, taking into account significant changes in the Company's internal or external environment. The plan is approved by the General Shareholders' Meeting, in accordance with applicable regulations and good governance practices.

           Additionally, Tubacex has implemented a variable remuneration system linked to sustainability objectives that applies to middle management and directors (approximately 300 individuals). Within this group, ESG objectives represent 5% of total annual variable remuneration. For the 2025 financial year, the indicators considered were:

         • Scope 1 and 2 emissions: 2.5%

         • Accident frequency rate: 2.5%This system complements the Long-Term Incentive Plan and contributes to strengthening the integration of ESG objectives into management and decision-making at different levels of the organisation

      4. GOV-4 Statement on due diligence

         (ESRS 2 GOV-4: 30-32)

         Tubacex applies a sustainability due diligence approach aligned with the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, progressively integrated into its governance system, strategy and business model.

         Due diligence is applied both to its own operations and, progressively and on a risk-based approach, to the value chain. It is structured across the different key stages of the process, as described below through cross-references to the sections of the Sustainability Statement where each of these elements is set out in detail.

         CORE ELEMENTS OF DUE DILIGENCE	SECTIONS OF THE SUSTAINABILITY STATEMENT
         a) Integration of due diligence into governance, strategy and the business model	ESRS 2 GOV-2 ESRS 2 GOV-3 ESRS 2 SBM-3
         b) Engagement with affected stakeholders across all key stages of the due diligence process	ESRS 2 GOV-2 ESRS 2 SBM-2 ESRS 2 IRO-1 ESRS 2 MDR-P ESRS S1 S1-2 ESRS S2 S2-2 ESRS S3 S3-2
         c) Identification and assessment of adverse impacts	ESRS 2 IRO-1 (including the application requirements related to specific sustainability matters set out in the relevant ESRS) ESRS SBM-3
         d) Adoption of measures to address those adverse impacts	ESRS 2 MDR-A ESRS E1 E1-1, E1-2, E1-3 ESRS E2 E2-1, E2-2 ESRS E3 E3-1, E3-2 ESRS E5 E5-1, E5-2 ESRS S1 S1-1, S1-4 ESRS S2 S2-1, S2-4 ESRS S3 S3-1, S3-4
         e) Monitoring the effectiveness of these efforts and communication	ESRS 2 MDR-M ESRS MDR-T ESRS E1 E1-4 ESRS E2 E2-3 ESRS E3 E3-3 ESRS E5 E5-3 ESRS S1 S1-5 ESRS S2 S2-5 ESRS S3 S3-5

         Table 14: Cross-references to due diligence elements

      5. GOV-5 Risk management and internal controls over sustainability reporting

         (ESRS 2 GOV-5: 36a-36b-36c-36d-36e)

         General framework of the internal control system for sustainability information (ICS-SI)

         (ESRS 2 GOV-5: 36a-36d)

         The Tubacex Group has an Internal Control System for Sustainability Information (ICS-SI), designed to ensure the reliability, traceability, consistency and quality of disclosed ESG information, in alignment with the requirements of the CSRD and the European Sustainability Reporting Standards. This system is integrated into the Group's overall internal control framework, together with the corporate risk management system, the compliance system and the Internal Control System for Financial Information.

         Responsibilities and governance

         (ESRS 2 GOV-5: 36b)

         The ICS-SI is structured through a clearly defined governance framework, with responsibilities assigned across the different levels of the organisation. The system is coordinated by the Sustainability function, in collaboration with the Risk and Internal Control, Human Resources, Compliance and Internal Audit functions, and is overseen by Management and the relevant committees of the Board of Directors. In the 2025 financial year, it was integrated into the same IT management tool used for the internal control of financial information.

         Identification of sustainability reporting risks

         (ESRS 2 GOV-5: 36c)

         As part of the design of the SCIIS, Tubacex has defined a specific sustainability information risk matrix, identifying the main risks associated with the ESG reporting process, including, among others, regulatory changes, errors in the presentation of information, failures in the identification of material matters, integrity of input data, fraud, cybersecurity and the uniqueness of reporting. The identification and prioritisation of these risks have been carried out using a risk-based approach, prioritising those with the greatest potential impact on publicly disclosed information and on the Group's financing.

         Control activities and methodology applied

         (ESRS 2 GOV-5: 36a-36d)

         The SCIIS has been developed in accordance with a methodology based on the COSO framework and its five components (control environment, risk assessment, control activities, information and communication, and monitoring). As a result of this work, more than 100 control activities (105 controls) have been defined, covering the different areas of sustainability reporting, including governance, strategy, indicators and operational processes, with the identification of owners, reviewers, evidence and frequency. These control activities are managed through specific digital tools, centralising oversight within the Sustainability team and ensuring the traceability of the data used for reporting.

         Oversight, continuous improvement and state of development

         (ESRS 2 GOV-5: 36e)

         The SCIIS is conceived as a dynamic and evolving system, subject to ongoing oversight and continuous improvement processes. During the 2025 financial year, the focus has been placed on meeting the minimum required standards and establishing a solid foundation for the system, in a context of regulatory developments and ongoing revision of the ESRS standards. Looking ahead to the 2026-2027 period, Tubacex plans to advance in the consolidation and further development of the SCIIS, progressively incorporating improvements and, where appropriate, the support of independent experts, as the applicable regulatory framework becomes clearer.

   3. Strategy, Business Model and Value Chain

      1. SBM-1 Strategy, business model and value chain

(ESRS 2 SBM-1: 40 a i-40 a ii-40 a iii -40 a iv-40b-40c-40 d i-40e-40f-40g-42a-42b-42c)

Tubacex is a company specialised in the design, manufacture and supply of advanced industrial products and high value-added services for the energy and mobility sectors. Among its key products and services are:

Table 15: Sectors of application

In recent financial years, Tubacex has expanded and diversified its product portfolio, incorporating innovative, high value-added technological solutions such as the Sentinel® Prime premium connection, and strengthening its positioning in customised solutions tailored to each client's needs. No products or services have been removed from the global catalogue.

In terms of markets, Tubacex operates on a well-established international basis, with a presence in strategic sectors such as energy, mobility and the aerospace industry. Its global network includes production plants and service centres in Spain, Austria, Italy, the United States, India, Thailand, Saudi Arabia, Dubai, Norway, Canada, Singapore, Guyana, Kazakhstan and Abu Dhabi.

The Group has strengthened its presence in emerging markets, particularly in sectors linked to the energy transition and renewable energy, with no significant market withdrawals recorded within its operating structure. Furthermore, Tubacex products are not prohibited in any market.

The number of employees by geographical area is detailed below:

Table 16: Employees by Country

During the 2025 financial year, the Company achieved consolidated sales of €719.2 million, compared to €767.5 million in 2024, reinforcing its position as an international benchmark in the design, manufacture and installation of advanced industrial products.

At present, the Company's main areas of focus are the Energy and Mobility sectors. Its activities range from the exploration and extraction of oil and gas, refining, and various chemical and petrochemical industries to low-emission energy, through the development of innovative solutions for energy generation, storage and transport, with a clear focus on emerging markets such as hydrogen and Carbon Capture and Storage (CCS).

Table 17: Sales by Market

Likewise, its products and services meet the needs of various chemical and petrochemical, aerospace, low-carbon, fertiliser, and electronics and new technologies industries, among other sectors of activity.

Within its sustainability strategy, Tubacex sets an ambitious course towards a sustainable future, establishing key strategic objectives focused on four fundamental pillars: the decarbonisation and circularity of its business; innovation for the energy transition; the care of people and local communities; and a strong culture of transparency and integrity. This commitment to sustainability forms part of the Company's overall strategy and is embedded transversally across all its business areas. At an operational level, it guides the evolution of all products and services offered, promoting the development of stainless steel solutions through more energy- and emissions-efficient processes, applying strategies that minimise environmental impact and actively contribute to the decarbonisation of its clients.

The main pillars and strategic lines are as follows:

Table 18: Strategic Pillars and Lines