Untitled

ANNUAL

FINANCIAL

REPORT 2025

FROM 1

JANUARY TO 31

DECEMBER 2025

PIRAEUS PORT AUTHORITY S.A.

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

PIRAEUS PORT AUTHORITY S.A.

ANNUAL

FINANCIAL REPORT

FOR THE YEAR ENDED

DECEMBER 31, 2025

(IN ACCORDANCE WITH THE L. 3556/2007)

 
 
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PIRAEUS PORT AUTHORITY S.A 
Annual Financial Report for the year ended December 31, 2025 
(amounts in Euro unless stated otherwise) 
 
 
 
Contents 
STATEMENTS OF THE MEMBERS OF THE BOARD OF DIRECTORS ............................................................................................................ 5 
ANNUAL REPORT OF THE BOARD OF DIRECTORS .................................................................................................................................... 6 
STATEMENT OF CORPORATE GOVERNANCE ......................................................................................................................................... 24 
ANNUAL SUSTAINABILITY  STATEMENT ............................................................................................................................................... 115 
ESRS 2 GENERAL DISCLOSURES .................................................................................................................................................................. 115 
EUROPEAN TAXONOMY ............................................................................................................................................................................. 195 
ESRS E1 & E2– CLIMATE CHANGE & POLLUTION .......................................................................................................................................... 213 
ESRS S1- OWN WORKFORCE ..................................................................................................................................................................... 254 
ESRS S3- AFFECTED COMMUNITIES ............................................................................................................................................................ 291 
ESRS S4 – CUSTOMERS AND END-USERS ...................................................................................................................................................... 304 
ESRS-G1 BUSINESS CONDUCT ................................................................................................................................................................... 322 
INDEPENDENT PRACTITIONER’S LIMITED ASSURANCE REPORT ON PIRAEUS PORT AUTHORITY S.A SUSTAINABILITY STATEMENT ... 360 
INDEPENDENT AUDITOR’S REPORT ..................................................................................................................................................... 365 
STATEMENT OF COMPREHENSIVE INCOME FOR THE YEAR ENDED DECEMBER  31, 2025 .................................................................. 375 
STATEMENT OF FINANCIAL POSITION AS AT DECEMBER  31, 2025 .................................................................................................... 376 
STATEMENT OF CHANGES IN EQUITY FOR THE YEAR ENDED  DECEMBER 31,2025 ............................................................................ 377 
CASH FLOW STATEMENT FOR THE YEAR  ENDED DECEMBER 31,2025 ............................................................................................... 378 
NOTES TO THE FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2025 ....................................................................... 379 
1.  ESTABLISHMENT AND ACTIVITY OF THE COMPANY .................................................................................................................. 379 
2.  BASIS OF PRESENTATION OF FINANCIAL STATEMENTS: ........................................................................................................... 380 
3.  MATERIAL ACCOUNTING POLICIES ........................................................................................................................................... 383 
4.  PROPERTY, PLANT & EQUIPMENT ............................................................................................................................................ 399 
5.  RIGHT OF USE ASSETS – LEASE LIABILITIES ................................................................................................................................ 400 
6.  INVESTMENT PROPERTY ........................................................................................................................................................... 402 
7.  INTANGIBLE ASSETS ................................................................................................................................................................. 403 
8.  ADVANCES AND OTHER NON-CURRENT ASSETS ....................................................................................................................... 404 
9.  INCOME TAX (CURRENT AND DEFERRED) ................................................................................................................................. 405 
10.  INVENTORIES........................................................................................................................................................................... 409 
11.  TRADE AND OTHER RECEIVABLES ............................................................................................................................................ 410 
12.  PREPAID EXPENSES .................................................................................................................................................................. 412 
13.  CASH AND CASH EQUIVALENTS ............................................................................................................................................... 412 
14.  SHARE CAPITAL ........................................................................................................................................................................ 412 
15.  RESERVES ................................................................................................................................................................................ 413 
16.  GOVERNMENT GRANTS ........................................................................................................................................................... 413 
17.  RESERVE FOR STAFF LEAVING INDEMNITIES ........................................................................................................................... 415 
18.  PROVISIONS ............................................................................................................................................................................ 416 
19.  LONG-TERM & SHORT TERM BORROWINGS............................................................................................................................ 417 
20.  SUPPLIERS ............................................................................................................................................................................... 418 
21.  DIVIDENDS .............................................................................................................................................................................. 418 
22.  ACCRUED AND OTHER CURRENT LIABILITIES ........................................................................................................................... 419 
23.  DEFERRED INCOME ................................................................................................................................................................. 420 
24.  SEGMENT INFORMATION ........................................................................................................................................................ 421 
25.  REVENUES ............................................................................................................................................................................... 423 
26.  ANALYSIS OF EXPENSES ........................................................................................................................................................... 425 
27.  OTHER OPERATING INCOME / EXPENSES ................................................................................................................................ 426 

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

28. FINANCIAL INCOME/EXPENSES ........................................................................................................................................... 426

29. DEPRECIATION AND AMORTISATION .................................................................................................................................. 427

30. PAYROLL AND EMPLOYEE RELATED COST ............................................................................................................................ 427

31. EARNINGS PER SHARE .......................................................................................................................................................... 427

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

33. RELATED PARTIES ................................................................................................................................................................. 430

34. FINANCIAL INSTRUMENTS ................................................................................................................................................... 432

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

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

STATEMENTS OF THE MEMBERS OF THE BOARD OF DIRECTORS

Statements of the Members of the Boards of Directors

The Board of Directors Members of the Company “Piraeus Port Authority Societé Anonyme” and trade

title “PPA S.A.” (hereinafter referred to as “Company” or as “PPA S.A.”) and the undersigned:

1. HAN CHAO, Chairman of the Board of Directors

2. SU XUDONG, Chief Executive Officer

3. LI JIN, Member of the Board of Directors

In our above-mentioned capacity and as specifically appointed by the Board of Directors of the Company,

we state and we assert that to the best of our knowledge:

(a) the financial statements of the societe anonyme Company under the name “Piraeus Port Authority

Societe Anonyme” and trade title “PPA S.A.” for the period from January 1, 2025 to December 31, 2025,

which were compiled according to the applicable International Financial Reporting Standards as adopted

by the E.U., provide a true and fair view of the assets and the liabilities, the equity and the results of the

period of the Company, according to that stated in paragraphs 3 to 5 of article 4 of the L.3556/2007 and

the relevant executive Decisions of the Board of Directors of the Capital Market Commission.

(b) the annual Report of the Board of Directors fairly represents the performance, results of operations

and financial position of the Company, as well as a description of the main risks and uncertainties it faces

and was drafted in accordance with the sustainability reporting standards referred to in article 154A of

Law 4548/2018 (A’ 104) and with the specifications approved pursuant to paragraph 4 of article 8 of

Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020, as referred to

in article 4, paragraph 2(c) of Law 3556/2007, which was amended by article 16 of Law 5164/2024.

Athens, March 31 , 2026

HAN CHAO

SU XUDONG

LI JIN

Chairman of the

Board of Directors

Chief Executive Officer

Member of the

Board of Directors

Passport No PE3327142

Passport No PE2263059

Passport No PE2316564

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

ANNUAL REPORT OF THE BOARD OF DIRECTORS

of the Company

“PIRAEUS PORT AUTHORITY S.Α.” with the distinctive title “PPA S.A.”

from 1st January 2025 until 31st December 2025

(In accordance with article 4 par. 2(c) of L. 3556/2007)

On the Financial Statements for the year

from 1 January 2025 to 31 December 2025

Economic performance, comments on Financial Statements

A.Economic performance

International Trade Conditions

The nature of Company's business activities depends on Greek and international trade, as well as on

external macroeconomic and geopolitical conditions. The immediate market of Piraeus port focuses on the

countries of the eastern Mediterranean and thus economic and geopolitical conditions have a key influence

on the volume served. It is further influenced by developments in the global port industry in general, as

well as by the developments of individual port activities, highly interconnected to both PPA's investment

plan and to the level of service provided to port users.

The economic environment in 2025 was highly influenced by the rising unilateral tariffs and geopolitical

tensions. Global tariffs rose in 2025, with manufacturing most affected. Governments are expected to

continue using tariffs in 2026 to pursue industrial and strategic objectives. Global rising tariffs had two

results.

The threat of a trade war between the United States and the EU led to a sharp rise in both imports and,

particularly, exports in Q1 2025. However, in Q2 2025, EU imports fell by 3.2%, while exports declined

more markedly by 6.7%. The downward trend continued in Q3 and Q4 2025, although at a slower pace,

with imports down 1.4% and exports down 0.8% in Q4 2025.This meant that both imports and exports

registered decreases for 3 consecutive quarters.

https://ec.europa.eu/eurostat/statistics-

explained/index.php?title=EU_international_trade_in_goods_-_latest_developments

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

In the middle of a turbulent economic environment created by rising trade tariffs and geopolitical

challenges, IMF expects global economy to grow at 3.3% in 2026 at par with 2025. World trade volume

growth is expected to decline from 4.1 percent in 2025 to 2.6 percent in 2026 and increase to 3.1 percent

in 2027

. The EU Commission expects World trade volume to decline from 2.8 percent in 2025 to 2.1 percent

in 2026 and increase to 2.7 percent in 2027.

Greek Economy

For the Greek economy, a growth rate is expected, exceeding the Eurozone average, at 2.1% in 2025 and

2.2% in 2026, according to the Commission’s autumn forecasts

. In January 2026, imports decreased by

7.4% and exports decreased by 11.9%. Excluding petroleum products and ships, the value of imports fell by

4.7% and exports by 3.6% compared to the corresponding month of 2025

. The EU estimates that in 2026

imports will increase by 3.7% and exports by 2.4%.

The geopolitical conditions in the east Mediterranean and middle east continue to affect Piraeus port

volumes. On one hand the closure of the Suez Canal instigated by the turbulence in Israel and subsequent

attacks by Houthis is seized. However, there is still no mass rerouting through Suez as shipping lines are still

testing the durability of the status quo

. As a result, volume build up at the Port of Piraeus, which is a key

transshipment hub, is expected to be gradual and can significantly benefit port volumes within 2026.

B. Comments on Financial Statements for the 2025

Revenues

The «Revenues” for the year 2025 amounted to € 250.8 million, where compared to the corresponding

year of 2024 increased by 8.6% or € 19.9 million (2024: € 230.1 million). The increase is mainly due to the

revenues’ increase of the container terminal sector, of the revenue from the concession of piers II & III as

well as from the the cruise sector by 17.0%, 10.8% and 24.8% or by € 8.5 million, € 8.8 million and € 7.5

million respectively.

The increase in revenue from loading/unloading is mainly due to the activities of the Container Terminal.

Throughput at the Container Terminal, Pier I, for the year 2025 reached 664,581 TEUs, recording an

increase of 17.9% compared to the corresponding year 2024 (563,725 TEUs).

In particular, a significant increase was recorded in domestic cargo (imports and exports) from 232,252

TEUs in 2024 to 254,591 TEUs in 2025 (+9.6%), as well as transshipment cargo by 23.7% from 331,473

TEUs in 2024 to 409,990 TEUs in 2025.

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

https://economy-finance.ec.europa.eu/document/download/34538512-fff6-451a-8bbc-

4c8d60e4d132_en?filename=ip327_en.pdf [accessed 20, February]

https://www.imf.org/en/publications/weo/issues/2026/01/19/world-economic-outlook-update-january-2026

[accessed 20, February]

https://www.statistics.gr/el/statistics/-/publication/SFC02/- [accessed 20, March]

https://www.reuters.com/world/middle-east/what-are-shipping-companies-plans-return-suez-canal-2025-12-19/

[accessed January 2026]

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The total number of passengers recorded an increase of 9.68% (1,863,397 passengers) compared to 2024

(1,698,877 passengers). Specifically, compared to 2024, there was an 8.2% increase (1,091,364 passengers

compared to 1,008,209 passengers) in homeport passengers and an 11.8% increase (772,033 passengers

compared to 690,668 passengers) in transit passengers.

The significant increase in revenue from the Pier II + III concession agreement is mainly due to the increase

in the variable consideration, which amounted to € 74,215,831.56 (31.12.2024: € 66,009,391.37). The

concession consideration is calculated and recognized in income for the period in accordance with the

terms of the contract and considered as lease contract based on IFRS 16.

This increase was offset by a decrease in revenue of the ferry sector by 28.4% or by € 3.6 million (Note

24 &25).

The decrease in revenue from ferry shipping is mainly because, from May 1, 2025, and for a period of one

(1) year, the Company proceeded to reduce the fees for ships and passengers of Ferry Shipping by 50% in

accordance with the relevant amendment of the Ministry of Shipping & Island Policy. The amendment has

a significant impact on the revenue of the activity for the period of application of the current year, i.e.

reduction by an amount of € 3.4 million compared to the corresponding period last year, as well as a

decrease of € 1.1 million resulting from the mooring of coastal shipping and included in the "Mooring"

item.

Cost and Expenses

" Payroll and employee related costs" constitute the most important category of the Company's operating

expenses, which during 2025 showed a significant increase and amounted to € 79.7 million compared to

€ 71.1 million in 2024 (Note 26). The significant increase in Payroll and employee related costs in the

current year compared to the corresponding last year is mainly due to the additional staggered increase

of payroll of employees and dock workers according to the Collective Bargaining Agreements in force from

1/8/2024 and 1/7/2024 respectively, the implementation from 1/4/2025 of the new Collective Bargaining

Agreement for Supervisors & Foremen, the increased employment (hourly wages) of dock workers to

serve the organic growth that occurs in most of the Company's activity sectors during year 2025, as well

as the increase in personnel during the current year compared to the previous year. Also, the Company's

Management, both in the current and the previous year, decided to grant voluntary retirement incentives

to those employees who had established the right to retirement and had reached the age of 60 on

December 31, 2025 and 2024 respectively. The total charge for the current year amounted to € 0.9 million

compared to € 0.7 million in the previous year.

In regard to the remaining operating costs, except for payroll costs, they remained consistent to the prior

year figures except for the following:

• A significant increase was recorded in “Various expenses” by € 3.7 million or 44.7%, which is mainly

due to the increase in cleaning port services expenses by the amount of € 2.0 million or 102.1%, and

in port guard fee by the amount of € 1.0 million or 32.3% (Note 26).

• An increase was recorded in “Third Party Fees and Expenses” by € 1.2 million or 23.4%, which is mainly

due to the increased use of external partners for loading and unloading services by approximately €

1.8 million compared to the previous year, which was partially offset by the decrease in consultants'

fees and expenses by the amount of € 0.4 million (Note 26).

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

• An increase was noted by € 0.9 million in legal cases due to to provisions for legal cases that arose

during the current year (Notes 18 & 26).

• The "Greek State Concession" fee presented an increase during the year 2025, by € 0.7 million or by

14.1% which is mainly due to the increase in revenues of the current year compared to the

corresponding year of 2024 (Note 22 & 26).

• Decrease was noted in inventories consumption by € 0.3 million or by 11.1%, which amounted during

the current year to € 2.4 million while in the corresponding last year it amounted to € 2.7 million (Notes

10 & 26).

Other Income/Expenses

• Other operating income for the current year showed a decrease compared to the previous year

amounting to € 0.5 million or by 7.0% amounting to € 6.4 million (31.12.2024: € 6.9 million) (Note 27).

• Other operating expenses for the current year amounted to € 1.7 million compared to the

corresponding year of 2024 (€ 0.6 million) presented an increase amounting to € 1.1 million. This increase

is due to the increase in compensation to suppliers arising from the execution of their contracts by the

Company (Note 27).

Net impairment losses on financial assets

The net impairment loss on financial assets for the current year amounted to € 0.8 million while a prior

years’ provision of € 0.6 million was used (31.12.2024: € 0.4 million) (Note 11).

Financial Expenses

In financial expenses during the current year an increase was noted by € 0.3 million or by 10.7%

(31.12.2025: € 2.9 million instead of € 2.6 million in 31.12.2024) (Note 28).

Financial Income

In financial income during the current year a significant decrease was noted amounted to € 3.1 million or

by 59.8% (31.12.2025: € 2.1 million instead of € 5.2 thousand in 31.12.2024) which is due to the decrease

to the amount of the time deposits concluded, as well as the relevant interest rates (Note 28).

Total Assets

Total assets at December 31, 2025 amounted to € 689.8 million, increased by 4.1% or € 27.0 million

(31.12.2024: € 662.8 million).

The increase in total assets was mainly due to the following sub-items, namely:

• increase of the unamortized balance of tangible property, plant and equipment by € 93.5 million or by

26.1% due to the additions € 110.9 million of the year reduced by € 17.3 million current year

depreciation and net value of write-offs-sales/transfers to intangible assets by € 0.1 million

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

These increases were mainly offset by:

• decrease in cash and cash equivalents by € 54.7 million or by 26.8% mainly due to the early repayment

of the Company's loan obligations, the high dividend yield of the previous year, as well as the significant

tangible investments of the current year (Note 13).

• decrease in “Trade and other receivables” by € 10.0 million or 47.2% mainly due to the decrease in the

net balance of customers by € 2.7 million, the decrease in other receivables for the collection of grants

by the amount of € 7.0 million, as well as the decrease in interest receivable by the amount of € 1.6

million (Note 11). The above decreases were mainly offset by the increase in advances to suppliers-

creditors by the amount of € 0.8 million.

• decrease in “Right of use assets” by € 1.9 million or by 3.6% due to the current’ s year depreciation

(Note 5).

Total Liabilities

Total liabilities as at 31.12.2025 amounted to € 242.6 million decreased by € 11.2 million or by 4.4%

(31.12.2024: € 253.7 million).

The fluctuation in total liabilities was mainly due to the following:

• decrease in bank debt by € 26.5 million due to the due to early repayment of the Company's two bank

loans (Note 19).

• decrease of tax income payable by the amount of € 2.4 million or by 17.3%,

• decrease in short-term and long-term lease liabilities by € 1.3 million or by 2.0%, due to the current

year payments of € 3.7 million, finance cost € 2.2 million and additions of € 0.2 million (Note 5).

The above decreases were mainly offset by the following increases:

• increase in “Accrued and other short-term liabilities” by 9.9 million or 36.1% mainly due to the increase

in accrued liabilities by 9.5 million during the current year.

• increase in liabilities to "Suppliers" by the amount of € 8.3 million or 29.75%.

• Increase in the provision for personnel compensation by the amount of € 0.5 million or by 3.7% (Note

17)

• increase in grants by € 1.2 million or 3.0%, due to the approval of an additional grant of € 2.0, less to

depreciation for the year (Note 16).

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Financial and Non-Financial Performance Indicators

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

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

Total Debt / Equity

It is calculated as the ratio of the sum of Debt Liabilities (Short-Term and Long-Term Loans) plus the total

of Lease Liabilities at the end of the year to the Total Equity at the end of the year.

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

It is calculated as the ratio of Earnings before taxes, interest and depreciation (EBITDA) to its Revenues.The

Company uses as Alternative Performance Measures (“APMs”) the ratios No 4, 5 and 9, in the context of

making decisions concerning its financial, operational and strategic planning, as well as assessing and

publishing its performance. These APMs help better understand the Company’s financial and operating

results, financial position and cash flow statement. Alternative performance measures (APMs) must

always be taken into account in combination with the financial results prepared in accordance with

International Financial Reporting Standards (“IFRS”) and will not replace the latter under any

circumstances.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

B.Financial and Non-Financial Performance Indicators

Presentation of a mixture of financial indicators took place in the previous modules with a distinct

reference to traffic data of each Company's business sector (Cruise, Coastal Shipping, Car Terminal,

Container Terminal, and Ship Repair).

In addition, PPA S.A. recognizing that the international ESG indicators (in the already published Corporate

Responsibility and Sustainable Development Report 2020, there is a special reference to ESG issues

entitled "ESG Data Scorecard") are a strategic tool for investor support in the context of identifying risks

and opportunities associated with the viability of their investment portfolio and responding at the same

time to the challenges of the new environment, builds a sustainable development strategy, aiming to

minimize the negative impact that its activities may have.

The Company's long-term commitment to Sustainable Development has already led to its participation

(August 2020) in the new ATHEX ESG index of the Athens Stock Exchange.

As demonstrated in the Corporate Governance Statement, PPA S.A. attaches great importance to

Sustainable Development and taking into account both the new legislation on Corporate Governance and

the principles of Taxonomy (EU Taxonomy).

C. Commentary on the Company’s significant intangible assets

According to article 150 of Law 4548/2018, large enterprises are required to disclose information

regarding the key intangible assets that directly affect their business model, strategic direction and value

creation process. Intangible assets are a critical factor in sustainable development, as they are not fully

reflected in the financial statements, but they decisively affect the competitiveness and long-term

performance of a company.

The Company relies heavily on its intangible assets to create added value, differentiate the services

provided and maintain a strong position in the competitive international port environment. In the case of

the Port of Piraeus, intangible assets do not simply function as complementary assets, but are

fundamental pillars of its operation, contributing decisively to ensuring its financial performance, business

continuity and long-term sustainability.

In the port of Piraeus, intangible resources contribute substantially to value creation and include a set of

elements that enhance the operational efficiency, reputation, innovation and strategic advantage of the

Company. These resources are categorized as follows:

1. Human Capital

Human capital is one of the most important intangible resources of the Company, as the skills, experience

and know-how of the staff directly affect the quality of the services provided and the operational

efficiency.

• Specialization and experience of staff: The Company's employees have a high level of know-how and

long-term experience in providing a wide range of port services, such as the handling of containers,

vehicles and passengers (cruise and coastal shipping), the supply chain and ship repair. This accumulated

knowledge is a critical factor in ensuring the reliability and efficiency of port operations.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

• Corporate culture and organizational knowledge: The corporate culture, characterized by cooperation,

responsibility and goal-orientedness, strengthens the cohesion of work teams and contributes to the

optimization of internal processes.

• Education and continuous training: The Company systematically invests in the continuous education

and development of human resources, with the aim of upgrading skills, adapting to technological

developments and improving productivity and safety of operations.

2. Corporate Reputation and Partnership Network

The strong corporate reputation and the extensive partnership network constitute strategic intangible

resources that strengthen the position of the port on the international map.

• International recognition: The port of Piraeus has established itself as the leading multi-purpose port in

the Mediterranean and is among the five largest ports in Europe in terms of container traffic. At the same

time, in terms of passenger traffic – including the Perama-Salamina ferry connection – it is the largest port

in Europe and one of the most important in the world.

• Customer and port user relations: Long-term partnerships with leading international shipping

companies and the port’s operation as a key transshipment hub for the southeastern Mediterranean

enhance the Company’s credibility and create added value for itself as well as for the local community

and the national economy.

• Contracts and concessions: Strategic agreements and long-term concession contracts ensure revenue

predictability, enhancing financial stability and the ability to implement long-term investments.

3. Technology and Information Systems

Technology is a critical intangible resource for improving the efficiency and quality of the services provided.

• Digital platforms and automated systems: The adoption of modern digital solutions and automated

information systems contributes to the optimization of cargo handling, storage and delivery processes,

reducing operational costs and service time.

4. Regulatory Advantages

• Exploitation rights and institutional framework: The Company holds strategic exploitation rights to port

infrastructure, which ensure stable cash flows and enhance its long-term viability, while creating

significant entry barriers for potential competitors.

5. Strategic Location and Competitive Advantage

• Geographical position: The strategic geographical position of the port of Piraeus makes it the main

gateway for Asian products to the European market, strengthening its role in international trade and

global supply chains.

• Interconnection with other means of transport: The effective connection of the port with the railway

network, the road system and the international airport strengthens the position.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Conclusion

The intangible assets of the Port of Piraeus play a decisive role in the operation, competitiveness and value

creation of the Company. The exploitation of human capital, technology, corporate reputation, strategic

partnerships and regulatory advantages allows the development of a strong and sustainable business model.

Value creation is achieved through the combined exploitation of intangible resources, with an emphasis on

technological investments, continuous optimization of processes and the development of human resources.

Through these mechanisms, the Port of Piraeus strengthens its competitiveness, efficiency and

attractiveness, consolidating its position as a leading global shipping and transit hub.

OWN SHARES

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

BRANCHES

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

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Related Parties

The Company has transactions (provides and receives services) in the normal course of its business with

certain companies controlled by its main Shareholders and considered related parties.

The Company’s transactions and account balances with related companies, as these are defined in IAS

24 ,are as follows:

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The revenues of € 90,511,252.16 (2024: € 81,706,669.33) (Note 25) from Piraeus Container Terminal S.A. are

related to the fixed and variable revenue from the concession agreement (PIER II & III) and revenues of €

1,852,057.64 (2024: € 805,208.86 ) related mainly loading/unloading and mooring. The Company recharged

energy costs to the related party under the concession agreement until January 14, 2025, amounted to €

376.064,88 (2024: € 9.169.250,06). After that date, the related party acquired its own electrical substation,

and the re-billing process was therefore concluded.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The transactions with COSCO SHIPPING LINES GREECE S.A. of the previous year mainly related to the supply

of ship services (from loading/unloading and berthing), as well as the provision of car transportation services

from China. In the current year, transactions mainly related to loading/unloading, berthing and storage

services.

The transaction with COSCO SHIPPING TECHNOLOGY Co. LTD relates to software support costs.

The transactions with COSCO SHIPPING GLOBAL EXH relate to exhibition expenses.

The transaction with COSCO SHIPPING TECHNOLOGY (Beijing) relates to software update .

The transaction with COSCO (HONG KONG) INSURANCE BROKERS L.T.D. of the current and the previous period

relates to the insurance coverage of PPA S.A. regarding third party liability, employer' s liability, property and

business interruption and directors and officers liability, according to article 17 of the Concession Agreement

(Law 4404/2016).

Board of Directors Members Remuneration: During the year ended December 31, 2025, were paid to the

Board of Directors members. remuneration and attendance costs, amounted to € 1,185,793.99 (31.12.2024: €

1,395,877.64 ) Furthermore during the year ended December 31, 2025 emoluments of € 1,174,245.45

(31.12.2024: € 846,326.35 ) were paid to Managers / Directors for services rendered.

Principal Risks Analysis and Risk Management

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

There are no suppliers, the interruption of which would jeopardize the operation of the Company in the event

of a temporary failure of supplies provision.

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

B1. Maximum Probable Loss (MPL) analysis

According to the requirements of Art. 17 and Annex 17.1 of the CA, the company has carried out the Maximum

Probable Loss (MPL) study

in collaboration with a specialized consulting firm in the field of risk insurance.

The MPL analysis includes the following elements:

1. Estimation of Maximum Probable Property Loss and loss of income for normal risks, excluding natural

disasters (such as earthquakes, tsunamis, etc.).

2. Estimation of Maximum Probable Property Damage and Loss of Revenues concerning natural disasters,

and in particular in the event of an earthquake.

3. Risk Quantification analyzing and quantifying the probable scenarios of liability losses, including

environmental liability, under the worst-case scenario.

The Maximum Probable Loss (MPL) is defined as the maximum estimated loss resulting from a single event or risk

assessed with due diligence, considering all the distinct elements of the Port of Piraeus and its environment

Page 18 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The conclusions and recommendations of MPL have already been incorporated into PPA’s Property Damage

and Business Interruption Loss of Profit insurance policy.

B2. Risk of property loss

The Company takes all necessary measures to minimize the risk and possible losses of assets due to natural

disasters or other causes.

Property Damage and Business Interruption Loss of Profit

The Company has insured all its assets in accordance with the provisions of Article 17.1 of the CA with the

Greek State for the following indicative but not limited to perils:

• Fire, lightning, explosion, storm damage, aircraft crashes and named perils or Property All Risks, based

on new replacement cost of asset.

• The income loss due to disaster-related closing / business interruption of the business facility or due to

the rebuilding process after a disaster, i.e. storm, earthquake, flood, strikes, riots and terrorist actions,

has been insured.

B3. Hull and Machinery Insurance

The Hull and Machinery (H&M) insurance policy provides comprehensive asset protection tailored for PPA’s

three floating docks Piraeus I, II & III against physical damage and maritime perils.

B4. Third Party Liability

The Company maintains insurance in respect of third-party liability in accordance with the provisions of

Article 17.1 of the CA with the Greek State for all its activities.

Business Risks Associated with the Company's business activities

A detailed report on the main risks associated with the sector in which the Company operates is set out in

Chapter of the Sustainability Report, which follows (Risk Policy and Risk Management / Major Business Risks

and Uncertainties).

Financial Instruments

Fair Value The carrying amounts reflected in the accompanying sheets of financial position for cash and

cash equivalents, trade and other receivables, suppliers and accrued and other current liabilities

approximate their respective fair values due to the relatively short-term maturity of these financial

instruments.

The fair value of variable rate loans and borrowings approximate the amounts appearing in the statements

of financial position.

Page 19 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Company categorized its financial instruments carried at fair value in three categories, defined as

follows:

Level 1: Quoted (unadjusted) values from active financial markets for identical negotiable assets or

liabilities.

Level 2: Other techniques for which all inflows that have a significant impact on the recorded fair value are

identified or determined directly or indirectly from active financial markets.

Level 3: Techniques that use inflows that have a significant impact on the recorded fair value and are not

based on quoted prices from active financial markets.

During the year ended December 31, 2025 , there were no transfers between Level 1 and Level 2 fair value

measurements, and no transfers into and out of Level 3 fair value measurements.

Financial risk management:

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

Credit Risk: The Company's Management estimates that its exposure to credit risk is limited towards the

contracting parties, - as a matter of policy - it receives advances payments or letters of guarantee for most

of its provided services . From the above applied policy are excluded customers who belong to the same

group of companies, as mentioned in note 32 "Related Party Transactions". In addition, the transactional

activity between the Company and its related party company, Piraeus Container Terminal SA, which is the

Company's largest customer in terms of volume, is mainly covered by the terms of the concession

agreement between them, which is under the supervision of the Greek State. It should be noted that

despite the very significant amount and range of related parties transactions, no credit event has occurred

until now that could raise a credit risk.

In addition, the Company's cash at banks and time deposits are placed in bank financial institutions in

Greece and generally in European Union, with the following ratings (Moody's credit rating):

Foreign Exchange Risk: The Company is neither involved in international trade nor has any long-term loans

in foreign currency and therefore is not exposed to foreign exchange risk resulting from foreign currency

rate variations.

Interest rate risk: The Company's bank lending concerns two loans in Euro and is subject to one fixed rate

and the other to a variable interest rate (Note 19). The Company, during the year does not use bank

borrowing and therefore there is no interest rate risk.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Additionally, in the context of managing its assets as effectively as possible, as well as limiting any possible

impact of increased borrowing interest rates on its results, the Company's Management, taking advantage

of its strong liquidity, implements short-term reinvestments of these, expoiting the increased interest rates

on term deposits.

The table below presents and analyses the sensitivity of the result in relation to financial assets (cash on

hand and in banks) and financial liabilities (loans) of the Company to the interest rate risk changes assuming

a simultaneous change in interest rates by ± 100 basis points on the Company’s profit.

Liquidity risk: The effective management of liquidity risk is ensured by maintaining sufficient cash and the

availability of financing in case of need. Corporate liquidity risk management is based on the proper

management of working capital and cash flows.

The following table summarizes the maturity dates of the financial liabilities of 31 December 2025 and 2024

respectively, arising from the relevant contracts at unpaid prices.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Τhe above table includes the interest on long-term loans, which were calculated until maturity according

to the European Investment Bank quarterly information note for the 1st quarter of 2025.

*Trade payables do not have interest and are settled in up to 60 days. Other payables also do not bear

any interest and are settled in up to 12 months.

Capital Management

The primary objective of the Company's capital management is to ensure the maintenance of high credit

rating, and healthy capital ratios in order to support and expand the Company's operations and maximize

shareholder value. The Company's policy is to maintain leverage targets, according to an investment grade

profile. The Company monitors capital adequacy using the ratio of total debt to operating profits. The

debt includes interest-bearing loans and lease liabilities, while the operating profit includes profit/(loss)

before taxes, financing costs and depreciation.

Amounts of fiscal year 2025

Current

portion

Less than

6 months

6-12 months 2 to 5 years >5 years Total

Borrowings - - - - - -

Lease liabilities 4.368,74 3.514.703,69 11.076,00 14.000.000,00 77.437.500,00 94.967.648,43

Trade and other payables* 23.710.719,51 26.084.597,02 12.857.973,91 - - 62.653.290,44

Total 23.715.088,25 29.599.300,71 12.869.049,91 14.000.000,00 77.437.500,00 157.620.938,87

Amounts of fiscal year 2024

Current

portion

Less than

6 months

6-12 months 2 to 5 years >5 years Total

Borrowings - 3.443.636,38 3.389.257,92 21.828.157,50 - 28.661.051,80

Lease liabilities 8.718,00 3.543.657,00 19.148,00 14.000.000,00 80.937.500,00 98.509.023,00

Trade and other payables* 16.438.265,11 18.187.960,56 10.029.851,49 - - 44.656.077,16

Total 16.446.983,11 25.175.253,94 13.438.257,41 35.828.157,50 80.937.500,00 171.826.151,96

Page 22 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

SUBSEQUENT EVENTS

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

First Investment Period Duration

In accordance with the provisions of article 7.2 and Annex 7.2a of the Concession Agreement between PPA

SA and the Hellenic Republic (the contracting parties), ratified by law 4404/2016, as amended (law

4838/2021), the identification and quantification of one or more Suspension Events, by the Independent

Engineer, during the execution of the Mandatory Investment projects, results in a corresponding extension

of the First Investment Period. The identification and quantification of the Suspension Events falls under

the competence of the Independent Engineer and is recorded in the Reports that they submit to the

contracting parties. In this case, the Independent Engineer has identified, quantified and recorded in his

Reports, to date, Suspension Events of a total duration of 1177 days. Consequently, the First Investment

Period, which was to expire on August 9, 2026, has been extended by the corresponding period, i.e. by 1177

days, with a new expiration date (as of this day and subject to any occurrence of new Suspension Events in

the future) on October 29, 2029. The above is established and recorded in the most recent 35

Quarterly

Report of the Independent Engineer referenced to the last quarter of 2025, which has been duly notified

by the Independent Engineer to both parties (PPA SA and the Greek State) on January 28, 2026.

Evolutions in the Middle East

Following the reporting date, and specifically during February 2026 ,an armed conflict broke out in Iran,

forming part of the broader context of geopolitical instability in the Middle East. This development does

not constitute an adjusting event in accordance with IAS 10 “Events after the Reporting Period”, as the

relevant conditions did not exist at the reporting date.

The Company’s Management closely monitors and continuously assesses the impact of the volatile situation

in the Middle East on the macroeconomic and financial environment , such as potential energy instability

and increase in energy costs, inflationary pressures, and severe disruptions in international shipping and

global trade, in order to ensure that all necessary actions and measures are taken to minimize any potential

effects on the Company’s operations.

As part of the Company’s operations, cargo containers are transported either from or to ports in the

countries involved or neighboring regions. These shipments for the 2025 fiscal year were not significant in

relation to the Company’s overall operations.

At the same time, in the context of developments in international shipping and trade flows in the wider

region, certain changes and diversions in routes and cargoes towards to Piraeus have been observed so far.

The nature of these changes is currently assessed as temporary, as the situation is evolving dynamically and

is constantly being reassessed in light of geopolitical developments, both by the Company and by shipping

providers.

As of the date of approval of the financial statements, it is not possible to estimate any potential

quantitative impact of this development on the Company’s results and financial position.

Other than the above, there are no other significant events after December 31, 2025, that may have a

material impact on the company's financial position.

Page 23 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

GOING CONCERN DISCLOSURE

The Company, for the preparation of the Financial Information of December 31, 2025, has adopted the

going concern basis. For the application of this principle, the Company took into account the current

financial developments as well as the risks arising from the financial environment and made estimates for

the shaping, in the near future, of the trends and the economic environment in which it operates. The main

factors that can affect the implementation of this principle are mainly related to the economic environment

in Greece and internationally as well as the ongoing Russia/Ukraine, unstable environment in the Middle

East region), with the resulting issues in the energy sector, rising inflation and the free navigation of

commercial ships.

As part of the consideration of whether to adopt the going concern basis in preparing the financial

statements, management has considered the Company’s financial performance in the year, as well as a

quantitative viability exercise, including the performance of various stress tests that consider the

Company’s principal risks, including that relating to climate change, and confirms the Company’s ability to

generate cash in 12 months from the date of approval of the financial statements and beyond. The

Company’s strong balance sheet and liquidity position, its operation in several segments, the strong and

dynamic management and the experienced human resources will allow the Company to successfully

overcome any period of uncertainty.Therefore, it is deemed appropriate that the Company continues to

adopt the going concern basis for the preparation of the financial statements.

Accordingly, and having reassessed the principal risks, the Directors continue to adopt the going concern

basis of accounting in preparing the Annual Financial Statements and have not identified any material

uncertainties to the Company's ability to continue trading as a going concern over a period of at least 12

months from the date of approval of annual financial statements.

Piraeus, March 31, 2026

THE CHAIRMAN OF BoD

HAN CHAO

Page 24 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

STATEMENT OF CORPORATE GOVERNANCE

(Article 152 of L. 4548/2018)

Introduction

Corporate Governance is the framework of structures, principles, rules, procedures and practices, through

which the continuous improvement of the efficient operation of the Company, the enhancement of the

long-term economic value and the protection of its general corporate interest.

The implementation and adherence of the optimum corporate governance practices is a priority for the

Company due to the important role it plays both as a gateway for import and export trade, and as a gateway

to serve the country's tourism industry, for the benefit of the local and national economy in general.

The Company, in compliance with Law 4706/2020, harmonized all the provisions of its Articles of

Association and adopted a series of Policies and Regulations, which ensure transparent and effective

governance, and instituted the necessary organizational structures for their adoption and implementation.

The Company continues to update existing and draft new Policies and Regulations, due to the constantly

changing environment in which it operates and the need to continuously adapt both the organizational

structure and the organizational and management practices it adopts and applies, taking into account in

particular the provisions to the Greek Corporate Governance Code of the Hellenic Corporate Governance

Council, which the Company has adopted and applies and the relevant decisions of the Capital Market

Commission.

The Company, taking into account international trends, in terms of Corporate Governance is moving in the

direction of adopting Environmental and Social Governance (ESG: Environmental, Social, Governance)

practices, recognizing that the creation of value for its stakeholders (shareholders, employees, investors,

suppliers, users of the port, local community) is not achieved solely through the achievement of strong

financial performance but mainly through proper Governance, and the impact of its activity on Society and

the Environment.

Structure of the Corporate Governance Statement

The current Statement of Corporate Governance is prepared pursuant to the provisions of article 152 of

Law 4548/2018, article 18 of Law 4706/2020, as in force, the provisions of the Hellenic Corporate

Governance Code of the Hellenic Corporate Governance Council (HCGC), which was issued in June 2021 and

has been adopted and is implemented by the Company, following the relevant approval of its BoD, and in

conformance with article 17 of Law 4706/2020, as well as relevant explanatory circulars and letters of the

Capital Market Commission, and in particular, the Letter of the Capital Market Commission with no. prot.

434/24.02.2025 to companies with securities listed on the Athens Stock Exchange

This Statement of Corporate Governance is a special part of the Annual Management Report of the Board

of Directors and contains all the information required by law. In addition, it includes the Company’s

response to specific practices under the Chapters of the Hellenic Corporate Governance Code of the HCGC,

which has been adopted and is implemented.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

In particular, the structure of this Statement of Corporate Governance is as follows:

I. Statement of Compliance with the Corporate Governance Code

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

III. Description of the main features of the Company’s internal control and risk management systems

in relation to the financial reporting process

IV. Reference to the information required for cases c`, d`, e`, f` and h` of par 7 of article 4 of Law

3556/2007 (Α` 91)

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

- General Assembly of Shareholders

- Board of Directors

- Audit Committee

- Nomination Committee

- Remuneration Committee

- Strategy Committee

VI. Periodic Evaluation Policy of the Internal Control System of PPA SA and Implementation of the

provisions on Corporate Governance of Law 4706/2020

VII. Periodic Evaluation Policy of the Corporate Governance System

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

bodies

Ι. Code of Corporate Governance

Law 4706/2020 (Government Gazette 136 / Α / 17-7-2020), on Corporate Governance of public limited

companies, modern capital market, which incorporated in Greek legislation the Directive (EU) 2017/828 of

the European Parliament and Council, measures to implement Regulation (EU) 2017/1131 and other

provisions, as well as Decision 2/905 / 3.3.2021 of the Board of Directors of the Hellenic Capital Market

Commission establish the obligation to adopt and implement the Corporate Governance Code, which has

been prepared by a body of known prestige.

The Company, in compliance with the requirements and regulations of the said law, implements with a

relevant decision of its BoD the Code of Corporate Governance, of the Hellenic Corporate Governance

Council issued in June 2021, the text of which is available at website of the Company at the following

link: https://www.esed.org.gr/en/code-listed.

The implementation of this Code aims at the continuous improvement of the corporate institutional

framework and the wider business environment, as well as the improvement of the Company's

competitiveness as a whole.

Page 26 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

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

The Company fully complies with the provisions of the relevant Greek legislation, rules and regulations

and internal corporate values for the development of corporate governance principles it applies and has

adapted to those defined by the existing institutional framework of corporate governance. As mentioned

above, following a Board of Directors (BoD) decision and in accordance with article 17 of law 4706/2020,

it implements and adopts the Hellenic Corporate Governance Code (HCGC, June 2021) of the Hellenic

Corporate Governance Council (HCGC).

The Company has not adopted some specific practices of the Code that are specifically mentioned below

but remains faithful to its commitment to take all the necessary actions for the implementation of the

provisions of Law 4706/2020:

Deviation from the Special practice of Code 2.2.15: “The company ensures that the diversity criteria

concern, in addition to the members of the BoD, senior and/or senior management with specific

representation objectives by gender, as well as timetables for achieving them”.

Explanation: Due to the particular nature of the port industry area in which the Company operates and

given that the overwhelming percentage of its staff is employed in labor-intensive activities (dockworkers,

operators of lifting machines, drivers of heavy-duty vehicles, workshop staff, etc.), it is not possible to

define and ensure specific goals of representation by gender, (beyond the BoD members in accordance

with the provisions of Law 4706) among the Managerial staff. Apart from the BoD members selection

where the Company applies the diversity criteria provided for in the BoD Suitability Policy, no specific

gender representation goals and specific timetables for their achievement have been set for the selection

of the Company's Managerial staff. However, the Company's Code of Conduct, which is uploaded on the

Company's website, states (Chapter of Equal Opportunities) that the Company promotes a work

environment that respects equality, individual rights and diversity no matter on characteristics such as

age, gender, race, nationality and physical ability. On 31.12.2025, the participation of women in all of the

Company's managerial positions amounted to 36.5%.

Deviation from the Special practices of Code: 2.2.21: “The Chair shall be elected by the independent non-

executive members. In the event that the Chair is elected by the non-executive members, one of the

independent non-executive members shall be appointed, either as vice-chair or as a senior independent

member (Senior Independent Director)”. 2.2.22: “The independent non-executive Vice-Chair or Senior

Independent Director shall, as appropriate, have the following responsibilities: to support the Chair, to

act as a liaison between the Chair and the members of the BoD, to coordinate the independent non-

executive members and lead the evaluation of the Chair”. 2.2.23: “Where the Chair is an executive, then

the independent non-executive vice-chair or the senior independent member (Senior Independent

Director) shall not replace the Chair in his executive duties.”.

Explanation: The Company's BoD, when constituted as a Body, applies the provisions of article 8 of Law

4706/2020 "In the event that the BoD appoints one of the executive members as Chairman, it must

appoint a Vice-Chairman from among the non-executive members". In addition, 67% of the members of

the Company's existing BoD are Non-Executive members, while the Chairmen and the majority of the

members of the Article 10 Committees (Audit, Remuneration, Nomination) are Independent Non-

Executive members.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Taking into account the above, the Company's BoD considers that the non-appointment of one of its

members as Senior Independent Director does not create any problem in its orderly operation and the

fulfillment of its duties, as well as that the burden of the independent non-executive members with the

additional burden of the object of the Vice Chairman of the BoD was not desirable, while it might cause

obstacles in the work of the above Committees. With the above specific balance, its efficient and

productive operation has been ensured during all the last years.

Deviation from the Special practices of Code: 2.3.1: “The company has a framework for filling positions

and succession of the members of the BoD, in order to identify the needs for filling positions or

replacements and to ensure each time the smooth continuation of the management and the achievement

of the company's purpose”. 2.3.2: “The company ensures the smooth succession of the members of the

BoD with their gradual replacement in order to avoid the lack of management.”. 2.3.3: “The succession

framework shall in particular take into account the findings of the evaluation of the BoD in order to

achieve the necessary changes in composition or skills and to maximise the effectiveness and collective

suitability of the BoD.”.

Explanation: Regarding to the succession of the BoD members, given that the term of office of the BoD

members launched in July 2025, it was not considered appropriate within 2025 to have a procedure for

the activiation of the Nominations Committee. In the event of the need to replace one or more members

of the BoD, the Nominations Committee is activated to find suitable candidates for new members in

accordance with the Company's Nominations Policy in order to carry out the replacement of members,

the procedure defined in the Committee's Operation Regulation and the BoD Operation Regulation.

Deviation from the Special practice of Code 2.3.4: “The company also has a succession plan for the

Chief Executive. The preparation of an integrated succession plan for the Chief Executive shall be

entrusted to the nomination committee, which in this case shall be responsible for: (a) identifying the

required quality characteristics that the Chief Executive should have, (b) ongoing monitoring and

identification of potential internal nominees, (c) where appropriate, search for potential external

nominees, (d) and a dialogue with the Chief Executive on the evaluation of nominees for his / her

position and other senior management positions. ”.

Explanation: The company has not formulated a special succession plan for the CEO, as the CEO is

replaced (by BoD decision), in case of absence or impediment, by the Chief Financial Officer who is also

an executive BoD member. In addition, the CEO has six (6) Deputies CEO, thus ensuring the smooth

continuity of the management of the Company's affairs and its daily corporate operation.

Deviation from the Special practice of Code 2.3.7: “The Board of Directors shall set up a nomination

committee, which shall play a leading role in the nomination process, in the design of the succession

plan and for the members of the Board of Directors and senior management.”

Explanation: The approval of the recruitment process of a senior management member and the

evaluation of his/her performance in the context of the implementation of the Corporate Governance

Law is of crucial importance for the successful achievement of the Company's objectives, as these

executives make the key decisions that lead to its development. In the event of the quit of a senior

management member of the Company or the creation of a need for a new position, the major

Shareholder proposes the appropriate candidate for it, and after a review of his/her qualifications by

the Nomination Committee, a proposal is submitted for approval by the BoD to fill the specific position.

Page 28 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

ΙIΙ. Description of the main features of the Company’s internal control and risk management

systems in relation to the financial reporting process

a) Company level controls

• The ICS of the Company covers adequately the control procedures involving risk management and

preparation of financial reports.

• In respect of the preparation of financial statements, the Company considers its accounting system

adequate for reporting to the Management and external users. The financial statements are

prepared in compliance with the International Financial Reporting Standards, as adopted by the

European Union for reporting purposes to the administration, and also for the purpose of

publication in line with the applicable regulations (hereinafter, “IFRS”). All reports include the data

of the current period, compared to the respective data of the Budget as approved by the BoD, and

to the data of the respective period of the year before the report. All published interim and annual

financial statements include all necessary information and disclosures in compliance with the IFRS,

are reviewed by the Audit Committee and are approved in their entirety by the BoD.

• Safeguards are implemented with respect to: a) supervision and approval of all important

transactions through the structural hierarchy of the Company; b) monitoring of financial figures and

risk evaluation as for the reliability of the financial statements; c) fraud prevention and tracking;

and d) protection of data provided by information systems.

• The Company’s progress is monitored through a detailed budget per operating sector. The budget

is adjusted when is necessary to take into account the changes in the development of the

Company’s financials that depend greatly on external factors. Management monitors the

development of the Company’s financial results through regular notes and reports.

• The Company's Operating Regulations, in which, among other things, the responsibilities and

responsibilities of the basic jobs are defined, aim at the adequate separation of responsibilities

within the Company. The approved Operating Regulations have been posted on the Company's

website in accordance with par. 2 of article 14 of Law 4706/2020.

• The internal reports to the Management and the reports required from the provisions of the

legislation and by the supervisory authorities are prepared by the Financial Management

Department, which is staffed with adequate and experienced executives to this effect.

b) Information systems’ controls

Given that the financial reporting processes are highly dependent on information systems, the Company

has undertaken a series of actions aimed at enhancing the operating effectiveness of controls in order

to ensure the completeness and accuracy of the financial records.

Specifically, the IT & BPS Department is responsible for defining and implementing the strategy. Their

responsibilities include the development, operation, and support of information systems, as well as the

implementation and monitoring of appropriate information security safeguards.

Page 29 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Information Systems Security

The Company implements a comprehensive monitoring and control framework for its information

systems which includes a set of control mechanisms, policies, and procedures in order ensure

compliance with required regulatory frameworks and guidelines (e.g. NIS2 Directive L. 5160/2024).

To enhance cybersecurity in 2025, the Company has implemented the following measures:

• Implementation of security policies based on cybersecurity risk assessments.

• Implemented cybersecurity training program including user awareness courses and campaigns.

• Initiation of enhanced data protection controls, including information classification and sensitivity

labeling, as well as improved secure file storage and sharing controls to reduce the risk of data loss.

• Design and execute IT Emergency plan and drill, including tests and recovery procedures for critical

infrastructure.

• Regular penetration and vulnerability Assessments for public and internal systems.

• Enhanced vulnerability patch management via dedicated module and automated patch policies.

• Collaborated with internal and external auditors to strengthen controls and compliance.

• Collaboration with competent national and European cybersecurity authorities in the execution of

threat landscape analysis and information systems risk assessment.

• Performed regular IT risk assessments to identify, evaluate and address potential risk.

Information Systems Governance

In 2025, the Company continue the implementation of information security and IT governance policies.

The development of these policies was based on a comprehensive consulting engagement, focused on

an audit of the IT management system, penetration test, baseline inspection, risk assessment, etc. This

involved meticulously outlining processes that oversee Information Systems governance and taking

several measures to strengthen the controls for its information systems.

By implementing these measures and continuously monitoring and improving information systems

controls, the Company can enhance the security and integrity of its data and mitigate potential threats

and risks.

During 2025, the Company further strengthened its information systems governance framework

through the establishment of a dedicated Chief Information Security Officer role, who is responsible for

managing the Information Security Framework. This Framework includes cybersecurity policies and

procedures aligned with international best practices and standards, reflecting Management's

commitment to managing cyber risks enhancing at the same time oversight, accountability, and

coordination of information security and cyber risk management.

The Company employs a multi-layered approach to protect its information, supported by a strategic plan

that incorporates state-of-the-art technologies and top-tier information systems, while ensuring

compliance with the required regulatory frameworks and directives. Indicatively, the Company has

adopted AI-enabled cutting-edge security solutions that continuously improve support for the digital

transformation strategy, while addressing the ever-evolving cybersecurity landscape.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Furthermore, the Company has invested in fostering a culture of cybersecurity awareness through e-

learnings, face to-face training sessions and phishing simulation drills aiming to minimize the risk of

human errors that could lead to unintentional or intentional adverse incidents.

Finally, the Company has implemented technical and organizational arrangements to enhance the

continuity of IT services in case of unexpected events that could affect system availability.

IV. Reference to the information required for cases c`, d`, e`, f` and h` of par 7 of article 4 of Law

3556/2007 (Α` 91).

The above information is included in another part of the Management Report, i.e. in the Explanatory

Report of the BoD according to article 4, par. 7 and 8 of Law 3556/2007.

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

A. General Assembly of Shareholders

1. The General Assembly (GA) of the shareholders of the company is the supreme body of the Company

and is entitled to decide on any affair regarding the Company. Its legal resolutions also bind the absent

or disagreeing shareholders.

2. The GA of shareholders is convened by the BoD and meets obligatorily at the seat of the Company or

in the region of another municipality within the region where the seat of the company is located, at least

once in any corporate fiscal year until the tenth (10th) calendar day of the ninth month at the latest

after the end of the corporate financial year. It may also be convened at the region of the Municipality,

in which the seat of the Athens Stock Exchange is located.

3. The GA has a quorum and validly meets on the issues of the daily agenda, provided they are present

or represented therein shareholders representing at least one fifth (1/5) of the paid share capital. If no

such quorum occurs at the first meeting, a repetitive GA is convened within twenty (20) days from the

date of the cancelled meeting, which is convened at least ten (10) days prior to this meeting, unless the

procedure of article 9 par. 5 last sentence of these articles of association has been applied. This

repetitive GA has quorum and validly meets on the issues of the initial daily agenda, whichever is the

part of the paid share capital of the company, which represented in the meeting. The resolutions of the

GA are taken upon full majority of the votes represented in the meeting.

4. Until the election of its Chairman, performed by the same meeting with a simple majority, in the GA

chairs the Chairman of the BoD or his/her alternate. The Chairman of the meeting may be assisted by a

secretary and a teller, elected in the same way. The Chairman checks if the convocation of the GA follows

the normal procedure, the identity and legalization of those present in the meeting, the accuracy of the

minutes, administers the discussion, sets the issues on vote and announces the results of the vote.

5. The discussions and resolutions of the GA are limited to the issues of the daily agenda. The result of

the voting is announced by the Chairman of the GA as soon as it is confirmed. The company, under the

responsibility of its BoD, publishes in its website the results of the voting within maximum five (5) days

from the date of the GA, specifying for each resolution at least the number of shares for which valid

votes were given, the percentage of the share capital that is represented by these votes, the total

number of valid votes, as well as the number of votes for and against each resolution and the number

of the absences.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Ordinary GA of the Company's Shareholders in the year 2025, took the following decisions:

1. Approval of the Annual Financial Statements, along with the Board of Director’s Annual Report

and the Independent Auditors’ Report.

For the above item agreed shareholders who participated in the GA representing 20,854,752 registered

shares, representing 83.299% of the paid-up share capital of the Company or 99.684% of the voting

shareholders.

2. Approval for dividend’s distribution.

For the above item - agreed shareholders who participated in the GA, with 20,851,179 registered shares,

representing 83.405% of the paid-up share capital of the Company or 99.811% of the voting

shareholders.

3. Approval of the remuneration report under article 112 of law 4548/2018.

For the above item agreed shareholders who participated in the GA, representing 20,448,661 registered

shares, representing 81.795% of the paid-up share capital of the Company or 97.884% of the voting

shareholders.

4. a) Approval of the remuneration and fees paid to the BoD members for the fiscal year 01.01.2024 –

31.12.2024, according to article 109, paragraph 1 of Law 4548/2018, and b) Approval of advance

payment of remuneration and fees for the fiscal year 01.01.2025 – 31.12.2025 according to article 109,

paragraph 4 of Law 4548/2018.

For the above item agreed regarding the item (a) shareholders who participated in the GA, representing

20.776.615 registered shares, representing 83.106% of the paid-up share capital of the Company or

99.454% of the voting shareholders, and regarding the item (b) shareholders who participated in the

GA, representing 19,816,779 registered shares, representing 79.267% of the paid-up share capital of the

Company or 94.859% of the voting shareholders.

5. Approval of the overall management of the Company according to article 108 of Law 4548/2018, as

in force, and discharge, pursuant to the article 117 of L. 4548/2018, of the Statutory Auditors of the

Company from any liability for compensation

For the above item agreed shareholders who participated in the GA, representing 20,768,950 registered

shares, representing a percentage of 83.076% of the paid-up share capital of the Company or a

percentage of 99.417% of the voting shareholders.

6. Appointment of Auditing Firm, and determination of its remuneration, for the fiscal year

01.01.2025 – 31.12.2025, for a) the statutory audit of the financial statements and the issuance of

the annual tax report of PPA SA and b) for the assurance of the Sustainability Report.For the above

item agreed regarding the item (a) shareholders who participated in the GA, representing 20.701.620

registered shares, representing 82.806% of the paid-up share capital of the Company or 99.095% of the

voting shareholders, and regarding the item (b) shareholders who participated in the GA, representing

20,780,909 registered shares, representing 83.124% of the paid-up share capital of the Company or

99.474% of the voting shareholders.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

7. Election of a new Board of Directors of the Company, definition of its term of office and appointment

of its independent members, in accordance with the current regulatory framework.

For the above item regarding the election of Mr. LIN Ji agreed shareholders who participated in the GA,

representing 18,835,986 registered shares, representing a percentage of 75.344% of the paid-up share

capital of the Company or a percentage of 90.164% of the voting shareholders.

For the above item regarding the election of Mr. ZHU Changyu agreed shareholders who participated in

the GA, representing 18,496,364 registered shares, representing a percentage of 73.973% of the paid-

up share capital of the Company or a percentage of 88.524% of the voting shareholders.

For the above item regarding the election of Mr. Su Xudong agreed shareholders who participated in

the GA, representing 19,049,946 registered shares, representing a percentage of 76.200% of the paid-

up share capital of the Company or a percentage of 91.189% of the voting shareholders.

For the above item regarding the election of Mrs. LI Jin agreed shareholders who participated in the GA,

representing 19,010,869 registered shares, representing a percentage of 76.043% of the paid-up share

capital of the Company or a percentage of 91.002% of the voting shareholders.

For the above item regarding the election of Mr. ZHOU Zhonghui agreed shareholders who participated

in the GA, representing 19,066,211 registered shares, representing a percentage of 76.265% of the paid-

up share capital of the Company or a percentage of 91.267% of the voting shareholders.

For the above item regarding the election of Mr. LIN Lan agreed shareholders who participated in the

GA, representing 19,066,739 registered shares, representing a percentage of 76.267% of the paid-up

share capital of the Company or a percentage of 91.269% of the voting shareholders.

For the above item regarding the election of Mrs. ZHANG Xueyan agreed shareholders who participated

in the GA, representing 18,991,739 registered shares, representing a percentage of 75.965% of the paid-

up share capital of the Company or a percentage of 90.908% of the voting shareholders.

For the above item regarding the election of Mrs. ZARAKELI Andriana agreed shareholders who

participated in the GA, representing 19,062,552 registered shares, representing a percentage of

76.267% of the paid-up share capital of the Company or a percentage of 91.269% of the voting

shareholders.

8. Election of a new Audit Committee (redefinition of its type, its term, the number and capacity of its

members).

For the above item agreed shareholders who participated in the GA, representing 19,062,552 registered

shares, representing a percentage of 76.250% of the paid-up share capital of the Company or a

percentage of 91.249% of the voting shareholders.

The following were also presented for the information of the shareholders of the Ordinary General

Meeting, without being put to a vote:

1. Presentation of Company’s Annual Audit Committee Activity Report, in accordance with the

article 44 of L. 4449/2017, as in force.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

2. Presentation of the Report of the Independent non-Executive members of the BoD Activity Report, in

accordance with the article 9 of L. 4706/2020, as in force.

B. Board of Directors

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

Composition - Operation of the BoD

1. The Company is managed by the BoD composed by nine (9) to thirteen (13) members (directors),

elected by the GA, subject to paragraph 2 below, with absolute majority of the represented votes,

for a duty up to five (5) years, which is extended until the expiry of the deadline, within which the

next ordinary GA following directly the previous one must be convened and until the adoption of

the relevant resolution.

2. As long as the Hellenic Corporation of Assets and Participations SA or any global successor or

successor by operation of law of the Hellenic Corporation of Assets and Participations SA(each and

collectively, the “GROWTHFUND”) holds at least one million two hundred and fifty thousand

(1,250,000) voting shares and less than 10% of the voting shares issued by the Company and subject

to the GROWTHFUND is entitled to appoint one (1) Member pursuant to article 79 of Law

4548/2018 as in force. If the GROWTHFUND holds at least 10% of the voting shares, the

GROWTHFUND is entitled to appoint 1/3 of the total number of Members of the BoD of the

Company.

3. Should any Director appointed pursuant to paragraph 2 of this article resign or become

incapacitated for whatever reason, they shall be replaced by such persons the GROWTHFUND shall

specify in a pertinent written notice to the Company, with immediate effect.

4. The directors, shareholders and non-shareholders may always be reelected and are freely

revocable.

5. Member of the BoD may also be a legal person. In this case the legal person is obliged to appoint

a natural person for the exercise of the powers of the legal person as member of the BoD. This

appointment is subject to publicity according to article 13 of the L.4548/2018. The natural person

is jointly and severally liable together with the legal person for the company's management.

6. The BoD consists of executive, non-executive and independent nonexecutive members.

7. Executive members are those who deal with the day-to-day management of the Company. The

executive members of the BoD, in particular: (a) are responsible for the implementation of the

strategy determined by the BoD and (b) consult at regular intervals with the non-executive

members of the BoD on the most appropriate strategy to be implemented. In situations of crisis or

risk, as well as when circumstances require it to take measures that are reasonably expected to

significantly affect the Company, such as when decisions are to be made regarding the development

of the business and the risks that are expected to affect the financial situation of the Company, the

executive members inform the BoD in writing without delay, either jointly or separately, submitting

a relevant report with their estimates and proposals.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

8. The non-executive members of the BoD, including the independent nonexecutive members,

have, in particular, the following obligations: (a) They monitor and examine the Company's strategy

and its implementation, as well as the achievement of its objectives. (b) Ensure effective oversight

of executive members, including monitoring and control of their performance. (c) Examine and

express views on the proposals submitted by the executive members, based on existing

information.

9. The number of non-executive members of the BoD must not be less than 1/3 of the total number

of members, including independent non-executive members.

10. Independent non-executive members are those members who are elected by the GA, or

appointed by the BoD (according to par. 4 of article 9 of Law 4706/2020), who are free from

financial, business, family or other relationships of dependency with the Company or with persons

related to it, which may influence their decisions and their independent and objective judgment,

and meet the additional conditions provided by the relevant legislation (article 9 of Law 4706/2020),

including non-executive obstruction assistance and not exceeding the maximum permitted

percentage of their participation in the share capital of the Company.

Power - Duties of the BoD

1. The BoD, acting collectively, exercises the management of the Company and exercises control over its

all activities. Manages the corporate property, represents the Company and makes decisions on all

matters concerning the Company with a view to promoting the corporate purpose, except for matters

relating to the exclusive responsibilities of the GA of Shareholders.

It is further responsible for the complete and effective control of the Company's activities and acts in

accordance with the provisions of the law and the articles of incorporation.

The main responsibilities of the BoD include:

• The drawing up of strategic directions, including the sale or otherwise disposal of the Company's

shares, the acquisition of any company or the proposal to merge the Company with another

company, which are subject to the final approval of the GA of the shareholders.

• The management and disposal of the corporate property and the representation of the Company in

court and out of court.

• The conclusion and receipt of loans on behalf of the Company.

• The conclusion of any kind of contract, subject to articles 99 -101 of Law 4548/2018 and agreements

with any third physical or legal persons.

• Ensuring the completeness and reliability of the data and information required for the accurate and

timely determination of the financial situation of the Company and the preparation of reliable

financial statements, as well as its non-financial situation, according to article 151 of law 4548/2018.

• The preparation of the annual budget and the business plan of the Company.

• Defining and achieving the Company's efficiency goals.

• Monitoring the progress of the Company and the control of large capital expenditures.

• Ensuring the adequacy and efficiency of the Company's ICS, which aims in particular:

a) the consistent implementation of the business strategy,

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

b) the identification and management of material risks associated with its business and operation,

c) the efficient operation of the internal control unit.

• Ensuring that the functions of the Internal Audit System are independent of the business sectors they

control, and that they have the appropriate financial and human resources, as well as the powers to

operate them effectively.

• The definition of the strategy and business risk management of the Company.

• The formulation, dissemination and application of the basic values and principles of the Company

that govern its relations with all parties, whose interests are related to those of the Company.

• The convergence of the General Assemblies (regular or extraordinary) and the determination of the

issues of its agenda.

• The preparation of the Company's remuneration policy, which is submitted for approval by the GA

of Shareholders (following a relevant proposal of the Remuneration Committee).

• The submission of a proposal for approval by the GA of Shareholders for the distribution of dividends.

• The submission of a proposal for approval by the GA of Shareholders for the election of Statutory

Auditors, for the regular audit of the financial statements of the Company (following a relevant

proposal of the Audit Committee).

• The submission of a proposal for approval by the GA of Shareholders for the eligibility policy of the

members of the BoD (as well as any substantial modification) and its posting on the Company's

website.

• The preparation of training policy for the members of the BoDand executives of the Company.

• The approval and any revision of the Internal Regulation of the Remuneration Committee as well as

the Nominations Committee (following a relevant suggestion of the above Committees).

• The responsibility for the compliance of all types of activities of the Company with the regulatory and

legislative framework, as well as the internal regulations governing the operation of the Company.

• The succession planning for the members of the BoD and the Chief Executive Officers.

• The annual collective evaluation of the effective BoD functioning, the fulfillment of its duties as well

as its committees.

The adoption of a calendar of meetings and an annual action plan, at the beginning of each calendar year,

which is revised according to the developments and needs of the Company, in order to ensure the correct,

complete and timely fulfillment of its duties.

• Supervising the implementation as well as ensuring the adequacy and effectiveness of the corporate

governance systems on which the Company operates and taking appropriate action to address

deficiencies.

• The appointment of the head of the Internal Audit Service of the Company.

• The possibility of assigning the duties of Coordinator or Mandated Advisor to one or more of its

members.

• Ensuring that the detailed curriculum vitae of the members of the Board of Directors is updated

without delay and is kept posted throughout the term of office of each member.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

2. The BoD may, only and exclusively in writing, assign the exercise of all its powers and duties, save these

requiring a collective action, as well as the representation of the company to one or more persons,

members of the BoD, managers and employees of the company or third parties, by specifying at the same

time the scope of such assignment as well. All these persons may, as long as it is provided by the relevant

resolution of the BoD, assign further the exercise of the powers entrusted to them or part of these powers

to other members or third parties.

2.Constitution and Convocation of the BoD

1. The BoD elects one of the Directors as Chairman and may designate up to two (2) other Directors as

Vice Chairmen.

2. The Chairman of the BoD chairs its meetings and exercises the responsibilities provided by law and the

articles of association. When the Chairman is absent or hindered, he shall be replaced by the appointed

for this purpose Vice Chairman.

3. In case the BoD, by way of derogation from par. 1, of article 8 of law 4706/2020 appoints as Chairman

one of the executive members of the BoD, it obligatorily appoints a vice-chairman from the non-executive

members.

4. The BoD elects a Member as the Chief Executive Officer of the Company. The Chief Executive Officer

and the Chairman may be the same person.

Chairman of the BoD

The Chairman of the BoD (in addition to his duties, which stem from his capacity as executive member

of the BoD and as legal representative of the Company) coordinates and directs the meetings and the

general operation of the BoD. Chairman of the BoD, has the responsibility of convening the BoD in a

meeting, setting the agenda, ensuring the good organization of the work of the BoD, but also the

effective conduct of its meetings. It is also the responsibility of the Chairman to ensure the timely and

correct information of the members of the BoD, as well as his effective communication with all

shareholders, with a view to fair and equal treatment of the interests of all shareholders.

Vice Chairman of the BoD

In case of temporary absence or impediment of the Executive member and Chairman of the BoD, the

Vice Chairman of the BoD convenes and chairs the meetings, ratifies the minutes, as well as issues the

official copies and extracts of his minutes.

Chief Executive Officer

The Chief Executive Officer in collaboration with the Executive Chairman of the BoD monitors and

controls the implementation of the strategic objectives of the Company and the management of the

affairs (day-to-day management) of the Company and draws up the guidelines of the Company.

Supervises and ensures its smooth, orderly and efficient operation, in accordance with the strategic

objectives, business plans and action plan, as determined by decisions of the BoD and the GA. The BoD

of the Company may elect Deputies and Assistants of the Chief Executive Officer, whose responsibilities

may relate to the responsibilities and jurisdictions of the Chief Executive Officer as well as the

coordination and supervision of the individual organizational units of the Company.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Convocation of the BoD

1. The BoD should meet any time provided by law, the articles of association or required under the needs

of the company.

2. Meetings of the BoD shall convene within the Municipality of the registered office of the Company or

alternatively within the prefecture of the Municipality of the registered office of the Athens Exchange.

Alternatively, meetings of the BoD may convene in Mainland China or Hong Kong.

3. The BoD may duly meet at another place out of the seat of the company, located either in Greece or

abroad, provided that in this meeting all the members of the BoD are present or represented, and no

member objects to the execution of the meeting and to the adoption of resolutions.

4. The invitation to the members of the BoD may provide that the meeting of the BoD will take place

through conference call for some or for all members. In this case, the invitation addressed to the

members of the BoD includes the necessary information and technical instructions about their

participation in the meeting.

5. The BoD is convened by the Chairman or Vice Chairman who chairs its meetings, upon invitation

notified to its members at least two (2) working days prior to the meeting, and at least five (5) working

days if the meeting is going to be held in a location outside the seat of the company. In the invitation

the issues of the daily agenda must be stated clearly, otherwise the adoption of resolutions is permitted

only if present or represented are all the members of the BoD and none objects to the adoption of

resolutions.

Corporate Secretary

The Board of Directors appoints a Corporate Secretary. The Corporate Secretary is in charge of keeping

the minutes of the meetings of the Board of Directors and its Committees. The responsibilities of the

Corporate Secretary include ensuring a good flow of information between the Board of Directors and its

Committees, as well as between the top management and the Board of Directors. The Corporate

Secretary formulates the introductory information program of the members of the Board of Directors,

immediately after the beginning of their term of office and their continuous information and training on

issues concerning the Company.

Decision making

a. The Board of Directors is quorum and meets validly, when more than one of the directors is present or

represented in this half, but the number of present or represented directors can never be less than six (6).

b. In the meetings of the Board of Directors that have as subject the Company’s financial statements

approval or include issues for the approval of which the decision of the general assembly is foreseen with

increased quorum and majority, according to law 4548/2018, the Board of Directors is in quorum when

at least two (2) independent non-executive members are present.

c. The decisions of the Board of Directors are validly taken by an absolute majority of the members present

and represented, while in case of a tie, the vote of the Chairman prevails

d. Each consultant may validly represent only one other consultant.

e. Representation on the Board of Directors may not be assigned to persons who are not members of

the Board of Directors.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

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

with by the BoD

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

of meetings attended by the members of the BoD.

Name

BoD position

Gender

Number of BoD

meetings within

2025, during

the BoD

Member term

of office

Percentage of

participation or

representation in

BoD meetings

Date of

commence

ment of

term office

or re-

election

End of term

of office

Lin Ji*

BoD

Chairman,

Executive

Member

100%

08/07/2025

07/11/2025

Han Chao*

BoD

Chairman,

Executive

Member

100%

07/11/2025

08/07/2027

Su Xudong

CEO,

Executive

Member

100%

08/07/2025

08/07/2027

Li Jin

CFO,

Executive

Member

100%

08/07/2025

08/07/2027

Zhu Changyu

BoD Vice

Chairman,

Non

Executive

Member

92%

08/07/2025

08/07/2027

Yu Tao**

Non

Executive

Member

100%

02/08/2023

08/07/2025

Zhang

Xueyan**

Non

Executive

Member

100%

08/07/2025

08/07/2027

Kwong Che

Keung

Gordon***

Independent,

Non

Executive

Member

100%

02/08/2023

08/07/2025

Zhou

Zhonghui***

100%

08/07/2025

08/07/2027

Arvanitis

Nikolaos***

Independent,

Non

Executive

Member

100%

02/08/2023

08/07/2025

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Lin Lan***

Independent,

Non

Executive

Member

100%

08/07/2025

08/07/2027

Moralis

Ioannis***

Independent,

Non

Executive

Member

83%

02/08/2023

08/07/2025

Zarakeli

Adriana***

Independent,

Non

Executive

Member

100%

08/07/2025

08/07/2027

Giourelis

Stefanos****

Non

Executive

Member

100%

24/01/2025

13/03/2025

Politis

Dimitrios****

Non

Executive

Member

100%

13/03/2025

08/07/2027

* Mr. LIN Ji served as executive Chairman of the Board until 07.11.2025, date on which Mr. Han Chao

assumed the duties of executive Chairman.

** Ms. YU Tao served as a non-executive member of the Board until 08.07.2025, date on which Ms. Zhang

Xueyan assumed the duties of non-executive member of the Board.

*** Messrs. Kwong Che Keung Gordon, Arvanitis Nikolaos, Moralis Ioannis served as independent non-

executive members of the Board until 08.07.2025, date on which Messrs. Zhou Zhonghui, Lin Lan, Zarakeli

Andriana assumed the duties of independent non-executive member of the Board.

**** Mr. Politis Dimitrios served as a non-executive member of the BoD from 01.01.2025 to 24.01.2025 and

from 13.03.2025 onwards, while in the interval from 24.01.2025 to 13.03.2025 the above duties were

performed by Mr. Giourelis Stefanos.

The main issues discussed at the BoD’ meetings during the 2025 financial year:

• Approval of the Annual Financial Report.

• Submission of a proposal to the GA of PPA SA Shareholders for the distribution of profits (dividend).

• Submission of proposal to the GA for the approval of the Remuneration Report.

• Approval of the Annual Budget.

• Approval of the Annual Donations and Sponsorships Plan

• Approval of the Annual Investment and Asset Disposal Plan

• Approval of the Annual Activity Report of the Audit Committee

• Approval of the Annual Activity Report of the Remuneration Committee

• Approval of the Annual Activity Report of the Nominations Committee

• Approval of the results of the Evaluation Process: a) of the Board of Directors of PPA SA and b) of its

Committees

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

• Risk Management Annual Report

• Approval of PPA S.A. Risk Appetite Statement.

• Approval of the Contract Conclusion Regulation

• Submission of a proposal for approval by the Ordinary General Meeting of PPA SA Shareholders

(following a relevant proposal by the Nominations Committee), of the election of the new Board of

Directors due to the expiration of its term of office

• Approval of updated Company’s Internal Organization and Operation Regulation (IOOR)

• Approval of the Company's Strategic Business Plan

• Approval of: the Operating Regulations of the Risk Management Unit

• Approval of the Risk Management Unit Policy, Methodology & Procedures

• Approval of the "Policy Suitability-Eligibility" of the Members of the Board of Directors

• Approval of the "Policy Diversity" of the Members of the Board of Directors

• Early Retirement Incentives Plan implementation to PPA SA personnel.

• Conclusion of a service contract between PPA SA and COSCO SHIPPING TECHNOLOGY (BEIJING) CO.,

LTD

• Conclusion of a service contract between PPA SA and COSCO SHIPPING GLOBAL EXHIBITION SERVICES

BEIJING Co Ltd

• Conclusion of a service contract between PPA SA and COSCO Shipping Specialized Carriers Co., Ltd .

* In the last three cases, the approval procedures of the above contracts were followed, in accordance

with article 100 par. 1 of Law 4548/2018.

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

CV’s of the BoD members

Below are presented the CV’s of the members of the BoD members pursuant to the provision of Article

18 of Law 4706/2020 which can are available on the web page of the Company, at the link

https://www.olp.gr/en/about-us/corporate-governance/board-of-directors.

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

Mr. Lin Ji has extensive international professional experience in management - strategic planning –

organization of port industry and maritime sector affairs in general.

Mr. LIN JI, is Executive Vice President of China COSCO SHIPPING Corporation Limited and he has also

served in various senior management positions such as:

• Deputy Director of the Secretariat of the Presidential Affairs Department of China Ocean Shipping

(Group) Company,

• Deputy Director of the Research Center of the Advisory Office of the President's Affairs Department

of China Ocean Shipping (Group) Company,

• Director of China Ocean Shipping (Group) Company,

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

• General Manager of COSCO Africa Limited,

• General Manager of Xiamen Ocean Shipping Company

• President of COSCO Europe Limited,

• President of COSCO Shipping (Europe) Co., Ltd.

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

Mr. HAN Chao is Chairman of Board of Directors of the Piraeus Port Authority S.A since 07.11.2025.Mr.

HAN Chao has extensive professional experience in administration, human resources management, and

the overall organization of maritime sector affairs. Throughout his thirty-year career, he has served in

major maritime industry companies, including COSCO Container Lines Company, Shanghai Ocean

Shipping Company, Xiamen Ocean Shipping Company, China Shipping International Ship Management

Company, and COSCO Shipping Seafarer Management Company, holding various senior managerial and

leadership positions up to the level of General Manager and Chairman .He also engaged actively in the

academic field, serving as Executive Vice President of the Corporate University of China COSCO Shipping

Corporation and President of the COSCO Shipping Talent Development Institute, where he led initiatives

to cultivate the next generation of maritime industry leaders.

Mr. HAN Chao graduated from Shanghai Maritime University, where he earned a Bachelor’s degree in

Engineering in Marine Engineering Management and a Master’s degree in Engineering in Transportation

Engineering.

Mr. SU Xudong, CEO, Executive BoD member

Mr. Su Xudong, appointed on 29 April 2024 as a member of the Board of Directors of the Port of Piraeus

S.A. and currently serving as CEO.

He has extensive international experience in information technology, port operations, shipping, and

logistics, having previously served in several senior management roles, including Deputy General Manager

of IT Development at COSCO Container Lines, General Manager of COSCO (Belgium) Co., Ltd., General

Manager of COSCO SHIPPING Lines (Belgium), General Manager of COSCO SHIPPING Lines (Greece), and

holds the position of deputy CEO at COSCO Shipping (Europe) Co., Ltd while concurrently managing COSCO

SHIPPING Lines (Greece) and Ocean Rail Logistics. He holds a degree in Applied Informatics from Shanghai

Maritime University.

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

Mr. Zhu Changyu is a member and Vice Chairman of Board of Directors of the Piraeus Port Authority SA.

since 03.05.2023.

Mr. Zhu is a director and president of COSCO SHIPPING (Hong Kong) Co., Limited. He is also executive

director, chairman and managing director of COSCO SHIPPING International (Hong Kong) Co., Ltd. and a

non-executive director of Piraeus Port Authority S.A.. He had been the head and division chief (handling

division duty) of Planning Division, the deputy manager of Marketing Division of China Shipping Group

International Trade Co., Ltd., the manager of Procurement Division and the assistant to general manager

of Shenzhen China Shipping Haisheng Asphalt Co., Ltd., the manager of Comprehensive Trade Division of

China Shipping Group International Trade Co., Ltd., the manager of Development and Research Division,

the manager of Investment Management Division and the assistant to general manager of China Shipping

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(amounts in Euro unless stated otherwise)

Group Investment Co., Ltd., the deputy supervisor of Research Office, the senior manager of Secretarial

Office of Executive Division, the deputy general manager of Strategic Development Division of China

Shipping (Group) Company, the deputy supervisor of Integration Management Office, the general

manager of Strategy & Corporate Management Division and the supervisor of Deepening Reform Office

of China COSCO Shipping Corporation Limited. He has extensive experience in strategic planning, capital

operation, corporate governance, integration and reorganization. He graduated from Shanghai Maritime

College (now known as Shanghai Maritime University), majoring in Transportation Management

Engineering and obtained a Master’s degree. He is a senior economist.

Ms. LI Jin, CFO, Executive BoD member

Ms. Li Jin, serves since May 2020 till today as a Deputy Chief Executive Officer and Chief Financial Officer

of PPA SA while since 17.07.2021 she is an executive member of the Board of Directors of the Company.

Ms. LI has 30 years’ professional experience and throughout her career professional served COSCO Ocean

Shipping, China COSCO Holding and COSCO Shipping in various Financial Managerial positions up to the

General Manager of Finance Division level and she has international working experience by serving COSCO

Shipping Group, In Oceania and Europe.

Ms. LI got the senior accountant qualification certificate and senior economist qualification certificate in

2008, and became a Certified management accountant in 2015. Ms. LI participated in “the National

Accounting Leading Talents training project” which was organized by Ministry of Finance of the People’s

Republic of China from 2012 to 2019 and in “the special training course for international talents” which

was organized by China COSCO Shipping Group in 2019.

Ms. LI graduated from Capital University of Economics and Business and holds a bachelor’s degree in

International Credit and Investment and a Master’s Degree in Finance from Central University of Finance

and Economics.

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

08.07.2025)

Mr.Kwong has been the Independent Non-executive Director of the COSCO SHIPPING INTERNATIONAL

(HONG KONG) CO., LTD since July 2020. Mr. Kwong is also independent non executive director of a

number of listed companies in Hong Kong, namely, Agile Group Holdings Limited, Chow Tai Fook

Jewellery Group Limited, FSE Lifestyle Services Group Limited, Henderson Investment Limited, Henderson

Land Development Company Limited.

Mr. Kwong graduated from The University of Hong Kong with a bachelor’s degree in social sciences in

1972 and is a fellow member of the Institute of Chartered Accountants in England and Wales and the

Hong Kong Institute of Certified Public Accountants respectively.

Mr. Kwong was a partner of international accounting firms from 1984 to 1998 and an independent

member of the Hong Kong Stock Exchange Council from 1992 to 1997, during which he had also served

as Chairman of both the Listing Committee and the Compliance Committee of the Hong Kong Stock

Exchange. He has over 40 years of experience in accounting and auditing, as well as long experience in

shipping industry.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

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

Mr. Zhou Zhong Hui is currently the Managing Director of China Appraisal Society.

He is also an Independent Non-Executive Director of CloudWalk Technology Co. Ltd.

Previously, he held various Independent Non-Executive Director positions in companies such as CITIC

Securities Co. Ltd., China Pacific Insurance (Group) Co., Ltd. and COSCO SHIPPING Holdings Co. Ltd. He

also served as Chief Accountant, General Manager and Senior Partner of PricewaterhouseCoopers Zhong

Tian LLP from 1992 to 2007.

In addition, he served as a Professor at Shanghai University of Economics from 1989 to 1998.

He holds a master’s degree and a doctorate in economics from Shanghai University of Economics and

Finance. Mr. ZHOU is a senior member of the China Institute of Certified Public Accountants, a member

of the Specialized Committee of Financial Directors of the China Association of Public Companies, and a

member of the Advisory Committee of the China Appraisal Society since November 2010. He is a member

of the International Advisory Committee of the China Securities Regulatory Commission, the Audit

Regulation Committee of the China Institute of Certified Public Accountants.

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

08.07.2025)

He studied and participated in seminars in the Maritime Economics, in the Management and Organization

of Shipping Companies and in Combined Transport. He has been graduated from BCA College of Athens,

London School of Foreign Trade and City of London Polytechnic. He started his career in 1980 in London

at FENTON STEAMSHIP CO, a subsidiary of Hellenic Lines LTD, and continued in Top Management

positions in Piraeus at ZIM HELLAS SA 1984-2010 and at VISTA MARITIME & LOGISTICS LTD since 2010.

He has participated since April 2000, as an elected member of the BoD of the International Maritime

Union, (an institution representing the agencies of international shipping companies in Greece) and was

elected President of the BoD for two consecutive terms Apr. 2006 - Mar- 2012.

In June 2013 the International Maritime Union BoD unanimously named him as Honorary President. Due

to his institutional role as President of the International Maritime Union, he participated in working

committees and meetings on issues related to the Port Industry, Shipping Policy, Customs and Regulation

Issues, in collaboration with the Ministry of Merchant Shipping & Island Policy, the General Secretariat

of Ports Policy and Maritime Investments, the PPA SA and other Port Organizations, the PCT SA, the

Customs Administration.

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

Dr. Lin Lan started his professional career in 1993 as General Manager of (GCT) Canada. From 1995, he

joined H.A. Simons Limited (now AMEC) as Director of Power System Software Development and from

2002, he held key management positions in Simons Limited (AMEC) and General Electric Power Systems.

In 2002, he became Vice President of Guangdong Korun Electric Company. From 2006 to 2023, he served

Hisense Group in many senior management positions such as Vice President, Director, General Manager,

Senior Vice President and Chairman of the Group.

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(amounts in Euro unless stated otherwise)

Dr. Lin Lan, is a mechanical engineer, a graduate of North China Electric Power University, and holds

master and PhD degrees from the University of Tennessee in Mechanical Engineering.

During his career at Hisense Group, Dr. Lin Lan was responsible for Hisense’s international operations

and promoted Hisense’s global layout, including the establishment of production bases in N. America,

Europe, Mexico and Eastern Europe.

In his official evaluation by Hisense, Dr. Lin Lan was recognized as “an active professional and key

contributor of the Company’s internationalization strategy and a to the Company’s outstanding

achievements in overseas expansion and layout.”

He was awarded the title of Economic Person of the Year for 2022 in the "Influential People" list of China

News Weekly.

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

Ms. Yu Tao is economist (graduated from University of International Business and Economics) and she

also holds a Master degree in Business Administration (Guanghua School of Management Peking

University), while she has significant experience in the following areas:

• "International Transportation"

• "Business Administration"

• "Import/Export trade"

• "Logistics"

• "Shipping Lines Management"

• "Container Lines Management".

Ms. YU Tao has also served in various management positions (Deputy Chief Executive Officer) at COSCO

Logistics Co., COSCO Container Lines Co., and COSCO SHIPPING Lines Co.

Ms. ZHANG Xueyan, Non Executive BoD member (launching of term of service 08.07.2025)

Ms. Zhang Xueyan is currently a non-executive Director of COSCO SHIPPING Development Co, ltd.

Ms. Zhang has served in roles including a deputy general manager of Capital Management & Operation

Division of China COSCO Shipping Corporation Limited since December 2017 and has extensive

experience in capital operation. She started her career in 1999 and since 2013, she has successively

served as a deputy manager of the capital operation office of the Strategic Development Division of China

Ocean Shipping Co. (listed on the Hong Kong Stock Exchange), Ltd. and COSCO SHIPPING Holdings Co.,

Ltd. (listed on the Shanghai Stock Exchange). She served as manager of capital operation office of the

Capital Management & Operation Division and a deputy general manager of the Capital Management &

Operation Division of China COSCO Shipping Corporation Limited.

Ms. Zhang graduated from Beijing Normal University with a master’s degree in economics, majoring in

international investment and international trade. She holds a professional title of senior economist and

is a certified public accountant.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Mr. Moralis Ioannis, Independent Non Executive BoD member (expiration of term of service

08.07.2025)

Mr. Moralis Ioannis studied at the finance department of the University of Piraeus. Son of the late

Minister Petros Moralis was always interest in citizenship and politics but without having actively joined

a political party. He works since the age of 22 years old. For more than 20 years he was engaged in Piraeus

both as a freelancer in the field of Sports Marketing and communication, as well as the strain Olympiacos

FC having taken major positions of responsibility. In 2011 he was appointed Vice President and General

Manager of Olympiacos FC. In 2012 he was elected Chairman of the Super League. Since 2014 is

continuously elected Mayor of Piraeus.

Ms. ZARAKELI Adriana, Independent Non Executive BoD member (launching of term of service

08.07.2025)

Ms. Zarakeli Adriana has been a twice-elected member of the Piraeus Municipal Council (since May 2019)

and since September 2019, she has been appointed, as Vice Mayor for Extroversion, Tourism, and EU

Funding Programs, responsible for the Extroversion, Communication, Promotion, and Tourism and Media

Directorate, as well as for the Department for the Utilization of European Programs.

Ms. Zarakeli began her career in 1996 working as an editor in printed media, as well as in various

television and radio stations and undertaking roles of Head Editor and Newscaster and has ever since

been serving journalism with undiminished interest through both radio and TV stations.

Ms. Zarakeli holds a Master degree in Journalism and New Technologies from ΕCI - European

Communication Institute, Donau Universität Krems - Austria, Athena Research and Innovation Centre,

and National (Metsovian) Technical University of Athens, with expertise in the examination of the

parameters that optimize the function of communication and journalism and emphasis on the

possibilities of digital technology. Ms. Zarakeli has also obtained two specialization diplomas from

National and Kapodistrian University of Athens in “Design and Management of European Programs’ and

“Mix of Marketing and Brand.”

Ms. Zarakeli is a member of the Journalist's Union of Athens Daily Newspapers (ESIEA) and the

International Federation of Journalists (IFJ). She is the co-founder and managing director of PROTZECT

LTD, a corporate communication, PR, & marketing agency and she fluently speaks English and German.

Mr. Giourelis stefanos, Non Executive BoD member, Growthfund Representative (launching of term of

service 24.01.2025 - expiration of term of service 13.03.2025)

Mr. Giourelis holds a Diploma from the School of Mining and Metallurgical Engineering of the National

Technical University of Athens and has extensive international experience of over 25 years in the IT and

technology sector. During his professional career, he has held leadership positions of increasing

responsibility in the areas of strategic development, corporate governance, international sales and

organizational management. For 19 years, he served in senior management positions at Hewlett-Packard,

with geographical responsibility spanning Greece, the Middle East, the Mediterranean and Africa, based

in Athens and subsequently in Dubai. He served as General Manager of Greece (4 years) and Managing

Director of Greece and Africa (8 years), where he led multinational teams, managed complex business

ecosystems and contributed to the strategic transformation and growth of the markets under his

responsibility. He also served as Deputy Managing Director of the Superfund, actively participating in the

formulation of strategic directions, the management of corporate holdings and the supervision of

investment initiatives of national importance.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Mr. Dimitris Politis, Non Executive BoD member, Growthfund Representative (Terms of service

01.01.2025 to 24.01.2025 and relaunching from 13.03.2025)

Mr. Politis Dimitrios is a graduate of the American College of Greece and holds a postgraduate degree in

International Business and Export Management from City University Business School, London.

Since 1993, he has held positions of responsibility in international financial institutions. He began his

career at HSBC Bank PLC, initially in Athens and later in London, in the Investment Banking Department

covering Greece and the wider region of Southeastern Europe and the Middle East.

He returned to Athens in 2001 as Head of the French Credit Commercial de France, while in 2003 he

assumed the duties of Head of Corporate and Institutional Banking at HSBC Bank plc Greece. From 2012

to September 2020, he worked at Credit Suisse AG, based in Zurich, as Head of the Wealth Management-

UHNWI Sector for Greece and Cyprus, while from October 2020 he took on the same role at EFG Bank

AG, based in Zurich. From August 2021 to December 2024, he held the position of Managing Director at

the Hellenic Republic Asset Development Fund S.A. (HRADF), while in March 2025 he was appointed as

the Superfund representative on the Board of Directors of PPA S.A.

Mr. Politis has particular experience in attracting and managing investments in strategic sectors of the

economy and close professional relationships with international institutional and private investors, and

since April 2025 he has assumed the position of advisor to the Prime Minister on investment matters.

Sanozidis Savvas - Corporate Secretary

Mr. Sanozidis Savvas is a Transport Economist and serves as Corporate Secretary of PPA S.A. since

December 2021. He has been Secretary to the Company’s Board of Directors since 2007 and has also

served as Secretary to all Board Committees (Audit Committee, Remuneration Committee, Nomination

Committee, and Strategy Committee) since their establishment. He holds a Bachelor’s degree in

Economics from the University of Piraeus and an MSc in Transport Economics from the University of

Leeds. He is a member of the Association of Greek Transportation Engineers and brings professional

experience in financial consulting services for transportation and infrastructure projects in Greece and

abroad, and keeps a long-standing track record and expertise in corporate secretariat services and board

governance support.

CV’s of Deputies CEO

Captain Jin Beiyuan has ten years’ officer experience on Ocean Going Ship from 1991-2002. Since then

he has served for China Shipping Container Line as planner and operator, General Manager of China

Shipping Europe Holding operator and planner department, General Manager of China Shipping (France)

Agency, Vice General Manager of China Shipping Car Carrier Company Limited, and General Manager of

Guangzhou Cosco Shipping Car Carrier company limited. He now serves as Deputy CEO in Piraeus Port

Authority (since 2022).

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Mr. QU Shengbin is a Senior Economist and holds a University Degree and an MSc in Transportation

Planning and Management. He has two decades of work experience in the shipping and logistics industry.

He joined the COSCO family initially working and gaining extensive business experience, covering a wide

range of fields such as shipping agent, cargo forwarder, air cargo transport, project logistics, project

management, etc.. He then enriched his company management experience, serving as top management

member in COSCO Logistics ShenZhen, KunMing, GuangXi and PENAVICO FangCheng. Furthermore, Mr.

Qu was appointed to upper managerial positions in COSCO SHIPPING headquarters, in both the Operation

Management Division and the Strategic and Corporate Management Division. He now serves as Deputy

CEO in Piraeus Port Authority (since 2022).

Mr. Chen Dong is a senior port and terminal management executive with over 30 years of experience in

shipping, port operations, safety management and corporate governance within COSCO Group (such as

COSCO Shipping Ports Limited) and its affiliated companies (such as Lianyungang New Orient

International Container Terminal Co., Lianyungang COSCO Container Transport Co.,). He has proven

experience in terminal operations, safety systems, performance evaluation, engineering and innovation

management. He is a graduate of the Department of Economics of Jiangsu University, specializing in

foreign trade and international economics, and holds a Master's degree in Business Administration from

Dalian Maritime University. Ιn July 2025 he was assigned Deputy CEO duties of PPA S.A.

Mr. Angelos Karakostas joined COSCO SHIPPING Lines (Greece) S.A. in 1997 as General Manager. In 2009,

he was appointed Deputy General Manager of the Piraeus Container Station (PCT SA). In August 2016, he

took over the duties of Deputy CEO of the Port of Piraeus SA. He holds a degree in Mathematics and a

postgraduate degree in Business Research from the University of Patras. He holds an MBA and an MSc in

Management from Teeside University of the United Kingdom.

Mr. Panagiotis Tsonis is a graduate of the Department of Civil Engineering of the Polytechnic School of

the University of Patras and holds a master's degree in the Organization and Administration of Public

Services, Public Organizations & Enterprises of the University of Peloponnese. He has many years of

experience as a Civil Engineer and has served in leadership positions in organizations in both the private

(construction companies) and public sectors. In the period 2019-2023, he held the position of CEO of the

Patras Port Authority. He has been vice-president of the Delegation of the Technical Chamber of Greece,

President of the Association of Civil Engineers of Achaia and member of the governing committee of the

Technical Chamber of Greece/TDE, while he is a member of the ELOT/TE 20 Technical Committee and of

the National Accreditation Council. Ιn July 2023 he was assigned Deputy CEO duties of PPA S.A.

From the above Members of the BoD and Company Executives Mr. Angelos Karakostas on 31/12/2023

held 1559 shares of PPA S.A.

For the fiscal year 01.01.2024-31.12.2024, the compensations paid to the BoD members are those

provided in the current Remuneration Policy and as has been approved by GA of Shareholders decision

(gross annual compensation for each BoD member of the amount of € 40,000.00 as well as gross annual

maximum total amount for the independent members of the BoD and the FUND representative, for their

participation in the meetings of the BoD Committees (Audit - Remuneration - Nominations Committees),

regardless of the total number of Committees in which they participate, amounting to € 20,000.00.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

It is to be noted that in 2024, the Company prepared the members of the BoD remuneration report for

fiscal year 01.01.2023-31.12.2023 in accordance with article 112 of Law 4548/2018. The remuneration

report for the fiscal year 01.01.2023-31.12.2023 is available on the Company's website:

https://www.olp.gr/en/about-us/corporate-governance/board-of-directors.

CV’s of other Senior Staff

Tsomakos Nikolaos - Manager of Internal Audit

Mr. Tsomakos Nikolaos serves as Head of the Internal Audit Department of PPA S.A. since April 2024. He

holds a bachelor’s degree in business administration from the University of Piraeus and possesses the

professional certifications CIA (Certified Internal Auditor) and CCSA (Certification in Control Self-

Assessment) awarded by the Global Institute of Internal Auditors, along with Postgraduate degree from

Cornell University.

He is a member of committees of the Hellenic Institute of Internal Auditors and is registered in the Internal

Auditors Registry of the Economic Chamber of Greece.

He has professional experience in financial management and external audit roles and has served for many

years as Head of Internal Audit in companies across various sectors.

Palia Afroditi - Regulatory Compliance Manager

Ms. Palia Afroditi, Attorney-at-Law at the Supreme Court, serves as Regulatory Compliance Manager of

PPA S.A. since January 2024. She holds a bachelor’s degree in Law from the Law School of the National

and Kapodistrian University of Athens and a postgraduate Degree (MSc) in Banking and Financial Law from

the University of Piraeus and possesses a professional certification as a Certified Compliance Officer

awarded by TUV AUSTRIA HELLAS.

She is a member of the Athens Bar Association (A.B.A.) and member of the Association of Compliance

Officers in Greece (ASCO).

She has extensive professional experience in positions of legal counsel to Societe Anonyms companies,

specializing in the areas of Corporate Law, Capital Market Law and Corporate Governance Law.

Tsakalogiannis Christos - Risk Management Manager

Mr. Tsakalogiannis Christos has served as the Risk Management Manager of PPA S.A. since July 2021. He

holds a Bachelor’s degree in International & European Studies and an MBA with a specialization in the

Financial Sector from the University of Hertfordshire (UK). In September 2023, he earned the prestigious

COSO ERM (Committee of Sponsoring Organizations— Enterprise Risk Management) certification.

He has an extensive background in financial management and stock markets, previously served for many

years as the Head of various investment institutions, where he developed deep expertise in financial risk.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

5 .Assertion of compliance with independence criteria for Independent BoD members (par. 3 article 9

of Law 4706/2020)

The BoD, following a relevant recommendation of the Nominations Committee, taking into account

paragraph 3 of article 9 of Law 4706/2020, pursuant to which the fulfillment of the conditions for the

classification of a member of the Board of Directors as an independent member is reviewed by the Board

of Directors at least annually, per financial year, ascertained (BoD resolution no 42/2025, meeting of 10

of June 2025) that each of the three (3) independent members (a) ZHOU Zhonghui, (b) LIN Lan, (c) Zarakeli

Andriana, at the time of their appointment met all suitability and reliability criteria included in the

Suitability Policy, for their election as members of the Company's BoD, and the conditions of

independence defined in article 9 par. 1 and 2 of law 4706/2020, as in force, as well as that there are no

obstacles or incompatibility in the face of any Candidate in relation to any relevant provisions, including

the Corporate Governance Code (HCGC) applied by the Company and the Rules of Operation of the

Company. In particular, none of the above, directly or indirectly held a percentage of voting rights greater

than zero-point five percent (0.5%) of the share capital of the Company and each of them was free from

financial, business, family or other dependent relationships, which may influence their decisions and their

independent and objective judgment.

Furthermore, from the performed audit and from the relevant personal declarations submitted by each

of the above independent members, it had been confirmed that, apart from the criteria of par. 1 of article

9 of Law 4706/2020, as in force, the indicative dependence criteria of par. 2 of article 9 of Law 4706/2020,

as in force, are not met either, as each of the above proposed independent members:

a) Did not receive any significant remuneration or benefit from the Company, or from a company affiliated

with it, nor participated in a stock options scheme or in any other remuneration or benefit system related

to the performance, other than the fee for their participation in the BoD or its committees, nor

participates in the collection of fixed benefits under the pension system, including deferred benefits, for

previous services to the Company.

b) Had neither the same nor a person, who had close ties with it, a business relationship during the last

three (3) financial years before their appointment with: ba) the Company or bb) a person affiliated with

the Company or bc) a shareholder who directly or indirectly held a participation percentage equal to or

greater than ten percent (10%) of the share capital of the Company during the last three (3) financial years

before their appointment, or a company affiliated with them, if this relationship affected the business

activity of either the Company or the candidate independent non-executive member of the BoD of the

Company or the person who had close ties with them.

c) Had neither the same nor a person who had close ties with it had: c1) served as member of the BoD of

the Company or any company affiliated thereto for more than nine (9) financial years in total at the time

of their election, c2) been an executive or maintained an employment or contractor or services provision

relationship or a paid mandate with the Company or with a company affiliated with it during the last three

(3) financial years prior to its appointment, c3) a second degree kinship by blood or by marriage, or is a

spouse or partner equated with a spouse, member of the BoD or senior executive or shareholder, with a

participation percentage equal to or greater than ten percent (10%) of the share capital of the Company

or a company affiliated with it, c4) been appointed by a certain shareholder of the Company, in

accordance with the articles of association, as provided in article 79 of law 4548/2018, c5) been

nominated as represented of shareholders who directly or indirectly hold a percentage equal to or greater

than five percent (5%) of the voting rights at the GA of the Company's shareholders during his/her term

of office, without written instructions, c6) conducted a mandatory audit of the Company or a company

affiliated with it, either through a company or himself or a second-degree relative by blood or by marriage

of him/her or his/her spouse, during the last three (3) financial years prior to his/her appointment, c7)

been assigned as an executive member in another company, in the BoD of which an executive member of

the Company participates as a non-executive member.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The fulfillment of the independence criteria of the Independent Non-Executive Members of the Board of

Directors, in accordance with the provisions of the law, was re-evaluated, for a second time within 2025,

at a meeting of the Nomination Committee (Dec 2025) and relevant information was provided to the BoD,

which in turn proceeded to a relevant determination of fulfillment of the independence criteria of its

Independent Non-Executive Members (BoD resolution no. 86/2025, meeting of December 17

, 2025).

6. Suitability Policy of the BoD Members

The Company has adopted and implements a Policy for the Suitability Assessment of the Members of the

BoD (Suitability Policy), which has been approved by decision of the GA of 02.08.2023, following BoD

recommendation by its resolution dated 22.12.2022, and constitutes the set of principles and criteria that

apply when selecting, replacing, and re-appointing Board members, in terms of assessing their suitability

on an individual and collective level. This Policy aims to ensure the quality of recruitment to the Board, its

effective functioning and fulfilment of its role, based on the Company’s general strategy and medium and

long -term business goals for promoting its corporate interest.

The Suitability Policy of the Members of the BoD is posted on the Company’s website at the following

address: https://www.olp.gr/en/about-us/corporate-governance/policies.

The Eligibility/Suitability Policy aims to ensure that;

a) the BoD is staffed with sufficient number of members and a suitable composition;

b) the BoD is staffed with persons of morality and reputation;

c) the members of the BoD have the skills and experience required based on the duties they undertake

and their role on the BoD, while at the same time they have sufficient time to perform their duties;

d) in the selection, renewal of the term of office and replacement of a member, the evaluation of

individual and collective suitability is taken into consideration;

e) the Eligibility/Suitability Policy stipulates that the candidate members of the BoD know, among other

things, as much as possible, before taking the position, the culture, the values and the general strategy of

the Company.

The suitability of the BoD members is assessed both on an individual and a collective level.

Individual suitability means that a person is considered to have - as a Board member - sufficient

knowledge, skills, experience, independence of mind, good repute and moral standing for the

performance of their duties as a member of the Company’ s BoD, for which performance of duties he/she

shall also commit sufficient time, pursuant to the said Policy, which establishes specific criteria for the

assessment of all above factors.

Collective suitability means that the Board collectively should be suitable for carrying out its

responsibilities and should be composed in such manner as to contribute to the effective management of

the Company and to balanced decision-making.

BoD members should collectively be able to take appropriate decisions taking into account the business

model, risk-taking, strategy and markets in which the Company operates. Also, the members of the BoD

collectively are able to effectively monitor and critique the decisions of senior management.

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All areas of knowledge required for the business activities of the Company are recommended to be

covered by the Board collectively with sufficient expertise among its members. It is recommended that

there be a sufficient number of knowledgeable members in each area to be able to discuss the decisions

to be taken. The Bod members collectively have the necessary skills to present their views.

The composition of the BoD reflects the knowledge, skills and experience required to carry out his / her

responsibilities. The BoD in its executive function should benefit from a high level of managerial skills as

a whole; whereas in its supervisory function the BoD should avail itself of sufficient management skills as

a whole in order to organize its work efficiently and be able to understand and process the proposals for

respective decisions. In this context, the BoD as a whole adequately understands the areas for which

members are collectively responsible and to have the necessary skills to exercise the actual management

and supervision of the Company, including in terms of:

- its business and the main risks associated with it,

- strategic planning,

- financial reports,

- compliance with the legislative and regulatory framework,

- understanding corporate governance issues,

- the ability to identify and manage risks,

- the impact of technology on its activity,

- adequate gender representation.

In compliance with Law 5178/2025 and in particular with the provisions concerning the balanced

representation of genders on the Board of Directors, it is necessary to update the Company's regulatory

framework and specifically the "Suitability and Eligibility Policy of the Members of the Board of Directors".

The new law provides for an increase in the minimum percentage of representation of the

underrepresented gender on the Board of Directors from 25% to 33%, further strengthening the principles

of equality, diversity and inclusion in the administrative operation of companies. This change requires its

respective incorporation into the approved Regulations of the Company, so that they are fully aligned

with the current institutional and regulatory framework. The Company's Board of Directors, with the

resolution no. 77/2025, of December 17th, 2025, approved the update of the "Suitability-Eligibility Policy"

of its Members (which will be submitted for approval by the upcoming Ordinary General Assembly of

Shareholders), in order to explicitly include this specific quantitative parameter in the said policy.

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(amounts in Euro unless stated otherwise)

7. Fulfillment of the conditions and requirements of the legislative and regulatory provisions

regarding the balanced representation of genders on the Board of Directors

The table below presents the percentage of women among all members of the Board of Directors, among

Executive members, among non-Executive members and among independent members.

Data on gender representation in the Board of Directors

Total

members

Male

members

Female

members

Underrepresented

gender percentage

Members

33%

Executive members

33%

Non-executive members

33%

Independent non-executive members

33%

As it turns out, the Company already fully complies with the provisions of article 3A par. 3 and 4 of Law

4706/2020, which was introduced by Law 5178/2025, with effect from 30.06.2026, as the participation of

the underrepresented gender in the Company's Board of Directors, due to its size, is not less than thirty-

three percent (33%) for all four indicators in the above table.

The Company recognizes that compliance with the relevant provisions on balanced gender representation

in the Board of Directors, in addition to being a legal obligation, is also an indicator of sound corporate

governance and is committed, as a leading Company in its sector of activity, to remaining committed to

its principles of eliminating any type of exclusion or unfair treatment based on gender.

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

Directors

Despite the provisions (Articles 3A par (3), (4), and (5) and 3B of Law 4706/2020, as applicable) coming

into force on June 30, 2026, the already Company's compliance as from this very present moment,

confirms both its constant vigilance in ensuring, through continuous review and implementation of the

necessary measures, its timely compliance with the legislative and regulatory framework, with the aim of

its lawful and smooth operation, as well as its willingness to adopt best corporate practices. Indicative,

but not restrictive, are mentioned:

• Representation in executive positions: Since July 2021, the underrepresented gender has been

represented by 33% of the executive members of the Board of Directors, in order to ensure balance in

decision-making.

• Promotion of women to positions of responsibility: Despite the particular nature of the port industry

in which the Company operates and given that the overwhelming majority of its workforce is employed

in labor-intensive activities (dockworkers, crane and forklift operators, truck drivers, manual services staff,

etc.), the participation of women in all management positions in the Company amounted to 36.5% on 31

December 2025.

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• Continuous monitoring and compliance: The composition of the Board of Directors is assessed annually

by an external consultant (a relevant report is included in the corporate governance statement of the

Annual Financial Report) to ensure that the percentage of the underrepresented gender remains within

or, ideally, exceeds the limits set by law.

• Training: Training executives on gender equality, discrimination prevention, and fair selection enhances

the effectiveness of the practice followed and contributes to changing mindsets, avoiding unconscious

biases, and promoting balanced representation.

• Integration into corporate governance: Promoting balanced gender representation is not a stand-alone

action, but is integrated into the company's governance policies, strategy, and internal procedures, such

as the Company's Suitability Policy and Diversity Policy.

Conclusion

The Company fully complies with the obligations of Article 3A of Law 4706/2020, as applicable. It

constantly strives to improve balanced representation through the above measures and ensures the

continuous monitoring and adjustment of its policies.

On the above, the Company drafted a special annual report in accordance with the provisions of

paragraph 1 of article 3C of Law 4706/2020, which was added by article 7 of Law 5178/2025 as well as in

accordance with the letter no. prot. 12678/8.9.2025 of the General Secretariat for Equality and Human

Rights of the Ministry of Cohesion and Family. The report is posted on the Company's website and was

communicated within the prescribed deadline to the following competent bodies:

a) to the Capital Market Commission, as the competent body for the supervision of listed companies and

specifically for compliance with the obligations of articles 3A, 3B and 3C of Law 4706/2020, as in force,

b) to the "Documentation, Research and Digital Support Department (Observatory)" of the General

Secretariat for Equality and Human Rights of the Ministry of Social Cohesion and Family and

c) to the "Ombudsman".

8. Training Policy for BoD Members and company Executives

The primary obligation and duty of the BoD is to oversee the functions of the Company and ensure the

continuous pursuit of strengthening the long-term financial value of the company and the defense of the

general Corporate interest.

The Training Policy aims at providing Orientation & Training programs to be offered to the BoD members

and other Company Executives (particularly those involved in internal control, risk management,

regulatory compliance and information systems). It aims at building leadership qualities and providing a

platform to share the knowledge, skills and experience gained by the BoD members and other Company

Executives.

The Company invests on the education of BoD members and other Company Executives, with their

individual areas of expertise on an ongoing basis, since the attendance of regular training programmes

and organization of regular in-house or external trainings will enable them:

- to discharge their roles and responsibilities in a most effective manner.

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- to empower and equip the BoD and its Committees with skills and attitudes required to perform their

challenging tasks and play their role manner as per the best corporate governance practices.

- to promote better understanding of professional requirements within the socio-economic and political

environment in which Company is operating.

- to promote an environment conducive to learning and development by serving as a role model for all

the other employees in the corporation.

Within 2025, the BoD Members attended for the fourth year in a row a training seminar of the Hellenic

Corporate Governance Council, with the aim of improving skills and a better understanding of corporate

governance issues.

The Company also shall ensure:

- on the one hand, that upon taking up their duties all BoD members are provided with a full induction

programme, and

on the other hand, that all BoD members update their skills and knowledge on an ongoing basis, in order

to effectively fulfil their duties as members of the BoD and its committees, subject to continuous training

by the Company for this purpose, in accordance with the provisions of the Training Policy.

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

In compliance with the provisions of Law 4706/2020, Circular 60 of the Capital Market Commission, the

Hellenic Code of Corporate Governance and the Internal Operating Regulations of the BoD, the Company

commissioned for third consecutive year, the assessment of the adequacy and effectiveness of the BoD

and its Committees to an external consultant.

The BoD Assessment Policy and the BoD Operation Regulation provides for the annual evaluation of the

effectiveness of the BoD (as a collective body), its committees and their individual members, while this

evaluation is provided by an external consultant every three years. To this end, as mentioned above, the

Company awarded to the company KPMG Single Member Societe Anonyme for the Provision of Advisory

Services to carry out the evaluation process.

The evaluation concerned the collective abilities of the BoD as a body, its committees and the individual

abilities of its members. The evaluation was carried out using evaluation tools provided by the external

advisor (filling out an electronic questionnaire, etc.) and through personal interviews. The evaluator had

access to the BoD’s and BoD’s Committees operating details.

The purpose of the evaluation was to determine whether the Board and its Committees function

effectively and efficiently, based on the Board Directors’ responses to the online questionnaires covering

a wide range of topics, documentation review and selected interviews with Board Directors.

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

Evaluation of the BoD as a Body and its Committees, as of 18th of March 2026:

• No significant weaknesses have been identified in the performance of the Board, its Committees,

or individual Board members. Furthermore, there are no immediate corrective actions required

under the current legislative and regulatory framework.

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• The Board’s performance remains stable, operating effectively, while, also, fostering an

environment that encourages open and constructive discussions, where all Board Directors feel

confident in expressing their views.

• The Board Committees (Audit Committee, Nomination Committee, Remuneration Committee)

are functioning effectively, with each contributing significantly to the overall governance and

decision-making processes of the Board, with the Nomination Committee demonstrating a strong

contribution to the Board’s operations.

• In respect to the individual evaluation of each Board member, all Board members perform their

duties effectively and demonstrate commitment to their role, as does the Chairperson of the Board. The

Board has taken proactive steps to develop a long-term strategic plan, enhancing alignment with the

Company’s broader business objectives.

The above result is a confirmation of both the proper functioning of the BoD and its compliance with the

current legislative and regulatory framework.

Independently of the assessment of the adequacy and effectiveness of the BoD and its Committees by

an external consultant, in the context of the obligations set out in article 1.13 of the Hellenic Corporate

Governance Code, was conducted the annual collective evaluation of the Executive BoD members

performance by non-Executive PPA SA BoD members.

In that framework is mentioned that executive BoD members:

- fulfill all the suitability and credibility criteria included in the Suitability Policy of the BoD members

for appropriately exercise their responsibilities for the benefit of Shareholders.

- proved their ability to face and overcome difficult situations and the ongoing challenges such as the

Red Sea crisis, which affected the supply chain and port industry (especially for Mediterranean area).

In particular, despite the above disruptive conditions, through efficient management, the Company

continued its upward progress, achieving growth in most of its business segments resulting to

historically high performances (Record-highest ever revenues) that clearly reflect the successful

implementation of Management's plans.

- successfully implemented the transition to the new EU reporting requirements (CSRD) by engaging

internationally recognized auditing firms in the drafting and assurance of these reports, ensuring in

this way not only the company’s compliance with the regulatory framework but also the high quality

of provided services.

- - successfully contributed to defining the company's strategic orientation, through the preparation

of its strategic and business plan by a renowned external consultant, with the ultimate goal of

achieving sustainable growth and optimizing its value, for the benefit of all parties involved (Major

Shareholder, Hellenic State, Investors).

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(amounts in Euro unless stated otherwise)

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

Board of Directors Executive Chairman

• Organizes and coordinates the Board and ensures effective functioning and organization of Board

meetings.

• Promotes good relations between BoD members and a culture of dialogue.

• Contributes effectively to the work of the BoD.

• Maintains the business plan and sets long-term goals for the organization.

• Monitors the results of the day-to-day actions and decisions of the Board.

• Identifies risks related to the Board members’ work.

Chief Executive Officer

• Implements Board decisions throughout the organization.

• Presents company goals, objectives, and performance to the Board.

• Establishes the tone for the company’s culture and vision.

• Manages the company’s resources and coordinated the works of all departments.

• Manages market placement and explores expansion of commercial opportunities.

• Perform duties of strategic planning and oversight.

Chief Financial Officer

• Provides guidance and management on financial issues.

• Manages the processes for financial forecasting and budgets, and overseeing the preparation of all

financial reporting.

• Provides advises on long-term business and financial planning.

• Establishes and develops relations with shareholders and investors community.

Conclusion

In this context, for the year 2025, the non-executive BoD members, in the field of executive BoD

members performance evaluation unanimously concluded that the Executive BoD members of the

Company:

- have the skills, the knowledge of the PPA’s Environment and the necessary experience on

Company’s functions and activities.

- are ensuring Company’s efficient management, operation and supervision, in order to serve the

long- term interests and sustainability of the Company.

- are distinguished for their integrity, objectivity and professionalism and have worked well

together just as harmoniously.

- have a healthy and transparent working relationship.

- consistently educate themselves on external landscape and industry trends and they concern for

the education of the whole BoD training and education.

- respond quickly and effectively to crises/unforeseen events

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(amounts in Euro unless stated otherwise)

Given the term of office of the current BoD, which started in summer 2025, it was also judged by the non-

executive BoD members of the Company that the performance of the Board of Directors and its executive

members will be evaluated and by the Ordinary General Assembly, at the same time of evaluation of the

Company’s annual financial statements and the relevant reports in combination with the results of the

year and the general course of the Company's operations.

10. External professional commitments of the BoD members

With a solemn declaration, the BoD members informed twice, about their other professional

commitments, that they do not participate in more than five (5) BoD of listed companies. For the position

of the President, the number is limited to three participations of other BoD based on the Hellenic

Corporate Governance Code provision. Detailed CV’s of the BoD members are posted on the Company's

website.

The GA of July 8th 2025 approved the election of existing BoD members for two years. The term of the

above BoD expires on July 8th 2027.

11. BoD members' Remuneration

The remuneration of the members of the BoD is determined by the Remuneration Policy, which was

prepared in the context of article 110 of Law 4548/2018 and includes all the information provided for in

article 111 of Law 4548/2018. The existing Policy was approved by the Extraordinary GA of August 2nd,

2023 (quorum: 79.99%, votes in favor: 98.1% of the represented shareholders). The Policy is available

on the corporate website www.olp.gr in the most specific option: Organization > Corporate Governance

> Policies.

Regarding Executive BoD Members

During the fiscal year 2025 and in compliance with the approved Company Remuneration Policy, the

remuneration of the Executive BoD Members shall be analyzed as follows:

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(amounts in Euro unless stated otherwise)

Fixed Remuneration of Executive BoD Members

During the fiscal year 2025, the Company held contracts of employment with the Executive Members of

BoD, Mr Su Xudong (CEO), Ms LI Jin (CFO). These contracts of employment were for an indefinite period

and included a monthly salary and ancillary benefits, and applied to those requirements of the labor law

relating to periods of notice, retirement and the payment of legal compensation in the event of

termination of the contract. Furthermore, the above Executive BoD Members received fees for their

participation in the meetings of the BoD (in proportion to the period of expiry or the beginning of their

term of office within the year) which had been approved by the Decision of 02/08/2023 of Annual GA

(40,000.00€ annually per Member).

Variable remuneration of Executive BoD Members

During the fiscal year 2025, no variable remuneration was paid to any Executive Member of BoD. All the

above remuneration of the Executive BoD Members shall be subject to the deductions provided for in

the applicable tax and labor legislation.

Regarding Non-Executive BoD members

During the fiscal year 2025 and in compliance with the approved Company Remuneration Policy, the

remuneration of the Non-Executive BoD Members shall be analyzed as follows:

Fixed remuneration of Non-Executive BoD Members

During the fiscal year 2025, the Non-Executive BoD members received fees for their participation in the

meetings of BoD, which were approved by the Annual GA Decision of 08.07.2025 (€40,000.00 annually

per Member).

In addition, is granted a gross annual amount for the independent members of the BoD and the FUND

representative, for their participation in the meetings of the BoD Committees (Audit - Remuneration -

Nominations Committees), regardless of the total number of Committees in which they participate.

Variable remuneration of Non-Executive BoD Members

During the fiscal year 2025 no variable remuneration was paid to any non-executive BoD member. All

the above remuneration of the Non-Executive BoD members shall be subject to the deductions provided

for in the applicable tax and labor legislation.

Shares and/or stock options for shares

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

Use of retrievability of variable remuneration

The Company did not make use of the possibility to recover variable remuneration during the fiscal year

2025.

It is to be noted that in 2025, the Company prepared the members of the BoD remuneration report for

fiscal year 01.01.2024-31.12.2024 in accordance with article 112 of Law 4548/2018.

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(amounts in Euro unless stated otherwise)

12. Disclosure of direct and indirect conflicts of interest

The Company, exercising the exclusive right to own, use, manage, maintain, improve and exploit the

Port Concession Items, provides a wide range of port services and facilities. In the context of the

provision and in the exercise of these activities it is possible to create conflict of interest situations

detrimental to the interests of the Company, its shareholders, its customers and its suppliers.

The Company, in accordance with the current regulatory framework for the defense of its own interests

and the interests of its shareholders, its customers and its suppliers, establishes the following Policy and

the following internal procedures, which include organizational measures aimed at Identifying,

Preventing and Dealing with Conflict of Interest Situations.

As Conflict of interest" is meant the situation that arises when either the private interests, personal

relationships, or any external activities of the "covered" persons could unjustly influence their decisions

of any kind in the performance of their obligations and duties. That includes any professional, personal,

family, financial condition, which affects or could unfairly affect a person's ability to assess a situation

or make a decision independently and impartially, and which is likely to result in jeopardizing the

interests of the Company for the benefit of another interest.

In accordance with the Policy, all members of the BoD of the Company and any third person to whom

duties have been assigned by them must, notify, in a timely, adequate and written manner, the other

members of the BoD and the Top management of the direct or indirect conflict of interest of which they

are aware of and which has arisen from the Company’s transactions and/or during the performance of

their duties.

Procedures of preventive measures to avoid situations of conflict of interest

The Company takes measures and implements policies and procedures for the determination of the

means of dealing with conflict of interest situations, as described:

Submission of a Conflict of Interest and Confidentiality Declaration.

In order to effectively identify and prevent situations of conflict of interest, the Company has established

an obligation to submit a declaration of non-conflict of interest of the members of the BoD as well as

members of Top Management, who are obliged at least

at the beginning of each year to submit such

declarations.

In addition to the above declaration and as a further verification and cross-check of the Independent

Members declaration’s content accuracy, the following certificates are collected by the BoD Secretariat:

- Certification from the Financial Management Department, that after checking the accounting records

and books, the candidate for election as BoD Independent member does not receive fees or benefits,

except his remuneration (in case of re-election) for his term of office as a BoD member.

- Certification by the Legal Department that, following check of the contract archive maintained, the

candidate for election or re-election as an Independent BoD member has not signed into any type of

contract with the Company.

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- Certification from the BoD Secretariat, Public Relations & Investors Relations Department, that

following a check of the Shareholding Registry, the candidate for election or re-election as an

Independent BoD member, does not own a percentage of the Company's shares equal to or greater

than 0.5%.

Code of Conduct

The Company has established and implements a Code of Conduct, which provides specific principles for

avoiding conflict of interest situations for all Company's staff.

Code against Corruption and Bribery

The Company is committed to its activities in accordance with the applicable National and European

Legislation and commercial customs and this commitment is incorporated into the present Code.

Company considers that on Company level, participation in corruption phenomena inflicts the

reputation, credibility of the Company itself, causes penal consequences and other legal risks as well as

financial damage (in the case of fines imposition), increases operational cost, affects the loyalty and faith

of Company personnel, creates negative corporate culture and causes exclusion from potential business

opportunities.

Remuneration

The Company takes the necessary measures so that the remuneration, the evaluation and the assigned

responsibilities do not encourage behaviors by the "covered" persons that may lead to conflict of

interest situations.

Gifts and personal benefits

The acceptance and offer of gifts and other personal benefits is governed by the relevant policies and

procedures of the Company, which are designed to prevent the use of the position within the Company,

in order to provide personal benefits for himself or for “related persons”.

Donations and Sponsorships

The Company has established and implements a Donations and Sponsorships Policy, which specifies on

the one hand the conditions and characteristics that should govern the sponsored actions and the

sponsored bodies, and on the other hand the procedure that should be followed up to the final stage of

their implementation.

BoD members' fees

The Company has established and applies principles and rules regarding the remuneration of the

members (executive and non-executive) of the BoD, in a transparent, clear and understandable manner

in accordance with the Company's Remuneration Policy in order not to encourage behaviors which may

lead to situations of conflict of interest or the taking of excessive risks. In this direction, the

Remuneration Committee of the Company's BoD operates as an independent and objective body,

consisting of non-executive members, the majority of whom are independent, in order to provide

guidance in a transparent manner on issues related to the remuneration of the BoD members and Top

Management.

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13. Monitoring conflict of interest situations

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

The Internal Audit Department reports to the BoD of the Company cases of conflict of private interests

of the BoD Members or Executives with the interests of the Company, which they ascertain during the

exercise of their duties.

In the event of a conflict of interest being identified, the BoD undertakes to deal with it, deciding on any

corrective measures or consequences, including their escalation according to the seriousness of the

situation and the potential invitation of negative consequences to the Company’s interests (indicative

and not limited to: temporary removal from the position of responsibility, suspension of performance

of duties, non-continuation of performance of duties, imposition of penalties provided for by law).

14. Communication with stakeholders and shareholders

Dialogue with other stakeholders

As a responsible corporate organization that prioritizes transparency and continuous communication of

its actions and activities, Company interacts systematically with its Stakeholders, who play an important

role in the Company's decision-making process. The Company's objective is to create the conditions for

a continuous two-way dialogue with the interested parties in order to understand the effects of its

activity and to improve its performance taking into account the opinion, needs, expectations and

proposals of all the parties it affects and they influence the decision-making and the formulation of the

Company's strategy.

For this reason, and in the context of conducting a materiality analysis, the Company redefines the

stakeholders who participate in, influence, and are significantly affected by its business activities, in

accordance with its principles/values, strategy, market, and the proximity of its activities to them.

The materiality analysis is a key to identifying, defining, and evaluating the priorities set by the Company

for sustainable development. To this end, it has been implementing a materiality analysis systematically

since 2018. In addition, the Company, in the context of its interaction with stakeholders, continuously

assesses its impact on people and the environment. This regular review allows for the timely

identification and management of the impacts of its activity, even if these change or new ones arise.

In 2025, the Company proceeded to a double materiality analysis for the second time, taking into

account the European Sustainability Reporting Standards (ESRS), while at the same time adhering to the

requirements of the GRI Standards, as the main reference standard for determining the content relating

to the completeness of the data, the double materiality of the issues, the response to the needs of

stakeholders and the overall framework for the Company's approach to Sustainable Development, as

well as all the principles for its quality.

Four main steps were followed in this process, to understand and address the most critical issues that

shape Company’s sustainability performance and financial success:

Step 1: Contextualization and Mapping

Step 2: Material Impact Identification

Step 3: Assessment of Financial Risks and Opportunities

Step 4: Double Materiality Results

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(amounts in Euro unless stated otherwise)

Results

Following the ESRS process and evaluating the outcomes of the interviews with internal and external

stakeholders, material topics were identified. The impact materiality assessment process enabled

Company to identify topics which considered material to the organization, topics which are recognized

for promoting a positive impact on one or more dimensions (environment, economy and people), and

topics were identified as having the potential to cause a negative impact on one of these dimensions.

The financial materiality assessment supported the process of identifying which of these material topics

are associated with financial risks and opportunities for the organization. Were identified financial

opportunities and financial risks to which Company is potentially exposed. As a final step, the double

materiality score was calculated considering both impact and financial materiality assessments.

Communication with the shareholders and the investor community

The BoD Secretariat, Public Relations and Investors Relations Department is in constant communication

with shareholders, institutional investors, financial analysts and the investment community in general,

providing information (based on publicly available information) on the progress of Company’s activites

and current business developments through:

• teleconferences that takes place to comment on the financial results.

• participation in roadshows, both in Greece and abroad: (a) WOOD’s Greek Retreat, Athens, May

2025, (b) Geneva Investment Conference, June 2025, (c) Morgan Stanley and Athens Stock Exchange

Greek Investment Conference, London, December 2025, (d) WOOD’s Winter Wonderland EMEA

Conference, Prague, December 2025.

• one-on-one meetings with institutional investors.

• presentations of its strategy (Investor Days)

• presentation of the Annual Financial Statements during the Annual General Meeting where

comments and questions of the shareholders are answered by the Management. For any questions

that did not manage to be answered within the time of the General Meeting, the BoD Secretariat,

Public Relations and Investor Relations Department contacts the shareholders who raised the

questions directly for further clarifications.

Share course

In 2025, the General Index of Athens Stock Exchange showed an increase of 44.3%. The share of the

Company recorded an increase of 36.0%, closing at €40.80 on 31.12.2025, with an annual average

transaction volume of 10,478 pieces/day and an average price of €40.67.

On 11/06/2025 the share of the Company closed at € 49.70 which is an all-time high. The next day intraday

reached the high of € 49.95. The year low was intraday on 20/01/2025 at € 28.30.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The following table presents the average closing price and the average daily trading volume of the

Company's share per month, for the financial year 2025 in relation to the corresponding time period of

2024.

Average Closing Price

(€)

Average Daily Volume

(# pieces)

2025

2024

2025

2024

January

30.16

24.28

6,810

9,055

February

32.30

25.34

8,064

10,667

March

33.22

26.72

7,727

22,276

April

38.36

25.27

15,823

10,476

May

43.80

24.74

17,528

7,235

June

45.55

25.41

17,834

7,445

July

47.19

26.57

8,082

4,600

August

46.24

25.91

14,452

21,884

September

43.93

27.15

5,973

6,229

October

43.58

27.68

7,316

9,043

November

41.34

29.87

10,081

9,222

December

40.84

30.22

6,859

7,412

The diagram below presents the development of the Company's stock for 2025, in relation to the

corresponding progress of the General Index of the Athens Stock Exchange.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

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

Exchange General Index

Regarding the dividend distribution, taking into account, among other things, the Company's progress,

prospects and investment plans, the Ordinary General Meeting of the Company's shareholders on

08.07.2025 approved the distribution of a dividend of a gross amount of € 1,92/share for the financial

year 2024 before withholding tax (according to current tax legislation) against € 1.336 per share for the

previous financial year.

Over the past decade, the dividend per share has increased from € 0.0892 for the financial year 2016 to

€1.92 for the financial year 2024, an increase of 2,052.47%. The proposed dividend for distribution for

the year 2025 is € 1.896/share, with the dividend yield at 4.6% (based on the closing price on 31.12.2025)

and the dividend payout ratio stable at 55%.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The diagrams below show the course of the dividend distributed by the Company per share and overall,

combined with dividend yield and dividend payout ratio, during the economic period 2016-2025.

Diagrammatic Illustration of Dividend Distribution - Dividend Yield

Diagrammatic Illustration of Total Dividend Distributed - Dividend Payout Ratio

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

Page 66 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The company has a wide shareholders base with a total of 4,426 shareholders (reference date

31.12.2025), the majority (91.5%) of which are shareholders with less than 1.000 shares.

However,

the biggest part of the share capital, besides “COSCO SHIPPING (Hong Kong) Co., Limited” which holds

67.00% and the “Hellenic Corporations of Assets and Participations S.A.” which holds 7.14% of the share

capital, is held by foreign and Greek institutional investors.

Number of

Investors

Number of

Percentage (%)

0<Shares<=1.000

4,050

604,530

2.42%

1.000<Shares<=10.000

295

887,194

3.55%

10.000<Shares<=100.000

2,178,113

8.71%

100.000<Shares<=1.000.000

2,795,723

11.18%

1.000.000<Shares<=10.000.000

1,784,440

7.14%

10.000.000<Shares

16,750,000

67.00%

Total:

4,426

25,000,000

100.00%

Page 67 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

C. Audit Committee (AC)

The AC operates within the framework of the provisions of Article 10 of Law 4706/2020 “on corporate

governance” and in accordance with the provisions of relevant circulars and decisions of the Hellenic

Capital Market Commission, as in force from time to time (indicatively the circulars/letters

1302/28.04.2017, 1508/17.07.2020, 1149/17.05.2021, 427/21.02.2022) of the Directorate of Listed

Companies of the Hellenic Capital Market Commission.

Composition of the Committee, skills and experience

he existing Audit Committee operates in accordance with the provisions of article 44 of Law 4449/2017.

It is a Committee of the Board of Directors and is composed of three (3) non-executive members of the

Board of Directors, of which two (2) are independent under article 9 of Law 4706/2020, who were

appointed by the BoD meeting that took place on 08.07.2025.

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

- Kwong Che Keung Gordon, Board of Directors independent Non-Executive Member and Chairman of the

Audit Committee.

- ARVANITIS Nikolaos, Board of Directors independent Non-Executive Member and Member of the Audit

Committee.

- POLITIS Dimitrios, Board of Directors Non-Executive Member and Member of the Audit Committee.

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

- ZHOU Zhonghui, Board of Directors independent Non-Executive Member and Chairman of the Audit

Committee.

- LIN Lan, Board of Directors independent Non-Executive Member and Member of the Audit Committee.

- POLITIS Dimitrios, Board of Directors Non-Executive Member and Member of the Audit Committee.

Detailed CVs of the Audit Committee members are posted on the Company's website.

The term of office of the Audit Committee is equal to the term of office of the elected Board of Directors

of the Company, whose term of office is two years, ie until 08.07.2027 and which is extended, in

accordance with the provisions of article 85, par. c of Law 4548/2018 until the expiration of the deadline,

within which the next Ordinary General Assembly must be convened in 2027 and until the relevant

decision is taken.

The members of the Audit Committee, all non-executive members, did not hold positions incompatible

with their status during 2025. Their objectivity and independence were ensured, in the absence of any

transaction with the Company which could affect them.

The members of the Committee have competencies related to the sectors in which the Company

operates, as they have as a whole sufficient knowledge in the field of industrial products and services, in

auditing or accounting and experience in the areas of Corporate Governance and Internal Control

Systems.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Evaluation of the AC

The Chairman of the Committee ensures the organization of the evaluation of the work of the Committee

on an annual basis. In the above context, it was carried out both a self-evaluation process of the AC and

an evaluation process by an external consultant based on the provisions of the Corporate Governance

Code (article 3.3.14), of the Law 4706/2020 and the Circular 60 of the Capital Market Committee.

The above process was carried out using evaluation tools provided by the external advisor (filling out an

electronic questionnaire, etc.) and through personal interviews, which referred to the collective ability of

the AC as a body, as well as to the individual abilities of its members.

The conclusion of the above evaluation of the external consultant stated, among other things, that the

Audit Committee is functioning effectively contributing significantly to the overall governance and

decision-making processes of the Board.

The above result is a confirmation of both the proper functioning of the AC and its compliance with the

current legislative and regulatory framework.

Purpose - Responsibilities

The main objective of the Audit Committee is to provide support to the Board of Directors of the Company

in the context of issues falling within its responsibilities, in accordance with the applicable legal and

regulatory framework and its Operational Regulation.

The members of the Committee as a whole have proven sufficient knowledge in the field in which the

Company operates, while the Chairman of the Committee has proven sufficient knowledge in issues of

accounting and auditing.

The main responsibilities of the Audit Committee are the following:

• Monitoring the financial reporting process.

• Monitoring the effective operation of the Internal Control System and the Risk Management System.

• Monitoring of proper functioning of the Company’s Internal Audit Department.

• Monitoring of the statutory audit of Financial Statements.

• Supervision of the official announcements concerning the Company's financial issues.

• Review and monitor issues related to the existence and maintenance of objectivity and independence

of the External Auditor or audit firm, particularly regarding the provision from them to the Company and

other non-audit services.

• Review the Financial Statements prior to approval by the Board of Directors.

• The Company's compliance with legal and regulatory framework of operation. The responsibilities and

the way of operation of the Audit Committee are described in the Operational Regulation of the

Committee, which has been approved by the Board of Directors.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

During 2025, the Audit Committee met in total fourteen (14) times (including cases of decisions issuing

through circulation of minutes), with the participation of each member in the meetings of the Audit

Committee amounted to 100%.

In order to ensure the Company’s independence, the meetings took place without the presence of other

top management executives, except in cases where their presence was deemed necessary (such as the

cases of discussion of the review of the interim and annual Financial Reports). All Committee members

participated in all the meetings and all Committee decisions were taken unanimously.

The main issues handled by the Audit Committee in 2025 were the following:

• Monitoring and evaluation in collaboration with the competent bodies of the Management and the

External Auditor of the Company the process of preparation of the semi-annual and annual Financial

Statements, prepared in accordance with the International Financial Reporting Standards, and

confirmation of their accuracy completeness and consistency, according to the information provided to

its members.

• Discussion with the External Auditor and receiving information about their cooperation with the

Management in issues of financial control.

• Discussion and provision of its agreement to all official announcements concerning the Company's

financial issues.

• Evaluation of the results of the audits carried out by the Internal Audit Department.

Approval of the annual internal audit program for the current year.

• Monitoring the effective operation of the internal control and risk management system, in accordance

with international standards and the applicable legal and regulatory framework.

• Provision of its consent to the proposal of the Board of Directors to the Ordinary General Assembly of

Shareholders for the appointment of the auditing company “ERNST & YOUNG (HELLAS) Chartered

Auditors Accountants S.A.”, (with Institute of Certified Public Accountants of Greece (SOEL)) register

number 107”, for the mandatory audit of the Company for the year 2025.

• Evaluation and confirmation the objectivity and independence of the cooperating External Auditor,

receiving a relevant letter.

• Assessing the nature and cost of the non-audit services provided by the auditing firm “ERNST & YOUNG

(HELLAS) Chartered Auditors Accountants S.A.” regarding the regular audit of the fiscal year 2025, in

accordance with the provisions of Law 4449/2018 and Regulation 537/2014 of the EU.

• Awarding of services for conducting the Control System evaluation process of PPA S.A.

• Awarding of services for conducting the Periodic Evaluation Policy of the Corporate Governance

System of PPA S.A.

• Internal Control System evaluation process

• Awarding of external assurance services provision for the information included in the PPA SA Corporate

Sustainability Report in accordance with European Directive 2022/2464 for the year ended Dec. 31, 2025.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

• Approval of Risk Management Unit Operational Regulation of.

• Approval of Risk Management Unit Policy, Methodology & Procedures.

• Monitoring of Regulatory Compliance Unit action plan implementation for 2025 and approval of 2026

respective annual Action Plan.

In the context of non-audit services, whose provision by the Statutory Auditor is not prohibited by law,

the Committee applied judgement on and assessed the following:

i. threats to independence and objectivity resulting from the provision of such services and any safeguards

in place to eliminate or reduce these threats to a level where they would not compromise the auditors’

independence and objectivity,

ii. the nature of the non-audit services,

iii. whether the skills and experience of the audit firm make it the most suitable supplier of the non-audit

services,

iv. the fees incurred, or to be incurred, for non-audit services both for individual services and in aggregate,

relative to the audit fee, including special terms and conditions (for example contingent fee

arrangements), and

v. the criteria which govern the compensation of the individuals performing the audit.

During 2025, the Committee examined the non-audit services that were proposed to be performed by the

external auditor for the Company, which concerned pre-agreed procedures, and after evaluating the

nature of proposed services and receiving relevant clarifications, declarations and assurance from the

external auditor, considered that they did not pose a threat to the external auditor's independence in

accordance with the provisions of article 44 of Law 4449/2017 and article 5 of Regulation (EU) 537/2014.

• Information towards the Board of Directors of the Company about the issues within its competence.

In carrying out its work in general, the Audit Committee had full access to all the information necessary

for the effective performance of its duties. The discussions and the decisions of the Audit Committee are

recorded in minutes signed by the members.

Α. Audit Committee Performance in relation to:

Mandatory External Audit (article 44, par. 3, case a of the Law).

Particularly:

a) Regarding the performance of the statutory audit (external audit) of the Company financial

statements, were not found significant deviations in the recognition, valuation and classification of assets

and liabilities and we consider that the Management's assumptions and estimates are reasonable. We

have found that the relevant disclosures in the notes to the financial statements are adequate.

b) During the mandatory inspection, were performed the following procedures:

1. Control of the process of registration and accounting of expenses, fixed assets, sales and other

accounting subjects.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

2. Control of the tax issues.

3. Control of the processes and procedures of Financial Management Department.

4. Review of External Auditor Report.

5. Evaluating risks of pending litigation

In the exercise of our responsibilities, were not identified any material weaknesses which may have an

impact on the truth and fairness of the financial information presented to shareholders.

It is noted that the Audit Committee always takes into account the content of any additional reports

submitted to it by the External Auditor hired by the Company, which contains the results of the statutory

audit performed and meets at least the specific requirements in accordance with Article 11 of Regulation

(EU) No 537/2014 of the European Parliament and of the Council of 16 April 2014.

In particular, based on the Supplementary Report delivered to the Audit Committee, there is no material

change, compared to the previous year, in the accounting principles and assumptions. Furthermore, no

material errors were found which should have been corrected by the Company's Management.

c) Within the framework of its responsibilities, was informed about the procedure and the schedule of

preparation of the financial information by the management of the Company, as well as was informed by

the External Auditor on the statutory audit program for the year 2025 before its implementation. Was

evaluated and made sure that this program covered the most important areas of control, considering the

key areas of business and financial risk of the Company. We also held meetings with the Company's

management / responsible executives and the External Auditor, during the preparation of the financial

statements, during the planning stage of the audit, its execution and during the stage of preparation of

the audit reports, respectively.

d) It was taken into account and examined the most important issues and risks that may have an impact

on the Company's financial statements, as well as the significant judgments and estimates of

management during their preparation. Specifically, were examined and evaluated in detail the following

issues with reference to specific actions on these issues:

(d1) Regarding the important judgments, assumptions and estimates in the preparation of the financial

statements, were found that they are reasonable.

( (d2) Regarding the disclosures for the above issues required by IAS / IFRS, were found that the

disclosures included in the financial statements were sufficient.

(d3) Regarding the transactions with related parties, was not found any significant unusual transactions.

e) Finally, there was timely and substantial communication with the External Auditor of the preparation

of the audit report and its supplementary report to the Audit Committee.

e) Were reviewed the financial reports before their approval by the Company's Board of Directors and

considered that were complete and consistent in relation to the information that was brought to

attention of Audit Committee, as well as to the accounting principles applied by the Company.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Based on the aforementioned, it was found that the Company's financial statements are in accordance

with the mandatory by law content and preparation framework and the Committee assessed that the

annual financial report, together with the financial statements and the Company's management report,

depict in a true, correct, balanced and comprehensible manner the evolution, performance and position

of the Company and provide the required information to the shareholders.

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

In relation to the process of preparing the financial information, the Audit Committee monitored,

examined and evaluated:

(1) the mechanisms and systems of flow and dissemination of financial information produced by the

involved organizational units of the Company and

(2) other disclosed information in any way (e.g. stock market announcements, press releases) in relation

to financial information.

In the exercise of our responsibilities, we did not find any material weaknesses in the process of compiling

the financial information.

In particular, the Audit Committee held meetings to receive briefings on the financial information process

on the financial statements and was informed by the Chief Financial Officer on the Company's financial

statements, which were drafted in accordance with IFRS. The Audit Committee was also informed about

the accounting principles followed by the Company for the preparation of the said financial statements,

which did not differ from those adopted by the Company in the previous fiscal year, apart from the

immaterial changes reflected in the financial statements, and for the main issues that occupied the

Department of Financial Management during the preparation of these financial statements.

During the exercise of the responsibilities of the Audit Committee, no significant weaknesses were found

in the process of preparing the financial information.

Financial Results for the first half of 2025

The Audit Committee was informed by the Financial Management Department of the financial results of

the 1st semester of 2024 and no gaps or discrepancies were found in the assurances provided for the

correctness and accuracy of the information. The Committee prepared a relevant report on the overview

of the company's six-monthly individual and consolidated financial statements to the Board of Directors.

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

The Audit Committee was informed by the Financial Management Department about the financial results

of the 1st and 3rd quarters of 2025 and brought to its attention a draft of the relevant announcement to

the investing public. The Committee, after receiving assurances about the correctness and accuracy of

the information to be made public, expressed its satisfaction with the Company's progress.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Procedures of internal control and risk management systems and the internal control unit (article 44,

par. 3, point B' of the Law).

Particularly In connection with the monitoring, examination and evaluation of the adequacy and

effectiveness of all the policies, procedures and safety controls of the Company regarding the internal

control system, the corporate governance system and the assessment and management of risks, in

relation to the financial information, the Audit Committee proceeded to actions below:

1. The assignment of services for the "Assessment of adequacy and effectiveness of Internal Control

System Evaluation" by an external auditing company (KPMG Certified Auditors S.A.) in accordance with

the provisions of Law 4706/2020, the Decisions of the Capital Market Commission and any other relevant

legislation on Corporate Governance, for the period 01.01.2023 – 31.12.2025.

2. The assignment of services for the "Assessment of adequacy and effectiveness of Corporate

Governance System Evaluation" by Regulatory Compliance Unit in accordance with the provisions of Law

4706/2020, the Decisions of the Capital Market Commission and any other relevant legislation on

Corporate Governance, for the period 01.01.2025 – 31.12.2025.

3. After reviewing the approval of the following items related to the Risk Management function:

− Risk Management Report

− Risk Appetite Statement

4. Evaluation of the functioning of the Internal Audit Department according to the professional

standards as well as the current legal and regulatory framework and evaluation of the work it performs,

its adequacy and effectiveness, without however affecting its independence.

5. Overview of the disclosed information regarding the internal audit and the main risks and

uncertainties of the Company in relation to the financial information.

6. Evaluation of the organizational structure of the Internal Audit Department and the Regulatory

Compliance and Risk Management Functions, and any staffing weaknesses of the above units, i.e. if they

have the necessary means, if they are insufficiently staffed with potential with insufficient knowledge,

experience, and training.

7. Assessing the existence or non-existence of restrictions on the work of the Internal Audit

Department and the functions of Regulatory Compliance and Risk Management as well as their

independence that they must have, to perform their work unobstructed.

8. Evaluation of the annual audit program of the Internal Audit Department before its implementation,

taking into account the main areas of business financial risk as well as the results of previous audits.

9. Considering that the annual audit program, in conjunction with any corresponding medium-term

programs, covers the most important areas of control and financial information systems.

10. Organizing regular meetings with the head of the Internal Audit Department, as well as with the

Managers of Regulatory Compliance and Risk Management functions on matters within their competence

and gaining knowledge of their work and their regular and ad-hoc reports.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

11. Monitoring the effectiveness of internal control systems through the work of the internal control

unit and the work of the External Auditors.

12. Overview of the management of the main risks and uncertainties of the Company and their periodic

review, evaluating the methods used by the Company to identify and monitor the risks, the treatment of

the main ones through the internal audit work of the Internal Audit Department as well as their disclosure

in the published financial information in a proper manner.

The Audit Committee was informed and has evaluated the reports of the audit program for the year 2025

and evaluated and approved the audit program of the year 2026 (before its submission for discussion to

the Company’s BoD) having thoroughly considered the proposed areas for scrutiny, in line with the

Internal Audit Department proposals, and judging that the control environment in relation to risk

assessment is adequately reflected, in line with the risk-based approach followed by the regulatory

framework and International Standards on Internal Auditing.

The Audit Committee, was informed of the following main risks for the year 2025:

• Risk of loss of assets.

• Property insurance.

• Third Party Liability and Employer’s Liability.

• Maximum Probable Loss (MPL) analysis.

• Business Risks Associated with the Company's business activities.

• Fair Value.

• Credit Risk.

• Foreign Exchange Risk.

• Interest rate risk.

• Liquidity risk.

• Commercial - Operation Risk, associated with:

Wider Economic Environment.

Economic instability.

Energy policy.

Non-expanded clientele (Container terminal).

Geopolitical conditions.

• Legal risk, related to:

Pending legal claims against third parties.

Legal claims of third parties.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

In the exercise of the responsibilities of the Audit Committee on the above-mentioned issues, it was not

identified any material weaknesses that may have an impact on the truth and fairness of the financial

information presented to shareholders.

The Audit Committee continuously kept the Board of Directors of the Company informed about its

activities.

B. Sustainable development policy followed by the Company

In accordance with the provisions of article 44 par. 1 of Law 4449/2017, as replaced by the provisions of

article 74 par. 4 case 9 of L.4706/2020, the Audit Committee is obliged to include in the annual report of

the proceedings to the ordinary General Assembly also a description of the sustainable development

policy followed by the Company.

The Company's long-term commitment to Sustainable Development has already led to its participation in

the ATHEX ESG Index of the Athens Stock Exchange, while it takes into consideration both the new

legislation on Corporate Governance and the principles of the EU Taxonomy.

The Company, the Sustainable Development seeks, over time, to create value for its stakeholders, i.e.

shareholders, customers, employees and society in general.

To achieve this goal, the Company places particular emphasis on, among others, the training and

development of its personnel, health and safety at work, as well as respect for the environment, following

the principles of sustainable development.

Responsible operation is a continuous commitment to action of substance, in order to generate value for

all stakeholders that meet the modern needs of society and contribute in general to its prosperity. The

Company has a specific strategy, which focuses on the important issues related to its activity and seeks

its continuous responsible development, focusing on the critical pillars of business responsibility:

Economy, Society, Environment.

Sustainable development is an integral part of the Company's business practice model and culture. In the

context of the implementation of Sustainable Development, the Company develops activities, among

others, in the following areas:

The policy, the results of the Company's performance in the issues of Sustainable Development, as well

as the implementation of the programs and the achievement of the objectives, are published on an annual

basis, in order to fully and comprehensively inform under a general framework of transparency.

The Company supports the United Nations 2030 Agenda, as set out in the 17 Sustainable Development

Goals, with a view to actively contributing to their achievement by promoting the prosperity and security

of the people; environmental protection and the fight against poverty.

The Company’s priority is the fulfillment of the objectives that are directly related to the activities and

challenges of the sector in which it operates, as well as to the essential issues arising from the Corporate

Responsibility and Sustainable Development Report, which details the connection of the programs and of

the Company's actions.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Company recognizes that international ESG indicators are a strategic tool to support investors in

identifying risks and opportunities linked to the sustainability of their investment portfolio. Subsequently,

simultaneously responding to the challenges of the new environment, it builds a sustainable development

strategy aiming at minimizing the negative impact that its activities may have.

Environmental responsibility

The Company recognizes its leading position in the Mediterranean region and in the wider maritime sector

and takes action to prevent and mitigate its environmental impacts, in accordance with European,

national and international environmental laws and regulations. Its goal is to achieve balanced economic

growth combined with environmental responsibility.

The Company implements a certified Integrated Quality, Environmental, Energy and Emissions

Management System that is aligned with the requirements of the ISO 9001:2015, ISO 14001:2015, ISO

50001:2018 and ISO 14064-1:2018 standards and which is adopted in all activities of PPA S.A. Through

this system, the Company's commitments are demonstrated and goals are set related to excellent quality,

minimizing the environmental footprint, energy saving and emission reduction, sustainable procurement,

as well as responsibility throughout the value chain.

At the same time, the Company is committed to the principles of the ESPO Green Guide and sets goals

and objectives to improve its environmental performance.

In addition, it maintains long-term cooperation with institutes and universities in the development and

implementation of environmental quality monitoring programs (Air quality, Noise nuisance, Marine water

and sediment quality) and in the preparation of a specific study on "Vulnerability and adaptation to

climate change" covering sectors such as port projects, infrastructure and activities.

Social Responsibility

Social responsibility is a key issue for the wider shipping industry, and for this reason the Company

emphasizes and is committed to maintaining the highest standards of integrity and ethical behavior in all

its business transactions.

The Company invests in its employees and is committed to creating an evolving, dynamic, cohesive and

diverse work environment that supports their professional development, and promotes a balance

between professional and personal life, prioritizing their health and well-being. With a view to promoting

equality, the Company recognizes the particularities of each person and consistently seeks to support

people with different backgrounds, regardless of gender, age, nationality, disability or any other personal

characteristic. Consequently, the Company does not tolerate any form of discrimination in the workplace

and the determining factors for the development of its people are based on performance, efficiency, skills

and qualifications. In support of international labor standards, the Company complies with the

conventions of the International Labor Organization (ILO), including those on working conditions, freedom

of association and occupational health and safety.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Company invests in the upskilling and retraining of its employees, enhancing talent development and

their responsiveness to customer needs, while supporting the communities in which it operates with the

aim of their economic development and well-being.

The Company promotes the protection of human rights and well-being in the context of its business

activities, as well as those of the supply chain, in accordance with its human rights policy and Code of

Conduct.

Corporate Governance

Transparency and accountability remain at the heart of the Company’s governance, both internally and

across its value chain.

The Company remains committed to effective corporate governance, which demonstrates a strong and

ongoing commitment to serving the interests of shareholders. The Company encourages its people to

practice and promote responsible business conduct throughout the value chain, in all directions, by

defining the rights and responsibilities and the power of corporate bodies, ensuring a clear picture of the

existing dynamics.

The Company remains committed to zero tolerance for behaviors and practices that may promote

corruption or unethical competition. To this end, a series of policies have been established that serve as

guidelines on how to avoid, prevent, mitigate and address corruption, and in particular the Code of

Conduct (COD), the Anti-Corruption and Bribery Code and the Internal Operating Regulations. The

Company promotes the interests of suppliers, as the management of relationships with suppliers and

contractors is largely determined in both the Company's Code of Conduct and the Contracts and Sub-

Concessions Regulation.

The strategy, programs, results and related commitments are analyzed in the annual Corporate

Responsibility and Sustainable Development Report, which is based on the Global Reporting Initiative

(GRI) guidelines and more specifically the Standards (In Accordance - Core), which are the most

internationally recognized and demanding guidelines of their kind, and is available in the Company’s

website.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

D. Nomination Committee

Composition

The existing Nomination Committee operates in accordance with the provisions of articles 10 and 12 of

L.4706/2020. It is a Committee of the BoD and is composed of three (3) non-executive members of the

BoD, of which two (2) are independent under the article 9 of Law 4706/2020, who were appointed by

from the Board of Directors meeting that took place on 08.07.2025.

The existing Nomination Committee operates in accordance with the provisions of articles 10 and 12 of

L.4706/2020. It is a Committee of the Board of Directors and is composed of three (3) non-executive

members of the Board of Directors, of which two (2) are independent under the article 9 of Law 4706/2020,

who were appointed by the BoD meeting that took place on 08.07.2025.

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

- Kwong Che Keung Gordon, Board of Directors independent Non-Executive Member and Chairman of the

Nomination Committee.

- ZHU Changyu, Board of Directors Non-Executive Member and Member of the Nomination Committee.

- ARVANITIS Nikolaos, Board of Directors independent Non-Executive Member and Member of the

Nomination Committee.

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

- LIN Lan, Board of Directors independent Non-Executive Member and Chairman of the Nomination

Committee.

- ZHU Changyu, Board of Directors Non-Executive Member and Member of the Nomination Committee.

- ZARAKELI Andriana, Board of Directors independent Non-Executive Member and Member of the

Nomination Committee.

The term of office of the Nomination Committee will be equal to the term of office of the elected Board

of Directors of the Company, whose term of office is two years, i.e. until 08.07.2027, which is extended,

in accordance with the provisions of article 85, par. c of Law 4548/2018 until the expiration of the

deadline, within which the next Ordinary General Assembly must be convened in 2027 and until the

relevant decision is taken.

The members of the Nomination Committee, all non-executive members, did not hold positions

incompatible with their status during 2025, while both their objectivity and independence were ensured,

in the absence of any transaction with the Company could affect they.

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Evaluation of the Nomination Committee

The Chairman of the Committee ensures the organization of the evaluation of the work of the Committee

on an annual basis. In the above context, it was carried out both a self-evaluation process of the

Nomination Committee and an evaluation process by an external consultant based on the provisions of

the Corporate Governance Code (article 3.3.14).

The above process was carried out using evaluation tools provided by the external advisor (filling out an

electronic questionnaire, etc.) and through personal interviews, which referred to the collective ability of

the Nomination Committee as a body, as well as to the individual abilities of its members.

The conclusion of the above evaluation of the external consultant stated, among other things, that the

Nomination Committee is functioning effectively contributing significantly to the overall governance and

decision-making processes of the Board.

The above result is a confirmation of both the proper functioning of the Nomination Committee and its

compliance with the current legislative and regulatory framework.

Purpose - Responsibilities

The main objective of the Nomination Committee is to provide support to the Board of Directors of the

Company in the context of issues falling within its responsibilities, in accordance with the applicable

regulatory framework and its Operational Regulation, for achieving the following objectives:

➢ Ensuring that the composition, structure and operation of the Board of Directors meet relevant legal,

regulatory and supervisory requirements.

➢ Ensuring that there is an effective and transparent procedure for the nomination of candidates to the

Board of Directors.

➢ Ensuring an appropriate mix of knowledge, skills and experience at Board level.

➢ Steering the process for the regular evaluation of the Board of Directors and of the Individual

Members' performance and effectiveness.

➢ Ensuring fit-for-purpose guidelines regarding the Member nomination process for the Boards of

Directors.

➢ Establishing the conditions required for effective succession and continuity in the Board of Directors.

The responsibilities and the mode of operation of the Nomination Committee are described in the Internal

Rules of Operation of the Committee, which has been approved by the Board of Directors.

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Exercise of duties of the Nomination Committee

During 2025, the Nominations Committee met six (6) times.

To ensure the independence of the Nomination Committee, the meetings were held without the presence

of other members of the Management. All the members of the Committee attended all the meetings and

all the decisions of the Committee were taken unanimously. The main issues handled by the Nomination

Committee in 2025 were the following:

➢ The continuation of the collective suitability and diversity of the Board of Directors, in such a way

that the composition of the Company’s Board of Directors, fully covers the appropriate and suitable

exercise of the responsibilities of the Board of Directors of the Company, and reflects the size and activity

of the Company and can further contribute to the implementation of its business objectives.

➢ The submission of proposal for the election of new Board of Directors of the Company, , taking into

consideration the expiration of the term of the previous Board of Directors of the Company elected by

the Ordinary General Assembly of the Company's shareholders of 2023, the completion of the maximum

total term of office of the current Independent Members and the obligation of electing a new Board of

Directors arises, following the identification and the submission of proposal to the Board of Directors

persons suitable for the acquisition of the status of member of the Board of Directors, taking into account

the factors and criteria of individual and collective suitability determined by the Company, in accordance

with the suitability policy it has adopted (which has been approved, in accordance with article 3 par. 3 of

law 4706/2020, as in force, by the Ordinary General Assembly of the Company's shareholders of

02.08.2023) and based on the relevant procedure provided in the Rules of Operation of the Committee.

Regarding the identification of persons suitable for the acquisition of the status of a member of the Board

of Directors of the Company and their proposal to the Board of Directors of the Company as candidates

for election, the Committee unanimously considered appropriate to initiate the above process of

suitability assessment by the existing members of the Board of Directors, namely the Executive Chairman,

the CEO, the CFO and the Vice Chairman of the Board.

As for the other members, given the completion (based on the provisions of article 9, paragraph 2ca of

Law 4706/2020) of the maximum total term of office of the Independent Members, the Committee

unanimously deemed it appropriate, following a suitability assessment process, to propose Messrs. Zhou

Zhonghui, Zhang Xueyan, Lin Lan and Zarakeli Andriana as new independent BoD members.

Specifically, the Committee, following the procedure for the evaluation of the suitability of the candidate

members of the Board of Directors, proceeded to the following actions:

Α) Regarding the (individual and collective) suitability criteria.

Regarding the verification of the fulfillment of the eligibility criteria of the candidates to be elected

members of the Board of Directors of the Company, the Committee:

a) thoroughly studied the detailed CVs of each of the candidate members of the Board of Directors,

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b) took into account the participation and general presence of the candidates in the meetings of the

existing Board of Directors of the Company throughout its term, of which the candidates are members, in

which meetings it was noted by the members of the Committee, the independence of their judgment, the

possibility to allocate the necessary time to fulfill their duties, the adequacy of knowledge in the field of

activity of the Company (which is the use and exploitation of the port of Piraeus in accordance with the

Concession Agreement with the Greek State, as applicable, and in particular the provision of services and

facilities to ships, cargo and passengers, including the mooring of ships and the management of cargo

and passengers to and from the port, and the creation, organization and operation of any kind of port

infrastructure), the skills and experience required to perform their duties, were established,

c) collected and processed on a case by case basis based on the approved Suitability Policy of the

Company, documents such as solemn declarations about non-occurrence of incompatibility / barriers,

qualifications, certificates, excerpts from criminal records, etc...

Β) Regarding the conditions and criteria of independence. Regarding the verification of the fulfillment

of the independence criteria and conditions, within the meaning of article 9 par. 1 and 2 of law 4706/2020,

as in force, of the candidates to be elected members of the Board of Directors of the Company, the

Committee:

a) received solemn declarations from the proposed independent members, regarding their independence

of the Company, within the meaning of article 9 par. 1 and 2 of law 4706/2020, as in force,

b) carried out an investigation and audit in the shareholders' register of the Company and found that does

not occur the case of article 9 par. a of law 4706/2020, as in force,

c) carried out a research and audit of the Company's accounting books and contracts and found that none

of the proposed members is a significant customer or supplier of the Company and that none of the cases

of article 9 par. 2 par. b) of law 4706/2020, as in force, occurs,

In particular, during the evaluation process of the above candidates in terms of determining the fulfillment

(a) of the eligibility criteria in accordance with the Suitability Policy and (b) the conditions of independence

defined in article 9 par. 1 and 2 of law 4706/2020, as in force, were unanimously established that:

The proposed for election members of the Board of Directors individually:

(a) have the required knowledge, skills and experience for the exercise of their duties and significant

practical experience in the issues relating to the business operation and the business scope of the

Company and the operation of its Board of Directors,

(b) have the guarantees of morality (honesty and integrity) and reputation which they are presumed to

possess, since the Committee has not been informed of the existence of objective and proven reasons or

facts to the contrary;

judgment in the performance of her duties, and

(d) may devote the time required to carry out their role within the Company.

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The proposed for election members of the Board of Directors collectively constitute a Board of Directors

suitable for the exercise of its responsibilities that will contribute to the effective corporate governance of

the Company and balanced decision-making, reflecting the guarantees of ethics, reputation, adequacy of

knowledge, skills, independence of judgment and experience for the performance of its role for the benefit

of the Company and its Shareholders, which (BoD) is in a position to:

- to make appropriate and informed decisions taking into account the opportunities as well as the various

risks and parameters that accompany a business decision, such as business environment and the business

prospects in the international markets, the risk appetite, the medium-long term growth strategy decided

by the Company, the developments in the sector in which the Company operates (which is the use and

exploitation of the port of Piraeus in accordance with the Concession Agreement with the Greek State, as

applicable, and in particular the provision of services and facilities to ships, cargo and passengers,

including the mooring of ships and the management of cargo and passengers to and from the port, and

the creation, organization and operation of any kind of port infrastructure), the issues related to the

protection of the environment, and the sustainable development etc.

- to supervise the top management that plays a very important role of its business and operational

activity,

- to monitor in essence, discuss and critique constructively the decisions of senior executives and intervene

directly in situations, if and when required. T

- to have an adequate understanding of the areas for which the members are collectively responsible and

has the necessary skills to monitor the implementation of the strategy of the Company and the basic

business decisions relating to enterprise matters in the medium term, the financial reporting references,

the compliance with the legal and regulatory framework, the understanding of corporate governance

issues, the ability to identify and manage risks, the impact of technology on its activity, etc..

Of the above proposed members of the Board of Directors of the Company, following, on the one hand, a

relevant examination carried out by the Committee and on the other hand, their relevant responsible

declarations, it was found that the following proposed candidates for election meet the independence

criteria of article 9 par. 1 and 2 of Law 4706/2020, as in force:

(a) ZHOU Zhonghui,

(b) LIN Lan, and

Based on findings regarding: a) the individual suitability of the members of the Board of Directors, b) the

collective suitability of the Board of Directors, c) the absence of impediments or incompatibilities in the

person of the candidate members proposed for election, d) the incompatibility of article 3 par. 4 of Law

4706/2020, e) the determination of independence, f) the legal composition of the Board of Directors, the

Committee unanimously decided:

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1) To propose to the Board of Directors of the Company, to recommend to the Ordinary General Assembly

of Shareholders of the Company, the election of a new nine-member Board of Directors of the Company

with two years term, which is automatically extended, according to article 85 par. 1 point c of Law

4548/2018, as in force, and article 11 par. 2 of the Company's Articles of Association, until the expiration

of the deadline, within which the Ordinary General Assembly of 2027 and until the relevant decision is

taken, consisting of :

the below proposed members to be elected:

1) Mr. LIN Ji,

2) Mr. ZHU Changyu,

3) Mr. SU Xudong,

4) Ms LI Jin,

5) Mr. ZHOU Zhonghui,

6) Mr. LIN Lan,

7) Ms ZHANG Xueyan,

8) Ms. ZARAKELI Adriana.

as well as the appointment of the Candidates (a) ZHOU Zhonghui, (b) LIN Lan, and (c) ZARAKELI Adriana,

as independent non-executive members of the Board of Directors.

[is noted that the Growthfund, in the exercise of its relevant constitutional right is entitled to appoint one

(1) Member (ie in this case the 9th member of the Board of Directors) pursuant to article 79 of Law

4548/2018 as in force by announcing with a statement the appointment of the members to the Board of

Directors of the Company, three (3) full days before the General Assembly.]

2) That the documents and information contained in the Candidates' dossier are complete and

substantiate, without any doubt, that the Candidates meet all suitability and reliability criteria included in

the Suitability Policy, for their election as members of the Company's Board of Directors, and, regarding

the Candidates (a) Mr. ZHOU Zhonghui, (b) Mr. LIN Lan, and (c) Ms. ZARAKELI Adriana, the conditions of

independence defined in article 9 par. 1 and 2 of law 4706/2020, as in force, as well as that there are no

obstacles or incompatibility in the face of any Candidate in relation to any relevant provisions, including

the Corporate Governance Code (HCGC) applied by the Company and the Rules of Operation of the

Company. [...]».

In consequence, it is proposed that the new Board of Directors of the Company have the following

composition, which allows the fulfillment and enhancement of the Board of Directors' expertise in the field

of the Company's activities, the implementation of the Company's strategy and the conduct of its daily

operations, enhances the proper and effective exercise of the Board of Directors duties and

responsibilities, reflects the size of the Company, its organization and its mode of operation, covering the

main risks associated with it, strategic planning, corporate governance issues, the ability to identify and

manage risks and the impacts of technology on the Company, includes members of different nationalities,

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strengthening the pool of skills, experience and vision that the Company has for its top positions, as well

as its competitiveness, productivity and innovation, and fully meets the requirements of law 4706/2020

on corporate governance and fully covers the appropriate and appropriate exercise of its responsibilities

for the benefit of its Shareholders, given that all the criteria of individual and collective suitability of the

new candidate members of the Board of Directors of the Company are met, in accordance with article 3

of law 4706/2020, as in force, and the approved Suitability Policy of the Company, there are no obstacles

or incompatibilities in the person of the new candidate members of the Board of Directors of the Company,

regarding any provisions of the relevant legal framework of corporate governance, including the

Corporate Governance Code implemented by the Company (Hellenic Code of Corporate Governance of

HCGC of June 2021), the Rules of Operation of the Company and the approved Suitability Policy of the

Company, there is no incompatibility / impediment of the provision of article 3 par. 4 of law 4706/2020

for any of the new candidate members of the Board of Directors, as in force, and there is an adequate

representation per gender in a percentage that is not less than thirty three- percent (33%) both of all the

members of the Board of Directors of the Company and its Executives members, with the resulting fraction

being rounded to the previous integral number, according to articles 3 and 4 of Law 51758/2025, as in

force, as from the eight (8) members are prosed three (3) women and five (5) men are proposed for

election, while of the three executive members, one (1) woman and two (2) men are proposed for election.:

1) Mr. LIN Ji,

2) Mr. ZHU Changyu,

3) Mr. SU Xudong,

4) Ms LI Jin,

5) Mr. ZHOU Zhonghui,

6) Mr. LIN Lan,

7) Ms ZHANG Xueyan,

8) Ms. ZARAKELI Adriana.

A. As for the Mr. HAN Chao nomination proposal following the resignation of Executive Chairman Mr.

LIN Ji , the Nomination Committee examined the below:

1. General conclusion of individual suitability:

Education – training

Professional experience

Personal skills

Reputation, ethics, honesty, and integrity

Allocating sufficient time

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2. Determination of criteria of collective suitability.

It is considered that the appointment of Mr. HAN Chao, who has progressive leadership experience in

shipping, crew management, and organizational development within COSCO Shipping Group and proven

expertise in corporate management, talent development, corporate governance and excellent

performance results and driving strategic transformation, can add significant value to the operation of

the Board.

Therefore, he can actively and effectively contribute to the monitoring of issues related to the strategic

planning, organization and further growth of the Company's business activity.

Mr. HAN Chao can contribute to the identification and management of risks associated with the above,

helping to safeguard the interests of all stakeholders to the best of his ability.

➢ The conducting of an Induction Training Program for BoD members whose main objectives were to (a)

communicate the Company's vision and culture, (b) communicate practical procedural duties, (c) reduce

the time taken for them to become productive in their duties, (d) become familiar with the Company's

organizational structure, (e) give them an understanding of Company's business and strategy and the

markets in which it operates, (f) to provide a link with the Company’s people and an understanding of its

main relationships. Also, the BoD members, upon their appointment received information material of

Company’s Obligations towards Supervisory Authorities, aiming to inform them on their main obligations

under the legislative and regulatory framework that the Company operates.

➢ The organizing (in Dec. 2025), of a training session conducted by Hellenic Corporate Governance

Council, in the thematic area “Key ESG concepts for board members and senior executives”.

➢ The evaluation of the fulfillment of the independence criteria of the Independent Non-Executive BoD

Members, according to the definition of the law, as well as the evaluation of the existence of conflicts of

interest to the extent that hinders the ability of Members to perform their duties independently and

objectively will).

➢ The information towards the Company’s BoD about the issues within its competence.

In carrying out its work in general, the Nomination Committee had full access to all the information

necessary for the effective performance of its duties. The discussions and the decisions of the Nomination

Committee are recorded in minutes signed by the members.

BoD and Committee Evaluation Process – Results of Evaluation Process

In compliance with the provisions of Law 4706/2020, Circular 60 of the Capital Market Commission, the

Hellenic Code of Corporate Governance and the Internal Operating Regulations of the Board of Directors

and in line with the commitment to adhering to leading corporate governance standards, the Company

assigned the assessment of the adequacy and effectiveness of the Board of Directors and its Committees

to an external consultant.

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The BoD Assessment Policy and the BoD Operation Regulation provides for the annual evaluation of the

effectiveness of the Board of Directors (as a collective body), its committees and their individual members.

To this end, as mentioned above, the Company awarded to the company KPMG Advisors Single Member

SA for the Provision of Advisory Services to carry out the evaluation process.

The evaluation concerned the collective abilities of the Board of Directors as a body, its committees and

the individual abilities of its members. The evaluation was carried out using evaluation tools provided by

the external advisor (filling out an electronic questionnaire, etc.) and through personal interviews. The

evaluator had access to the BoD’s and BoD’s Committees operating details.

The purpose of the evaluation was to determine whether the Board and its Committees function

effectively and efficiently, based on the Board Directors’ responses to the online questionnaires covering

a wide range of topics, documentation review and selected interviews with Board Directors.

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

Based on the evaluation of the Board of Directors and its Committees, with a reference date of March

18th, 2026, is mentioned among others:

No significant weaknesses have been identified in the performance of the Board, its Committees, or

individual Board members. Furthermore, there are no immediate corrective actions required under the

current legislative and regulatory framework.

The Board’s performance remains stable, operating effectively, while, also, fostering an environment that

encourages open and constructive discussions, where all Board Directors feel confident in expressing their

views.

The Board Committees (Audit Committee, Nomination Committee, Remuneration Committee) are

functioning effectively, with each contributing significantly to the overall governance and decision-making

processes of the Board, with the Nomination Committee demonstrating a strong contribution to the

Board’s operations.

In respect to the individual evaluation of each Board member, all Board members perform their duties

effectively and demonstrate commitment to their role, as does the Chairperson of the Board. The Board

has taken proactive steps to develop a long-term strategic plan, enhancing alignment with the Company’s

broader business objectives.

The above result is a confirmation of both the proper functioning of the Board of Directors and its

compliance with the current legislative and regulatory framework.

E. Remuneration Committee

Composition

The existing Remuneration Committee operates in accordance with the provisions of articles 10 and 11 of

L.4706/2020. It is a Committee of the Board of Directors and is composed of three (3) non-executive

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members of the Board of Directors, and are independent in majority under the article 9 of Law 4706/2020,

who were appointed by the BoD meeting that took place on 08.07.2025.

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

- ARVANITIS Nikolaos, Board of Directors independent Non-Executive Member and Chairman of the

Remuneration Committee.

- KWONG Che Keung Gordon, Board of Directors independent Non-Executive Member and Member of

the Remuneration Committee.

- POLITIS Dimitrios, Board of Directors Non-Executive Member and Member of the Remuneration

Committee.

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

- LIN Lan, Board of Directors independent Non-Executive Member and Chairman of the Remuneration

Committee.

- POLITIS Dimitrios, Board of Directors Non-Executive Member and Member of the Remuneration

Committee.

- ZARAKELI Andriana, Board of Directors independent Non-Executive Member and Member of the

Remuneration Committee.

The term of office of the Remuneration Committee will be equal to the term of office of the elected Board

of Directors of the Company, whose term of office is two years, ie until 08.07.2027, which is extended, in

accordance with the provisions of article 85, par. c of Law 4548/2018 until the expiration of the deadline,

within which the next Ordinary General Meeting must be convened in 2027 and until the relevant decision

is taken.

The members of the Remuneration Committee, all non-executive members, did not hold positions

incompatible with their status during 2025, while both their objectivity and independence were ensured,

in the absence of any transaction with the Company could affect they.

Evaluation of the Remuneration Committee

The Chairman of the Committee ensures the organization of the evaluation of the work of the Committee

on an annual basis. In the above context, it was carried out both a self-evaluation process of the

Remuneration Committee and an evaluation process by an external consultant based on the provisions

of the Corporate Governance Code (article 3.3.14).

The above process was carried out using evaluation tools provided by the external advisor (filling out an

electronic questionnaire, etc.) and through personal interviews, which referred to the collective ability of

the Remuneration Committee as a body, as well as to the individual abilities of its members.

The conclusion of the above evaluation of the external consultant stated, among other things, that the

Remuneration Committee is functioning effectively contributing significantly to the overall

governance and decision-making processes of the Board.

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The above result is a confirmation of both the proper functioning of the Remuneration Committee and

its compliance with the current legislative and regulatory framework.

Purpose - Responsibilities

The Remuneration Committee acts as an independent and objective body that assists the Board of

Directors in the performance of its duties with regard to the remuneration of the Board of Directors and

the executives of the Company. drawing up procedures and monitoring of the Remuneration Policy and

the Remuneration Report of Articles 110-113 of Law 4548/2018. and is generally responsible for

proposing, making decisions and expressing an opinion on any matter falling under Articles 109-114 of

Law 4548/2018, either voluntarily or at the request of the Board of Directors or the General Assembly.

The role of Remuneration Committee is fulfilled on the basis of the following responsibilities and duties

through the procedures applied by it.

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

a) formulates proposals to the Board of Directors regarding the remuneration policy submitted for

approval to the General Assembly, in accordance with paragraph 2 of article 110 of law 4548/2018,

b) formulates proposals to the Board of Directors regarding the remuneration of persons falling within

the scope of the remuneration policy, in accordance with article 110 of Law 4548/2018, and the

remuneration of the Company's executives; and in particular the head of the internal audit service,

c) examines the information included in the final draft of the annual remuneration report, providing its

opinion to the Board of Directors, before submitting the report to the General Assembly, in accordance

with article 112 of law 4548/2018.

d) examines and submits proposals to the Board of Directors for the performance targets for any variable

remuneration of the Executive Members of the Board and senior executives, and the objectives associated

with rights or stock options.

e) examines and submits proposals to the Board of Directors (and, as such, to the General Assembly of

Shareholders, when required) regarding any stock option or stock option plans.

f) submits proposals for the review and improvement of any process related to the drafting of the

remuneration policy, the remuneration report and the determination of the information contained

therein.

g) submits a report to the Board of Directors describing the way in which the Remuneration Report takes

into account the result of the General Assembly vote on the previous Remuneration Report.

The responsibilities and the mode of operation of the Remuneration Committee are described in the

Internal Rules of Operation of the Committee, which has been approved by the Board of Directors.

Exercise of duties of the Remuneration Committee

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

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To ensure the independence of the Remuneration Committee, the meetings were held without the

presence of other members of the Management, All the members of the Committee attended all the

meetings and all the decisions of the Committee were taken unanimously.

The main issues handled by the Remuneration Committee were the following:

➢ The submission of proposal to the Company’s BoD, for the setting up of the regular remuneration up

to the amount of 40.000€ per annum, for each BoD member for the fiscal year 2025 (equal to the fiscal

year 2024), as well as an annual gross maximum total compensation for the financial year 2025 of €

20,000.00 (equal to the fiscal year 2024) for the independent BoD members and Hellenic FUND

representative for their participation in the meetings of the BoD Committees (Audit–Remuneration-

Nomination Committees), regardless of the total number of BoD Committees in which they participate;

➢ The review and the afterwards submission of a proposal to the Company's BoD for the Remuneration

Report of the members of the Board of Directors, taking into account the last vote at the General Assembly

of Shareholders of the Company regarding the approval of the relevant report.

➢ The submission of a proposal to the Board of Directors of PPA SA for the granting of an extraordinary

voluntary benefit of the Company's Top Management executives based on exceptional performance.

➢ The submission of a proposal to the Board of Directors of PPA SA for the granting of an extraordinary

voluntary benefit to an executive of the Company's Senior Management based on his exceptional

performance.

➢ The submission of a proposal to the Company's BoD regarding the remuneration of persons falling

within the scope of the remuneration policy, in accordance with article 110 of N. 4548/2018. In particular,

after a review, the following was approved the readjustment of Company’s CEO and DCEOs remuneration

and the forwarding to the PPA SA BoD of respective formulated proposal that these remunerations are in

line with the high level of responsibility related with the performance of the duties of the CEO and DCEO

positions and can be supported by the Company's strong financial position.

➢ The granting of consent for the submission to the PPA SA Board of Directors " Incentives Plan for

voluntary leave /retirement to Company’s personnel " as it has been prepared in a correct, balanced and

understandable manner in its implementation, can be supported by the Company's strong financial

position, and contributes to the sustainability of the Company, promoting its interests and ensuring its

business continuity (through effective replacement of existing staff in a manner that will not negatively

impact service delivery, operations, customer relationships).

➢ Conducting contacts of the Committee’s Chairman with the Senior Management of the Company on

issues related to the responsibilities of the Committee.

In carrying out its work in general, the Remuneration Committee had full access to all the information

necessary for the effective performance of its duties. The discussions and the decisions of the

Remuneration Committee are recorded in minutes signed by the members.

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F. Strategy Committee

Composition

The existing Strategy Committee operates in accordance with the provisions of its Operation Regulation.

It is a Board of Directors Committee and is composed by BoD and Top Management (DCEO level) members,

six (6) of them having the BoD membership and one (1) to have the DCEO capacity, who were appointed

by the BoD meeting that took place on 28.11.2025, with the below composition:

1. Company’s CEO and Executive BoD member Mr. SU Xudong, Chairman of the Strategy Committee.

2. Company’s BoD member and Vice chairman Mr. ZHU Changyu, member of the Strategy Committee.

3. Company’s CFO and Executive BoD member Ms. LI Jin, member of the Strategy Committee.

4. Independent Non- Executive ΒοD member Mr. LIN Lan, member of the Strategy Committee.

5. Non- Executive BoD member Mr. POLITIS Dimitrios, member of the Strategy Committee.

6. Non- Executive BoD member Ms. ZHANG Xueyan, member of the Strategy Committee.

7. Company’s Deputy CEO Mr. QU Shengbin, member of the Strategy Committee.

The term of office of the Remuneration Committee will be equal to the term of office of the elected Board

of Directors of the Company, whose term of office is two years, ie until 08.07.2027.

Strategy Committee Evaluation

The above process did not take place as it was considered that the brief operation period (just one

month) in 2025 was not sufficient itself for drawing safe conclusions.

Purpose - Responsibilities

The Strategy Committee acts as an independent and objective body that assists the Board of Directors in

the performance of its duties on issues related to the general strategy of the Company, and also

specifically on issues of strategy regarding sustainable development, as well as new technologies and

innovation, including the Company's digital transformation and sustainability through innovative

technologies. The ultimate goal of the Committee is the sustainable development and optimization of the

Company's value. The role of Strategy Committee is fulfilled on the basis of the following responsibilities

and duties through the procedures applied by it.

In particular, the Strategy Committee in compliance with its operation Regulation:

(1) Stays up-to-date, evaluates, advises and expresses an opinion on the main long-term strategic goals

of the Company and its medium-term strategy, in compliance with the guidelines and objectives set by

the BoD.

(2) Stays up-to-date, evaluates, advises and expresses an opinion on Greek, European and international

Sustainable Development trends, as well as the best practices that may have a significant impact on the

Company's business activities and performance. In this context, it monitors the work of other

international organizations and entities in Greece and abroad, respecting the principle of confidentiality

and the rules of competition.

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(3) Stays up-to-date, evaluates, advises and expresses an opinion on the strategy relating to new

technologies, innovation and transformation of the Company.

(4) Stays up-to-date, evaluates, advises and expresses an opinion on the strategy regarding issues of risk

from digital and new technologies.

(5) Stays up-to-date, evaluates, advises and expresses an opinion on the strategy regarding the

implementation of the Sustainable Development Policy, in accordance with the Company's relevant

strategy.

(6) Monitors the implementation of the Company's strategy on a semi-annual basis, regarding the

Company's strategic projects as well as innovation and digital transformation projects. Provides an

opinion to the BoD in the framework of the preparation of the annual budget and the investment plan

regarding the above.

(7) Examines and approves the process of defining the essential issues of sustainable development,

validating, whenever appropriate, the results that form the structure of the Sustainable Development

Annual Report of the Company.

(8) Stays up-to-date and approves the context of the Sustainable Development Annual Report of the

Company.

(9) Organizes presentations in cooperation with Management at the invitation of Management or the

BoD or on its own initiative in order to inform the BoD Members on the issues within its competence.

(10) Submits to the BoD a Regular Annual Report on matters of Strategy of the Company. It can also

submit specialized reports on specific technologies or innovations when needed or requested by BoD.

The Strategy Committee assists the BoD in its responsibilities regarding the goals, the vision and the

strategic direction of the Company.

More specifically, in carrying out its purpose the Committee shall undertake the following duties and

responsibilities:

i. Business Plan

Submits proposal to the BoD on the approval of the business plan, reviews it at least annually or where

deemed necessary and monitor on a regular basis its implementation. To this effect, the Committee shall

review all material information and documentation relating to planning and strategy (including for

example, significant efforts on commercial model, operating model, technology, and ESG - Climate &

Environment issues) and shall develop goals, vision and strategic initiatives as well as its main innovative

programs and services, according to the needs of the Company, and innovative solutions based on

changes in the market, the needs of the community and other factors

ii. Annual Budget

Reviews and proposes to the BoD for approval the Annual Budget of the Company and monitors its

implementation on a semiannual basis.

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iii. Strategic and Organizational Transformation

Submits proposals with regard to initiatives taken in the context of strategic and corporate

transformation, oversees related activities and monitors on a regular basis the implementation of

Strategic and Corporate Transformation Projects undertaken by the Company.

iv. Corporate Structure related Actions, Strategic Transactions, Mergers, Acquisitions and Partnerships

Reviews all significant actions concerning Company’s structure, such as divestments, mergers, acquisitions

of shareholdings in other companies or the creation of special purpose companies, the formation of joint

ventures, partnerships and any other major investments by Company, apart from those which are purely

related to Concession Agreement and where deemed necessary, make proposals, to the BoD on all of the

above issues. To this effect, should be ensured that the Committee is apprised of all relevant, material

information in a timely manner.

Reviews transactions and provides guidance, as stipulated within the applicable Mergers and Acquisitions

(M&A) and Partnership framework of the Company, as each time in force, in which context the Committee

can engage in the early stages of a potential transaction and have a role in providing initial guidance.

v. Issues of strategic importance

Review and, as needed, make proposals to the BoD on other issues of strategic importance to the

Company, as put forward for discussion by the Chair or the CEO, and in conjunction with the competencies

of the BoD for discussion on matters of strategic importance.

Exercise of duties of the Strategy Committee

During 2025, the Remuneration Committee met once, given the fact that its establishment took place just

one month before the year-end. The main issue handled by the Strategy Committee was the submission

of a proposal to the Company’s BoD, for the approval of the Strategic Business Plan of the period 2025 -

2032 and its deliverables, which were related to be below:

Stage 1 “AS-IS ANALYSIS”

Stage 2 “MARKET ANALYSIS”

Stage 3 “STRATEGIC PLAN”

Stage 4 “INVESTMENT PLAN”

Stage 5 “FINANCIAL PROJECTIONS”

In carrying out its work in general, the Strategy Committee had full access to all the information necessary

for the effective performance of its duties. The discussions and the decisions of the Strategy Committee

are recorded in minutes signed by the members.

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a) Periodic Evaluation Policy of the Internal Control System of PPA SA and Implementation of the

provisions on Corporate Governance of Law 4706/2020

1. Key Elements

The Company recognizing the importance of the operation of an adequate and integrated Internal Control

System (hereinafter "ICS") to achieve its business objectives and in accordance with Law 4706/2020

regarding corporate governance and decision of the BoD of the Hellenic Capital Market Commission

1/891/30.09.2020 as in force from time to time, adopts the present policy of periodic evaluation of the

Company's ICS as well as of the Implementation of the provisions on Corporate Governance of Law

4706/2020. The Company's ICS includes five (5) basic elements that exist and operate in the Company and

are described in general terms below:

a. Control Environment

The Company is committed to operate with integrity and ethical values. Its organizational structure

determines a specific position and specific and distinct responsibilities for each body and organizational

unit of the Company. There are specific benchmarks and areas of responsibility in achieving the Company's

goals, while a regulation is followed on the selection and recruitment of staff and senior management as

well as a remuneration policy aiming at attracting and retaining highly qualified human resources. In

particular:

Integrity, Moral Values & Top Management Behavior: The Management of the Company provides

direction, leadership as well as an appropriate environment for its operation, in order to ensure that all

its available resources are fully utilized to achieve its objectives. The Company has a Code of Conduct. Any

deviation is reported to the Top Management which is solely responsible for taking relevant actions.

Organizational structure: The Company maintains an organizational structure sufficient for the planning,

execution, control and supervision of corporate operations for all its Departments and operational

activities, according to which the main areas of responsibility are determined while at the same time the

appropriate reference lines are established.

BoD: The BoD follows the Law, the Bylaws or the needs of the Company dictate and decides on any matter

concerning the management of the Company, the management of its assets and the general pursuit of its

purpose. The BoD maintains adequate oversight of the operation and effectiveness of the ICS. For this

purpose, it consists of a sufficient number of executive, non-executive and independent non-executive

members, with a variety of knowledge, skills and experience in order to achieve the business model and

strategy of the Company.

Corporate Responsibility: The Company maintains appropriate structures and pursues policies that

promote the principle of responsibility, the speed of decision making, the smooth operation of the

Company, and the effective control of all its actions. Based on this principle, responsibilities are assigned

to the executives of the Company, according to their position in the hierarchy and their qualifications.

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Furthermore, the Company forms the framework to enable the individual organizational units to operate

within the components of the specific management authority (Responsibility – Accountability Obligation

- Assumption of Responsibility), as well as the Management to control its effectiveness.

Human Resources: Recognizing the utilization of human resources as a cornerstone for the achievement

of the Company's goals, the Company pursues specific policies of recruitment, training, remuneration,

and evaluation of staff.

b. Risk Management

The Organization’s risk management methodology constitutes a structured framework of strategic

importance for identifying, assessing, and addressing threats that may impact the achievement of

business objectives. The primary goal is to minimize uncertainty and limit negative consequences through

a proactive approach. The core stages of the methodology are:

Risk Identification: Identifying and recording internal and external risks (financial, technological, legal,

geopolitical, operational, etc.) using tools such as SWOT analysis, executive interviews, and historical data

analysis. The scope includes factors classified into categories such as financial, technological, legal,

operational, and human resources.

Risk Assessment: Estimating the probability of occurrence and the severity of impact. The assessment

combines qualitative and quantitative criteria to prioritize risks using a Risk Heat Map.

Risk Response: Designing and implementing response strategies, such as avoidance, mitigation, transfer,

or conscious acceptance of the threat.

Reporting & Monitoring System

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

reporting schedule:

Monthly Risk Reports: These focus on monitoring Key Risks for each functional unit and analyzing

significant events. They serve as an Early Warning system, recording deviations from tolerance limits and

allowing for immediate corrective intervention at both the departmental and organizational levels.

Quarterly Risk Reviews: These provide a holistic analysis of the Company’s risk profile, presenting trends

of the most significant risks and the progress of mitigation plans, while proposing strategic revisions to

Management and the Audit Committee.

Annual Comprehensive Assessment: A full update of the Risk Registry is conducted across all Company

activities.

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Risk Management Unit

The Company maintains a Risk Management Unit that utilizes effective policies and tools (Risk Registry,

Risk Assessment, Historical Data, and KRIs) for identifying and managing every form of risk. The

implementation of Key Risk Indicators (KRIs) per department enables early detection and transforms risk

management from a formal compliance procedure into a dynamic management tool that enhances

operational resilience.

c. Control Mechanisms and Security Controls

The Company develops policies and procedures aligned with Management’s objectives. It implements a

system of safeguards based on identified risks while considering its unique organizational characteristics.

Specific evaluations are conducted regarding the adequacy and correct application of procedures, the

handling of errors, and the frequency of policy re-evaluations.

As part of strengthening corporate governance, the Organization has established the Risk Management

and Compliance Committee. This Committee acts as an advisory body to the Board of Directors with the

following primary missions:

Oversight & Strategy: Approving risk management policies and ensuring that the Organization’s strategy

aligns with the defined Risk Appetite.

Regulatory Compliance: Ensuring full alignment with the current legislative and regulatory framework to

prevent legal or reputational risks.

Report Review: Evaluating monthly and quarterly risk reports and monitoring the implementation of

Mitigation Plans.

In addition, the Company implements adequate security controls for issues of conflict of interest,

segregation of duties, as well as the governance and security of its information systems.

d. Cοmmunication System

The Company ensures the quality of financial and non-financial information and follows appropriate ways

of internal and external communication, such as communication with the members of the BoD,

shareholders and investors, communication with the existing Company committees, complaint on

whistleblowing, Regulatory Authorities etc.

e. Monitoring of the ICS

The Company has mechanisms and functions that have as object the continuous evaluation of the ICS

and the reporting of findings to be corrected or improved:

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Audit Committee

The Company has an AC, which is a committee of the BoD, consists in its majority of independent non-

executive members of the BoD and its goal is to support the BoD fulfilling its responsibilities for overseeing

compliance control procedures with the legislative and regulatory framework on: (a) financial

information, (b) the ICS, the risk management system, the regulatory compliance system and (c) its

supervision of the (external) statutory audit of the financial statements of the Company.

Internal Audit Department

The Company has an Internal Audit Department, which operates in accordance with the applicable

Regulation approved by the BoD. The Internal Audit Department is organizationally independent and

adequately staffed. Implements the appropriate tools and control methodology in order to achieve the

best result, while the audit reports that are prepared are submitted at least quarterly to the AC and then

to the BoD.

The responsibilities of the Internal Audit Department, are the following:

a) To monitor, audit and evaluate:

• the implementation of the Internal Organization & Operation Regulation and the ICS, in particular as

to the adequacy and accuracy of the provided financial and non-financial information, risk

management, regulatory compliance and the Code of Corporate Governance adopted by the

Company,

• the internal controls of quality assurance

• corporate governance mechanisms, and

• the compliance with the commitments contained in newsletters and the Company's business plans

regarding the use of funds raised from the regulated market.

b) To prepare reports to the audited Departments with findings regarding tasks, the risks arising from

them and suggestions for improvement, if any. The reports, after incorporating the relevant comments of

the audited Departments, the agreed actions, if any, or the acceptance of the risk of non-action by

them,the limitations on its scope of audit, if any, the final internal audit proposals and the results of

the response of the audited Departments of the Company to its proposals, are submitted at least quarterly

to the AC.

c) To inform the AC on a monthly basis about its activities, the audits carried out and the progress of its

work.

d) To submit at least every three (3) months to the AC reports, including its most important issues and

proposals, regarding the tasks a) and b), which the AC presents and submits along with recommendations

to the BoD.

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Regulatory Compliance Unit

The Company has a Regulatory Compliance Unit (RCU), which is functionally independent and its staff has

sufficient knowledge, experience to carry out its responsibilities, appropriate training and information to

monitor the effective adoption and smooth implementation of the changes that take place in a regulatory

and legislative context and concern the Company. The Manager and the members of the RCU have

received a Compliance Officer Certification according to the international standard ISO/IEC 17024 and

have attended numerous specialized training courses, seminars and conferences, receiving the

corresponding certificates.

The main mission of RCU is the establishment and implementation of effective and updated policies and

procedures, in order to accomplish timely and continuous compliance of the Company with the applicable

regulatory framework and to have a full picture at all times of the degree of achievement of this objective,

through the effective management of regulatory and statutory implementation as a prerequisite for high

standards of Corporate Governance leading to high efficiency and optimal operational performance. The

purpose of RCU is the preparation and implementation of the appropriate procedures methodology for

the regulation, assessment and management of the Company's policies and procedures in accordance

with the existing legislation, and the general coordination of the relevant process through the Company's

Departments. RCU must comprehend future changes in the regulatory field, while having the appropriate

response at the process level. It monitors the effective adoption and smooth implementation of changes

that take place in the regulatory framework, having direct access to all sources of information required

for the proper performance of its tasks. RCU with direct reporting line to the Audit Committee and Top

Management, has the following responsibilities: · operates as an advisory and preventive service on

Company's compliance within its legal and regulatory obligations, · adopts appropriate and updated

policies and procedures, monitors and reviews their proper implementation, and proposes solutions to

issues that need improvement or development, · communicates with the supervising Authorities and try

to resolve any problems that arise, · designs processes, integrating security safeguards to mitigate risks

and monitors their proper implementation, · drafts an annual action working plan which is subject to

approval by the Audit Committee and includes the compliance audits to be conducted, · replies to

questions raised by Departments, related to responsibilities that RCU already has, such as new legislation

and harmonization of Departments with them. RCU assess possible regulatory risks, arising from the non

- application or deviant behavior of legal and regulatory framework, in order to predict, process and

reduce potential negative impact. The responsibilities of RCU, as defined and specified by the Law and the

instructions of the Capital Market Commission as in force, are indicative by the following: · mapping of

the systemic difficulties and compliance weaknesses within the Company and making recommendations

to resolve them, · cooperation with relevant Departments and provision of information, suggestions and

strategic references in relation to regulatory compliance issues, · regular cooperation, communication and

interaction with Top Management, having full access to Company’s Data, while monitoring the work of

the relevant Committees, · establishment and implementation of appropriate and updated practices,

policies and procedures aiming to timely and full compliance of the Company with the applicable

legislative framework on National and European level, · assessment of the new procedures and practices,

as to their nature and complexity, contribution to the enhancement of corporate governance through

compliance audits and other Regulatory Compliance tools.

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2. General Description

The Company in the context of ensuring the continuous operation of an adequate and integrated ICS and

the continuous improvement where and when deemed appropriate, follows this policy, which sets out

the framework for periodic evaluation of the ICS and implementation of the provisions on Corporate

Governance of Law 4706/2020 that is in effect and governs its operation.

3. Legal and regulatory framework

The content of this policy fully complies with Law 4706/2020 and the relevant decision 1/891/30.09.2020

of the BoD of the Hellenic Capital Market Commission. The terms of periodic evaluation policy of CGS are

applied in combination with the respective provisions of the Company's Internal Organization and

Operation Regulations, the Regulations of the AC, the Internal Audit Department, the Regulatory

Compliance function and the Risk Management function.

4. Policy Purpose

The purpose of this policy is to establish the framework to ensure the timely and correct implementation

of the periodic evaluation of the ICS based on the respective standards by appropriate evaluators and the

compliance of the Company with the applicable legislation on relevant corporate governance matters.

5. Policy Scope - Compliance

This policy applies to Top Management, the collective bodies and all the organizational units of the

Company, its processes and functions, as well as its Information Systems.

The Top Management, the collective bodies and all the organizational units are obliged to comply with

the content of this policy.

6. Policy Subject

The subject of this policy includes the general principles regarding the object, the periodicity of the audit,

the scope of evaluation and the general process which governs the periodic evaluation of the Company's

ICS as well as the Implementation of the provisions on Corporate Governance of Law 4706 / 2020 as well

as the assignment and monitoring of the results of the evaluation and the determination of the object of

the evaluation.

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7. Evaluation Process

7 a. General

The periodic assessment of the adequacy of the ICS is carried out on the basis of international best

practices.

The purpose of the evaluation is to evaluate the system of identification and risk management and

regulatory compliance developed by the Company, the system of safeguards that applies to the adequacy

and effectiveness of financial information, as well as the application of corporate governance provisions

of the Law. 4706/2020.

7 b. Subjects of evaluation

Subject of the evaluation are the following:

Control Environment

The review of the control environment consists mainly of the following:

▪ Integrity, Morals & Conduct of the Management

▪ Organization structure

▪ BoD

▪ Corporate responsibility

▪ Human Resources

Risk Management

It consists of the review of the risk acknowledgement and assessment procedure (risk assessment),

management and response procedures of the Company to the said risks (risk response) and the

procedures on the monitoring of the development of the risk (risk monitoring).

Control Activities

Review of the mechanisms on the control of the critical safety net emphasizing on the safety net related

to conflict of interest issues, separation of duties and governance and security of Information Systems.

Information and Communication

Review of the procedure of the development of the financial, including the reports of the auditing

mechanisms and non-financial information as well as the review of the procedures on the critical internal

and external communication of the Company.

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Monitoring of ICS

Review of the infrastructure and the mechanisms of the Company that are competent for the constant

evaluation of the components of the ICS and the report of the findings to be corrected or improved.

In particular, the operation of the following infrastructure and mechanisms are reviewed:

▪ Audit Committee

▪ Internal Audit Department

▪ Regulatory Compliance

7 c. Timing – periodicity

The evaluation of the ICS is carried out either periodically or on an ad hoc basis.

Periodicity is defined as the time period between two consecutive evaluations and which is determined

in three (3) years starting from the reference date of the last evaluation.

The time is defined as the time at which it is required to carry out either the periodic evaluation or the ad

hoc evaluation at the request of the Hellenic Capital Market Commission.

In any case, the evaluation of the ICS is part of the overall evaluation of the corporate governance system

of the Company, according to article 4 par. 1 of Law 4706/2020.

The first evaluation of the ICS for the period 17.07.2021 – 31.12.2022 is completed and forwarded to the

Capital Market Commission, according to the provisions of this decision, as in force to the law 4706/2020.

The second evaluation of the ICS for the period 01.01.2023 – 31.12.2024 is completed (as a preparation

for the next evaluation to be carried out by 31.03.2026, with a reference period of 01.01.2023 -

31.12.2025),, discussed and its results were approved both by the Audit Committee (meeting of

27.03.2025) and the BoD (meeting of 31.03.2025)

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

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

characteristics:

Matters of independence and objectivity

When selecting the evaluator of the ICS, matters of independence and integrity of the Company are taken

into consideration. The evaluator and the members of his taskforce must be independent and do not have

any dependency according to par. 1 of article 9 as particularized in par. 2 of Law 4706/2020 as well as be

objective in the course of exercising his duties.

When the evaluation is carried out by a physical person in the context of an employment or cooperation

relationship with a legal entity, the dependency relationship concerns the physical pearson himself and

not necessarily the legal entity with which he has an employment or cooperation relationship.

Objectivity is the impartial attitude and ways of thinking that shall allow for the evaluator to perform his

duties as he thinks proper and do not settle as to its quality. The objectivity requires for the evaluator not

to be affected by third parties or other facts.

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In the course of ensuring the independence and the objectivity, the evaluation of the ICS shall not be

carried out by the same evaluator for three subsequent evaluations.

Proven relevant professional experience and training

When selecting the evaluator of the ICS matters related to the knowledge and his professional experience

are taken into consideration. In particular, the head of the taskforce of the evaluation of the ICS and in

any case the signatory of the evaluation must have the appropriate professional qualifications (depending

on the professional standards that he refers to) as well as proven relevant experience (such as in

evaluations of other ICS and structures of corporate governance). The evaluator implements all the

necessary measures in order in the course of his work the persons that participate therein have the

appropriate knowledge and experience as to the duties assigned to them and he uses the suitable systems

on quality assurance, sufficient human and material resources and procedures in order to ensure the

continuity, periodicity and quality of the performance of the works.

7 e. Candidates selection and award of evaluation – Responsibilities

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

evaluator. Specifically:

Within a reasonable time and at least six months before the date of mandatory submission of the final

evaluation report to the Hellenic Capital Market Commission, the AC arranges for the selection of suitable

candidate or candidates to submit a tender within a specific deadline, after the relevant invitation (7 d).

Interested parties are invited to submit a bid within a specific deadline specified in the relevant invitation,

where relevant reference is especially made to the independence and proven experience and training in

relevant ICS and corporate governance structure evaluation projects as defined in point (7 d).

The submitted offers are reviewed and evaluated by the AC, which proposes as the competent body to

the BoD, the assignment of the evaluation of the ICS to an appropriate at their discretion candidate,

considering the independence and professional experience of the candidate. The BoD decides upon the

assignment of the project of the periodic evaluation of the ICS to the appropriate evaluator.

The Regulatory Compliance function and / or the Internal Audit Department, under the guidance of the

AC, facilitate the evaluator during the implementation of his project regarding the communication and

cooperation with the various bodies or Departments of the Company.

7 f. Evaluation report and recipients

The evaluator carries out the evaluation of the ICS, within the agreed schedule and upon completion

submits an evaluation report, which should at least include:

▪ Summary of test results and a detailed description of them;

▪ The time of submission of the evaluation report;

▪ The reference date of the evaluation and the period it covers (which starts from the next day of the

reference date of the previous evaluation).

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The summary includes the evaluator’s conclusion regarding the adequacy and effectiveness of the ICS. It

also includes the most important findings of the evaluation, the risks and the consequences arising from

them as well as the response from Top Management to these findings, including the relevant action plans

with clear and realistic timetables.

The detailed report includes all the findings of the evaluation with the relevant analyses.

Recipients of the report are defined the AC and the BoD.

The Company submits without delay to the Hellenic Capital Market Commission, and in any case within

three (3) months from the reference date of the evaluation report, the report and, if required, the detailed

report.

The annual declaration on corporate governance includes a relevant reference on the results of the

Evaluation Report, the response of the Company’s management through a competent body decision, as

well as the action plans of the Company with the relevant time plans.

8. Relevant documents – references

Reference of this policy is made to the Internal Organization and Operation Regulation of the Company

as it applies, the Regulation of operation of the AC and the Internal Audit Department and the Hellenic

Corporate Governance Code adopted by the Company.

9. Force – Exceptions

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

10. Policy Update

This Policy will be evaluated for update when significant changes are identified in the covered area or

upon the implementation of legislative changes.

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

31-12-2025, in accordance with article 14, par. 3 and 4 of L. 4706/2020

The Company, by decision of its BoD, assigned to KPMG Certified Auditors S.A. the assessment of the

adequacy and effectiveness of the ICS of the Company, with reference date of 31 December 2025. In

accordance with the provisions of section j of par. 3 and par. 4 of article 14 of L. 4706/2020 and decision

1/891/30.09.2020 of the Capital Market Commission’s BoD as applicable (the "Legislative Framework").

and the Letter of the Capital Market Commission with protocol number 434/24.02.2025, the Company

will carry out the next ICS evaluation by 31.03.2026, with a reference period of 01.01.2023 - 31.12.2025).

The assurance was carried out in accordance with the audit program included in the decision of the

Hellenic Accounting and Auditing Standards Oversight Board (HAASOB), number 278/16.01.2026 and the

International Standard on Assurance Engagement 3000 (updated) "Assurance Engagements other than

Audits or Reviews of Historical Financial Information". Based on the work carried out on March 27, 2026

by the evaluator and the evidence obtained regarding the assessment of the adequacy and effectiveness

of the Company’s ICS, is reported that nothing was identified that could be considered as a material

weaknesses of ICS according to the Regulatory Framework.

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This result for the period 01-01-2023 until 31-12-2025 is one more confirmation that the Company is

constantly vigilant in order to ensure, through continuous review and taking corrective actions, its

compliance with the applicable legislative and regulatory framework governing the ICS with the aim of its

lawful and orderly operation.

VII. a) Evaluation Policy of the Corporate Governance System

1. Introduction

The Company recognizing the importance of ensuring the continuous operation of an adequate and

complete Corporate Governance System (hereinafter referred to as the "CGS") and its continuous

improvement, where and when deemed appropriate, for the achievement of its business objectives and

in compliance with Law 4706/2020 on corporate governance, adopts this policy of Periodic Evaluation of

the Corporate Governance System (the "Policy").

2. Key elements

The scope of this policy includes the basic principles of the evaluation of the pillars of the CGS in terms of

periodicity and evaluation scope, the roles involved and the general process by which the evaluation of

the Company's CGS is carried out.

The Company's CGS includes the following:

a) ICS, including risk management and compliance systems,

b) Procedures for preventing, detecting and addressing conflict of interest situations;

c) Communication mechanisms with shareholders to facilitate the exercise of their rights and active

dialogue with them (shareholder engagement);

d) Remuneration policy, which contributes to the business strategy, long-term interests and sustainability

of the Company.

The Company through the (a) Audit Committee (b) Internal Audit Department (c) Regulatory Compliance

Unit (d) Risk Management Unit has mechanisms and functions that have as their object the continuous

evaluation of the CGS and the reporting of findings for correction or improvement.

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

The Company has established and implements a policy and procedure for preventing and dealing with

conflict of interest situations, through which it seeks (a) the indicative recording of any harmful situations

that may arise for the interests of the Company, its shareholders, customers, and suppliers, (b) the

establishment and implementation of procedures, mechanisms and systems for managing conflicts of

interest and (c) the design and implementation of procedures and systems for the prevention and

deterrence of potential losses to the interests of the Company, its shareholders, its customers and its

suppliers.

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Mechanisms of communication with shareholders

The Company has an Investor Relations sector to promote active dialogue with its shareholders. The main

responsibilities of the specialized sector are (a) the design and implementation of the Company's

communication strategy, the service and information of shareholders and other third parties, as well as

the compliance with the obligations arising from the relevant legislation, regarding the services of

shareholders and the company's announcements on the Athens Exchange market, (b) maintaining and

developing relationships with investor’s community, institutional analysts and Company’s shareholders

and (c) organizing meetings, conference calls and other events to inform investors and drafting of

corporate presentations for meetings with institutional investors in Greece and abroad.

Remuneration policy

The Company, in compliance with the legislative and regulatory framework governing its operation, has

established a remuneration policy. The purpose of the policy is to ensure that the Company remunerates

BoD members based on its short- and long-term business plan, so as to continue to create value for its

customers, shareholders and employees.

3. General Description

The Company, in the context of ensuring the continuous operation of an adequate and comprehensive

CGS and continuous improvement where and when deemed appropriate, follows this policy, which

constitutes the framework for periodic evaluation of the CGS.

4. Legal and Regulatory Framework

The content of this policy is governed by Law 4706/2020 as in force from time to time, the decisions of

the Hellenic Capital Market Commission issued under its authority, certain provisions of Law 4548/2018

on sociétés anonymes and the principles and best practices and recommendations of self-regulation

incorporated in the Greek Corporate Governance Code which the Company has adopted in accordance

with a decision of its BoD.

5. Policy Purpose

The purpose of this policy is to establish the framework to ensure the timely and correct implementation

of the CGS and the Company's compliance with the applicable legislation on relevant corporate

governance issues and corporate governance principles.

6. Policy Scope – Compliance

This policy applies to the evaluation of the CGS of PPA SA. The BoD defines and supervises the

implementation of the CGS, monitors and evaluates its implementation and effectiveness, taking

appropriate actions to address deficiencies.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

7. Policy Scope

The scope of this policy includes the basic principles of the evaluation of the pillars of the CGS in terms of

periodicity and scope of evaluation, the roles involved and the general process by which the evaluation of

the Company's CGS is carried out.

8. Assessment Objectives

The following are the main pillars of evaluation:

(a) Internal Control System:

The company's ICS is evaluated by an external evaluator, in accordance with the approved Periodic

Evaluation Policy of the ICS of PPA S.A. and the Implementation of the provisions on Corporate

Governance of Law 4706/2020, as included in the Internal Organization and Operation Regulation of PPA

SA.

In any case, the evaluation of the ICS is part of the overall evaluation of the Company's CGS, in accordance

with article 13 of Law 4706/2020.

(b) Procedures for preventing, detecting and combating conflict of interest situations:

The Company has established and implements multiple safeguards to prevent and detect situations of

conflict of interest. These include the adoption of the Code of Ethics by all staff and members of the BoD

of PPA S.A., the submission of an Annual Declaration of meeting the Independence criteria, Confidentiality

and Non-Conflict of Interest situations (for independent Non-Executive Members of the BoD), the

submission of an Annual Declaration of Confidentiality and Non-Conflict of Interest situations (for BoD

Members (except Independent) and Members of Senior Management) and the submission of a

Declaration of Independence for employees involved in tendering procedures.

engagement:

The mechanisms of (a) immediate, accurate and equal information to shareholders, as well as their

support, regarding the exercise of their rights and (b) adequate information to shareholders and

compliance of the Company with the obligations provided for in article 17 of Regulation (EU) 596/2014,

regarding the disclosure of inside information, are reviewed.

d) Remuneration Policy:

The Remuneration Policy is reviewed and evaluated in terms of:

- compliance with Law 4548/2018,

- compliance with the respective Corporate Governance Code adopted by the Company,

- its contribution to the long-term interests and viability of the Company.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

9. Evaluation Process

9.a. General

The purpose of the evaluation is to monitor the implementation, application and effectiveness of the CGS

as defined by the BoD in the context of provisions 1 to 24 of Law 4706/2020 as in force from time to time,

and the Greek Corporate Governance Code as adopted by the Company.

9.b. Time - periodicity

The evaluation of the CGS is carried out periodically at least every three (3) financial years and coincides

with the periodic evaluation of the ICS except for the first evaluation which will concern the period

17/07/2021 to 31/12/2024.

9.c. Selection of candidates and assignment of assessment

The Company ensures, through its competent bodies, that the competent evaluator of the CGS is

determined, either through internal resources or by assignment to an external evaluator.

Interested parties are evaluated in terms of independence and proven experience in relevant CGS

evaluation projects.

The AC recommends, as the competent body, to the BoD the assignment of the task of evaluating the CGS

to the appropriate evaluator, according to its judgement. The BoD by decision decides the assignment to

the appropriate evaluator.

9.d. Evaluation report and addressees

The evaluation report of the CGS shall contain the following:

▪ Summary of the audit results and their detailed description;

▪ The timing of the evaluation report;

▪ The period covered;

▪ The conclusion regarding the Corporate Governance System.

The recipient of the evaluation report is the BoD of the Company.

A relevant reference is included in the Corporate Governance Statement, which will be included in the

respective Annual Financial Report.

10. Validity - Exceptions

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

11. Review of the Policy

This Policy will be evaluated for any update when significant changes/developments are identified in the

area covered or in implementation of legislative changes.

Page 107 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

VΙΙ. b) Results of the process of the evaluation of the CGS of PPA S.A. for the period 01-01-2025 until 31-

12-2025, in accordance with article 4, par. 1 and article 13 par. 1 of L. 4706/2020 and the relevant letters

of the Capital Market Commission (prot. no 434/24-02-2025 "Comments, clarifications and

recommendations regarding the actions of listed companies in view of the assessment of the CGS and the

implementation of the law 4706/2020, in order to comply with its provisions, with a view to assessing the

Company's CGS for the period 01.01.2025- 31.12.2025”).

The Company, by decision of its BoD, following respective recommendation of AC, decided the conducting

of the evaluation process of the CGS through internal resources and specifically by the Regulatory

Compliance Unit.

The content of this policy fully complies with Law 4706/2020 and the relevant decision 1/891/30.09.2020

of the BoD of the Hellenic Capital Market Commission. The terms of periodic evaluation policy of CGS are

applied in combination with the respective provisions of the Company's Internal Organization and

Operation Regulations, the Regulations of the AC, the Internal Audit Department, the Regulatory

Compliance function and the Risk Management function.

Detailed presentation of the regulatory framework considered in the evaluation, the methodology

adopted, the material evaluated and evaluator’s findings, which do not constitute material weaknesses,

have been recorded in the Analytical Report to the AC and BoD of the Company.

This result constitutes one more confirmation that the Company is in constant compliance with the

current legislative and regulatory framework governing the CGS to ensure the lawful and orderly

operation towards achieving its sustainable development strategy.

VΙIΙ.Diversity Policy applied in relation to the Company’s administrative, managerial and

supervisory bodies

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

Given the fact the BoD is the highest administrative body of the Company, which is responsible for the

safeguarding of the broader corporate interests, the policy making and the growth strategy of the

Company as well as for the strengthening of the long-term economic value of the Company, it is very

essential for the particular body to possess, with regard to its composition, a diversity of skills, views and

abilities which at the same time respond to the need to effectively attain corporate goals.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

From the time of the Company’s establishment and until today, the entire members of the BoD fulfill all

necessary conditions and have set the foundations in order to be granted with the capacity of the member

of the BoD. At the same time, they are distinguished for their high professional skills, educational level,

knowledge, capabilities, experiences and their organizational and administrative abilities, and at the same

time they possess high standards of ethics and integrity of character. The members of the BoD cover a

broad range in terms of age combining effectively their dynamics and experience. The members, in their

majority, are holders of graduate and postgraduate degrees of domestic as well as international

universities, have worked in high ranked positions of major companies domestically and abroad.

They have also been members of the higher managerial staff of large organizations and as a result they

possess significant international experience in the corporate as well as the broader social fields and are in

position to actively contribute to the growth prospects of the Company. They finally fulfill the

requirements of suitability as well as the criteria with regard to the Company’s effective staffing and

operation.

The current composition of the BoD aims undoubtedly at the best possible facilitation of corporate goals,

as it increases the pool of skills, experience and vision that the Company has for its highest-ranking

personnel, and consequently its competitiveness, productivity and innovation.

The current nine-member BoD of the Company, consists of 6 men and 3 women and was elected in the

framework of the decision of the Company’s Management for immediate, substantial and effective

compliance and harmonization with the provisions of the law 4706/2020, as amended and in force after

law 5178/2025, on suitability, diversity and, above all, adequate representation by gender on the BoD and

completely covers the appropriate exercise of the responsibilities of the BoD of the Company, reflects the

size and activity of the Company and its characteristic feature is diversity of knowledge, skills and

experience that can contribute to the achievement of business objectives.

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

transactions with related parties

The Company recognizes the importance of its compliance with the obligations arising from articles 99 to

101 of Law 4548/2018, regarding transactions with related parties, to ensure the smooth and efficient

operation of the market.

Therefore, the Company establishes the following procedure of compliance with the obligations arising

from articles 99 to 101 of Law 4548/2018, regarding transactions with related parties:

The Group to which the Company belongs, maintains a list of related parties, from which the Company

has the opportunity to obtain relevant information.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Contracts of the Company with related parties, as well as the provision of security and guarantees to third

parties in favor of such parties, within the meaning of articles 99-101 of Law 4548/2018, are only

permitted upon prior authorization by the BoD or, in the case of paragraph 4 of this article, by the GA.

Related parties with respect to the Company are those parties defined as related parties of the Company

pursuant to International Accounting Standard 24, as well as the legal entities controlled by them,

pursuant to International Accounting Standard 27.

In the case where, a contract with a related party of the Company is awarded after and according to tender

procedures, as they are described in the approved and posted on the Company's website Regulations for

the Award of Contracts and Sub-concessions of the Company, the above paragraph is not followed.

The BoD may grant authorization, pursuant to the preceding paragraph, which is valid for six (6) months.

In the case of recurring contracts with the same person, a single authorization may be provided that sets

forth the characteristics of the contracts concerned and is valid for one (1) year.

Within ten (10) days as of the publication of the notice on the granting of the said permission by the BoD,

shareholders representing one twentieth (1/20) of the paid-in share capital may request the convocation

of the GA in order for the GA to adopt a resolution on the matter of the said permission. The contract for

which permission has been granted by the BoD shall be considered as effective only after the lapse of the

said ten-day time period or upon securing the permission of the GA or upon a written statement by all

shareholders to the Company to the effect that they do not intend to request the convocation of the GA.

If by the time permission is granted by the GA, the contract under par. 1 of this article has already been

concluded or the guarantee or security has been provided, then the granting of permission by the GA is

canceled if objected to by shareholders representing one twentieth (1/20) of the capital represented at

the Meeting.

If the transaction involves a shareholder of the Company, the shareholder concerned does not take part

at the vote in the GA and is not counted for the purposes of quorum and majority. Other shareholders

with whom the counterparty is related under a relationship falling under paragraph 2 of article 99 of Law

4548/2018 will not take part in the vote either. This paragraph is not applicable when permission by the

BoD was given with the concurrence of the majority of its independent members.

In all cases, the granting of permission by the GA is canceled if opposed by shareholders representing one

third (1/3) of the capital represented thereat.

If the permission for the conclusion of the contract was given by the GA, any amendments thereto may

be made under permission by the BoD, unless the GA has reserved for itself the right to authorize such

amendments as well.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Decision thereon by the BoD or the GA is made on the basis of a report by a certified public accountant

or auditing firm or other third party unrelated to the Company, that assesses whether the transaction is

fair and reasonable for the Company and shareholders who are not a related party, including the minority

shareholders of the Company, and explains the assumptions on which it has relied together with the

methods employed.

The BoD issues a notice about the granting of permission to the conclusion of the contract by the BoD

itself or by the GA, and the lapse of the time period set forth in paragraph 4 of the present article. Such

notice is published prior to the conclusion of the transaction. An inaccuracy in the notice cannot be

invoked towards third parties, unless the Company demonstrates that such third parties were aware of

the inaccuracy in question. The notice shall as a minimum include information: (a) on the nature of the

relationship of the Company to the related party; (b) the date and value of the transaction;

for the Company and those persons who are not a related party, including the minority shareholders. The

said notice is accompanied by the report referred to in the preceding paragraph.

A transaction entered into between the related party of the Company shall also be subjected to the

publication formalities.

Page 111 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Board of Directors Explanatory Report (according to article 4,

par. 7 and 8 of Law 3556/2007)

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

part of the Annual Report of the BoD.

Share capital structure

The Company’s share capital amounts to Euro fifty million (50,000,000€) and is divided into 25 million

ordinary shares, of a nominal value of Euro two (€2,00) each. Each share is entitled to one vote. The

Company’s shares are dematerialised and listed to trading on the Athens Stock Exchange.

According to the Company’s Articles of Association, the Company’s shares and rights deriving

therefrom are indivisible and, in case of joint ownership, the joint owners exercise their rights through

a common representative, whereas each joint owner is jointly and severally liable to the Company for

the fulfillment of the obligations deriving from the share.

Restrictions on the transfer of the Company’s shares

The Company’s shares may be transferred in the manner laid down by law and there are no restrictions

on their transfer contained in the Articles of Association of the Company.

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

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

Following the execution of a share purchase agreement and corresponding over the counter

transaction made on August 10th, 2016, COSCO SHIPPING (Hong Kong) Co., Limited obtained 51% of

shares and voting rights in the Company.

As a result of an over-the-counter transaction that took place on 06 October 2021, the percentage of

voting rights of COSCO SHIPPING (Hong Kong) Co., Limited in PPA S.A. has increased from 51% to 67%.

With the above over-the counter transaction, COSCO SHIPPING (Hong Kong) Co., Limited has acquired

from Hellenic Republic Asset Development Fund S.A. an additional 16% of shares in PPA S.A.

The above transaction has taken place under an Amended Share Purchase Agreement between COSCO

SHIPPING (Hong Kong) Co., Limited as Purchaser and Hellenic Republic Asset Development Fund S.A.

as Seller, following ratification of an Amendment to the Concession Agreement between the Hellenic

Republic and PPA S.A. (Law 4838/2021, Government Gazette 180A/ 01.10.2021).

COSCO SHIPPING (Hong Kong) Co., Limited is 100% held by China Shipping Group Co. Ltd, which is 100%

held by China COSCO Shipping Corporation Limited. As a result of the transaction, China COSCO

Shipping Corporation Limited indirectly holds 67% of voting rights in PPA S.A.

Page 112 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

As a result of the above referred transaction, the “Hellenic Republic Asset Development Fund S.A.”

(HRADF) percentage of voting rights in PPA S.A. directly has fallen from 23.1378% to 7.1378%. The total

(100%) of the shares in HRADF is owned by HELLENIC CORPORATIONS OF ASSETS AND PARTICIPATIONS

S.A (H.C.A.P)., which is 100% controlled by the Greek State.

The transfer is attributed to an amended Share Purchase Agreement following ratification of the

amendment of the Concession Agreement (Law 4838/2021, Government Gazette 180A/ 01.10.2021).

Pursuant to a transaction made on November 10, 2021, the percentage of voting rights in PPA held by

the shareholder Helikon Long Short Equity Fund Master ICAV amounts to 5.376%.

Holders of any type of shares granting special rights of control

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

Restrictions to voting rights

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

the Company’s shares.

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

limitations on voting rights

The Company is aware of a Shareholders Agreement dated 8 April 2016 between COSCO Hong Kong

Group Limited (currently incorporated under the corporate name COSCO SHIPPING (Hong Kong) Co.,

Limited) and Hellenic Republic Asset Development Fund S.A., which contains certain restrictions on the

transfer of shares and certain limitations on voting rights of the contracting parties.

The rules contained in the Company’s Articles of Association on appointment and replacement of

members of the BoD and on amendment of the provisions of the Articles of Association are not

different from the provisions of the legislation. However, the Company wishes to inform that according

to article 18 of the Articles of Association, as long as the Hellenic Republic Asset Development Fund

S.A. or any global successor or successor by operation of law of the Hellenic Republic Asset

Development Fund S.A. (each and collectively, the “FUND”) holds at least one million two hundred and

fifty thousand (1,250,000) voting shares and less than 10% of the voting shares issued by the Company

and subject to the FUND is entitled to appoint one (1) Member pursuant to article 79 of Law 4548/2018

as in force. If the FUND holds at least 10% of the voting shares, the FUND is entitled to appoint 1/3 of

the total number of Members of the BoD of the Company.

Page 113 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Should any Director appointed pursuant to paragraph 2 of this article resign or become incapacitated

for whatever reason, they shall be replaced by such personas the HRADF shall specify in a pertinent

written notice to the Company, with immediate effect.

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

No special competence different from the provisions of the legislation is awarded by the Articles of

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

Company.

Important agreements contracted by the Company, which will enter into effect, be amended or expire

in case of change in the Company’s control following a public offer and the results of such agreements.

There are no such agreements.

Agreements that the Company has contracted with the members of the BoD or with its personnel,

which provide for the payment of compensation in case of resignation or release without substantiated

reason or in case of termination of their term or employment due to a public offer.

There are no such agreements.

Piraeus, March 31 , 2026

THE CHAIRMAN OF THE BoD

HAN CHAO

Page 114 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Piraeus Port Authority S.A.

Transformation of the port into a

sustainability hub

Sustainability

Statement 2025

Page 115 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

ANNUAL SUSTAINABILITY STATEMENT

ESRS 2 General Disclosures

Sustainability Report

General Disclosures

Sustainability Report

Piraeus Port Authority S.A. (hereinafter the Company or PPA S.A.) publishes its second Sustainability Report

(hereinafter the “Report”) for the reporting period from 01/01/2025 to 31/12/2025. The current report is

prepared in accordance with the requirements of the European Sustainability Reporting Standards (ESRS) and the

Corporate Sustainability Reporting Directive (CSRD), Law 5164/2024 as in force and the EU Taxonomy Regulation

(2020/852).

The Double Materiality Principle forms the foundation of this Report, constituting a methodological framework

that was first applied in 2024. For the current reporting year, the approach included a comprehensive

reassessment of the actual and potential impacts arising from port operations. In addition, all financial risks and

opportunities were reviewed and re-evaluated, taking into account not only direct effects but also the broader

interconnections, dependencies, and conditions extending across the entire value chain. This holistic approach

ensures that both impact materiality and financial materiality are accurately reflected. In this context, the

impacts, risks, and opportunities (IROs) presented in this Report have been updated compared to the previous

year, primarily with regard to their definitions and designations, in order to enhance clarity and achieve closer

alignment with the ESRS Standards. However, the material topics, as identified in accordance with the ESRS

Standards, remain unchanged compared to the previous year.

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

The Sustainability Report has been prepared on an individual basis, consistent with the scope applied in the

Company’s annual financial statements for the financial year 2025. As the Company does not have subsidiaries,

the preparation of a consolidated Sustainability Report is not required.

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

Information relating to the value chain is presented in various sections of the Sustainability Report. This includes

a description of the Company’s upstream and downstream value chain, due diligence processes across the value

chain, and Scope 3 greenhouse gas (GHG) emissions. The assessment conducted includes an analysis of impacts,

risks, and opportunities and considers how these extend across the Company’s value chain.

Omission of Information

The Company did not make use of the option to omit information related to intellectual property, know-how, or

the results of innovation [ESRS 2:BP-1_5 d]. It also did not apply the exemption from disclosure relating to

pending developments or matters under negotiation [ESRS 2: BP-1_5 e].

Page 116 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Time Horizon, Metrics, and Uncertainty Framework

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

Throughout the Report, the Company applies the time horizons defined by the European Sustainability Reporting

Standards (ESRS) without deviation from the established definitions. This ensures the preparation of the Report

with transparency, consistency, and accuracy.

The definitions used are as follows:

• Short-term: objectives with a time horizon of less than one year

• Medium-term: objectives with a time horizon of one to five years

• Long-term: objectives with a time horizon of more than five years

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

bii]

The data included in this Report primarily reflect the Company’s own operations and are recorded and monitored

directly through internal systems, covering energy consumption, water use, waste management, and

procurement activities. Where relevant, data from third-party providers are also incorporated, particularly where

such services influence the Company’s environmental and operational performance, including maintenance

contractors, waste management partners, logistics providers, and suppliers.

While most quantitative indicators (such as Scope 1 and Scope 2 emissions) are based on direct, primary, and

verifiable data, certain environmental metrics—specifically Scope 3 emissions (see Environment Chapter, Climate

Change section)—are often calculated using industry-average data or other proxy values and are therefore

subject to a degree of uncertainty.

The measurement indicators used are based on primary data collected for Categories 3.3 and 3.5, while in certain

cases average values were used to estimate the relevant parameters. In particular, for Category 5.1, emission

factors as well as engine power were based on average data due to limited availability of asset-specific

information.

For Category 3.3, the distance-based approach of the GHG Protocol was applied, whereby emissions are

estimated based on distances travelled per mode of transport and the application of appropriate emission factors

per kilometre. The data used for the calculations were derived from a staff mobility survey conducted within the

organisation, with a participation rate of 46%.

For Category 3.5, the distance-based approach of the GHG Protocol was applied to air travel, while the average-

data approach was applied to hotel stays during business travel. In the case of air travel, the data were primary

and verifiable; however, in a limited number of instances, due to the absence of information on ticket class, the

assumption of an average passenger was applied. For the calculation of emissions from overnight stays, the data

used were primary and verifiable, while the emission factors applied were based on country-level average data.

For Category 5.1, the fuel-based approach of the Fourth IMO GHG Study 2020 was applied for CO₂ emissions,

while the energy-based approach was used for CH₄ and N₂O emissions from berthed vessels, using the respective

emission factors from the Fourth IMO GHG Study 2020. The available primary data included vessel type and size,

year of construction, and time spent at berth. Based on vessel size and type, engine power was determined using

data from the Fourth IMO GHG Study 2020, which provides average operational power values per vessel type and

size. Based on engine power and berthing time, the required energy was estimated, and subsequently, based on

the required energy and standard fuel consumption per engine type, fuel consumption was estimated for the

duration of the vessel’s engine operation.

Page 117 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Changes in the Preparation and Presentation of Sustainability Information Compared to

the Previous Reporting Period [ESRS 2: BP-2_13 a, b, c]

This Report marks the Company’s second disclosure of sustainability information in accordance with the ESRS.

Following a review of the previous report, the changes implemented, along with the rationale behind them, are

outlined below:

Changes

Reasoning

2025 Report (Data)

(Reference)

Reference Point

in the 2025

Report Where

the Change Is

Idened

Discrepancies

Energy

Eciency &

Scope 1 & 2

Emissions

Revision of

emission factors

and improvement

of available acvity

data

Update of emission

factors and improvement

of available acvity data.

The revised informaon

provides a more accurate

and comparable

representaon of

emissions between the

two reporng periods.

(The revised 2024 gures

are presented in the

“Energy Eciency and

Carbon Footprint”

secon of Chapter E1)

Performance

Monitoring

Indicators

Restatement of the

2024 nal calculaons

for comparability

purposes, without

changes to the

organizaonal or

operaonal

boundaries of the

inventory.

Scope 3

emissions

(Catg. 3.3, 3.5,

5.1)

Revision of the

calculaon

methodology

(from the GHG

Protocol to a more

targeted ISO-based

approach)

In 2025, the calculaons

were carried out using a

more targeted and well-

documented

methodology, with

increased use of primary

data.

(The revised 2024 gures

are presented in the

“Energy Eciency and

Carbon Footprint”

secon of Chapter E1)

Performance

Monitoring

Indicators

Direct comparability

with 2024 is limited

due to the change in

the underlying

calculaon

methodology.

Water

Management

Revision of water

consumpon

categorizaon and

update of 2024

data

In 2025, water

consumpon is

presented in dierent

and more detailed

categories compared to

2024.

(The revised 2024 gures

are presented in the

“Water Management”

secon of Chapter E2)

“Water

Management”

secon

Direct comparability

with 2024 is limited

due to the change in

data categorizaon.

Page 118 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Other Legislation or Generally Accepted Sustainability Reporting Standards and

Frameworks Used in the Sustainability Report [ESRS 2: BP-2-15]

In addion to the indicators dened by the ESRS, the Company has included selected disclosures in line with the

standards of the Global Reporng Iniave (GRI).

The table below presents sustainability topics disclosed in this Report that are derived from other reporng

standards.

Addional Disclosures /

Indicators

Data Point descripon and

denion

Secon in the 2025 Sustainability Report

where the metrics are presented

C-G1 C-G1-7 Board of

Directors Composion –

Average age of Board

members

ESG Informaon Disclosure

Guide 2024 issued by the

Athens Stock Exchange

ESRS 2 GOV-1 – Role of the

administrave, management and

supervisory bodies

C-G1 C-G1 Board of Directors

Composion – Average

tenure of Board members

ESG Informaon Disclosure

Guide 2024 issued by the

Athens Stock Exchange

ESRS 2 GOV-1 – Role of the

administrave, management and

supervisory bodies

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

Specific information has been incorporated by reference in order to address specific disclosure requirements. The

table below outlines the relevant European Sustainability Reporting Standards (ESRS) elements that are covered

through this approach. The table below includes sustainability topics disclosed in this Report that originate from

other reporng standards.

ESRS Disclosure Requirement

Data Point

Document Source

GOV-1 — The role of the

administrative, management and

supervisory bodies

G1.GOV-1_5b

Corporate Governance

Statement

GOV-2 — Information received by

and sustainability matters

addressed by the Company’s

administrative, management and

supervisory bodies

ESRS2.GOV-2_26a,

ESRS2.GOV-2_26b,

ESRS2.GOV-2_26c

Corporate Governance

Statement

GOV-5 Risk Management and

Internal Control System in relation

to sustainability reporting

ESRS2.GOV-5_36e

Corporate Governance

Statement

G1-1 Business Conduct Policies and

Corporate Culture

G1.MDR-P_65e

Corporate Governance

Statement

E1-5 Energy Consumption

E1-5_43_ΑR_38

Annual Financial Statements

E2-2 — Actions and resources

related to pollution

MDR-A_69_a,

MDR-A_69_b

Annual Financial Statements

E2-4 — Pollution of air, water and

soil

MDR-A_69_a,

MDR-A_69_b,

MDR-A_69_c

Annual Financial Statements

S1-6 Employee Characteristics of

the Company

S1-6_50 f

Annual Financial Statements

Page 119 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

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

The Port of Piraeus serves as a key hub for both the Greek and the global economy, bringing together multiple

business activities within an integrated operational ecosystem. Its strategic location between Europe, Asia, and

Africa, combined with strong connectivity to major shipping routes and modern infrastructure, supports its role

as an important centre for logistics and trade. The Port facilitates the movement of goods and passengers,

supports a broad range of industries, and contributes to economic activity at both national and international

levels. Its core objective is to operate as a reliable and secure hub for trade, communication, and exchange,

supporting the smooth and safe flow of goods, services, and information across regions.

Services [ESRS 2: SBM-1 40 ai]

The Company provides a wide range of services, including cargo handling, passenger and cruise-related services,

ship repair, and integrated logistics solutions across its four terminalsThe Company is also active in the real estate

sector, offering land and buildings both within the port area and in surrounding locations outside the port, which

are available for concession. The information provided during 2025 is presented below.

Passenger Traffic

Cruise Terminal

The Company aims to increase its share of the cruise market, thereby generating significant benefits for the

national economy through the creation of new jobs and the growth of income derived from tourism-related

spending.

Characteristic

Description

Cruise

terminals

Cruise Terminal A – Miaoulis

Cruise Terminal B – Themistocles

Cruise Terminal C – Alkimos

Berthing

Positions

9–11 berthing positions (depending on the length of the vessels to be

accommodated), with two additional piers currently under construction to enable the

reception of larger ships.

Key Facilities

240 coach parking spaces; arrivals and departures halls; designated parking areas for

buses and taxis; X-ray screening equipment; passport control counters;

complimentary shuttle buses from the anchorage areas to the passenger terminals;

Tourist Police presence; duty-free shops; free Wi-Fi; check-in counters; currency

exchange services; baby-changing facilities; facilities for persons with disabilities;

close proximity to the centre of Piraeus; and public transport connections near the

terminals.

Page 120 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Ferry Terminal

The Piraeus ferry terminal serves as a vital link between mainland Greece and the islands, handling millions of

passengers each year and supporting both local and regional transportation needs. The main technical

characteristics and facilities are outlined below:

Characteristic

Description

Passenger

Terminal

Passenger Terminal – Vassiliadis Quay

Passenger Terminal – Hetionas

Passenger Terminal – Agios Dionysios

Key Facilities

Covered passenger waiting areas along the entire length of the main port; 130 parking

spaces; taxi stands; pedestrian bridges; complimentary shuttle buses within the port;

free Wi-Fi within the terminals; water coolers inside the terminals; restrooms,

including facilities for persons with disabilities; digital information screens; 24-hour

telephone service providing schedule information; and pedestrian walkways.

Cargo Handling Unit

Container Terminal

The container terminal at Pier 1, operated by the Company, serves as a key hub for imports, exports, and

transshipment across the Mediterranean and Black Sea. The terminal is equipped to handle the largest container

vessels, featuring advanced electromechanical equipment.

Characteristic

Description

Technical

Characteristics

• Annual Capacity: 1,100,000 TEUs

• Operating Hours: 24/7, 365 days a year

• Total Quay Length: 1,150 meters

• Maximum Depth: 18 meters

• Total Storage Area: 72,400 m²

Infrastructure

capabilities

Equipped with 8 ship-to-shore cranes, 5 Over Super Post-Panamax Twinlift and 3

Panamax Twinlift, 1 mobile port crane, 8 rail-mounted gantry cranes (RMGs), 22

wheeled straddle carriers for material handling, 36 terminal tractors, 2 front-lift

stacking cranes, and 4 empty container handling vehicles.

Car Terminal

The car terminal is one of the largest hubs for domestic and transshipment vehicle traffic in the Eastern

Mediterranean, the Black Sea, and North Africa. In addition to the loading, unloading, and storage of new vehicles,

the terminal handles all types of wheeled cargo vehicles, including heavy machinery, trucks, mafi trailers (roll

trailers), standard trailers, and general cargo.

Characteristic

Description

Technical

characteristics

• Location: Terminal Management G2 (Keratsini – Drapetsona)

• Annual Total Throughput: over 300,000 vehicles/year

• Storage Capacity: 6,700 vehicles

Page 121 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

• Total Area: 145,000 m²

Ship Repair Zone

The Ship Repair Zone provides essential maintenance and repair infrastructure for a wide range of vessels. The

Company operates five dry docks, including three floating docks and two fixed docks, all fully equipped with

cranes. With upgraded floating piers and onshore dry-dock facilities, operational efficiency is enhanced while

strict environmental regulations are maintained, reinforcing the port’s reputation as a regional hub for ship repair

activities.

Floating Dry Docks in the Perama Ship Repair Zone

Lifting Capacity

(tn)

Length (m)

Internal breadth (m)

Floating dry dock

«Piraeus I»

15,000

202

Floating dry dock

«Piraeus II»

4,000

113

Floating dry dock

«Piraeus III»

22,000

240

Permanent Dry Docks on Vassiliadis Quay, Drapetsona

Small Permanent Dry-

Dock

12.5

Large Permanent Dry-

Dock

140

18.5

Logistics Center

The Logistics Center in Keratsini offers a wide range of cargo handling services, including TIR truck unloading,

container emptying, storage, sorting, and direct deliveries. Strategically located near the national road network

within the urban area of Attica, it ensures easy and secure access to the warehouses and supports multimodal

transport. The center features specialized facilities, modern equipment, enhanced security, and direct access to

Customs and related services, facilitating the smooth execution of customs procedures. It comprises four

warehouses: two for imported food (G-3, G-5), one for unclaimed goods (G-8), and the export warehouse.

Characteristic

Description

Storage Areas

Fenced area of 86,402 m² with a perimeter of 1,157 meters and covered storage space

of approximately 10,000 m²

Safety and

protection

• Fire detection and suppression systems and generator for uninterrupted operation

• 24/7 guards and patrols, CCTV coverage throughout all areas

Equipment

Forklift trucks, specialized container lifting equipment, self-propelled scissor lift,

pallets

Page 122 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Real Estate & Concessions

The Company’s concessioned real estate assets available for lease play a significant role in supporting the growth

and development of the concession area, while also generating additional revenue streams. These include

modern warehouses, high-quality office spaces, retail premises, and other facilities that support business activity

within and around the port. Their prime locations and modern infrastructure make them attractive for investment

and reinforce the port’s role as a key economic hub. The underground parking facility at Karaiskaki Square is also

available for concession, offering convenient access to passenger terminals and transport connections.

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

The Company’s markets and customer groups are broad and diverse. Each segment contributes to the Company’s

overall economic activity and operational resilience:

CARGO HANDLING UNIT

Terminal

Customers

Market Served

Compeve

Advantage

Strategic Role

ESG Priority

Containers

Internaonal

shipping

companies,

logiscs

service

providers,

exporters/

importers

Trade routes of

Europe, the

Mediterranean,

the Black Sea, and

the Middle East

Deep-water

berths, state-

of-the-art

cranes, highly

ecient

terminal

layout

Serves as a

commercial hub

and a vital part

of the value

chain for many

businesses

Key driver of

the port’s

compeveness

and revenue

Strengthens its

posion in the

global market

As part of the supply

chain for numerous

imports and exports,

the adopon of

sustainabilityprincipl

es directly inuences

stakeholders’

preference for the

Company as a port of

choice

Cars (Ro-Ro)

Car

manufacture

rs, vehicle

logiscs

providers,

and car

distributors

Eastern

Mediterranean,

the Black Sea, and

North Africa

Rail

connecvity,

specialized

storage areas,

and high-

capacity Ro-

Ro handling

equipment

Supports

industrial supply

chains and

trade corridors

Diversied

cargo base

Page 123 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

PASSENGER TRAFFIC

Terminal

Customers

Marget served

Compeve

Advantage

Strategic role

ESG Priority

Cruise

Internaonal

cruise

companies,

cruise service

providers

Mediterranean

tourism routes

Deep-water

berths, high

simultaneous

berthing

capacity, highly

ecient

terminal layout,

operaon of

three passenger

terminals with

passenger

services, and

gateway to the

country

Key pillar for the

development of

tourism and the

regional economy

Enhances the port’s

visibility

Strong posion in

Mediterranean cruise

markets

Posive and

negave impacts on

the environment

and society

Ferries

Ferry

operators,

tourists, and

local

passengers

Domesc Greek

market, connecng

mainland Greece

with the islands

Advanced

passenger

facilies, digital

informaon

systems, and

free internal

port transport

services

Essenal for naonal

connecvity and

social cohesion,

stable and recurring

trac

The port serves as a

crical hub

supporng a

signicant part of the

naonal economy and

tourism

Posive and

negave impacts on

the environment

and society

SHIP REPAIR ZONE

Customers

Markets Served

Compeve Advantage

Strategic Role

ESG Priority

Shipowners,

commercial

shipping

companies, and

marime

service

providers

Mediterranean and

global marime

industry

Modern repair berths,

investments in infrastructure

upgrades

Strengthens the

port’s industrial

ecosystem

Supports marime

compeveness and

employment

Health and safety of

employees

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

OTHER ACTIVITIES

Acvity

Customers

Markets Served

Compeve

Advantage

Strategic role

ESG Priority

Supply Chain

Import/export

businesses,

logiscs

companies

Naonal and

internaonal supply

chains

Proximity to

customs

services, direct

cargo handling,

and expansion

plans for

addional

logiscs

facilies

Strengthens the

port’s role as a

regional logiscs

hub, increases

throughput and

connecvity with

Europe and Asia;

supports revenue

diversicaon

Health and safety of

the local

community

Real Estate &

Concessions

Tenants

(warehouses,

oces),

commercial/retail

businesses,

parking facility

operators

Local and regional

businesses seeking

port-adjacent

facilies;

internaonal

companies needing

logiscs, oce, or

commercial space

within the port area

Strategic

waterfront

locaons near

the port;

integrated

access to port

infrastructure,

logiscs

services, and

transport

networks;

exible mix of

industrial,

logiscs,

commercial,

and oce

spaces

Provides stable,

recurring rental

income and

diversies port

revenues; aracts

complementary

businesses that

strengthen the port

ecosystem

Building energy

eciency and

potenal for green

building

cercaon;

opmized land use

and revitalizaon of

abandoned

industrial areas

instead of

unchecked

expansion

Company Performance in 2025

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

corresponding percentage change.

Business Unit

2025

2024

% Μεταβολή

Container

(TEUs)

664,581

563,725

17.9% increase in total throughput

RO/RO

(individual

units)

291,287

247,600

17.6% increase in total throughput

Cruise

(passengers)

1,863,397

1,698,877

9.8% increase in passenger trac

Ferries

(vehicles)

3,055,596

3,025,457

1% increase in vehicle throughput

Ferries

(passengers)

17,213,513

17,053,118

0.9% increase in passenger trac

Ship Repair

(vessels)

256

275

6.9% decrease in ship repair acvies

Dry docking

(vessels )

115

143

19.6% decrease in dry docking services

Logistics

(tonnage)

130,882

128,953

1.5% increase in cargo volumes

Page 125 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

To meet these market demands and the specific needs of its customer groups, the Company continuously invests

in its infrastructure, service development and people. At present, a total of 1,058 persons are employed at the

port, 100% of whom form part of the Company’s workforce working at the port facilities. Employees are further

organized into specialized business units, leveraging their expertise to meet the evolving need of global shipping

and trade. The workforce consists of the Company’s employees as well as self-employed persons (NACE 78, self-

employed persons). [ESRS 2: SBM-1_40 a iii]

In 2025, the Company recorded revenue of approximately €250.8 million, reflecting its strong market presence.

To respond to the evolving needs of global trade and the wider shipping sector, the Company continues to invest

in the development of its infrastructure and services.

Cruise

Coastal

Shipping

Concession

of Piers II &

III

Container

Terminal

Car

Distribuon

Ship Repair

(Dry Docks

and

Mooring)

Other

Sectors

Total

2024

2025

2024

2025

2024

2025

2024

2025

2024

2025

2024

2025

2024

2025

2024

2025

Income

(million

€)

30.4

37.9

12.5

9.0

81.7

90.5

50.0

58.5

27.1

25.6

15.9

14.8

13.3

14.5

230.9

250.8

[ESRS 2: SBM-1_40 b]

Research and Development

At PPA S.A. our purpose is to drive innovation and sustainable growth through strategic R&D collaborations with

Greek and international partners. By focusing on green technologies, we actively contribute to the European

Green Deal and Fit for 55 objectives, promoting energy efficiency and climate neutrality. These ongoing projects

in 2025 continue to build on the progress made in previous years.

Program

Project Descripon

PPA Budget

Co-

Funding

Rate

Role of the

Company

Climate

Resilient

Regions

Through

Systemic

Soluons and

Innovaons

ARSINOE

(HORIZON

2020)

Studying the potenal eects of

Climate Change in Ports within

the Mediterranean basin. A

Systems Innovaon Approach

(SIA) is applied with which

challenges are analyzed,

opportunies are idened, and

innovave soluons are

designed. The ulmate goal is to

create an Ecosystem that adopts

Climate Change Adaptaon

soluons for the port of Piraeus.

- Completed within 2025

• 497,500.00€

70%

Project

Partner

Page 126 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

TRIERES

(HORIZON

EUROPE)

Greece’s rst Hydrogen Valley

that brings together business,

knowledge, and regional

interests. PPA’s involvement

concerns two pilots: 1. One (1)

short sea ferry vessel retroed

with 200kW FC system, which

will be operated on the 1.6

naucal mile route of Perama-

Paloukia, situated near the port

of Piraeus. 2. One (1) Fuel Cell

Auxiliary Power Unit (FC-APU)

with a capacity of 100kWe to

produce electricity via green

hydrogen used for the heang in

PPA premises.

• 705,000.00€

• 70%

• Project

Partner

GREENLIFE4SEAS

(LIFE+)

Demonstrates the technical

feasibility, full safety and

commercial viability of

innovave soluons for in situ

recovery and reuse of sediments

from harbor dredging and

shellsh shells, used as

secondary raw materials.

• 258,402.87€

60%

Project

Partner

MISSION

(HORIZON

EUROPE)

An interoperable digital real-

me-based opmizaon and

decision support tool enabling

coordinated port call operaons,

planning and execuon in terms

of me, fuel consumpon,

environmental impact, and

safety, spanning the overall

marime supply chain. A pilot

applicaon on the “JustInTime

“concept will be applied at the

port of Valencia, the port of

Genoa, with the cooperaon of

COSCO SHIPPING Lines Spain

• 162,500.00€

• 60%

• Project

Partner

RENEWPORT

(MED)

Supports the clean energy

transion of Mediterranean

ports, transforming ports into

clean energy hubs by exploing

the untapped potenal of

renewable energy sources (RES).

It concerns the installaon of

photovoltaic units on a roof and

vehicle chargers.

319,800.00€

80%

Project

Partner

Page 127 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

TREASURE

(MED)

Soil and water polluon

reducon in and around

Mediterranean port areas

through transnaonal tesng

mini-labs, development and

applicaon of novel techniques

to restore degraded and

polluted port ecosystems. It

concerns the installaon of a

port environment quality

monitoring system with sensor

systems and sample collecon

tools.

• 328,160.00€

• 80%

• Project

Partner

ADRIREC

(ADRION)

Refers to renewable Energy

Communies (RECs) for ports.

The project facilitates the energy

transion of ADRION ports by

exploing untapped potenal of

RES through the establishment

of Renewable Energy

Communies (RECs), to enhance

their decarbonisaon potenal.

189,000.00€

85%

Project

Partner

SUPER-ALFUEL

(ADRION)

Prepares the port for the use of

eecve low- carbon/zero-

emission and safe operave

model of hydrogen, ammonia

and methanol in marine

transportaon. Explores ways in

which the supply, bunkering,

and storage of alternave fuels

should be developed. Includes

consideraons for infrastructure

construcon or renovaon, risk

management measures, and the

establishment of relevant

regulaons and standards.

172,200.00€

85%

Project

Partner

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

TRAVEL WISE

(HORIZON)

As the EU promotes synergies

between connected desnaons

(e.g., ports, airports, train

staons). The project involves

companies that are

operaonally connected,

parcularly for the Greek pilot

implementaon, with

parcipants such as AEGEAN,

HELLENIC TRAIN, and the

ATHENS INTERNATIONAL

AIRPORT. The port links to the

operaonal informaon ows

and systems of each

organizaon involved gaining

access to schedules and

passenger ows to and from the

port's previous and subsequent

desnaons, as well as receiving

real-me nocaons in case of

crises or incidents.

162,500€

60%

Project

Partner

Investments

PPA S.A. designs and implements an annual investment plan to strengthen its financial position, as well as to secure the

necessary capital investments required for the adaptation of infrastructure and the financing of actions that support

sustainable operation. According to the current Concession Agreement, the Company's Mandatory Investments amount to

a reference cost of € 293.8 million for the First Investment Period and € 56 million for the Second Investment Period. The

additional voluntary investments amount to a reference cost of € 156 million, while the additional voluntary investments for

the maintenance and repair of port and building facilities amount to € 33.3 million. By the end of 2025, the Construction

Contracted mount of the above Mandatory Investments amounts to € 380.7 million. The Accumulated Investment amount

up to December 2025 of Mandatory Investments, reached € 320 million, which concerns completed projects of € 96.2 million,

projects under execution of € 210.0 million, as well as advances of € 13.8 million.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Page 130 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Strategic Priorities

PPA S.A., serves as a dynamic hub of economic acvity, connecng internaonal economies with local

communies. As a natural global connector, it facilitates communicaon and coordinaon of trade ows across

the world, with a vision to deliver operaonal and sustainable added value to the communies it serves and the

broader value chains in which the port is embedded. With connecvity and accessibility as core principles, the

port drives growth and business development through the adopon of innovave pracces and technologies. At

its core, the port is driven by a fundamental commitment to safety and security for its employees, stakeholders,

and the wider local community.

Mission, Vision, Values

Mission

To build and operate port facilities in an efficient and reliable way to optimize productivity of available resources,

minimize environmental footprint, advance digital capabilities, and create both economic and social value for its

stakeholders.

Vision

To be established as the port of choice in the Mediterranean Sea and a major node for freight transportation in

Europe, while promoting intermodal, sustainable and smart solutions.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Values

• Profitability: Safeguarding and promoting corporate interest and the interests of our shareholders

• Excellence: Striving for continuous improvement

• Safety: Maintaining high standards for health and safety

• Professional Growth: Guiding the professional development of employees

• Responsibility: Acting to ensure both environmental and social responsibility

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

Being one of the largest ports in Europe, PPA S.A. aspires to create long-term value through strong service

governance and strategic partnerships. Our strategic approach progressively integrates sustainability ambions

and ESG principles into decision-making, ensuring the eecve management of impacts, risks and opportunies.

The Company’s commitments are outlined in its ESG and Sustainability Policy (see Policies related to business

conduct and corporate culture – Chapter G1-1). The policy is reviewed annually and provides the framework for

the sustainability strategy, which is evaluated through the double materiality assessment (DMA). This approach

ensures comprehensive monitoring and supports the ongoing update of policies, acons, and targets to eecvely

manage material impacts, risks, and opportunies (IROs).

The sustainability strategy of PPA S.A. is grounded in three ambions that drive economic progress and sustainable

outcomes, focusing on reducing the environmental footprint, fostering social involvement, and supporng the

growth and development of employees, alongside strong corporate governance. Through these commitments,

we set a series of key objecves.

As part of the Group’s sustainability strategy, the ESG Committee, established by the Board of Directors, oversees

the Company’s environmental, social, and governance performance and ensures the effective integration of non-

financial factors into business strategy and decision-making. In 2025, the Committee met five times to review the

value chain, significant impacts, risks and opportunities, and to propose sustainability goals and monitoring

indicators to the Board, while also supporting the preparation of the Sustainability Report. Through its work, the

Committee strengthens the port’s risk management and due diligence processes and ensures the implementation

of the Company’s Sustainability Policy.

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As part of its sustainability development strategy, the Company has set targets and actions, as described in the

table below.

Acons

Targets

Year

KPIs

Progress

Integraon of the

Sustainability

Strategy into the

Corporate Strategy

3 Targets per ESG

Pillar

2025

3 Targets

100% achieved in

2025

Preparaon of the

Net Zero Strategy

for the enre

Company

Achievement of

European targets,

such as the Paris

Agreement goals,

by md-century

2027

No progress was

recorded during

2025 – Ongoing

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

Identifying Stakeholders

A clear understanding of PPA S.A.’s business environment and the key parties involved at each stage was achieved

through a comprehensive value chain mapping. This mapping enabled the identification of the core stakeholder

groups embedded in the Company’s upstream and downstream activities, as well as how these stakeholders

interact with and influence the Company’s operations

Upstream Activities

The upstream segment of the value chain encompasses all entities involved in supplying the essential products,

services, and resources required for the port’s operations. This stage focuses on the delivery of foundational

inputs such as infrastructure, utilities and energy, skilled workforce, and operational as well as management

systems. These elements collectively ensure the port’s efficient, safe, and continuous functioning. Upstream

activities are organized into Tier 1, consisting of direct providers of core services and assets, and Tier 2, comprising

indirect suppliers and contractors who support and enable the primary providers.

Own Activities

PPA S.A. oversees interconnected port operations. Its core activities include cargo handling, cruise and ferry

passenger services, and ship repair, supported by warehousing and coordinated transport. Commercial

operations target shipping lines, logistics providers, cruise operators, ship repair clients, and real estate tenants.

Service quality is ensured through customer support, infrastructure upkeep, and adherence to environmental,

safety, and regulatory standards. These functions rely on procurement, advanced IT systems, skilled staff, and

financial and administrative support.

Downstream Activities

The downstream value chain of PPA S.A. includes entities that rely on the port’s after-delivery services. The

downstream boundaries extend to Tier 1 and 2, covering Tier 1 direct customers (shipping companies, terminal

operators, vehicle importers/exporters, cruise lines and tenants) and Tier 2 indirect customers (the customers of

those customers), as well as suppliers and partners involved in service and product distribution and further

handling of cargo and passenger flows. It also includes regulatory authorities, environmental and waste service

providers (working directly with the port’s output rather than vessels), as well as the local community impacted

by the port’s operations.

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How the Company creates value

[ESRS-2_SBM-1 42a, b, c]

The Company creates long-term value for

stakeholders. The main purpose of the port is

to act as a secure hub for trade,

communication and exchanges. Our strategic

focus on operational efficiency, safety, and

sustainability guides all operations, guided by

our values.

The value creation model demonstrates the

transformation of input capital into output

capital and highlights the multidimensional

impacts generated across economic,

environmental and social sectors.

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Stakeholder Engagement [ESRS 2: SBM-2_45]

Interest and views of stakeholders

PPA S.A. interacts with a wide range of stakeholder groups across all parts of the value chain. The

engagement process is designed to support a comprehensive understanding of stakeholders’

interests and expectations. As part of an ongoing action plan initiated in 2024, a survey was conducted

targeting key stakeholder groups and remained open throughout 2025. This survey has now been

updated and is to run for yet another year. This step establishes an open communication channel and

enables the identification of material issues along the value chain that require attention, planning,

and action.

The Company’s goal is to ensure transparency, build trust, and provide stakeholders with insight into

its strategy, performance, and objectives. Feedback gathered through various communication

channels (as presented at the table below), is supporting regular and constructive dialogue tailored

to each stakeholder group. The importance of this engagement is reflected during the Double

Materiality Assessment, where stakeholders actively participate in identifying actual and potential

negative impacts of the organization and are informed about the measures taken to mitigate or

remediate these impacts. The Company actively informs and engages employees and other key

stakeholders on materiality results and ESG performance through ongoing communication and

through its sustainability reporting.

Stakeholder input (based on surveys, meetings, and feedback collection) is assessed and presented

during the Company’s annual management review, with emphasis on issues related to sustainability.

These insights are discussed among the Board of Directors and the ESG Committee for the

determination of relevant actions [ESRS 2: SBM-2 45 b, d]. The outcomes of this process contribute

to the adjustment of corporate strategy, governance practices, and capital allocation decisions. The

material issues and associated material impacts, risks and opportunities are recorded as important

factors that become the subject of internal strategic reviews.

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The table presents an overview of stakeholders’ views.

Stakeholder

Group

[ESRS-2: SBM-2

45a(i)]

Engagement Channels

[ESRS-2: SBM-2 45a (ii,

iii)]

Areas of Interest

Engagement Focus

(purpose & outcomes)

[ESRS-2: SBM-2 45a (iv, v)]

• Shareholders

• Annual General

Meeng

• Press releases /

announcements

• Financial statements

and reports

• Risk Management

Reports

• Achieving nancial

returns

• Maximize

shareholder value

• Strengthening

compeveness and

the opening of new

markets

• Ensure robust

corporate

governance

• Ensure transparency

and accountability

• Build trust through

consistent reporng

and governance

• Minimize nancial

risks

• Ensure protability and

deliver dividends

• Expand market presence

and foster economic

growth (Cruise sector,

Concessions)

• Strengthen governance

and implement risk

management

• Develop and apply risk

migaon strategies

• Maintain transparent and

accountable reporng

• Financial

Instuons,

Investors and

Creditors

• Regular investor

presentaons

• Press releases /

announcements

• Financial statements

and reports

• Investor calls /

meengs

• Risk management

reports

• Meengs

• Stakeholder survey

• ESG performance

assessment

quesonnaires

• Maximize return on

investment (ROI)

• Ensure access to

capital and

favorable credit

terms

• Ensure Company

nancial stability

• Minimize credit risk

• Minimize risk

exposure to ensure

nancial stability

• Ensure compliance

with nancial

agreements

• Ensure responsible

investment

Pracces

• Ensure nancial stability

and access to capital

• Diversify revenue streams

and grow market

presence (Cruise sector,

Concessions)

• Secure contract reliability

and foster co-

development of strategies

• Maintain regular

stakeholder feedback and

engagement

• Enhance governance and

risk management

pracces

• Develop and implement

risk migaon strategies

• Provide transparent and

accountable reporng

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• Employees

and Workers

• Internal

communicaon

channels (Newsleer)

• Oce automaon

system designed to

expedite the

compleon of internal

processes

• Employee sasfacon

survey

• Corporate

announcement board

• Internal portal

• Internal complaints

process

(whistleblowing

mechanism)

• Employee commiees

and delegaons

• Employee unions

• Stakeholder survey

• Job security

• Career development

and educaon

• Health and safety at

work

• Fair compensaon

and benets

• Equal opportunies

• Recognion

• Ensure fair contract

agreements and promote

union collaboraon

• Maintain robust health

and safety systems

• Provide compeve

remuneraon and

benets policies

• Advance diversity, equity,

and inclusion (DEI)

iniaves

• Support ongoing training,

upskilling, and reskilling

opportunies

• Implement regular

performance evaluaons

• Customers

and End users

(Direct / Indirect

end-users

• Support via phone, e-

mails

• Sustainability Report

• Press releases,

announcements

• Customer sasfacon

survey

• Feedback mechanism

• Events and exhibions

• Complaints

Management

Procedure

• Stakeholder survey

• Corporate website

• Complaint and

reporng mechanisms

• Fast, reliable,

responsive, and

ecient service

• Well-maintained

facilies,

infrastructure

• Safe operaons and

secure environment

• Environmental

responsibility

• Compeve pricing

• Professional,

responsive, and

customer-focused

sta

• Competent

management

ensuring fair

treatment of

employees and

stakeholders

• Innovaon and

market reputaon

• Integrate ESG principles

into products and services

• Deliver strong value

proposion and

responsiveness to

customer needs

• Invest in infrastructure

upgrades and

maintenance

• Develop compeve

pricing strategies and

benchmark against peers

• Maintain skilled and

professional workforce

• Strengthen governance

and management systems

• Implement risk

management and invest

in R&D

• Ensure eecve

whistleblowing

mechanisms and

complaint handling

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• Complaint

Management and

willingness to collect

and act on feedback

for connuous

improvement

• Collect and act on

customer feedback

through surveys

• Maintain cered

management systems for

quality and compliance

Suppliers and

Service providers

• Public tenders

• Contracts

management

• Joint planning

sessions for common

development

• Press releases /

announcements

• Performance reviews

• Service level

agreements

• Stakeholder survey

• Payment and credit

issues

• Terms of

collaboraon (fair

contracts)

• Reliability

• Delivery mes

• Cered

management

systems

• Mutual business

growth and success

• Minimize credit risk

through sound nancial

pracces

• Establish mutually

benecial and fair

contracts

• Build capacity and

streamline supply chain

processes

• Maintain cered

management systems and

operaonal protocols

• Foster collaboraon for

eecve dispute

resoluon

• Develop long-term

partnerships based on

clear agreements and

mely payments

• Implement automated

systems to improve

eciency

• Provide training and

capability-building

programs (inducon and

other job)

• Conduct regular

performance and

competency evaluaons

• Government

and Regulatory

Authories

• Compliance and

regulatory reporng

• Direct meengs with

policy makers and

regulators

• Collaboraon on

policies shaping

• Stakeholder survey

• Regulatory

compliance (local,

naonal,

internaonal)

• Inuence policy

decisions related to

marime industry

• Facilitate cross-sectoral

collaboraon and

stakeholder engagement

• Ensure transparency in

operaons and reporng

• Maintain full regulatory

compliance

• Promote acve

parcipaon and

consultaon in policy-

making

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• R n D

(Industry

Associaons,

Academia and

Instuons)

• Parcipaon in

industry

• conferences and

workshops

• Collaboraon on R &

D projects

• Partnerships with

Universies and

Research centers

• Educaonal visits and

guided tours within

PPA S.A.’s premises

• Stakeholder survey

• Knowledge

exchange

• Achieving

innovaon

• Contribute to

technological

• advancement

• Promote cross-sector

collaboraon through EU

programmes

• Facilitate experse and

knowledge exchange

• Secure co-funding for

joint projects

• Advance decarbonisaon

and sustainability

research

• Conduct environmental

monitoring iniaves

• Support infrastructure

development and

modernizaon

• Driving technological

innovaon and

advancements

• Local

community and

NGOS

• Public meengs

• Community outreach

programs

• Environmental and

CSR iniaves

• Annual Reports

(Financial and

Sustainability)

• Joint Environmental

and CSR programs

• Press releases

• Meengs / For a

• Stakeholder survey

• Economic and

social benets

• Employment

opportunies

• Sponsorships and

donaons

• Sustainable

business pracces

that minimize

environmental

impact

• Ensure alignment of

business pracces

with SDGs

• Ensure

transparency

• Work towards

migaon of

negave impacts on

society and the

environment

• Develop partnerships to

migate environmental

and social impacts

• Invest in renewable

energy and emissions

reducon projects

• Promote regional job

creaon and economic

development

• Support community

investments and fund

donaons

• Provide detailed and

transparent reporng

• Engage in consultaon

and collaboraon for

policymaking

• Maintain ongoing

communicaon with

stakeholders

A detailed description of the key elements of engagement with stakeholders is available in the relevant

sections of this Report, as set out in the table below. [S1.SBM-2_12, S3. SBM-2_7, S4.SBM-2_8]

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Key elements of

engagement with

stakeholders

Chapter and Secon in the Report

Report page

S1.SBM-2_12

Chapter: “Our People” ESRS S1 – The Company’s

Workforce

Secon: Interests and Views of Stakeholders

254

S3. SBM-2_7

Chapter: “S3 Aected Communies”

Secon: Interests and Views of Stakeholders

291

S4.SBM-2_8

Chapter: “PPA S.A.’s commitment to its customers

ESRS S4 – Consumers and End-users”

Secon: Interests and Views of Stakeholders

304

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

Priorizing sustainability and transparency, PPA S.A. conducted the rst Double Materiality

Assessment in 2024 to evaluate the material topics that have environmental and social impacts

resulng from its operaons, and the associated material risks and opportunies alongside their

eects on nancial performance and value creaon. In 2025, the DMA exercise was re-evaluated and

the relevant IROs have been re-dened. The materiality of each IRO has not changed, yet the

denions on specic IROs have been claried. .

The Double Materiality Assessment followed a structured methodological approach in four steps. The

process involved data collecon and analysis with the acve parcipaon of experts and stakeholders.

This enabled the clear idencaon of the Company’s material impacts, risks, and opportunies. The

results of this assessment have been incorporated into the central risk management system, to ensure

resilience of the business strategy in managing challenges, meeng stakeholder expectaons and

eecvely addressing its material topics.

The review of the process during the second year of implementaon included the incorporaon of

updates and addional data sources. This review included a reassessment of stakeholder engagement

approaches, monitoring and reporng mechanisms, and the integraon of sustainability into overall

business strategy.

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The four-step DMA process:

[ESRS2: IRO-1-53 a, b]

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

The DMA is founded on the principles outlined in the ESRS. The process evaluates how the acvies

of PPA S.A. have actual and potenal posive or negave impacts on the environment, people, and

society (impact materiality). Addionally, it considers how sustainability issues inuence the

Company’s operaons by presenng real and potenal nancial risks and opportunies (nancial

materiality).

To address this dual approach the following step was followed:

1. Understanding the business context

PPA S.A. conducted a thorough analysis of its internal and external environments, as well as its enre

value chain, to idenfy key material topics. To support this evaluaon, internal data, including

stakeholder inquiries, exisng due diligence processes, and the risk management system were all

reviewed alongside publicly available company informaon from published reports. Insights from the

value chain analysis, stakeholder feedback, and external expert contribuons were all incorporated to

idenfy the key topics for the assessment.

This assessment phase was completed during 2024. In the cycle of the current reporng period (2025),

no signicant internal changes occurred in the Company’s operaons and strategy and thus the

exercise has only been updated rather than repeated.

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

To ensure a robust and comprehensive idencaon of potenal impacts, risks and opportunies, the

process began with an extensive review of leading sustainability frameworks and external sources.

This included analysing SASB and ISSB sector-specic standards, MSCI and other ESG rang

methodologies, emerging industry and sustainability trends, and benchmarking against peer reporng

pracces.

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Insights from these sources, together with relevant regulatory requirements and sustainability-

focused guidelines, were consolidated to develop an inial long list of topics that reect the most

relevant sustainability consideraons for the sector.

The long list of sustainability topics was inially compiled from various sources and subsequently

reviewed and rened into a list of relevant topics through consultaons with internal and external

stakeholders. This stakeholder engagement, including workshops, working groups, and interviews

with execuves and relevant teams, ensured that the topics reect the Group’s actual impacts, risks,

and opportunies. Based on this rened list, a preliminary inventory of potenal impacts, risks, and

opportunies (IROs) was developed, which was further elaborated and validated through ongoing

stakeholder dialogue.

In the current reporng period (2025), the process was reviewed through addional discussions and

stakeholder input. The idened impacts, risks and opportunies were reassessed, and the IROs list

was reviewed accordingly.

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

Aer idenfying the potenal material IROs, company execuves, external experts and stakeholders

were engaged to evaluate their materiality from an impact and a nancial perspecve. In this step,

the company applied dened criteria for assessing impact and nancial materiality to idenfy which

actual and potenal impacts, risks, and opportunies are considered material.

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

PPA carried out the impact materiality assessment to idenfy the most signicant environmental and

social topics across its value chain, examining both direct and indirect eects from operaons,

partners, and local communies, with a focus on sensive operaons and spots along the value chain.

The analysis considered both actual and potenal impacts. The evaluaon combined internal data

derived from Company operaons and processes with external sources, including academic research

and industry reports.

The materiality assessment for negave impacts is based on likelihood and severity, considering scale,

scope, and irremediability. For posive impacts, it is based on scale, scope, and likelihood. These

criteria are scored to assess the materiality of impacts. Materiality thresholds help establish

signicance, while scoring supports the priorizaon of future sustainability acons.

The Company maintains an ongoing dialogue with its stakeholders, including the survey conducted in

2024–2025, which incorporates the Double Materiality assessment for idenfying and priorizing ESG

maers that aect the Company. The feedback collected through this process was used to inform the

assessment of material topics.

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Risk and Opportunies Assessment - Financial Materiality [ESRS 2: IRO-1 53 c]

This process began with the assessment of potenal nancial risks and opportunies by analyzing

PPA’s operaons, market environment, and value chain. Focus was placed on acvies or contexts

related to sustainability, such as regulatory shis, stakeholder expectaons, or environmental

pressures, may have an impact on nancial outcomes. The materiality of risks and opportunies was

assessed based on the likelihood of and the potenal magnitude of the nancial eects.

The likelihood of occurrence is esmated based on industry experience, market trends, historical data,

and professional judgment. A standardized scoring scale is applied to facilitate priorizaon and

integraon of the risks into strategic risk planning.

The magnitude of the nancial impact is esmated based on their potenal impact on key nancial

and operaonal indicators such as revenue, operang costs, brand reputaon, customer trust,

investor appeal, and regulatory compliance.

The nature of the nancial impact is categorized and assessed based on the following criteria [ESRS 2:

IRO-1_53 c ii]:

• Direct or indirect impact (e.g. operaonal cost increases due to regulaon or demand shis

due to environmental performance)

• Short-term or long-term (e.g. compliance costs incurred today to secure access to green

nancing in the future)

• Financial or non-nancial (e.g. reduced occupancy rates in the event of a safety incident or

loss of trust due to poor HR or waste management)

Integrating Sustainability risks into risk management and strategy

The Double Materiality Assessment process has been fully embedded into the Group’s strategic and

risk management systems, ensuring that material impacts and dependencies are idened promptly

and considered in strategic decision-making. This approach enhances the Group’s long-term resilience

and allows for connuous adaptaon to market dynamics and the evolving regulatory requirements.

During the materiality assessment, aenon was given to how material impacts, whether posive or

negave, arising from the Group’s operaons, products, and stakeholder relaonships could lead to

nancially material risks or opportunies. Likewise, key dependencies were also assessed, including

the availability of natural resources (such as water and energy), geopolical stability, the availability

of skilled workforce, and the stability of Supply Chains and Logiscs. Disrupons to these

dependencies may signicantly aect operaonal connuity, reputaon, and nancial performance.

[ESRS 2: IRO-1 53 ci]

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The following table provides a detailed breakdown of the dependencies inuencing the port's

operaons:

Dependency

Category

Descripon

Link to Impacts, Risks, and Opportunies

Infrastructure

and Ulies

Energy Supply

(Electricity, Fuel,

Renewable Sources)

The port relies on a reliable supply of electricity

for operaons, lighng, and IT systems. Cold

ironing (shore connecon) is crucial for

reducing emissions and to cover for the

upcoming needs of customers, and

uctuaons in fuel prices or delays in

transioning to renewable sources can impact

performance

Water Supply

A stable supply of freshwater is essenal for

ship services such as cleaning and cooling and

drinking.

Waste Management

Waste management (in line with MARPOL

standards) depends on external contractors for

eecve disposal

Digital and IT

Infrastructure

Advanced IT systems are essenal for cargo

tracking, customs clearance, and security.

Cybersecurity threats or delays in

infrastructure upgrades (e.g., blockchain

integraon) can disrupt operaons.

Climate and

Environmental

Factors

Extreme Weather Events

Climate and Environmental Factors Extreme

Weather Events Storms, high winds, and rising

sea levels can disrupt cargo loading/unloading

operaons and potenally damage port

infrastructure (refer to the Appendix IRO table)

Shipping and

Logiscs

Supply Chains

Global Trade Flows

The smooth operaon of container and car

terminals relies on steady cargo throughput

driven by global trade and the services

provided by shipping lines.

Rail and Road

Connecvity

Ecient integraon with naonal and regional

transportaon networks via rail and road is

crucial for moving cargo from the port to inland

markets

Workforce

and

Availability

Availability of Skilled

Labor

The port depends on specialized labor for

operaonal acvies, logiscs management,

and ship repair services. Labor shortages, rising

wage costs, or changes in working condions

(due to legislaon or automaon) can aect

eciency.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Sustainability risks are prioritized within the Company’s overall risk management framework, using

the same methodology applied to operational and financial risks. Emphasis is placed on serious ESG

risks with long-term implications. These key risks are integrated into the central risk register and

monitored by the Board of Directors, ensuring a holistic approach and increased strategic priority

relative to other risks. [ESRS 2: IRO-1_53 ciii]

4. Selecting Material Topics

The outcome of the assessment nalized the selecon and priorizaon of the material impacts, risks,

and opportunies included in the Sustainability Report. The assessment criteria were based on clear

and well-documented methodologies to ensure that the topics idened as material have a genuinely

signicant eect on the Company’s business model, as well as on the environment and society. Upon

compleon of the assessment, the material impacts, risks, and opportunies were idened by

comparing their scores against the established thresholds. The process for determining material topics

included the use of specic criteria and thresholds to assess which issues should be considered

material. The methodology was applied by evaluang the range of scores assigned to impacts, risks,

and opportunies. Issues exceeding the predened minimum thresholds were classied as material.

The Company idened as material those maers that aect the environment and society, operang

costs or revenues, as well as any issue that may have an adverse impact on the Company’s reputaon

or its compliance with regulatory requirements. In addion, issues aecng the Company’s strategy

and its ability to respond to sustainability-related challenges are also assessed. [ESRS-2: IRO-2_59]

Regulatory

and Legislave

Dependencies

Legislaon and

Regulaons

Naonal and internaonal regulaons

(covering environmental standards, safety, and

labor laws) establish the operaonal

framework and can impact processes and

operaonal costs.

Security and

Cybersecurity

Physical and Cyber

Security

Protecng the port from physical threats (such

as terrorism or criminal acvies) and ensuring

the security of IT systems against cyberaacks

are crical for stable operaons.

Financial

Dependencies

Investment Flows and

Economic Condions

compeveness of the

port.

Access to nance and prevailing economic

condions (involving both public and private

investors) directly aect infrastructure

upgrades, investment levels, and the overall

compeveness of the port.

Internaonal

Relaons and

Cooperaon

Cross-border and

Commercial Agreements

Internaonal relaonships and commercial

agreements with other global ports and

shipping companies inuence cargo ows and

can enhance the port's compeveness

Page 147 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

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

The Double Materiality Assessment, inially implemented in 2024, is now integrated into the

Company’s broader strategic and risk management framework. Through this process, material ESG

topics are idened and assessed with the acve involvement of execuves from various business

units, ensuring their mely integraon into strategic and operaonal planning. Throughout the

process, the ESG Commiee was consulted on the Double Materiality Assessment, the approval of

which forms part of the overall approval of the Sustainability Statement. For more informaon, see

the discussion in GOV 5.

Integraon of Risks and Opportunity Management in the General Management System [ESRS-2: IRO-

1 _53 e, f, c]

PPA S.A. assesses risks through a structured COSO-based ERM approach, integrang sustainability

consideraons idened in the DMA. A central Risk Register consolidates all convenonal and ESG-

related risks and opportunies, supporng consistent priorizaon across business units. Risks are

assessed for inherent and residual exposure, ranked by likelihood and severity, and reviewed through

internal audits, the Board-approved Risk Appete Statement, probability–impact matrices, and Key

Risk Indicators (KRIs). Opportunies are evaluated in a similar manner and monitored through Key

Opportunity Indicators (KOIs) to support strategic development. Risk reporng is conducted quarterly

and annually, updang senior management and the Audit Commiee on exposures, migaon

progress and emerging issues. The 2025 Risk Registry covers key areas such as climate change,

resource management, health and safety, regulatory compliance and data protecon.

As per ISO standards requirements, each department has established its own SWOT analysis and Risk

& Opportunies assessment. In line with these requirements and governance pracces, the Quality

Department records risks and opportunies at departmental level, progressively integrang

sustainability-related aspects. This includes embedding both climate-related and other ESG risks and

opportunies into operaonal business risk assessments. All idened risks and opportunies are

documented, evaluated, and communicated through the Management Review process (ISO 9001,

14001, 50001, 14064-1).

This integrated approach strengthens oversight and accountability, ensuring that sustainability-related

risks and opportunies emerging from the DMA, are embedded into strategic and operaonal

decision-making and contribute to the Company’s long-term resilience and performance. For more

informaon see the discussion in GOV 5 – Risk Management and Internal Control Systme related to

sustainability reporng.

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

The company’s DMA process is based on a combinaon of quantave and qualitave input

parameters. The company’s business units contributed by providing the necessary data and relevant

informaon. The collecon, processing, and analysis of data were conducted in accordance with

internaonally recognized standards, sciencally established methodologies, and applicable

reporng frameworks.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The main input parameters include:

Analysis of the value chain (upstream, own operaons, downstream):

• Operaonal performance data (energy consumpon, waste generaon, water use)

• Regulatory and instuonal frameworks (EU Taxonomy, ESRS, CSRD)

• Market-based, voluntary sustainability frameworks (SASB, MSCI)

• Risk assessments and industry-specic benchmarking (sectoral trends, peer review)

• Stakeholder insights gathered through consultaons, surveys, and interviews with employees,

suppliers, customers, and instuonal stakeholders

These parameters inform both the selecon of material topics, and the mapping of impacts, risks, and

opportunies.

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

During the current reporng period, the Company introduced several improvements to the impact,

risk and opportunity assessment process compared to the previous reporng period. These

enhancements improve clarity, reliability and alignment, and include:

• A clear disncon between impacts and risks and opportunies, along with the development

of a clear, concise and robust IRO matrix.

• An assessment of sustainability trends within the sector and among peer companies.

• Enhanced stakeholder engagement through more structured feedback processes and a

recurring simplied stakeholder survey.

The DMA is reviewed and updated on an annual basis, with future revisions scheduled to be carried

out annually as part of the Company’s regular reporng cycle and strategic planning process.

Page 149 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Informaon regarding the management of impacts, risks and opportunies is disclosed in relevant

secons of this Report, as presented in the table below. [E1.IRO-1, E2.IRO-1, E3.IRO-1, E4.IRO-1,

E5.IRO-1, G1.IRO-1]

Key Elements in

Managing the Impacts

of Risks and

Opportunies

Chapter and Secon in the Report

Report Page

E1. IRO-1

Chapter: “Our Commitment to

Environmental Responsibility: ESRS E1 –

Climate Change, E2 – Polluon”

Secon: Climate Change Management,

Energy, and Greenhouse Gas Emissions

220

E2.IRO-1

Chapter: “Our Commitment to

Environmental Responsibility: ESRS E1 –

Climate Change, E2 – Polluon”

Secon: Climate Change Management,

Energy, and Greenhouse Gas Emissions

235

E3.IRO-1

Chapter: “Our Commitment to

Environmental Responsibility: ESRS E1 –

Climate Change, E2 – Polluon”

Secon: Water Management

248

E4.IRO-1

Chapter: “Our Commitment to

Environmental Responsibility: ESRS E1 –

Climate Change, E2 – Polluon”

Secon: Biodiversity

252

E5.IRO-1

Chapter: “Our Commitment to

Environmental Responsibility: ESRS E1 –

Climate Change, E2 – Polluon”

Secon Circular Economy

249

G1. IRO-1

Chapter: “G1 Business Conduct”

Secon: Policies related to business

conduct and corporate culture

321

Material Impacts, Risks, and Opportunities and Their Interaction with the

Company’s Strategy and Business Model [ESRS 2: SBM-3_48 a, b, c i, ii, iii, iv, d, h]

By identifying thematerial impacts, risks and opportunities, the Company builds resilience and can

anticipate emerging challenges while constructing a resilient response framework and shaping an

agile strategy that leverages opportunities and enhances differentiation. In this way, sustainability

becomes a driver of transformation and may eventually turn into a source of competitive advantage.

PPA integrates all environmental, social, and governance IROs into its overall corporate strategy and

enterprise risk management system ensuring oversight, improved decision-making, and alignment

between sustainability priorities and operational performance.

Page 150 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The table below presents the results of the Company’s double materiality analysis following the

reassessment process, as described above in the various stages of the methodological approach, as

well as topicsthat are specific to the Company.

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

Sustainability

Topic

Subtopic

Time

Horizon

Value Chain Posion

Upstream

Own

Operaon

Downstream

ESRS E1

Climate change

Energy Consumpon

and GHG Emissions

Acvies controlled

either directly by the

Company or by

enes along the

port’s value chain

consume energy. This

consumpon leads to

greenhouse gas (GHG)

emissions, which

contribute to climate

change. To ensure the

smooth operaon of

its acvies, as well as

to support services

and business

relaonships, the

Company requires a

connuous and

reliable energy supply.

Actual

Negave

ESRS E2

Polluon

Polluon of Air

Air polluon is a key

focus for the Company

and includes emissions

of sulfur oxides (SOx),

nitrogen oxides (NOx),

parculate maer

(PM), carbon

monoxide (CO), and

volale organic

compounds (VOCs).

These emissions

originate from ships,

cargo handling

equipment, trucks,

and trac generated

by port acvies,

aecng the wider

region. To a large

extent, air polluon

arises along the

Company’s value chain

and has negave

impacts on local air

quality, public health,

and the broader

ecosystem.

Actual

Negave

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(amounts in Euro unless stated otherwise)

Polluon of Coasts,

Water Column and

Sediments (Company

Specic)

The Company’s

acvies across the

enre value chain

signicantly aect

marine ecosystems

through the polluon

of coastal waters, the

water column, and

sediments. Over me,

port expansions lead

to the loss of marine

habitats, increased

stress on aquac

species, and negave

impacts on sheries,

while the overall

ecosystem of the

wider area is

degraded. At the same

me, the quality of life

of neighboring

communies is

aected, as they may

lack access to clean

coastal waters. Oil and

chemical spills,

although usually

limited in scale, sll

occur, while ocean

acidicaon

constutes an

addional form of

polluon linked to

port acvies and

locally impacts the

water column.

Actual

Negave

Noise Polluon

(Company Specic)

The Company’s

acvies and business

relaonships are

linked to trac control

within the port and

the wider area, cargo

handling, construcon

works, shipping, and

land transportaon.

These acvies

generate noise

polluon, which

degrades the quality

of life of neighbouring

communies and may

cause health eects

for residents of the

surrounding areas.

Actual

Negave

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ESRS S1

Own Workforce

Work-life Balance &

Well-being

PPA S.A. provides safe

and fair working

condions through a

clear internal

regulatory framework

and connuous

dialogue with

employees. Employees

benet from stable

employment, access

to health services, and

family‑oriented

benets, which create

a lasng posive

impact on their well-

being and strengthen

the Company’s trust,

commitment, and

operaonal stability.

Actual

Posive

Occupaonal Health

and Safety

The Company

operates in a

demanding and

inherently high-risk

port environment,

where employees are

exposed to

occupaonal hazards

arising from vessel

movements, the use

of heavy equipment,

and the connuous

operaon of facilies.

Although the

Company implements

strict procedures,

targeted training

programs, and

monitoring systems to

ensure Occupaonal

Health and Safety,

work-related risks

cannot be eliminated,

making the existence

of eecve response

and remediaon

mechanisms essenal.

Actual –

Potenal

Negave

Longterm

impact (>5

years)

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(amounts in Euro unless stated otherwise)

Equal Opportunies

The shipping and port

sector has long faced

gaps in diversity and

gender equality, with

women and minority

groups being

signicantly

underrepresented in

most posions. The

Company integrates

key principles of equal

opportunies and

non-discriminaon

into its human

resources

management

framework, ensuring

fair treatment in

recruitment,

remuneraon, and

career development.

While the Company

currently records a

low percentage of

female employees, in

linewith broader

industry trends; it

implements inclusive

hiring pracces,

equal-pay assurance

controls, and

mentoring programs

that can generate

measurable social

value and highlight

PPA S.A.

Actual

Posive

Employee

Engagement and

Social Dialogue

The Company plays a

vital role in job

creaon at the local

level, in strengthening

naonal economic

development, and in

facilitang

internaonal trade.

The Company has a

tangible posive

impact on

employment and on

the economic

development of the

communies

neighboring the port,

as well as on the

naonal economy as a

whole.

Actual

Posive

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PIRAEUS PORT AUTHORITY S.A

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(amounts in Euro unless stated otherwise)

Training and Skills

Development for New

Technologies

(Company Specic)

The Company exhibits

dependencies on its

human capital. In light

of internaonal

decarbonizaon

targets and the search

for alternave fuels

within the broader

marime sector, the

upskilling and

reskilling of

employees—so that

the skills required for

new technologies

remain available—is

crical for maintaining

operaonal

performance. The

potenally posive

impact lies in the

Company’s ability to

ancipate these

developments

promptly and to

strengthen workforce

readiness, thereby

migang safety risks

and supporng a

smooth and

sustainable transion.

Potenal

Posive

Long-term

Impact (>5

years)

ESRS S3

Aected Communies

Job Creaon and

Economic Growth

(Company Specic)

The Company plays a

vital role in job

creaon at the local

level, in strengthening

naonal economic

development, and in

facilitang

internaonal trade.

The Port of Piraeus

has a tangible posive

impact on

employment and on

the economic

development of the

communies

neighboring the port,

as well as on the

naonal economy.

Actual

Posive

Medium-

term

Impact (<5

years)

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Polluon Related

Community Eects in

Relaon to Health &

Quality of Life (Spills,

Noise, Emissions,

Waste, Trac)

The communies

surrounding the Port

of Piraeus are exposed

to tangible pressures

associated with the

Company’s port and

marime acvies,

primarily due to trac

congeson linked to

the movement of

heavy vehicles,

transport ows, and

the overall operaonal

acvity in the wider

area. This impact may

aect residents’ daily

lives, causing delays in

transportaon,

increased disturbance,

and a deterioraon in

the quality of life in

the neighborhoods

adjacent to the port.

Actual

Negave

Medium-

term

Impact (<5

years)

Corporate Social

Responsibility

(Company Specic)

PPA S.A., as a port

authority, interacts

directly with the local

communies. As a

crical hub in global

trade, the port is

required to operate

responsibly, ensuring

safe working

condions, the

protecon of human

rights across the value

chain, the reducon of

polluon, and the

transparent and

meaningful

engagement of

stakeholders. A strong

Corporate Social

Responsibility

approach by the

Company. reinforces

Actual

Posive

Medium-

term

Impact (<5

years)

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the trust of local

communies,

regulatory authories,

and business partners,

supporng the

Company’s social

license to operate and

its reputaon.

ESRS S4

Consumers & end-users

Passenger Port

Operaon Safety &

Security (Company

Specic)

The operaon of the

Company may have

potenally negave

impacts on the safety,

health, and protecon

of passengers who use

the port facilies and

services, including

adults, children, older

individuals, persons

with disabilies, and

other visitors. Due to

the scale and intensity

of marime and

passenger acvies,

port users may be

exposed to accidents,

emergencies, or

security incidents that

could endanger their

well-being or disrupt

their travel. Such

incidents directly

aect individuals who

interact with the port

or depend on its safe

and smooth operaon.

Potenal

Negave

Medium-

term

Impact (<5

years)

ESRS G1

Business Conduct

Stakeholder Trust

Maintaining and

strengthening

stakeholder trust is a

crical factor for PPA

S.A., as it supports the

Port’s social license to

operate, ensures

investor condence,

and reinforces

long‑term

partnerships

throughout the value

chain.

Actual

Posive

Medium-

term

Impact (<5

years)

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Risks and Opportunities Identified through the Double Significance Assessment

The table below summarizes the key risks (R) and opportunities (O) identified through the Double

Materiality Assessment, along with their relevant descriptions and specific points of occurrence in the

value chain (upstream activities, own operations, downstream activities).

ESRS

Descripon

Time Horizon

Posion in the Value Chain

Upstream

Own

Acvies

Down

strea

ESRS E1

Climate Change

Energy Dependence

Energy consumpon is a crical factor for the

Company, as almost all operaons depend on

a connuous supply of energy. The energy

comes from the naonal grid, with possible

support from EU reserves during periods of

high demand. Energy consumpon is not only

a cost, but also a systemic risk that aects the

long-term resilience and sustainability of

operaons.

Long-Term Risk

>5 years

Natural Hazards due to Climate Change

The Company. It is exposed to natural risks

stemming from climate change, which may

negavely aect its operaons. The

associated natural hazards include, but are

not limited to, marine ooding from storms,

heavy rainfall, increased wind speeds, and

more frequent or prolonged heatwaves.

These phenomena negavely aect safety

and operaonal connuity throughout the

value chain and may cause disrupons,

especially if the energy supply is also aected.

The Company can strengthen its resilience

through appropriate adaptaon acons.

Long-Term Risk

>5 years

Climate Change Transion Risks

The Company faces transion risks related to

regulatory changes and the ghtening of

greenhouse gas emissions legislaon, as well

as market-driven changes. These risks arise

from the transion to a low-carbon economy

and include policy, market, technology and

reputaonal impacts. Addressing them

requires migaon acons and measures,

such as decarbonisaon, electricaon and

adaptaon to relevant regulatory

developments.

Long-Term Risk

>5 years

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Transion to Renewable Energy Sources /

Energy Mix ImprovementThe improvement

of the energy mix and the gradual full

transion to renewable energy sources is an

important opportunity for the Company.

Electricity from renewable sources can lead to

cost reducon, reducon of emissions,

enhancement of compeveness and

reducon of negave impact on the

environment and society.

Long-Term

Opportunity

>5 years

Parcipaon in EU Climate Finance Programs

Access to European programs, such as the EU

Green Deal, CEF Transport, LIFE, HORIZON or

the EU Innovaon Fund, oers external

nancing opportunies that can support both

the transion to renewable energy sources

and the implementaon of specic migaon

acons. The use of these nancial tools can

reduce the Company's capital expenditures,

foster innovaon and promote cross-sectoral

cooperaon.

Long Term

Opportunity >5

years

Use of Arcial Intelligence PlaormsThe

Company can benet from the

implementaon of digital energy monitoring

plaorms, arcial intelligence soluons for

ship trac planning, and integrated smart

grid systems. These systems allow for real-

me monitoring and opmizaon of energy

consumpon in loading and unloading

equipment, lighng, and electric vehicles.

Overall, an improvement in the performance

of the Company is expected. as well as

reducing the impact and risks of the

transion.

Long-Term

Opportunity

>5 years

ESRS S1

Own Workforce

Employee Health and Safety Incidents

Employee health and safety incidents

constute a constant risk to the Company, as

the nature of port operaons exposes

personnel to potenal risks related to heavy

machinery and ship acvity. Such incidents

may result in injuries, business interrupons,

legal obligaons or even negave eects on

the reputaon of the Company.

Short-term

Danger

<1 year

Aracng Diverse Human Resources

The limited diversity that characterizes the

shipping sector creates a strategic

opportunity for PPA SA to posion itself as

an employer of choice and leader in

inclusion issues. By aracng and retaining a

wider range of talent including women,

younger professionals, people from diverse

cultural backgrounds and underrepresented

groups. The Company can strengthen the

whole beer meet market and stakeholder

expectaons, and ulmately improve its

operaonal performance.

Medium-term

Opportunity

<5 years

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(amounts in Euro unless stated otherwise)

Skills Shortage and Technological Readiness

The increasing automaon, digitalizaon and

energy transion of port operaons creates a

material risk for the Company in case human

resources are not suciently prepared for

new technologies. The skills decit may lead

to reduced producvity, increased security

risks and loss of compeveness compared

to more technologically advanced ports.

Medium-term risk

<5 years

Upskilling - Technological Skills of the

Workforce

The transion to digital and sustainable port

operaons oers PPA SA a substanal

opportunity to enhance its compeveness

by upgrading the skills of its human

resources. The systemac development of

employees' skills ensures business connuity

and supports the long-term viability of the

Company.

Medium-Term

Opportunity

<5 years

ESRS S4

Consumers and End Users

Failures and Safety Incidents

A signicant operaonal risk for PPA S.A. is

related to the possible occurrence of failures

or safety incidents, which could cause

damage to individuals, disrupt operaons or

damage crical infrastructure.

Medium-term risk

<5 years

ESRS G1

Business Conduct

Robust Governance and Risk Management

Having strong governance and risk

management policies in place creates

signicant opportunies for the Company, as

it can ensure eecve oversight, clear

decision-making, and liming exposure to

corrupon or regulatory non-compliance.

Addionally, having a robust governance and

risk management framework in the Company

prevents mismanagement of nancial

resources, regulatory violaons, and

reputaonal deterioraon. Through clear

policies, accountability mechanisms, and

internal controls, risks such as corrupon,

non-compliance, and operaonal

ineciencies are migated, enhancing

stakeholder trust and the Port's credibility.

Robust risk management policies and

procedures further protect the Port from

operaonal disrupons, legal disputes, and

strategic setbacks, enhancing its resilience

and long-term compeveness.

Medium-Term

Opportunity

<5 years

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Cybersecurity Threats

The lack of eecve cybersecurity measures

can put the Company at crical risk, with

potenal repercussions such as operaonal

disrupons, data breaches, and loss of trust

from stakeholders. A successful cyberaack

could paralyze key port operaons,

compromise sensive commercial and

personal data, and bring signicant nancial

and legal consequences.

Medium-term risk

<5 years

Operaonal Procedures and Controls

The strengthening of operaonal processes

and controls oers PPA SA the opportunity

to improve governance, eciency and

accountability. Through digitalizaon and

automaon, standardized processes can

opmize resource ulizaon, support data-

driven decision-making, and ensure

consistent compliance with internaonal

standards.

Medium-Term

Opportunity

<5 years

Technology and Digital Transformaon

Digital transformaon oers the Company a

signicant opportunity to enhance

eciency, transparency and resilience.

Smart technologies support data-driven

operaons, opmize resource ulizaon,

and enhance cybersecurity and compliance.

These developments can make PPA a leader

as a smart and sustainable port in the

Mediterranean.

Long-Term

Opportunity

>5 years

Access to Green Finance

Strong ESG performance oers the

Company the opportunity to aract

nancing ed to green growth and

sustainability. Access to such funds allows

for investments in energy-ecient

infrastructure and renewable energy

iniaves that reduce environmental

footprint and operang costs.

Medium-Term

Opportunity

<5 years

Compeve Advantage and Regional

LeadershipThe integraon of strong

governance, digital innovaon, and

sustainability can enable the Company. to

strengthen its regional leadership in the

Eastern Mediterranean. Improved eciency,

transparency, and environmental

performance may make the port a

benchmark for sustainable operaons and a

preferred partner in global trade networks.

Long-Term

Opportunity

>5 years

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Geopolical Externalies and Domesc

Polical Environment

(Special Topic for the Company)

Regional and internaonal polical

instability may disrupt the Company's

operaons, trade ows and investment

acvity. Geopolical tensions, polical

changes, or economic uncertainty can

impact sea routes, costs, and investor

condence.

Medium-term risk

<5 years

Supplier/Contractor Selecon Risk

Inadequate adherence to specicaons and

standards during the supplier/contractor

selecon process and tender processes may

lead to regulatory violaons, contractual

failures, or ethical issues. However, this risk

is migated through enhanced due diligence

processes, the integraon of ESG criteria,

and an-bribery clauses into contracts.

guarantees for the protecon of suppliers'

data as well as systemac and enhanced

oversight of partners.

Medium-term risk

<5 years

Information on the interaction of impacts, risks and opportunities with the Company's strategy and

business model are disclosed in the relevant sections of the Report, as set out in the table below.

[Ε1.SBM-3, S1.SBM-3, S3. SBM-3, S4.SBM-3]

Signicant Impacts, Risks and

Opportunies and their

Interacon with the Company's

Strategy and Business Model

Chapter and Secon

Report Page

E1. SBM-3

Chapter: Our Approach to Manage PPA S.A.

Material Impacts, Risks, and Opportunies (IROs) -

Climate Change- E2 – Polluon"

Secon: Climate Change

215

S1. SBM-3

Chapter: "Our People ESRS S1 – The Company's

Workforce"

Secon: The Company's Workforce

253

S3. SBM-3

Chapter: "S3 Aected Communies"

Secon: Material impacts, risks and opportunies

and their interacon with the strategy and business

model of the Piraeus Port Authority

290

S4. SBM-3

Chapter: "The Company’s commitment towards the

customers of ESRS S4 – Consumers and end users"

Secon: Material IRO Issues and Their Interacon

with Strategy and Operaons

303

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(amounts in Euro unless stated otherwise)

Impact on the Environment and People

Environmental, social and governance issues affect the Company's business model and value chain,

requiring strategic adaptation and investment. Climate change, greenhouse gas emissions, resource

consumption, and community health risks are key challenges for businesses. These issues influence

the Company's strategy, shape the business model, and also arise throughout the entire value chain,

from upstream suppliers to downstream port users.

In the previous reporting period, a list of ESG-related objectives was submitted (see updated version

of the Objectives, Targets and Progress section). In the current Sustainability Report, the Company

presents the progress made and the efforts to gradually incorporate the necessary changes into its

operations.

The Company has launched actions to address climate change and reduce carbon dioxide emissions,

focusing on investments in renewable energy sources, alternative fuel supply services to ships,

circular economy practices and digital technologies (IoT, preventive maintenance and automation) to

improve efficiency. This direction has already begun to guide project planning and resource

allocation. [ESRS 2: SMB-3_48 b].

The Company recognizes that its operations create both positive and negative impacts. Negative

environmental impacts include greenhouse gas and air pollutant emissions, noise pollution, and

potential marine or coastal pollution, which can impact ecosystems and community well-being.

Positive impacts include contributing to economic development, creating jobs and strengthening

green infrastructure and services. These impacts stem both from direct activities, such as ship

movements and cargo management, and from activities along the entire value chain, including

relationships with suppliers and shipping companies. [ESRS 2: SMB-3_48 c(i)]

To manage these impacts, the Company has started to implement targeted actions, such as switching

to electrified equipment, enhancing environmental monitoring and applying ESG criteria to supplier

selection (see section Governance G1-2). The Company is also actively involved in 9 EU-funded

projects that support decarbonization and biodiversity protection. Through the risk assessment

process, the Company integrates and monitors the environmental impacts that may create financial

obligations, regulatory risks and loss of stakeholder trust, while opportunities support innovation and

competitive advantage. [ESRS 2: SMB-3_48 c(i)]

The Company recognizes the social dimension of its operations, including employee well-being, health

and safety, and the port's relationship with local communities. Initiatives to improve infrastructure,

port-city connectivity, and stakeholder engagement have been initiated and continue to enhance

resilience and compliance with evolving expectations. negative or positive. Among the negatives are

the pressure on local communities and the challenges for the workforce, while the positive ones

include local employment, skills development and the strengthening of regional economic activity.

Unmanageable social risks can cause reputational damage or operational disruption, while

opportunities contribute to stronger partnerships and increased social value. [ESRS 2: SMB-3_48 ci]

Page 163 από 437

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(amounts in Euro unless stated otherwise)

Impact of Activities and Business Relationships

The environmental and social impacts associated with the Company's operations and business

relationships may manifest as financial risks or opportunities, impacting the Company's operational

performance and cash flow. [ESRS 2: SBM-3_48 c i, ESRS 2: SBM-3_48 civ] Tightening environmental

and other regulatory requirements is a key source of financial risk, as it may require additional

compliance investments, temporarily putting a strain on the Company's financial position. In addition,

potential deviations from the regulatory framework could result in fines, legal consequences, or

adverse effects on the Company's reputation. In line with new environmental requirements, they may

be impaired, while increased environmental remediation obligations may lead to the recognition of

new provisions. [ESRS 2: SBM-3_48 d]

As part of its strategy, the Company is making investments in sustainable technologies and green

infrastructure, which have contributed to enhancing the value of its fixed assets. Although the

implementation of these investments implies a temporary increase in liabilities and short-term cash

flow pressures, it is expected to pay off in the long term through the reduction of operating costs.

The adoption of energy-efficient solutions and the utilization of renewable energy sources support

improving profitability while reducing the environmental footprint. [ESRS 2: SBM-3_48 ci]

At the same time, the transition to more sustainable practices creates significant opportunities, such

as further improving energy efficiency, containing operating costs and developing partnerships with

environmentally responsible stakeholders. These developments strengthen the port's competitive

position and support the diversification of the Company's revenues [ESRS 2: SBM-3_48 c, iv]. In

addition, participation in innovative partnerships, EU programs and improved transparency promote

competitiveness and strengthen the Company's strategic direction. (ESRS 2: SBM-3_48 c i]

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

Risk management plays a central role in decision-making and, together with strategic and execuve

management, supports the Company's transion from tradional risk and crisis management to

enhancing organizaonal resilience. As part of its sustainability strategy, the Company plans to

conducta resilience analysis aimed at enhancing its ability to address signicant impacts and risks,

while idenfying and capitalizing on signicant opportunies. Upon compleon of this analysis, the

Company will be able to further assess the resilience of its strategy in relaon to the signicant risks

and opportunies in the next reporng period.

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

3_48g]

In 2024, impacts, risks, and opportunies were idened and revised in 2025. In this context, no new

double materiality assessment was carried out in 2025. Instead, changes were made to the IROs to

ensure a clearer and more accurate representaon of topic materiality, including separaons,

renamings, and new addions.

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(amounts in Euro unless stated otherwise)

The table below shows the relevant changes: it includes the tle of each IRO as disclosed in 2024 and

its alignment with the 2025 IROs, where the individual changes are reected.

ESRS

Subtopic

2024 Materiality Status

Change

2025 Materiality Status

Impacts, Risks, and Opportunies

Noise Polluon

Renaming

Noise Management (Company-

specic topic)

Energy Mix

Split

Energy Dependence

(Risk)

Transion to Renewable Energy

Sources / Energy Mix Improvement

(Opportunity)

Climate Change Adaptaon

Renaming

Physical risks due to Climate Change

(Risk)

Climate Change Migaon

Renaming

Climate Change Transion Risks

(Risk)

New Addion

Parcipaon in EU Climate

FundingPrograms (Opportunity)

New Addion

Use of Arcial Intelligence

Plaorms

(Opportunity)

Health, Safety and Well-

being

Split

Work-Life Balance and Well-Being

(Impact)

Occupaonal Health and Safety

(Impact)

Employee Health and Safety

Incidents (Risk)

Employee engagement and

social dialogue

Renaming

Employee Engagement and Social

Dialogue (Impact)

Training and skills

development in new

technologies

Split

Skills Shortage and Technological

Readiness (Risk)

Upskilling - Technological Skills of

the Workforce (Opportunity)

New Addion

Aracon of a Diverse

Workforce(Opportunity)

Community impacts related

to polluon aecng health

and quality of life. (Impact)

Renaming

Impacts of polluon on the

community in relaon to quality of

life (Impact)

Safety and Security in

Passenger Terminals

(Impact)

Renaming and

Spling

Safety and Protecon of passengers

during port operaons (Company-

specic) (Impact)

Accidents and Safety Incidents (Risk)

New Addion

Stakeholder Trust (Impact)

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(amounts in Euro unless stated otherwise)

Governance Structure and

Composion

Renaming

Robust Governance and Risk

Management (Opportunity)

Economic growth and

organizaonal digitalizaon

Split

Cybersecurity Threats (Risk)

Operaonal Procedures and

Controls (Opportunity)

Environmental

Management System

(Company-specic topic)

Renaming

Compeve Advantage and

Regional Leadership (Opportunity)

Corrupon and Bribery

Merged into

another IRO

Robust Governance and Risk

Management (Opportunity)

Whistleblower Protecon

Merged into

another IRO

New Addion

Access to Green Financing

(Opportunity)

New Addion

Geopolical Externalies and

Domesc Polical Environment

(Company-specic topic), (Risk)

New Addion

Supplier/Contractor Selecon Risk

Disclosure requirements in the European Sustainability Reference Standards

(ESRS) covered by the company's Sustainability Report [ESRS 2: IRO-2_56]

The table below provides an overview of the data points derived from the ESRS, which are derived

from other European legislaon, as well as informaon on where they can be located.

General disclosures

ESRS Disclosure Requirements

Secon of the ESRS 2

Report

Page

BP-1

General basis for the preparaon of

the Sustainability Report

General Disclosures

115

BP-2

Nocaons in relaon to special

circumstances

Time Horizon, Indicators and

Uncertainty Framework

116

GOV-1

The role of administrave, managerial

and supervisory

bodies

Governance Structure and

Sustainability Oversight

184

GOV-2

Informaon received and sustainability

issues

examine the administrave,

management and supervisory bodies of

the undertaking

Governance Structure and

Sustainability Oversight

184

GOV-3

Integrang performance-related

sustainability in incenve schemes

GOV-3 - Integrang

Sustainability-Related

Performance into Incenve

Schemes

189

GOV-4

Due diligence statement

GOV-4 - Due Diligence

Statement [ESRS2. GOV-4_30;

32]

190

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GOV-5

Risk management and internal controls

in relaon to sustainability reporng

GOV-5 Risk Management and

Internal Control System on

Sustainability Reporng

191

SBM-1

Strategy, business model and value

chain

Strategy, Business Model &

Value Chain

119

SBM-2

Interests and views of interested

pares

Stakeholder Engagement

136

SBM-3

Signicant impacts, risks and

opportunies and the

interacon with strategy and business

Model

Impact of Acvies and

Business Relaonships

163

IRO-1

Descripon of the process for

idenfying and assessing material

impacts, risks and opportunies

The DMA methodological

approach

142

IRO-2

Nocaon requirements under the

ESRS covered by the company's

Sustainability Report

Disclosure requirements under

the European Sustainability

Reporng Standards (ESRS)

covered by the company's

Sustainability Report

165

Environment

European Sustainability Reporng Standards

(ESRS) Disclosure Requirements

ESRS Report Secon E1, E2,

E3, E4, E5

Report

Page

Climate Change

E1. GOV-3

Integrang sustainability-related

performance into incenve

schemes

Table "Environmental

Policy"

213

E1-1

Transion Plan for Climate

Change Migaon

Climate Change Adaptaon

Acons,

Planning and

Ongoing Iniaves

218

E1. SBM-3

Signicant impacts, risks and

opportunies and the

interacon with the strategy and

the business

Model

European Taxonomy

194

E1. IRO-1

Descripon of the procedures for

idenfying and detecng

assessment of the signicant

impacts, risks and

climate-related opportunies

European Taxonomy

194

E1-2

Policies related to climate change

migaon and adaptaon

Table "Environmental

Policy"

213

E1-3

Acons and resources related to

climate change policies

Change

Climate Change Adaptaon

Acons,

Planning and

Ongoing Iniaves

218

E1-4

Climate change migaon targets

and

adaptaon to it

Climate Change

Management, Energy and

Greenhouse Gas Emissions

220

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(amounts in Euro unless stated otherwise)

E1-5

Energy Consumpon and Mix

Acons Related to Own

Acvies

224

E1-6

Mixed emissions of scope 1, 2, 3

and total greenhouse gas

emissions

Energy Eciency and

Carbon Footprint

228

Polluon

E2-1

Polluon-related policies

Table "Environmental

Policy"

213

E2. IRO-1

Descripon of the procedures

for idenfying and detecng

assessment of material impacts,

risks and opportunies

associated with polluon

Polluon

235

E2-2

Polluon-related acons and

resources

Acons, performance and

measurement indicators

239

E2-3

Polluon targets

Targets and acons for

polluon prevenon and

reducon

236

E2-4

Air, water and soil polluon

Acons, performance and

measurement indicators,

Air Quality Monitoring

Program

245

E2-5

Substances of concern and

substances of very high concern

Acons, performance and

indicators

Measurement Indicators

239

Water and marine resources

E3. IRO-1

Descripon of the procedures

for idenfying and detecng

assessment of material impacts,

risks and opportunies

associated with water and

marine

resources

Water Management

248

Biodiversity and ecosystems

E4. IRO-1

Descripon of the procedures

for idenfying and detecng

assessment of signicant

impacts, risks,

dependencies and

opportunies related to the

Biodiversity and ecosystems

Biodiversity

252

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(amounts in Euro unless stated otherwise)

Resource Use and Circular Economy

E5. IRO-1

Descripon of the procedures

for idenfying and detecng

an assessment of the use of

material resources and the

impact;

risks and opportunies related

to the circular economy

Circular Economy

249

E5-5

Resource oulows

Circular Economy

249

General disclosures

European Sustainability Reporng

Standards (ESRS) Disclosure Requirements

Secon of the Report

S1. S3, S4

Report

Page

The Company's workforce

S1. SBM-2

Interests and views of

interested pares

Interests and Opinions of

Stakeholders

253

S1. SBM-3

Signicant impacts, risks

and opportunies and

their interacon with the

strategy and business

model

Signicant impacts, risks and

opportunies related to the

workforce and their

interacon with the strategy

and business model

254

S1-1

Policies regarding the

workforce concerned

Policies regarding the

Company's workforce

257

S1-2

Procedures for engaging

with the workforce

concerned and workers'

representaves on

impacts

Procedures for cooperaon

with the Company's

workforce and employee

representaves

268

S1-3

Procedures for remedying

negave impacts and

channels for concerns

from the workforce

concerned

Procedures for the

remediaon of negave

impacts and channels for

submission of concerns by

the Company's workforce

269

S1-4

Taking acon in relaon

tomaterial impacts on the

own workforce and

approaches to migate

material risks and seize

material opportunies in

relaon to the own

workforce, as well asthe

eecveness of these

acons

Taking acon on the

signicant impacts and

approaches to migate

signicant risks and seize

signicant opportunies in

relaon to the Company's

workforce and the

eecveness of these

acons and approaches

271

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(amounts in Euro unless stated otherwise)

S1-6

Characteriscs of the

company's employees

The Company's workforce,

Equal Opportunies,

Aracng diverse talents

253,278,282

S1-8

Coverage of collecve

bargaining and social

dialogue

Employee Interacon and

Social Dialogue

277

S1-9

Diversity measurement

indicators

Aracng Diverse Talent,

Equal Opportunies

282,278

S1-12

People with disabilies

Equal Opportunies

278

S1-13

Training and skills

development metrics

Educaon, skills and

technological readiness

285

S1-14

Health and safety metrics

Employee Health & Safety

Incidents

274

Aected communies

S3. SBM-2

Interests and views of

interested pares

Interests and Views of

Stakeholders

291

S3. SBM-3

Signicant impacts, risks

and opportunies and their

interacon with the

strategy and business

model

Signicant impacts, risks and

opportunies and their

interacon with the strategy

and business model of the

Piraeus Port Authority

291

S3-1

Policies Regarding Aected

Communies

Policies of PPA SA related to

the aected communies

293

S3-2

Procedures for working

with aected communies

in relaon to impacts

Procedures for interacng

with aected communies

regarding impacts

295

S3-3

Procedures for remedying

negave impacts and

channels for concerns from

aected communies

Procedures for remedying

negave impacts and

channels for concerns from

aected communies

296

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S3-4

Taking acon on the

signicant impacts on

aected communies and

approaches to managing

the signicant risks and

seizing signicant

opportunies in relaon to

the aected communies

and the eecveness of

these acons

Acons and approaches on

signicant impacts for

aected communies

298

S3-5

Objecves related to the

management of signicant

negave impacts, the

promoon of posive

impacts and the

management of signicant

risks and opportunies

Targets established in 2024

and progress

302

Consumers and end-users

S4. SBM-2

Interests and views of

interested pares

Interests and Views of

Stakeholders

304

S4. SBM-3

Signicant impacts, risks

and opportunies and their

interacon with the

strategy and business

model

Important IRO Issues and

Their Interacon with

Strategy and Operaons

304

Consumers and end-users

S4-1

Consumers and end-users

policies

Policies in relaon to

Consumers and End-Users

306

S4-2

Procedures for engaging

with consumers and end-

users regarding impacts

Processes for engaging with

consumers and end-users

regarding impacts

311

S4-3

Procedures to remediate

negave impacts and

channels for consumers

and end-users to raise

concerns

Processes for the

remediaon of negave

impacts and channels for

consumers to raise concerns

on behalf of end-users

312

S4-4

Acons taken to address

material impacts on

consumers and end-users

and approaches to manage

material risks and seizing

material opportunies in

relaon to consumers and

end-users, as well as the

Measures taken in relaon to

material impacts on

consumers and end-users, as

well as approaches to

manage material risks

315

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eecveness of these

acons

S4-5

Targets related to the

management of material

negave impacts, the

promoon of posive

impacts and the

management of material

risks and opportunies

Targets related to the

management of material

negave impacts, the

promoon of posive

impacts and the

management of material

risks and opportunies

317

General disclosures

Governance

Secon of the G1 Report

Report

Page

G1. GOV-1

The role of administrave,

supervisory and

management bodies

Business Conduct

322

G1. IRO-1

Descripon of the

procedures for idenfying

and detecng

assessment of the signicant

impacts, risks and

opportunies

Policies related to business

conduct and corporate

culture

323

G1-1

Business conduct policies

and corporate governance

Culture

Policies related to business

conduct and corporate

culture

322

G1-2

Managing Supplier

Relaonships

Managing Supplier

Relaonships

333

G1-3

Prevenon and detecon of

corrupon and bribery

Prevenon and Detecon

of Corrupon and Bribery

336

G1-4

Conrmed cases of

corrupon or bribery

Incidents of Corrupon or

Bribery

337

G1-5

Polical inuence and

representaon acvies

interests

Polical Inuence and

Lobbying Acvies

340

G1-6

Payment pracces

Payment Pracces

341

Goals, targets and progress

Following the ESRS framework and guided by the outcomes of the DMA, PPA has established focused

objecves addressing its most signicant sustainability impacts, risks, and opportunies. These

objecves reect the Company’s commitment to connuous improvement and responsible port

management, specically pung forward eorts to progressively reduce negave environmental

impacts ensuring employee welfare, achieving stakeholder engagement, and boosng economic

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growth. Each objecve is linked to a material topic and supports PPA’s long-term value creaon,

aligned with EU sustainability expectaons.

In the current statement these objecves are reviewed, next steps are outlined and planned acons

are described. These are all summarized in the table that follows

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ClLIMATE CHANGE

IRO

Acons

[MDR-A_68a]

Target

[MDR-T_

80b]

Year

[MDR-A_68c/

MDR-T_80e]

KPIs

[MDR-A_68e/ MDR-

T_80b/ MDR-M_75]

Progress in 2025

[MDR-A_68e/ MDR-T_80j]

Consumpon

energy and

Broadcasts

gases of the

greenhouse

Acon Plan to Migate

Greenhouse Gas

Emissions

Greenhouse

gas migaon

2025

Greenhouse gas emissions

In progress/ Compleon 85%

of the target

Redening

Target for 2026

Shore/Onshore

Electricaon (OPS)

2030

In progress/ Compleon 3% of

the target

According to the

plan

Preparaon for the

provision of LNG fuel

supply services to cruise

ships

2026

Ongoing/ Compleon 80% of

the target

According to the

plan

Calculaon of Scope 3

emissions

2026

In progress/ Compleon 70%

of the target

According to the

plan

Climate Change

Migaon Transion Plan

(in accordance with the

requirements of the

European Sustainability

Reporng Standards

(ESRS) (ESRS Requirement

E1-1_17: In the absence

of a transion plan, the

Company must nofy

whether a transion plan

will be adopted.)

2028

In progress

According to the

plan

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Energy Mix

Installaon of a solar

panel system with a

capacity of 1000kWh,

corresponding to a

reducon in greenhouse

gas emissions by 4%.

2030

In progress/ Compleon 70%

of the target

According to the

plan

Adaptaon to

climate change

(Natural and

Transional

Hazards)

Preparaon of a

"Vulnerability and

Adaptaon to Climate

Change Study"

- Finalize and share with

the enre organizaon &

- Design of a resilience

acon plan (natural

hazards)

2025

100% achieved

Improvement of the

study, including transion

risks (nancial) in

accordance with the

requirements of the

European Sustainability

Reporng Standards

(ESRS)

2028

In progress

According to the

plan

Implementaon of the

resilience acon plan

(approved resilience

measures)

2030

In progress

According to the

plan

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POLLUTION

IRO

Acons

[MDR-A_68a]

Target

[MDR-

T_80b]

Year

[MDR-A_68c/

MDR-T_80e]

KPIs

[MDR-A_68e/ MDR-

T_80b/ MDR-M_75]

Progress in 2025

[MDR-A_68e/ MDR-T_80j]

Air Polluon

Air polluon monitoring

programme (in line with

ambient air quality

guidelines)

Ongoing

Keeping

concentraons

below

legislave limits.

– SO 2 average

daily limit<125 μg

m 3

SO2

Concentraon

Ongoing

Electronic plaorm for

the electronic monitoring

of data and measurement

results

2025

100% achieved

Coastal

polluon,

of the water

column and

of sediment

(company-

specic)

Implementaon of

conngency plans for

spills at sea and on land

Ongoing

Number of polluon

incidents

100% achieved

Annual exercise

(emergency exercise) to

deal with spills at sea and

on land

Ongoing

At least one

exercise per year

Number of exercises

100% achieved

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Marine Water and

Sediment Monitoring

Programme

Ongoing

Annual reports

Number of reports

100% achieved

Noise polluon

Management

(for the

company)

Noise monitoring program

for the enre port area

Ongoing

Annual reports -

Lden noise level

limit = 70 dB

Number of reports

100% achieved

Container Terminal Noise

Acon Plan Submied and

Approved by the Ministry

of Environment

2028

-Construcon of

sound barriers in

accordance with

the approved

Acon Plan for the

Noise of the

Containers

Passenger Terminal.

-Reducon of noise

levels in the area

covered by the

sound barriers,

aer their

construcon.

Curtain wall eecveness:

Lden reducon of at least 2

dB by making sound barriers

In progress/ Compleon 30%

of the target

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OWN WORKFORCE

IRO

Acons

[MDR-A_68a]

Target

[MDR-T_80b]

Year

[MDR-A_68c/

MDR-T_80e]

KPIs

[MDR-A_68e/ MDR-

T_80b/ MDR-M_75]

Progress in 2025

[MDR-A_68e/ MDR-T_80j]

Health, Safety &

Wellbeing

Gradual implementaon

of the ISO 45001

management system

Improving health

and safety

management

2027

Number

Accidents

In progress/ Compleon 5%

of the target

Installaon of weather

staons to measure

condions aecng

employee safety and

provide real-me alerts

Prevenve

approach to

maintaining health

and safety of

workers

(Ensuring health

and safety for all)

the sectors of PPA

S.A.)

2026

In progress/ Compleon 30%

of the target

IRO

Acons

[MDR-A_68a]

Target

[MDR-T_80b]

Year

[MDR-A_68c/

MDR-T_80e]

KPIs

[MDR-A_68e/ MDR-

T_80b/ MDR-M_75]

Progress in 2025

[MDR-A_68e/ MDR-T_80j]

Employee

Interacon and

Social Dialogue

Employee sasfacon

survey

- Design and

implementaon

- KPI tracking

Meeng the needs

and expectaons

of employees

2026

% Survey Compleon

No progress was made

Developing an acon

plan based on

The results of the survey

- Design and

implementaon

2028

Sasfacon rates

and the indicators

performance

will depend on

from The Acon Plan

No progress was made

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Equal

opportunies

(Diversity &

Inclusion)

DEI Acon Plan

Assessing diversity

- Design and

implementaon

Promong

diversity, equity

and inclusion in

the Company

2025

Percentage of people with

disabilies

100% achieved

Working with

organisaons that

support the inclusion of

people with disabilies

in the workforce

Creaon of

relevant benets

in contracts for

persons with

disabilies

2026

Number of trainings

provided

100% achieved

Educaon and

skills

development

for new

Technologies

Oer training to upskill

and retrain the

workforce

Achieve 1.6

number of hours

per employee

2026

Number

trainings

provided

100% achieved

Achieve 1,500

number of hours

of training in new

technologies

Number

of parcipants

In progress/ Compleon 50%

of the target

ESG Educaon

Achieve 200

number of

employee

aendance

2026

Number

of parcipants

In progress/ 66 entries

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AFFECTED COMMUNITIES

IRO

Acons

[MDR-A_68a]

Target

[MDR-T_80b]

Year

[MDR-A_68c/

MDR-T_80e]

KPIs

[MDR-A_68e/ MDR-

T_80b/ MDR-M_75]

Progress in 2025

[MDR-A_68e/ MDR-T_80j]

Corporate

Social

Liability (special

issue for the

Company)

Connuing to engage

with local stakeholders

Annual budget to

support local

communies

Annually

Number of projects

Budget

made available

100% achieved

Port users / Stakeholder

Council

Improve the

stakeholder

management

framework and

achieve open

communicaon

with all port

users/stakeholder

groups

Semi-annual

List of acve users

Percentage of

users/stakeholders

parcipang in the Port

Users' Council

Number of

requests/complaints

received and resolved

within a specied

meframe

100% achieved

New model park in the

cruise port area (12.5

acres)

Strengthening

relaons with the

local community

and the

Municipality of

Piraeus

2027

Community Sasfacon

Rate

In progress/ Compleon 15%

of the target

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Strengthening the

presence of the

Company S.A. in society

and social dialogue

Monitoring of the

Company's social

media accounts

2025

Number of posts/press

releases of the following

100% achieved

Parcipaon of the

Company S.A. in trade

associaons and trade

unions

Strengthening the

acve role of the

Company

2025

100% achieved

CONSUMERS AND END-USERS

IRO

Acons

[MDR-A_68a]

Target

[MDR-T_80b]

Year

[MDR-A_68c/

MDR-T_80e]

KPIs

[MDR-A_68e/ MDR-

T_80b/ MDR-M_75]

Progress in 2025

[MDR-A_68e/ MDR-T_80j]

Next steps

Security &

Passenger

protecon

(Special issue for

the Company)

-Conduct an accessibility

assessment for people

with reduced mobility.

-Development of an acon

plan based on the results

Conduct an accessibility

assessment for people

with reduced mobility.

Improving

accessibility for

disabled groups

across the port

2027

Percentage of disabled

end-users

In Progress/ Compleon 10%

of the target

- Reconstrucon of

concrete stairs

Enhancing security

Connuous 2025

N/A

100% achieved

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-Installaon of steel

stairs and LED solar

lighng with poles on

the walls of the main

port dock

-Trac management at

cruise terminals to

reduce trac congeson

and the risk of accidents

-Restructuring of parking

lots

Proacve

approach to

maintain the

health, safety and

security of all

visitors to the port

of Piraeus

2027

N/A

In Progress/ Compleon 10%

of the target

Eco-buses

Transportaon of

passengers within

the port, with zero

emissions

2028

Reducing carbon

equivalence

In progress/ Compleon 5%

of the target

Interacon with End

Users

Collaboraons

with direct

customers to

collect feedback

from end users

2028

Number of parcipang

companies

No progress was made

Updang the

website to provide

informaon

(passenger rights,

complaint form,

2025

List Feedback

Category

enabling

activity (19)

Category

transitional

activity (20)

€000 % Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T

A. TAXONOMY-ELIGIBLE ACTIVITIES

A.1. Environmentally sustainable activities (Taxonomy-aligned)

Sea and coastal freight water transport, vessels for port

operations and auxiliary activities

CCM 6.10/ CCA

6.10

5.875,42 2% Y N N/EL N/EL N/EL N/EL - Y Y Y Y Y Y 3%

Infrastructure enabling low carbon water transport CCM 6.16 82.758,16 33% Y N/EL N/EL N/EL N/EL N/EL - Y Y Y Y Y Y 33% Ε

88.633,59 35% 35% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 36%

82.758,16 33% 33% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 33% E

0,00 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 0% T

A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)

EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL

Infrastructure enabling low carbon water transport CCM 6.16 60.987,31 24% EL N/EL N/EL N/EL N/EL N/EL 24%

Transport by motorbikes, passenger cars and light

commercial vehicles

CCM 6.5 / CCA

6.5

0,00 0% EL EL N/EL N/EL N/EL N/EL -

60.987,31 24% 24% 0% 0% 0% 0% 0% 24%

149.620,90 60% 60% 0% 0% 0% 0% 0% 60%

101.164,89 40%

250.785,79 100%

TOTAL

Turnover of Taxonomy-eligible but not environmentally sustainable

activities (not Taxonomy-aligned activities) (A.2)

A.TurnoverofTaxonomy-eligibleactivities(A.1+A.2)

B. TAXONOMY-NON-ELIGIBLE ACTIVITIES

Turnover of Taxonomy-non-eligible activities

Year

Substantial contribution criteria

DNSHcriteria(“DoesNotSignificantlyHarm”)

Turnover of environmentally sustainable activities (Taxonomy-

aligned) (A.1)

Of which enabling

Of which transitional

Proporon of turnover/Total turnover

Taxonomy-aligned per objecve

Taxonomy-eligible per objecve

CCM

35%

60%

CCA

WTR

PPC

BIO

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Τable KPI of Capital Expenses

Proporon of CapEx/Total CapEx

Taxonomy-aligned per objecve

Taxonomy-eligible per objecve

CCM

86%

CCA

WTR

PPC

BIO

Financial year 2025

Economic Activities (1) Code(2) CapEx (3)

Proportion of

CapEx 2025

(4)

Climate

Change

Mitigation

(5)

Climate

Change

Adaptation

(6)

Water (7)

Pollution

(8)

Circular

Economy

(9)

Biodiversit

y (10)

Climate

Change

Mitigation

(11)

Climate

Change

Adaptation

(12)

Water (13)

Pollution

(14)

Circular

Economy

(15)

Biodiversit

y (16)

Minimum

Safeguards

(17)

Proportion of

Taxonomy-aligned

(A.1.) or -eligible

(A.2.) CapEx 2024

(18)

Category

enabling

activity (19)

Category

transitional

activity (20)

€000 % Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T

A. TAXONOMY-ELIGIBLE ACTIVITIES

A.1. Environmentally sustainable activities (Taxonomy-aligned)

Sea and coastal freight water transport, vessels for port

operations and auxiliary activities

CCM 6.10/

CCA 6.10

2.009,69 2% Y N N/EL N/EL N/EL N/EL - Y Y Y Y Y Y 0%

Infrastructure enabling low carbon water transport CCM 6.16 3.360,84 3% Y N/EL N/EL N/EL N/EL N/EL - Y Y Y Y Y Y 3% Ε

5.370,53 5% 5% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 3%

3.360,84 3% 3% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 3% E

0,00 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 0% T

A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)

EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL

Infrastructure enabling low carbon water transport CCM 6.16 91.848,90 81% EL N/EL N/EL N/EL N/EL N/EL 80%

Transport by motorbikes, passenger cars and light

commercial vehicles

CCM 6.5 /

CCA 6.5

217,01 0% EL EL N/EL N/EL N/EL N/EL -

92.065,91 82% 82% 0% 0% 0% 0% 0% 80%

97.436,44 86% 86% 0% 0% 0% 0% 0% 83%

B. TAXONOMY-NON-ELIGIBLE ACTIVITIES

15.343,69 14%

TOTAL 112.780,13 100%

CapEx of Taxonomy-eligible but not environmentally sustainable

activities (not Taxonomy-aligned activities) (A.2)

A.CapExofTaxonomy-eligibleactivities(A.1+A.2)

CapEx of Taxonomy-non-eligible activities

Year

Substantial contribution criteria

DNSHcriteria(“DoesNotSignificantlyHarm”)

CapEx of environmentally sustainable activities (Taxonomy-

aligned) (A.1)

Of which enabling

Of which transitional

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Operational Expenses KPI table

Proporon of OpEx/Total OpEx

Taxonomy-aligned per objecve

Taxonomy-eligible per objecve

CCM

22%

49%

CCA

WTR

PPC

BIO

Financial year 2025

Economic Activities (1) Code(2) OpEx (3)

Proportion

of OpEx

2025 (4)

Climate

Change

Mitigation

(5)

Climate

Change

Adaptation

(6)

Water (7)

Pollution

(8)

Circular

Economy

(9)

Biodiversit

y (10)

Climate

Change

Mitigation

(11)

Climate

Change

Adaptation

(12)

Water (13)

Pollution

(14)

Circular

Economy

(15)

Biodiversit

y (16)

Minimum

Safeguards

(17)

Proportion of

Taxonomy-aligned

(A.1.) or -eligible

(A.2.) OpEx 2024

(18)

Category

enabling

activity (19)

Category

transitional

activity (20)

€000 % Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y; N; N/EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T

A. TAXONOMY-ELIGIBLE ACTIVITIES

A.1. Environmentally sustainable activities (Taxonomy-aligned)

Sea and coastal freight water transport, vessels for port

operations and auxiliary activities

CCM 6.10/

CCA 6.10

403,47 13% Y N N/EL N/EL N/EL N/EL - Y Y Y Y Y Y 9%

Infrastructure enabling low carbon water transport CCM 6.16 282,13 9% Y N/EL N/EL N/EL N/EL N/EL - Y Y Y Y Y Y 5% Ε

685,60 22% 22% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 15%

282,13 9% 9% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 5% E

0,00 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 0% T

A.2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)

EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL EL; N/EL

Infrastructure enabling low carbon water transport CCM 6.16 670,31 22% EL N/EL N/EL N/EL N/EL N/EL 30%

Transport by motorbikes, passenger cars and light

commercial vehicles

CCM 6.5 /

CCA 6.5

138,09 4% EL EL N/EL N/EL N/EL N/EL -

808,39 26% 26% 0% 0% 0% 0% 0% 30%

1.494,00 49% 49% 0% 0% 0% 0% 0% 45%

B. TAXONOMY-NON-ELIGIBLE ACTIVITIES

1.582,29 51%

3.076,29 100%

OpEx of Taxonomy-eligible but not environmentally sustainable

activities (not Taxonomy-aligned activities) (A.2)

A.OpExofTaxonomy-eligibleactivities(A.1+A.2)

OpEx of Taxonomy-non-eligible activities

TOTAL

Year

Substantial contribution criteria

DNSHcriteria(“DoesNotSignificantlyHarm”)

OpEx of environmentally sustainable activities (Taxonomy-

aligned) (A.1)

Of which enabling

Of which transitional

Page 213 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

ESRS E1 & E2– Climate Change & Pollution

Our Environmental Management Approach

Environmental responsibility remains a fundamental pillar of PPA S.A.’s operaons, as the Port

of Piraeus constutes a strategic reference point for commercial and passenger ows in the

southeastern Mediterranean. Since publishing its rst Sustainability Report, under CSRD

framework, in 2024, the Company has connued to strengthen its environmental governance

mechanisms and enhanced its processes for assessing impacts, risks and opportunies,

supporng the transion toward improved environmental performance and climate resilience.

In 2025, the Double Materiality Assessment was updated and rened.

As a result of this process, the Company idened the most material environmental impacts,

risks and opportunies (IROs) and integrated relevant acon into the annual environmental

plan.

ESRS E1 – Climate Change

Negave Actual Impacts

Energy Consumpon and GHG Emissions

Risks

Dependency on Energy

Climate Change-Induced Physical Risks

Climate Change Transion Risks

Opportunies

Renewable Energy Transion / Energy Mix Improvements

Parcipaon in EU Climate-Related Funding

Use of AI-based Plaorms

ESRS E2 – Pollution

Negave Actual Impacts

Polluon of Air

Polluon of Coasts, Water Column and Sediments (Company Specic)

Noise Polluon Management (Company Specic)

To support the eecve implementaon of its environmental commitments, PPA S.A.

maintains an integrated management system for quality, environmental, energy and emissions

management system cered to:

• ISO 9001:2015 (Quality Management)

• ISO 14001:2015 (Environmental Management)

• ISO 50001:2018 (Energy Management)

• ISO 14064-1:2018 (Emissions Management)

Page 214 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

PPA S.A.’s Integrated Management System

In line with Law 4936/2022, the Company’s Scope 1 and Scope 2 GHG emissions are veried annually

by an accredited independent body, ensuring the accuracy and transparency of disclosed data.

Polluon-related measurements are conducted exclusively by cered contractors, ensuring the

reliability and consistency of environmental informaon published by the Company.

Environmental Policy

In line with its ongoing commitment to responsible environmental management, PPA S.A. updated

its Environmental Policy in March 2025, ensuring alignment with contemporary climate and

regulatory requirements, as well as with the ESRS and the obligaons of the Naonal Climate Law

(Law 4936/2022). This revision strengthened the Company’s acon framework by seng clearer

direcons for reducing GHG emissions, improving energy eciency, and prevenng polluon across

port operaons.

The Environmental Policy explicitly provides for the prevenon of polluon incidents and

emergencies and, should they occur, the implementaon of appropriate measures to control them,

liming and reducing the impact on human health and the environment. This approach is

implemented through the Company's Integrated Management System, which includes procedures

for prevenon, preparedness, and response to incidents of air, water, and soil polluon, in

accordance with the Environmental Terms Approval Decision and applicable regulatory

requirements. [E2-1_15_c]

The Policy reects the Company’s commitment to idenfying and managing signicant

environmental impacts, risks and opportunies (IROs), prevenng polluon and integrang climate

change adaptaon into business planning. At the same me, the Company aims to reduce energy

consumpon and greenhouse gas emissions, enhance the use of renewable energy sources and

ensure the connuous improvement of environmental and energy performance. [MDR-P_65_a, E1-

2_25, E2-1_15_a].

These commitments are implemented through the Integrated Management System, cered to ISO

9001:2015, ISO 14001:2015, ISO 50001:2018 and ISO 14064-1:2018. The Environmental Policy is

fully aligned with these internaonally recognized standards and iniaves, forming a robust and

reliable environmental and energy management framework that supports the Organizaon’s

ongoing improvement. [MDR-P_65_d]

The environmental policy applies to all port’s operaons and to any stakeholder that uses or works

on the premises. [MDR-P_65_b]

ISO

9001:2015

ISO

14001:201

ISO

50001:201

ISO

14064-

1:2018

Page 215 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Manager of the Quality Control Department is the most senior level in the organizaon,

accountable for the implementaon of the Policy, while specic aspects of the Environmental Policy

are also implemented by the Manager of the Environmental Department. [MDR-P_65_c]

The own workforce of PPA S.A. is acvely engaged in the Company’s operaons, and employee

recommendaons and feedback are taken into consideraon during the revision of the Company’s

Policy. Furthermore, as part of the Company’s DMA Principle, the interests of all stakeholders are

assessed, and the Organizaon’s policies may be adjusted to reect their needs and expectaons

when deemed appropriate. [MDR-P_65_e]

The Environmental Policy is integrated in the company’s Quality, Environmental & Energy Policy,

publicly available on PPA S.A.’s ocial website, at: hps://www.olp.gr/en/quality-control/quality-

environmental-energy-policy [MDR-P_65_f]

ESG and Sustainable Development Policy

The ESG and Sustainable Development Policy is incorporated into the broader framework of the

Company’s Sustainable Development Strategy, which denes the integraon of environmental,

social and governance (ESG) parameters into the Company’s operaon and strategy. The

Sustainable Development Policy supports the implementaon of long-term sustainability targets

and the achievement of climate-neutral and environmentally responsible port acvies. [MDR-

P_65_a].

The Company is commied to systemacally reducing its environmental footprint and contribung

to climate change migaon through:

• proacve measures to reduce environmental impact and greenhouse gas emissions

• adopng sustainable pracces across all port operaons

• investments in renewable and alternave forms of energy

• ecient use of natural and energy resources

• minimizing negave impacts on local ecosystems

• implemenng the principles of the EU Taxonomy as a tool for dening sustainability

targets and green investments

The Company aligns its policy with the principles of ESPO’s Green Guide, seng clear goals and

targets for the connuous improvement of its environmental performance. At the same me, it

strengthens cooperaon with universies and research instutes with the aim of:

• developing and implemenng environmental monitoring programs (ambient air

quality, noise, water columns and sediments), and

• preparing climate change risk analyses for port projects, infrastructure and

acvies, to minimize climate-related impacts on the Company’s assets and

operaons.

The ESG and Sustainable Development Policy applies to all acvies within the Port of Piraeus and

is binding for all employees, contractors, partners and third pares operang at the Company’s

facilies. [MDR-P_65_b]

The Policy is implemented within PPA S.A.’s Integrated Management System, cered to ISO

9001:2015, ISO 14001:2015, ISO 50001:2018 and ISO 14064-1:2018, which ensures the connuous

improvement of quality, environmental performance and energy eciency. [MDR-P_65_d]

The Policy was developed with the parcipaon of all competent internal departments and

stakeholders, within the framework of the Double Materiality Assessment and the Company’s

integrated management system. [MDR-P_65_e]

The highest level of the Company responsible for the implementaon of the ESG and Sustainable

Development Policy is the CEO Board, while the ESG Commiee supports the coordinaon,

monitoring of implementaon, communicaon and updang of the policy. [MDR-P_65_c]

The ESG and Sustainable Development Policy is publicly available on PPA S.A.’s website:

hps://www.olp.gr/en/ [MDR-P_65_f]

Page 216 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Our Approach to Manage PPA S.A. Material Impacts, Risks, and

Opportunities (IROs)

Climate Change

Climate change aects the operaonal connuity, infrastructure performance and long-term

resilience of PPA S.A. The port is exposed to physical hazards such as sea-level rise, extreme

temperatures and intense rainfall, which may impact vessel servicing, cargo handling, crical

infrastructure and the safety of employees and passengers.

Recognizing that climate change is both an environmental and an operaonal/economic factor,

the Company has conducted a comprehensive assessment of physical climate risks in line with

the Naonal Climate Change Law and the ESRS. The assessment supports strategic planning,

future infrastructure design and long-term resilience.

Assessment of Physical Climate Risks

Climate change is an increasingly signicant factor inuencing port infrastructure and the daily

operaons of Piraeus Port. To fully understand the potenal impacts, PPA S.A. completed in

2025 an updated resilience and vulnerability assessment covering all acvies and crical

assets of the port area, following the methodological requirements of the Naonal Climate

Change Law and the Regional Adaptaon Plan for Aca (PeSPKA) [E1-IRO-1-AR-11c, E1_SBM-

3_19_a]. The analysis includes all of the Company's infrastructure and acvies but does not

include its value chain. [E1_IRO-1_20_b].

•Identifying and mapping the interactions that PPA

S.A.'s activities have with the environment

•Engaging with PPA S.A. stakeholders

Identification

•Determining material impacts the Company's

operations may have on the environment

•Determining material risks and opportunities that

may result from the Company's business activities

Categorisation

•Adopting policies that address material impacts,

risks and opportunities

•Developing processes to implement the

commitments of the adopted policies

Commitment

•Adopt metrics that accurately represent PPA

S.A.'s performace

•Implement action plans that improve PPA S.A.'s

performance

Continuous

Improvement

Page 217 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The assessment was conducted in the framework of the “Climate Change Vulnerability and

Adaptaon Study of Piraeus port” in collaboraon with the Academy of Athens. The scope of

the study is as follows:

• Analysing climate changes using models and scenarios aligned with the Aca Regional Climate

Change Adaptaon Plan (PeSPKA).

• Assessing short- and long-term impacts of climate change on port infrastructure and

operaons, using the latest climate data. Vulnerability is evaluated against key climate risks

such as sea-level rise, wave acon, ooding, strong winds, and extreme temperatures.

• Idenfying areas requiring addional climate-resilience measures, proposing acons,

esmang implementaon costs, and exploring potenal synergies with other stakeholders.

• Checking the compability of proposed measures with the Aca PeSPKA [E1_SBM-3_19_b].

The analysis incorporates climate parameters derived from internaonally recognized climate

models and the IPCC Representave Concentraon Pathways (RCPs), combined with high-

resoluon projecons tailored to the port’s geographical seng. Specically, the analysis used

the RCP4.5 scenario (an intermediate or migaon scenario) and the RCP8.5 scenario (a

scenario of drasc increase in GHG emissions or a no-acon scenario).

Methodology

The assessment used seven EURO-CORDEX simulaons of 11 km spaal resoluon,

subsequently downscaled to a ner grid of approximately 250 meters to capture localized

climate dynamics. Projecons covered the period 1970–2100, and mean values of climate

variables and indices were calculated for four me horizons:

• 1986–2005 (baseline period)

• 2041–2060 (short term)

• 2061–2080 (medium term)

• 2081–2100 (long term) [E1_IRO-1_AR11_b, Ε1_SBM-3_AR7_b]

The Company's assets and business acvies were reviewed to assess their exposure to

climate risks across all the above me horizons. [E1_IRO-1_AR11_a]

The analysis evaluated both chronic and acute climac changes, focusing on temperature,

humidity, precipitaon, wind, wave height and sea-level rise. These parameters were assessed

using a combinaon of:

• Quantave analysis of climate model outputs to evaluate likelihood and magnitude

• Qualitave assessment of potenal impacts on port infrastructure and operaons

• Risk categorizaon, based on:

1. Likelihood (high, medium, low)

2. Impact severity (extreme, signicant, moderate, minor)

3. Duraon (short- or long-term eects)

The categorizaon process supports decision-making and helps priorize adaptaon

measures.

The climate scenarios used for the physical vulnerability analysis were: [Ε1_IRO-1_21]

Page 218 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

RCP8.5 Scenario

The RCP8.5 scenario is a high-emissions pathway characterized by rapidly increasing

greenhouse gas concentraons, expanded fossil fuel use and accelerang land-use pressures.

It represents a “worst-case” situaon, with projects temperature increases of approximately

3.7°C for the period 2081–2100 compared with 1986–2005. [E1_IRO-1_AR11_d]

RCP4.5 Scenario

The RCP4.5 scenario is a stabilizaon pathway in which emissions peak around 2040 and

decline thereaer, supported by reforestaon eorts, increasing renewable energy use and

reduced reliance on fossil fuels. The projected temperature rise is approximately 1.8°C by

2081–2100.

Key Physical Climate Risks Idened

PPA S.A.’s Specic Study on Climate Resilience highlights the Company's ability to adapt its

strategy and business model to the impacts of climate change in the short, medium, and long

term. In this context, specic climate change adaptaon acons have been planned (see next

paragraph), through which the connuous adaptaon of PPA S.A.'s strategy and business

model to changing climac condions is supported.

In the short term, the Company integrates the ndings of the Specic Study on Climate

Resilience of PPA S.A. into operaonal planning, the monitoring of crical physical climate risks

and the determinaon of immediate adaptaon measures for its acvies and infrastructure.

In the medium term, the Company may adjust individual technical projects, infrastructure,

operaonal processes and investment priories, in order to limit exposure to physical climate

risks and ensure business connuity. In the long term, the Company maintains the ability to

revise planning, upgrade or redesign infrastructure and adapt the way port services are

developed and operated, with the aim of maintaining the resilience of its business model

under changing climac condions. [E1_SBM-3_AR8_b]

For example, the acon "Development of a cooperaon network with academic and research

instuons" provides for systemac cooperaon with scienc and research bodies to

monitor climate change developments, ulizing new scienc data and regularly updang

individual adaptaon acons. Through this process, the Company ensures the mely review

and adjustment of its acons and planning, strengthening the long-term resilience of its

acvies and infrastructure to the impact of climate change.

The secon "Climate Adaptaon Acons, Planning, and Ongoing Iniaves" presents the

adaptaon acons designed to strengthen the Company's ability to adapt, and where

necessary, readjust its strategy and business model to climate change condions in the short,

medium, and long term.

The results of the assessment indicate that the most signicant climate-related risks aecng

the Company are the following two physical climate risks (climate-related physical risks). PPA

S.A.’s Specic Study on Climate Resilience examines only physical risks, while transional risks

will be assessed separately, to complete this assessment by 2028.

Page 219 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

According to the ndings of the Specic Study on Climate Resilience, there is uncertainty

regarding the likelihood of certain climate risks occurring due to the nature of climate

projecons and related scenarios. This uncertainty is addressed using expert judgement,

based on the best available informaon and data, including stascs, event logs, simulaons,

and scienc studies, as well as knowledge gained from consultaons with relevant

stakeholders. For this reason, the study examines exible and adapve risk management

measures, such as systemac monitoring of relevant phenomena and the implementaon of

technical measures when condions exceed predened crical thresholds. [E1_SBM-3_18,

E1_SBM-3_19_c]

1. Increase of average summer temperature and increase of heatwaves, leading to higher

energy and water consumpon, challenging outdoor working condions, reduced service

capacity during peak passenger periods and addional strain on electromechanical

equipment. Milder winters, however, may reduce heang demand and improve working

condions.

2. Rise of average sea level, which may cause damages to port infrastructures and pose

challenges for berthing operaons.

All risks appear under both RCP4.5 and RCP8.5, though their intensity becomes signicantly

more pronounced under RCP8.5 toward the end of the century.

According to the results of the Climate Change Study, the likelihood and ming of certain

physical climate risks remain uncertain, parcularly in the medium and long term. The analysis

is based on climate model scenarios and available scienc data, but future developments

may dier due to uncertaines related to global emissions, technological developments, and

macroeconomic condions.

To address these uncertaines, the Company adopts an adapve approach, which includes

connuous monitoring of crical indicators, regular updang of the analysis, and

implementaon of adjustment measures when predetermined risk thresholds are exceeded.

Assets and business acvies that are considered to be exposed to signicant natural climate

risks are taken into account in the Company's strategic planning, in infrastructure investment

planning and in the denion of exisng and future migaon and adaptaon measures, as

described in the secon “Climate Adaptaon Acons”. [E1_SBM-3_AR8_a]

Climate Adaptation Actions, Planning and Ongoing Initiatives

In 2024, no specic adaptaon measures had yet been idened in the context of the climate

resilience study. Following the compleon of the “Specic Study on Climate Resilience" in

2025, PPA S.A. formulated for the rst me a targeted set of adaptaon acons aimed at

ensuring adequate resilience to extreme and chronic climate events. Strengthening the port's

resilience is considered crical for both its connued smooth operaon and the protecon of

its crical infrastructure.

Page 220 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

At the same me, PPA S.A., as part of its overall strategy for decarbonizaon and reducon of

greenhouse gas (GHG) emissions, is developing a special "Acon Plan for the Reducon of

Greenhouse Gas Emissions" that will cover the enre port area. This plan is currently in its nal

stages of development and is expected to be completed and published in 2026.

In the context of the preparaon of the above-menoned Acon Plan measures and specic

targets for greenhouse gas emissions in the port area are being examined; however, they have

not yet been nalized and remain under development. [E1 IRO-1, AR 11 (c)]

Indicavely, among the inial direcons that have been proposed are the upgrading of the

energy eciency of the facilies, the priorizaon of intervenons in the building stock, the

replacement of convenonal lighng with LED lighng, the integraon of renewable energy

soluons and smart energy management systems, as well as the improvement of the energy

management of building and electromechanical infrastructure. These measures are at a stage

of further specicaon and will be incorporated into the nal Acon Plan aer its compleon.

[E1-1_16, E1-1_AR18]

The acons presented in this secon primarily concern the adaptaon of the port to climate

change. However, some of them are also expected to contribute indirectly to reducing

greenhouse gas emissions, while supporng the Company's broader goals of reducing its

carbon footprint. [MDR-A_68_a]

The short-term acons to be implemented between 2027 and 2035 include: [E1_SBM-

3_19_c, MDR-A_68_c]

• Development of a cooperaon network with academic and research

instuons

• Creaon of a database of port infrastructure in a GIS environment

• Energy-eciency upgrade specicaons

• Priorisaon of building stock upgrades

• Outdoor area intervenons

• Replacement of convenonal lighng with LED

• Maintenance manual for air condioning and electromechanical networks

• Integraon of renewable energy soluons and smart energy-management

systems.

• Installaon of water tanks

• Improvement of rainwater management

• Emergency plans and Crisis response

• Cooperaon framework with neighbouring municipalies

• Smart monitoring and early-warning systems

• Maintenance and Construcon Manual for Port Works with Integraon of

Climate Parameters

The “Climate Change Vulnerability and Adaptaon Study” is the main acon implemented and

completed by the Company in 2025 in relaon to climate change. At this stage, the study has

been submied to the Ministry of Environment and Energy for review. The study examines the

climate-related impacts, risks, and opportunies that may aect the Company’s port facilies

and was completed and submied to the Ministry of Environment in 2025.

Page 221 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Migaon and adaptaon acons are planned across short, medium and long-term horizons.

PPA S.A. has already commied €169,000 to support the implementaon of the study. As of

the reporng date, these commied resources pertain exclusively to the support of the Study.

The above expenditure relates exclusively to the preparaon and support of the “Climate

Change Resilience and Adaptaon Study” and, as at the reporng date, is not associated with

implemented investments or physical adaptaon projects. As such, the relevant expenditure

concerns the current stage of preparaon and assessment and is linked to the relevant

operang expense items / fees and third-party expenses, as presented in the Financial

Statements for the year [E1-3_29_c_i]. As at the reporng date, the above expenditure does

not correspond to an implemented investment project or eligible technical intervenon and,

therefore, is not directly linked to the key performance indicators (KPIs) required under

Commission Delegated Regulaon (EU) 2021/2178. Any future linkage with relevant CapEx or

OpEx indicators will be assessed at the stage of specicaon and implementaon of the

individual acons foreseen by the Study. [E1-3_29_c_ii]

The future nancial instruments for implemenng the adaptaon acons proposed by the

Study will be specied aer the compleon of the Study's evaluaon by the Ministry of

Environment and Energy and the examinaon of each acon separately in terms of its budget

and nancing. [MDR-A_69_c, MDR-A_68_b, MDR-A_69_b, E1-3_AR21, E1-3_29_c_i, E1-

3_29_c_i].

To ensure connuous monitoring of such climate-related developments, PPA S.A. parcipates

in the EU-funded project ARSINOE (Climate-resilient regions through systemic soluons and

innovaons). The project idenes climate-related risks and opportunies and examines

measures that can enhance the port’s resilience to the impacts of climate change.

Climate Change Management, Energy, & GHG Emissions

Energy management and GHG emissions constute a key priority for PPA S.A. In this context,

the Company implements a cered ISO 50001:2018 Energy Management System and, in

accordance with the Naonal Climate Law, calculates its Scope 1 and Scope 2 emissions based

on ISO 14064-1:2018 since 2022. In 2025, the Company also calculated the signicant

categories of Scope 3 emissions in accordance with ISO 14064-1:2018. [E1_IRO-1_20_a]

As part of the Double Materiality Assessment process and the annual emissions inventory, the

Company conducts systemac screening of all its acvies, facilies, and business plans, with

the aim of idenfying exisng and potenal future sources of greenhouse gas emissions in its

acvies and along the value chain. The process includes recording direct emissions from fuel

consumpon and equipment operaon, indirect emissions from purchased electricity (Scope

2), and an assessment of relevant Scope 3 categories associated with moored vessels,

employee commung, and business travel. [E1_IRO-1_20_a]

The assessment of actual and potenal impacts on climate change is based on the quantave

calculaon of total greenhouse gas emissions (tCO₂e), the analysis of the main sources of

emissions, and the assessment of each category's contribuon to the Company's total carbon

footprint.

Page 222 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

This process idenes the areas with the largest contribuon to emissions, which are taken

into account when designing reducon and energy opmisaon measures. This assessment

focuses mainly on physical risks, which are examined in the context of the Company's Climate

Change Study. As the dedicated climate resilience study of PPA S.A. was completed at the end

of the reporng period and is under evaluaon by the Ministry of Environment, the crical

assumpons related to climate are not currently reected in the nancial statements [E1 IRO-

1, AR 15]. During the reporng period, the Company has not yet completed a disnct

assessment of transion risks related to climate change (transion risks), such as risks

associated with regulatory developments, technological changes, changes in the market or

demand and other factors related to the transion to a low-carbon economy. The assessment

of these transion risks is expected to be examined separately at a later stage, with a

compleon horizon up to 2028. [E1_IRO-1_AR9_a], [E1_IRO-1_AR9_b]

Regarding alignment with the EU Taxonomy criteria, the Company discloses the relevant

nancial indicators as required by Regulaon 2021/2139. However, a specic capital

expenditure or operaonal expenditure plan for full acvity alignment with the Taxonomy

criteria has not been developed for the current period. [E1-1_16_e]

At the same me, the Company is in the nal stage of preparing the “Acon Plan for the

Migaon of Greenhouse Gas Emissions” for the enre port area with the goal to reduce the

overall GHG emissions of the Company’s acvies. The analysis is centered around measures

and acons that reduce GHG emissions, such as energy eciency, electricaon, fuel

switching, and use of renewable energy etc., by 2030.

The Company does not fall under the exempons of Regulaon (EU) 2020/1818 and is

assessed based on the European alignment indicators with the Paris Agreement. [E1_1_16_g]

To ensure data reliability and process alignment a uniform methodology for both carbon

footprint measurement and target seng for reducing emissions is applied. During the

reporng period, quantave greenhouse gas emission reducon targets are being developed

and will be nalized aer the compleon and approval of the Acon Plan for the Reducon of

Greenhouse Gas Emissions. Once nalized, the targets will be disclosed in absolute values

(tCO₂e and/or as a percentage of the base year) and, where applicable, in terms of intensity,

and will be specied for Scope 1, Scope 2 and Scope 3, either separately or in combinaon.

[E1-4_34_a, E1-4_34_b]

Addionally, a climate transion plan has not yet been developed, therefore locked-in

emissions are not calculated or reported [E1-1_16_d]. The emission targets set to date are not

based on a pathway that limits global warming to 1.5°C [E1-4_34_e], nor was climate scenario

analysis used to determine them [E1-4_AR30_c]. The Company has set 2028 as the reference

year, when it will assess the possibility of developing a formal transion plan [E1-1_17].

During the reference year, the Company did not make any CapEx investments related to coal,

oil, natural gas, or energy producon acvies (NACE B.05, C.19, D.35.1, D.35.3, G.46.71) [E1-

1_16_f].

Page 223 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Climate and Energy Targets

The Company is developing specic targets for the reducon of greenhouse gas emissions and

the improvement of energy eciency, which are consistent with the material impacts

idened in the context of the climate change assessment. During the reporng period, the

quantave targets for the reducon of greenhouse gas emissions have not yet been nalized

and are under development, while they will be further specied aer the compleon and

approval of the “Greenhouse Gas Emissions Reducon Acon Plan”. [E1-4_33, E1-4_34_a, E1-

4_34_b]

Page 224 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

CLIMATE CHANGE

IRO

Acons

[MDR-A 68a]

Target [MDR-

T- 80b]

Year

]MD

R-A

68c/

R-T

80e]

KPIs

[MDR-A

68e/

MDR-T

80b/ MDR

– M- 75]

Progress in

2025

[MDR-A

68e/ MDR-

T- 80j]

Next Steps

Ε1

Energy

Consump

on and

GHG

Emissions

Acon Plan for GHG

Emissions

migaon

Migaon of

greenhouse

gases

2025

GHG

emissions

In progress

/ 85% of

the target

achieved

Re-seng the

target for

2026

Cold Ironing /

onshore power

supply (OPS)

2030

In progress

/ 3% of the

target

achieved

According to

planning

Preparaon of LNG

bunkering for cruise

vessels

2026

In progress

/ 80% of

the target

achieved

According to

planning

Calculaon of

Scope 3 emissions

2026

In progress

/ 70% of

the target

achieved

According to

planning

Transion plan in

the frame of

climate change

migaon (acc. to

ESRS requirements)

(ESRS Requirement

E1-1_17: If the

undertaking does

not have a

transion plan in

place, it must

indicate whether it

intends to adopt

one and, if so,

when.)

2028

In progress

According to

planning

Energy Mix

Installaon of 1000

kWh solar system

corresponding to a

4% reducon of

GHG emissions

2030

In progress

/ 70% of

the target

achieved

According to

planning

Page 225 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Climate

change

adaptaon

(Physical &

Transion

Risks)

Preparaon of

“Climate Change

Vulnerability and

Adaptaon Study”

-Finalised and

communicated

throughout the

organisaon &

-Design of a

Resilience Acon

Plan (physical risks)

2025

100%

achieved

Enhancement of

the study to include

Transition

(financial) risks in

accordance with

ESRS requirements

2028

In progress

According to

planning

Implementaon of

the Resilience

Acon Plan

(approved

resilience

measures)

2030

In progress

According to

planning

During the reporting period, PPA S.A. has not yet finalized measurable, outcome-oriented and

time-bound targets for the reduction of greenhouse gas emissions and the improvement of

energy efficiency. The relevant targets are under development and will be further specified

following the completion and approval of the “Greenhouse Gas Emissions Reduction Action

Plan”, from which both the base year and the corresponding quantitative targets, as well as

the individual actions for their achievement, are expected to be derived. As a result, during

the current reporting period, the disclosure requirements relating to specific quantitative

characteristics of targets are not yet applicable, as no final, measurable, outcome-oriented

and time-bound targets have been set. [MDR-T_81_b_i, MDR-T_81_b_ii, MDR-T_80_h]

Actions Related to Own Operations

PPA S.A. implements a series of energy acons focused on the gradual increase of renewable

energy parcipaon in the Company’s energy mix, the reducon of electricity consumpon

and the improvement of overall energy performance. These iniaves fall within the

framework of the ESRS obligaons and the requirements for climate change migaon. [MDR-

T_80_a, E1-3_29_a, E1-4_34_f]

Page 226 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Company operates a 430 kWp photovoltaic plant within the Container Terminal, which

channels the electricity generated to the Hellenic Electricity Distribuon Network. The

electricity generated by this staon contributes to increasing the producon of electricity from

renewable sources in the naonal energy system. For the exisng installed capacity, the

esmated annual renewable energy producon corresponds to emissions avoidance of 232 t

CO₂e according to locaon-based factors and 171 t CO₂e according to market-based factors, at

the level of the electricity system.

Producon capacity is expected to increase by 2030 through the expansion of the exisng

facility, which will provide an addional 1,000 kWp of capacity, bringing the total to 1,430 kWp.

The provision is currently under study. The facility is expected to generate around 2,030 MWh

of electricity per year, thereby strengthening the contribuon of renewable energy sources to

the energy system. [MDR-A_68_a, MDR-A_68_b, MDR-A_68_c]

Based on esmates, the total installed capacity of 1,430 kWp could correspond to the

avoidance of approximately 770 t CO₂e per year according to locaon-based factors and 568 t

CO₂e according to market-based factors, at the level of the electricity system. The addional

contribuon aributable exclusively to the 1,000 kWp expansion is esmated at 538 t CO₂e

(locaon-based) and 397 t CO₂e (market-based) according to the Ministry of Environment and

Energy's latest emission factors. [E1-3_29_b]

The above esmates take into account both exisng electricity producon from the 430 kWp

photovoltaic system and the planned installaon of a new system by 2030. These calculaons

are based on the assumpon of stable electricity consumpon and emission factors for

imported energy throughout the reporng period. [MDR-T_80_f]

The electricity generated by PPA SA's photovoltaic systems is fed into the naonal electricity

grid and is not consumed by the Company itself during the reporng period. During the

sameperiod, the Company did not consume energy from nuclear sources; therefore, total

nuclear energy consumpon was zero (0). In addion, during the reporng period, the

Company did not consume renewable energy or other forms of energy beyond those reected

in the relevant table in secon E1-5. Informaon on the energy mix and energy consumpon

is presented in detail in secon E1-5 of this Report. Furthermore, PPA S.A. does not implement

projects involving the removal, capture or storage of greenhouse gases (E1-7), nor does it

apply an internal carbon pricing system (E1-8). [E1-5_37_b, E1-5_37_ci, E1-5_37_ciii, E1-

5_AR_34]

430 kWp

Installed PV Plants

1430 kWp

Planned PV Plants

Page 227 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

In parallel, the Company is preparing the “Acon Plan for the Migaon of Greenhouse Gas

Emissions”, which covers all port facilies and aims to dene coherent measures for reducing

emissions by 2030. [MDR-A_68_a], [MDR-A_68_b] The study incurred operang expenses

totaling €25,500, as presented in the “Expenses” table [MDR-A_69_a], [MDR-A_69_b]. Given

that the ”Acon Plan for the Migaon of Greenhouse Gas Emissions” is sll under

preparaon, as the reporng date it is not yet possible to esmate reliably the amount of

future nancial resources that will be required for the implementaon of the proposed

acons. The relevant cost and funding esmates will be determined aer the implementaon

and nalizaon of the plan and of the individual measures to be proposed. [MDR-A_69_c].

The Acon Plan examines a series of decarbonizaon iniaves, such as energy eciency,

electricaon, transion to other types of fuels and the expanded use of renewable energy

sources. The Acon Plan is expected to be completed within the rst half of 2026.

Through the Acon Plan specic targets for the reducon of greenhouse gas emissions and

specic acons for achieving those targets will be dened. During the reporng period, there

is not yet any available quaned esmate of the amount of future nancial resources that

will be required for the implementaon of the acons under the “Acon Plan for the

Reducon of Greenhouse Gas Emissions”, which is sll under preparaon. The relevant

esmate will be made aer the compleon and nalizaon of the Plan and of the individual

measures to be proposed. [MDR-A_69_c]

Moreover, PPA S.A.’s Masterplan (Government Gazee 32D/2023) provides for the design and

renovaon of building infrastructure in accordance with energy eciency and green building

standards (LEED, ELGBC, DGNB), which will further contribute to the reducon of Scope 2

emissions and improve the Company’s overall environmental performance. [MDR-A_68_a],

[MDR-A_68_b] Given that the “Acon Plan for the Migaon of Greenhouse Gas Emissions”

is sll under preparaon, there are currently no available esmates regarding the amount of

future financial resources that will be required for the implementation of the proposed

actions. The relevant cost estimates will be determined after the completion and finalization

of the plan and of the individual measures to be proposed. [MDR-A_69_c]

686.3

579.68

2024 2025

Annual electricity production from renewable sources (MWh)

Page 228 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

With regard to the completion time horizons of the main actions, it is noted that:

I. the “Action Plan for the Reduction of Greenhouse Gas Emissions” is expected to be

completed within the first half of 2026,

II. the interventions arising from the Masterplan will be implemented gradually, depending on

the maturity and approval of the individual projects,

III. the existing operational optimization actions are already being implemented and continue

on an ongoing basis, and

IV. the actions related to the potential use of artificial intelligence tools are under evaluation

and, if approved, will be included at a later stage of implementation. [MDR-A_68_c]

At the operaonal level, PPA S.A. implements a range of energy- and fuel-saving pracces,

including algorithmic opmizaon of container-terminal operaons (CATOS), the gradual

replacement of lighng with LED xtures and the procurement of energy-ecient equipment

where technically feasible.

In addion, the Company is examining the potenal use of digital and AI-supported tools to

enhance operaonal and energy performance. Such technologies may support improved

monitoring of equipment eciency, opmizaon of terminal operaons and the early

idencaon of “abnormal”/elevated consumpon paerns. These iniaves are intended to

complement PPA S.A.’s broader acons under its GHG Migaon Plan.

The Company also supports emission reducons beyond its own boundaries through acons

that support port users in their own eorts to reduce emissions. In this context, the Company,

through its parcipaon in an EU-co-funded project (CIPORT) has prepared technical,

environmental and nancial studies for ve passenger-ship berths and four cruise berths. OPS

infrastructure is expected to signicantly reduce fossil fuel consumpon and emissions during

berth periods and contribute to the migaon of the port’s GHG and air pollutant emissions.

[E1-3_29_a]

Project nancing is covered by both EU and Company funds, with PPA S.A. contribung

approximately 50% of eligible costs. PPA S.A.’s budget allocaon amounts to €170,000 for the

CIPORT project, with the Company covering 50% of eligible expenditures. [MDR-A_69_a],

[MDR-A-69_b], [MDR-A_69_c, E1-3_AR21]

The implementaon of the above iniaves is subject to the availability and allocaon of

appropriate nancial and technical resources, as well as the integraon of the relevant

technological soluons into the Company's exisng operaonal framework.

In addion, the Company is working on the development of liqueed natural gas (LNG)

bunkering services for cruise vessels, as a rst step towards providing alternave fuel

bunkering services to vessels [MDR-A_68_b, E1-3_29_a].

Page 229 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

This acon is expected to support the gradual transion of the port towards lower-carbon

soluons and to contribute to the Company’s broader goals for reducing greenhouse gas

emissions. Liqueed Natural Gas is considered a transional fuel towards decarbonization, and

its bunkering requires research and the implementaon of specic procedures to ensure safe

operaon. The meline for decision-making on related acons is expected within 2026. [MDR-

A_68_c]

Energy Efficiency and Carbon Footprint

PPA S.A. relies on actual electricity and fuel consumpon data, drawn from supplier invoices

and from available measuring equipment installed within the facilies. These data are used to

record and disnguish consumpon by facility, operaon and type of equipment, ensuring

accuracy in data collecon and subsequent processing.

For the conversion of fuel consumption into energy and GHG emissions, the official emission

factors and the relevant methodologies issued by the Ministry of Environment and Energy are

applied, aligned with the framework of the national climate change law. The emission factors

used for the following calculaons of Scope 1 and Scope 2 emissions are based on the

published factors of the Ministry of the Environment and Energy for the year 2024. These

calculaons will be updated aer the publicaon of the corresponding factors for the year

2025 by the Ministry of Environment and Energy and will be subject to external vericaon in

accordance with ISO 14064-1. It should be noted that, as part of this process, there may be

minor dierences in the inially esmated results due to the updang of emission factors or

improvements in the available acvity data. Upon compleon of the external vericaon, the

updated data will be reected in the Company's subsequent Report. [E1-6_AR_39_b], E1-

6_AR_46_h [E1-6_AR_46_h], [MDR-M_77_a] [MDR-M_77_a]

In the tables below, the 2024 figures show minor deviations compared to those published in

the 2024 Annual Financial Report, as detailed in the section ‘Changes in the preparation and

presentation of sustainability information compared to the previous reporting period’ of ESRS

2. The revised calculations for 2024 correspond to figures that have already been externally

verified in accordance with ISO 14064-1.

Page 230 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Energy Consumption (MWh)

Category

2024

(Published)

2024

(Revised)

2025

Gasoline

562.88

604.88

Diesel

10,847.11

11,023.5

12,116

Fuel consumption from crude

oil and petroleum products

11,409.99

11,586.38

12,720.88

Consumption of purchased/

acquired electricity, thermal

energy, steam & cooling from

fossil fuels

18,979.23

19,407.52

19,783.17

Total non-renewable energy

consumption (fossil fuels)

30,389.22

30,993.90

32,504.05

Percentage of non-renewable

energy sources (fossil fuels) in

total energy consumption (%)

100%

Consumption of

purchased/acquired energy

(electricity, heat, steam,

cooling) from RES

Total renewable energy

consumption

Share of renewable sources in

total energy consumption(%)

Total energy consumption

30,389.22

30,993.90

32,504.05

Energy intensity (MWh/million

€ net revenue)

132.38

134.20

129.60

Annual electricity production

from RES for sale

(MWh)

686.30

579.68

Electricity Percentage (%)

62.50%

62.5%

60.9%

[E1-5_37], [E1-5_37_a], [E1-5_37_c], [E1-5_37_cii], [E1-5_AR_34], [E1-5_38_b], [E1-

5_38_e], [E1-5_AR_34], [E1-5_39], [MDR-M_75]

Page 231 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

For the calculation of energy intensity, the Company distinguishes revenue streams associated

with climate-related activities, in line with ESRS requirements. [E1-5_40, E1-5_41, E1-5_42,

E1-5_43]. This distinction allows for a more accurate association between energy

consumption and relevant economic activity, enhancing transparency and comparability

among indicators. PPA operates in NACE sectors C, E, and H, which have been classified as high

climate impact, while all other revenue from low climate impact sectors relates to foreign

currency fluctuations, which do not involve any energy consumption.

[E1-5_43_ΑR_38]

Scope 1 and Scope 2 emissions are calculated and disclosed based on the level of operaonal

control exercised by PPA S.A. over the relevant acvies, [E1-6_48_a_AR43] , [E1-6_49_a, E1-

6_44, 52_b_AR45_AR47, E1-6_44, 52_a_ AR45_AR47] in accordance with ESRS requirements

and boundaries applied remain consistent, ensuring comparability with previous reporng

periods and in compliance with ISO 14064-1 standard.

Revenue (million € net revenue) [E1-5_43_ΑR_38]

Category

2024

2025

Net revenue from activities in high climate impact sectors (used for

calculating energy intensity

229.56

249.52

Other income – Regarding exchange rate fluctuations

1.43

1.44

Total revenue as presented in the financial statements

230.99

250.96

All renewable electricity generated through the PV panels of the Company is fed into the

national grid and at present no other renewable or non-renewable energy is produced or

consumed. [E1-5_39, E1-5_37_ci, E1-5_37_ciii, E1-5_37_b, E1-5_AR_34] The Company

does not use coal, coal products, natural gas or other fossil fuels beyond those shown in

the table above. [Ε1-5_38_a, E1-5_38_c, E1-5_38_d]

134.17

129.60

2024 2025

Specific Energy Consumption (MWh/million €

Turnover)

Page 232 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Company also reassessed its Scope 3 emissions for the current reporng year in compliance

with ISO 14064-1:2018. Τhe most material source of Scope 3 emissions relates to vessels berthed

at the port’s facilies.

In accordance with ISO 14064-1:2018, the Company connues to quanfy the following Scope 3

categories, which have been idened as relevant to its operaonal prole:

• Category 3.3: Emissions from business travel

• Category 3.5: Emissions from employee commung

• Category 5.1: Emissions or removals from the product use stage

These categories were calculated for both 2024 and 2025, remaining essenally unchanged in

terms of their scope. However, for 2025, the Company adjusted the coding of emission categories,

switching from the GHG Protocol classicaon to the corresponding coding provided for in ISO

14064-1:2018. During the current reporng period, PPA SA focused mainly on updang and

improving the quality and completeness of the data used for the calculaon of Scope 3 emission

categories. The remaining Scope 3 emission categories were assessed as not relevant, primarily

based on qualitave assessment and documented professional judgment, taking into account PPA

S.A.’s operaonal prole, the nature of its acvies, and the relevance of each category to port

operaons. This assessment was not based on a full quantave esmaon for all other

categories. [E1-6_AR_46_i]

GHG emissions (t CO

2024

(Published)

2024

(Revised)

2025

Stationary combustion

176.21

223.32

264.05

Mobile combustion

3,081.42

2,856.38

3,117.12

Fugitive emissions

188.29

325.45

107.97

Total Scope 1

3,445.92

3,405.15

3,489.15

Scope 2 – Market-based

6,909.52

5,288.26

5,390.61

Scope 2 – Location-based

9,482.06

4,518.79

4,606.25

Total Scope 1 & 2 (market-based)

10,355.44

8,693.41

8,879.76

Total Scope 1 & 2 (location-based)

12,927.98

7,923.94

8,095.40

Scope 3 Emissions (t CO₂e)

2024

(Published)

2024

(Revised)

2025

Category 3.3: Business travel

125.84

147.71

Category 3.5: Employee commuting

1,025.64

851.28

Category 5.1: Emissions or removals from the product

use stage

44,549.10

232,174.11

244,970.93

Total Scope 3 Emissions

45,700.59

233,325.59

245,969.93

Page 233 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Total Emissions (Scope 1-2-3) (t CO₂e)

2024

(Published)

2024

(Revised)

2025

Total emissions – Market-based

56,056.03

242,019.00

254,849.69

Total emissions – Location-based

58,628.57

241,249.53

254,065.33

Total emissions intensity index (t CO₂e / million €) –

Market based

242.68

1.047.75

1,016.15

Total emissions intensity index (t CO₂e / million €) –

Location based

253.82

1.044.42

1,013.02

Page 234 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The GHG emissions calculaons were carried out in accordance with ESRS requirements and

ISO 14064-1:2018. [E1-6_44, E1-6_48_a, E1-6_49_a, E1-6_49_b, E1-6_50, E1-6_51, E1-

6_52_a, E1-6_52_b, E1-6_AR_41, E1-6_AR_46_d, E1-6_AR_50, E1-6_53, MDR-T_80_j, MDR-

M_75].

The Company does not parcipate in regulated emissions trading schemes [E1-6_48_b], nor

does it use guarantees of origin or other convenonal means for Scope 2 emissions. [E1-

6_AR_45_d]

No biofuels are used in the Company’s acvies or in the reported Scope 3 categories,

therefore biogenic emissions are considered insignicant. During the reporng period, there

were no signicant changes in the denion of the reporng enty or in the scope of the

upstream and downstream value chain of the Company compared to the previous reporng

period. Therefore, there are no eects from "subsequent signicant events or changes in

circumstances" between the reporng dates of the enes in the value chain and the date of

approval of the nancial statements of the Company for the purposes of calculang emissions.

However, in 2025, the Company undertook a signicant methodological review of the

calculaon of category 5.1 emissions in order to improve accuracy. The new approach includes

the use of more detailed calculaon methods, improved data collecon and analysis, and the

idencaon of new parameters relang to the specic condions of vessels and their

acvies. These changes have led to a change in the results compared to the previous

reporng period, enhancing the consistency and connuous improvement of the

methodological calculaon approach. As a result of the methodological review and the

adaptaon of the coding of emission categories to the ISO 14064-1:2018 standard, dierences

arose in the results for the 2025 period compared to the previous reporng period. For

comparability purposes, the corresponding 2024 data were recalculated according to the new

methodological approach and the comparave gures were updated accordingly. [E1-6_47,

E1-6_AR_43_c, E1-6_AR_45_e, E1-6_AR_46_j, E1-6_47, E1-6_AR_42]

Scope 2 locaon-based emissions were calculated with the country’s unied energy mix, while

market-based emissions were calculated using the supplier’s energy mix. The CO₂e conversion

factors were obtained from DAPEEP, while CH₄ and N₂O factors were applied based on the

Naonal Climate Law (4936/2022). [E1-6_AR39_b]

Page 235 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Category 3.3 Emissions from Employee Travel includes the daily commutes of the

organisaon's sta to and from work, using private cars, public transport, or alternave means

(such as bicycles, scooters, walking, etc.). Employees and senior management who use

company vehicles are excluded from the calculaon, as emissions related to company vehicles

are included in the organisaon's Scope 1 emissions. It should be noted that no teleworking

model is applied, so this parameter is not examined. For quancaon purposes, a travel

survey was conducted with a 46% response rate, and the results were extrapolated to the

enre workforce (excluding those who travel in company vehicles). Emissions were calculated

based on distance traveled and the latest emission factors per mode of transport from the UK

Department for Environment, Food and Rural Aairs (DEFRA). To esmate the number of trips

per employee, the ve-day working week, public holidays, and an average number of vacaon

days per employee were taken into account, in accordance with naonal legislaon. [E1-

6_AR_46_g].

Category 3.5 Emissions from Business Travel includes domesc and internaonal travel

undertaken by sta for business purposes. The scope includes air travel and overnight stays in

accommodaon for business purposes, regardless of whether the trip was organised through

a contracted travel agency or directly by the employee.

Emissions from air travel were calculated based on distance traveled (distance-based

approach). Flights were categorised by type (domesc, short-haul, long-haul) and seat class

(economy, business, average), and the most recent DEFRA emission factors available for the

corresponding reference year were applied.

Emissions from hotel stays were esmated based on the total number of overnight stays per

country. Country-specic emission factors, as published by DEFRA and the GREENVIEW tool,

were used for the calculaon, taking into account variaons in the energy mix and average

energy intensity of the hotel sector in each country.

The methodology was applied based on available primary data (distances, number of

overnight stays) and secondary emission factors from internaonally recognised sources,

ensuring consistency and comparability between reporng periods.

Secon 5.1 Emissions or removals from the product use stage includes vessels moored at the

organisaon's port facilies. The scope includes vessels operang at the Container Terminal,

the Ro-Ro Terminal, the Coastal Shipping Lines (including Argosaronic, Perama ferry terminal

and G1), the Ship Repair Zone and other repair areas, as well as the vessel service areas of

AGET, CORAL, foreign cargo ships, and small vessels operang within the port.

Emissions were calculated using the boom-up methodological approach of the Fourth IMO

GHG Study 2020, based on the operaon of main and auxiliary engines during berthing. The

following were used to determine emissions:

• arrival and departure mes (where available from the Agency and/or the competent

Port Authority),

• vessel type and size data,

• technical characteriscs (engine power, year of manufacture),

• typical fuel consumpon values.

The technical data were obtained either from available internal informaon or from

recognised external databases (Fourth IMO GHG Study 2020, EQUASIS, MarineTrac).

Page 236 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

In cases of insucient data (e.g., unavailable precise data on berthing mes or vessel technical

characteriscs), documented assumpons were applied regarding average dwell me and

engine operaon. Where crical technical data (e.g., year of manufacture) were missing, a

conservave approach was adopted, selecng the most unfavorable technological scenario to

avoid underesmang emissions.

The CO₂, CH₄, and N₂O emission factors per fuel type were taken from the Fourth IMO GHG

Study 2020 and converted to CO₂e based on the corresponding global warming potenal

(GWP) values. The calculaon took into account the regulatory framework governing the use

of fuels within European ports, in accordance with applicable European and naonal

legislaon[E1-6_AR_46_h, E1-6_AR_39_b]

Greenhouse gas emission intensity indicators are calculated as tons of CO₂e per million euros

of turnover (tCO₂e/€ million). The revenue used to calculate the specic indicators

corresponds to the net revenue of PPA S.A., as presented in the published nancial statements

for the reporng period. No adjustment or exclusion of revenue is made for the calculaon of

the intensity indicator, and therefore the net turnover used to calculate the emission intensity

is fully consistent with the net revenue in the nancial statements, without any dierenaon

or balance of revenue that is not taken into account. [E1-6_55, E1-6_AR_55, E1-6_55, E1-

6_AR_55]

Pollution

Within the framework of the Double Materiality Assessment and in accordance with the

requirements of the European Sustainability Reporng Standards (ESRS), PPA S.A. carried out

a systemac screening of all port facilies, acvies and operaonal areas, with the objecve

of idenfying actual and potenal impacts, risks and opportunies related to polluon.

[E2_IRO-1_11_a]

During the assessment, a stakeholder consultaon process was conducted, involving shipping

companies, employees, port service providers and local communies aected by port

operaons, in line with the engagement process described in the relevant chapter of this

Report. [E2_IRO-1_11_b]

The screening process for polluon issues was based on the approved Environmental Impact

Study (EIS) and the applicable Decision on the Approval of Environmental Terms (AEPT), which

specify the relevant sources of polluon, monitoring requirements, and prevenon and

migaon measures for port acvies. At the same me, the results of the Environmental

Monitoring Programme (seawater, sediments, air polluon, noise) were taken into account, as

well as the Company's procedures and acons for the prevenon and management of

polluon incidents. The basic assumpons of the assessment were the full coverage of the

facilies and acvies controlled by PPA S.A., the examinaon of both actual and potenal

impacts, and the use of measurement data where available. [E2_IRO-1_11_a]

The results revealed that material impacts are primarily linked to acvies within the port

value chain, including berthing, vessel operaons, loading/unloading acvies and fuel

handling, which may result in leaks of lubricants or fuels and local air quality degradaon. [E2-

IRO-1_AR9]

Page 237 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Within the screening process, the Company idened areas and acvies where polluon

constutes a material topic:

(a) Operaonal locaons where polluon is a potenal impact

• Cruise Terminal

• Container Terminal

• Car Terminal

• Ship Repair Zone and Dry Docks

• Land-based support facilies (auxiliary & bunkering zones)

(b) Business acvies associated with signicant polluon impacts

• Vessel berthing and dwell

• Loading and unloading operaons

• Bunkering, transport and handling of fuels

• Maintenance and repair acvies

• Operaons of service providers and contractors

Targets and Actions for Pollution Prevention and Reduction

Although the acvies of PPA S.A. do not involve the discharge of pollutants into the

environment, the Company has established a structured framework of objecves and

prevenve measures aimed at minimizing the risk of any small-scale leaks or polluon

incidents that may occur. The Company systemacally monitors and evaluates the impact of

its acvies and remains commied to their connuous reducon, in full alignment with its

Integrated Management System, the Environmental Terms Approval Decision, and the

European Sustainability Reporng Standards (ESRS). The relevant targets cover all acvies of

PPA S.A. within the port area and are monitored at company level, with 2024 as the base year,

unless otherwise stated in the relevant table [MDR-T_80_a], [MDR-T_80_b], [MDR-T_80_c],

[MDR-T_80_f], [MDR-T_80_g]

To address marine and land-based polluon, the Company implements approved Emergency

Response Plans and programmes for monitoring the quality of seawater and sediments, which

are supported by annual preparedness exercises, with the aim of ensuring an immediate and

eecve response in the event of an incident. [MDR-T_80_b], [MDR-T_80_c], [MDR-T_80_d],

[MDR-T_80_e], [E2-3_23_b]

In terms of air quality, the Company operates atmospheric quality monitoring staons and a

digital data management plaorm to ensure that pollutant concentraons remain within the

applicable legal limits. [MDR-T_80_b], [MDR-T_80_c], [MDR-T_80_d], [MDR-T_80_e], [E2-

3_23_a]

All polluon-related objecves and acons have been developed following consultaon with

employees and stakeholders, in line with the requirements of the Management System and

the environmental permits framework. [MDR-T_80_h]

The Company’s objecves, acons and monitoring indicators are presented on the table

below.

Page 238 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

POLLUTION

IRO

Acons

[MDR-A 68a]

Target

[MDR-T- 80b]

Year

[MDR-A 68c/ MDR-

T 80e]

KPIs

[MDR-A 68e/ MDR-T

80b/ MDR – M- 75]

Progress in 2025

[MDR-A 68e/ MDR-T-

80j]

Ε2

Air Polluon

Air polluon monitoring programme

(in accordance with the Air Quality

Guidelines)

Ongoing

Maintain

concentraons

below legal limits.

– Daily average SO

limit<125 μg/m

concentraon

Ongoing

Ε2

Digital plaorm for online monitoring

of measurements and results

2025

100% achieved

Ε2

Polluon of Coasts,

Marine Water and

Sediments (Company-

Specic)

Implementaon of Emergency

Response Plans for sea and land

polluon incidents

Ongoing

Number of polluon

incidents

100% achieved

Ε2

Annual drill (emergency drill) for

responding to spills at sea and on land

Ongoing

Minimum one drill

per year

Number of drills

100% achieved

Ε2

Sea water monitoring programme &

sediment monitoring programme

Ongoing

Annual reports

Number of reports

100% achieved

Ε2

Noise Management

(Company-Specic)

Noise monitoring programme across the

enre port area

Ongoing

Annual reports -

Noise level limit Lden

= 70 dB

Number of reports

100% achieved

Page 239 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

A noise acon plan for the container

terminal was submied to and approved

by the Ministry of the Environment

2028

- Installaon of noise

barriers in accordance

with the approved

Acon Plan for Noise

at the E/T Container

Terminal.

- Reducon of noise

levels in the area

covered by the noise

barriers aer their

construcon

Eecveness of noise

barriers: Reducon of

Lden by at least 2 dB

with the construcon

of noise barriers

Ongoing/ 30% of

target achieved

Page 240 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The above objecves are linked to the prevenon and control of air polluon through the

monitoring of pollutant concentraons and compliance with the applicable limit values [E2-

3_23_a], and to the prevenon and control of emissions/discharges into the aquac

environment through the implementaon of marine water and sediment monitoring

programmes and the implementaon of Emergency Response Plans [E2-3_23_b], as well as

by liming incidents of land-based polluon through control and operaonal readiness

procedures [E2-3_23_c]. During the reporng period, targets are monitored mainly through

compliance indicators (concentraon limit values, number of exceedances, number of

incidents and exercises), without quaned targets being set at the level of “specic loads”.

The targets related to the prevenon and reducon of polluon derive from the obligaons

set out in the applicable Environmental Terms Approval Decision (AEPO) of PPA S.A. and

therefore, are of a mandatory nature. [E2-3_25]

The implementaon of Emergency Plans and the relevant operaonal readiness are carried

out in accordance with the applicable regulatory framework (indicavely: OPRC90

Convenon, Law 743/1977, Presidenal Decree 55/1998, Presidenal Decree 11/2002, and

HNS Protocol 2000). [MDR-T_80_f], [MDR-T_80_g]

Actions, Performance and Measurement Indicators

To quanfy performance and monitor progress against the commitments of both the

Environmental Policy and the approved targets and in alignment with the provision of the port

Environmental Approval Decision, the Company implements integrated monitoring and

control programmes. These programmes allow the mely idencaon of deviaons and the

adopon of addional, or emergency measures where required.

Within the Double Materiality Assessment, polluon has been idened as an actual negave

environmental impact for PPA S.A. However, the Company is not subject to Regulaon (EC)

166/2006 (E-PRTR), as its acvies do not fall within the scope of the regulaon. Therefore,

PPA S.A. is not required to submit pollutant release and transfer reports. [E2-4].

Furthermore, the Company does not produce, use, procure, or release any substances

classied as substances of concern or substances of very high concern (SVHCs) under

applicable EU chemicals legislaon. Consequently, no such substances arise as emissions or

outputs from its operaons. [E2-5]

In the event of a signicant polluon incident aecng the local community or the marine

environment, PPA S.A., together with the responsible party (e.g. the pollung vessel), is

commied to cooperang with aected stakeholders to provide support and ensure the

restoraon of any related impacts, in accordance with applicable legislaon and

environmental terms. [MDR-A_68_d], [E2-2_AR_13]

Page 241 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Emergency Response

PPA S.A. applies approved Emergency Response Plans for marine and land-based polluon

incidents, developed in accordance with the OPRC 90 Convenon, Law 743/1977, Presidenal

Decree 55/1998, Presidenal Decree 11/2002 and the 2000 HNS Protocol. [MDR-A_68_a],

[MDR-A_68_b] These Plans dene the required procedures for responding to oil spills or

hazardous substance releases within the areas under the Company’s responsibility. To ensure

operaonal readiness, the Company conducts one polluon-response drill annually, rotang

between dierent operaonal areas. [MDR-A_68_c]

Following the Company's stated objecves for the prevenon/response to incidents of

marine and land polluon, and in parcular the objecve of conducng at least one (1) drill

per year, the Company conducted its annual drill on 26/11/2025 at the Central Port of Piraeus

(Gate E7 – Cyclades). Consequently, the annual drill objecve for 2025 was achieved. The

exercise was evaluated based on the procedures of the Emergency Plans and recorded the

eecveness of coordinaon between the pares involved (Company, specialised contractor,

Coast Guard), as well as any necessary improvement/correcve acons that are incorporated

into the Company's preparedness programme. [MDR-T_80_j], [E2-2_AR_13] [MDR-T_80_j]

Oil spill response drill at the Central Port of Piraeus

During the drill and the acvaon of the relevant conngency plans, coordinaon between

the Hellenic Coast Guard and the polluter (e.g. vessels) is closely monitored and maintained

to simulate the migaon of the potenal negave impacts. [E2-2_AR_13]

Page 242 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

In the present case, no revenues arise from products or services that are or contain substances

of concern or substances of very high concern. The Company cooperates with a specialized

contractor for the acvaon and implementaon of its Emergency Response Plans, when

required. For 2025, the related cost amounted to €45,518.40 excluding VAT. These costs are

recorded under the Company’s operang expenses in the “EXPENSES” table, while no relevant

capital expenditures were incurred during the reporng period. [MDR-A_69_a], [MDR-

A_69_b] A slight increase is ancipated for the following year. [MDR-A_69_c], [E2-6_40_b]

The acvaon of the emergency response plan is assessed in accordance with the applicable

legislaon and is used to evaluate PPA S.A.’s performance on likely impacts of coastal and

marine polluon. It should be noted that the Coast Guard is responsible for approving the

emergency plan and all the procedures it provides for. In cases where the Emergency Plan is

acvated, the competent Port Authority is immediately noed and all intervenon work is

carried out under its coordinaon, in accordance with the applicable regulatory framework.

[MDR-M_75], [MDR-M_77_a].

The measurement of the indicator (number of Emergency Plan acvaons) is based on

internally recorded operaonal data and is not subject to validaon by an external body other

than the provider of the Assurance Report. [MDR-M_77_b]

As illustrated in the chart below, in 2025 the emergency plan was acvated eight (8) mes for

marine polluon incidents and 23 mes for land-based polluon incidents. It is important to

note that 12 of the 23 land polluon incidents were extremely minor (spill less than 5 m

while all incidents were eecvely dealt with based on PPA S.A.'s Emergency Response Plans.

Page 243 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Environmental Monitoring Programmes

The Company implements a

comprehensive

Environmental Monitoring

Programme that covers all

crical operaonal areas of

the port, in order to monitor

the impacts of PPA S.A.’s

business acvies on the natural environment. The programme includes:

• Noise monitoring programme

• Air quality monitoring programme

• Marine water monitoring programme

• Marine sediment monitoring programme

Measurements and analyses are carried out by specialized external partners and scienc

bodies (including the Naonal Technical University of Athens), using internaonally

recognized laboratory and instrumentaon methods and applying quality assurance

procedures. In summary, the measurement methodologies include:

Seawater quality: periodic sampling (summer and winter) is carried out at representave

locaons. The samples are analyzed for basic physicochemical parameters, nutrients, heavy

metals, microbiological indicators, and selected organic pollutants in order to assess the

condion of the water column and idenfy any trends or deviaons.

Μarine sediments quality: periodic sampling is also carried out at targeted locaons of

interest. Samples are prepared and analyzed for heavy metals and key organic pollutants (such

as PAHs/PCBs), as well as for indicators related to the organic composion of sediments,

supporng the assessment of potenal pressures from port acvies.

Air polluon: Permanent monitoring staons operate within the port area, systemacally

recording key atmospheric pollutants (e.g. nitrogen oxides, sulfur dioxide, parculate maer,

ozone, carbon monoxide, and/or volale organic compounds—per staon). The operaon of

the staons is supported by a programme for monitoring and ensuring the quality of

measurements.

Noise: the acousc environment is monitored by taking 24-hour measurements at specic

locaons every quarter, as well as by ulizing data from permanent connuous recording

staons. The assessment is based on established noise indicators and the relevant regulatory

framework.

Trac load: 24-hour measurements are carried out at selected cross-secons of the road

network serving the port, in order to correlate changes in trac load (including heavy

vehicles) with the observed pressures on the acousc and atmospherice environment. [E2-

4_30_b], [E2-4_30_c], [MDR-M_77_a] [E2-4_30_b], [E2-4_30_c], [MDR-M_77_a]

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(amounts in Euro unless stated otherwise)

The measurement of indicators is based on data collected by specialized external partners and

scienc bodies. The data is not subject to separate validaon by an external body.

[MDR-M_77_b]

To enhance the eecveness of the Environmental Monitoring Programmes, PPA S.A.

developed in 2024 an electronic plaorm for the consolidaon of monitoring data and

observaons. The plaorm provides:

• direct access to observaons and data for each monitoring staon

• the ability to idenfy data points that require invesgaon or correcve acons

• detecon of potenal sensor malfuncons

• automac generaon of charts and comparave visualisaons

• data export for reporng or internal evaluaon.

Noise Pollution

Noise Monitoring Programme

PPA S.A. in cooperaon with a specialised licensed partner implements the Noise Monitoring

Programme to assess the impacts, risks and opportunies related to noise from port acvies.

[MDR-A_68_a], [MDR-A_68_b], [MDR-A_68_c]

Image Measurement position of Environmental Monitoring Programmes (noise, air

quality, water, sediments) for 2025

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Programme covers the main operaonal sectors of the port (commercial, passenger,

repair etc.) and includes:

• Recording Lden and Lnight indicators at eight (8) locaons, with 24-hour noise

measurement

• Joint assessment of measurements from three (3) connuously operang Permanent

Noise Monitoring Staons

• Trac load measurements at four (4) high-load points

All measurements follow the methodology of the naonal legislaon (ΚΥΑ 211773/2012) and

include the recording of percenle indicators (L1, L10, L50, L95, L99), maximum and minimum

values (Lmax, Lmin), LAeq (day-night, 24h), and Lden/Lnight/Lday/Levening indicators.

Noise measurements for 2025 were carried out in four quarterly cycles, lasng two days per

locaon, during the following periods:

• 24/02/2025 - 28/02/2025

• 12/05/2025 - 16/05/2025

• 14/07/2025 – 18/07/2025

• 03/11/2025 – 07/11/2025

Key Monitoring Results for 2025

Assessment of the 2025 measurements revealed that:

• Noise levels are in general within PPA S.A.’s targets and the permied limit of the

regulaons as well as the Environmental Approval Decision of port.

• Road trac noise is a major contributor to the overall noise levels at the port

(commercial and central port)

• Port operaons make a notable contribuon to noise levels in the area of the

Container Terminal.

Noise Action Plan

Based on the ndings of the Noise Monitoring Programme and having as priority the

migaon of the noise impacts linked with port operaons, in 2024 PPA S.A., prepared a

comprehensive Noise Migaon Acon Plan for the Container Terminal which was approved

by the Ministry of Environment. In this context in 2025 the Specic Acousc Calculaon and

Implementaon Study (ΕΑΜΥΕ) for Noise Barriers in the Container Terminal was elaborated

and approved by the Ministry of Environment. The implementaon of the proposed measures

is in progress and will be implemented gradually by 2028. [MDR-A_68_a], [MDR-A_68_b],

[MDR-A_68_c]

The cumulave cost for implemenng the Noise Monitoring Programme and for EAMYE study

in total in 2025 was €27,500 plus VAT and has been recorded in the Company’s operang

expenses [MDR-A_69_a], [MDR-A_69_b]. There are currently no esmates available

regarding the amount of future nancial resources that will be required for the connuaon

and further development of the relevant acons, as the relevant needs will be determined in

the context of the annual planning and updang of the Company's environmental acons.

[MDR-A_69_c]

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PIRAEUS PORT AUTHORITY S.A

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(amounts in Euro unless stated otherwise)

Air Quality Monitoring Programme

The integrated Air Quality Monitoring Program, which has been carried out since 2009 in

cooperaon with the Naonal Technical University of Athens, was sll acve throughout the

year. The aim of the Programme is the connuous recording, assessment and quancaon

of air pollutants associated with port acvies, as well as the development of appropriate

techniques and measures to protect and improve air quality in the port and neighbouring

areas. [MDR-A_68_a], [MDR-A_68_b], [MDR-A_68_c].

The air quality monitoring programme is based on a network of 5 permanent air-quality

monitoring staons located within the Company’s area of responsibility. The concentraons

of the following parameters are monitored: [E2-4_30_b], [E2-4_30_c]

• nitrogen oxides (NOx),

• sulfur dioxide (SO₂),

• carbon monoxide (CO),

• ozone (O₃),

• parculate maer (PM10 and PM2.5),

• hydrocarbons (BTEX).

The total operang and monitoring and evaluaon costs for the reporng year including the

operaon of the digital monitoring plaorm is €34,000 plus VAT, are recorded as operang

expenses and disclosed in line with ESRS requirements. The relevant cost esmates will be

determined at a later stage [MDR-A_69_a], [MDR-A_69_b], [MDR-A_69_c].

Posions of permanent Air quality monitoring staons

According to the 2025 Annual Report, the results show no signicant deviaons from previous

periods and are consistent with the 2024 values; they are summarized in the following charts

[E2-4_30_a] [E2-4_30_a].

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(amounts in Euro unless stated otherwise)

None of the values of the remaining parameters (NO₂, SO₂, CO, O₃) exceeded the limits during

2025. With regard to the target set for maintaining the average daily concentraon below the

limit of 125 μg/m³, as shown in the chart below, it is fully complied with and no exceedances

are observed [MDR-T_80_j], [MDR-M_75] [MDR-T_80_j]

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PIRAEUS PORT AUTHORITY S.A

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(amounts in Euro unless stated otherwise)

Although, all SO₂ measurements for the reporng year remain within the permied limits,

PPA S.A. connues to systemacally monitor this specic pollutant due to its connecon to

ship acvity. The expected operaon of expanded measures for supplying electricity to

berthed ships from shore (cold ironing) is esmated to further contribute to reducing the

related air polluon loads.

All measurement data are submied to the Ministry of Environment in accordance with the

requirements of the Environmental Approval Decision of PPA S.A. and are summarised in PPA

S.A.’s Annual Environmental Report, which is publicly available on the Company’s website

hps://www.olp.gr/el/prostasia-perivallontos/prostasia-perivallontos-prasino-limani.

Seawater and Sediments Monitoring Programmes

PPA S.A.’s Seawater Monitoring Programme and Sediments Monitoring Programme remained

acve and in eect in 2025 and were run in cooperaon with the Laboratory of Sanitary

Engineering Technology of the School of Civil Engineering at the Naonal Technical University

of Athens. The aim of the Programmes is the integrated assessment of the state of the marine

environment and the formulaon of proposals for its improvement, within the requirements

of DAEC and the Company’s Integrated Management System. [MDR-A_68_b], [MDR-A_68_a]

For the implementaon of the seawater and sediments monitoring acvies in 2025, PPA S.A.

allocated a total amount of € 40,000 excluding VAT. These expenses are recorded in the

Company's operang expenses in the “EXPENSES” table. The relevant cost esmates will be

determined at a later stage. [MDR-A_69_a], [MDR-A_69_b]

Seawater Monitoring Programme

In 2025, two monitoring campaigns of the water column were carried out:

• Summer sampling: on 24/06/2025

• Winter sampling: on 10/12/2025

During these campaigns, 20 seawater samples were collected each me from selected

representave locaons across the port area, including the passenger port, commercial port,

and ship-repair zone. [MDR-A_68_c]

The samples were analysed for:

• general physicochemical parameters (temperature, pH, salinity, conducvity, total

dissolved solids, dissolved oxygen, turbidity, transparency, coloraon, suspended

solids),

• nutrients (orthophosphates, ammonium nitrogen, nitrite nitrogen, nitrate nitrogen),

• heavy metals (nickel, lead, copper, iron, chromium, zinc, cadmium, mercury, arsenic),

• microbiological parameters (total coliforms, E. Coli, enterococci),

• organic pollutants (hydrocarbons and TBT),

ensuring a complete and accurate assessment of the marine water quality.

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(amounts in Euro unless stated otherwise)

Sediment Monitoring Programme

Sediment monitoring was carried out through the collecon of 10 sediment samples from key

points within the port basin, including the passenger port, commercial port, and ship repair

zone. Sampling was conducted:

• Summer sampling: on 24/06/2025

• Winter sampling: on 10/12/2025

Samples were analysed for:

• heavy metals (nickel, lead, copper, iron, chromium, zinc, cadmium, mercury, arsenic,

manganese),

• PCBs (polychlorinated biphenyls) related compounds),

• PAHs (polycyclic aromac hydrocarbons),

• TBT compounds,

• TOC (total organic carbon).

Due to the large number of measurements and the wide range of parameters examined, the

results of the laboratory analysis are not presented in this report. As foreseen, the full

technical reports have been submied to the Decentralized Administraon of Aca and are

included in PPA S.A.’s annual Environmental Report, which is published on the Company’s

website hps://www.olp.gr/en/environmental-protecon/environmental-protecon. [MDR-

A_68_ d].

Water Management

PPA S.A.’s water impact mainly concerns the use of freshwater which is supplied through the

public network. The Organisaon’s business acvies do not extract marine resources either

biological or non-biological [E3_IRO-1_8_a] [E3_IRO-1_8_b]. The value chain analysis and

Double Materiality Principle did not conclude in the materiality of either impact to the

freshwater resources or the marine ecosystem. This was reinforced through specic

consultaon with stakeholders, which conrmed that water use and water quality do not

constute a material environmental issue for PPA S.A.’s operaons.

With regard to freshwater withdrawal related to the PPA's business model, water is drawn

exclusively from EYDAP and is divided into three uses to meet the needs of: PPA S.A.'s own

facilies, third-party land sub-concessionaires, and ships. However, most of the fresh water is

supplied to ships to meet their drinking water needs, as well as for hygiene, equipment

washing, cooling, reghng systems, etc.

As the volume of water consumed depends largely on ship trac which varies annually

depending on the number and type of ships calling at the port water demand cannot be

reliably predicted or stabilized. In 2025 PPA S.A. connued to systemacally monitor water

consumpon in all operaons. This monitoring helps to idenfy potenal changes that could

aect the materiality of the issue in the upcoming reporng periods and to plan responsible

resource-use pracces for the future. Customary annual quality tesng of the supplied water

was carried out, to ensure full compliance with EYDAP specicaons for drinking water and

its safe provision to third pares within the port zone.

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PIRAEUS PORT AUTHORITY S.A

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(amounts in Euro unless stated otherwise)

Water consumpon data for 2025 are presented in the table below. In the table below, the

2024 data show minor deviaons compared to those published in the 2024 Annual Financial

Report, as detailed in the secon “Changes in the preparaon and presentaon of

sustainability informaon compared to the previous reporng period” of ESRS 2.

Water Use (m

)

2024

(Published)

2024

(Revised)

2025

Water withdrawn from the network

for use in PPA S.A. facilities (m³)

225,520.00

319,582.00

316,067.00

Water consumption intensity (m³ /

million € turnover)

976.34

1,383.47

1260.24

Water drawn from the network for

use by land concessionaires (m³)

This category

had not been

calculated

22,115.00

20,287.00

Water drawn for the supplying ships

berthed at port facilities (m³)

649,295.70

595,086.00

655,456.00

Circular Economy

Waste Management in the Port Zone

Within the framework of the Double Materiality Principle and stakeholder consultaons, the

topic of Circular Economy was reassessed and again deemed non-material for PPA S.A.

[E5_IRO-1_11_a]. This conclusion is consistent with the previous period, as the Company’s

business model is based on providing port services and does not include a producon process

or the use of raw materials in signicant volumes.

In addion, PPA S.A. does not produce products or materials, while the resource inputs

required for its acvies are limited and are analysed in the “Value Chain” in chapter

“Business model and Value Chain” [E5-4_30]. Consequently, no signicant resource oulows

linked to products, packaging or residual ows were idened in line with ESRS E5-5_35

requirements. [E5_IRO-1_11_a], [E5_IRO-1_11_b]

Although no material IROs for the topic of Circular Economy have been idened, PPA S.A.

ensures the lawful and proper management of waste generated within the port zone through

licensed and specialised contractors. Waste ows are classied into two main categories:

1. Ship-generated waste

Ship-generated waste is managed in accordance with the Ship Waste Management Plan,

which has been approved by the competent Ministry. In accordance with the Plan, PPA S.A.

implements a port recepon system for the collecon and management of solid and liquid

ship waste by licensed, qualied contractors, giving priority to recovery and recycling.

2. Waste generated from port operaons and facilies

This category includes waste generated from PPA S.A.’s acvies and infrastructure,

disnguished as:

• Waste from the port’s regular operaonal acvity (daily port operaons)

• Waste from emergency works

, such as excavaons, construcons, and dredging

operaons.

The quantities in this category are not directly comparable between years due to the nature of the works.

Page 251 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The table below presents the total quanes of waste generated by the port, by type of waste

and management method. In addion, the quanes resulng from regular port operaons

(from regular operaons only) are shown separately, as they are considered representave

for comparisons between years.

Table: Total

port waste

generated (tn)

Waste Category

(tn)

Waste Category

(tonnes)

2024 Total port

waste

2025* Total

port waste

2025

2024 From

regular

operaons only

2025 From

regular

operaons only

Hazardous Waste

Hazardous Solid

waste

95,654

185,142

Hazardous Liquid

waste sent for

recovery

398

405

390

405

Total hazardous

waste

96,052

185,547

398

414

Non-Hazardous Waste

Paper, plasc,

metal, glass,

wood etc. /

Recycling

336

265

245

265

Mixed household

waste / Disposal

766

708

766

708

Operaonal

waste sent for

recovery /

Recovery

152,390

143,832

361

152

Total non-

hazardous waste

153,492

144,805

1,372

1,125

Total port waste

(hazardous &

non-hazardous)

249,545

330,352

1,770

1,539

The waste data for the year 2024 are finalised by registering the annual Waste Report of 2024

to the Electronic Waste Register (HMA) of the Ministry of Environment and Energy. It is noted

that the waste data for 2024 as published in the “Annual Financial Report 2024” of PPA SA

were based on internal company data, because the Waste Report 2024 was not submitted at

that time.

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PIRAEUS PORT AUTHORITY S.A

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(amounts in Euro unless stated otherwise)

This is the reason for the slight differences between waste quantities of 2024 in the two

reports.

In 2025 (as in 2024), high amounts of waste are observed due to dredging works implemented

in the main port, as well as other maintenance works, which are classied as "Waste from

emergency works" (WEEW). Waste in this category is classied as Excavaon, Construcon,

and Demolion Waste (ECDW) and is intended for recovery, while part of it is classied as

hazardous solid waste.

The table below shows the individual amounts of waste delivered to Alternave Management

Systems for the years 2024 and 2025 and are included in the category "Operaonal waste for

recovery/ Recovery," as reected in the above table of total port waste.

Table: Waste to Alternave Management Systems(tn)

(This waste is included in "Operaonal waste for recovery”)

Waste Category

2024 (tn)

2025 (tn)

Used Tires

11.16

19.98

Waste Electrical & Electronic Equipment (WEEE)

4.73

2.48

Vehicle Baery Waste

3.88

5.12

Waste Potable Baeries

0.15

0.14

Waste Lubricang Oils

19.22

13.87

Excavaon, Construcon, and Demolion Waste (ECDW)

152,027.86

143,636.89

When comparing the amounts of waste delivered to Alternave Management Systems for the

years 2024 and 2025, it can be observed that there is no signicant change and that, in

general, the amounts are small, with the excepon of Excavaon Waste, Construcon and

Demolion Waste (CDW), which is aributed to the emergency dredging works in the main

port.

• Waste volumes for 2025, compared to 2024, show that the amounts of waste generated by

normal port operaons (hazardous and non-hazardous) remain at similar levels, indicang

stability in the port's daily operaons.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Biodiversity

PPA S.A. operates within the coastal and marine environment. The port zone is classied as

an Arcially Modied Water Body under the EU Water Framework Direcve. This

classicaon is taken into account when assessing the potenal environmental impacts of PPA

S.A. on the marine and coastal environment. Furthermore, the Company’s facilies are neither

located in nor in close proximity to protected areas or zones of high biodiversity value

[E4_IRO-1_19_a].

As part of the Double Materiality Assessment, the Company examined potenal impacts,

dependencies, risks, and opportunies related to biodiversity. The assessment concluded that

biodiversity was not a material topic during the reporng period, considering the nature of

the Company’s acvies, the locaon of its facilies, and the exisng environmental

monitoring and control measures [E4_IRO-1_17_a].

The Company does not use raw materials in a producon process, as its acvies are primarily

operaonal and service-based rather than industrial [E4_IRO-1_17_e_i].

Nevertheless, the Company operates within and depends on the coastal and marine

environment and therefore maintains funconal interacons with ecosystems that may be

aected by port-related acvies [E4_IRO-1_17_b].

During the assessment of impacts, risks, and opportunies related to biodiversity, the

Company also considered potenal systemic risks associated with cumulave environmental

pressures on the coastal and marine ecosystem, including possible interacons among

atmospheric emissions, marine water quality, sediments, and noise. Based on the nature and

scale of the Company’s acvies, the locaon of its facilies, and exisng monitoring and

control mechanisms, these factors were not considered a material biodiversity issue during

the reporng period. Addionally, according to the Environmental Impact Study of PPA S.A.,

approved by the Ministry of Environment and Energy, the impacts of the Company’s

operaons on the natural environment (ecosystems, ora, and fauna) are assessed and

documented as non-signicant [E4_IRO-1_17_d].

Environmental pressures related to air emissions, marine water quality, sediments and noise

are monitored through the Integrated Environmental Monitoring Program, implemented in

accordance with the Environmental Approval Decision of port operaons and applicable

legislaon.

During the double materiality assessment, a consultaon with stakeholders was conducted to

assess potenal impacts, risks and opportunies [E4_IRO-1_17_c], [E4_IRO-1_17_e, E4_IRO-

1_17_e_ii], as described in the secon “Stakeholder engagement”.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Our People ESRS S1 – Own Workforce

ESRS S1- Own workforce

Stakeholders' Interests and Opinions [S1.SBM-2 12]

The Company recognizes its workforce as a key stakeholder group and integrates their views,

expectaons, and rights into the formulaon of its strategy and business model. Through

established engagement mechanisms and communicaon channels such as internal plaorms,

employee engagement surveys, and grievance mechanisms feedback is gathered on material

issues including working condions, Occupaonal Health and Safety, professional

development, equal opportunies, and fair treatment. This informaon is evaluated by

Management and incorporated into decision-making processes, contribung to the

development of policies and pracces that promote a safe and fair work environment, as well

as the respect for human rights within the framework of the Company’s overall strategy and

responsible operaons.

PPA S.A. places its workforce at the core of its strategy and business model, recognising it as

the foundaon for the port's safe, ecient, and resilient operaon. Due to the nature of port

acvies, including 24/7 operaons, the use of heavy machinery, and connuous service

provision, actual and potenal impacts on employees stem directly from and are closely linked

to the Company’s strategic objecves, such as operaonal excellence, digital transformaon,

and sustainable development, as well as its operang model. [S1.SBM-3 13 a (i)] The

Company’s commitment to responsible employment pracces, equal opportunies, and

connuous development is reected in its mission and values, and is further reinforced by

stable employment structures, such as the universal applicaon of full-me employment

(100%).

As of the end of the 2025 reporng period, PPA S.A. employed a total of 1,058 employees. The

workforce consists exclusively of employees operang within the Organisaon’s facilies in

Greece. PPA S.A. also engages one self-employed employee, who is not included in the

Company’s total number of employees. All workforce-related data presented in this Report

have been calculated using the headcount methodology as of 31 December 2025.

Number of Employees by Gender [S1-6_50(a)], [S1-6_50 b]

KPI

2024

2025

Male

872

898

Female

152

160

Total

1024

1058

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PIRAEUS PORT AUTHORITY S.A

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(amounts in Euro unless stated otherwise)

S1.SBM-3 – Material impacts, risks and opportunities related to

own workforce and their interaction with strategy and business

model

The actual and potenal impacts idened through the Double Materiality Assessment inform

the Company’s strategic choices, parcularly in strengthening occupaonal health and safety

systems, enhancing professional development and maintaining stable labour relaons. These

data support the adaptaon of PPA S.A.’s strategy to evolving workforce needs, sectoral trends

and applicable regulatory requirements. [S1.SBM-3 13 a (ii)]

Through the Double Materiality Assessment, PPA S.A. idened material impacts aecng its

own workforce, risks and opportunies, informed by input from employees, unions and

management representaves. [S1.SBM-3 13 a (ii)] The process highlighted that employees are

the most aected by working condions, especially health and safety maers in high-risk port

areas, equal treatment and inclusion, employee engagement and the need to build capabilies

for new technologies. These insights feed into decision-making processes and shape ongoing

and future strategic iniaves, as indicavely, the development of an occupaonal health and

safety management system (in accordance with ISO 45001 standard) and extensive training

programs for upskilling and reskilling. [S1.SBM-3 13 a (ii)], [S1.SBM-3 13 b]

To fully understand how the Company’s activities may impact its people, the assessment

covered the entirety of the Company’s workforce. Consequently, all employees who may be

materially affected by the Company’s operations are included within the reporting scope of

the assessment, in full compliance with the requirements of the European Sustainability

Reporting Standards (ESRS). [S1.SBM-3 14]

The Organisation’s workforce consists of 1,058 full-time employees, comprising both

permanent staff (1,000 employees) and temporary staff on fixed-term contracts (58

employees). Additionally, the Company engages one self-employed employee. [S1.SBM-3 14

The Double Materiality Assessment idened nine (9) material IROs:

Actual Posive Impacts

Work-life Balance & Well-being

Equal Opportunies

Employee Engagement and Social Dialogue

Potenal Posive Impacts

Training and Skills Development for New Technologies (Company Specic)

Actual and Potenal Negave Impacts

Occupaonal Health and Safety

Risks

Employee Health and Safety Incidents

Skill Gap and Technological Readiness

Opportunies

Diverse Talent Aracon

Upskilling – Technological Capabilies of Workforce

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The Double Materiality Assessment for 2025 idened Occupaonal Health and Safety as an

actual and potenal negave impact on its workforce, due to the nature of port acvies and

the possibility of isolated workplace incidents. This impact is not characterised by a systemic

or broad-scale eect but is associated with individual occurrences, which are systemacally

monitored. The Company implements extensive prevenve and migatory measures aimed at

liming associated risks and connuously improving working condions, while acknowledging

that, given the nature of its operaons, such risks cannot be enrely eliminated. [S1.SBM-3 14

Furthermore, the assessment conrmed the existence of signicant posive impacts

stemming from the Company’s established employment pracces and its long-term

commitments. PPA S.A. provides stable and quality employment, supported by a full-me

workforce and Human Resources management processes that promote fairness, equal

opportunies, and inclusion. These posive impacts are further enhanced by the

Organisaon’s robust social dialogue framework, which includes acve trade union

representaon and mulple channels for employee communicaon and engagement,

contribung to a construcve work environment. Simultaneously, the Organisaon

systemacally invests in workforce development through structured training programs and

connuous learning iniaves, strengthening professional growth and workforce adaptability

as technologies evolve and industry demands increase. These pracces generate actual and

potenal posive outcomes for employee well-being, engagement, equal treatment, and long-

term skills development. [S1.SBM-3 14 c]

The material risks and opportunies idened for the Company regarding its impacts and

dependencies on its own workforce primarily relate to performance in Occupaonal Health

and Safety, sta competencies in adopng new technologies, and the acquision of diverse

talent. Due to the nature of port acvies involving heavy equipment, vessel movements, and

operaons in high-security zones, there is an inherent risk of isolated occupaonal incidents.

This risk is addressed through structured preventave measures, systemac monitoring, and

emergency management procedures, as well as the phased development of a cered

Occupaonal Health and Safety Management System in accordance with the ISO 45001

standard, aiming for the connuous improvement of working condions.

Furthermore, in an environment where the marime sector is dynamically evolving toward

more digitalised and technologically advanced operaons, the Company systemacally invests

in upskilling and reskilling iniaves. These acons aim to enhance the readiness and

adaptability of the workforce, supporng the eecve ulisaon of emerging technologies

and modern operaonal pracces. [S1.SBM-3 14 d]

Beyond the risks associated with the Company’s workforce, the assessment also idened

opportunies arising from its ability to leverage exisng human capital strengths. These

opportunies include aracng diverse talent through the Company’s equal opportunity

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framework and inclusive recruitment pracces, as well as enhancing technological

competencies through connuous professional development.

Maintaining robust social dialogue structures and stable employment pracces, the

Organisaon is well-posioned to transform these opportunies into long-term value for both

the Company and its people. [S1.SBM-3 14 d]

The marime sector's transion toward digitalisaon, automaon, and low-carbon

technologies was assessed as material to the Company’s workforce, as it creates both potenal

impacts and dependencies that require management. Within the context of the assessment,

no signicant negave impacts were idened regarding the Company’s transion eorts, as

no restructuring, job losses, or adverse changes in employment condions are ancipated.

Conversely, the transion presents a signicant opportunity for the Organisaon linked to the

need for upskilling and reskilling for new technologies; the Company’s ability to adapt to future

alternave fuel systems and digital port operaons depends on having a workforce with the

appropriate competencies. This dependency is reected in the Company’s long-term

commitment to connuous educaon and professional development, supported by structured

learning programs and technological skill enhancement iniaves already in place. [S1.SBM-3

14 e]

The transion also entails challenges associated with the potenal emergence of a skills gap,

should the workforce be insuciently prepared for the technological evoluon of port

operaons. This risk impacts producvity, safety, and long-term compeveness, and is

migated through the strengthening of internal training systems and the implementaon of

targeted upskilling and reskilling iniaves. [S1.SBM-3 14 e]

The Company implements a comprehensive framework of internal policies and regulaons,

which ensures the protecon of labour rights and guarantees that all employment pracces

are grounded in respect, fairness, and protecon against misconduct. This framework aims to

prevent any potenal labour rights violaons and to promote a safe and non-discriminatory

working environment. As part of the Company’s Human Rights Due Diligence, the Organisaon

assessed the potenal risk of forced or compulsory labour within its operaons and idened

no such risk, given that the Company operates exclusively in Greece and complies with the

applicable naonal and European regulatory frameworks for the protecon of employees'

rights. [S1.SBM-3 f (i)] The Company does not engage in any acvies that could pose a

signicant risk of human rights violaons, including forced or compulsory labour, and no such

incidents have been recorded within its operaons. Correspondingly, the risk assessment

idened no operaonal acvies or geographic locaons involving a signicant risk of forced

or compulsory labour. [S1.SBM-3 f (ii)]

The Company also assessed the potenal risk of child labour within the scope of its operaons.

The assessment idened no such risk, as the Company operates exclusively in Greece—a

jurisdicon with a stringent regulatory framework for employee protecon and the

enforcement of the minimum age for employment—and maintains no operaons in countries

or regions where child labour is prevalent. The Company implements a comprehensive internal

policy framework that safeguards human and labour rights and establishes clear protocols for

fair and safe working condions. In alignment with this framework, no incidents related to

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child labour or other material human rights violaons were recorded during the reporng

period. [S1.SBM-3 g (i)]

Consequently, no type of operaonal acvity or geographic region within the Company’s scope

has been idened as posing a signicant risk of child labour. [S1.SBM-3 g (ii)]

Within the framework of the Double Materiality Assessment, the Company examined how

dierent segments of its workforce may be exposed to risks or benet from emerging

opportunies. The analysis accounted for the specic nature of dues performed across the

port, recognising that employees in high-risk operaonal areas, such as the Container Terminal

and the Ship Repair Zone, are exposed to heightened occupaonal health and safety risks due

to their working environment. Concurrently, the assessment integrated characteriscs

protected under the Company’s Diversity, Equity, and Inclusion Policy, the Policy for the

Prevenon and Combang of Violence and Harassment at Work, the Internal Grievance

Mechanism for Incidents of Violence and Harassment, and the Code of Conduct. Indicavely,

factors such as gender, age, and disability were examined to guide the Organisaon in

idenfying vulnerable groups or cohorts requiring addional support or enhanced workplace

protecon measures. [S1.SBM-3 15]

The assessment also highlighted that certain material risks and opportunies pertain to

specic workforce segments. For instance, the potenal risk of a skills gap primarily aects

employees in technical and operaonal roles, who are more directly impacted by the

technological evoluon of port operaons; this is addressed through targeted training and

capacity-building programs. Similarly, the opportunity to aract and retain diverse talent is

supported by the Company’s Inclusion Policy, specically focusing on groups such as women

and employees with disabilies. Insights derived from ongoing social dialogue with employees

and labour unions enhance the Company’s understanding of these groups' needs and provide

aconable guidance for designing iniaves that ensure safe, equitable, and supporve

working condions for all. [S1.SBM-3 16]

S1.1 – Policies related to Own Workforce

ESG and Sustainability Policy

The ESG and Sustainability Policy sets the overarching framework that guides the Company

in operang responsibly, ethically and sustainably, acng as a reference point for

integrang environmental management, social responsibility and sound governance into its

business pracces.

Its stated purpose, as explicitly described in the Policy, is to ensure that the Company not

only complies with applicable legislaon but also takes steps to address stakeholder

expectaons, migate environmental and social risks, enhance social dialogue, promote

human rights and maintain ethical business conduct. Through this framework, the Company

aims to reinforce its long-term value, build a resilient business model and contribute

posively to society and the environment. [S1.MDR_P_65 a]

In relaon to the Company’s own workforce, the Policy underpins several material IROs

idened in the Double Materiality Assessment, including:

• Work-life Balance & Well-being

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• Equal Opportunies

• Employee Engagement & Social Dialogue

• Training and Skills Development for New Technologies

• Upskilling – Technological Capabilies of Workforce

• Employee Health & Safety Incidents

• Skill Gap and Technological Readiness [S1-1_17]

Within the framework of the Corporate Social Responsibility pillar, the Policy commits the

Company to creang an inclusive and diverse working environment that supports employee

development and promotes work-life balance. It also arms that the Company does not

tolerate any form of discriminaon, and that advancement is based solely on performance,

eciency, skills and qualicaons. These commitments form a high-level policy basis for

managing workforce-related Impacts, Risks & Opportunies, later operaonalised through

more specic internal policies. [S1-1_18]

The ESG & Sustainability Policy applies to all acvies of PPA S.A. and is to be followed by

all employees, contractors, partners and third pares collaborang with or operang on

behalf of the Company, with no excepons menoned. [S1.MDR_P_65 b], [S1-1_19]

The Policy also relates to the two workforce-related risks idened in the assessment. Its

aim is to maintain a safe, healthy and respecul work environment, and compliance with

ILO convenons on occupaonal health and safety, supporng the management of the

Employee Health & Safety Incidents risk. Its emphasis on connuous learning and employee

capability-building provides a policy foundaon for addressing the Skill Gap and

Technological Readiness risk linked to technological evoluon.

The ESG Commiee is responsible for the publicaon of the latest version of this Policy and

for ensuring its disseminaon to all employees. [S1.MDR_P_65 a] The Commiee is also

responsible for the supervision of the implementaon and the review of this Policy..

[S1.MDR_P_65 c]

The Policy is publicly available on the Company’s ocial website (hps://www.olp.gr/en/)

in both English and Greek, ensuring accessibility for all employees, partners and other

stakeholders. [S1.MDR_P_65 f]

The Policy undergoes reviews on an ad hoc basis as needed. Revisions are driven by legal

and regulatory changes, the idencaon of risks or adverse impacts, ATHEX ESG scoring,

opportunies for improvement, updates in the Company’s strategic direcon and broader

stakeholder awareness. This ongoing review process helps ensure alignment with evolving

sustainability and workforce priories. [S1.MDR_P_65 e]

The Policy explicitly states that the Company adheres to the UN Global Compact’s Ten

Principles and supports the UN Guiding Principles on Business and Human Rights. It also

conrms compliance with Internaonal Labour Organisaon (ILO) convenons, including

those on working condions, freedom of associaon and occupaonal health and safety.

[S1.MDR_P_65 d], [S1-1_20], [S1-1_20 a], [S1-1_21]

Through these commitments, the Policy sets out the Company’s human rights and labour

rights expectaons for its workforce, including respect for dignity, equal treatment, safe

working condions and eecve social dialogue. [S1-1_22]

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Code of Conduct

The Company’s Code of Conduct (hereinaer “the Code”) sets out the Company’s

fundamental principles, values and rules of professional behavior, ensuring that all

members of sta and the Board of Directors act with integrity, honesty and respect in full

alignment with applicable legislaon relang to human rights, labour, the environment

and an-corrupon. The Code serves as a reference framework that guides employees in

managing ethical dilemmas and in applying responsible business conduct across daily

operaons and interacons with colleagues, customers, suppliers and other stakeholders.

[S1.MDR_P_65 a], [S1-1_18]

The scope of the Code clearly covers the total number of employees, as well as all

members of the Board of Directors, both inside and outside Greece. It denes

expectaons for behavior, communicaon, condenality, fair treatment, equal

opportunies, and professional responsibility. These principles apply across all

organisaonal levels and business acvies. [S1.MDR_P_65 b], [S1-1_19]

Responsibility for applying and upholding the Code is shared across the Company.

Managers are required to set an example, ensure that their teams understand and comply

with the Code, foster transparency, and respond promptly when concerns are raised.

Employees are responsible for demonstrang moral values, reporng potenal violaons,

remaining up to date with ethical standards and performing their dues in accordance

with Company policies and the law. [S1.MDR_P_65 a], [S1.MDR_P_65 c]

The Code is approved and periodically updated by the BoD and is made publicly available

on the Company’s ocial website (hps://www.olp.gr/en/), ensuring full transparency,

accessibility and consistent communicaon to all employees and external stakeholders.

[S1.MDR_P_65 f]

The Code of Conduct contains explicit provisions relevant to workforce-related impacts

and opportunies idened in the Double Materiality Assessment, including:

• Equal Opportunies

• Diverse Workforce Aracon

• Interacon with employees & Social Dialogue

• Work-life Balance & Well-being [S1-1_17]

Equal Opportunies Policy (Arcle 14 of the Code)

Furthermore, the Code sets a clear commitment to equality, personal rights and diversity,

covering both visible characteriscs (age, sex, race, ethnicity, disability) and non-visible

ones (culture, religion, marital status, experience, opinion). The Company explicitly

prohibits any form of discriminaon, harassment or retaliaon, requiring full compliance

with legislaon on equal treatment in the workplace. [S1-1_20 a], [S1-1_24 a], [S1-1_24

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Forced and Child Labour (Arcle 15 of the Code)

The Code states that the Company does not use any form of forced labour and does not

employ individuals below the legal minimum age. Child labour is dened as employing any

person under the legal working age in Greece. [S1-1_22]

Violence and Harassment in the Workplace (Arcle 16 of the Code)

The Code denes violence and harassment as any act or threat that may cause physical,

psychological, sexual or economic harm or violate a person’s dignity.

All forms of violence and harassment are strictly prohibited.

The Code explicitly references the dedicated “Policy on prevenng and combang

violence and harassment at work & the management of internal complaints about

incidents of violence and harassment,” establishing a formal link to the Company’s

internal complaint mechanisms. [S1-1_20 a], [S1-1_24 a], [S1-1_24 d]

The Code requires sta to report violaons or concerns regarding ethical issues through

designated internal channels, including:

• the whistleblowing email address (whistleblowing@olp.gr)

• internal complaint boxes located in Company facilies

It states that all complaints are treated imparally, condenally and in accordance with

the Whistleblowing Policy and other compliance mechanisms. These provisions

contribute to the Company’s overall remediaon framework for addressing workplace

concerns. [S1-1_20 c]

Compliance with the Code is monitored through various mechanisms and policies,

including the Whistleblowing Policy, conict of interest procedures, the recruitment

process, and the Policy to Prevent and Combat Violence and Harassment. Reviews are

undertaken by the Regulatory Compliance Unit and/or the Internal Audit Department.

[S1.MDR_P_65 a], [S1-1_20 c]

Diversity, Equality, and Inclusion (DE&I) Policy

The Diversity, Equality & Inclusion (DEI) Policy sets out the Company’s commitment to

promong a respecul, fair and inclusive working environment, where every employee is

treated with dignity and without discriminaon. Diversity, as dened by the Policy,

encompasses visible characteriscs such as age, gender, race, naonality and physical

ability, as well as non-visible characteriscs such as culture, religion, marital status,

experience and opinion. The Policy arms zero tolerance for discriminaon, harassment

and retaliatory behavior, and emphasizes that dierences of opinion are valued as a

source of construcve dialogue and connuous improvement. [S1.MDR_P_65 a], [S1-

1_24 a], [S1-1_24 b]

The Policy applies to all individuals employed or engaged by the Company, irrespecve of

employment status, including dependent employees, independent service providers and

individuals working under salaried mandate arrangements. It covers all aspects of the

employment lifecycle; recruitment, compensaon, development, training, promoon and

career progression, without exclusions. [S1.MDR_P_65 b], [S1-1_19]

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The DEI Policy is adopted through a formal decision of the competent corporate body and

is publicly available on the Company’s ocial website (hps://www.olp.gr/en/),

ensuring visibility and accessibility for employees and external stakeholders.

[S1.MDR_P_65 f]

By requiring equal opportunies and fair treatment, the Policy supports the Company’s

workforce-related material impacts and opportunies and forms part of the foundaonal

policy framework for managing issues related to:

• Equal Opportunies

• Diverse Workforce Aracon

These commitments promote merit-based career development, ensuring that skills,

qualicaons and performance are the sole criteria for advancement. [S1-1_17], [S1-

1_18], [S1-1_24 b], [S1-1_24 c]

The Policy also sets clear expectaons for employee behavior: sta must behave with

respect and tolerance toward colleagues, parcipate in relevant training and report

incidents of discriminatory or inappropriate behavior. Any concerns can be raised through

the complaint procedure established in the Policy to Prevent and Combat Violence and

Harassment at Work and for the Management of Internal Complaints about Incidents of

Violence and Harassment, ensuring a structured, condenal and responsive mechanism

for addressing issues. [S1-1_24 d]

Furthermore, the Policy emphasizes the Company’s commitment to diversity and

inclusion at the highest levels of leadership. The selecon of Board members and senior

managers must reect diversity criteria, including gender, race, sexual orientaon,

religion, polical opinions, social origin, disability and age. This approach aligns leadership

appointments with principles of equal opportunity and contributes to the Company’s

ability to aract and retain diverse talent, a signicant impact according to the Double

Materiality Principle. [S1-1_24 c]

Overall, the DEI Policy reinforces the Organisaon’s broader human-rights commitments

by promong equality, prohibing discriminaon and embedding inclusion throughout

the Company’s operaons. It complements the Code of Conduct and the Policy to Prevent

and Combat Violence and Harassment at Work, forming an integrated framework that

supports employee dignity, well-being and a culture of respect.

Policy to Prevent and Combat Violence and Harassment at Work and for the

Management of Internal Complaints about Incidents of Violence and

Harassment

The Policy to Prevent and Combat Violence and Harassment at Work and for the

Management of Internal Complaints about Incidents of Violence and Harassment sets out

the Company’s commitment to ensuring a workplace where every person is treated with

dignity and respect. Its purpose is to prevent, address and eliminate behaviors that may

cause physical, psychological, sexual or economic harm, or that violate an individual’s

dignity, in full alignment with the denions and obligaons established by Greek Law

4808/2021. [S1.MDR_P_65 a], [S1-1_20 a]

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The Policy applies to all the Company’s employees, regardless of their employment

relaonship, and to any individual present in or connected to the work environment. It

covers conduct occurring at Company premises, during work-related travel or events, and

in any context linked to the employment relaonship, ensuring that protecon extends

across all workplace sengs. [S1.MDR_P_65 b] [S1-1_19]

Responsibility for implemenng the Policy lies with specically designated internal bodies.

The Violence and Harassment Incidents Reference Person (the Secretary of the

Disciplinary Board) acts as the rst point of contact for the receipt of internal complaints.

The Complaint Management Team, comprised of the Regulatory Compliance Manager,

the HR Manager and the Deputy HR Manager, examines and assesses complaints,

ensuring imparality, condenality and mely handling.

Depending on the severity of the incident, cases may be escalated to the Disciplinary

Board, which determines correcve or disciplinary acons.

The Policy is also made publicly available on the Company’s ocial website

(hps://www.olp.gr/en/) to ensure transparency and accessibility for employees and

external stakeholders. [S1.MDR_P_65 c], [S1.MDR_P_65 f]

In relaon to PPA’s own workforce, the Policy supports several material impacts idened

in the Double Materiality Assessment. By promong dignity, respect, non-retaliaon and

a safe working environment, it contributes directly to the Company’s commitments to

workforce well-being and construcve internal communicaon. [S1-1_18]

Specically, the Policy is linked to the following material impacts:

• Work-life Balance & Well-being

• Interacon with employees & Social Dialogue [S1-1_17]

A core feature of the Policy is its internal complaints mechanism, which provides

employees with secure and condenal channels for reporng incidents of violence or

harassment. Complaints may be submied in wring to the Reference Person, the HR

Department or through the communicaon channels specied in the Policy. The

procedure outlines the steps for receiving, assessing and addressing complaints, while

ensuring condenality and protecon for complainants throughout the process. This

framework strengthens the Company’s broader human-rights approach by oering

employees reliable avenues to seek support and remedy. [S1-1_20 c] [S1-1_24 d] [S1-

1_AR 17 g]

The Policy also claries the responsibilies of employees, who are expected to refrain

from behavior that may harm the dignity or safety of others and to report any incidents

they witness or experience. Awareness-raising and training iniaves, coordinated by the

Human Resources Directorate and other responsible funcons, help reinforce a shared

understanding of acceptable conduct, promote respect in the workplace and prevent

inappropriate behavior before it occurs. [S1.MDR_P_65 a] [S1-1_18]

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Health & Safety Regulaon of Container Terminal

The 'Occupaonal Health and Safety Regulaon for Pier I – Container Terminal' constutes

the Company’s ocial regulatory framework for managing health and safety issues within

the Pier I workspaces. Its purpose is the prevenon of occupaonal accidents and

diseases, the idencaon and assessment of occupaonal risks, and the implementaon

of appropriate measures to protect the life and health of employees. The core content of

the Regulaon includes the documentaon of the obligaons of the Company,

employees, and supervisors; the descripon of risk prevenon and control procedures;

and detailed instrucons for the use of Personal Protecve Equipment and the safe

execuon of stevedoring and technical operaons.

Compliance is monitored through audits, inspecons, sta training, and collaboraon

with the Safety Technician and the Occupaonal Physician, as provided for by the

Regulaon.

The Regulaon aims to manage material health and safety issues associated with

Container Terminal (CT) operaons, covering risks arising from the use of heavy

machinery, container handling, loading and unloading acvies, as well as technical

works. It outlines preventave measures, the obligaon to provide training and inducon,

and the mandatory compliance with safety protocols. [S1.MDR_P_65 a]

The scope of applicaon of the Regulaon extends to all acvies conducted at Pier I –

Container Terminal and covers the enrety of the workforce operang within the

facilies, including stevedores, equipment operators, and technical personnel. No explicit

exclusions are cited regarding acvies or geographic areas outside the Container

Terminal facilies. [S1.MDR_P_65 b]

The BoD holds ulmate responsibility for the approval and updang of the Regulaon,

which is formally signed by the Chairman of the Board. Concurrently, the responsibility

for implementaon lies with the relevant execuve management, department heads, and

site supervisors, who are mandated to ensure strict adherence to the prescribed

measures within the workplace. [S1.MDR_P_65 c]

The framework for the development and implementaon of the Regulaon provides for

employee informaon, training, and consultaon, with employees being required to

adhere to safety measures and report hazards or deciencies. Their parcipaon in the

prevenon process, alongside their cooperaon with the Safety Technician and the

Occupaonal Physician, reects the integraon of employees' needs and protecon into

the Company's safety culture. [S1.MDR_P_65 e]

The Regulaon is made available to employees through inducon and training sessions,

while the Company is mandated to provide the necessary instrucons and protecve

equipment. While there is no specic protocol for public disclosure to external

stakeholders, the implementaon of the Regulaon directly concerns all individuals

operang within the Container Terminal facilies. [S1.MDR_P_65 f]

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Personnel Training Policy

The Personnel Training Policy establishes the framework for the connuous development

of employees’ skills at the Company, ensuring that all training acvies support the

strategic needs of the Company and contribute to maintaining a high-performing and

compliant workforce. Its purpose is to dene the principles and procedures governing

employee training and to promote connuous learning as a core element of operaonal

excellence. [S1.MDR_P_65 a]

The Policy applies to all sta of the Company, including xed-term employees, providing

equal access to training and professional development opportunies across all employment

categories. [S1.MDR_P_65 b], [S1-1_19]

Responsibility for implemenng, coordinang and reviewing the Policy lies with the Human

Resources Department. Its dues include idenfying training needs, preparing the Annual

Training Plan, evaluang training proposals, coordinang approvals and overseeing

parcipaon and evaluaon procedures. The Policy is approved by Company management

and may be revised whenever necessary to reect operaonal requirements or changes in

legislaon. [S1.MDR_P_65 c]

The Policy sets out four core objecves, which reect the Company’s commitment to

workforce development:

• Skills Development: enhancing exisng skills and acquiring new ones.

• Performance & Producvity: improving work eciency through targeted

training.

• Compliance & Ethics: ensuring adherence to Company rules, internal

procedures and legal requirements

• Professional Development: supporng employees’ long-term career

growth

These objecves directly support several workforce-related material impacts, risks and

opportunies idened in the Double Materiality Assessment, including:

• Training & Skills Development for New Technologies

• Upskilling – Technological Capabilies of Workforce

• Equal Opportunies

• Interacon with employees & Social Dialogue

• Skill Gap & Technological Readiness [S1-1_17], [S1-1_18], [S1-1_AR17 h]

Training needs are idened through four structured processes:

• the Annual Training Plan, compiled based on needs submied by

Department Heads

• ad hoc needs, arising from new challenges or operaonal changes

• performance evaluaon results, which reveal skills gaps and areas for

improvement

• cercaon or qualicaon needs, in line with the Regulaon for the

Coverage of Cercaon and Educaonal Qualicaon Costs

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Once a training request is approved, the Human Resources Department evaluates training

programmes available, liaises with providers, and nalizes parcipaon arrangements.

Parcipaon in approved programs is mandatory, and cercates of aendance or

successful compleon are recorded in each employee’s personal le. [S1.MDR_P_65 a],

[S1-1_AR17 f]

The Policy is supplemented by the Regulaons Governing the Reimbursement of Expenses

for Cercaons and the Acquision of Educaonal Qualicaons for Company

Employees, which provides fair and transparent procedures for nancial support to

employees seeking job-related cercaons or degrees. This Regulaon supports equal

access to development opportunies and strengthens the Company’s framework for

connuous learning.

Training eecveness is monitored through structured tools. Parcipants complete the

Training Program Assessment Form, evaluang content relevance, usefulness and overall

sasfacon. Departments complete the Training Program Eecveness Assessment, which

assesses whether newly acquired skills are being applied, contribung to improved

performance, problem-solving and employee engagement. These tools provide a

systemac mechanism for monitoring outcomes and implemenng improvements in the

training process. [S1.MDR_P_65 a], [S1-1_AR17 f]

Whistleblowing Policy

The Whistleblowing Policy establishes the framework through which the Company enables

employees and other individuals working under its supervision to report concerns or

suspected violaons safely, condenally and without fear of retaliaon. Its purpose is to

promote integrity, ethical behavior and compliance across the Organisaon by providing

structured and secure reporng channels, in line with the requirements of Direcve (EU)

2019/1937 and Greek Law 4990/2022. [S1.MDR_P_65 a]

The Policy applies to all employees, members of the BoD and Top Management, as well as

to external collaborators, contractors, suppliers, customers, users and any third pares who

work with or provide services to the Company. This broad scope ensures that anyone who

becomes aware of misconduct or potenal violaons is able to report them. [S1.MDR_P_65

b] [S1-1_19]

Reports may concern breaches of EU or naonal legislaon, violaons of Company policies

or procedures, issues related to corrupon, bribery, fraud, conicts of interest, nancial

irregularies, data protecon breaches, or/and other forms of unethical or improper

conduct. The Policy describes the available communicaon channels, which include:

• a dedicated email address (whistleblowing@olp.gr)

• postal submissions addressed to the Whistleblowing responsible and

marked “Condenal”

• physical report boxes located at designated points across PPA S.A. facilies

All channels guarantee condenality, secure handling of informaon and the protecon

of the whistleblower’s identy. Retaliaon against any person who reports a concern in

good faith is strictly prohibited under the Policy and in accordance with Arcle 17 of Law

4990/2022. [S1-1_20 b]

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Responsibility for receiving and monitoring internal reports lies with the Whistleblowing

responsible, who is the Manager of the Risk Management Unit. The Whistleblowing

responsible registers incoming reports, ensures condenality and independence, and

forwards cases requiring invesgaon to the Reports Management Commiee

(Whistleblowing Commiee).

This three-member Commiee, comprised of the Managers of the Regulatory Compliance

Unit and the Human Resources Department, and the Deputy Manager of the Legal

Department, with the support of the DPO, conducts invesgaons following a structured

and imparal procedure. At its discreon, the Commiee may request addional

informaon, invite the whistleblower or the reported party to interviews, consult relevant

Departments and issue a nal invesgaon Report. [S1.MDR_P_65 c] [S1-1_18] [S1-1_AR

17 g]

The Policy is communicated internally to employees, execuves and external collaborators

through email, the Company portal and other internal channels. It is also publicly available

on the Company’s website (hps://www.olp.gr/en/), ensuring transparency and

accessibility for all stakeholders. [S1.MDR_P_65 f]

In relaon to the Company’s own workforce, the Policy supports several material impacts

idened in the Double Materiality Assessment. By providing safe and trusted channels for

raising concerns, it promotes fairness, well-being and open communicaon in the working

environment.

Specically, it contributes to:

• Work-life Balance & Well-being

• Interacon with employees and Social Dialogue

• Equal Opportunies [S1-1_17]

The Policy also sets out a clear procedure for the management of reports and complaints.

This includes melines for acknowledging reports, safeguarding condenality, establishing

imparal assessment of facts, preserving evidence, and informing whistleblowers of the

outcome, in line with the requirements of Law 4990/2022. These elements ensure that

employees have reliable and eecve avenues to seek remedy when observing or

experiencing misconduct, reinforcing the Company’s broader commitment to responsible

conduct and the protecon of human and labour rights. [S1-1_20 a], [S1-1_20 c]

Sta Promoon Policy

The Sta Promoon Regulaon governs the framework through which the Company

ensures that posions of responsibility are lled by competent personnel and that

employees who demonstrate high performance, skills and professional behavior are

recognised and advanced within the Company. [S1.MDR_P_65 a]

Its stated purpose is to promote a culture of meritocracy, movaon and connuous

development, ensuring that professional progression aligns with organisaonal needs and

supports long-term workforce stability and engagement.

The Regulaon applies to all the Company’s sta employed under an open-ended

employment relaonship, excluding only top management execuves who fall under

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separate governance frameworks. All eligible employees are provided with equal

opportunies for professional development and advancement. [S1.MDR_P_65 b], [S1-

1_19]

Responsibility for implemenng the Regulaon lies primarily with the Human Resources

Department, in collaboraon with Department Heads, Deputy CEOs and ulmately the CEO,

who provides nal approval for senior-level promoons. This governance structure ensures

that decisions are properly reviewed, documented and aligned with organisaonal needs.

[S1.MDR_P_65 c]

Promoonal decisions are based on clear, predened criteria, including length of service,

performance assessments, skills and competencies required for the target posion and

demonstraon of values consistent with the Company’s culture. These criteria ensure that

qualicaons, skills and experience serve as the basis for advancement, in line with the

expectaons of internaonally recognised good pracces for equal treatment. . [S1-1_AR

17 a]

Responsibilies for the promoon process are assigned to management-level roles,

supporng accountability and consistency across departments. [S1-1_AR 17 b]

The Regulaon supports several workforce-related IROs by strengthening the Company’s

merit-based career development framework:

• Equal Opportunies

• Interacon with employees and Social Dialogue

• Diverse Workforce Aracon

• Upskilling - Technological Capabilies of Workforce [S1-1_17], [S1-1_18]

The Regulaon also includes structured procedures for announcing vacancies, subming

candidacies, conducng interviews and issuing approvals, with HR maintaining the

corresponding documentaon and records. This supports transparency and provides a clear

view of employee progression within the Company. [S1-1_AR 17 f]

Moreover, newly promoted employees receive the necessary inducon and role-specic

training to support a smooth transion into their new responsibilies, thereby promong

access to skills development and long-term employability. [S1-1_AR 17 h]

In addion to the above policies, the following are of signicant importance for managing

maers related to the Company’s workforce:

• the Operang Regulaon (further informaon is provided in Chapter G1- 1 Business

Conduct)

• the Recruitment Process, the Regulaon for the granng of short-term leaves to the

employees of the Company due to extraordinary circumstances or special needs

beyond the provisions of the General Sta Regulaon

• the Terms and Condions for the granng of interest-free personal loans to the

Company personnel

• the Procedure for Internal Transfers of the Company personnel,

• the Age-Compleon Compulsory Rerement Regulaon for the Company personnel

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S1.2 – Processes for engaging with own workforce and workers’

representatives

The Company places strong value on maintaining an open and construcve relaonship with

its people. Interacon with employees and social dialogue form an essenal part of how the

Company understands and manages its impact on its workforce and reects the importance

of Employee Engagement and Social Dialogue as a material impact area. Employees are

represented by organised bodies that parcipate in discussions on workplace pracces and

employment condions, ensuring that their views are heard and considered

. [S1-2_27 a]

Engagement takes place through several processes across the year. Under the Personnel

Training Policy, Department Heads idenfy training needs as part of the Annual Training Plan

and through ad-hoc requests arising from the operaonal requirements. Employees then

provide structured feedback through Evaluaon Forms aer each training program, enabling

them to express views on content, relevance and areas for improvement. At the same me,

employees and their representaves contribute to the Double Materiality Assessment,

providing informaon on topics such as working condions, equal opportunies and skills

development. These pracces support connuous dialogue and help strengthen acve

parcipaon across the workforce. [S1-2_27 b]

The eecveness of engagement is supported by structured procedures. The Whistleblowing

Policy outlines the steps for acknowledging reports, reviewing concerns, following up and

providing feedback where appropriate. The Policy to Prevent and Combat Violence and

Harassment at Work and for the Management of Internal Complaints about Incidents of

Violence and Harassment sets out a clear process for subming, examining and resolving

internal complaints, ensuring condenality and support for aected individuals. Training

processes include evaluaon forms and eecveness assessments, enabling the Company to

monitor whether programs meet employees’ needs and to adjust future acons accordingly.

[S1-2_27 e]

When idenfying and assessing material impacts, risks and opportunies, the Company

considers the perspecves of employees who may be more exposed to impacts. The Double

Materiality Assessment examined the condions of employees working in high-risk

operaonal areas, such as the Container Terminal and the Ship Repair Zone, and also

considered characteriscs including gender, age, disability and mulcultural background. This

approach supports the Company’s ability to understand diverse workforce perspecves and

ensures that engagement pracces remain inclusive, informing material areas such as

Employee Engagement & Social Dialogue, Equal Opportunies and Training and Skills

Development. In 2025, as part of the reassessment of the Company’s material maers, a

For more information on channels of communication with employees, please refer to the Stakeholder

Engagement Table on page 311

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materiality quesonnaire was distributed to employees to solicit their perspecves for the

priorisaon process of material topics related to the workforce. [S1-2_28]

S1.3 – Processes to remediate negative impacts and channels

for own workforce to raise concerns

During the reporng period, the Company idened one actual and potenal negave impact

regarding occupaonal health and safety, which is inherently linked to the nature of port

operaons. Although the Company maintains overall low incident rates, the possibility of

isolated occurrences is recognised. To this end, the Company priorizes the strengthening of

a prevenon culture, while implemenng structured procedures and ensuring full compliance

with the prevailing naonal and European regulatory frameworks. This approach aims for the

connuous improvement of working condions and the eecve management of any

potenal impacts.

In accordance with applicable Greek and EU health and safety legislaon, the relevant

Internaonal Labour Organisaon (ILO) convenons, and internal regulaons, the Company

implements a structured remediaon process for every work-related incident or idened

hazardous situaon. When an incident impacts an employee's health or safety, immediate

remediaon measures include the provision of rst aid or medical treatment, facilitated access

to external healthcare providers, and coverage via the Company’s private health insurance, as

well as the adjustment of working condions where necessary. In the long term, remediaon

may involve temporary or permanent modicaon of dues, ergonomic improvements,

engineering controls, or addional training and supervision. These measures both aim to

restore, to the extent possible, the well-being of the aected employee and to prevent the

recurrence of similar incidents.

The Company conducts occupaonal health and safety risk assessments for all core acvies

and workspaces; these are reviewed whenever signicant changes occur to proacvely

idenfy and control hazards, and to provide data for both preventave and correcve

measures. [S1-3_32 a]

All incidents are recorded and systemacally invesgated by the relevant internal bodies (such

as the Safety Department, the Human Resources Department, and Department Heads), with

the parcipaon, where applicable, of employee representaves through the Health and

Safety Commiee. Accidents are reported on the SEPENET electronic plaorm. The accident

invesgaon procedure is dened by the relevant internal procedure SOP-28-01. Findings from

these invesgaons are ulised to update and revise procedures and to enhance technical and

organisaonal controls, thereby strengthening the overall health and safety management

system.

The Company maintains formal grievance mechanisms through:

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• the Whistleblowing Policy, covering violaons of EU and naonal legislaon, internal

regulaons, ethics breaches, data protecon, conicts of interest, environmental concerns,

and other misconduct; and

• the Violence & Harassment Policy, covering incidents of discriminaon, violence, harassment

(including gender-based harassment) and domesc violence aecng employees in the

workplace context.

Both mechanisms are fully compliant with relevant Greek legislaon (Law 4990/2022 and Law

4808/2021) and provide clear, secure pathways through which employees can seek remedy.

[S1-3_32 c]

The Company provides mulple dedicated channels that allow employees to raise concerns

safely, condenally and, when preferred, anonymously. These include:

Whistleblowing channels:

• A dedicated email: whistleblowing@olp.gr

• Postal submissions marked “Condenal”

• Physical report boxes at:

o Internal Audit Department (Company HQ)

o Container Terminal Building

o Car Terminal Building

• Direct submission to the Whistleblowing responsible

Channels for violence and harassment complaints:

• Email to odk@olp.gr

• Submission by post to the “HR Department, Reference Person”

• Direct communicaon with the Violence & Harassment Incidents Reference Person

• Access to the Complaint Management Team for guidance and support

The Company therefore maintains two fully independent and complementary grievance

structures; each tailored to specic categories of incidents but fully aligned in terms of

procedural safeguards. [S1-3_32 b]

The Company acvely supports awareness and availability of these mechanisms through:

• posng the policies on the Company’s website: olp.gr - POLICIES

• internal communicaon via email and bullens

• direct guidance from HR and the Reference Person

• training and awareness-raising acons coordinated with the HR Department

• open door culture

The Company also ensures that employees can submit reports without fear, and that they are

informed about the process, their rights, and the protecon measures available.

The Company maintains an open and regular social dialogue with trade unions and elected

employee representaves, who play a material role as feedback and escalaon channels on

health and safety, working condions and broader employment issues. Through regular

meengs, joint commiees and consultaon processes, union representaves are able to

convey employees’ concerns regarding occupaonal risks, incidents, near-misses or perceived

deciencies in prevenve and remedial measures. They parcipate, where appropriate, in

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discussions on incident invesgaons and necessary correcve acons, contribute to the

review of health and safety risk assessments, and monitor the implementaon of agreed

improvements.

This connuous interacon ensures that remediaon processes are not only compliant with

legislaon and internal procedures, but also informed by the praccal experience and

expectaons of the workforce, reinforcing trust in the eecveness and fairness of the

Company’s mechanisms. [S1-3_32 d]

The Management Commiee keeps complete records of all reports, invesgaons and acons

taken, and provides quarterly updates to Top Management, including the CEO, Deputy CEOs

and the Audit Commiee. The Violence & Harassment Policy similarly requires the Complaint

Management Team to invesgate, document and communicate outcomes within dened

deadlines, ensuring transparency and accountability. Regular monitoring allows the Company

to evaluate systemic issues, idenfy recurring paerns and implement targeted

improvements. [S1-3_32 e]

Furthermore, the Company’s policies explicitly prohibit any form of retaliaon against

individuals who report concerns in good faith. Condenality of both whistleblowers and

reported people is strictly safeguarded, and employees are informed of their rights through

internal communicaons and accessible policy documents. The Violence & Harassment Policy

further ensures that complainants receive support, can access administrave or judicial

authories, and may request protecve work arrangements when needed. These provisions

contribute to employee trust in the integrity and safety of the mechanisms. [S1-3_33]

S1.4 – Taking action on material impacts on own workforce, and

approaches to managing material risks and pursuing material

opportunities related to own workforce, and effectiveness of

those actions

Occupational Health and Safety

The Company operates within a complex port environment, where employees may be exposed

to risks associated with vessels movements, heavy machinery, and demanding operaonal

procedures. Given the nature of these acvies, the Company has developed a structured

occupaonal health and safety framework, focused on prevenon, risk control, and the

connuous improvement of working condions, aiming to migate incident rates and foster a

robust safety culture across its port facilies.

A core component of this framework is the Occupational Risk Assessment Study, which covers

all job positions and is regularly updated to reflect changes in operations and working

condions. Through this process, risks are systemacally idened and assessed, and

appropriate prevenve measures are determined to limit potenal adverse eects on the

workforce.

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The Company implements structured procedures and internal regulaons governing port

operaons that facilitate the management of occupaonal risks. At the same me, Standard

Operang Procedures (SOPs) and prevenve controls are implemented, while emergency

response plans are maintained for incidents such as re, earthquakes, natural disasters, or

hazardous spills. These plans are validated through scheduled readiness drills, enhancing

operaonal resilience and migang potenal impacts on the health and safety of the

workfoce.

Employee parcipaon is a key element of the Company's approach. The Health and Safety

Commiee, which consists of employee and management representaves, meets regularly to

review working condions, monitor compliance with safety measures, and make proposals for

improvement. Furthermore, the Company is noed upon the introducon of new

equipment, materials, or installaons that may impact safety, facilitang the mely integraon

of prevenve measures into operaonal planning.

Employees also participate in safety training and awareness initiatives, while role-specific

safety instructions and targeted actions reinforce a culture of prevention and vigilance in the

workplace. In the event of an incident, the Company follows a structured investigation process

to identify root causes and determine corrective and preventive actions. Where employees

are affected by health and safety incidents, the Company ensures the provision of appropriate

support and the remediation of working conditions, while corrective measures are

implemented to prevent recurrence. The conclusions are incorporated into updated

procedures or operational adjustments, ensuring the continuous improvement of safety

practices. [S1-4_38 a], [S1-4_38 b]

At the same me, employee representaves acvely parcipate through the Health and Safety

Commiee, helping to idenfy and assess negave impacts and plan prevenve acons. The

eecveness of the measures is monitored through health and safety indicators and internal

audits, the results of which are used for the evaluaon of the acons' eecveness and the

connuous improvement of the procedures. The monitoring mechanisms include, among

others:

• monitoring work-related incidents and health and safety issues,

• conducng regular inspecons of workplaces,

• assessing the adequacy and use of Personal Protecve Equipment (PPE),

Health and Safety Framework

Standard

Operating

Procedures

(SOPs)

Checklists

Emergency

Plans

Page 274 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

• the operaonal readiness of support infrastructure (e.g., 24/7 ambulances) [S1-4_38

The Company has adequate human, organisaonal, material, and nancial resources to

manage and migate the material impacts related to its workforce, with a parcular focus on

occupaonal health and safety. At an organisaonal level, the Human Resources Department

supports the implementaon of relevant policies, while Health and Safety ocers acvely

contribute to the prevenon of occupaonal risks and the monitoring of relevant procedures.

At an operaonal level, the Company systemacally invests in means of prevenon and

response to incidents, providing appropriate Personal Protecve Equipment (PPE) to sta,

depending on the nature of the work. At the same me, two ambulances with trained

personnel are on standby 24 hours per day (24/7) to respond immediately to emergencies,

while debrillators have been installed and are operaonal in crical work areas. In addion,

a budget is available for health and safety acons, sta training, and equipment for the

prevenon and management of emergencies. [S1-4_43]

Finally, one of the Company’s fundamental principles is to give priority to the protecon of the

health, safety and rights of employees over operaonal or nancial pressures. In cases of

conict between operaonal objecves and the need for the prevenon of adverse eects on

the workforce, the Company priorises the protecon of employees and takes the necessary

adjustment measures, such as redistribung tasks or adjusng schedules. [S1-4_41]

Employee Health & Safety Incidents

Employee health and safety issues are linked to operaonal risks for the Company, given that

port acvies involve vessel movements, the use of heavy equipment, and complex

operaonal procedures. Potenal work-related injuries or occupaonal health issues may

adversely aect employee well-being and business connuity, while also carrying the potenal

for legal liabilies or reputaonal damage.

The Company implements a structured set of procedures and Standard Operang Procedures

(SOPs) governing port acvies in order to manage and migate the relevant risks. These

procedures incorporate prevenve controls into daily operaons and are supported by training

and awareness-raising acvies, as well as safety guidelines for each job role. Incidents are

recorded, monitored, and analysed systemacally in order to idenfy root causes and

implement correcve and prevenve measures. The ndings are communicated to the

relevant departments, reinforcing the prevenon and safety culture. [S1-4_40 a]

In the context of strengthening prevenon and early warning, the Company is in the process

of developing an ISO 45001-cered Health & Safety Management System, planned for full

implementaon by 2027, which will provide a more comprehensive and standardised

framework for managing occupaonal risks. In parallel, the installaon of weather staons by

2026 for the monitoring of real-me meteorological condions and for the issuing of alerts on

wind or weather phenomena that could aect workforce safety. These iniaves are expected

to further enhance resilience and reduce both the likelihood and severity of incidents.

Page 275 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Governance and oversight mechanisms also support the management of this risk. The Health

& Safety Commiee, comprising employee representaves and management, meets regularly

to examine working condions, discuss incidents and propose improvements. At a strategic

level, the ESG & Sustainability Policy includes commitments to safe and healthy working

condions and alignment with internaonal standards. Management bodies review key

performance indicators and signicant incidents as part of the broader risk-management

framework, ensuring appropriate supervision and connuous improvement. [S1-4_40 a]

Health and Safety Indicators

KPIs

2024

2025

Percentage of

people in its own

workforce who are

covered by PPA’s

health and safety

management

system based on

legal requirements

and/or recognised

standards or

guidelines [S1-

14_88 a]

The Company is in the process of

developing a Health and Safety

Management System in accordance

with ISO 45001. In the reporng

period, the system has not yet

been cered, and therefore, no

coverage rate of the workforce

based on a cered framework is

available. At the same me,

organised health and safety

procedures are implemented in

accordance with the applicable

legal requirements.

The Company is in the process of

developing a Health and Safety

Management System in accordance

with ISO 45001. In the reporng

period, the system has not yet been

cered, and therefore no coverage

rate of the workforce based on a

cered framework is available. At

the same me, organised health and

safety procedures are implemented

in accordance with the applicable

legal requirements.

The number of

fatalies in own

workforce as result

of work-related

injuries and work-

related ill health

[S1-14_88 b]

The number of

recordable work-

related accidents

[S1-14_88 c]

Recorded work-

related accidents

indicator

[S1-

14_88 c]

7.19

6.95

The number of

cases of recordable

work-related ill

health of

employees [S1-

14_88 d]

The number of days

lost to work-related

injuries and

fatalies from

work-related

accidents, work-

related ill health

and fatalies from

ill health related to

employees [S1-

14_88 e]

454

784

The workplace accident indicator is calculated by dividing the number of recorded incidents by the total

number of hours worked by the Company’s staff and multiplying the result by 1,000,000.

Page 276 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Work-life balance and Well-being.

Work-life Balance and well-being have been idened as a material actual posive impact for

the Company’s own workforce. The Company provides safe and fair working condions

through a structured internal framework of corporate regulaons and collecve agreements,

which dene clear rules on career development, working condions and employee

parcipaon. This framework contributes to a transparent working environment where

employees feel secure and valued while the Company conrms that all its employees are paid

an adequate wage, in accordance with the applicable legislave and regulatory frameworks

and the relevant benchmarks, as dened by naonal legislaon and collecve labor

agreements. [S1-10_69]

Within this framework, the Sta Promoon Regulaon sets out transparent criteria for

promoons and internal moves and claries rights and obligaons relang to working me,

remuneraon and parcipaon in decision-making. The ESG & Sustainability Policy

complements the Regulaon, the Code of Conduct, the Diversity, Equality & Inclusion Policy

and the Policy to Prevent and Combat Violence and Harassment at Work, which together

promote respect, non-discriminaon, equal opportunies and protecon from inappropriate

behavior, thereby supporng employees’ physical and mental well-being.

The Company maintains open communicaon channels with trade unions and employee

representaves, including regular consultaon on maers related to working condions, well-

being and work-life balance. Social dialogue, parcipaon of workers’ representaves in

health and safety maers and structured feedback mechanisms through training, complaints

and engagement processes strengthen trust, transparency and mutual understanding

between management and sta. [S1-4_38 c], [S1-4_39]

In addion, the Company oers a range of health-related employee benets that directly

support employees’ well-being and their ability to balance professional and personal

responsibilies. These include discounted health diagnosc packages for employees and their

immediate family (screening and consultaon with experts), a Life and Health Insurance

Program covering hospital and out-of-hospital care, accidents and pharmaceucal expenses,

as well as access to interest-free health-related loans. Together with access to prevenve

medical services and family-oriented leave provisions, these benets enhance employees’

sense of security and help them manage unexpected health-related costs. [S1-4_38 c]

The eecveness of the Company’s acons on work-life balance and well-being is reected in

the outcomes of the Company’s Double Materiality Assessment and in workforce indicators.

The Company maintains a highly stable workforce with strong employee engagement and trust

in management, consistently recording low levels of absenteeism and work-related incidents

relave to the nature of port acvies. [S1-4_38 d]

Page 277 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Key Performance Indicator (KPI)

2025

Women

Men

Total

Percentage of employees entitled to take

family-related leave [S1-15_93 a], [S1-15_94]

100%

Percentage of employees entitled that took

maternity leave

2.5%

0.4%

Percentage of employees entitled that took

paternity leave

1.5%

1.3%

Number of entitled employees that took

family-related leave [S1-15_93 b]

157

Percentage of eligible employees who took

family-related leave

41,3%

10.1%

14.8%

Percentage of employees that are entitled to

and make use of carers’ leave from work [S1-

15_93 b]

8.4%

34.4%%

12.9%

Percentage of employees that are entitled to

and took parental leave

4.4%

0.2%

0.85%

Employee Engagement and Social Dialogue

The Company maintains a long-standing tradion of structured social dialogue and

construcve engagement with its workforce. This has resulted in a posive material impact on

labour relaons, organisaonal stability and employee trust. As one of the largest port

organisaons in Greece, the Company operates in a labour-intensive environment where

collaboraon between management and employee representaves is essenal for ensuring

operaonal connuity and a stable working climate. The percentage of employees that are

covered by collecve bargaining agreements is 100%, while all the employees (100%) are

covered by social protecon. [S1-8_60 a], [S1-4_38 c]

Furthermore, all employees are covered by social protecon schemes, either through the

naonal public social security system or through supplementary benets provided by the

Company, against loss of income resulng from major life events. Specically, employees are

covered in relaon to:

• sickness [S1-11_74 a]

• unemployment [S1-11_74 b]

• occupaonal accident and acquired disability [S1-11_74 c]

• parental leave [S1-11_74 d]

• rerement [S1-11_74 e]

in accordance with applicable Greek legislaon and the Company’s addional benets

framework.

Furthermore, all the PPA S.A. employees receive adequate remuneraon in accordance with

the applicable legislave and regulatory frameworks and benchmarks, as dened by naonal

legislaon and collecve labour agreements [S1-10_69]

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Regular interacon between management and employees, including formal meengs with

unions, day-to-day exchanges and ongoing consultaon on employment maers, supports an

environment in which employees feel encouraged to express their views, raise concerns and

contribute to discussions that inuence decision-making. This connuous engagement allows

workplace issues to be idened and addressed early, helping prevent escalaon and

reinforcing transparency and mutual understanding.

Employee unions play a central role in this posive impact. PPA S.A.’s employees parcipate

acvely through four primary unions (Permanent Employees, Technicians & Operators Union,

Dockworkers Union and the Associaon of Supervisors-Foremen) and one secondary union

(Federaon of Employees of Greek Ports). Union parcipaon covers nearly the enre

workforce. In 2025, 1031 employees were union members, including 884 men and 147

women. This high level of representaon contributes to structured communicaon, promotes

trust and strengthens collecve representaon. The Company maintains regular

communicaon with union representaves on key topics such as working condions, health

and safety, training, stang needs and organisaonal changes, helping maintain predictable

labour relaons and reducing the risk of conict or operaonal disrupon. Furthermore, the

Company's unions are acvely involved in European representave bodies. Specically, there

is representaon on the European Dockworkers Council (EDC), which strengthens the

internaonal dimension of trade union acon and the connecon with European ports. The

Permanent Employees Union and the Technicians and Operators Union parcipate in the EDC

through the Federaon of Greek Port Employees (OMYLE), while the Dockworkers Union is

also a member of the EDC. This parcipaon strengthens the instuonal representaon of

workers at European level, facilitates the exchange of know-how and good pracces, and

contributes to the formaon of common posions on issues relang to labour relaons and

employment condions in the port sector. [S1-8 63 b]

In addion to union engagement, the Company facilitates open communicaon through

various channels that allow employees to express their views, seek informaon and provide

feedback. These include:

• internal announcements

• email communicaon

• the Oce Automaon (OA) system for processing requests

• direct dialogue with management under the Company’s open-door approach

Feedback is also collected through structured mechanisms such as targeted compliance

surveys, OA plaorm assessments and exit interviews. These tools help the Company monitor

employee senment, idenfy areas for improvement and evaluate the eecveness of its

engagement acons. [S1-2_27 a], [S1-2_27 b], [S1-2_27 c], [S1-2_27 e]

Page 279 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

As a result of these engagement mechanisms, employees experience a stronger sense of

representaon and greater condence in inuencing maers that aect their work

environment. At the same me, the Organisaon benets from smoother day-to-day

operaons, reduced labour-related risks and a more cohesive organisaonal culture. Social

dialogue contributes to workforce stability, supports retenon and reinforces long-term

organisaonal performance.

Equal Opportunities

PPA S.A. fosters an inclusive, fair and non-discriminatory working environment, generang an

actual posive social impact on its workforce. The Company implements structured Diversity,

Equity and Inclusion (DEI) pracces that promote equal treatment in employment,

recruitment, training and professional development.

The Company’s commitment to equal opportunies is embedded in its DEI Policies, the Code

of Conduct and all HR procedures, ensuring transparent and objecve decision-making across

the employee lifecycle The Company has an approved Diversity, Equality & Inclusion (DEI)

Policy covering all employees, regardless of employment status or naonality. In addion,

diversity criteria for members of the Board of Directors are further specied in the Company’s

separate Diversity Policy for BoD Members.

The Company already meets the 33% gender representaon requirement for Boards under

Naonal Law 5178/2025, achieving compliance ahead of the 2026 legal deadline. This

demonstrates PPA S.A.’s early integraon of EU DEI principles and its strong governance on

diversity.

Distribuon in Number and Percentage at Top Management level by Gender

[S1-9_66 a]

KPI

2024

Number

Percentage

Male

Female

Male

Female

Senior Management

83.33

16.67

Remuneraon pracces follow the principle of equal pay for equal work, without

dierenaon based on gender or naonality, supporng workplace equity and fairness.

Inclusive recruitment and transparent promoon criteria further reinforce the Company’s

posion among Greece’s leading port organisaons in applying DEI standards.

Distribuon in Number and Percentage at Top Management level by Gender

[S1-

9_66 a]

KPI

2025

Number

Percentage

Male

Female

Male

Female

Senior Management

87.50%

12.50%

Page 280 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Company monitors and evaluates the implementaon and eecveness of relevant

acons and iniaves through specic mechanisms and procedures.

In parcular:

• Compliance with regulaons and policies is monitored by relevant organisaonal

units, in addion to the Human Resources Department, such as the Regulatory

Compliance, Risk Management, and Internal Audit, which contribute to ensuring

compliance and evaluang the eecve implementaon of relevant procedures.

• The Company maintains reporng channels through which reports or complaints

regarding unequal treatment or policy violaons can be submied. To date, no cases

of unequal treatment have been recorded.

• The Company's operaons are aligned with the country's current instuonal

framework, such as Law 5178/2025 on gender balance on the BoD, which also serves

as a basis for monitoring the implementaon of equality principles.

• The presence and operaon of employee unions for various sta categories serves as

an addional communicaon channel and mechanism for raising issues related to

human resources.

Through the above mechanisms, the Company systemacally monitors the implementaon of

relevant policies and evaluates the eecveness of acons and iniaves aimed at ensuring

equal treatment and equal opportunies for its workforce.

These pracces create a workplace where equal treatment is embedded in daily operaons,

supporng Equal Opportunies on the Company’s material IRO and contribung to a fair and

inclusive working environment. [S1-1_18], [S1-4_38 c], [S1-4_38 d]

In 2025, PPA SA employed 11 people (1.03% of the total number of employees) with

disabilies, of whom 5 (0.55% of the total number of employees) are men and 6 (3.75% of

the total number of employees) are women, promong inclusion and providing access to

jobs for underrepresented groups. [S1-12_79, S1-12_80]

The disclosure of informaon relang to persons with disabilies is carried out in accordance

with the applicable naonal legal and regulatory framework. The data is sourced from

internal human resources records and is based on available and legally processable

informaon. Given that the Company operates exclusively in Greece, there are no

implicaons arising from dierences in the legal denions of persons with disabilies

between dierent countries. [S1-12_AR76]

Distribuon of employees by gender and age [S1-9_66 b]

KPI

2024

2025

Male

Female

Total

Male

Female

Total

<30

30-50

347

422

380

454

51+

464

532

443

511

Page 281 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

It should be noted that for the current reporting year, the staff classification has been revised into three groups

(Senior Management, Department Heads, Employees), compared to the previous year, when staff were presented

as Senior Management, Supervisors, Office Employees, Technical Staff, Dockworkers, and Foremen. Under the new

scheme, Senior Management corresponds to the same category, Supervisors are included in the Department Heads

category, and all other categories fall under Employees.

The gender pay gap is calculated as the difference between the average gross hourly earnings of men and

women, divided by the average gross hourly earnings of men and expressed as a percentage. The result is −5.06%,

which indicates that women have an average higher gross hourly earnings than men.

The ratio of the highest-paid individual's total annual compensation is calculated by dividing their total annual

compensation by the median total annual compensation of employees, excluding the highest-paid individual. [S1-

16_97 c]

Distribuon of employees by gender and leven of hierarchy [ S1-9 _66 a]

KPI

2024

Number

Percentage

Male

Female

Male

Female

Senior

management

83%

17%

Department

managers

63%

37%

Employees

826

127

87%

13%

Employees by gender and contract type

[S1-6_52 a], [S1-6_52 b]

2024

2025

KPI

Male

Female

Total

Male

Female

Total

Number of

Employees

872

152

1,024

898

160

1058

Number of

Permanent

Employees

865

150

1,015

853

147

1000

Fixed Term

Employees

Number of

employees with

non-guaranteed

working hours

Full Time Employee

872

152

1,024

898

160

1,058

Part Time

Employees

Distribuon of employees by gender and hierarchical level

KPI

2024

Number

Percentage

Male

Female

Male

Female

Directors

88%

12%

Managers (Senior

Sta)

62%

38%

Oce Employees

858

139

86%

14%

Remuneraon metrics

Gender Pay Gap [S1-16_97 a]

-5.06%

Pay rao between the highest-paid individual and the median employee

remuneraon [S1-16_97 b]

7.8

Page 282 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

During the reporng period, there were no complaints, incidents or grievances related to

social issues or human rights violaons and consequently no nes, penales or compensaon

for damages were imposed in relaon to the above. All data regarding employee relaons have

been collected in accordance with the usual internal reporng pracces, without any special

incidents having occurred. Regarding the 4 complaints, all of the submissions received

concerned the General Sta Regulaons as well as the General Conduct among employees.

For these complaints, the prescribed internal procedure was followed with the closure of the

complaints in their enrety without any ne or convicon for the Company. Therefore, no

amounts related to nes, penales or compensaon for such maers are presented in the

nancial statements.

Incidents of discrimination, human rights violations, and related sanctions

Number of discrimination incidents [S1-17_103 a]

Number of harassment incidents

Number of complaints submitted through channels for the Company's

workforce [S1-17_103 b]

Fines, penalties, and compensation for damages resulting from incidents of

discrimination, including complaints and harassment [S1-17_103 c]

0€

Number of complaints filed to the National Contact Point for OECD

Multinational Enterprises

Number of serious human rights violations and incidents related to the

Company's workforce [S1-17_104 a]

Number of serious human rights violations and incidents related to the

Company's workforce that constitute non-compliance with the United Nations

Guiding Principles and the OECD Guidelines for Multinational Enterprises [S1-

17_104 a]

Non-serious human rights issues and incidents related to the Company's

workforce [S1-17_104 a]

Fines, penalties, and damages for serious human rights issues and incidents

related to the Company's workforce [S1-17_104 b]

0€

Page 283 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Incidents of discrimination, human rights violations, and related sanctions

Number of discrimination incidents [S1-17_103 a]

Number of harassment incidents

Number of complaints submitted through channels for the Company's

workforce [S1-17_103 b]

Fines, penalties, and compensation for damages resulting from incidents of

discrimination, including complaints and harassment [S1-17_103 c]

0€

Number of complaints filed to the National Contact Point for OECD

Multinational Enterprises

Number of serious human rights violations and incidents related to the

Company's workforce [S1-17_104 a]

Number of serious human rights violations and incidents related to the

Company's workforce that constitute non-compliance with the United Nations

Guiding Principles and the OECD Guidelines for Multinational Enterprise [S1-

17_104 a]

Fines, penalties, and damages for serious human rights issues and incidents

related to the Company's workforce [S1-17_104 b]

0€

Diverse talent attraction

The Company operates in a tradionally male-dominated sector where diversity across age,

gender and cultural background remains limited naonally and internaonally. This creates a

signicant strategic opportunity for the Company to strengthen its posion as an inclusive

employer and aract a broader range of talent. To capitalise on this opportunity, the Company

implements specic policies and pracces that promote inclusion and equal treatment in the

workplace. Specically, the Company implements a Diversity, Equality, and Inclusion Policy,

and maintains an established and transparent promoon process through its Sta Promoon

Regulaons, ensuring equal career advancement opportunies for all employees. At the same

me, it implements collecve bargaining agreements that guarantee fair employment terms.

As part of its eorts to aract new talent, the Company parcipates in university career days

and career fairs, while job posngs are published in a manner that is open and accessible to

all candidates, without discriminaon. Through these and other iniaves, the Company seeks

to strengthen its posion as an inclusive employer and aract a broader and more diverse

range of talent. [S1-4_40 b]The Company’s workforce already reects a mix of professional

backgrounds, age groups and funconal roles. Women currently represent 15% of total

employees, while employees under 30 constute a smaller share of the workforce, consistent

with wider sectoral dynamics. [S1-6_50 a], [S1-9_66 b]

Representaon varies across hierarchical levels: administrave roles show comparavely

stronger gender balance, whereas technical and dockworker roles remain predominantly

male. These paerns highlight the potenal to broaden the candidate pool and strengthen

diversity over me.

Employees Recruitments by Gender and Age

KPI

2024

2025

Male

Female

Total

Male

Female

Total

Recruitment

100

145

164

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(amounts in Euro unless stated otherwise)

The Company’s employment model is characterised by 100% full-me posions, transparent

recruitment and promoon processes, connuous training pathways and structured social

dialogue, which creates an aracve working environment for diverse talent groups. [S1-4_38

c] The Personnel Training Policy, the Sta Promoon Regulaon and regular performance

assessments support predictable career development and reinforce equal access to

advancement opportunies.

By enhancing representaon across genders, age groups, cultural backgrounds and people

with disabilies, the Company can expand its skills base, strengthen organisaonal adaptability

and improve decision-making. This opportunity supports long-term compeveness in a

rapidly evolving labour market and aligns with emerging EU expectaons on inclusion and

social sustainability [S1-4_40 b]

The eecveness of these pracces is reected in the Company’s stable workforce structure,

its transparent career-development framework and its consistently high levels of employee

retenon and engagement. [S1-4_38 d]

During the reporng period, a total of 58 employees departed from the Company,

consisng of 52 men and 6 women. The employee turnover rate for the reporng period

stood at 5.48%.Employees turnover [S1-6_50 c]

KPIs

2024

2025

Voluntary

Dismissals

Rerements

Work-related fatalies

Total

Employee departure rate

(%)

6.64

5.48

Employee turnover by gender

KPIs

2024

2025

Male

Female

Male

Female

Voluntary

Dismissals

Rerements

Deaths in service

Total

Employee departure rate

(%)

6.88

5.26

5.79

3.75

Arion data were calculated based on headcount. The employee turnover rate was

calculated as the rao of the total number of departures (voluntary resignaons, dismissals,

rerements, and work-related fatalies) during the reporng period to the total headcount for

the same period. [S1-6_50 d]

Compared to the previous reporng period, during which 68 employees departed from the

Company, a decrease in the number of departures was recorded. [S1-6_50 e]

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(amounts in Euro unless stated otherwise)

The number of employees used for calculang the turnover rate is consistent with the number

of sta presented in the Company's Financial Statements for the corresponding period

.[S1-

6_50 f]

Training, Skills and Technological Readiness

The Company places strong emphasis on connuous learning and capability building,

recognising that the port sector is undergoing rapid technological, digital and environmental

transformaon. To support workforce readiness and maintain operaonal excellence, the

Company implements a structured and comprehensive training framework, governed by the

Personnel Training Policy, which ensures equal access to development opportunies for all

employees, including xed-term sta. [S1-4_38 c]

Training needs are idened through the Annual Training Plan, ad-hoc departmental requests,

performance evaluaons and cercaon requirements. The Human Resources Department

coordinates all training processes (needs idencaon, provider selecon, approvals,

scheduling and monitoring), as well as the documentaon of training parcipaon and

outcomes. [S1-4_39] Parcipaon in approved training programs is mandatory, and all

cercates or proof of successful aendance are recorded in employees’ personal les.

During the reporng period, employees parcipated in a diverse range of training programs

covering sustainability, compliance, health and safety, digital skills, operaonal procedures,

specialised technical skills. In total, 16,237 training hours were delivered in 2025 (2024:

11,524). Training subjects included:

• Board of Directors Training (ESG Core Principles)

• Risk Management

• Internal Audit Issues

• Occupaonal Health and Safety Management System (ISO 45001)

• MS Oce Training

• Data Protecon and GDPR Regulaon

• Port & Container Terminal Training

• Corporate Governance

• Tax & Financial Training

• Legal & Regulatory Compliance Training

• Labour & Social Security Training

• Diversity, Equality & Inclusion Policy

• ISPS Code (Internaonal Ship and Port Facility Security Code)

• Services for People with Disabilies

• Security Personnel Training

• Occupaonal Health & Safety

• Forkli Truck Operaon (Clark)

• Arcial Intelligence & ChatGPT

• IT Trainings

• ESG Sustainability Issues

See Annual Financial Statements 2025, Notes to the Financial Statements, Note 1 "Company Structure and

Activities"

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(amounts in Euro unless stated otherwise)

• Prevenon of Violence & Harassment in the Workplace

• Fire Safety

• Human Resources

• Inducon Training

• Training in the IMO IMDG Code (Dangerous Goods)

• Procurement Regulaons

• Administrave / Leadership Training

• Sta training hours on an-corrupon and an-bribery issues

• Customs Issues

The Company’s commitment to life-long learning is further supported through the Regulaon

for Cercaon Costs, which provides nancial coverage for employees pursuing professional

cercaons or academic qualicaons relevant to their roles.

The average training hours per employee for 2025 stood at 15.35, with female employees

recording 23.31 hours and male employees 13.91 hours. [S1-13_83 b] Training progress and

compleon are monitored via a Connuous Educaon Checklist, while inducon training is

mandatory for all new hires and includes safety protocols, internal regulaons, corporate

policies and standard operaonal procedures. [S1-4_38 d]

Employee Average Training Hours

2024

2025

Male

17.39

13.91

Female

10.18

23.31

Total-Average

11.25

15.35

To support structured professional development, a Competency Model and Managers’

Assessment framework has been implemented, enabling annual evaluaon of skills,

performance and capability gaps. These processes help idenfy areas where upskilling is

required and enhance alignment with technological and operaonal needs. [S1-4_83 a]

Training & Skills Development for New Technologies

Technological and environmental transitions in global shipping (e.g. automation, digitalisation,

alternative fuels and new energy systems) require employees to acquire new skills to safely

and efficiently operate evolving port infrastructure. The Company is actively preparing its

workforce through targeted training, induction, certifications and collaboration with external

institutions.

Although most initiatives are still expanding, the Company already provides structured

learning on ESG issues, specialised technical training, Code of Conduct training and continuous

on-the-job development. These efforts help ensure that employees can adapt to new

technologies, improving operational safety, efficiency and readiness for future regulatory and

technological changes. [S1-4_38 a]

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Skill Gap and Technological Readiness

The accelerated automation and digitalisation of port operations create a significant risk if the

workforce is not adequately prepared. Insufficient familiarity with new systems could lead to

lower productivity, operational errors, higher safety risks and reduced competitiveness versus

technologically advanced ports.

The Company mitigates this risk through the structured Training Policy, annual skill

assessments and department-level evaluations that identify training needs and areas where

upskilling is essential. These processes form the basis for training roadmaps that support

workforce readiness and prevent capability gaps. [S1-4_40 a], [S1-4_40 b]. Failure to address

these gaps could hinder the Company’s transition toward more efficient and sustainable

operations, increase operational costs and delay innovation.

Upskilling – Technological Capabilities of Workforce

As ports internationally shift toward digital, automated and low-carbon operations, the

Company has a strategic opportunity to enhance its competitive position by investing in

technological upskilling. Strengthening digital literacy, operational capabilities, and knowledge

of new technologies can:

• improve efficiency and accuracy in port operations

• enhance safety and reduce incident likelihood

• support faster adoption of alternative fuels and greener operations

• attract high-calibre talent aligned with future port needs

• reinforce the Company’s position as a leading Mediterranean port embracing innovation

By building a tech-ready workforce, the Company increases its resilience and its long-term

ability to respond to global maritime shifts [S1-4_40 b]. Effectiveness is reflected in training

participation levels, skill-development outcomes and the ability of employees to adapt to new

technological and operational demands [S1-4_40 a].

Employee evaluation

The percentage of employees who parcipated in regular performance and professional

development evaluaons totalled 97.5% of the workforce (1,032 employees out of a total of

1,058). The breakdown of this percentage by gender is 97.77% for male employees and 96.25%

for female employees. [S1-13_83 a]

The Company has adequate human, financial, and organisational resources to manage the

material impacts related to its human resources. The implementation of the relevant policies,

procedures, and actions is mainly supported by the Human Resources Department, in

collaboration with other relevant functions of the Company, such as the Occupational Health

and Safety function. The implementation of the relevant policies, procedures, and actions is

mainly supported by the Human Resources Department, in collaboration with other relevant

Company functions, such as the Occupational Health and Safety function.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Company allocates resources for the implementation of training and skills development

programs, initiatives for employee health and safety, as well as actions that promote employee

well-being and professional development. To support these actions, internal human resources

management systems are utilised and, where necessary, collaborations with external

specialised partners, such as training providers and health and safety consultants is used.

These resources contribute to the effective implementation of relevant policies and

procedures and to the management of material impacts related to the Company's human

resources. [S1-4_43]

Further information on the actions defined by PPA S.A. is presented in the “Targets and

Actions Table” in section S1.5.

S1.5 – Targets related to managing material negative impacts,

advancing positive impacts and managing material risks and

opportunities

Regarding the targets, the base year has been set as 2024 [MDR-T 80(d)]. Specically, for the

target “Number of accidents,” the base year is 2022. The methodology applied for dening

and monitoring the targets is based on tracking relevant performance indicators (KPIs) [MDR-

T 80(d)]. The Company has established specic targets, with corresponding acons, for some

of the material topics it has addressed, as presented in the table below. These targets are not

quaned [MDR-T 80(b)], [MDR-M 75], [MDR-M 76], [MDR-M 77(c)]. Furthermore, no

specic methodologies or signicant assumpons have been used in the development of the

targets [MDR-T 80(f)], and there is no structured stakeholder engagement process in their

denion [MDR-T 80(h)]. Scienc evidence was not taken into account for target seng

[MDR-T 80(g)]. Finally, no changes have been made to targets, methodologies, or

assumpons, as the related processes are sll at an early stage of development and

maturaon [MDR-T 80(i)].

No targets have yet been set for the impact “Work–Life Balance and Wellbeing,” as the

Company plans to develop the relevant targets in the coming years [MDR-T 81].

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Targets and Acons Table

HEALTH AND SAFETY ENHANCEMENT

IRO

Acons

[MDR-A 68a]

Target

[MDR-T- 80b]

Year

[MDR-A 68c/

MDR-T 80e]

Scope of Coverage

[MDR-A 68b/

MDR-T 80c]

KPIs

[MDR-A 68e/ MDR-T

80b/ MDR – M- 75]

Progress

by 2025

[MDR-A 68e/

MDR-T- 80j]

Occupaonal Health

and Safety, Employee

Health and Safety

Incidents

Gradual

implementaon of

the ISO 45001

Management System

Improvement of

health and safety

issues

management

2027

Own operaons

Number of accidents

Ongoing / 5% of

target achieved

Installaon of weather

staons to measure

condions aecng

worker safety and

provide real-me

alerts

Prevenve

approach to

maintaining

employee health

and safety

(ensuring health

and safety in all

areas of PPA S.A.)

2026

Own operaons

Ongoing/ 30%

of target

achieved

STRENGTHENING EMPLOYEE ENGAGEMENT AND IMPROVING PERFORMANCE

IRO

Acons

[MDR-A 68a]

Target

[MDR-T- 80b]

Year

[MDR-A 68c/

MDR-T 80e]

Scope of Coverage

[MDR-A 68b/

MDR-T 80c]

KPIs

[MDR-A 68e/ MDR-T

80b/ MDR – M- 75]

Progress

by 2025

[MDR-A 68e/

MDR-T- 80j]

Interacon with

Employees and Social

Dialogue

Employee sasfacon

survey

- Design and

implementaon

- KPI monitoring

Meeng the needs

and expectaons

of employees

2026

Own operaons

% of Research

Compleon

No progress has

been made

Developing an acon

plan based on

the results of the

survey

- Design and

implementaon

2028

Own operaons

Sasfacon rates

and performance

indicators

will depend

the acon plan.

No progress has

been ma

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(amounts in Euro unless stated otherwise)

Equal Opportunies

DEI Acon Plan

Diversity Assessment

- Design and

Implementaon

Promong

diversity, equality,

and inclusion in

the Company

2025

Own operaons

Percentage of

people with

disabilies

Achieved 100%

Cooperaon with

organisaons that

support workforce

inclusion for people

with disabilies

Inclusion of

relevant

provisions in

contracts for

persons with

disabilies

2026

Own operaons

Number of training

courses provided

Achieved 100%

Training and skills

development for new

technologies

Training oer for

skills upgrading and

retraining of the

workforce

-1.6 hours per

employee

2026

Own operaons

Number of training

sessions provided

Achieved 100%

- X hours of

training in new

technologies

Own operaons

Number of

parcipants

Ongoing/ 50%

of the target

achieved

ESG Training

200 parcipants

2026

Own operaons

Number of

parcipants

Ongoing / 66

parcipaons

At the indicator level, no specic methodologies or assumpons have been applied [MDR-M_77 (a)], and no external party, has been involved in validang

the metrics used [MDR-M 77 (b)].

The budget for these acons is esmated at €208,000, of which €102,000 is CAPEX and €106,000 is OPEX. During the reporng period, €48,000 has been

implemented, while the remaining acons will be completed in the future according to the planned schedule [MDR-T 69 (a), (b)]

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(amounts in Euro unless stated otherwise)

ESRS S3- Affected Communities

S3.SBM-3 – Material impacts, risks and opportunities and their

interaction with PPA’s strategy and business model

Stakeholder’s Interests and Opinions [S3. SBM-2 7]

The Company idenes the local and regional communies aected by port acvies as a key

stakeholder group, incorporang their interests, perspecves, and rights into its strategy and

business model. Through stakeholder engagement processes and communicaon channels,

the Company gathers feedback regarding the social and environmental impacts of the port

operaons, which is evaluated by management and incorporated into the sustainability

strategy and decisions concerning the operaon and development of the port, with the aim of

ensuring responsible business conduct and the protecon of human rights.

Ports worldwide act as major economic engines, supporng and smulang local, regional and

naonal economies through job creaon and the movement of goods. At the same me,

neighbouring communies are mainly aected by environmental pressures arising from port

operaons and related transport networks. As a result, ports face the ongoing challenge of

creang local value while maintaining the support and acceptance of neighbouring

communies. These impacts arise directly from the Company’s business model and

operaonal strategy and are taken into account in their planning and adjustment through the

integraon of migaon measures and related iniaves, as well as by leveraging feedback

from aected communies and other stakeholders [S3.SBM-3_8].

In the case of the port of Piraeus, the aected communies include residents, businesses and

workers who operate or reside in areas adjacent to the port's operang zones, specically in

the following areas:

• Piraeus

• Perama

• Keratsini–Drapetsona

• Salamina [S3.SBM-3_9 a (i)]

These communies interact daily with port operaons and are exposed to both posive socio-

economic benets and environmental pressures associated with marime and land-based

acvity. The vicinity of ship repair, cruise operaons, ferry terminals and logiscs corridors

creates a parcularly close port–city relaonship.

Furthermore, due to the geographically concentrated nature of the Company’s operaons and

the absence of signicant evidence of community-level impacts beyond the port’s immediate

operang area, value-chain communies were not idened in the assessment.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Although the aected communies within the value chain are considered in the Company's

double materiality assessment, they do not present signicant risks or challenges that would

jusfy their presence in the Company's sustainability report for the reporng period. [S3.SBM-

3_9 a (ii)], [S3.SBM-3_9 a (iii)]

In the 2025 Double Materiality Assessment review, S3- Aected Communies chapter

remained a material issue for the Company,which strives to minimise operaonal negave

impacts on the wider community, to progressively migate them where possible, and to

implement targeted community-focused iniaves that oset, to the greatest extent possible,

any remaining impacts.

In the 2025 Double Materiality Assessment review, S3- Aected Communies chapter

remained a material issue for the Company, which strives to minimise operaonal negave

impacts on the wider community, to progressively migate them where possible, and to

implement targeted community-focused iniaves that oset, to the greatest extent possible,

any remaining impacts.

The Double Materiality Assessment idened 3 material Impacts.:

Actual Posive Impacts

Job Creaon and Economic Growth (Company specic)

Corporate Social Responsibility (Company specic)

Actual Negave Impacts

Polluon Related Community Eects in Relaon to Health & Quality of Life (Spills, Noise,

Emissions, Waste, Trac)

The Company contributes substanally to the local and naonal economy by generang

employment opportunies and supporng the global logiscs chain, while through its

operaons it directly facilitates trade and indirectly supports industry and service sectors. Job

creaon and economic development extend beyond Greece, given the Company’s strategic

geographical posion. As one of the major European ports in the Eastern Mediterranean,

located at the crossroads of Asia, Africa and Europe, it provides the infrastructure required to

serve signicant volumes of transit trade.

Furthermore, the Company, as a major gateway in global trade, generates positive impacts

for affected communities through its responsible business operations and its structured

Sustainability approach. By committing to safe working conditions, the protection of human

rights throughout its value chain, to the level possible, the transparent stakeholder

engagement and the continuous minimisation of environmental impacts, the Company

strengthens trust with residents, public authorities and business partners contributing to a

stable social licence to operate and enhancing the long-term reputation of the port in the

regions it operates.

Through its CSR initiatives, the Company supports education, culture, social inclusion and local

development in the wider Piraeus area, benefiting communities in Piraeus, Drapetsona–

Keratsini, Perama and Salamina. Partnerships with educational institutions, support to cultural

and sports activities and contributions to local social programmes foster community well-

being, strengthen local capabilities and promote cohesion in a dense urban environment

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(amounts in Euro unless stated otherwise)

influenced by port operations. These actions help build more resilient, engaged and

prosperous communities while reinforcing the Company’s role as a responsible corporate

citizen. [S3.SBM-3_9 c]

At the same time, as with all large-scale port operations, the operation of the port may entail

certain challenges and negative impacts, for neighboring communities, mainly in relation to

increased traffic and congestion in the wider area. This impact may affect the daily life and

quality of life of residents, while in some areas it may appear with greater intensity, such as in

the Perama Shipbuilding and Repair Zone, where local communities are in closer proximity to

the relevant port operations. To address these impacts and mitigate associated risks, the

Company has established mechanisms covering both environmental and operational aspects,

which are presented later in this section. [S3.SBM-3_9 b]

The Company assessed whether certain affected communities may reasonably be at greater

risk of experiencing impacts, based on objective factors such as geographical proximity to

operational areas, the type and intensity of port-related activities and the physical

characteristics of the surrounding environment. Communities located immediately adjacent

to key operational zones, such as those near cargo handling areas, ferry terminals or the Ship

Repair Zone, were considered more likely to experience potential exposure to environmental

pressures associated with port activities compared to communities located at further

distances.

This understanding was developed through a structured review of the spatial relationship

between port operations and residential areas, the nature of activities carried out in each zone

and publicly available environmental and urban data. No additional groups of affected

communities were identified as being at heightened risk beyond those located in the

immediate vicinity of the port’s operational footprint. [S3.SBM-3_10]

S3.1 – PPA S.A.’s Policies related to affected communities

The Company has established a comprehensive policy framework aimed at prevenng,

migang, and, where necessary, remediaon of the potenal impacts of its operaons on

aected communies, while maximising the posive socio-economic value created through

the Port of Piraeus. These policies guide responsible business conduct, environmental and

corporate social responsibility, stakeholder engagement and transparent reporng.

They apply across all the Company acvies and form the basis for managing the material

impacts regarding the “Aected Communies” secon as idened in the 2025 Double

Materiality Assessment, namely:

• Job creation and Economic Growth and

• Corporate Social Responsibility [S3-1_12]

The set of interrelated policies that collecvely ensure a responsible, ethical and sustainable

approach to operaons are as follows and addional details may be found in the relevant

secon of the current Statement the ESG & Sustainability Policy,

• the Quality, Environmental & Energy Policy,

• the Code of Conduct, and

• the Whistleblowing Policy and Procedure for Managing Reports and Complaints.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

They are embedded into the Company’s day-to-day operaons and apply to all employees,

contractors, partners and third pares acng on behalf of the Company. [S3-1_14],

[S3.MDR_P_65 a]

The ESG and Sustainability Policy provides the overarching framework for integrang

environmental & corporate social responsibility, as well as good governance pracces, into

business processes. It sets out the Company’s objecve of responsible operaons, minimizing

environmental impacts, enhancing social dialogue and contribung posively to society. It

outlines key commitments related to climate change migaon, environmental performance,

stakeholder collaboraon, and human rights, and is aligned with internaonally recognised

standards including the UN Global Compact, the UN Guiding Principles on Business and Human

Rights, relevant Internaonal Labour Organisaon (ILO convenons), ISO 9001:2015, ISO

14001:2015, ISO 50001:2018, and ISO 14064-1:2018. [S3-1_17, MDR-P_65 d] Oversight is

assigned to the ESG Committee, which acts as the policy owner and ensures proper

implementation and alignment with the Company’s strategic direction. [S3.MDR_P_65 c, S3-

1_16]

Through its ESG and Sustainability Policy, the Company recognises the importance of

stakeholder engagement and collaboraon with local communies, governmental agencies,

NGOs and industry partners to co-develop soluons that balance economic development and

environmental protecon. The Company maintains open communicaon channels and

parcipates in processes requiring public consultaon, thereby integrang community

feedback into decision-making and environmental management pracces. [S3-1_16 b]

However, through the Code of Ethics, the Company is committed to respecting human rights,

which are taken into account within the broader approach to sustainable development,

corporate governance, and compliance with the applicable regulatory and institutional

framework. [S3-1_16]

In addion, the Quality, Environmental & Energy Policy denes the Company’s commitment

to idenfying and managing signicant environmental impacts across its operaons and value

chain. This Policy emphasises prevenon and migaon of polluon, enhancement of

resource eciency and operaon under a cered Integrated Management System aligned

with ISO 9001:2015, ISO 14001:2015, ISO 50001:2018 and ISO 14064-1:2018. These systems

support connuous improvement, eecve operaonal control and transparent

communicaon with interested pares. At the same me, the Policy provides for the

implementaon of documented procedures, monitoring mechanisms, and targeted acon

plans, which are implemented under the Company’s Integrated Management System,

ensuring that environmental commitments are consistently translated into pracce. [S3-

1_17], [MDR-P_65d]

The Company places parcular emphasis on maintaining secure and reliable communicaon

channels for reporng problems by individuals and communies. The Whistleblowing Policy

establishes a structured and condenal mechanism for idenfying and addressing potenal

illegal, irregular or unethical acvies, including those that may relate to community impacts.

The policy further outlines clear reporng channels, denes responsibilies, and enables

correcve acons that strengthen transparency, risk migaon and accountability.

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(amounts in Euro unless stated otherwise)

Whistleblowing Commiee, appointed by Top Management, includes representaves from

the Regulatory Compliance Unit, the Human Resources Department and the Legal

Department, with the support of the Data Protecon Ocer. The Policy is fully aligned with

Law 4990/2022, which incorporates Direcve (EU) 2019/1937 and complies with GDPR and

naonal data-protecon requirements. [S3-1_16 c], [S3-1_17]

Collecvely, these Policies form a coherent and integrated framework that supports the

management of the Company’s impact on aected communies, aligns with applicable

standards and regulaons and strengthens the Company’s contribuon to sustainable

development. More Informaon about the policies can be found on the chapters E1-Climate

Change, S1-Own Workforce, and G1-Business Conduct.

S3.2 - Processes for engaging with affected communities about

impacts

The Company recognises the importance of understanding the perspecves of local

communies and maintaining open and accessible channels through which concerns,

comments and observaons can be raised. Engagement with aected communies takes place

directly, primarily through the corporate email address published on the Company’s website,

which is available for residents and other interested pares to submit queries or feedback. In

addion, the Company maintains regular and direct communicaon with local Municipalies

on various issues that may arise, ensuring mely coordinaon and eecve resoluon of

maers of local relevance. This communicaon is conducted in person and by telephone and

occurs frequently, reecng the Organisaon’s commitment to maintaining transparent and

cooperave relaonships with municipal authories. No engagement through intermediaries,

proxies or formal community representaves has been idened within the current reporng

framework. [S3-3_21 a]

Engagement occurs on an ongoing basis, as the communicaon channels remain connuously

accessible. The nature of engagement mainly consists of wrien exchanges, enabling members

of the community to contact the Company whenever an issue arises relang to their interests

or well-being. Similarly, interacons with Municipalies take place whenever operaonal,

social or environmental maers require coordinaon, with discussions held directly and oen

informally to ensure the mely and ecient handling of the issues arising. This process allows

the Company to receive input on a regular basis and to respond to potenal issues where

necessary. Apart from this connuous communicaon mechanism no addional structured

stages or forms of engagement have been reported. [S3-3_21 b]

Responsibility for ensuring that engagement with local communies takes place while the

insights collected through the relevant communicaon channels are incorporated in the

Company’s decision-making through the management structure. The CEO holds the most

senior responsibility for social engagement maers, overseeing community-related issues and

approving relevant social iniaves. Community input and comments received through the

Company’s communicaon channels are escalated through internal processes that ensure all

relevant maers are brought to the aenon of senior leadership when necessary.

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Similarly, feedback originang from the collaboraon and discussions with Municipalies is

assessed internally, with signicant maers are forwarded to senior management to ensure

alignment with the Company’s strategic and operaonal planning. [S3-3_21 c]

The eecveness of this engagement is supported through the Company’s established process

for receiving, registering and managing comments and complaints submied via the corporate

website and email. Submissions are handled in accordance with the Company’s internal

Complaints & Comments Management Procedure, which ensures condenal treatment in

compliance with GDPR and provides a structured process for reviewing and responding to

concerns. While this mechanism applies to individual submissions, issues raised through

ongoing communicaon with Municipalies are also recorded and monitored where relevant,

supporng coordinated follow-up and shared problem-solving. This mechanism allows the

Company to track any issues raised, ensure follow-up where required and integrate relevant

feedback into its connuous improvement eorts. [S3-3_21 d]

S3.3 - Processes to remediate negative impacts and channels

for affected communities to raise concerns

Remediation and Channels for Raising Concerns

All residents and members of the wider community are able to submit their comments,

complaints or any maers of concern through the Company’s corporate email address, which

is publicly available on it’s website. The Markeng and Quality Control departments receive

complaints or posive feedback via clientservice@olp.gr. The Markeng department forwards

the complaint to all involved departments and to clientservice@olp.gr requesng feedback

(provision of informaon) from the Directors of the responsible departments as soon as

possible, and no later than three (3) business days. In the case of cruise or ferry passenger

complaints falling under Greek Law 3709/2008 (FEK 213A/14−10−2008) regarding terminal

management operators, as amended, or Regulaon (EC) No 1177/2010, PPA S.A. must nofy

the passenger in wring within one (1) month of receipt of the complaint whether it was

upheld, rejected, or is sll under review. The me required to provide the nal wrien

response will not exceed two (2) months from receipt of the complaint. The Markeng and

Quality Control departments monitor the response process to ensure that all the accusers

receive a reply and maintain the relevant stascal records.

Understanding community concerns enables the Company to idenfy weaknesses and

incorporate relevant perspecves into its strategy. These communicaon channels also

contribute to mely addressing issues that may require correcve acon. [S3-3_27 a, S3-3_27

All feedback received from stakeholders is treated

condenally and is managed in accordance with the

Company’s Complaints & Comments Management

Procedure, which is fully compliant with GDPR requirement

[S3-3_28]

In 2025, zero incidents or

issues related to human

rights violations have been

reported. [S3-4_36]

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(amounts in Euro unless stated otherwise)

As part of its due diligence processes, the Company has designated the Head of the Risk

Management Unit as the Ocer Responsible for the Receipt and Monitoring of Reports. The

Company’s Whistleblowing Policy ensures that concerns can be expressed safely and

transparently through mulple communicaon channels, including:

• Email: whistleblowing@olp.gr

• Postal mail addressed to the Ocer Responsible for the Receipt and Monitoring of

Reports with the indicaon “Condenal”.

• Physical reporng boxes located at Company facilies

The relevant boxes for reports/complaints are located at the following points within the

Company’s facilies:

• Outdoor area of the Internal Audit Department Oce (PPA central building)

• Container Terminal Building (ground oor next to the elevator)

• Car Terminal Building (ground oor next to the main entrance)

In any case where a report/complaint is submied to a dierent corporate email and not to

whistleblowing@olp.gr, it must be forwarded to this address by any recipient, so that the

Compliance Ocer is noed and can take appropriate acon.

Given that the procedure is governed by condenality regarding all collected and analyzed

data, personnel are encouraged to submit each report/complaint openly to facilitate proper,

faster review, evaluaon, and invesgaon.

The management of reports/complaints is based on the following characteriscs considered

to constute/ensure an eecve dispute resoluon plan:

• Accessibility: The Policy and Procedure for managing reports/complaints is easy to

understand and use.

• Condenality: Informaon regarding a report/complaint is provided only to those

designated to know about it, in order to take proper acons to resolve it.

• Independence: The Compliance Ocer and the Reports Management Commiee

operate independently in carrying out their dues from both the reporng person and

the reported person. [S3-3_27 c]

In addion, the monitoring of reports and complaints submied by stakeholders is further

supported by the Data Protecon Ocer (DPO), who ensures compliance with personal data

protecon regulaons. These mechanisms reect commitment to responsible business

conduct by integrang reporng channels into its broader due diligence framework. The

structured reporng system enables the mely and appropriate handling of issues,

strengthening transparency and accountability across the Company’s operaons. All the above

procedures and mechanisms are described in the Reports/Complaints Management Policy and

Procedure, which is posted on the Company’s ocial website (hps://www.olp.gr/el/o-

organismos/etairiki-diakivernisi/polikes). [S3-3_28]

For issues such as trac, air polluon and the overall safety of the port and surrounding

communies, the Company collaborates with local authories and government bodies to

address these maers collecvely and enhance posive outcomes. [S3-3_27 d] Through its

reporng mechanisms, communicaon channels and connuous cooperaon with local

municipalies, any issues or complaints that arise are addressed either through policy review

or through immediate acons aimed at reducing negave impacts, depending on the nature

of each case.

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The Company’s CEO ulmately holds full responsibility for acons related to the protecon

and support of aected communies. The CEO oversees social contribuon iniaves and due

diligence processes maintaining a consistent overview of the maers aecng the community.

All social iniaves and support programs are subject to the CEO’s approval, ensuring

alignment with the Company’s strategic priories and commitments to sustainable

development. [S3-2_21 c]

S3.4– Actions and approaches regarding material impacts on

affected communities

Job Creation and Economic Growth

The Company plays a key role in generang local jobs, driving naonal economic growth and

enabling internaonal trade. The port of Piraeus has a tangible posive impact on employment

and economic development both in the communies surrounding the port and across the

naonal economy. Enhancing employment opportunies has consistently remained a priority

for the Company. By creang job opportunies, the Company contributes to social well-being

and helps reduce unemployment at both the local and naonal level. Increased employment

also strengthens the purchasing power of the workforce, smulang economic acvity in the

wider Piraeus region, while supporng strategic objecves related to the port’s sustainability,

reputaon and social contribuon.

Port’s operaons also support a diverse value chain, engaging local suppliers and businesses

in sectors such as logiscs, ship repair, transportaon and other port-related services, thereby

reinforcing the economic vitality of neighbouring municipalies. As a major gateway for trade

in the Eastern Mediterranean, the Company plays a signicant role in Greece’s GDP by

facilitang trade, investment and industrial acvity. Port’s strategic role enhances the

country’s compeveness, strengthens supply chains and ensures long-term economic

resilience for both local communies and businesses. As a result, the Company’s presence

generates sustained employment, income opportunies and economic circulaon in Piraeus

and beyond, strengthening both the regional economy and the broader social fabric of the

communies that depend on the port.

The Company reinforces its commitment to job creaon and contribuon to naonal GDP

through iniaves such as:

• Providing reduced dues for exporng cargo to support the naonal economy and the

balance of payments

• Operating the largest coastal passenger terminal in Europe, which promotes national

cohesion and supports the economic development of the islands, with port fees

remaining unchanged since 2016 to enable low-cost coastal connections

• Offering special pricing policies for vessels serving remote island routes

• Achieving high-performing economic indicators (KPIs) reported in the annual financial

statements.

• Establishing acons and performance indicators specically related to the Company’s

contribuon to naonal GDP. [S3-4_31 b]

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(amounts in Euro unless stated otherwise)

Impacts of Pollution on Local Communities in Relation to Quality of Life

(Traffic Congestion) (Material Topic for the Company)

Communities surrounding the Port of Piraeus are exposed to environmental pressures

associated with the Company’s port and shipping activities, the most significant being traffic

congestion caused by vehicle circulation, port operations, and the concentration of transport

flows in the wider area. Increased traffic congestion may negatively affect the daily lives and

quality of life of residents in neighboring areas, as it is associated with higher noise levels,

deterioration of air quality, travel delays, and general stress on the urban fabric.

At the same me, some external impacts, such as trac congeson and environmental

burden, are addressed through structured mechanisms led by the State, designed to balance

port acvies with broader societal needs. [S3-4_33 a, S3-4_33 b, S3-4_35] Migaon of such

external impacts is part of naonal policy and, therefore, is not solely at the discreon of

private enes like Piraeus Port Authority S.A. [S3-4_32 d]

Where negave impacts cannot be fully avoided, the Company provides or enables

remediaon through compensaon mechanisms established under the Concession

Agreement with the Hellenic Republic. Within this framework, the Company indirectly makes

nancial compensatory contribuons to the neighboring municipalies of Piraeus,

Drapetsona-Keratsini, Perama, and Salamina, as provided in the Concession Agreement. In

2025, the amount paid to the Hellenic Republic reached €9,000,000 [S3-4_38], supporng

local development, public infrastructure, and essenal community services. Addionally,

specic land areas within the port’s terrestrial zone have been allocated for public interest

purposes, including healthcare facilies and other essenal public services, as well as the

construcon of a recreaonal park, enhancing community resilience and social well-being. [S3-

4_32 b]

The Company idenes appropriate measures to address negave impacts through

environmental monitoring systems, environmental assessments, and public consultaon

processes linked to environmental permits (EPE, AEPO, MPE), which ensure regulatory

compliance and provide opportunies for stakeholder parcipaon. [S3-4_33 c] Furthermore,

the Company has completed a strategic resilience assessment and plans to implement shore-

to-ship electricaon infrastructure (cold ironing), allowing vessels to connect to the local

electricity grid while docked. [S3-4_31 a, S3-4_32 a, S3-4_33 b, S3-4_35]

Decisions regarding prevenve or correcve measures reect combined informaon from

monitoring results, public feedback, and regulatory trends (including Med SECA and EU

emissions direcves), ensuring that acons remain relevant, proporonate, and aligned with

broader environmental objecves. [S3-4_33 a]

The eecveness of the Company’s acons is monitored through connuous reporng,

dened sustainability targets, structured control programs, consultaon requirements, and

maintenance of communicaon channels with communies. [S3-4_32 d] These systems

enable Piraeus Port Authority S.A. to track progress, idenfy areas needing further

intervenon, and ensure that environmental and compensatory measures achieve the

expected outcomes. Overall, the Company’s structured compensatory and environmental

management frameworks contribute to long-term community resilience and environmental

protecon.

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(amounts in Euro unless stated otherwise)

Corporate Social Responsibility (Company Specific)

The Company, being a crical node in global trade, is expected to operate responsibly, ensuring

safe working condions, protecng human rights in the value chain, minimising polluon, and

engaging transparently with stakeholders. The Company’s CSR approach enhances the

community’s and business partners’ trust, thus contribung to the Company’s operaonal

eciency and long-term reputaon.

Through its CSR iniaves, PPA S.A. creates tangible posive impacts on local communies by

supporng educaon, culture, social inclusion, and local development in the wider Piraeus

area.

CSR acons, such as partnerships with schools and universies, sponsorship of cultural and

sport acvies, and donaons to local social programs, strengthen community well-being,

foster local skills and opportunies, and promote cultural cohesion in an urban environment

directly inuenced by port operaons. In 2025, the Company contributed over €730,000 in

donaon and sponsorships. [S3-4 31 b]

Sponsorship Programme

The Company has launched a new Scholarship Program for the 2025-2026 academic year,

underscoring its commitment to supporng local communies through educaonal iniaves.

The program allocates a total of €30,000 in funding, providing ten scholarships of €3,000 each

to outstanding rst-year university students from the broader Piraeus region. Through this

nancial contribuon, the Company supports the reducon of economic barriers to higher

educaon, rewards academic excellence, and invests in the development of the next

generaon. The iniave reects the organisaon’s broader corporate social responsibility

strategy, fostering long-term social value and strengthening its es with the communies it

serves. [S.3- MDR-A_68 a, S.3- MDR-A_68 b, S.3- MDR-A_68 c, S.3- MDR-A_69 b, S3-4_32 c]

Community park at the cruise terminal

In cooperaon with COSCO SHIPPING and within the framework of CSR and enhanced

engagement with local communies, the Company has undertaken the responsibility of

creang a new, modern public park for the Municipality of Piraeus. The iniave includes a

modern playground and a dedicated bicycle lane within the port’s cruise-terminal area. The

project aims to enhance relaons with the local community and the Municipality of Piraeus,

while providing a signicant environmental and social benet. The planned 125-hectare green

space is expected to help migate negave environmental impacts, parcularly air polluon

and noise, by acng as a natural buer and contribung to air ltraon. The total budget for

the park remains esmated at €4.4 million. T

he Company will connue tracking community sasfacon, the mely resoluon of

community complaints and the number of training courses conducted on eecve complaint-

handling processes, through the communicaon channels dened above. [S.3- MDR-A_68 a,

S.3- MDR-A_68 b, S.3- MDR-A_68 d, S.3- MDR-A_69 a, S3-4_32 c , S3-4_32 d]

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(amounts in Euro unless stated otherwise)

Port Users/Stakeholders Council

In 2024, the Company launched the establishment of a Port Users/Stakeholders Council, which

is planned to meet on a semi-annual basis. This iniave aims to strengthen the Company’s

stakeholder-management framework and enhance open communicaon with all port users

and stakeholder groups. Throughout 2025, the Company monitors parcipaon levels in the

Council, the number of acve users involved, and the number of requests and complaints

submied and resolved within the dened response meframe. [S.3- MDR-A_68 a, S.3- MDR-

A_68 b, S.3- MDR-A_68 c,S3-4_32 c, S3-4_32 d]

Participation in Trade Associations and Unions

In 2025, the Company also began acons to expand its parcipaon in trade associaons and

unions to reinforce its acve role within the local community and the wider marime sector.

As part of promong social dialogue, the Company is monitoring its social-media accounts and

tracking outreach acvies and engagement metrics throughout the year. [S.3- MDR-A_68 a,

S.3- MDR-A_68 b, S.3- MDR-A_68 c, S3-4_32 c, S3-4_32 d]

Distribution of Christmas gift vouchers to children in the neighbouring municipalities

Every Christmas season the Company distributes through the local authories more than

5,000 Christmas gi vouchers for children in the neighbouring municipalies, as well as

families of workers in the ship repair sector, providing essenal support to local communies

during the holiday season.

This iniave forms part of the Company’s broader social programme, which focuses on

supporng vulnerable groups and promong acons with a substanal social footprint. The

nominal value of the vouchers for the year 2025 was over 200,000 euros. [S.3- MDR-A_68 a,

S.3- MDR-A_68 b, S.3- MDR-A_68 c, S.3- MDR-A_69 b, S3-4_32 c, S3-4_32 d]

More informaon regarding the acons dened by Piraeus Port Authority S.A. is presented in

the table “Targets and Acons” in secon S3.5.

For the material topics “Job Creaon and Economic Development” and “Impacts of Polluon

on Local Communies in Relaon to Quality of Life (Trac Congeson),” there are no specic

acons yet, as their gradual integraon is currently in progress. [MDR-A 62]

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S3.5– Targets set in 2024 and progress

Regarding the targets, the base year has been set as 2024 [MDR-T 80 (d)], while the

methodology applied for their identification and monitoring is based on internal tracking of

relevant performance indicators (KPIs) [MDR-T 80 (f)]. Furthermore, there is no structured

stakeholder engagement process in defining them [MDR-T 80 (h)], no changes in targets,

methodologies, or assumptions have been reported [MDR-T 80 (i)], and no scientific evidence

has been used for their creation [MDR-T 80 (g)], as the related processes are still in an initial

stage of development and maturation. In addition, the table of actions and targets currently

covers selected material topics, specifically the topic (“Corporate Social Responsibility –

Special Topic for the Company”), while other material topics (“Job Creation and Economic

Development” and “Impacts of Pollution on Local Communities in Relation to Quality of Life

(Traffic Congestion) – Special Topic for the Company”) are not yet fully represented, with the

gradual integration of targets for all material topics ongoing [MDR-T 81].

The targets included in the table below are not quantified [MDR-T 80 (b), MDR-M_75, MDR-

M_76, MDR-M 77 (c)].

Page 303 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Table of Targets and Actions

Ensuring Corporate Social Responsibility

IRO

Actions [MDR-A 68a]

Target [MDR-T- 80b]

Year

[MDR-A

68c/ MDR-T

80e]

Scope of

Coverage

KPIs [MDR-A 68e/ MDR-T 80b/ MDR –

M- 75]

Progress

by 2025

[MDR-A 68e/

MDR-T- 80j]

[MDR-A

68b/ MDR-T

80c]

Corporate

Social

Responsibility

(Company

Specific)

Continuing its cooperation with

local stakeholders

Annual budget for local

community support

Annually

Downstream

Number of projects

100%

achieved

Budget allocated

Port users / Stakeholder Council

Improving the stakeholder

management framework

and achieving open

communication with all

port users/stakeholder

groups

Quarterly

Downstream

List of active users

100%

achieved

Percentage of users/stakeholders

participating in the Port Users Council

Number of requests/complaints

received and resolved within a specified

time frame

New model park in the cruise port

area (12.5 acres)

Strengthening relations

with the local community

and the Municipality of

Piraeus

2027

Downstream

Community satisfaction rate

progress/15%

of target

achieved

Strengthening the presence of the

Company in the community and in

social dialogue

Monitoring the Company's

social media accounts

2025

Downstream

Number of posts/press releases by

followers

100%

achieved

Participation of the Company in

trade associations and unions

Strengthening the

Company's active role

2025

Downstream

100%

achieved

At the level of indicators, no specic methodologies or assumpons have been used [MDR-M_77 (a)], and no external party has been involved in validang

the metrics employed [MDR-M_77 (b)]. The budget for the above acons is esmated at €5,280,000, of which €4,550,000 is CAPEX and €730,000 is OPEX.

For the reporng period, €1,030,000 has been implemented, while the remaining acons will be completed in the future according to the planned schedule.

[MDR-A_69].

Page 304 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Our Commitment towards our Customers

ESRS S4 – Customers and End-users

Strategy

Interests and Views of Stakeholders

[ESRS 2: SBM 2]

PPA S.A. acts as a key hub of connecvity and accessibility, shaping its strategy around the

interests, views and rights of its stakeholders. Its long-term approach is built on respect for

human rights, health and safety, ensuring that consumers, users and all aected groups are

heard and treated responsibly. PPA S.A. strives to maintain open and eecve communicaon

channels to build mutual trust and collaboraon, enabling the organisaon to idenfy and

monitor stakeholder concerns, needs and expectaons. Delivering high-quality processes and

services remains a strategic priority, with stakeholder feedback serving as a core driver for

connuous improvement. [S4: SBM2 8]

Material IROs and Their Interaction with Strategy and

Businesses

[S4: SBM3]

The business model of the Port of Piraeus integrates all impacts related to the safety, health,

and security of its users to enhance accessibility and the overall user experience. Millions of

travellers, passengers, and port visitors of all ages, including vulnerable groups such as people

with disabilies, rely daily on the port’s infrastructure and services. The customers and end-

users that are impacted by the acvies of PPA S.A., are presented as Indirect Customers

(Tier2) in the relevant stakeholder idencaon sector as presented in ESRS 2. [S4: SBM-3 10,

SBM-3 10 a, SBM-3 11]

17,213,513

3,055,596

1,092,697

772,042

864

Passengers

at the Ferry

Terminal

(+1%

compared

to 2024)

Vehicle traffic

(+1% compared

to 2024)

Homeport

passengers at Cruise

Terminal (+8%

compared to 2024)

Transit

passengers

(+12%

compared to

2024)

Ship calls

(+7%

compared to

2024)

The management of safety and security maintenance of customers and visitors is a rm

commitment embedded in every operaonal process of the port and has a signicant eect

on the decision-making process. PPA S.A. implements a strict risk management process and

regularly monitors potenal systemic threats through risk control systems. [S4: SBM-3_10d]

Page 305 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Through safety reports, the risk assessment of the operaonal procedures and through regular

communicaon with the ferry and cruise operators PPA S.A. receives insights on which

consumers and end users could be negavely aected- by operaons- and how.

In this context, PPA S.A. has idened specic characteriscs of consumers and end users that

may increase the risk of harm. These include persons with disabilies or reduced mobility,

elderly passengers, children, and passengers who are unfamiliar with the port environment,

such as rst-me users or tourists. These groups may be more exposed to safety and security

risks due to mobility limitaons, increased dependence on accessible infrastructure, or limited

familiarity with port procedures. [S4: SBM3_11]

Further promong construcve interacon with this stakeholder group, the port maintains an

open channel of communicaon and builds trust by systemacally monitoring customer and

end-user complaints. This channel strengthens the mely idencaon of potenal

challenges, supports eecve problem-solving, and enhances overall customer sasfacon,

thereby fostering long-term, trust-based relaonships with port users.

Through the Double Materiality Assessment according to ESRS-2 the Company idened

Passengers Port Safety and Security as bearing a potenal negave impact that might aect

the people who interact with or depend on the port’s safe funconing. The Company’s risk

outlined below, in relaon to consumers and/or end users, arises from potenal impacts rather

than dependencies. [S4: SBM3_10d]

Based on the informaon collected through observaons, complaints, and reports, PPA S.A.

integrates these impacts on consumers and end-users into risk management and the

priorizaon of strategic investments, such as the upgrading of terminal facilies, parking

areas, and accessibility infrastructure [ESRS 2: SBM-3_48b].

In this context, the Company takes measures to protect consumers and end-users by

leveraging the results of the Double Materiality Assessment and the Risk Register to inform its

strategy and business model. These measures include infrastructure improvements, sta

training, revision of safety procedures, and strengthening communicaon channels with users,

ensuring that actual and potenal negave impacts on consumers and end-users are directly

incorporated into strategic decisions and resource allocaon [ESRS 2: SBM-3_48 ai, ii].

In the case of PPA S.A., potenal negave impacts on passenger safety and security do not

constute a systemic risk, but mainly concern isolated incidents that may arise from

operaonal failures or extraordinary events. These incidents are addressed through a

comprehensive safety framework. At the same me, any impacts that may arise from

collaboraons with third pares (e.g. service providers or contractors) are managed through

contractual compliance clauses, supervision, and inspecons, ensuring that the required

safety and security standards are met. [S4 SBM3 10b]

Page 306 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Company uses informaon on the impact on consumers and end users, as derived from

comments, complaints, and stakeholder surveys, to adapt its strategy and business model,

enhancing safety, security, trust, and the overall user experience, while relevant risks and

opportunies are recorded and monitored in the Risk Register and through target seng. [S4:

SBM3 9]

Due to the crucial role of the Port of Piraeus as a major transport and passenger hub, the

negave impact on passenger safety and security is considered substanal. These include

accidents and security incidents that may aect passengers, including vulnerable groups. Such

risks can aect safe operaon and may cause service interrupons or damage to the port's

reputaon. Therefore, connuous monitoring and management of these risks is essenal for

decision-making by the Company. [S4: SBM-3_10b]

Potential Negative Impact

Passenger’s Port Operation Safety & Security (Company Specific)

Risks

Failures and Safety Incidents

Policies Related to Consumers and End-Users

Quality, Environmental & Energy Policy

The Company’s Integrated Management System [MDR-P_65 a, b, d]

The Quality, Environmental & Energy Policy of PPA S.A. is a central element of the Company's

business strategy and an integral part of its Integrated Management System. During the

reporng period , the Policy was updated as part of the regular review of the Management

System, without any substanal change in its scope or basic principles, conrming PPA's

commitment to connuous improvement and the provision of safe, reliable, and high-quality

services to all port users, with parcular emphasis on customers and passengers at the

passenger terminal. The Integrated Management System is externally audited and cered,

with the latest standards cercaon renewed in 2025 for a three-year period. The Policy

applies to all of the Company's acvies and applies to business partners and end users,

without restricons on any specic groups. [S4: S4-1_AR9]

The implementaon of the policy is achieved through planning, seng goals, connuous

monitoring and reviews in compliance with ISO 9001, 14001, 50001 & 14064-1 standards and

maintenance of relevant cercaons. The company has developed and maintains PPA’s

Integrated Management System as per ISO 9001, 14001, 50001 & 14064-1 standards.

Companies’ processes and operaons are subject to internal audits conducted at least once a

year, with the results reviewed during the Management Review Report. These standards

include:

• ISO 9001:2015 (Quality Management)

• ISO 14001:2015 (Environmental Management)

• ISO 50001:2018 (Energy Management)

• ISO 14064-1:2018 (Emissions Management)

Page 307 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Adopon of these standards ensures a systemac, transparent, and responsible approach to

port operaons, which enables the company to be proacve, ensuring the provision of high-

quality services to customers and end-users, while controlling and minimising any potenal

impact to the environment and eecvely managing energy consumpon and eciency

aiming at reduced operaonal cost and emissions.

Key Commitments of the Policy [MDR-P 65a]

The policy focuses on enhancing service quality, protecng the environment, and improving

energy performance. Its core commitments that relate to safety, health and security are:

• delivering services that meet the needs and expectaons of customers and port users,

• idenfying, assessing, and managing environmental risks (air, water, soil),

• implemenng measures that support the health and safety of passengers, employees, and

partners,

• establishing robust procedures for emergency preparedness and response,

• raising awareness and providing ongoing training to employees and collaborators,

• promong connuous improvement through monitoring, internal audits, and performance

evaluaon.

PPA’s Policy reects the demands of a complex operaonal environment and ensures that

safety and high-quality service remain central to its mission. As part of its connuous approach

to improvement, the Company has set a strategic objecve to integrate the ISO 45001:2018

standard into the Company’s Integrated Safety Management System. This future cercaon

will further strengthen the Company’s capacity to manage health and safety issues and achieve

connuous improvement of procedures and prevenve measures.

Governance & Accountability [MDR-P 65c]

The Policy is approved by the Top Management and overseen by the Manager of the Quality

Control Department of PPA S.A., who is responsible for:

• regularly reviewing and assessing the performance and eecveness of the Integrated

Management System as per the respecve ISO standards,

• ensuring the availability of resources and mechanisms for compliance,

• seng, monitoring, and assessing quality, environmental, and energy objecves, in

cooperaon with PPA S.A.’s departments which are accountable for the

implementaon of the objecves set.

Compliance and connuous improvement are veried through external audits conducted by

independent cercaon bodies, as well as structured internal audits.

Page 308 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Stakeholder Engagement [MDR-P 65e, 65f]

The Policy is developed and updated by taking into account the expectaons and needs of all

key stakeholder groups. Since it addresses the safety and security of passengers, end users,

and everyone who uses the port facilies, the Policy considers the requirements of passengers

and customers, employees and contractors who contribute to daily operaons. Special

aenon is also given to the guidelines and standards set by port authories and regulatory

bodies. Its public availability reinforces transparency and strengthens stakeholder trust in the

Company’s commitment to responsible, high-quality, and safe operaons.

Complementary Policies [S4: S4-1_15]

In addion to its core Quality, Environmental, and Energy Policy, PPA S.A. has implemented a

set of complementary policies specically addressing the safety and well-being of customers

and end users. These policies cover areas such as corporate governance, ethics, social

responsibility and privacy, and apply inclusively to all consumers and end-users, rather than

targeng specic groups. Together, they create a comprehensive framework that enhances the

protecon, trust, and overall safety of all stakeholders interacng with the port. More details

on the relevant policies can be found on the corporate governance structure secon of the

current Statement.

Policy

Contribuon to Health and Safety of Customers and End

Users

Whistleblowing and

Incident Reporng Policy

Enables prompt reporng and resoluon of safety

concerns and incidents.

An-Harassment and

Workplace Violence Policy

Ensures a safe and respecul environment for all port

users and employees.

Data Protecon and Privacy

Policy

Protects customer data, fostering trust and security for

port users

ESG and Sustainability

Policy

Promote responsible operaons that support a safe and

healthy port environment.

Code of Conduct

Ensures ethical conduct, transparency, compliance —

indirectly supporng safety, trust, fairness and responsible

operaons for all port users.

The section on Policies relating to Business Conduct and Corporate Culture provides details

on the MDR-P 65 a-f indicators.

Page 309 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Human Rights Protecon [S4: S4-1_16a, b, c], [S4:S4-1_17]

PPA S.A. aligns its operaons with the United

Naons Guiding Principles, OECD Guidelines, ILO

Principles and the UN Consumer Protecon

Guidelines. These frameworks guide the

Company’s commitment to protecng passenger

rights, well-being and safety across all services.

Exisng policies already cover key aspects of protecon, while the full integraon of human

rights and customer safety issues into all governance and operaonal processes is in progress.

A Human Rights Assessment is planned to idenfy potenal impacts on passengers and other

users and to inform targeted updates to related policies and safeguards.

Any case of non-compliance with internaonal principles is promptly invesgated, and

relevant ndings are incorporated into the corporate risk registry. Connuous monitoring and

correcve acons ensure that risks to passenger safety and user protecon are eecvely

managed under the established risk management framework. Furthermore, PPA S.A.

integrates end-users into its customer interacon process (see relevant paragraph for S4-20),

ulizing available communicaon channels such as sasfacon surveys, online complaint

forms, the corporate website, email, and telephone hotlines to idenfy actual or potenal

impacts on services. Finally, remediaon procedures are implemented (see relevant paragraph

S4-3 25), which include correcve acons, infrastructure upgrades, sta training programmes

and policy revisions, ensuring the eecve resoluon of grievances and the connuous

improvement of service quality, safety, and accessibility. Insights from risk assessments,

stakeholder feedback and incident reviews are used to update related policies and strengthen

security. This cycle of improvement reinforces PPA’s commitment to responsible operaons

and sustained enhancement of customer and passenger safety.

Legislative and Regulatory Controls and Mechanisms

The Company operates in full compliance with the established legal and regulatory

frameworks governing the health, safety, and protecon of passengers using its terminals.

These frameworks include internaonally-recognised safety standards, cered safety plans,

and strict naonal regulaons, which together ensure eecve protecve measures and

comprehensive preparedness for responding to emergencies.

Holistic port security and preparedness for emergency situations

The Port of Piraeus strictly complies with the Internaonal Ship and Port Facility Security Code

(ISPS) Code, an internaonal regulaon designed to protect ships and port facilies from

security threats. Incorporated into European Regulaon 725/2004, the ISPS Code ensures

harmonised security standards across EU ports.

serious issues or incidents were reported

regarding human rights related to end

users. [S4: S4-4_35].

Page 310 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Under the ISPS Code, PPA develops and maintains cered Port Facility Security Plans (PFSPs)

tailored to each terminal. These PFSPs specify detailed measures for access control,

surveillance, security sta training, and emergency response, ensuring robust and proacve

management of security risks.

PPA S.A. also implements Sea and Land Polluon Emergency Plans aligned with internaonal

and naonal legislaon (OPRC 90, Greek Law 743/1997, PD 11/2002, and the 2000 HNS

Protocol). These plans include annual emergency drills to ensure rapid and coordinated

response to incidents.

Security personnel have undergone specialised training, including cercaon as drone pilots,

supporng the Smart Port iniave to monitor security and detect potenal spillages

eecvely. These combined measures ensure a proacve approach to safeguard passenger

safety and port security.

Passenger Rights Regulation

PPA operates in full compliance with EU Regulaon No. 1177/2010, which safeguards

passenger rights and establishes rules for sea and inland waterway transport. [MDR-P_65_d,

S4:S4-1_17] This regulaon addresses key aspects such as:

• Informaon provision before and during the journey,

• Assistance in case of delay or cancellaon,

• Rights of people with reduced mobility,

• Compensaon and reimbursement procedures.

Through adherence to this regulaon, PPA ensures that passengers receive clear informaon,

fair treatment, and appropriate assistance, reinforcing safety, accessibility, and trust in port

services.

• Addional services supporng passenger welfare at the port include:

• Customer service points and help desks,

• Accessibility features and facilies for people with disabilies,

• Safety and emergency medical services are available throughout passenger terminals.

Page 311 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Processes for Engaging with Consumers and End-Users

Regarding Impacts

Engagement Processes with Clients and Port Users [S4: S4-2 20]

PPA S.A. maintains a structured and systemac approach to engaging with clients and end-

users, designed to ensure connuous feedback, idenfy expectaons, and understand the

actual or potenal impacts associated with its services. Engagement with end-users is carried

out through mulple communicaon channels that enable connuous feedback collecon,

reporng of concerns, and dynamic interacon. These channels support the idencaon of

risks to consumer welfare, accessibility, sasfacon, and safety, and ensure that issues are

addressed in a mely and systemac manner. The table below summarises the engagement

framework of PPA S.A. describing the interacon and the outcome of this process.

Communicaon

Channels

[S4: S4-2 20b]

Interests & Expectaons

of Consumers / End-

Users

PPA S.A. response

[S4: S4-2_20d]

Impact

[S4: S4-2 20d]

Customer

Sasfacon Surveys

• High-quality and reliable

services

• Well-maintained facilies

• Improved passenger

experience

• Annual surveys

• Systemac analysis of results

• Integraon of ndings into

service design

• Operaonal planning

• Service

improvements based

on user input.

• Idencaon of

emerging risks

aecng consumer

experience

Corporate Website

• Transparent, accessible,

up-to-date informaon

• Clear guidance

• Mullingual content

• Regular updates

• Accessible design

• Downloadable documents

from the Company’s ocial

website

• Equal access to

informaon.

• Informaon gaps

could impact

consumer

understanding

Online Complaint

Forms

(Grievance

Mechanisms)

• Easy submission of

complaints

• Fair and mely resoluon

• Clarity in procedures

• Dedicated digital grievance

mechanism

• Categorisaon and tracking

of complaints

• Correcve measures

implemented

• Strengthened

accountability &

transparency

• Complaints reveal

areas needing

improvement

• Early detecon of

consumer harm

Communicaon

(clientservice@olp.gr

olp@olp.gr)/

Customer Service

Phone Lines

• Direct access to

informaon

• Personalised guidance

• Quick response

• Real-me informaon

• Ecient crisis response

• Connuous monitoring of

email channels

• Maintained response-me

standards

• Escalaon for complex cases

• Dedicated support lines

• Published emergency

contacts

• Enhanced

accessibility and

responsiveness

• Avoidance of delayed

responses that may

aect sasfacon

• Strengthened safety

and user condence.

• Possible delay if call

volume is high

Page 312 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Company maintains connuous engagement with its stakeholders throughout the year via

mulple communicaon channels. Engagement can take various forms, including consultaon

and informaon provision, with the frequency depending on the channel. The results of

engagement are incorporated into key stages of risk management, such as risk idencaon,

migaon approach determinaon, and eecveness assessment. [S4-2 20b].

The secon “Policy and Complaints Management Procedures” describes the mechanism for

subming and handling complaints, as well as the stages of their processing. It also species

the operaonal responsibility and oversight of the engagement process. [S4: S4-2_20 c]

To further enhance engagement, the Company operates a Port Users Council. This enables

users to contribute to improving services by recording any needs and issues that arise. [S4-5

41 a, b, c]

Complementary Enabling Mechanisms

The Company also engages indirectly with clients, passengers and end users through its

relaonships with B2B / intermediary client companies (e.g., cruise operators, ferry

companies, and other commercial partners), which act as intermediaries conveying the needs,

expectaons, and concerns of their passengers and end-users. This enables PPA S.A. to capture

broader stakeholder perspecves, including those of client groups with limited direct

interacon with the Company. Further, PPA’ s S.A. clients have access to valuable informaon

through annual surveys and assist in the idencaon, monitoring and understanding key

concerns and expectaons. [S4: S4-2 20a]

To strengthen structured and transparent stakeholder communicaon, the Company iniated

one more communicaon channel by developing and conducng a comprehensive

Stakeholder Engagement Quesonnaire in 2024–2025. The survey is repeated for the 2025 –

2026 period similarly conveys the Company’s ESG material topics while gathering the

perspecves, expectaons, and concerns of various stakeholder groups. The insights collected

are systemacally integrated into decision-making processes, supporng strategic planning,

ESG priorisaon, and connuous enhancement of stakeholder engagement.

Processes for Remediang Negave Impacts and Channels for

Raising Concerns by Consumers on Behalf of End-Users

Complaints Management Policy and Procedures

Adherence to Regulaon (EU) No. 1177/2010 is essenal for ensuring the rights of passengers

in marime and inland waterway transport. This includes provisions for compensaon,

assistance, and eecve complaint handling in cases of disrupons, discriminaon, or

accessibility issues. These measures are in place to protect cruise and ferry passengers by

ensuring that any concerns are addressed appropriately. In the event of recurring problems or

serious concerns, correcve measures such as infrastructure improvements, training

programmes, and policy reviews are implemented to improve quality, safety, and accessibility.

[ S4: S4-4 32b, S4: S4-3 26 AR23]

Page 313 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

PPA S.A. provides a comprehensive grievance mechanism that enables clients, end users,

visitors, and the wider community to submit complaints, concerns, or issues directly.

Complaints can be submied via a dedicated email (clientservice@olp.gr) or through an online

complaint form specically designed for cruise passengers, accessible via the corporate

website. [S4: S4-3 25b] The Code of Ethics of PPA S.A. supports the responsible management

of business relaonships, promong transparency, accountability, and compliance with the

Company’s policies, including complaint-handling procedures for clients and end users. [S4:

S4-3_25c]

This ensures an accessible, transparent, and user-friendly process for raising concerns related

to port services, accessibility, safety, or other relevant maers. For complex cases requiring

remediaon or further acon, the Deputy Chief Execuve Ocer is responsible for escalang

the issue to the Risk Register, where it is assessed and addressed through the Company's due

diligence procedures. [S4:S4-2 20c]

The steps of the complaint handling process include [ S4: S4-3 25 a,b,c,d]:

BUSINESSThe Company ensures the condenality and anonymity of complaints through

secure submission channels. [S4: S4-3 AR22]

34 Complaints

recorded in 2025

[S4: S4-3 AR22]

• 97% used email as a

communicaon

channel

• 3% used social

media

23.5% of

complaints

have been

resolved

Correcve acons

are planned for

29.4% of the

complaints

1 complaint

relates to

health issues

and 3 to

safety

issues.

Any complaints not resolved within the reporng period are under invesgaon and

monitored unl a resoluon is found. The eecveness of the mechanism is assessed on the

basis of specic indicators, such as the complaint resoluon rate, the average response and

handling me, and the rate of implementaon of correcve acons. [S4: S4-4 32c]

Page 314 από 437

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(amounts in Euro unless stated otherwise)

Through these integrated mechanisms, the Company builds a transparent, accountable, and

client-focused grievance management system that strengthens risk migaon, enhances

stakeholder trust, and ensures connuous improvement in addressing negave impacts on

consumers and end-users.

Whistleblowing Policy for Safety and Operaonal Concerns [MDR-P 65a]

In addion to the standard compliance and complaints-management mechanisms described

above, the Company also applies a dedicated “Whistleblowing Policy and Procedure for the

Management of Reports/Complaints”, which enables the reporng of a broad spectrum of

concerns, including operaonal irregularies, safety deciencies, service -quality failures,

unethical behavior, or any condion that may pose a negave impact or risk for passengers,

port users or the wider environment. Through this policy and its reporng mechanism

facilitated via (i) electronic submission channels, (ii) dedicated email contact, and (iii) the

opon for direct reporng to authorised ocers, the Company ensures that all potenal risks

and adverse impacts are idened, assessed, and addressed promptly and eecvely, while

end-users are protected from retaliaon, in accordance with the safeguards set out in the

Policy. [MDR-A_68a]

The Company also regularly assesses that consumers and end users are aware of and trust the

available reporng structures through awareness measurements, channel usage rates,

customer sasfacon surveys, analysis of recurring complaints, and resoluon rates within

predetermined me limits. These assessments ensure that the reporng process is eecve

and supports the integrity of port operaons. [MDR-A_68c]

Other negave impacts and risks: Customer Privacy Management

Procedures

During the materiality assessment, the Company idened a potenal negave impact related

to customer privacy and data protecon. However, this sustainability maer is not classied

as material. For the Company privacy and data protecon remain crical issues, as signicant

volumes of sensive operaonal data are processed daily. The Privacy Policy of the Company

reets its commitment to connuous evaluaon of its services.

PPA S.A. complies with EU and naonal legislaon, including the General Data Protecon

Regulaon (GDPR), supported by a dedicated Data Protecon Ocer, compliance

management pracces, and Data Protecon Impact Assessments (DPIA) across various

acvies. The Company remains dedicated to ongoing service assessments and maintains

open communicaon channels to ensure the prompt handling of any emerging issues.

The section on Policies relating to Business Conduct and Corporate Culture provides details

on the MDR-P 65 a-f indicators.

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(amounts in Euro unless stated otherwise)

The Company is commied to the management of customer privacy and data through its

compliance policies, such as the Whistleblowing Policy and due diligence procedures. These

policies ensure the connuous monitoring, evaluaon, and improvement of data protecon

procedures, as well as the informaon and training of employees, customers, and partners on

privacy rights and the proper use of personal data.

Furthermore, the Policy is aligned with the due diligence procedures implemented for the

safeguarding of customer rights and ensures the idencaon and eecve migaon of

operaonal risks.

Taking acon on material impacts on consumers and end-

users, and approaches to managing material risks

PPA S.A. applies a holisc and systemac approach to safeguarding the health, safety and

well-being of customers and end users. [MDR-A 68b] The Company’s prevenon and

migaon framework is grounded in clear governance mechanisms, standardised procedures

and dedicated operaonal pracces. . [MDR-A_68a]

Governance and Systematic Controls

• Code of Conduct seng principles for responsible behavior and the protecon of

stakeholder interests. [S4: S4-5 33a, MDR-A_68 a]

• ISO 9001:2015-cered Quality Management System ensuring standardised processes,

quality controls and connuous improvement. [S4: S4-5 33a, MDR-A_68 a]

• Quality Policy integrang structured procedures for monitoring performance and

implemenng correcve acons. [S4: S4-5 _33 a, MDR-A_68 a, c]

• Compliance framework and Whistleblowing Procedure enabling secure reporng,

invesgaon and remediaon of incidents that may negavely aect customers and end-

users. [S4: S4-5_33 a, MDR-A_68 d]

• Risks related to consumers and end-users, such as passenger safety and health, are

incorporated into the Company's Risk Register as part of the Integrated Management

System. This allows for the systemac idencaon, assessment, and monitoring of

relevant risks, ensuring that any negave impacts on users are addressed in a

comprehensive and consistent manner and that the results of monitoring shape strategic

decisions and process improvements. [S4: S4-5 33a]

• Training programmes for employees, including service standards, safety, accessibility and

ESG-related consumer topics, enhancing the Company’s capacity to idenfy, prevent and

address potenal negave impacts. [S4: S4-5 34, MDR-A_68 a]

• Targeted training on accessibility and assistance for vulnerable passenger groups,

delivered in collaboraon with the Instute of the Naonal Confederaon of Persons with

Disabilies and Chronic Condions (IN-ESAMEA), providing over 1,000 employees with

specialised theorecal and praccal training on serving passengers with disabilies,

chronic condions and reduced mobility.

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(amounts in Euro unless stated otherwise)

The programme strengthens employees’ capacity to prevent exclusion, service failures

and safety risks, and supports the systemac integraon of inclusiveness principles into

daily operaons. [S4: S4-5_34, MDR-A_68 a,c]

• Ensuring fair treatment, accessibility, and established mechanisms for compensaon,

assistance, and complaint handling, within the framework of the applicaon of the

Regulaon on Passenger Rights (EU 1177/2010). [S4: S4-5 34, MDR-A_68 d]

• Internal and external audits verifying adherence to standards and supporng connuous

enhancement of control and migaon processes. [S4: S4-5 33a, MDR-A_68 e]

Operational Safety and Emergency Preparedness

PPA S.A. maintains approved Emergency Response Plans for marine and land polluon in

alignment with OPRC 90, Law 743/1997, Presidenal Decree 11/2002 and the 2000 HNS

Protocol. Annual emergency drills are conducted to test readiness and ensure coordinated

response in case of an incident. [MDR-A_68 a]

The Security Department has introduced system improvements to enhance the eciency and

safety of cruise passenger screening, including upgrades to X-ray equipment at the Cruise

Terminal. [S4:4 31d, MDR-A_68 a, MDR-A_69a] Addional prevenve measures include the

installaon of mobile warning signs to reduce accident risks and informaonal signage at ferry

terminal entries to guide vehicles and passengers, reducing congeson and enhancing safety.

[MDR-A_68 a, b] Collaboraon with the Piraeus Health Services connues to support

prevenve emergency readiness across port operaons. [S4:4 31a, b]

Security personnel have been trained as cered drone operators, strengthening monitoring,

surveillance and early detecon capabilies under the Smart Port iniave. In cooperaon

with local authories, the Company also supports the safe relocaon of homeless individuals

to designated facilies, whenever a need arises during the year. [S4: 4 31c, MDR-A_68 a, c,

MDR-A_69 a]

The Car Terminal operates on a 24/7 basis with trained sta and connuous security

supervision, achieving an almost zero-damage rate. ISPS Code compliance, favourable

operang condions and the availability of specialised equipment support safe vehicle

handling and eecve response to customer needs. [MDR-A_68 a, MDR-A_69 a ,b]

Page 317 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Targets related to managing material negave impacts,

advancing posive impacts, and managing material risks and

opportunies

PPA S.A. is responsible for determining the appropriate acons to address actual or potenal

negave impacts on consumers and end-users. This determinaon is made based on a

combined assessment of the risk analysis, the results of the Double Materiality Assessment

(DMA), and the idencaon of important issues in accordance with the Company’s ESG and

Sustainability Policy, concerning safety and accessibility. [MDR-T_80a]. The aforemenoned

factors, when considered in conjuncon with the objecves derived from the ISO 9001:2015,

ISO 14001:2015, ISO 50001:2018, and ISO 14064-1: 2018 standards, the commitment to

connuous improvement of the safety, protecon, and sustainability of operaons and taking

into account the results of the annual stakeholder survey [MDR-T h], serve as a guide for the

connuous adaptaon of mechanisms, policies, procedures, and feedback and complaint

management systems. In this parcular context, specic acons and objecves are dened,

with the aim of eecvely addressing the idened impacts and improving the experience of

all pares involved. [S4: S4-4 32a], [MDR-T_80 f]. The base year for these targets has been

set as 2024. [MDR-T_80 (d)] Furthermore, no changes have been made to targets,

methodologies, or assumpons [MDR-T 80 (i)], and no scienc evidence has been used for

their creaon [MDR-T 80 (g)], as the related processes are at an early stage of development

and maturaon. The Company did not set targets for the reporng period for the material

topic ‘Failures and safety incidents’ as the integraon of these targets is sll in progress [MDR-

T_81]

Each department, aligned with ISO 9001:2015 and ISO 14001:2015 requirements, sets and

monitors specic targets and KPIs. In a similar manner, improvement targets are set for energy

management and emissions management within the framework of ISO 50001 and ISO 14064-

1:2018. The incorporaon of these targets form part of PPA S.A.’s annual target-seng and

strategic planning framework, through which the Company strengthens operaonal eciency,

migates material risks, and proacvely addresses emerging challenges across all business

units [MDR-T_80c]. Regarding the material issue of health and safety at the passenger port,

the Cruise and Ferry Department oversees relevant targets and tracks performance to improve

service quality, passenger experience, and operaonal safety. [S4: S4-4 32a, MDR-T_80j]

The 2024 targets sll acve in 2025 include managing specied volumes of vessels, passengers,

and vehicles, expanding infrastructure, and opmising operaonal ows. Planned upgrades

involve new screening equipment, modernisaon of weighbridges, mechanical system

improvements, and facility enhancements. Addional measures in ferry areas focus on

terminal upgrades, shelter installaons, trac management, and strengthened safety, lighng,

and signage. Accessibility is priorised through new parking spaces, facility upgrades, and an

accessibility study. Internal processes are opmised by revising operaonal pracces,

enhancing stang, and strengthening customer communicaon through regular meengs to

collect feedback and promptly address issues. [S4: S4-4 31c, S4: S4-4 32b, MDR-T_80 d, e]

Page 318 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

To achieve the above, PPA S.A. is implemenng an investment plan focused on strengthening

operaonal capacity and enhancing health, safety and security condions for customers and

end users. In this context, the Company has planned the following key investments. [S4:S4-4

37]:

Construcon of a new cruise passenger terminal, with a budgeted cost of 55 m€.[MDR-A_69

a, MDR-T_80 i]

Construcon of two car-park buildings in the G2 area, with a budgeted cost of 27 m€. [MDR-

A_69 a, MDR-T_80 i]

The nancing and allocaon of resources for these projects ensure the mely implementaon

of acons and the achievement of the Company’s objecves, as well as the connuous

monitoring of their progress. [MDR-A_69 b, c]

In this context, the following table presents the corporate targets set in 2024, together with

the performance achieved in 2025 [S4:S4-4 30]. When seng targets, the Company takes into

account comments, recorded incidents and complaints. Furthermore, stakeholder surveys

enable customers to provide recommendaons and feedback regarding topics material to the

Company and its management approaches. Progress toward achieving these targets is

analycally presented within the annual sustainability reports, ensuring transparency. [MDR-

T_80 j]

The targets included in the table below are not quaned [MDR-T_80 b, MDR-M_75, MDR-

M 76, MDR-M 77 (c)].

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Table of Targets and Acons

Passenger Safety

IRO

Acons

[MDR-A_68 a]

Target

[MDR-T_80b]

Year

[MDR-

A_68 c

/ MDR-

T_80 e]

Scope of

Coverage

[MDR-A 68b

/ MDR-T

80c]

KPIs

[MDR-A_68 e/

MDR-T_80 b/

MDR-M_75]

Progress by 2025

[MDR-A_68 e /

MDR-T_80 j]

Passenger

Safety &

Protecon

(Company-

specic

topic)

Conducng an accessibility assessment for

persons with reduced mobility.

Developing an acon plan based on the

results.

Conducng an accessibility assessment for

persons with reduced mobility.

Improving accessibility for

groups with special needs

throughout the port

2027

downstream

Percentage of

end users with

special needs

In progress / 10% of

the target completed

Reconstrucon of concrete stairs

Installaon of steel stairs and LED solar

lighng with poles on the walls of the

central port quay

Enhancement of safety

Ongoing

2025

downstream

N/A

100% achieved

Trac management at cruise terminals to

reduce congeson and accident risk

Restructuring of parking areas

Proacve approach for

maintaining the health,

safety, and protecon of all

visitors to the Port of

Piraeus

2027

downstream

N/A

In progress / 10% of

the target completed

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(amounts in Euro unless stated otherwise)

Eco-friendly buses

Passenger transport within

the port, with zero

emissions

2028

downstream

Reducon of

carbon footprint

In progress / 5% of

the target completed

Interacon with end users

Collaboraons with direct

customers to collect

feedback from end users

2028

downstream

Number of

parcipang

companies

No progress recorded

Updang the website to

provide informaon

(passenger rights, complaint

submission form, useful

phone numbers) to end

users for ships, similar to

the informaon provided to

cruise ship passengers.

2025

downstream

List of feedback

categories from

end users

100% achieved

Human rights assessment by the UN

Integraon of human rights

risk into the risk register

2027

downstream

Number of human

rights violaons

100% achieved

downstream

Number of

complaints related

to human rights

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(amounts in Euro unless stated otherwise)

downstream

Number of

organizaonal

funcons exposed

to human rights

violaon risk

Review and update of

policies based on human

rights assessment and risk

integraon

2027

downstream

100% achieved

Parcipaon in Global

Compact Greece

2027

downstream

No progress recorded

At the indicator level, no specific methodologies or assumptions have been used [MDR-M_77 (a)] and no external body has been involved to validate the metrics used

[MDR-M 77 (b)].

The budget of the above actions is estimated at €5,255,000, of which €5,160,000 is CAPEX and €95,000 is OPEX. For the reporting period, €117,000 has been implemented,

while the remainder of the actions will be completed in the future based on a schedule. [MDR-A_69]

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(amounts in Euro unless stated otherwise)

ESRS-G1 Business Conduct

ESRS G1-1 – Business conduct and corporate mindset policies, ESRS G1-2 –

Management of supplier relationships, ESRS G1-3 – Prevention and detection of

corruption and bribery, ESRS G1-4 – Incidents of corruption or bribery

G1-1 Policies related to business conduct and corporate culture

PPA S.A. maintains a comprehensive framework of business conduct policies that establish

clear expectaons for ethical behavior, integrity, and transparency across all levels of the

Company. These policies include the Code of Conduct, the An-Corrupon and An-Bribery

Policy, the ESG and Sustainability Policy, and the Whistleblowing Policy and Procedure.

Together, they form the foundaon of the Company’s corporate culture and ensure

responsible behavior consistent with legal obligaons, internaonal standards, and

stakeholder expectaons [G1-1_7],[G1-1_9].

Following the results of Double Materiality Assessment conducted for the year 2025, PPA S.A.

idened updated material impacts, risks and opportunies (IROs) related to the topic of

business conduct. As required by ESRS 2 IRO-1, the idencaon process considered all

relevant criteria, including the nature of the Company’s acvies, operaonal locaons, sector

characteriscs and the structure of underlying transacons [G1.IRO-1 6]

The Double Materiality Assessment idened twelve (12) material IROs:

Actual Posive Impact

Stakeholder Trust

Risks in relaon to business conduct maers

Cybersecurity Threats

Geopolical Externalies & Domesc Polical Environment (Company Specic)

Supplier / Contractor Selecon Risk

Opportunies in relaon to business conduct maers

Operaonal Procedures and Controls

Technology and Digital Transformaon

Access to Green Investment

Compeve Advantage and Regional Leadership

Robust Governance and Risk Management

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(amounts in Euro unless stated otherwise)

Each IRO is further discussed under the relevant subsecon of this ESRS topical disclosure

requirement through the lens of business conduct and corporate culture. The relevant

descripon and strategic discussion of all PPA S.A.’s IRO is available in ESRS 2 segment of this

Report.

Policies related to business conduct and corporate culture

[ESRS2.GOV-1_22b, G1-1_7, G1-1_9, G1-1_10a, G1-3_18c]

Internal Operaon Regulaon

The Internal Operang Regulaon of the company outlines the Company’s organisaonal

structure, governance bodies, commiees, internal control mechanisms, and key procedures

required by laws 4706/2020, 4548/2018, 3016/2002 and the EU Regulaon 596/2014. It sets

objecves related to eecve corporate governance, regulatory compliance, risk management,

prevenon of conicts of interest, transparency in related-party transacons, proper handling of

condenal informaon, and structured procedures for hiring, evaluang, and training senior

execuves [G1.MDR-P_65a].

It applies to all Company acvies, departments and commiees without stated exclusions, and is

monitored through the BoD , the CEO, the Audit Commiee, the Internal Audit Department, the

Risk Management Unit, the Regulatory Compliance Unit and other standing commiees, each

reporng as required. [G1.MDR-P_65b,c].

The Regulaon references third-party standards including MAR, IAS 24 and IAS 27, HCMC

decisions, internaonal internal audit standards and environmental terms issued by naonal

authories. [G1.MDR-P_65d].

Stakeholder interests are considered primarily through requirements relang to shareholders,

regulatory authories, investor relaons, whistleblowing and environmental compliance, although

no consultaon process is explicitly described. [G1.MDR-P_65e].

The Regulaon is made available internally and, where required, through the Company’s ocial

website, supporng its disseminaon to all responsible and aected stakeholders [G1.MDR-

P_65f].

BoD Regulaon

The BoD Regulaon of the company denes the responsibilies, composion, operaon and

internal governance of the Board, in accordance with Laws 4548/2018, 4706/2020, 4449/2017 and

other applicable provisions. It sets the roles of execuve and non-execuve members, including

independent members, and outlines obligaons relang to strategy-seng, nancial informaon

and sustainability reporng internal control, risk management, compliance, succession planning,

and supervision of corporate funcons. [G1.MDR-P_65a]

The Regulaon applies to all Board members and Board Commiees without exclusions. It

establishes the structure, mandate and obligaons of the Audit Commiee, the Remuneraon

Commiee and the Nominaon Commiee, as explicitly dened in Arcle 16 of the Regulaon.

[G1.MDR-P_65b,c]

References to third-party standards and bodies appear explicitly in the Regulaon, including

statutory audit requirements under Law 4449/2017, interacons with the Hellenic Capital Market

Commission, and obligaons relang to nancial reporng and internal control as required by

applicable legislaon. [G1.MDR-P_65d]

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(amounts in Euro unless stated otherwise)

Stakeholder consideraons are addressed exclusively through legally mandated interacons,

including disclosures to shareholders, the General Assembly, the Hellenic Capital Market

Commission and G.E.MI., as explicitly described in the Regulaon. No consultaon process with

other stakeholders is provided for. [G1.MDR-P_65e]

The Regulaon becomes eecve upon Board approval and amendments are made by Board

decision, and is made available through the Company’s ocial website, ensuring access by all

stakeholders. [G1.MDR-P_65f]

Audit Commiee Regulaon

The Audit Commiee Regulaon denes the operaon of the Audit Commiee as a commiee of

the BoD, established in accordance with laws 3016/2002, 4449/2017, 4706/2020, the relevant

circulars of the Hellenic Capital Market Commission and decision 1/891/30.09.2020, seng out its

role in supporng the BoD in overseeing statutory audit, nancial reporng, the Internal Control

System, Risk Management and Regulatory Compliance. It species the Commiee’s objecves,

including monitoring the statutory audit process, reviewing nancial informaon procedures,

assessing the adequacy and eecveness of internal controls, ensuring the independence and

performance of external auditors, supervising the Internal Audit Department, Regulatory

Compliance and Risk Management funcons, and subming an Annual Acvity Report to the

General Assembly [G1.MDR-P_65a].

The Regulaon applies across all acvies of PPA S.A., with no exclusions [G1.MDR-P_65b], and

grants the Commiee unrestricted access to informaon, the ability to engage external advisors

and the necessary resources to full its responsibilies. Implementaon responsibility lies with the

Audit Commiee itself, composed of at least three members of the Board of Directors, the majority

independent, and chaired by an independent member with proven audit or accounng experse,

supported administravely by the Secretariat of the Board [G1.MDR-P_65c].

The Regulaon explicitly references Law 3016/2002, Law 4449/2017, Law 4706/2020, Regulaon

(EU) 537/2014, Capital Market Commission circulars 1302/2017 and 1508/2020, and decision

1/891/30.09.2020 [G1.MDR-P_65d]. While no explicit stakeholder consultaon is referenced,

stakeholder interests are indirectly safeguarded through statutory compliance, internal control

eecveness and the integrity of nancial reporng [G1.MDR-P_65e].

The Regulaon enters into force upon approval by the Board of Directors and is made publicly

available through publicaon on the Company’s ocial website [G1.MDR-P_65f].

Remuneraon Commiee Regulaon

The Remuneraon Commiee Regulaon sets out the role, scope, responsibilies, composion

and operang procedures of the Remuneraon Commiee of PPA S.A., as approved by BoD

decisions 31/16.07.2021 and 48/22.12.2022. The Regulaon denes the Commiee as an

independent and objecve body that assists the BoD in maers related to remuneraon, including

the Remuneraon Policy and Remuneraon Report under Arcles 109–114 of Law 4548/2018, and

outlines its dues such as subming proposals on the Remuneraon Policy, reviewing the annual

Remuneraon Report, recommending performance targets for variable remuneraon, assessing

stock opon plans, and advising on improvements to remuneraon processes [G1.MDR-P_65a].

The Regulaon applies to all remuneraon-related acvies of the Company with no exclusions

and grants the Commiee full access to necessary informaon, as well as the ability to request

external advisors through the BoD [G1.MDR-P_65b].

The Commiee consists of three non-execuve BoD members, the majority independent under

law 3016/2002 and law 4706/2020, chaired by an independent non-execuve member, and

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supported administravely by a designated Secretary, meeng at least twice per year or as

required [G1.MDR-P_65c].

The Regulaon refers to the applicable legal framework, namely law 4548/2018 and Law

4706/2020 [G1.MDR-P_65d].

While it does not provide for stakeholder consultaon, it ensures transparency through obligaons

for minute-keeping, reporng to the BoD and informing shareholders at the Annual General

Meeng [G1.MDR-P_65e].

The Regulaon is published on the Company’s ocial website and may be amended only by

decision of the Board of Directors [G1.MDR-P_65f].

Nominaon Commiee Regulaon

The Nominaon Commiee Regulaon denes the role, scope, responsibilies, composion and

operang procedures of the Nominaon Commiee of PPA S.A., as approved by BoD decisions

29/16.07.2021 and 47/22.12.2022. The Regulaon establishes the Commiee as an independent

and objecve body that assists the BoD by ensuring lawful and eecve composion, structure

and operaon of the BoD, by overseeing transparent nominaon procedures, and by assessing the

mix of knowledge, skills, experience, diversity and suitability of BoD Members. The Regulaon

outlines detailed responsibilies, including reviewing the Suitability Policy, preparing inducon and

training programmes, evaluang Board structure and eecveness, assessing independence and

conicts of interest, maintaining a target prole matrix, monitoring diversity, reviewing succession

planning for senior execuves, assessing nominaon processes, and recommending changes to

the organisaonal chart [G1.MDR-P_65a].The Regulaon applies fully across all nominaon and

suitability maers without exclusions and requires the Commiee to have full access to

informaon, to collaborate with relevant internal funcons and other BoD Commiees, and to

request external advisors through the BoD when required [G1.MDR-P_65b].

It species that the Commiee consists of three non-execuve BoD members, the majority

independent under law 3016/2002 and law 4706/2020, chaired by an independent non-execuve

member, meeng at least twice annually or as needed, and supported by a designated Secretary

keeping minutes [G1.MDR-P_65c].

The Regulaon refers to the applicable legal framework, including Law 4706/2020 and Law

4548/2018 [G1.MDR-P_65d].

Transparency is ensured through minute-keeping, reporng to the BoD for Corporate Governance

disclosures and compliance with internal rules [G1.MDR-P_65e].

Amendments may only be made by decision of the BoD, and the Regulaon is published on the

Company’s ocial website [G1.MDR-P_65f].

Strategy Commiee Regulaon

The Strategy Commiee Regulaon of PPA S.A. denes the role, scope, responsibilies,

composion, and operang procedures , as approved by BoD 71/28.11.2025. The Regulaon

establishes the Commiee as an independent and objecve body that advises the Company's

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(amounts in Euro unless stated otherwise)

Management and BoD, in accordance with the provisions of its Regulaon, on maers relang to

the Company's general strategy, and specically on strategic issues relang to sustainability, new

technologies, and innovaon, including the Company's digital transformaon and sustainability

through innovave technologies. The Commiee has a total number of members as determined

from me to me by the Board of Directors. Members of the Company's BoD may be elected as

members of the Commiee and, by decision of the Board of Directors, the composion of the

Commiee may also include members of Senior Management (DCEO level). The Commiee

convenes at least twice a year, or more frequently as required, in order to fulll its mission. The

Regulaon is available on the Company's ocial website and may only be amended by a decision

of the BoD following a recommendaon by the Commiee. [G1.MDR-P_65a-f]

Diversity Policy of BoD Members

The Policy promotes diversity on the (BoD) by emphasising gender representaon, professional

qualicaons, and skills balance, seng a minimum gender representaon threshold of 33% in

line with law 4706/2020, as amended by law 5178/2025, and specically the provisions on gender

balance on Boards of Directors [G1.MDR-P_65a]

It applies to the nominaon, selecon, and assessment of BoD members at PPA S.A. [G1.MDR-

P_65b]

The Nominaon Commiee is responsible for monitoring compliance and proposing updates

[G1.MDR-P_65c] The Policy complies with Law 4706/2020, as amended by law 5178/2025, and

follows internaonal best pracces for corporate governance [G1.MDR-P_65d]

Progress on diversity objecves is reported annually in the Annual Financial Statement, specically

in the Statement of Corporate Governance [G1.MDR-P_65e]

The Policy is publicly accessible and published on the Company’s ocial website [G1.MDR-P_65f]

Succession Planning Policy for BoD Members & Execuve Ocers

This Policy establishes a structured process for succession planning to ensure leadership connuity,

covering the nominaon, assessment, and replacement of BoD members and execuve ocers

[G1.MDR-P_65a].

It applies to all BoD members and senior execuve posions at PPA S.A. [G1.MDR-P_65b]

The Nominaon Commiee oversees the implementaon and compliance with this Policy

[G1.MDR-P_65c].

The Policy ensures transparency through regular assessments and reporng of leadership

connuity pracces [G1.MDR-P_65e].

The Policy is publicly accessible and published on the Company’s ocial website [G1.MDR-P_65f].

Suitability-Eligibility Policy of BoD Members

This Policy denes the principles and criteria for selecng, replacing, and assessing the suitability

of BoD members, with a focus on ethics, diversity, and professional qualicaons [G1.MDR-P_65a]

It applies to all BoD members at PPA S.A. [G1.MDR-P_65b], and its oversight and compliance are

the responsibility of the Nominaon Commiee. [G1.MDR-P_65c]

The Policy aligns with law 4706/2020, as amended by law 5178/2025, the Hellenic Corporate

Governance Code, and law 4449/2017 [G1.MDR-P_65d]

It is disclosed through the Annual Financial Statements in the Statement of Corporate Governance

and is part of the ocial governance framework [G1.MDR-P_65e] The Policy is publicly accessible

and published on the Company’s website [G1.MDR-P_65f]

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Training Policy for BoD Members and Senior Execuves [G1-1_10g]

This Policy sets out the key principles, objecves and procedures governing the inducon,

orientaon and connuous training of Board members and other Covered Persons involved in

internal control, risk management, regulatory compliance and informaon systems, ensuring they

possess the skills and competencies required to full their responsibilies eecvely [G1.MDR-

P_65a] The Policy applies to all members of the Board of Directors and designated Company

Execuves without exclusions, covering both newly appointed and exisng members [G1.MDR-

P_65b] Oversight and accountability for the implementaon of the Policy rest with the highest

governance level, including the Board, its Commiees and Senior Management [G1.MDR-P_65c]

The Policy is publicly available through the Company’s Internal Operaon Regulaon, which is

available through the Company’s website [G1.MDR-P_65f]

Code of Conduct

The Code outlines the principles of integrity, transparency, an-corrupon, and fair business

pracces, ensuring compliance with laws and covering rules on gis, conicts of interest, and

whistleblowing [G1.MDR-P_65a]

It applies to all employees, management, contractors, and business partners involved in PPA S.A.’s

operaons [G1.MDR-P_65b] The Internal Audit Department and Regulatory Compliance Unit

oversee implementaon and adherence to the Code [G1.MDR-P_65c]

The Code aligns with Law 4706/2020 and the Hellenic Corporate Governance Code, which is

adopted by the Company [G1.MDR-P_65d]

It is communicated through sta training, internal announcements, and disclosures available to

stakeholders [G1.MDR-P_65e]

The Code is publicly accessible and published on the Company’s ocial website [G1.MDR-P_65f]

Code against Corrupon and Bribery

TheCode denes corrupon and bribery and their various forms while outlining the Company’s

expectaons regarding compliance. Employees and associates must adhere to the Code’s an-

corrupon and an-bribery requirements, follow Company procedures, maintain due diligence in

transacon recording, and ensure compliance with legal, condenality, and conict of interest

Policies [G1.MDR-P_65a]

The Code applies to all Company personnel, external associates, suppliers, and contractors, unless

other relevant laws apply to the laer [G1.MDR-P_65b] The Audit Commiee rst approved the

Code, while the Board of Directors is responsible for its review [G1.MDR-P_65c]

The Code aligns with naonal legislaon, the Treaty of the European Union on ghng corrupon

(EE C 195 of 25.6.1997, 0.1), the Council Framework Decision on combang corrupon in the

private sector (EE L 192 of 31.7.2003, 0.54), and internal regulaons of PPA S.A. [G1.MDR-P_65d]

It is communicated to employees and external associates to ensure compliance [G1.MDR-P_65e]

and is available on the Company’s intranet [G1.MDR-P_65f, G1-3_20]

Whistleblowing Policy and Procedure

The Whistleblowing Policy and Procedure establishes a structured internal reporng system for

managing complaints related to violaons of EU law and company policies, ensuring whistleblower

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(amounts in Euro unless stated otherwise)

protecon, with a specic procedure set out in arcles 11 and 12 of the Policy, and non-retaliaon

safeguards [G1.MDR-P_65a] [G1-1_10a] [G1-1_10c(i)[G1-1_10c(ii)]

It applies to all employees, members of the BoD, members of the Top Management, shareholders,

clients, users, contractors, suppliers, and third pares who collaborate or provide services to the

Company [G1.MDR-P_65b]

The Manager of the Risk Management Unit is responsible for receiving and monitoring

reports/complaints (Whistleblowing responsible) and is supported by the Data Protecon Ocer

[G1.MDR-P 65a] [G1.MDR-P_65c]

The Policy aligns with law 4990/2022, EU Direcve 2019/1937, and the General Data Protecon

Regulaon (GDPR) [G1.MDR-P_65d] [G1.G1-1_11] It is communicated through internal channels,

(either via email or via the corporate portal) to all employees, members of theBoD, members of

the Top Management, shareholders, customers, users, contractors, suppliers and third pares,

while training and clear instrucons are provided on how to submit both named and anonymous

reports [G1.MDR-P_65e] [G1-1_10c(i)][G1-3_20]

The Policy is publicly accessible and published on the Company’s ocial website [G1.MDR-P_65f]

ESG and Sustainability Policy

The ESG and Sustainability Policy guides PPA S.A. in operang responsibly, ethically and sustainably

by integrang environmental stewardship, social responsibility and sound governance into its

business pracces. It conrms compliance with applicable regulaons while addressing

stakeholder expectaons, migang climate and environmental impacts, strengthening social

dialogue and upholding ethical conduct, thereby supporng long-term value creaon, resilience

and posive contribuons to society and the environment [G1.MDR-P_65a]

The Policy outlines the Company’s sustainability principles, objecves and procedures and applies

to all acvies of the Port of Piraeus, binding employees, contractors, partners and third pares

acng on behalf of PPA S.A. [G1.MDR-P_65b]

The ESG Commiee serves as the Policy Owner, overseeing sustainability-related frameworks and

compliance measures [G1.MDR-P_65c]

The Policy aligns with internaonal standards and iniaves, including the ILO, ISO 9001:2015, ISO

14001:2015, ISO 50001:2018 and ISO 14064-1:2018 [G1.MDR-P_65d]

Through the double materiality process, stakeholder perspecves are assessed to ensure that the

Policy remains responsive to evolving needs and expectaons [G1.MDR-P_65e]

It further aligns with relevant third-party standards and iniaves [G1.MDR-P_65d] and is publicly

available on the Company’s ocial website [G1.MDR-P_65f]

The Privacy Policy of . (PPA S.A.) sets out the key principles governing the collecon, use,

protecon and management of personal data, outlining the categories of data processed, the

purposes and legal bases of processing, data retenon periods, recipients, data subject rights and

the security measures applied [G1.MDR-P_65a]

The Policy applies to all personal data processed through PPA S.A.’s acvies and online services

without exclusions, covering website users, employees, contractors, suppliers and visitors

[G1.MDR-P_65b]

Responsibility for implemenng the Policy rests with the highest level of governance through the

Data Protecon Ocer and the Commiee for supervising and ensuring compliance with the

General Data Protecon Regulaon, which oversees and ensures compliance with it.

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The Data Protecon Ocer is appointed as Chair of the Commiee and oversees compliance with

the GDPR and applicable naonal legislaon [G1.MDR-P_65c]

The Policy is aligned with the GDPR, naonal port-related legislaon, the guidelines of the Hellenic

Data Protecon Authority and recognized internaonal best pracces in data protecon [G1.MDR-

P_65d]

Stakeholder interests, including the rights, expectaons and needs of data subjects, are considered

in dening the Policy’s provisions on transparency, lawful processing, security and the exercise of

rights [G1.MDR-P_65e]

The Policy is publicly available on the Company’s ocial website [G1.MDR-P_65f]

For more informaon, data are available in Secon ESRS2.GOV-1.

PPA S.A. maintains a comprehensive and formally approved framework of business conduct

and ethics policies that arculate clear expectaons for ethical behavior, integrity and

transparency across the organizaon, forming the basis of a mature corporate culture that is

aligned with naonal legislaon, EU requirements and sectoral governance standards. This

framework comprises among others, the Code of Conduct, the Code Against Corrupon and

Bribery, the Conict-of-Interest Policy, the Whistleblowing Policy and Procedure, the Internal

Operang Regulaon, the General Sta Regulaon, and the ESG and Sustainability Policy.

These instruments apply to Board Members, execuves, employees, external collaborators,

suppliers and contractors, ensuring consistent behavioral standards and supporng the

idencaon, assessment and management of material Impacts, Risks and Opportunies

relang to business conduct maers.

Corporate culture is developed and promoted through formalized mechanisms embedded in

the Company’s governance model, including mandatory inducon programmes, connuous

training, leadership behavior, transparent internal communicaon and the operaon of

structured reporng and invesgaon channels. Culture is also shaped through systemac

supervision by Internal Audit, Regulatory Compliance, Risk Management and the execuve

leadership, each receiving relevant reporng as dened in the Internal Operang Regulaon

and the BoD’sRules of Procedure, creang a transparent and well-governed environment for

the oversight of business conduct maers.

Mechanisms for idenfying, reporng and invesgang concerns about unlawful behavior or

behavior inconsistent with internal rules are explicitly dened in the Whistleblowing Policy

and Procedure, which sets out internal condenal reporng channels accessible to all

employees and external stakeholders. Reports are received by designated and trained

employees, handled independently and objecvely, and invesgated in accordance with

predened procedures ensuring integrity, condenality and mely follow-up. These

mechanisms enable early idencaon of emerging concerns across the Company’s

operaons, supporng the migaon of material risks, including unethical pracces, conicts

of interest and failures to comply with applicable regulaons [G1-1_10a,G1-1_10c,G1-

1_10e,G1-3_18a].

PPA S.A. has in place a Code Against Corrupon and Bribery, approved by the BoD, which

prohibits any act of bribery, undue inuence or illicit advantage in commercial dealings.

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(amounts in Euro unless stated otherwise)

Although the Code does not refer explicitly to the United Naons Convenon Against

Corrupon, it incorporates equivalent principles, including denions, zero-tolerance

provisions, expected behaviors, due-diligence obligaons and disciplinary consequences.

It is therefore fully operaonal and no metable for further implementaon is required. [G1-

1_10b,G1-3_18a].

Hence, the Company has established safeguards for whistleblowers, including protecon

against retaliaon, condenal processing of reports, secure informaon handling and the

right to report concerns anonymously, where permied by law. PPA S.A. is subject to the

naonal legal framework transposing Direcve (EU) 2019/1937 on the protecon of

whistleblowers and has already implemented the required internal channels and procedures,

and therefore no addional policy development or implementaon plan is required [G1-

1_10c,G1-1_11,G1-1_10d].

Apart from the whistleblowing procedures, the Company invesgates business conduct

incidents promptly, independently and objecvely, with clear separaon of responsibilies

between the invesgang funcons and the operaonal departments, supported by Internal

Audit, Regulatory Compliance and Legal, ensuring that all substanated incidents are

addressed in accordance with the Company’s disciplinary provisions and applicable laws [G1-

1_10e,G1-3_18a,G1-3_18b].

Business conduct training is embedded across the organisaon. During 2025, 1,140 employee

parcipaons were recorded across 13 training programmes covering ethics, an-corrupon,

an-bribery, conicts of interest, regulatory compliance, cybersecurity, ESG maers,

dangerous goods handling, internal audit principles and customer service for vulnerable

groups. These programmes reinforce employees’ capacity to idenfy ethical risks, comply with

internal rules, respond appropriately to emerging compliance challenges and uphold the

Company’s culture of integrity. At the same me, training on business ethics is conducted in

accordance with the established Educaon Plan, which will connue into 2026. Some training

programmes are designed for all employees, while others are tailored to specic departments

and roles. Furthermore, all employees are provided with training on ethics issues during

onboarding and on an ongoing basis in accordance with the annual Educaon Plan [G1-

1_10g,G1-3_AR7,G1-1_9].

While the Company has not yet formally designated any operaonal units as “high-risk

funcons” under its internal framework, it acknowledges the need to establish formal

categorisaon and targeted controls for high-risk funcons and plans to further develop these

measures within the context of its ongoing compliance enhancement acvies [G1-1_10h,G1-

3_19].

It is noted that due to the nature of PPA S.A.’s acvies, it does not involve operaons relang

to animal welfare and therefore no such Policy is required or applicable [G1-1_10f].

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Material Impact Risks and Opportunies

Stakeholder Trust

The Double Materiality assessment idened Stakeholder Trust as a material posive impact

for PPA S.A., driven by the maturity of its governance architecture and the systemac

applicaon of its business conduct framework. The Company’s integrated system of Codes,

policies, internal regulaons and control mechanisms fosters responsible behavior, regulatory

compliance and organizaonal integrity, which together strengthen stakeholder condence in

the Company’s operaons. This posive impact is further reinforced by a series of external

recognions in 2025.

Specically, PPA S.A.

• was named a “Growth Pioneer” at the 2025 Growth Awards organized by Eurobank

and Grant Thornton, recognized as one of the 20 most dynamic companies in Greece,

and received an award in the “Employees Involvement” category at the Health &

Safety Awards for its iniave “A Strategic Health & Safety Training Program with

universal appeal,”

• received the “Sector Leader – Port Authories” award from the Direcon Business

Network for its contribuon to the Greek economy based on its nancial performance.

• it was recognized by the QualityNet Foundaon as one of “The Most Sustainable

Companies in Greece 2025” for its performance across the three ESG pillars, as well as

with the Bravo Governance Award 2025 for pracces related to co-funded European

Research and Development projects.

In 2025, the Company also received three awards at the 2025 Compliance Awards, winning

two gold awards and one bronze award for its compliance pracces, while it was honored with

a Gold Award at the 2025 Greek Accounng and Finance Awards in the “Top Financial Strategy

Iniave” category. Furthermore, it received the True Leader Award 2024 from ICAP CRIF and

the Leading ESG Company Award at the Diamonds of the Greek Economy Awards 2025,

entering the DIAMONDS ELITE category for the rst me. These disncons reinforce the

recognion of PPA S.A. by independent bodies for its performance in governance, nancial

strategy, sustainability, and compliance.

Risks

The Double Materiality assessment idened three risks related to business conduct.

The rst relates to potenal Cybersecurity Threats given the increasing digitalizaon of port

operaons and interconnected IT systems. Cyber incidents could disrupt operaonal

connuity, compromise sensive data or impair service delivery. The Company migates this

risk by embedding cybersecurity safeguards into its digital transformaon iniaves, including

Terminal Operang System upgrades, EDI plaorms and automaon pilots, and by providing

sta training on cybersecurity as part of the 2025 curriculum.

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The second risk, which is Company-specic, is Geopolical Externalies and the Domesc

Polical Environment. Polical or regulatory developments may aect trade ows, investment

condence or operaonal condions. The Company migates this exposure by maintaining

strict neutrality, reinforced by the explicit prohibion of polical contribuons in the Code of

Conduct and by full compliance with Presidenal Decree 15/2022, which prohibits all polical

donaons by legal enes. This legal alignment reduces exposure to geopolical sensivies

and supports operaonal stability.

The third and nal risk relates to Supplier / Contractor Selecon. This risk persists despite the

implementaon of high-level, opmized pre-qualicaon processes, technical specicaons,

and standards during the procurement and tendering stages. Potenal weaknesses in the

evaluaon, monitoring, or compliance of partners could lead to regulatory breaches,

contractual failures, or ethical issues, with potenal impacts on the Company’s reputaon and

credibility. Nevertheless, this risk is migated through enhanced due diligence requirements,

the incorporaon of ESG criteria and an-bribery clauses in contracts, the provision of data

protecon guarantees, as well as enhanced oversight, as further detailed in Secon G1-2

“Management of Relaonships with Suppliers”.

Opportunies

Following the conclusion of the Dual Materiality Assessment, a number of addional

opportunies were idened that are directly linked to the maturity of the Company's

governance.

Strengthening Operaonal Procedures and Controls was recognised as a material opportunity,

as enhanced standardisaon and automaon can improve eciency, reliability and

transparency. The Company’s governance architecture provides a stable foundaon for scaling

such procedural improvements.

Technology and Digital Transformaon constute another material opportunity. The

combinaon of digital tools, real-me systems and automaon enhances operaonal

resilience and transparency. Strong conduct rules, data governance and cyber-controls ensure

that digitalisaon advances are embedded responsibly and support both eciency and

regulatory compliance.

An addional material opportunity relates to Access to Green Financing. The Company’s

sustainability performance and governance maturity strengthen its eligibility for EU funding

programmes, innovaon grants and sustainability-linked nancial instruments. Parcipaon in

naonal and internaonal iniaves, as well as repeated external recognion in the eld of

sustainability, further strengthens the Company’s posion in terms of its access to green and

sustainable nancing.

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Moreover, Compeve Advantage and Regional Leadership were also idened as material

opportunies. The alignment of strong governance, operaonal excellence and sustainability

commitments posions PPA S.A. as a leading port in the Eastern Mediterranean. Key

infrastructure investments, including the cruise terminal expansion, car terminal upgrades,

ship repair zone revitalisaon and environmentally aligned dredging works, further reinforce

this strategic posioning by integrang circular economy elements and environmental

stewardship into core operaons.

Robust Governance and Risk Management represent a strategic opportunity for the Company,

as they ensure consistent and eecve oversight, evidence-based decision-making, and a

substanal reducon in exposure to corrupon or regulatory non-compliance. The existence

of a clear regulatory framework, dened accountability mechanisms, and robust internal

controls strengthens the prevenon of nancial failures, regulatory violaons, and

reputaonal risks. At the same me, a comprehensive and dynamic risk management system

enables the mely idencaon and migaon of threats. This reduces the likelihood of

operaonal disrupons or strategic deviaons, enhancing the Company's long-term resilience

and compeveness.

G1-2 Management of Relaonships with Suppliers

. PPA S.A. manages its supplier relaonships through a structured and fully documented

procurement governance framework, as set out in the new Internal Procurement Procedures

Manual, which applies to all suppliers registered in the Company’s Supplier Register. The

framework ensures transparent, and compeve legal procurement agreements,

incorporang detailed procedures for supplier selecon, contract execuon, monitoring,

evaluaon, classicaon and potenal exclusion. Supplier assessments are based on mul-

dimensional criteria, including contractual performance, quality, safety, innovaon,

governance, risk and sustainability. ESG-specic criteria, such as an-corrupon compliance,

environmental cercaons (including ISO 14001), carbon-reducon iniaves, waste-

management pracces and operaonal risk-management capabilies, form an integral part of

this process and will also be included in the Supplier Code of Conduct, which is currently being

developed during the reporng year [G1-2_15a,G1-2_15b]

Contracts and Sub-Concessions Regulaon and Internal Procurement Procedures Manual

The Contracts and Sub-Concessions Regulaon and the Internal Procurement Procedures

Manual dene PPA S.A.’s procurement and contracng framework as required by Arcles

8 and 9 paragraph 1 and 12.2(a) of Law 4404/2016, seng the principles of transparency,

equal treatment, imparality and non-discriminaon in all procurement acvies

[G1.MDR-P_65a,G1.MDR-P_65d]

They establish the scope of contracts (construcon works, operaonal equipment,

services, supplies, studies, outsourcing, minor sub-concessions) and idenfy exclusions

such as emergencies, specic direct awards and specialised expert services [ESRS2.MDR-

P_65b]

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The Manual puts these rules into operaon through structured procurement procedures

(open bidding, selected bidding, non-bidding), centralised procurement, roles and

responsibilies of Procurement, Controlling, User Departments and Internal Audit, and

detailed steps for iniaon, evaluaon, negoaon and approval [ESRS2.MDR-P_65c]

It further species the operaon of the Contractors Register, supplier qualicaon and

performance evaluaon requirements, ensuring compliance with the Concession

Agreement and applicable legislaon. The framework provides clear processes,

documentaon requirements and internal controls for contract award, supplier

management and sub-concession administraon. The Regulaon is publicly accessible and

published on the Company’s website to ensure transparency for all stakeholders

[ESRS2.MDR-P_65f]

Suppliers’ Personal Data Protecon Policy

The Suppliers’ Personal Data Protecon Policy sets out the principles and procedures

governing the processing of personal data of suppliers who are natural persons, as well as

of employees or representaves of supplier-legal-enes. The Policy denes the categories

of data collected, the purposes of processing related to contract execuon, regulatory

compliance and the defense of legal claims, and the lawful bases applied. It idenes key

data-protecon risks and describes the safeguards implemented, including technical and

organisaonal security measures, condenality obligaons, internal procedures,

employee training, retenon rules and secure destrucon [G1.MDR-P_65a]

The Policy applies across all procurement-related acvies and includes no exclusions

[ESRS2.MDR-P_65b] Responsibility for implementaon rests with PPA S.A. acng as Data

Controller, supported by the Data Protecon Ocer [ESRS2.MDR-P_65c]

The Policy aligns with GDPR (Regulaon 2016/679), naonal legislaon and internal

regulaons. Data subjects’ rights are clearly dened, with established processes for

exercising them and the opon to contact the Hellenic Data Protecon Authority

[ESRS2.MDR-P_65d,e]

The Policy is publicly accessible and published on the Company’s ocial website and

updated on a regular basis to ensure transparency for all stakeholders [ESRS2.MDR-P_65f]

The evaluaon methodology includes weighted scoring ranges (5–30 percent) across key

categories and results in annual supplier classicaon into Grades A–D. Grade A suppliers

receive priority under equal-treatment condions; Grade B remain fully eligible; Grade C

suppliers enter a correcve-acon phase with temporary suspension; and Grade D suppliers

are removed from the contractors register for two years. The Supplier Exclusion Registry

operates under principles of fairness, accountability, proporonality and transparency, with

clear procedures for documenng breaches, approving exclusion decisions, nofying suppliers

and enabling reconsideraon when correcve measures have been implemented [G1-

2_15a],[G1-2_15b]

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Although PPA S.A. does not maintain a stand-alone policy specically aimed at prevenng late

payments to SMEs, it embeds mely-payment safeguards through its procurement processes.

These include contractually dened payment terms, internal vericaon workows,

compliance monitoring, cross-departmental coordinaon between procurement, controlling

and nance, and ongoing contract-performance monitoring. While not SME-targeted, these

mechanisms ensure fairness and minimise undue delays for all suppliers irrespecve of size

[G1-2_14]

The Company also implements the Suppliers’ Personal Data Protecon Policy, which governs

the processing of personal data belonging to supplier-physical-persons and to employees or

representaves of supplier-legal-enes. The Policy denes the categories of data collected,

the purposes of processing, the lawful bases applied, retenon rules, technical and

organisaonal security measures, condenality requirements and data-subject rights. The

Policy aligns with GDPR and naonal law, applies across all procurement acvies and is

publicly accessible for transparency.

This integrated procurement system generates a posive sustainability impact by promong

ethical pracces, transparency, responsible sourcing and alignment with environmental and

social standards across PPA S.A.’s supply chain. ESG performance criteria, documented

evaluaon processes, supplier improvement mechanisms and exclusion rules incenvise

suppliers to enhance compliance, quality, safety and environmental performance, thereby

strengthening the sustainability prole of PPA S.A.’s upstream operaons.

At the same me, these measures directly migate the material risk associated with supply-

chain mismanagement, including the potenal for unethical pracces, non-compliance with

environmental or labour standards, reputaonal harm, operaonal delays and legal exposure.

Through annual ESG-inclusive scoring, supplier classicaon, stringent contract-compliance

monitoring, risk-based exclusion policies and structured re-evaluaon processes, PPA S.A.

ensures that sustainability-related risks are idened, assessed and addressed in a consistent

and controlled manner. These controls help maintain stakeholder trust, safeguard the

Company’s social license to operate and uphold transparency across the supply chain.

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G1-3 Prevenon and Detecon of Corrupon and Bribery

PPA S.A. maintains a structured and connuously evolving system to prevent, detect and

address corrupon and bribery risks, directly supporng the migaon of the material risk

“Incidents on Ethics and Integrity” and enabling the opportunity to strengthen “Operaonal

Procedures and Controls”. The system is anchored in the Code of Conduct, the Code Against

Corrupon and Bribery, the Conict-of-Interest Policy, the Whistleblowing Policy and

Procedure, and the Internal Operang Regulaon, all of which dene prohibited pracces, set

due-diligence expectaons and establish clear disciplinary consequences. These policies

operate prevenvely through mandatory conict-of-interest declaraons, segregaon of

dues, procurement-specic controls, and systemac monitoring by Internal Audit, Regulatory

Compliance, Risk Management and the Procurement Department [G1-3_18a]

Invesgaons of corrupon or bribery-related allegaons are carried out independently of the

relevant management chain, ensuring imparality and full access to informaon.

Whistleblowing submissions are handled by trained case-handlers, while Internal Audit

maintains the authority to review ethical risks across operaons, including the monitoring of

gis above EUR 100. During 2025, the relevant audit conrmed zero reportable incidents,

demonstrang the eecveness of exisng controls and contribung to the early detecon

and containment of integrity risks. Outcomes of invesgaons and systemic ndings are

reported through the established internal-reporng framework to senior management, the

Board Commiees and the Board of Directors, in line with the Internal Operang Regulaon

and the Rules of Procedure of the Governance Bodies [G1-3_18a,b,c]

To ensure that all personnel understand the Company’s expectaons, PPA S.A. disseminates

its an-corrupon and an-bribery policies through inducon programmes, targeted circulars,

internal plaorms [G1-3_20] During the rst half of 2025, employees received extensive

training on ethics, an-bribery, an-corrupon and regulatory compliance. These

programmes, which recorded 1,564 parcipaons across 38 sessions, included specialised

modules on bribery prevenon, conicts of interest, dangerous goods compliance,

cybersecurity, ESG governance and internal controls, reinforcing employees’ capacity to

idenfy and escalate concerns promptly [G1-3_21a].

Although the Company has not yet formally codied its list of “funcons-at-risk”, processes

involving procurement, contract management, port operaons, nance, and high-value

commercial engagements have been recognised internally as requiring higher vigilance. PPA

S.A. is progressing towards a structured mapping of high-risk funcons, with the aim of linking

specialised training, control tesng and monitoring mechanisms to the funcons most

exposed to corrupon and bribery risks. This enhancement supports the Company’s

connuous improvement and the opportunity to strengthen operaonal procedures and

internal controls [G1-3_21b].

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Training for the administrave, management and supervisory bodies forms part of the

mandatory training framework under the Internal Operang Regulaon and includes sessions

on ethics, an-bribery, conicts of interest, regulatory obligaons and oversight

responsibilies [G1-3_21c].

In parallel, PPA S.A. is advancing its compliance maturity by progressively aligning its Code

Against Corrupon and Bribery with the principles of the UN Convenon Against Corrupon.

While the Code already incorporates equivalent prohibions, due-diligence elements and

disciplinary measures, future revisions will explicitly reect UN-aligned provisions, reinforcing

the Company’s approach to integrity management.

The Company’s prevenve controls also extend to its business counterpares. The Preliminary

Cooperaon Agreement requires every supplier to declare the absence of conicts of interest,

commit to an-bribery standards and comply with PPA S.A.’s integrity framework. Prospecve

suppliers must also submit an An-Commercial Bribery Commitment Statement, and PPA S.A.

veries an-bribery and an-corrupon declaraons during pre-contractual due diligence.

Failure to comply constutes a material breach, enabling contract terminaon. These

mechanisms strengthen third-party governance and reduce exposure to ethical breaches

across the supply chain [G1-3_18a],[G1-2_15a].

In 2025, further reinforcement came through the revised Contracts & Sub-concessions

Regulaons – Internal Procurement Procedures Working Manual, which explicitly integrates

controls for bribery and corrupon prevenon. Employees involved in procurement processes

received targeted training on the updated requirements, ensuring consistent understanding

and implementaon across the Company.

Overall, these mechanisms reduce the likelihood and impact of integrity-related incidents,

strengthen procedural resilience, support connuous improvement and reinforce stakeholder

trust.

G1-4 Incidents of Corrupon or Bribery

During the reporng period, PPA S.A. recorded no convicons, no nes, and no penales

relang to violaons of an-corrupon or an-bribery legislaon. Internal reviews, monitoring

acvies, audits and the assessment of gis above EUR 100 reported zero breaches, and thus

no addional correcve acons or sancons were required. [G1-4_24 a].

In line with voluntary ESRS disclosures, PPA S.A. conrms that during the reporng period:

• no conrmed incidents of corrupon or bribery occurred,

• no dismissals or disciplinary acons were implemented in relaon to corrupon or

bribery,

• no contracts were terminated or not renewed due to corrupon- or bribery-related

violaons, and

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• no new or pending legal cases involving corrupon or bribery were recorded.

These results demonstrate the eecveness of the Company’s prevenve framework in

migang the material risk of ethical and integrity breaches and reinforce the opportunity to

enhance operaonal procedures, internal controls and compliance assurance mechanisms.

[G1-4_25 a-d]

Corporate Governance Acons and Targets

High-Level Sustainability Targets approved by the BoD under the oversight of the Chief

Execuve Ocer

As part of its management of material impacts, risks, and opportunies related to business

conduct, the Company has established objecves and monitoring mechanisms linked to

relevant governance, an-corrupon, and responsible supply chain management policies.

These targets primarily cover the Company’s own acvies and, where necessary, the

upstream value chain, [MDR-T 80(a)], [MDR-T 80(c)]

The eecveness of these acons is monitored using specic key performance indicators

(KPIs), which are evaluated annually and reported to the relevant governing bodies, supporng

the monitoring of performance against the set targets.

At the level of indicators, no external party has been involved for the validation of the metrics

used. [MDR-M 77 (b)] Regarding the targets, the base year has been set as 2024 [MDR-T 80

(d)], while the methodology applied for their determination and monitoring is based on the

internal tracking of relevant performance indicators (KPIs). [MDR-T 80 (f)]

Furthermore, there is no structured process for stakeholder involvement in their definition

[MDR-T 80 (h)] and no scientific evidence has been used for their creation [MDR-T 80 (g)]

Finally, no changes have been made to targets, methodologies, or assumptions [MDR-T 80

(i)], as the related processes are at an early stage of development and maturation. The targets

included in the table below are not quantified. [MDR-T_80 b] [MDR-M_75]

At the level of indicators, no specific methodologies or assumptions have been used [MDR-

M_77 (a)], and no external party has been involved in the validation of the metrics used [MDR-

M 77 (b)]

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Business Conduct

IRO

Actions

[MDR-A 68a]

Target

[MDR-T- 80b]

Year

[MDR-A

68c/ MDR-T 80e]

[MDR-A

68b/ MDR-

T 80c]

KPIs MDR-A

68e/ MDR-T 80b/

MDR – M- 75

Progress in 2025 MDR-

A 68e/ MDR-T- 80j

Improve

Governance

Structure

Strengthening of internal

frameworks

Expanding cybersecurity

monitoring capabilities

2028

Own operations

No progress was made

in 2025

Linking management

remuneration to ESG

criteria

2027

Own operations

No progress was made

in 2025

BoD ESG seminars

2025

Own operations

100% achieved in 2025

Corruption &

Bribery

Identifying functions at

risk of corruption and

bribery

2026

Own operations

Number of functions

and business

processes at risk

No progress was made

Training of employees holding

critical positions related to

issues of corruption and

bribery [G1-4_24 b]

Zero bribery and

corruption incidents

Ongoing annual

monitoring

Own operations

Number of employees

trained per year

100% achieved in 2025

Handling of all

whistleblowing incidents

according to

Whistleblowing Policy

Ongoing annual

monitoring

Own operations

Number of training

seminars completed

No progress was made

in 2025 - In progress

Management of all

incidents

No progress was made

in 2025 - In progress

Responsible

Evaluation of key suppliers

with ESG criteria

Setting specific criteria

2028

upstream

Number of suppliers

evaluated

In progress in 2025

supply chain

The budget for the above acons is esmated at €107,500, corresponding to OPEX. For the reporng period, €7,500 have been implemented, while the

remaining acons will be completed in the future according to the schedule. [MDR-A_69]

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G1-5 Polical Inuence and Lobbying Acvies [Non-Material]

PPA S.A. does not engage in polical inuence or lobbying acvies and is legally prohibited

from providing any nancial or in-kind polical contribuons. In accordance with Presidenal

Decree 15/2022 (Greek Government Gazee Issue A 39/01.03.2022), Arcle 5 paragraph 6, all

forms of nancing or provision of benets to polical pares or coalions are strictly

prohibited for legal enes, including PPA S.A. This prohibion is embedded in the Company’s

internal regulaons and governance framework, and no exempons or deviaons are

permied [G1-5_29b].

Consistent with the outcome of the 2025 Double Materiality Assessment, polical inuence

and lobbying were assessed as non-material for the reporng period. While non-material in

2025, the topic is monitored due to its connecon with the idened Geopolical Externalies

Maintaining a strict prohibion on polical contribuons and avoiding lobbying acvies

funcons as a risk-migaon measure, ensuring independence from polical inuence,

prevenng exposure to polical sensivies, and safeguarding the Company’s neutrality in a

highly regulated sector. This approach supports regulatory compliance, preserves stakeholder

trust and reduces exposure to governance or reputaonal risks arising from external

geopolical or domesc polical developments.

The Company does not engage in polical lobbying, advocacy, or polical inuence, and its

internal and external obligaons strictly prohibit polical contribuons. PPA S.A. is legally

prohibited from providing any nancial or in-kind polical contribuons. In accordance with

Presidenal Decree 15/2022 (Greek Government Gazee Issue A 39/01.03.2022), Arcle 5

paragraph 6, legal enes—including PPA S.A.—are forbidden from nancing or providing any

benet to polical pares or coalions. This restricon is fully embedded in the Company’s

governance framework, without excepons or discreonary applicaon [G1-5_29b].

The Code of Conduct further formalises this prohibion. Arcle 12 explicitly states that while

the Company supports acvies related to educaon, science, culture, corporate social

responsibility, sports and environmental protecon, The Code also prohibits bribery and the

use of donaons to gain commercial advantage, as well as donaons to polical gures or

elected ocials, and does not provide sponsorships beyond what is legally permied, ensuring

full alignment with the Company’s integrity framework and the Code Against Corrupon and

Bribery.

Maintaining a strict prohibion on polical contribuons, combined with the absence of

lobbying acvies, serves as a risk-migaon measure. It supports operaonal neutrality,

prevents exposure to polical sensivies, and safeguards the Company’s reputaon and

compliance posture in a highly regulated sector.

Page 341 από 437

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

G1-6 Payment Pracces [Non-Material]

Based on the results of the 2025 Double Materiality Assessment, payment pracces were

assessed as non-material for the reporng period. PPA S.A. maintains consistently mely

selement of obligaons, with very few disputes or delays, and cooperates with a relavely

limited number of SMEs, which reduces exposure to risks related to late payments. Although

the topic is not material for 2025, the Company remains commied to legal, transparent and

responsible payment pracces as part of its broader supply chain governance. Other topics

were determined to hold higher material signicance for the Company and its stakeholders at

this stage. Nonetheless, payment pracces may become material in the future should

operang condions, stakeholder expectaons or the structure of the value chain evolve.

Further informaon on the materiality assessment methodology and results is provided in the

ESRS 2 secon of this Report.

Page 342 από 437

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Annex 1: Mandatory disclosures of the European Sustainability Reporting Standards (ESRS) aligned with other EU legislation

Disclosure requirement

and related data point

SFDR

Regulaon

Reference (1)

Pillar 3 reference (2)

Benchmark

regulaon

reference (3)

EU Climate

Law reference

(4)

Material

Secon

ESRS 2 GOV-1

Gender diversity on the

board, paragraph 21,

point (d)

Indicator No.

13, Table 1 of

Annex Ι

Commission

Delegated

Regulaon (EU)

2020/1816(5),

Annex (II) 

YES

Governance

Structure and

Sustainability

Oversight

ESRS 2 GOV-1

Proporon of board

members who are

independent

–

Commission

Delegated

Regulaon (EU)

2020/1816, Annex

–

YES

Governance

Structure and

Sustainability

Oversight

ESRS 2 GOV-4

Statement on due

diligence-paragraph 30

Indicator No.

10, Table 3 of

Annex I 

–

YES

Statement on

Due Diligence

ESRS 2 SBM-1

Involvement acvies

related to the fossil fuel

sector, paragraph 40,

point (d), sub-point (i) 

Indicator No.

4, Table 1 of

Annex I 

Arcle 449a of Delegated

Regulaon (EU) No 575/2013 –

Commission Implemenng

Regulaon (EU) 2022/2453:

Table 1: Qualitave Informaon

on environmental risk

Table 2: Qualitave informaon

related to social risk

Commission

Delegated

Regulaon (ΕU)

2020/1816, Annex

(II) 

– 

Page 343 από 437

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

ESRS 2 SBM-1

Involvement in acvies

related to the producon

of chemical

products  paragraph 40,

point (d), sub-point (ii) 

Indicator No.

9, Table 2 of

Annex I 

– 

Commission

Delegated

Regulaon (ΕU)

2020/1816, Annex

(II) 

– 

ESRS 2 SBM-1 

Involvement in acvies

related to controversial

weapons, paragraph 40

point (d), sub-point (iii) 

Indicator No.

14, Table 1 of

Annex Ι 

Commission

Delegated

Regulaon (ΕU)

2020/1818(7),

Arcle 12,

paragraph 1,

Commission

Delegated

Regulaon (ΕU)

2020/1816, Annex

(II) 

ESRS 2 SBM-1 

Involvement in acvies

related to culvaon and

producon of tobacco

products paragraph 40

point (d), sub-point (iv) 

– 

Commission

Delegated

Regulaon (ΕU)

2020/1818, Arcle

12, paragraph 1,

Commission

Delegated

Regulaon (ΕU)

2020/1816, Annex

(II) 

– 

Page 344 από 437

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(amounts in Euro unless stated otherwise)

ESRS E1-1

Transion plan for climate

neutrality by 2050

paragraph 14

– 

Regulaon

(ΕU)

2021/1119,

Arcle 2,

paragraph 1 

ESRS E1-1

Companies excluded from

Paris-aligned benchmarks,

paragraph 16, point (g) 

– 

Arcle 449a of Delegated

Regulaon (EU) No 575/2013 –

Commission Implemenng

Regulaon (EU) 2022/2453:

Template 1: Banking book —

Transion risk from climate

change: Credit quality of

exposures by sector, emissions

and remaining maturity

Commission

Delegated

Regulaon (ΕU)

2020/1818 (Arcle

12, paragraph 1,

point d) up to

(g)and Arcle 12,

paragraph 2

– 

ESRS E1-4

GHG emissions reducon

targets paragraph 34

Indicator No.

4, Table 2 of

Annex I 

Arcle 449a of Delegated

Regulaon (EU) No 575/2013 –

Commission Implemenng

Regulaon (EU)

2022/2453Template 3: Banking

book – Transion risk from

climate change – Alignment

Measurement Indicators

Commission

Delegated

Regulaon (ΕU)

2020/1818, Arcle

– 

YES

Climate and

Energy-related

Targets

Page 345 από 437

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(amounts in Euro unless stated otherwise)

ESRS E1-5 

Energy consumpon from

fossil sources broken

down by source (high

climate impact sectors

only), paragraph 38 

Indicator No.

5, Table 1 and

Table 2 of

Annex I 

– 

YES

Energy Eciency

and Carbon

Footprint

ESRS E1-5

Energy consumpon and

mix, paragraph 37 

Indicator No.

5, Table 1 of

Annex Ι 

– 

YES

Energy Eciency

and Carbon

Footprint

ESRS E1-5 

Energy intensity

associated with acvies

in high climate impact

sectors paragraphs 40 to

Indicator No.

6, table1 of

Annex Ι 

– 

YES

Energy Eciency

and Carbon

Footprint

ESRS E1-6

Scope 1, 2, 3

grossemissions and total

emissions (GHG),

paragraph 44 

Indicator No.

1 and 2, Table

1 of Annex I 

Arcle 449a of Delegated

Regulaon (EU) No 575/2013 –

Commission Implemenng

Regulaon (EU) 2022/2453:

Template 1: Banking book —

Transion risk from climate

change: Credit quality of

exposures by sector, emissions

and remaining maturity

Commission

Delegated

Regulaon (ΕU)

2020/1818, Arcle

5 paragraph 1,

Arcle 6 and

Arcle 8 paragraph

– 

YES

Energy Eciency

and Carbon

Footprint

Page 346 από 437

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(amounts in Euro unless stated otherwise)

ESRS E1-6 

Gross GHG emissions,

paragraph 53 to 55 

Indicator No.

3, Table 1 of

Annex I 

Arcle 449a of Delegated

Regulaon (EU) No 575/2013 –

Commission Implemenng

Regulaon (EU) 2022/2453 of the

Commission, Template 3: Banking

Porolio – Transion Risk due to

Climate Change: Alignment

Measurement Indicators

Commission

Delegated

Regulaon (ΕU)

2020/1818, Arcle

8 paragraph 1 

– 

YES

Energy Eciency

and Carbon

Footprint

ESRS E1-7 

GHG removals and carbon

credits, paragraph 56 

– 

Regulaon

(ΕU)

2021/1119,

Arcle 2,

paragraph 1 

ESRS E1-9 

Exposure of the reference

porolio to material

climate-related risks,

paragraph 66 

– 

Commission

Delegated

Regulaon (ΕU)

2020/1818, Annex

ΙΙ & Commission

Delegated

Regulaon (ΕU)

2020/1816, Annex

ΙΙ

– 

ESRS E1-9

Arcle 449a of Delegated

Regulaon (EU) No 575/2013 –

Page 347 από 437

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(amounts in Euro unless stated otherwise)

Analysis of nancial

amountsby type and

ming of material risk,

paragraph 66, point (a) 

ESRS E1-9

Locaon of signicant

material assets exposed to

signicant material risk,

paragraph 66, point (c) 

Commission Implemenng

Regulaon (EU) 2022/2453,

paragraphs 46 to 47 – Template 5:

Banking book – Material climate

change risk: Exposures subject to

material risk.

ESRS E1-9

Analysis of the carrying

amount of its real estate

by energy performance

class, paragraph 67, point

(c).

Arcle 449a of Delegated

Regulaon (EU) No 575/2013 –

Commission Implemenng

Regulaon (EU) 2022/2453,

paragraph 34:

Template 2: Banking book —

Transion risk from climate

change: Loans secured by real

estate — Energy performance of

the collateral Loans secured by

real estate — Energy

performance of the collateral

ESRS E1-9 

Commission

Delegated

Page 348 από 437

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Degree of exposure of the

porolio to climate-

related opportunies

paragraph 69 

Regulaon (EU)

2020/1818, Annex

ESRS E2-4 

Quanty of each pollutant

listed in Annex II of the EU

PRTR Regulaon

(European Pollutant

Release and Transfer

water, and soil, paragraph

Indicator No. 8

Table 1 of

Annex I,

Indicator No. 2

Table 2 of

Annex I,

Indicator No. 1

Table 2 of

Annex I,

Indicator No. 3

Table 2 of

Annex I 

ESRS E3-1

Water and marine

resources, paragraph 9 

Indicator No.

7, Table 2 of

Annex Ι 

ESRS E3-1

Specic policy, paragraph

Indicator No.

8, Table 2 of

Annex Ι 

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(amounts in Euro unless stated otherwise)

ESRS E3-1

Sustainable oceans and

seas, paragraph 14 

Indicator No.

12, Table 2 of

Annex Ι 

ESRS E3-4

Total water recovered,

recycled and/or reused,

paragraph 28, point (c) 

Indicator No.

6.2, Table 2 of

Annex Ι 

ESRS E3-4

Total water consumpon

in m³ per net revenue from

own acvies, paragraph

Indicator No.

6.1, Table 2 of

Annex Ι 

YES

Water

Management

ESRS 2 – IRO 1 – E4,

paragraph 16, point (a)

sub-point (i) 

Indicator No.

7, Table 1 of

Annex Ι 

YES

Biodiversity

ESRS 2 – IRO 1 – E4,

paragraph 16, point (b)

Indicator No.

10, Table 2 of

Annex Ι 

ESRS 2 – IRO 1 – E4,

paragraph 16, point (c) 

Indicator No.

1, Table 2 of

Annex Ι 

Page 350 από 437

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(amounts in Euro unless stated otherwise)

ESRS E4-2

Sustainable

land/agriculture use

pracces or policies,

paragraph 24, point (b) 

Indicator No.

11, Table 2 of

Annex Ι 

ESRS E4-2

Sustainable pracces or

policies for the oceans/

seas, paragraph 24, point

(c) 

Indicator No.

12, Table 2 of

Annex Ι 

ESRS E4-2

Policies addressing

deforestaon, paragraph

24, point (d) 

Indicator No.

15, Table 2 of

Annex Ι 

ESRS E3-1

Water and marine

resources, paragraph 9 

Indicator No.

7, Table 2 of

Annex Ι 

ESRS E3-1 Specic policy,

paragraph 13 

Indicator No.

8, Table 2 of

Annex Ι 

Page 351 από 437

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(amounts in Euro unless stated otherwise)

ESRS E3-1

Sustainable oceans and

seas, paragraph 14 

Indicator No.

12, Table 2 of

Annex Ι 

ESRS E3-4

Total water, recycled, and

reused, paragraph 28,

point (c) 

Indicator No.

6.2, Table 2 of

Annex Ι 

ESRS E3-4

Total water consumpon

in m³ per net revenue from

own acvies, paragraph

Indicator No.

6.1, Table 2 of

Annex Ι 

YES

Water

Management

ESRS 2 – IRO 1 – E4,

paragraph 16, point (a)

sub-point (i) 

Indicator No.

7, Table 1 of

Annex Ι 

YES

Biodiversity

ESRS 2 – IRO 1 – E4,

paragraph 16, point (b)

Indicator No.

8, Table 2 of

Annex Ι 

ESRS 2 – IRO 1 – E4,

paragraph 16, point (c) 

Indicator No.

1, Table 2 of

Annex Ι 

Page 352 από 437

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(amounts in Euro unless stated otherwise)

ESRS E4-2

Sustainable land

use/agriculture pracces

or policies, paragraph 24,

point (b) 

Indicator No.

11, Table 2 of

Annex Ι 

ESRS E4-2

Sustainable pracces or

policies for the

oceans/seas, paragraph

24, point (c) 

Indicator No.

12, Table 2 of

Annex Ι 

ESRS E4-2

Policies addressing

deforestaon, paragraph

24, point (d) 

Indicator No.

15, Table 2 of

Annex Ι 

ESRS E5-5

Non-recycled waste,

paragraph 37, point (d) 

Indicator No.

13, Table 2 of

Annex Ι 

– 

YES

Waste

Management in

the Port Area

ESRS E5-5

Hazardous waste and

radioacve waste,

paragraph 39 

Indicator No.

9, Table 1 of

Annex Ι 

– 

YES

Waste

Management in

the Port Area

Page 353 από 437

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(amounts in Euro unless stated otherwise)

ESRS 2 – SBM-3 – S1

Risk of forced labor

incidents, paragraph 14,

point (f)

Indicator No.

13, Table 3 of

Annex Ι 

– 

ESRS 2 – SBM-3 – S1

Risk of child labor

incidents, paragraph 14,

point (g)

Indicator No.

12, Table 3 of

Annex Ι 

– 

ESRS S1-1

Commitments on human

rights policy, paragraph

Indicator No.

9, Table 3 and

Indicator No.

11, Table 1 of

Annex Ι 

– 

YES

Policies related to

the Company’s

workforce

ESRS S1-1

Due diligence policies

regarding issues

addressed by the

Fundamental Convenons

of the Internaonal

Labour Organizaon 1 to

8, paragraph 21 

– 

Commission

Delegated

Regulaon (EU)

2020/1816, Annex

ΙΙ 

– 

YES

Equal

Opportunies

ESRS S1-1

Processes and measures

to prevent human

tracking, paragraph 22 

Indicator No.

11, Table 3of

Annex Ι 

– 

ESRS S1-1 

Workplace accident

prevenon policy or

Indicator No.

1, Table 3 of

Annex Ι 

– 

YES

Occupaonal

Health and Safety

Page 354 από 437

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

management system,

paragraph 23 

ESRS S1-3

Complaint / grievance

mechanisms, paragraph

32 point (c) 

Indicator No.

5, Table 3 of

Annex Ι 

– 

YES

Procedures for

addressing

negave impacts

and mechanisms

for the

Company’s

workforce to

raise concerns

ΕSRS S1-14

Number of fatalies and

number and rate of work-

related accidents,

paragraph 88, points (b)

and (c) 

Indicator No.

2, Table 3 of

Annex Ι 

– 

Commission

Delegated

Regulaon (EU)

2020/1816, Annex

ΙΙ 

– 

YES

Incidents Related

to Employee

Health and Safety

ESRS S1-14

Lost workdays due to

injuries, accidents,

fatalies, or illnesses,

paragraph 88, point (e) 

Indicator No.

3, Table 3 of

Annex Ι 

– 

YES

Incidents Related

to Employee

Health and Safety

ESRS S1-16

Unadjusted gender pay

gap, paragraph 97, point

(a) (a) 

Indicator No.

12, Table 1 of

Annex Ι 

– 

Commission

Delegated

Regulaon (EU)

2020/1816, Annex

ΙΙ 

– 

YES

Equal

Opportunies

Page 355 από 437

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(amounts in Euro unless stated otherwise)

ESRS S1-16

Excessively high CEO pay

rao, paragraph 97, point

(b) 

Indicator No.

8, Table 3 of

Annex Ι 

– 

ESRS S1-17

Incidents of

discriminaon, paragraph

103, point (a) 

Indicator No.

7, Table 3 of

Annex Ι 

– 

YES

Equal

Opportunies

ESRS S1-17

Non-compliance with the

UN Guiding Principles on

Business and Human

Rights and OECD

Guidelines, paragraph 104,

point (a) 

Indicator No.

10, Table 1 and

Indicator No.

14, Table 3 of

Annex Ι 

– 

Commission

Delegated

Regulaon (EU)

2020/1816, Annex

ΙΙ, Commission

Delegated

Regulaon (EU)

2020/1818, Arcle

12, paragraph 1 

– 

YES

Equal

Opportunies

ESRS 2 – SBM-3 – S2

Signicant risk of child or

forced labor in the value

chain, paragraph 11, point

(b) 

Indicators No.

12 and 13,

Table 3 of

Annex Ι 

– 

Page 356 από 437

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(amounts in Euro unless stated otherwise)

ESRS S2-1

Commitments on human

rights policy, paragraph

Indicator No.

9, Table 3 and

Indicator No.

11, Table 1 of

Annex Ι 

– 

ESRS S2-1

Policies related to the

labor value chain,

paragraph 18 

Indicators No.

11 and 4, Table

3 of Annex I

– 

ESRS S2-1

Non-compliance with the

UN Guiding Principles on

Business and Human

Rights and OECD

Guidelines, paragraph 19 

Indicator No.

10, Table 1 of

Annex Ι 

– 

Commission

Delegated

Regulaon (EU)

2020/1816, Annex

ΙΙ, Commission

Delegated

Regulaon (EU)

2020/1818, Arcle

12, paragraph 1 

– 

ESRS S2-1

Due diligence policies

regarding issues covered

by ILO Fundamental

Convenons1 to 8,

paragraph 19  

– 

Commission

Delegated

Regulaon (EU)

2020/1816, Annex

ΙΙ 

– 

Page 357 από 437

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(amounts in Euro unless stated otherwise)

ESRS S2-4

Human rights issues and

incidents related to the

upstream and

downstream value chain,

paragraph 36

Indicator No.

14, Table 3 of

Annex Ι 

– 

ESRS S3-1

Commitments on human

rights policy, paragraph

Indicator No.

9, Table 3 of

AnnexΙ and

Indicator No.

11, Table 1 of

Annex Ι 

– 

YES

Policies of Piraeus

Port Authority

S.A. relang to

aected

communies

ESRS S3-1

Non-compliance with the

UN Guiding Principles on

business and Human

Rights and/or OECD

Guidelines, paragraph 17

Indicator No.

10, Table 1 of

Annex Ι 

– 

Commission

Delegated

Regulaon (EU)

2020/1816, Annex

ΙΙ, Commission

Delegated

Regulaon (EU)

2020/1818, Arcle

12, paragraph 1 

– 

YES

Policies of Piraeus

Port Authority

S.A. relang to

aected

communies

Page 358 από 437

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(amounts in Euro unless stated otherwise)

ESRS S3-4

Human rights issues and

incidents, paragraph 36 

Indicator No.

14, Table 3 of

Annex Ι 

– 

YES

Procedures for

engagement with

aected

communies in

relaon to

impacts

ESRS S4-1

Policies regarding

consumers and end-users,

paragraph 16 

Indicator No.

9, Table 3 and

Indicator No.

11, Table 1 of

Annex Ι 

– 

YES

Policies in

Relaon to

Consumers and

End Users

ESRS S4-1

Non-compliance with the

UN Guiding Principles on

Business and Human

Rights and OECD

Guidelines, paragraph 17 

Indicator No.

10, Table 1 of

Annex Ι 

– 

Commission

Delegated

Regulaon (EU)

2020/1816, Annex

ΙΙ, Commission

Delegated

Regulaon (EU)

2020/1818, Arcle

12, paragraph 1 

– 

YES

Protecon of

Human Rights

ESRS S4-4

Human rights issues and

incidents, paragraph 35 

Indicator No.

14, Table 3 of

Annex Ι 

– 

YES

Protecon of

Human Rights

Page 359 από 437

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(amounts in Euro unless stated otherwise)

ESRS G1-1

UN Convenon against

Corrupon, paragraph 10,

point (b) 

Indicator No.

15, Table 3 of

Annex Ι 

– 

ESRS G1-1

Whistleblower protecon

of public interest,

paragraph 10, point (b) 

Indicator No.

6, Table 3 of

Annex Ι 

– 

YES

Policies related to

business conduct

and corporate

culture

ESRS G1-4

Fines for violaons of

legislave provisions

concerning the ght

against corrupon and

bribery, paragraph 24,

poiont a)

Indicator No.

17, Table 3 of

Annex Ι 

– 

Commission

Delegated

Regulaon (EU)

2020/1816, Annex

ΙΙ 

– 

YES

Prevenon and

Detecon of

Corrupon and

Bribery

ESRS G1-4

Standards for combang

corrupon and bribery,

paragraph 24, point (b) 

Indicator No.

16, Table 3 of

Annex Ι 

– 

Page 360 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

THIS REPORT IS A FREE TRANSLATION FROM THE GREEK ORIGINAL

Independent practitioner’s limited assurance report on Piraeus Port Authority S.A

Sustainability Statement

To the shareholders of Piraeus Port Authority S.A

We have conducted a limited assurance engagement on the Sustainability Statement of Piraeus Port

Authority S.A (hereinafter the “Company”), included in section “Annual Sustainability Statement” of the

Annual Report of the Board of Directors (hereinafter the “Sustainability Statement”), for the period

from 01.01.2025 to 31.12.2025.

Limited assurance conclusion

Based on the procedures we have performed, as described below in the paragraph “Scope of Work

Performed”, as well as the evidence obtained, nothing has come to our attention that causes us to

believe that:

• the Sustainability Statement is not prepared, in all material respects, in accordance with article 151

of L.4548/2018 as amended by L.5164/2024 and in effect, with which it was incorporated into Greek

legislation the article 19(a) of EU Directive 2013/34/EU;

• the Sustainability Statement does not comply with the European Sustainability Reporting Standards

(hereinafter “ESRS”), in accordance with Regulation (EU) 2023/2772 of the Commission of 31 July

2023 and Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December

2022;

• the process carried out by the Company for the identification and assessment of material impacts,

risks and opportunities (the "Process"), as set out in section “Double Materiality Assessment” of the

Sustainability Statement, does not comply with "Requirement IRO-1- Description of the processes

to identify and assess material impacts, risks and opportunities" of ESRS 2 "General Disclosures";

• the disclosures of section “European Taxonomy” of the Sustainability Statement do not comply with

article 8 of EU Regulation 2020/852.

This assurance report does not extend to information for previous periods.

Basis for the conclusion

The limited assurance engagement was conducted in accordance with International Standard on

Assurance Engagements (ISAE) 3000 (Revised) “Assurance Engagements Other than Audits or Reviews

of Historical Financial Information” (hereinafter “ISAE 3000 (Revised)”).

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The procedures in a limited assurance engagement vary in nature and timing from, and are less in

extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained in

a limited assurance engagement is substantially lower than the assurance that would have been

obtained had a reasonable assurance engagement been performed.

Our responsibilities are further described in the “Practitioner’s Responsibilities” section.

Professional Ethics and Quality Management

We are independent from the Company throughout this work and have complied with the

requirements of the Code of Ethics for Professional Accountants issued by the International Ethics

Standards Board for Accountants (IAS Code), the ethics and independence requirements of

L.4449/2017 and EU Regulation 537/2014.

Our firm applies the International Standard on Quality Management (ISQM) 1 “Quality Management

for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related

Services engagements”, and consequently maintains a comprehensive quality management system,

which includes documented policies and procedures regarding compliance with ethical requirements,

professional standards, and applicable legal and regulatory requirements.

We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our

conclusion.

Responsibilities of the Company’s Management for the Sustainability Statement

The Company’s Management is responsible for designing and implementing an appropriate Process to

identify the information reported in the Sustainability Statement in accordance with the ESRS and for

disclosing this Process in section “Double Materiality Assessment” of the Sustainability Statement.

More specifically, this responsibility includes:

• The understanding of the context in which the Company activities and business relationships take

place and developing an understanding of its affected stakeholders.

• The identification of the actual and potential impacts (both negative and positive) related to

sustainability matters, as well as risks and opportunities that affect, or could reasonably be expected

to affect, the Company’s financial position, financial performance, cash flows, access to finance or

cost of capital over the short-, medium, or long-term.

• The assessment of the materiality of the identified impacts, risks and opportunities related to

sustainability matters by selecting and applying appropriate thresholds and

• The making of assumptions that are reasonable in the circumstances.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The Company’s Management is further responsible for the preparation of the Sustainability Statement,

in accordance with article 151 of L.4548/2018, as amended with L.5164/2024 and in force, by which

article 19(a) of EU Directive 2013/34 was incorporated into Greek legislation.

In this context, the Company’s Management is responsible for:

• The compliance of the Sustainability Statement with the ESRS.

• The preparation of the disclosures in section “European Taxonomy” of the Sustainability Statement,

in compliance with Article 8 of EU Regulation 2020/852.

• The design and implementation of such internal controls that management determines are

necessary to enable the preparation of the Sustainability Statement, that is free from material

misstatement, whether due to fraud or error.

• The selection and implementation of appropriate reporting methods and making assumptions and

estimates about individual sustainability disclosures within the Sustainability Statement that are

reasonable in the circumstances.

The Company’s Audit Committee is responsible for supervising the drafting process of the Company’s

Sustainability Statement.

Inherent limitations in preparing the Sustainability Statement

In reporting forward-looking information in accordance with ESRS, the Company’s Management is

required to prepare the forward-looking information on the basis of disclosed assumptions, about

events that may occur in the future and possible future actions by the Company. The actual outcome is

likely to be different since anticipated events frequently do not occur, as expected.

As stated in section “Climate Change Management, Energy, & GHG Emissions” of the Sustainability

Statement, the information incorporated in the relevant disclosures is based, among other things, on

climate-related scenarios, which are subject to inherent uncertainty regarding the likelihood, timing or

impact of potential future natural and transient climate-related impacts.

Our work covered the items specified in the “Scope of Work Performed” section to obtain limited

assurance based on the procedures included in the Program, as this is defined in that section. Our work

does not constitute an audit or review of historical financial information, in accordance with applicable

International Standards on Auditing or International Standards on Review Engagements, and therefore

we do not express any assurance other than those listed in the "Scope of Work Performed" section.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Practitioner’s responsibilities

This limited assurance report has been drawn up based on the provisions of Article 154C of L.

4548/2018 and Article 32A of L.4449/2017.

Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about

whether the Sustainability Statement is free from material misstatement, whether due to fraud or

error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise

from fraud or error and are considered material if, individually or in the aggregate, they could

reasonably be expected to influence decisions of users taken on the basis of the Sustainability

Statement as a whole.

As part of a limited assurance engagement in accordance with ISAE 3000 (Revised), we exercise

professional judgement and maintain professional skepticism throughout the engagement.

Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:

• Carrying out risk assessment procedures, including an understanding of the relevant internal control

gaps, to identify risks related to whether the Process, followed by the Company to determine the

information referred to in the Sustainability Statement does not cover the applicable requirements

of the ESRS, but not for the purpose of providing a conclusion regarding the effectiveness of the

internal controls on the Process and

• Designing and carrying out procedures to assess whether the Process for identifying the information

referred to in the Sustainability Statement is consistent with the description of the Process, as

disclosed in section “Double Materiality Assessment” of the said Statement.

Moreover, we are responsible for:

• Performing risk assessment procedures, including an understanding of the relevant internal control

mechanisms, to identify those disclosures that are likely to be materially misstated, whether due to

fraud or error, but not for the purpose of providing a conclusion on the effectiveness of the

Company's internal control mechanisms.

• Designing and carrying out procedures related to those disclosures of the Sustainability Statement,

in which a material error is likely to occur. The risk of not detecting a material misstatement arising

from fraud is higher than that arising from error, as fraud may involve collusion, forgery, intentional

omissions, misrepresentations or the circumvention of internal control barriers.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Scope of Work Performed

Our work includes performing procedures and obtaining assurance evidence for the purpose of deriving

a limited assurance conclusion and covers only the procedures provided for in the limited assurance

program issued by the ELTE Board of Directors with decision number 262/22.01.2025, as it was formed

for the purpose of issuing a limited assurance report on the Company's Sustainability Statement.

Our procedures were designed to obtain a limited level of assurance on which to base our conclusion

and do not provide all of the evidence that would be required to provide a reasonable level of

assurance.

Athens, 31 March 2026

The Cered Auditor Accountant

Maria Chatziantoniou

SOEL R.Ν.: 25301

ERNST & YOUNG (HELLAS)

CERTIFIED AUDITORS ACCOUNTANTS S.A.

Chimarras 8Β

151 25 Maroussi, Greece

Company SOEL R.N.: 107

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

THIS REPORT IS A FREE TRANSLATION FROM THE GREEK ORIGINAL

Independent Auditor’s Report

To the shareholders of Piraeus Port Authority S.A.

Report on the Audit of the Financial Statements

Opinion

We have audited the accompanying financial statements of Piraeus Port Authority S.A. (the “Company”), which

comprise the statements of financial position as at December 31, 2025, and the statements of comprehensive

income, changes in equity and cash flows for the year then ended, and notes to the financial statements, including

material accounting policy information.

In our opinion, the accompanying financial statements present fairly in all material respects, the financial position

of Piraeus Port Authority S.A. as at December 31, 2025 and its financial performance and cash flows for the year

then ended in accordance with International Financial Reporting Standards (“IFRS”), as endorsed by the European

Union.

Basis for Opinion

We conducted our audit in accordance with International Standards on Auditing (“ISAs”), as incorporated in Greek

Law. Our responsibilities under those standards are further described in the “Auditor’s Responsibilities for the Audit

of the Financial Statements” section of our report. We remained independent of the Company throughout the

period of our appointment in accordance with the International Ethics Standards Board for Accountants’ Code of

Ethics for Professional Accountants (“IESBA Code”), as applicable to audits of public interest entities’ financial

statements, together with the ethical requirements that are relevant to the audit of the financial statements in

Greece, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA

Code. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our

opinion.

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of

the financial statements of the current period. These matters and the related risks of material misstatement were

addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon,

and we do not provide a separate opinion on these matters.

For each matter below, our description of how our audit addressed the matter is provided in that context.

We have fulfilled the responsibilities described in the “Auditor’s Responsibilities for the Audit of the Financial

Statements” section of our report, including in relation to these matters. Accordingly, our audit included the

performance of procedures designed to respond to our assessment of the risks of material misstatement of the

financial statements. The results of our audit procedures, including the procedures performed to address the

matters below, provide the basis for our audit opinion on the accompanying financial statements.

Page 366 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Key Audit Matters

How our audit addressed the Key Audit Matters

Measurement of tangible and intangible assets under construction

In the course of its operations and in accordance with

the obligations arising from the Concession Agreement,

the Company undertakes the development,

maintenance and exploitation of port infrastructure,

which constitutes a significant portion of its total assets.

As at 31 December 2025, the total amount of tangible

and intangible assets under construction amounted to

€222 million.

During the year, the Company implemented significant

capital investments amounting to €107 million. The

accounting monitoring and measurement of these

assets require the exercise of significant judgement by

Management, particularly with respect to the

distinction between capital and operating

expenditures, as well as the identification of the point

in time at which assets are available for their intended

use.

Furthermore, the nature, scale and duration of projects

under construction, combined with exposure to

regulatory approvals, tendering procedures and

potential delays or cost overruns, together with the

required monitoring analyses, increase the complexity

of their monitoring and may indicate the existence of

impairment indicators.

We determined the measurement of tangible and

intangible assets under construction as one of the Key

Audit matters due to the materiality of the related

balances, the level of judgement exercised by

Management and the nature and extent of the audit

procedures designed and performed.

Disclosures related to tangible and intangible assets

under construction are included in Notes “2.c.1(vii)

Impairment of property, plant and equipment”, “3(a)

Tangible Assets”, “3(c) Impairment of non‑financial

Assets”, “3(f) Intangible Assets”, “4. Property, Plant and

Equipment” and “7. Intangible Assets” to the financial

statements.

The audit procedures we performed in this area included, among

others, the following:

• We obtained an understanding of the processes, policies and

methodologies applied by Management for monitoring tangible

and intangible assets under construction.

• We evaluated Management’s judgements regarding the

distinction between capital and operating expenditures.

• We reviewed Management’s assessment of whether indicators

of impairment existed for tangible and intangible assets under

construction as at 31 December 2025.

• We held meetings and discussions with the Company’s

Management regarding the nature and current status of a

sample of projects under construction.

• We examined, on a sample basis, expenditures capitalized as

tangible and intangible assets under construction, in relation to

the relevant contracts, invoices and other supporting

documentation, such as the Company’s analyses and engineers’

and constructors’ certifications. We also assessed whether these

expenditures met the criteria for capitalization.

Finally, we evaluated the adequacy of the related disclosures

included in Notes “2.c.1(vii) Impairment of property, plant and

equipment”, “3(a) Tangible Assets”, “3(c) Impairment of non‑financial

Assets”, “3(f) Intangible Assets”, “4. Property, Plant and Equipment”

and “7. Intangible Assets” to the financial statements.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Key Audit Matters

How our audit addressed the Key Audit Matters

Provisions for legal cases and contingent liabilities

The Company is involved in a significant number of

pending legal cases arising from the ordinary course of

its operations, the total exposure of which amounts to

€108.3 million, for which a provision of €14.7 million

has been raised as at December 31, 2025. The

Company’s portfolio of pending legal cases mainly

relates to claims involving employees, the Greek State,

neighboring municipalities, as well as other third

parties.

The recognition and measurement of provisions, as well

as the disclosure of contingent liabilities, require the

exercise of significant judgment and estimation by

Management, particularly in relation to:

• the likelihood of an unfavorable outcome of the

cases,

• the potential outflow of economic resources, and

• the reliable estimation of the related amount.

This process is based, among other factors, on

Management’s assessments, on opinions provided by

internal and external legal advisors, as well as on the

interpretation of the applicable legislation. Due to the

nature of the cases and the inherent uncertainty

involved, such estimates are subject to change.

We determined provisions for legal cases and

contingent liabilities as one of the Key Audit Matters

due to the significant number of pending legal cases

and the materiality of the related amounts, as well as

due to the need for extensive estimates and

assumptions by Management in determining the

amount of the related provision.

Disclosures related to provisions for pending legal cases

and contingent liabilities are included in Notes “2.c.1(ii)

Provisions for legal cases and contingent liabilities”,

“18. Provisions” and “32(a) Litigation and Claims” to the

financial statements.

The audit procedures we performed in this area included, among

others, the following:

• We obtained an understanding of the processes, policies and

methodologies applied by Management, in cooperation with the

Company’s Legal Department, for monitoring pending legal cases

and assessing the related provision.

• We obtained a letter from the Company’s Legal Department,

accompanied by a detailed schedule of all pending legal cases in

which the Company is involved, prepared by the Company’s

Legal Department, either as defendant or claimant, including the

assessments of the Company’s legal advisors regarding their

probable outcome and the corresponding provision.

• We obtained letters from the Company’s external legal advisors,

providing a detailed overview of the pending legal cases under

their responsibility, including their assessments of the probable

outcome.

• We held meetings and discussions with representatives of the

Legal Department and the Company’s Management regarding

the nature and current status of a sample of pending legal cases.

• We examined whether the pending legal cases and the related

provisions, as presented in the financial statements, were

supported by the underlying analyses with an assessment date of

31 December 2025.

Finally, we evaluated the adequacy of the related disclosures

included in Notes “2.c.1(ii) Provisions for legal cases and contingent

liabilities”, “18. Provisions” and “32(a) Litigation and Claims” to the

financial statements.

Page 368 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Other Matter

The Company’s financial statements for the prior financial year ended 31 December 2024 were audited by another

Statutory Auditor. For that financial year, the Statutory Auditor issued an audit report dated 31 March 2025 with

an unmodified opinion.

Other information

Management is responsible for the other information in the Annual Financial Report. The other information,

includes the Board of Directors’ Report, for which reference is also made in section “Report on Other Legal and

Regulatory Requirements”, the Statements of the Members of the Board of Directors, and any other information

either required by law or voluntarily incorporated by the Company in its Annual Financial Report prepared in

accordance with Law 3556/2007, but does not include the financial statements and our auditor’s report thereon.

Our opinion on the financial statements does not cover the other information and we do not express any form of

assurance conclusion thereon.

In connection with our audit of the financial statements, our responsibility is to read the other information

identified above and, in doing so, consider whether the other information is materially inconsistent with the

financial statements, or our knowledge obtained in the audit, or otherwise appears to be materially misstated. If,

based on the work we have performed, we conclude that there is a material misstatement of this other information,

we are required to report that fact. We have nothing to report in this regard.

Responsibilities of the Management and Those Charged with Governance for Financial Statements

Management is responsible for the preparation and fair presentation of the financial statements in accordance with

International Financial Reporting Standards as endorsed by the European Union, and for such internal control as

management determines is necessary to enable the preparation of financial statements that are free from material

misstatement, whether due to fraud or error.

In preparing the financial statements, management is responsible for assessing the Company’s ability to continue

as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of

accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic

alternative but to do so.

The Company’s Audit Committee (Article 44, Law 4449/2017) is responsible for overseeing the Company’s financial

reporting process.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Auditor’s Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from

material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion.

Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance

with ISAs, as incorporated in Greek Law, will always detect a material misstatement when it exists. Misstatements

can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably

be expected to influence the economic decisions of users taken on the basis of these financial statements.

Αs part of an audit in accordance with ISAs, as incorporated in Greek Law, we exercise professional judgment and

maintain professional scepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the financial statements, whether due to fraud or

error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is

sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement

resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery,

intentional omissions, misrepresentations, or the override of internal control.

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are

appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the

Company’s internal control.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and

related disclosures made by management.

• Conclude on the appropriateness of management’s use of the going concern basis of accounting and, based

on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that

may cast significant doubt on the Company’s ability to continue as a going concern. If we conclude that a

material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures

in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are

based on the audit evidence obtained up to the date of our auditor’s report. However, future events or

conditions may cause the Company to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the financial statements, including the disclosures,

and whether the financial statements represent the underlying transactions and events in a manner that

achieves fair presentation.

We communicate with those charged with governance regarding, among other matters, the planned scope and

timing of the audit and significant audit findings, including any significant deficiencies in internal control that we

identify during our audit.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

We also provide those charged with governance with a statement that we have complied with relevant ethical

requirements regarding independence, and to communicate with them all relationships and other matters that

may reasonably be thought to bear on our independence, and where applicable, related safeguards.

From the matters communicated with those charged with governance, we determine those matters that were of

most significance in the audit of the financial statements of the current period and are therefore the key audit

matters.

Report on Other Legal and Regulatory Requirements

1. Board of Directors’ Report

Taking into consideration that management is responsible for the preparation of the Board of Directors’ Report and

the Corporate Governance Statement that is included therein, in accordance with the provisions of paragraph 1,

citations aa, ab and b, of article 154C of Law 4548/2018, which do not include the sustainability statement, on

which we have issued a limited assurance report dated 31/03/2026, based on International Standard on Assurance

Engagements 3000 (Revised), we report that:

a) The Board of Directors’ Report includes a Corporate Governance Statement that contains the information

required by article 152 of Law 4548/2018.

b) In our opinion the Board of Directors’ Report has been prepared in accordance with the legal requirements of

articles 150 of Law 4548/2018, excluding the requirement of paragraph 5A of article 150 of the same law to

submit a sustainability statement, and the content of the Board of Directors’ report is consistent with the

accompanying financial statements for the year ended December 31, 2025.

c) Based on the knowledge we obtained during our audit, concerning Piraeus Port Authority S.A. and its

environment, we have not identified information included in the Board of Directors’ Report that contains a

material misstatement.

2. Additional Report to the Audit Committee

Our opinion on the accompanying financial statements is consistent with our Additional Report to the Audit

Committee of the Company, in accordance with Article 11 of the EU Regulation 537/2014.

3. Provision of Non-audit Services

We have not provided in the Company any prohibited non-audit services per Article 5 of the EU Regulation

537/2014.

Permissible non-audit services provided by us to the Company during the year ended December 31, 2025, are

disclosed in Note 26 of the accompanying financial statements.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

4. Appointment of the Auditor

We were appointed for the first time as auditors of the Company pursuant to the resolution of the Annual Ordinary

General Assembly of Shareholders dated 8 July 2025.

5. Rules of Procedure

The Company has in place Rules of Procedure, the context of which is in accordance with the provisions of article

14 of Law 4706/2020.

6. Reasonable Assurance report on the European Single Electronic Format

Subject Matter

We have been engaged to perform a reasonable assurance engagement in order to examine the digital file of

Piraeus Port Authority S.A., prepared in accordance with the European Single Electronic Format (“ESEF”), which

includes the financial statements of the Company for the year ended December 31, 2025 in XHTML format

[549300UNB6JCR0XZT864-2025-12-31-en.xhtml] (the “Subject Matter”), and report about whether the Subject

Matter is prepared in accordance with the Applicable Criteria.

Applicable Criteria

The Applicable Criteria for the European Single Electronic Format (ESEF) are defined in the EU Delegated Regulation

2019/815, as amended by the EU Delegated Regulation 2020/1989 of the European Commission (the “ESEF

Regulation”) and the Interpretative Communication of the European Commission 2020/C 379/01 dated 10

November 2020, as required by Law 3556/2007 and the relevant communications of the Hellenic Capital Market

Commission and the Athens Stock Exchange.

The Applicable Criteria provide, among others, that all annual financial reports should be prepared in XHTML

format.

Responsibilities of Management and Those Charged With Governance

Management is responsible for the preparation and submission of the financial statements of the Company for the

year ended December 31, 2025, in accordance with the Applicable Criteria, and for such internal control as

management determines is necessary to enable the preparation of the digital file that is free from material

misstatement, whether due to fraud or error.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Auditor’s Responsibilities

Our responsibility is to issue this report regarding the evaluation of the Subject Matter, based on the work

performed, which is described below in the section “Scope of work performed”.

We conducted our engagement in accordance with the International Standard on Assurance Engagements 3000

(Revised), "Assurance Engagements Other Than Audits or Reviews of Historical Financial Information” (ISAE 3000).

ISAE 3000 requires that we plan and perform our engagement to obtain reasonable assurance for the evaluation

of Subject Matter in accordance with the Applicable Criteria. As part of the procedures performed, we assess the

risk of material misstatement of the information related to the Subject Matter.

We believe that the evidence we have obtained is sufficient and appropriate to provide a reasonable basis for our

conclusion.

Professional ethics and quality management

We remained independent of the Company throughout the period of this assignment, and we have complied with

the requirements of International Ethics Standards Board for Accountants’ Code of Ethics for Professional

Accountants (IESBA Code), the ethical and independence requirements of Law 4449/2017 and the EU Regulation

537/2014.

Our audit firm applies the International Standard on Quality Management (ISQM) 1, “Quality Management for Firms

that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services engagements”,

which requires that we design, implement and operate a system of quality management including policies or

procedures regarding compliance with ethical requirements, professional standards and applicable legal and

regulatory requirements.

Scope of work performed

The assurance engagement we performed is limited to the objectives included in the Decision 214/4/11-02-2022

of the Board of Directors of the Hellenic Accounting and Auditing Standards Oversight Board and the guiding

instructions to auditors in connection with their assurance engagement on the European Single Electronic Format

(ESEF) of public issuers in regulated Greek markets, as issued by the Institute of Certified Public Accountants of

Greece on February 14, 2022, in order to obtain reasonable assurance that the financial statements of the Company

prepared by management comply, in all material respects, with the Applicable Criteria.

Inherent limitations

Our work is limited to the objectives mentioned in the section “Scope of work performed” for obtaining reasonable

assurance based on the procedures described. In this context, the work we performed could not guarantee that all

issues that might be considered material weaknesses would be disclosed.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Conclusion

Based on the procedures performed and the evidence obtained, we express the conclusion that the financial statements

of the Company for the year ended December 31, 2025, in XHTML file format [549300UNB6JCR0XZT864-2025-12-31-

en.xhtml] has been prepared and presented, in all material respects, in accordance with the Applicable Criteria.

Athens, 31 March 2026

The Cered Auditor Accountant

Maria Chatziantoniou

SOEL R.Ν.: 25301

ERNST & YOUNG (HELLAS)

CERTIFIED AUDITORS ACCOUNTANTS S.A.

Chimarras 8Β

151 25 Maroussi, Greece

Company SOEL R.N.: 107

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

ANNUAL

FINANCIAL STATEMENTS

PPA S.A.

for the year

January 1

– December 31

, 2025

In accordance with the International Financial Reporting

Standards as adopted by the European Union

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

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

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

STATEMENT OF FINANCIAL POSITION AS AT DECEMBER 31, 2025

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

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

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

CASH FLOW STATEMENT FOR THE YEAR ENDED DECEMBER 31,2025

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

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

1. ESTABLISHMENT AND ACTIVITY OF THE COMPANY

“Piraeus Port Authority S.A” (from now on “PPA S.A.” or “Company”) was established in 1930 as Civil

Law Legal Corporation (C.L.L.C.) by Law 4748/1930, which was revised by L.1559/1950 and was ratified

by L.1630/1951 and converted into a Societé Anonyme (S.A.) by Law 2688/1999. The Company is located

at Municipality of Piraeus, at 10 Akti Miaouli street, TC 185 38.

The Company’s main objective is to perform its obligations, conduct its activities, and exercise its

faculties under or in respect of the concession agreement between the Company and the Hellenic

Republic dated 13 February 2002 regarding the use and exploitation of certain areas and assets within

the Port of Piraeus, as amended and in force.

The Company may, by way of an illustrative but not exhaustive list, conduct and be engaged in the

following activities:

- to use all rights assigned to the Company pursuant to the Concession Agreement and maintain,

utilize, and exploit all concession assets in accordance with the Concession Agreement;

- provide services and facilities to vessels, cargo, and passengers, including ship berthing and cargo

and passenger handling to and from the port;

- install, organize, and exploit all kinds of port infrastructure;

- undertake any activities related to the port and all other commercial activities associated with or

reasonably incidental to the operation of the port of Piraeus;

- engage third parties to provide any kind of port services;

- award contracts for works;

- engage in such further activities as are prudent or customary for the proper conduct of its business

and operations in accordance with the Concession Agreement; and

- engage in any activities, transactions, or operations of a type that are generally conducted by

commercial corporations.

The main activities of the Company are anchoring services of vessels, handling cargo, loading and

unloading services, as well as goods storage and car transportation. The Company is also responsible for

the maintenance of port facilities, the supply of port services (water, electricity, telephone connection,

etc.), for services provided to travelers (coastal and cruise ships), and for renting space to third parties.

The Company is governed by the principles of L. 4548/2018, which replaced the Company Law

2190/1920 and the founding Law 2688/1999, as amended by Law 2881/2001 and Law 4404/2016.

The duration period of the Company is one hundred (100) years from the effective date of Law

2688/1999. This period may be extended by special resolution of the shareholders' general meeting.

COSCO SHIPPING (Hong Kong) Limited controlled the 51% of the voting rights, with the date of transfer

of such rights on 10 August 2016. COSCO SHIPPING (Hong Kong) Limited is 100% held by China Shipping

Company Limited, which is 100% held by China COSCO SHIPPING Corporation Limited, a Chinese state-

owned company. As a result, China COSCO SHIPPING Corporation Limited, by indirectly holding 100% of

COSCO SHIPPING (Hong Kong) Limited, indirectly held 51% of the voting rights in PPA.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

On 6 October 2021, an over-the-counter transaction took place where COSCO SHIPPING (Hong Kong)

Co., Limited acquired from Hellenic Republic Asset Development Fund S.A. an additional 16% of shares

in PPA S.A. As a result, the percentage of voting rights of COSCO SHIPPING (Hong Kong) Co., Limited in

PPA S.A. has increased from 51% to 67%. The above transaction has taken place under an Amended

Share Purchase Agreement between COSCO SHIPPING (Hong Kong) Co., Limited as Purchaser and

Hellenic Republic Asset Development Fund S.A. as Seller, following ratification of an Amendment to the

Concession Agreement between the Hellenic Republic and PPA S.A. (Law 4838/2021, Government

Gazette 180A/ 01.10.2021).

As a result of the above transaction, China COSCO Shipping Corporation Limited indirectly holds 67% of

voting rights in PPA S.A.

The Company’s number of employees as of December 31, 2025, amounted to 1.058. At December 31,

2024, the respective number of employees was 1.024.

2. BASIS OF PRESENTATION OF FINANCIAL STATEMENTS:

(a) Basis of Preparation of Financial Statements

The financial statements have been prepared in accordance with International Financial Reporting

Standards (IFRS) as adopted by the European Union. These financial statements have been prepared

under the historical cost.All amounts presented in the financial statements are in euros. Any

differences between the amounts included in the financial statements and the respective amounts

included in the notes are attributed to rounding.

The preparation of financial statements according to the IFRS requires estimates and assumptions to

be made by the management, influencing the assets and liabilities amounts, the disclosure of potential

receivable and liabilities as at the financial statements date, as well as the revenue and expenditure

amounts, during the financial period. Actual results may differ from these estimations. The areas

involving a higher degree of judgment or complexity, or areas where assumptions and estimates are

significant to the financial statements, are disclosed in note 2(c).

The Company's management observes closely and continuously the extended conflict in Ukraine, the

war in the Gaza Strip, the turbulent situation in the Middle East, the prevailing situation, which results

in the unsafe transit of cargo ships through the Suez Canal and Red Sea, and their effects on the

macroeconomic and financial environment, such as the energy instability, the increase in energy costs

and bank interest rates, the most intense inflationary pressures, and the most serious complications

in international shipping and global trade, to ensure that all necessary actions and initiatives are

undertaken to minimize possible consequences for the Company’s activities.

Management believes that its strong capital position and liquidity, its activity in different sectors, its

strong and dynamic Μanagement, the experienced human resources as well as the fact that until now

the above conditions have not significantly affected its activities , will allow the Company to

successfully overcome any period of uncertainty and has reached the conclusion that no additional

impairment provisions of the financial and non-financial assets of the Company are required on

December 31, 2025.

The “Advances and other long-term receivables” account from the prior year was reclassified to ensure

consistency and comparability with the corresponding account for the current year.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

(b) Approval of Financial Statements

The Board of Directors of the Company approved the financial statements for the year ended at

December 31, 2025, on 31 March, 2026. The abovementioned financial statements are subject to the

final approval of the Annual GA of the Shareholders.

The Company makes estimates and judgments in order to select the most appropriate accounting

principles taking into consideration the future outcome of events and transactions. Estimates and

judgments are continually evaluated and are based on historical experience and other factors,

including expectations of future events that are believed to be reasonable under the circumstances.

Estimates and judgments adopted in the preparation of the annual financial statements are consistent

with those followed in the preparation of the annual financial statements for the year ended December

31, 2024.

The significant estimates and judgments that have a risk of causing a significant adjustment to the

carrying amounts of assets and liabilities within the next financial year are as follows:

c.1 Significant accounting estimates and assumptions

(i) Allowance for doubtful accounts receivable and legal cases: Management periodically reassess the

adequacy of allowance for doubtful accounts receivable following the simplified approach of IFRS 9 of

calculating expected credit losses (‘ECLs’). The expected loss rate is assessed on the basis of historical

credit losses adjusted to reflect current and forward-looking information. ECLs are based on the

difference between the contractual cash flows due and all the cash flows that the Company expects to

receive and taking into consideration reports from its legal department.

(ii) Provisions for legal cases and contingent liabilities: The Company, in conjunction with its legal

department and its external advisors who manage the cases, assesses the outcome of the litigation at

the end of each financial year. Based on Management's judgment based on all available information,

including the opinion of its legal advisors managing the cases, the Company evaluates the likelihood of

an adverse outcome, as well as the amounts potentially payable to settle the cases, and makes the

necessary provision or disclosure of contingent liabilities related to pending litigation. The above

assessment is a complex process involving judgments about the potential consequences as well as

interpretations of laws and regulations.

(iii) Income taxes: Income tax expense consists of current and deferred tax. According to IAS 12, income

tax provisions are based on estimations as to the taxes that shall be paid to the tax authorities and

includes the current income tax for each fiscal year, the provision for additional taxes which may arise

from future tax audits, and the recognition of future tax benefits. The final clearance of income taxes

may be different from the relevant amounts that are included in these financial statements.

Estimates on deferred tax arise in the process of recognition of deferred tax assets, which is performed

to the extent that it is probable that future taxable profit will be available against which the deductible

temporary differences and the carry forward of unused tax credits and unused tax losses can be utilized.

In addition, the tax rates used for both deferred tax assets and liabilities are the ones that are estimated

to be enacted in the following years, where the differences are expected to reverse.

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(amounts in Euro unless stated otherwise)

(iv) Depreciation rates: The Company’s assets are depreciated over their estimated remaining useful

lives. These useful lives are periodically reassessed to determine whether the original period continues

to be appropriate. The actual lives of these assets can vary depending on a variety of factors such as

technological innovation, maintenance programs and environmental imperatives due to climate

changes.

(v) Provision for staff leaving indemnities: The cost for staff leaving indemnities is determined based on

actuarial valuations. The actuarial valuation requires management to make assumptions about future

salary increases, discount rates, mortality rates, etc. Management, at each reporting date when the

provision is re-examined, tries to give its best estimate regarding the above mentioned parameters.

(vi) Leases: The Company made a significant estimate to determine the “incremental borrowing rate”

that it used to recognize its lease contract with the Greek State because of its special nature. This

contract is the Company's main lease agreement (Note 3 (s)).

(vii) Impairment of property, plant and equipment: Cash flows generation units are tested for

impairment when there are indicators that the carrying amounts may not be recoverable. When value

in use calculations are undertaken, Management estimates the expected future cash flows from the

asset or cash-generating unit, chooses a suitable discount rate and long-term growth indicators in order

to calculate the present value of those cash flows. The subjectivity which is involved in the key

assumptions that are used by Management in the check of impairment and the inherent uncertainty of

these assumptions is high.

The Company's Management, in the context of assessing impairment indicators, takes into account the

broader macroeconomic and geopolitical environment. In particular, current geopolitical developments

are examined, including the ongoing conflicts in Ukraine and the Middle East, as well as potential

disruptions to international supply chains and maritime transport, such as those related to the passage

of commercial vessels through the Suez Canal and the Red Sea region. Management assesses whether

these developments may affect the Company's activities and constitute indications of impairment of the

value of tangible fixed assets or the cash-generating units to which they belong.

No indications of impairment of the Company's tangible fixed assets emerged during the current year.

(viii ) Contingent liabilities: The existence of contingent liabilities requires from Management to make

assumptions and estimates continuously related to the possibility that future events may or may not

occur as well as the effects that those events may have on the activities of the Company.

c.2 Significant judgements on the implementation of accounting policies

Leases: The Company made judgments as to whether the sub-lease agreements in which the Company

is a lessor relate to operating or finance leases. The contracts to which the Company is a lessor relate

mainly to the contract with Piraeus Container Terminal S.A. (Note 3 o(iii)) as well as contracts related to

leased areas to ship repair zone. The management's judgment was based mainly on the duration of the

leases.

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(amounts in Euro unless stated otherwise)

Concerning the contract with Piraeus Container Terminal S.A., in previous years, Management

concluded that it is an operating lease due to its duration and because the lease does not substantially

transfer the risks and rewards of the right of use.

Concerning the concession agreement with the Greek State, the Company concluded that it falls under

the provisions of IFRS 16 and not to the corresponding provisions of IFRIC 12, as the Company has control

over the pricing of its services other than coastal shipping and therefore the contract is a contract lease.

3. MATERIAL ACCOUNTING POLICIES

The Company applies the following material accounting policies for the preparation of the accompanying

financial statements:

(a) Tangible Assets: Buildings, technical projects, and other building installations are valued at acquisition

cost less accumulated depreciation and possible impairment provision. The privately owned land,

machinery, and other equipment, acquired before PPA’s conversion into an S.A., 1.6.1999, were valued

at deemed cost, arising from the Evaluation Committee of article 9 C.L. 2190/1920, while those acquired

afterwards are valued at acquisition cost less accumulated depreciation and possible value impairment

provision.

The acquisition cost of a building installation or equipment consists of the purchase price include import

duties, plus non-refundable purchase taxes, as well as any costs required for the asset to become

operational. Repairs and maintenance are posted to the financial period in which they were incurred.

Significant additions and improvements made at a later stage are capitalized in the relevant asset cost.

Fixed assets constructed by the Company are posted to the self-construction cost, which includes

subcontractors’ fees, materials, and technicians’ payroll costs involved in the construction (including

relevant employer contributions) as well as part of the general administration expenses.

Assets under construction include fixed assets under construction and are stated at their cost. Assets

under construction are not depreciated until the fixed assets are complete and operational.

(b) Depreciation: Fixed assets are depreciated on a straight line basis according to the following useful lives

per fixed asset category:

Fixed Asset Categories

Useful Life (years)

Buildings, technical & port projects

25-40

Machinery & other equipment

10-30

Motor Vehicles

5-12

Floating transportation means

20-35

Furniture, fixture & fittings

5-10

The residual value, the useful life, and the depreciation method of the Company's assets are examined

annually, and they are adjusted if necessary.

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evaluated for possible impairment loss when there are indications that the asset’s book value is over its

recoverable amount.

In addition, the Company's Management considers that given the approved, received from the

competent state bodies, decision of approval of environmental conditions (AEPO)

Dec.YPEN/DIPA/94636/6224/15-9-2023 for its expantion projects and its operation, the current

environmental legislation has no negative impact on the Company's activities and does not create

circumstances indicating that the carrying amount of its non-financial assets is no longer recoverable.

In this direction, all of the Company's activities have been examined in the Environmental Impact Study

(EIS) of PPA SA, which led to the new Environmental Terms Approval Decision (EEPD) of PPA SA issued

in September 2023, which aims to mitigate and offset all impacts of PPA SA's activities on the climate

and the environment in general through appropriate measures.

In the implementation of the AEPO's forecasts, the PPA is currently preparing a Special Climate Shielding

Study, which includes:

• specialization of the findings of the Environmental Impact Study regarding the climate vulnerability

and the port's adaptation needs to climate change,

• examination of the consequences of climate change on the port,

• ensuring compatibility with the Attica Regional Climate Change Adaptation Plan (PESPKA).

When an asset’s book value is over its recoverable amount, the respective impairment loss is posted to

the period's financial results. An asset’s recoverable value is the greater amount between the fair value

less the cost of disposal and the value in use.

Value in use is based on the Company's projected cash flows, discounted to present value using a

discount rate that reflects current economic considerations and risks associated with the particular asset

or cash-generating unit.

For the purpose of assessing impairment, assets are grouped at the lowest level for which cash flows

can be identified separately (cash generating units). Impairment losses recognized in prior periods in

non-financial assets are reviewed at each reporting date for any reversal.

(d) Investment property: Investment property that includes land and buildings is held by the Company for

long-term rental yields and not for its own use. Investment property is measured at cost less

depreciation and impairment.

Land is not depreciated. The depreciation of buildings is calculated using the straight line method over

the buildings’ useful life, which is 30 years. When the carrying amounts of the investment property

exceed their recoverable amounts, the difference (impairment) is charged directly to the statement of

comprehensive income.

Transfers are made to investment property when, and only when, there is a use change, evidenced by

the end of owner occupation.

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(amounts in Euro unless stated otherwise)

(e) Fixed Asset Subsidies: Government grants are recognised when there is reasonable assurance that the

grant will be received, and all attached conditions will be complied with. Subsidies are considered as

deferred revenue and are recognized as income at the same depreciation rate as the relevant subsidized

fixed assets are depreciated. This income is deducted from the depreciation in the period financial

results.

(f) Intangible Assets: Intangible assets include software purchase cost and any expenditure for software

development. Software is carried at cost less accumulated amortization. Software depreciation is

calculated on a straight line basis and its useful life of 3-4 years.

(g) Borrowing Cost: Borrowing costs are interest and other costs an entity incurs in relation to the borrowing

of funds. Borrowing costs directly attributable to the acquisition, construction or production of an asset

that necessarily takes a substantial period of time to get ready for its intended use or sale are capitalised

as part of the cost of the asset.

If the funds were generally raised and used for the construction of fixed assets, the portion of the

borrowing costs capitalized is determined by applying a capitalization factor to the cost of acquiring the

asset. All other borrowing costs are expensed in the period in which they occur.

(h) Financial Instruments: Initial recognition and subsequent measurement

A financial instrument is any contract that gives rise to a financial asset of one entity and a financial

liability or equity instrument of another entity.

▪ Financial assets

Initial recognition and measurement

Financial assets of the Company are classified, at initial recognition, as subsequently measured at

amortised cost, fair value through other comprehensive income, and fair value through profit or loss.

The classification of financial assets at initial recognition depends on the financial asset’s contractual

cash flow characteristics and the Company’s business model for managing them.

Cash and cash equivalents mainly include demand deposits and time deposits held with credit

institutions and are part of the Company's cash Μanagement. These deposits are highly liquid and are

readily convertible into specific amounts of cash without significant risk of loss of the invested capital.

Time deposits may be liquidated at any time upon request of the Company without risk of loss of the

principal. In the event of early termination, there may be a loss of part or all of the accrued interest.

Interest is recognized in the results using the effective interest method.

Except for trade receivables that do not contain a significant financing component or for which the

Company has applied the practical expedient, the Company initially measures a financial asset at its fair

value plus, in the case of a financial asset not measured at fair value through profit or loss, transaction

costs. Trade receivables that do not contain a significant financing component or for which the Company

has applied the practical expedient are measured at the transaction price as determined under IFRS 15.

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(amounts in Euro unless stated otherwise)

In order for a financial asset to be classified and measured at amortised cost or fair value through other

comprehensive income, it needs to give rise to cash flows that are solely payments of principal and

interest on the principal amount outstanding. This assessment is referred to as the ‘solely payments of

principal and interest’ test and is performed at an instrument level.

The Company’s business model for managing financial assets refers to how the Company manages its

financial assets in order to generate cash flows. The business model determines whether cash flows will

result from collecting contractual cash flows, selling the financial assets, or both.

Purchases or sales of financial assets that require delivery of assets within a time frame established by

regulation or convention in the marketplace (regular way trades) are recognised on the trade date, i.e.,

the date that the Company commits to purchase or sell the asset.

Subsequent measurement

For purposes of subsequent measurement, financial assets are classified in four categories:

• Financial assets at amortised cost (debt instruments)

• Financial assets at fair value through OCI with recycling of cumulative gains and losses (debt

instruments)

• Financial assets designated at fair value through OCI with no recycling of cumulative gains and losses

upon derecognition (equity instruments)

• Financial assets at fair value through profit or loss

During the current year, there are no financial assets measured at fair value through other

comprehensive income or through profit or loss.

Financial assets at amortised cost (debt instruments)

This category is the most relevant to the Company. The Company measures financial assets at amortised

cost if both of the following conditions are met:

• The financial asset is held within a business model to hold financial assets to collect contractual cash

flows, and

• The contractual terms of the financial asset give rise on specified dates to cash flows that are solely

payments of principal and interest on the principal amount outstanding.

Financial assets at amortised cost are subsequently measured using the effective interest (EIR) method

and are subject to impairment. Gains and losses are recognised in profit or loss when the asset is

derecognised, modified, or impaired.

The Company’s financial assets at amortised cost include trade and other receivables.

Derecognition of a financial asset

A financial asset (or, where applicable, a part of a financial asset or part of a group of similar financial

assets) is derecognised when:

• The rights to receive cash flows from the asset have expired

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(amounts in Euro unless stated otherwise)

• The Company tranfers a financial asset and the tranfer meets the requirements for write-off.

The Company transfers a financial asset if, and only if, it either:

• transfers the contractual rights to receive the cash flows of the financial asset

• retains the contractual rights to receive the cash flows of the financial asset but assumes a

contractual obligation to pay the cash flows to one or more recipients in an arrangement.

When the Company transfers a financial asset, it shall evaluate the extent to which retains the risks and

rewards of ownership of the financial asset.

In this case:

• if the Company transfers substantially all the risks and rewards of ownership of the financial asset, the

entity shall derecognise the financial asset and recognise separately as assets or liabilities any rights and

obligations created or retained in the transfer.

• if the Company retains substantially all the risks and rewards of ownership of the financial asset, the

Company shall continue to recognise the financial asset.

• if the Company neither transfers nor retains substantially all the risks and rewards of ownership of the

financial asset, shall determine whether it has retained control of the financial asset.

In this case:

(i) if the Company has not retained control, it shall derecognise the financial asset and recognise

separately as assets or liabilities any rights and obligations created or retained in the transfer.

(ii) if the Company has retained control, it shall continue to recognise the financial asset to the extent of

its continuing involvement in the financial asset.

Impairment of financial assets

The Company recognise an allowance for expected credit losses for all debt instruments not held at fair

value through profit or loss. Expected credit losses are based on the difference between the contractual

cash flows due in accordance with the contract and all the cash flows that the Company expects to

receive, discounted at an approximation of the original effective interest rate.

The expected cash flows will include cash flows from the sale of collateral held or other credit

enhancements that are integral to the contractual terms.

For trade and other receivables, the Company apply a simplified approach in calculating expected credit

losses. Therefore, the Company does not track changes in credit risk, but instead recognises a loss

allowance based on lifetime expected credit losses at each reporting date. For other financial assets, the

ECL is based on the 12-month ECL.

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The 12-month ECL is the portion of lifetime ECLs that results from default events on a financial

instrument that are possible within 12 months after the reporting date. It should be noted that no such

case occurred during the fiscal year.

However, when there has been a significant increase in credit risk since origination, the allowance will

be based on the lifetime ECL. The Company considered the risk of default, the days past due and the

historical credit losses experienced adjusted to reflect current and forward-looking information per

debtor to measure the expected credit losses for each individual trade and other receivable balance.

At each reporting date, the Company assess whether the credit risk of a financial asset has increased

significantly from the initial recognition. The Company consider a financial asset in default when

contractual payments past due over the Company’s credit policy. However, in certain cases, the

Company may also consider a financial asset to be in default when internal or external information

indicates that the Company is unlikely to receive the outstanding contractual amounts in full before

taking into account any credit enhancements held by the Company. A financial asset is written off when

there is no reasonable expectation of recovering the contractual cash flows.

▪ Financial liabilities

Initial recognition and measurement

Financial liabilities of the Company are classified, at initial recognition, as financial liabilities at fair value

through profit or loss.

All financial liabilities are recognised initially at fair value and, in the case of loans and borrowings and

payables, net of directly attributable transaction costs.

The Company’s financial liabilities include trade and other payables, loans and borrowings including

bank overdrafts.

Subsequent measurement

The measurement of financial liabilities depends on their classification, as described below:

Loans and borrowings

After initial recognition, interest-bearing loans and borrowings are subsequently measured at amortised

cost using the effective interest rate method. Gains and losses are recognised in the statement of

comprehensive income when the liabilities are derecognised as well as through the effective interest

rate amortisation process.

Amortised cost is calculated by taking into account any discount or premium on acquisition and fees or

costs that are an integral part of the effective interest rate. The effective interest rate amortisation is

included as finance costs in the statement of comprehensive income.

This category generally applies to interest-bearing loans and borrowings. Loans and borrowings are

classified as current liabilities unless the Group and the Company has the right to defer settlement for

at least twelve months from the date of financial position date.

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Trade and other payables

Trade payables are obligations for goods or services that have been acquired in the ordinary course of

business by suppliers. Accounts payable are classified as current liabilities if payment is due within one

year or less. If not, they are presented as non-current liabilities. Trade account payables subsequent to

the initial recognition are measured at amortized cost using the effective interest method.

Derecognition of financial liabilities

A financial liability is derecognised when the obligation under the liability is discharged or cancelled or

expires. When an existing financial liability is replaced by another from the same lender on substantially

different terms, or the terms of an existing liability are substantially modified, such an exchange or

modification is treated as the derecognition of the original liability and the recognition of a new

liability.The difference in the respective carrying amounts is recognised in the statement of

comprehensive income.

▪ Offsetting of financial instruments

Financial assets and financial liabilities are offset, and the net amount is reported in the consolidated

statement of financial position if there is a currently enforceable legal right to offset the recognised

amounts and there is an intention to settle on a net basis, to demand the assets and settle the liabilities

simultaneously.

(i) Share Capital: The share capital includes the Company's ordinary shares that are included in equity.

Upon acquisition of treasury shares, the consideration paid, including the related expenses, is shown as

a deduction from equity (share premium). Expenses incurred for the issue of shares are recognized after

deduction of the relevant income tax, net of the issue proceeds. Expenses related to the issue of shares

for the acquisition of business are included in the acquisition cost of the business acquire.

The Company considers as cash (apart from cash on hand) time deposits and liquid investments

maturing in three months from the acquisition date.

(j) Provisions: Provisions are recognized when the Company has a present obligation (legal or constructive)

as a result of a past event, it is probable that an outflow of resources embodying economic benefits will

be required to settle the obligation and a reliable estimate can be made of the amount of the obligation.

If the effect of the time value of money is material, provisions are measured by discounting the expected

future cash flows at a pre-tax rate that reflects current market assessments of the time value of money

and the risks specific to the liability. Where discounting is used, the increase of the provision due to the

passage of time is recognized as a borrowing cost.

Provisions are reviewed at each reporting date, and if it is no longer probable that an outflow of

resources embodying economic benefits will be required to settle the obligation, they are reversed.

Provisions are used only for expenditures for which they were originally recognized. No provisions are

recognized for future operating losses. Contingent assets and contingent liabilities are not recognized.

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(k) Income Tax (Current and Deferred): Current and deferred income tax assessment are based on the

relevant amounts of the financial statements, according to tax Laws effective in Greece. Current income

tax concerns tax on the Company taxable profits, adjusted according to Greek tax Law and calculated

using the current tax rate on the reference date.

Deferred tax is assessed using the liability method in all temporary tax differences on the balance- sheet

date between the tax base and the accounting value of assets and liabilities. The expected tax

consequences from the temporary tax differences are assessed and stated either as deferred tax

liabilities or as deferred tax assets.

Deferred tax assets are posted to the financial statements for all allowable temporary differences and

tax losses carried forward as far as it is likely to set off these allowable temporary differences against

available taxable profits.

The accounting value of deferred tax assets is revised at each balance- sheet date and it is reduced up

to the point that it is not likely to have enough taxable profits, where part or all of the deferred tax assets

may be set off against. Current income tax receivable and liabilities for current and previous financial

years are valued at the amount expected to be paid to Tax Authorities (or be refunded by them), using

the tax rates (and tax Laws) in force up to the balance- sheet date.

Any differences resulting from tax audits are recorded in accordance with International Accounting

Standard 12 "Income Taxes" in the "Income Tax" line of the Statement of Comprehensive Income, while

the corresponding fines and surcharges are recorded in the "Other Operating Expenses" line of the

Statement of Comprehensive Income in accordance with the provisions of IAS 37.

(l) Revenue Recognition: Revenue is the amount of consideration expected to be received in exchange for

transferring promised services to a customer, excluding amounts collected on behalf of third parties

(value-added tax, other sales taxes, etc.).

The Company recognizes revenue upon the transfer of promising goods or services to customers, in

amounts that reflect the reward to which the Company is expected to be entitled of these goods or

services based on the following five-step approach:

Step 1: To identify the Contract or based on the applicable services described in the Company's tariffs

and regulations.

Step 2: To identify the separate performance obligations within a Contract or regulations.

Step 3: To determine the transaction price.

Step 4: To allocate the transaction price to the performance obligations in the Contract.

Step 5: To recognize revenue when or as a performance obligation is satisfied.

The Company derives revenue from Cargo loading and unloading services, mooring services, storage of

cargo services, income from passenger fees, income from vehicle passage , dry docking, and shipbuilding

repair zones services, the provision of electricity and water to the vessels, environmental services which

include a standard fee charged to each vessel approaching the port and fees related to the waste

handling of the vessels and other supporting services to the vessels.

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(amounts in Euro unless stated otherwise)

Revenue is recognized when (or as) a performance obligation is satisfied by transferring the control of a

promised service to the customer. A customer obtains control of a service if it has the ability to direct

the use of and obtain substantially all of the remaining benefits from that service. Control is transferred

over time or at a point in time when the service is provided to the customer.

Management has determined that for loading and unloading services, berthing and mooring services,

passenger services, services relating to the provision of water and electricity, and for environmental

services there is a single performance obligation which is the loading and unloading of the respective

cargo (container, vehicles, bulk cargo), the berthing and the mooring of the vessel, the unboarding or

boarding of passengers, the provision of water and electricity, the mooring of the vessel and the waste

handling, respectively, and revenue is recognized at a point in time when the respective service is

provided to the customer and the customer obtains the benefit of these services.

For the storage services where the customer is charged with a daily charge for each day that the cargo

remains in the warehouse and for dry-docking and shipbuilding repairs zone services where the

customer is charged with a daily charge for each day that the vessel remains in the zone, the Company

has determined that there is one single performance obligation which is to provide the customer with

the required space and the related services. The Company has concluded that revenue from these

services meets the criteria to be recognized over time because the customer simultaneously receives

and consumes the benefits of the Company’s performance as the Company performs. Therefore, since

the Company’s performance obligation is met evenly, revenue is recognized ratably for the period that

the cargo actually remained in the warehouse and the period that the vessel actually remained in the

zone, respectively. Prices for all services are fixed, based on stand-alone selling prices derived from price

lists.

A receivable is recognized when there is an unconditional right to consideration for the performance

obligations to the customer that are satisfied.

A contract asset is recognized when the performance obligation to the customer is satisfied before the

customer pays or before payment is due, usually when services are transferred to the customer before

the Company has a right to invoice.

A contract liability is recognized when there is an obligation to transfer services to a customer for which

the Company has received consideration from the customer (prepayments) or there is an unconditional

right to receive consideration before the Company transfers a service (deferred income). The contract

liability is derecognized when the promise is fulfilled and revenue is recorded in the profit or loss

statement.

(m) Inventories: Materials and spare parts related to the Company mechanical equipment maintenance are

valued at the lower of acquisition cost and net realisable value and their cost is determined on the

weighted average cost basis. Materials are posted to inventories on purchase and recognized as

expenditure on consumption.

(n) Defined benefit plan: The provision for staff termination indemnities recorded in the statement of

financial position for the defined benefit plan is the present value of the liability for the defined benefit

in addition to changes occurring from any other actuarial profit or loss and the past service cost.

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(amounts in Euro unless stated otherwise)

The discount rate is considered as the yield, at the balance sheet date, of high quality European

corporate bonds which have a maturity which approaches the time period of the Company’s liability.

The liability for this plan is determined using the projected unit credit method from an independent

valuer and includes the present value of accrued services during the year, the interest on future

liabilities, the prior service cost and the actuarial gains or losses.

The cost of current employment of defined benefit plan, the past service cost and finance cost are

recognized in the Statement of Comprehensive Income.

Re-measurements, comprising of actuarial gains and losses, the effect of the asset ceiling, excluding net

interest and the return on plan assets, are recognized immediately in the statement of financial position

with a corresponding debit or credit to the actuarial differences reserve through other comprehensive

income in the period in which they occur. Remeasurements are not classified to profit or loss in

subsequent periods.

(o) Leases:

i. Company as lessee

Leases are recognised as a right-of-use asset and a corresponding liability at the date at which the leased

asset is available for use by the Company. Each lease payment is divided between the lease liability and

the finance cost. The interest on the lease liability for each period of the lease term is equal to the

amount resulting from the application of a fixed periodic interest rate on the outstanding balance of the

lease liability. The right of use asset is depreciated over the shorter period between the useful life of the

asset and the lease contact duration.

The assets and liabilities arising from the lease are initially valued at present value.

Lease liabilities include the net present value of the following lease payments:

• fixed payments (including in-substance fixed payments), ,

• variable lease payment that are based on an index or a rate, which are initially measured using the

ratio or interest rate at the date of commencement of the lease term

• amounts expected to be payable by the lessee under residual value guarantees,

• the exercise price of a purchase option if the lessee is reasonably certain to exercise that option, and

• payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that

option.

The lease payments are discounted using the lessee’s incremental borrowing rate, being the rate that

the lessee would have to pay to borrow the funds necessary to obtain an asset of similar value in a

similar economic environment with similar terms and conditions.

After their initial measurement, lease liabilities are increased by the finance cost and reduced by the

lease payments. The lease liability is remeasured to reflect any reassessment or lease modifications or

to reflect revised in-substance fixed lease payments.

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(amounts in Euro unless stated otherwise)

The Company elected to use the on-going recognition exemptions for lease contracts that, at the

commencement date, have a lease term of 12 months or less and do not contain a purchase option

(short-term leases), and lease contracts for which the underlying asset is of low value (low-value assets).

Payments associated with short-term leases and leases of low-value assets are recognized on a straight-

line basis as an expense in profit or loss.

Finally, the Company chose not to separate the non-lease components from lease components, and

instead account for each lease component and any associated non-lease components as a single lease

component for all classes of underlying assets to which the right of use relates.

Right-of-use assets are measured at cost comprising the following:

• the amount of the initial measurement of lease liability,

• any lease payments made at or before the commencement date less any lease incentives received,

• any initial direct costs, and

• an estimate of costs to be incurred by the lessee in dismantling and removing the underlying asset,

restoring the site on which it is located or restoring the underlying asset to the condition required by

the terms and conditions of the lease, unless those costs are incurred to produce inventories. The lessee

incurs the obligation for those costs either at the commencement date or as a consequence of having

used the underlying asset during a particular period.

The Company presents the rights of use of the assets of the assets, which are not investment properties,

in the account "Right of use assets".

ii. Company as lessor

The leases in which the Company is a lessor relate solely to sub-leases and are classified as finance or

operating. The Company's sub-lease agreements at 31 December 2025 and 2024 relate exclusively to

operating leases.

Revenue from rental income arising, from operating leases, is accounted for on a straight-line basis over

the lease terms.

The Company reflects the future tax impacts of leases and recognises deferred tax. When recognising

deferred tax the Company has assessed the lease asset and lease liability together as a single or

‘integrally linked’ transaction and assessed the net temporary difference.

iii. Concession Agreement to PPA S.A.: In persuasion of the 35th article of 2932/2001 Law, Greek

Government and the Company signed on 13.2.2002 the Concession Agreement, by which the Greek

State transfers its exclusive right of use and exploitation of port zone lands, buildings and facilities of

Piraeus Port to the Company.

This concession was agreed for fixed period initial duration of 40 years, beginning on the day the

agreement and ending on 13.2.2042. The initial duration is possible to be extended once or several times

by Law and a new written agreement and modification of the 4.1 article of the Concession Agreement.

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(amounts in Euro unless stated otherwise)

With the Common Ministry Decision (CMD) no. 8322/3-12-2008, published in Government Paper

2372/21-11-2008, the Concession Agreement duration has been modified from 40 to 50 years, beginning

on the 13/2/2002 (initial signature date) and ending on the respective date of the year 2052.

Management has examined whether the contract for the concession of the exclusive right to use and

exploit land, buildings and facilities at the Port of Piraeus Land Zone fall under the scope of the provisions

of Interpretation 12. Management concluded that the concession does not fall under the scope of

application of Interpretation 12, but meets the definition of a lease under IFRS 16. Therefore, the

Concession Agreement is accounted for in accordance with the Company's accounting policies for leases

where the Company acts as a lessee.

Government has received 1% of the Company’s consolidated annual income for each of the first 3 years

of the concession. The above percentage has increased to 2% of the Company’s consolidated annual

income after the 3rd year, on the same calculation basis.

Based on the new Concession Agreement signed on 24.6.2016 the percentage to Greek State has

increased to 3.5% of the Company’s consolidated annual income excluding finance income with fixed

minimum fee amounted to € 3.5 million.

As of 1/1/2019, following the adoption of IFRS 16, the minimum guaranteed consideration of the

Concession Agreement is included in the calculation of the lease liability and the related right-of-use

assets (Note 5). The variable part of the consideration, which is calculated as a percentage of the

Company's annual consolidated revenues, is not included in the measurement of the lease liability and

is recognized in the results of the period in which it arises.

The Company’ s most significant obligations arising from this agreement are:

• Constant rendering of port services

• Responsibility for the installation, improvement and maintenance of the security level in Piraeus

Port

• Ensure fair deal to all port users

• Payment of maintenance expenditure for all the property included in the Concession Agreement.

The Concession Agreement was amended by Law 4838/2021, Government Gazette 180A/ 01.10.2021

and the main points are the following:

• non-imposition of liquidated damages for the non-time completion of the first mandatory

enhancements under article 16 of the concession agreement par 5 (a) (i)

• extension of the first investment period for five (5) years

• possibility of suspension of the first investment period - establishment of an amicable

settlement mechanism - possibility of replacing of the first investment period

• non-imposition of liquidated damages against PPA in case of suspension

• extension of the second investment period

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(amounts in Euro unless stated otherwise)

• introduction of a flexible procedure for the approval of final studies and non-mandatory PPA

investments

• extension of the grace for the partial achievement of minimum levels of services

(p) National Insurance Programs:

The obligation for main or supplementary pension provision is covered by the main National Insurance

Department (EFKA- Social Insurance Institute) which concerns private sector and provides retirement,

medical and pharmaceutical services. Each employee is obliged to contribute part of his salary to the

National Insurance Department, while part of the total contribution is paid by the Company. On

employee retirement the National Insurance Department is responsible for their pension payments.

Therefore, the Company has no legal or presumed obligation for future payments according to this

program.

The employees of PPA are entitled upon retirement an allowance from the Unified Fund for

Supplementary Benefits and Lump-sum Benefits (ΕΤΕΑΕP) according to the statutory provisions of the

Fund and the Law N. 2084/92.

For the two welfare sectors, dockworkers and employees of PPA, the granted amount is currently

determined on the basis of the provisions of article 35 of Law N.4387 / 12-05-2016 (FEK 85A), considering

the average of the total remuneration – without accounting holiday bonus - on which were calculated

social insurance contributions for welfare for the five-year period 2009-2013 and with the employee's

work year experience until 31/12/2013.

To this amount is added the total of insurance contributions for welfare from 01/01/2014 and

afterwards. Every employee is required to contribute a part of his monthly salary to the fund, while part

of the total contribution is covered by the Company.

This fund is a legal public company and is responsible for paying the above benefits to employees.

Consequently, the Company has no legal or constructive obligation to pay future benefits under this

plan.

(q) Earnings per Share:

Earnings per share are calculated by dividing the financial period net profit, corresponding to ordinary

shareholders, by the weighted average number of ordinary shares issued. The accompanying financial

statements did not include any profit decreasing bonds or other stock, convertible to shares.

Consequently, diluted earnings per share were not calculated.

(r) Dividends:

Dividends are accounted for when receipt rights are finalized by the resolution of the shareholders

general meeting.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

(s) Concession Agreement of Piers II and III:

The Law 3755/2009 ratified by the Parliament ruled the concession of use and operation of Piers II and

III between the Company and COSCO Pacific Ltd. The contract term provided for 35 years. The

Concession Agreement entered into force on 1/10/2009 and till 31/5/2010 the operation of Pier II was

provided by the staff of the Company as a subcontractor. Within this period the project in Pier I, which

was constructed by the Company, was completed and started its operation by providing services directly

to Company’s clients.

The Agreement B’ Modification of the original Concession Agreement (GG 52 / 30.03.2009) between the

Company and Piraeus Container Terminal (PCT S.A.) following the 'Practical Process Amicable

Settlement', has been published in the Government Gazette 269 / 24.12.2014.

Under the Concession Agreement a payment of guaranteed consideration was foreseen, until

31.12.2021, which was replaced by the payment of Variable consideration that arises as a percentage

on consolidated revenues of PCT SA from the previous contract year.

In addition, it is envisaged by the Concession Agreement the calculation of fixed consideration I & II is

adjusted regarding the length of exploitation and the corresponding sq.m (Note 25). The concession

consideration is calculated and recognized in income for the period in accordance with the terms of the

contract and considered as lease contract based on IFRS 16 (Notes 2c and 3o(iii)).

The payment of Variable Consideration is performed on a monthly basis in arrears and the payment of

the standard exchange every six months in advance (Note 26).

(t) Benefits that depend on the value of share and are settled in cash:

The Company in accordance with IFRS 2 measures the services it obtains and the liability it undertakes

at the fair value of the liability. Until the settlement of the liability, the entity shall remeasure the fair

value of the liability at the reporting date as well as at the settlement date, and any changes in fair value

are recognized in profit or loss for the period. The obligation is measured, initially and at each reporting

date until the final settlement, at the fair value of the units on the increase in the share price from the

grant date and the respective redemption date, with the application of a valuation model taking into

account the terms and conditions under which the units have been granted. The fair value of the long-

term reward plan was determined using the Binomial model taking into account the share price, the

expected volatility of the share, the dividend yield as well as the free interest rate and the liability is

recognized in other long-term liabilities.

(u) Foreign Currency Conversion:

All the operations of the Company are all performed in Euro. Transactions made in foreign currencies

are converted into Euro using exchange rates effective at transaction date. Receivable and liabilities in

foreign currency are adjusted at the financial statements preparation date in order to state the exchange

rates effective at that date. Gains or losses arising from these adjustments are included in the Statement

of comprehensive income as foreign exchange gains or losses.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Changes in accounting policies and disclosures

The standards/amendments that are effective and have been endorsed by the European Union

The accounting policies adopted are consistent with those of the previous financial year, except for the

following IFRS Accounting Standard which has been adopted by the Group/Company as of 1 January

2025:

• IAS 21 The Effects of Changes in Foreign Exchange Rates: Lack of Exchangeability (Amendments).

The amendments are effective for annual reporting periods beginning on or after January 1, 2025.

The newly adopted IΑS Accounting Standard did not have a material impact on the Group’s/Company’s

accounting policies.

Standards that have been issued but are not effective in the current accounting period and the

Company has not adopted earlier

- Standards/amendments that are not yet effective, but have been adopted by the European Union

• IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures - Classification and

Measurement of Financial Instruments (Amendments). In May 2024, the IASB issued amendments

to the Classification and Measurement of Financial Instruments which amended IFRS 9 Financial

Instruments and IFRS 7 Financial Instruments: Disclosures and they become effective for annual

reporting periods beginning on or after January 1, 2026, with earlier application permitted.

Management has assessed that these amendments will not have a material impact.

• IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures - Contracts Referencing

Nature-dependent Electricity (Amendments). In December 2024, the IASB issued targeted

amendments for a better reflection of Contracts Referencing Nature-dependent Electricity, which

amended IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures and they

become effective for annual reporting periods beginning on or after January 1, 2026, with earlier

application permitted.

• Annual Improvements to IFRS Accounting Standards – Volume 11. In July 2024, the IASB issued

Annual Improvements to IFRS Accounting Standards – Volume 11. An entity shall apply those

amendments for annual reporting periods beginning on or after January 1, 2026. Earlier application

is permitted. The Company’s Management is currently assessing the potential impact of the

implementation of the above standards, which at this stage are not expected to have a material

impact.

Standards/amendments that are not yet effective and have not yet been endorsed by the European

Union

• IFRS 18 Presentation and Disclosure in Financial Statements. IFRS 18 introduces new

requirements on presentation within the statement of profit or loss. It requires an entity to

classify all income and expenses within its statement of profit or loss into one of the five

categories: operating; investing; financing; income taxes; and discontinued operations. These

categories are complemented by the requirements to present subtotals and totals for ‘operating

profit or loss’, ‘profit or loss before financing and income taxes’ and ‘profit or loss’.

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(amounts in Euro unless stated otherwise)

It also requires disclosure of management-defined performance measures and includes new

requirements for aggregation and disaggregation of financial information based on the identified ‘roles’

of the primary financial statements and the notes. In addition, there are consequential amendments to

other accounting standards. IFRS 18 is effective for reporting periods beginning on or after January 1,

2027, with earlier application permitted. Retrospective application is required in both annual and

interim financial statements. The standard has not yet been endorsed by the EU.

In subsequent reporting periods, Management will analyze the requirements of this new standard and

evaluate its impact.

• IFRS 19 Subsidiaries without Public Accountability: Disclosures (including amendments)

In May 2024, the IASB issued IFRS 19 – Subsidiaries that are not Public Interest Entities:

Disclosures, while in August 2025 the IASB issued amendments to IFRS 19. IFRS 19 (including the

amendments) is effective for annual reporting periods beginning on or after 1 January 2027,

with earlier application permitted. The Company’s Management has assessed that these

amendments will not have a material impact.

• IAS 21 The Effects of Changes in Foreign Exchange Rates: Translation to a Hyperinflationary

Presentation Currency (Amendments). In November 2025, the IASB issued amendments to

Presentation of Transactions in Hyperinflationary Economies, which amend IAS 21 “The Effects of

Changes in Foreign Exchange Rates”, and which are effective for annual reporting periods beginning

on or after January 1, 2027, with earlier application permitted. The Company’s Management has

assessed that these amendments will not have a material impact.

• Amendment in IFRS 10 Consolidated Financial Statements and IAS 28 Investments in Associates

and Joint Ventures: Sale or Contribution of Assets between an Investor and its Associate or Joint

Venture.

In December 2015, the IASB indefinitely postponed the effective date of this amendment, pending the

outcome of its work on the equity method of accounting.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

4. PROPERTY, PLANT & EQUIPMENT

Property, plant and equipment are analysed as follows:

The Company’s property, plant and equipment are insured with various insurance companies. Insurance

covers compulsory insurance of transport vehicles and machinery up to 30.11.2026 as well as general

civil liability up to 15.03.2026, employer liability up to 13.11.2026, civil liability of executives until

30.07.2026, as well as property insurance up to 16.05.2026 and floating tanks insurance up to

15.03.2026 .

During the year ended December 31, 2025 the total investment in property, plant and equipment

amounted to € 110,860,524.51 (01.01.2024-31.12.2024 € 60,398,016.25 ) and related mainly to the

purchase of machinery and other equipment as well as port infrastructure. In the current year, the

Company made payments of € 110,569,889.10 (01.01.2024-31.12.2024: € 58,818,045.59) to suppliers

relating to investments in tangible fixed assets.

Fixed assets under construction amounting to € 220,389,951.40 mainly include projects in progress as

part of the Company's mandatory investments.

During the current year, the transfers to buildings and building facilities, vehicles/floating tanks, and

other equipment from fixed assets under construction include an amount of € 2,595,608.66 relating to

projects for upgrading of floating tanks and technological equipment, as well as € 619,019.96, which

includes the construction of infrastructure for the improvement of building and mechanical equipment.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

During the previous year, transfers to buildings-buildings installations from assets under construction

include an amount of € 23,422,919.03 relating to the project "Expansion of the Car Terminal

(Herakleous)" which was delivered on January 16

, 2024.

During the current year, the Company capitalized the general borrowing cost which was related to loan

interest and loan guarantee costs, amounted to € 255,319.98 and € 35,315.49 respectively (31.12.2024:

€ 1,371,961.68 and € 208,008.96 respectively), which are mainly included in the fund " Asset under

construction " at the end of the year (note 3(g)).

These amounts were calculated based on an average capitalization rate which corresponds to the

weighted-average interest cost, which was 0.9% in 2025 (2024: 6.00% ).

Property, plant and equipment are tested for impairment when there are indicators that the carrying

amounts may not be recoverable. (note 2.c.1(vii)& 24).

During the current year, there were no indications of impairment of the tangible fixed assets and

therefore the Company did not proceed with an impairment test.

There is no property, plant and equipment that has been pledged as security.

5. RIGHT OF USE ASSETS – LEASE LIABILITIES

The recognised right-of-use assets and lease liabilities as at December 31, 2025 and December 31, 2024

are as follows:

Regarding the recognized right of use assets from the concession of the Greek State, see accounting

principle (3o(iii)).

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The amounts recognized in the statement of comprehensive income and the movement of the right of

use of assets and the lease liability from 1 January 2025 to 31 December 2025 as well as the

corresponding period last year are as follows:

Lease expense less than 12 months for 2025 amounted to € 483,047.10 (31.12.2024: € 303,979.55) and

is included in expenses and specifically in the lines “Payroll and employee related costs” and “Third-

party services” (Note 26).

The most important contract signed by the Company is that with the Greek State for the concession of

the exclusive right to use and exploit the land, buildings and facilities of the land port zone of the Port

of Piraeus (“Greek State Concession”), until 13/2/2052, against a consideration calculated on the annual

revenue of the Company, with a minimum annual consideration of € 3.5 million. The minimum annual

consideration is accounted for in accordance with the requirements of IFRS 16. The Company's

contractual obligation to pay consideration to the Greek State amounts to € 9,002,454.37 as of

December 31, 2025 (31.12.2024: € 8,321,446.24) and was calculated as a percentage of 3.5% of the total

revenue of the current period excluding financial income, and includes the proportion of the minimum

annual consideration, as well as the variable amount of consideration in each reporting period (Notes

22 & 26).

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

6. INVESTMENT PROPERTY

The movement of investment property for ended December 31, 2025 and their balance as at 31.12.2025

was as follows:

The movement of investment property for ended December 31, 2024 and their balance as at 31.12.2024

was as follows:

Investment property includes seven land plots and two buildings (commercial spaces and schools)

located in Athens and Piraeus.

There is no investment property that has been pledged as security.

The fair value of investment property as at December 31, 2025 amounted to € 6.3 million (December

31, 2024: € 6.1 million) according to the valuation of an independent appraiser. The fair value

measurement is based on the income approach method combined with the comparative sales and

market approach method

The investment properties are leased with operating leases and the income from rent for the above

investment property for the year ended December 31, 2025 and December 31, 2024 amounted to €

22,709.07 and € 21,162.08 respectively and is included in other operating income (Note 27). For the

years ended December 31, 2025 and 2024 there were no repair and maintenance costs for

investmentproperty.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

7. INTANGIBLE ASSETS

The movement of intangible assets for ended December 31, 2025 and their balance as at 31.12.2025

was as follows:

The movement of intangible assets for ended December 31, 2024 and their balance as at 31.12.2024

was as follows:

During the current year, the Company made payments of € 1,973,301.14 (01.01.2024-31.12.2024:

€ 390,493.09 ) to suppliers related to investments in intangible fixed assets.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

8. ADVANCES AND OTHER NON-CURRENT ASSETS

This account consists of the following:

The total "Advances to suppliers" refers to the unamortized balance of advance payments that have been

given to suppliers for the construction of investment projects of significant value, which advance payments

are reduced by the amount of the 5% withholding on the issued invoices related to the execution of their

work, in accordance with the signed contracts .

The item is analyzed as follows:

• Project " Expansion of the cruise Passenger Port"

During 2020, an advance payment of € 5,147,718.36 was given to a supplier for the commencement of work

for the project. On 31 December 2020, the amount of withholding amounted to € 394,632.51 and the

respective receivable amounted to € 4,753,085.85. As of December 31, 2021, the amount of withheld on

the issued invoices, amounted to € 840,996.55 and the balance of the receivable amounted to €

3,912,089.30. In previous year an amount of € 134,593.03 was withheld on the value of the invoices issued

and the balance of the receivable amounted to € 3,777,496.27.

In previous fiscal year, an additional advance of € 4,771,785.90 was given for the implementation of

additional future works, which is not subject to withholding. Also, during the previous fiscal year, an

additional advance payment of € 5,000,000.00 was given. During the current fiscal year, an amount of

€394,901.14 was withheld from the value of the invoices issued, and the balance of the receivable

amounted to €13,154,381.03.

• Project " Improvement of Infrastructure of the Ship Repair Zone"

During 2021, an advance payment of € 941,444.13 was given to a supplier for the commencement of work

for the project. On 31 December 2021 the amount of withholding amounted to € 18,212.91 and the

respective receivable amounted to € 923,231.22. In previous year an amount of € 30,149.32 was withheld

on the value of the invoices issued and the balance of the receivable amounted to € 893,081.90.

During 2023, an amount of € 225,121.52 was withheld on the value of the invoices issued and the balance

of the receivable amounted to € 667,960.38. During the previous year an amount of € 86,666.94 was

withheld on the value of the invoices issued and the balance of the receivable amounted to € 581,293.44.

During the current fiscal year, an amount of €95,058.37 was withheld from the value of the invoices issued

and the balance of the receivable amounted to €486,235.07.

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(amounts in Euro unless stated otherwise)

• Project “Underground road connection of Car Terminal with ex-ODDY "

In previous year an advance payment of € 320,815.00 was given to a supplier for the commencement of

work for the project. On 31 December 2022 the amount of withholding amounted to € 71,277.66 while

the respective receivable amounted to € 249,537.34.

During the previous year an amount of € 82,153.69 was withheld on the value of the invoices issued and

the balance of the receivable amounted to € 167,383.65. During the previous year an amount of €

60,033.34 was withheld on the value of the invoices issued and the balance of the receivable amounted

to € 107,350.31. During the current fiscal year, an amount of €55,816.45 was withheld from the value of

the invoices issued and the balance of the receivable amounted to €51,533.86.

• Project “Dredging of port”

In previous year, an advance payment of € 306,416.23 was given to a supplier for the commencement of

work for the project. During the previous year an amount of € 97,396.10 was withheld on the value of the

invoices issued and the balance of the receivable amounted to € 209,020.13. During the current fiscal

year, an amount of € 133,700.85 was withheld from the value of the invoices issued and the balance of

the receivable amounted to € 75,319.28.

9. INCOME TAX (CURRENT AND DEFERRED)

With Law 4799/2021 the income tax rate amounded to 22% for the financial income of the fiscal year 2021 and

afterward.

The amount of income taxes which are reflected in the statements of comprehensive income are as follows:

The payments made for the income tax liability for the current year amounted to € 25,639,618.39 and

concerns to the last two installments of the income tax declaration of the year 2022 amounted to €

8,088,404.23, six installments of the income tax declaration of the year 2024 amounted to € 17,551,214.16.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The reconciliation of income taxes reflected in statements of income and the amount of income taxes

determined by the application of the Greek statutory tax rate to pretax income is summarized as follows:

Greek tax laws and regulations are subject to interpretations by the tax authorities. Tax returns are filed

annually but the profits or losses declared for tax purposes remain provisional until such time, as the tax

authorities examine the returns and the records of the taxpayer and a final assessment is issued. Tax losses,

to the extent accepted by the tax authorities, can be used to offset profits of the five fiscal years following

the fiscal year to which they relate.

Tax Compliance certificate:

The Company has received tax compliance certificates with agreement from its statutory auditor for each

fiscal year from 2011 to 2022 in accordance with Greek tax legislation (2011 - 2013 in accordance with the

provisions of article 82 of Law 2238/1994 , 2014 - 2022 in accordance with the provisions of article 65A of

Law 4174/2013 and for the years 2023 -2024 in accordance with the provisions of articles 78 and 83 par. 54

of Law 5104/2024.

Unaudited fiscal years are analyzed below. It is noted that on 31.12.2025 the years up to 31.12.2019 were

time-barred in accordance with the provisions of paragraph 1 of article 36 of Law 4174/2013.

For the fiscal year 2025, the audit of the tax compliance certificate (in accordance with the provisions of

articles 78 and 83 par. 54 of Law 5104/2024) is in progress and the Company’s Management estimates that

no significant differences will arise from this audit. The audit is expected to be completed after the

publication of the financial statements for this year.

Open tax years:

With the numbers 444/2/1118 of December 14, 2021 and 445/1/1118 of October 9, 2021, the Company was

notified of the partial and full audit order from the General Directorate of Tax Administration (Large

Enterprises Audit Center) for the periods 1/1/2020-31/7/2021 and 1/1/2016-31/12/2019, respectively.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Following the above audit orders, on December 29, 2022, the Company was served with the final act of

corrective determination/imposition of an income tax fine for the tax year 2016, which resulted in additional

income tax and fines of € 6,345,212.94 and € 3,172,606.47 respectively. In addition, relevant surcharges of €

3,057,123.59 were determined.

On December 19, 2023, the final deed of corrective determination/imposition of income tax fine and other

taxes for the tax year 2017,2018 and 2019 was given to the Company (No 154,155,156,157,158,159,160 &

161 with issued date 19.12.2023), resulting in additional total income tax and fines amounting to €

5,213,169.54 and € 3,411,851.56 respectively. In addition, relevant surcharges amounting to € 2,424,132.62

were determined.

The Company, disputing the above final deed of corrective determination/imposition of income tax fine,

proceeded to appeal against to the General Directorate of Tax Administration for all of the deeds, having

previously paid and recognize in the income statement, the total additional income tax and fines, as well as

the corresponding surcharges corresponding to the above acts.

The Company received the decisions of the Head of the Dispute Resolution Division of the Independent

Authority for Public Revenue (AADE) with decision numbers 1423, 1424, 1425, 1426, 1428, & 1429 dated 14

May 2024, where it was decided to reject the claims filed on 18.1. 2024 and the ratification of the (original -

as above) Final Corrective Determination Acts Taxes / Fines of the Head of the CEMEP, re-determining the

final tax liabilities - amounts to be charged based on the present decisions, which resulted in a lower amount

of fines of € 340.354,99. The Company, continuing to challenge the entirety of the above decisions of the

Head of the Dispute Resolution Division of the ADEA, has proceeded to file an appeal before the competent

Administrative Courts for the entirety of these decisions within the legal deadline.

Regarding the income tax for the year 2016, the Administrative Court of Appeal of Piraeus (Decision

A2225/2025) deemed it necessary to postpone the issuance of a final decision and obliged the Head of

KEMEEP to submit to the Court Secretariat, within ninety (90) days from the performance of this decision

(9/2/2026), additional supporting material for the relevant findings in order to ensure the unity and

completeness of its judgment. Following this, the Court set a new hearing for the Company's appeal on

September 18, 2026.

Regarding the Company's appeal for the stamp duties for the years 2018 and 2019, which was heard on the

Administrative Court of First Instance of Piraeus during the trial on November 15, the aforementioned Court

issued decision number 2456/2025, which referred the case to the Head of the Dispute Resolution

Directorate (D.E.E.), in order for the competent audit bodies to conduct a re-audit and submit a new report

to the Court Secretariat within a period of four (4) months from the issuance of the decision. A trial is

expected to be for the re-discussion of the appeal.

Regarding VAT for the years 2017 and 2018, the Company's appeal was discussed on 11/2/2025 before the

Administrative Court of First Instance of Piraeus and the issuance of the relevant decision is expected.

Also, the Company's appeals regarding the income tax for the tax years 2017 and 2018 were discussed to

the Administrative Court of First Instance of Piraeus on 28/5/2025 and the relevant decision is expected.

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(amounts in Euro unless stated otherwise)

In addition, regarding the income tax for the tax year 2019 as well as the time-barred dividends for the tax

year 2017, the Company's appeals have been discussed on the Administrative Court of First Instance of

Piraeus on 12/11/2025 and 10/12/2025 and the relevant decisions are expected.

Also a partial tax audit took place, based on the above audit order for the period 1/1/2020 – 31/7/2021,

concerns the types of taxation: VAT, Other Taxes, Fees Contributions, Audit of Correct Bookkeeping and

Issuance of Data, were submitted to the Company on February 28, 2024 by the General Directorate of Tax

Administration (Large Business Control Center) the Reports of a Partial On-Site Audit for the above taxable

items, where no difference was found.

Additionally, for the remaining unaudited fiscal years of the Company that ended on December 31, 2020 up

to and including December 31, 2025 for the purpose of income tax, as well as the unaudited period 1/8/2021

– 31/12/2025 for the remaining items of taxation, the Company's Management also estimates that no

significant fines and surcharges will arise.

It is noted that, in accordance with the provisions of paragraph 1 of article 36 of Law 4174/2013, as of

31.12.2025, tax years up to and including 31.12.2019 have expired. Nevertheless, the Company is subject to

pending appeal proceedings before the competent authorities against corrective tax assessments and fines

issued for the years 2016–2019, as above.

Deffered tax asset:

The movement of the deferred tax asset is as follows:

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The movement of deferred tax assets/liabilities as at December 31, 2025 and 2024 is as follows:

10. INVENTORIES

Inventories are analysed as follows:

Inventory consumption cost for the year ended December 31, 2025 and 2024 amounted to € 2,409,365.29

and € 2,709,330.25 respectively (Note 26).

Inventories are valued at the lower value between their cost and net realizable value.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

11. TRADE AND OTHER RECEIVABLES

This account is analysed as follows:

Personnel loans: The Company provides interest-free loans to its personnel. The loan amount per employee

does not exceed approximately € 3,000.00 and loan repayments are made by withholding monthly

instalments from the employee salaries.

Other receivable: Other receivable is included a claim from the Greek State (VAT) of the amount of €

1,946,367.97 (31.12.2024: € 1,178,501.80) as well as various claims from third parties and the Municipality

of Drapetsona amounting to € 1,762,906.20 (31.12.2024: € 1,951,708.57).

For the claim of the Municipality of Drapetsona, a provision amounted to € 1,740,149.52 has been recorded,

during the previous years.

Grant receivable: The grant receivable for the previous year concerns the outstanding balance from the

Attica Regional Fund (Special Program Management Service "Attica") of the approved grant for the project

"Expansion of the Passenger Port for cruise ship ”(Note 16), which was collected during the current year.

Interest receivable: Mainly concerns interest receivable by time deposits of the Company (Note 28).

The movement of the allowance for doubtful trade receivables is analysed as follows:

Trade receivables are normally settled on 10 days’ terms. A single customer (Piraeus Container Terminal S.A.)

represents 36,8% of the Company’s total revenue (31.12.2024: 35,7%). The outstanding amount of this

customer as at December 31, 2025 amounted to € 0.01 million (31.12.2024: € 2.2 million) (Note 33).

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

For trade receivables and other receivables, the Company has calculated estimated credit losses (ECLs) based

on lifetime expected credit losses. Taking into consideration that trade receivables are normally settled

within 10 days from the issuance of the invoice, the risk of default and the expected loss rate of 0.52%

(31.12.2024:0.67%) have been determined by management, based on historical data, for all balances that

are outstanding for less than 10 days (no overdue balances). Regarding the outstanding balances above 10

days, the Company has considered the risk of default, the days past due and the historical credit losses

experienced adjusted to reflect current and forward-looking information per debtor to measure the expected

credit losses for each individual trade receivable balance.

The provision used for the previous year relates mainly to the write-off of old customer balances of the

Company following a decision of the Management in the total amount of € 4,843,776.59, which were

impaired in previous years by € 4,776,008.18.

The provision used for the current year mainly concerns write-off of old customer balances of the Company

following a relevant decision by Management in the total amount of € 709,377.87, which had been impaired

in previous years by an amount of € 649,084.75.

The Company is actively monitoring the recoverability of trade receivables and ensures that the loss

allowance recorded reflects, on a timely basis management’s best estimate of potential losses in compliance

with IFRS 9.

The ageing analysis of trade receivables (both gross and net of ECLs) for the year ended 31 December 2025

and 2024 is as follows:

The ageing analysis of receivables past due more than 365 days applies to claims for which and for their most

part, the Company has filed appeals or taken actions for their collectability.

The Company's Τop management and legal department review and reassess the relative cases periodically.

There is no movement of the allowance for doubtful other receivables and advances to suppliers with a

balance amounting to € 2,204,043.54.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The net impairment losses on financial assets are analysed as follows:

12. PREPAID EXPENSES

Prepaid expenses of current year mainly includes an advance payment of the commission for the guarantee

of the paid off loans during the fiscal year, that Company had, amounting to € 1,003,725.70 (31.12.2024: €

1,401,378.68), that is subject to a settlement agreement with the guarantor bank, as well as an advance

payment of car/other wheeled vehicle, property and civil liability insurance premiums amounting to €

508,458.57 (31.12.2024: € 325,605.04).

13. CASH AND CASH EQUIVALENTS

Cash and cash equivalents are analyzed as follows:

The Company taking advantage of its strong liquidity and the favorable interest rate conditions that have

been created, continued its short-term investments in time deposits with both domestic and foreign credit

institutions, with a total value of € 90.5 million (31.12.2024: 120.0 million) with particularly favorable terms

for it within the reference period.Cash at banks earns interest at floating rates based on monthly bank deposit

rates. Interest earned on cash at banks and time deposits is accounted for on an accrual basis and for the

year ended December 31, 2025, amounted to € 2,030,800.65 (31.12.2024: € 5,170,241.47). These amounts

are included in the financial income (Note 28).

14. SHARE CAPITAL

Share capital amounts to € 50,000,000.00 is fully paid up and consists of 25,000,000 ordinary shares, of

nominal value € 2.00 each. There are neither shares which do not represent Company’s capital nor bond

acquisition rights.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

15. RESERVES

Reserves are analysed as follows:

Statutory reserve: Under the provisions of Greek corporate Law, companies are obliged to transfer at least

5% of their annual net profit, as defined, to a statutory reserve, until the reserve equals the 1/3 of the issued

share capital. The Company has covered the amount required by the law in the previous years. The reserve

is not available for distribution throughout the Company activity.

Special tax free reserve Law 2881/2001: This reserve which is exempt from taxation, was created during the

conversion of the Company to a Societé Anonyme. The total Company’s net shareholder funds (Equity) was

valued, by the article 9 Committee of the Codified Law 2190/1920, at € 111,282,225.52, € 50,000,000.00 out

of which was decided by Law 2881/2001 to form the Company share capital and the remaining €

61,282,225.52 to form this special reserve. The above Special Tax-Free Reserve is taxed under the conditions

and to the extent provided for in the general provisions, i.e. in the event of its distribution or capitalization.

Untaxed or specially taxed income reserve: This is interest income which was either not taxed or taxed by

withholding 15% tax at source. In case these reserves are distributed, they are subject to tax on the general

income tax provision basis. Based on Article 72 par.11 of Law 4172/2013 those reserves are subject (from 1

January 2014) to an independent taxation at a rate of 19%. On December 30

, 2014, the Company proceeded

to the taxation of those reserves which amounted to € 1,428,029.58. After the tax deduction created the

taxed reserves of Article 72 N.4172 / 2013 and the taxed reserve with the general provisions amounting to €

6,087,915.56 and € 188,760.09 respectively.

16. GOVERNMENT GRANTS

The movement of the account is analyzed as follows:

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Grants received up to December 31, 2011 relate to the requirements of the Olympic Games of 2004 Olympic

Games, amounting to €11,400,000.00, with an unamortized balance as of December 31, 2025 of

€1,755,385.32, and, on the other hand, the construction of infrastructure for the creation by OSE S.A. a

coastal railway station in the amount of €3,700,000.00, with an unamortized balance as of December 31,

2025, of €1,383,383.68

A grant of € 3,653,518.80 has been received in 2012 and is divided in a) € 2,536,168.80, which relates to the

widening of the quay Port Alon and b) € 1,117,350.00 for the construction of new dock at the area of Agios

Nikolaos in the central port of Piraeus, under the operational program “Improvement of accessibility-energy”

of the Attica region.

In accordance with the financial Correction Decision issued by the Special Management Service for the

Operational Program of the Attica Region, it was decided during the 2017 to correct the amount of

€13,735.39 to correct the grant for the project “Widening of the quay wall at Alon Port, Central Port of

Piraeus” , with an unamortized balance as of December 31, 2025, of €1,622,715.36.

Furthermore, in accordance with the financial Correction Decision issued by the Special Management Service

for the Operational Program of the Attica Region, it was decided during the 2018 to correct the amount of

€546,750.77 to correct the grant for the project “Widening of the new quay wall in the Agios Nikolaos area,”

with an unamortized balance as of December 31, 2025, of € 437,586.18.

Also, a grant amounted to € 9,901,740.45 has been received in December 2013 and relates to the operational

program “Support Accessibility” of the Ministry of Infrastructure, Transport and Network and in particular,

in two projects which have been completed, with an unamortized balance as of December 31, 2025, in the

amount of €5,797,715.62.

The project “Expansion of the Port of Piraeus to Support Cruise Ship Operations” involves the extension of

the Themistocles Pier and the construction of a new pier on the southern side of the main port. This project

was initially included by the Attica Regional Operational Program (ROP) in the “Attica 2014-2020” program,

co-financed by the European Regional Development Fund, in accordance with Decision No. 403/11-2-2020.

With decision A.D. 2580/ 18-10-2024 of the Region of Attica, the project was re-included in the "Attica 2021

- 2027" Program and in the Priority "Strengthening regional interconnection through the promotion of local

and supra-local smart and safe mobility". The total approved grant for this project amounts to €

97,703,694.43.

For project “Expansion of the Port of Piraeus to Support the Cruise” under execution, in the previous year a

grant of € 19,578,373.83 was approved and paid by the Regional Fund of Attica.

As of December 31, 2024, a grant of a total amount of € 6,941,900.58 (Note 11) was pending for collection ,

which the Company received on 24/3/2025.

During the current year, the Company has received a grant of € 2,031,627.99, in addition to the above amount

that was outstanding as of 31/12/2024. The total grand regarding project “Expansion of the Port of Piraeus

to Support the Cruise”, received as of December 31, 2025 amounted to €28,551,902.39, while no additional

amounts were pending collection on the same date.

Grants are considered as future revenue and are recognized in revenue at the same rate at which the

subsidized assets are depreciated (Note 29). Grants related to assets under execution are not amortized until

the fixed asset is completed and available for its intended productive operation.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

17. RESERVE FOR STAFF LEAVING INDEMNITIES

The relevant provision movement for the financial year ended on December 31, 2025 and the financial year

ended on December 31, 2024 is as follows:

On 31 December 2025, the total cost of the provision for staff leaving indemnities amounted to €

2,821,515.81 (31.12.2024: € 1,893,145.38) and is included in personnel fees and expenses (Note 30).

The principal actuarial assumptions used are as follows:

The assumption of a wage increase concerns all employees, but it only affects the benefit provided for

employees who are not included in the Collective Labor Agreements, as the benefit provided by the Collective

Labor Agreements for the rest of the employees is independent of the pensionable salary at the time of the

retirement.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

A quantitative sensitivity analysis for significant assumption as at December 31, 2025 and December 31, 2024

is as shown below:

The expected cash flows in the future years are analyzed as follows:

The average duration of the defined benefit plan obligation at the end of the year is 3,75years (2024: 4,0

years).

18. PROVISIONS

The Company has made provisions for various pending legal cases (Note 32) as at December 31, 2025 in total

amounting to € 14,646,117.11 (31.12.2024: € 14,338,656.33 ).

The movement of the provision for legal claims by third parties is as follows:

The current’s year provision relates to legal cases of employees, Hellenic Republic and other third parties

amounting to € 39,631.96, € 0.00 and € 573,534.65 respectively (31.12.2024: € 282,295.24, € 0.00 and €

288,856.80 ).

The current and prior year reversal of the provision relates to legal cases which have been reassessed by the

Company’s legal department based on current developments or finalized in favor of the Company.

The provision used of current and previous year relates to legal cases mainly related to cases of employees

and other third parties, which were finalized against the Company and a related provision has been made in

prior years (Note32a).

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

19. LONG-TERM & SHORT TERM BORROWINGS

a) Long-term borrowings:

The long term portion of borrowings as at December 31, 2025 and December 31, 2024 respectively is as

follows:

The table below shows the changes in liabilities resulting from financing activities:

The Company's Management decided and proceeded with the early repayment of the above loan obligations

of the total amount of € 26,499,999.99 on 7/3/2025, aiming to avoid relevant financial expenses by taking

advantage of its strong cash position.

The balance of the account during tle previous year related to the following loans between the Company and

the European Investment Bank:

1. Loan of € 35,000,000.00 for the construction of Container Terminal Pier I to N. Ikonio, issued on

30/7/2008.

The balance of the loan ,both on the 7/3/2025 early repayment date and on as at 31 December 2024

amounted to € 8,166,666.59.

2. Loan of € 55,000,000.00 for the construction of Container Terminal Pier I to N. Ikonio, issued on the

10/02/2010.

The balance of the loan ,both on the 7/3/2025 early repayment date and on as at 31 December 2024

amounted to € 18,333,333.40 .

On September 26, 2017 a Guarantee Issuance Facility Agreement was signed between the Company and the

‘’Export Import Bank of China’’, in respect of the issuance of guarantees of an initial amount of €

75,074,999.99 to support the loans from the European Investment Bank outstanding debt.

The guarantee bears an issuance fee of zero point six per cent (0.6%) of the relevant maximum guarantee

amount, for a period of up to 5 years following the full repayment of the loan obligations.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

On 31 December 2025, the issuance fee amounted to € 397,649.96 (31.12.2024: € 208,008.96 .The above

guarantee, in the part that concerns the period that the loans were active, amounted to € 35,315.49

(31.12.2024: € 208,008.96), is included in the general borrowing cost capitalized within the current year

(Notes 4).

The total interest on long-term borrowings for the years ended December 31, 2025 and 2024 amounted, for

the Company, to € 255,319.80 and € 1,579,970.64 respectively, and is also included in the general borrowing

cost which was capitalized within the current year (Notes 4).

b) Short-term borrowings and loan commitments:

On 16.10.2025, an agreement was signed for the increase by €30,000,000.00 of the credit line held by the

Company with the National Bank of Greece S.A., which currently amounts to €80,000,000.00 for the issuance

of Letters of Guarantee, opening of Letters of Credit and/or financing for Working Capital purposes.

The Company now has a credit limit of €53,000,000.00 for Working Capital purposes with the National Bank

of Greece S.A., valid until 31 December 2026. The credit limit carries an annual floating interest rate of

Euribor, plus margin, plus a contribution of 0.60%.

The Company proceeded to raise an amount of €10,000,000.00 under the Open Account Credit Agreement

on 11.04.2025 and proceeded to fully repay the said amount on 30.05.2025. It is noted that the margin on

the said available financing line was modified (reduced), effective from 09.05.2025.

On 17.09.2025, a Credit Agreement with an Open (Inter-Debt) Account of up to €50,000,000.00 for Working

Capital purposes was signed with Eurobank S.A., valid until February 28, 2026.

The credit line bears an annual floating interest rate based on Euribor, plus a margin, plus a 0.60% fee.

20. SUPPLIERS

The balance of suppliers during the current year amounted to € 36.2 million compared to € 27.9 million in

the previous year, showing a significant increase of € 8.3 million or 29.7%. This increase is consistent with

the Company's enhanced investment activity during the current fiscal year compared to the previous one

(Notes 4 & 7), and is mainly due to pricing at the end of the current fiscal year for the "Dredging of the

Central Port" project, as well as to other suppliers of construction projects.

21. DIVIDENDS

Dividends related to fiscal year 2024, paid in 2025: The Annual General Meeting of the Company, which took

place on July 8, 2025, approved the proposal of the BoD proposed for the distribution of dividend for the

fiscal year 2024 amounted to € 48,000,000.00 or € 1.920 per share. The dividend is subject to withholding

tax at the corresponding rate provided by income tax. The dividend for the fiscal year 2024 was paid on

August 8, 2025.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

22. ACCRUED AND OTHER CURRENT LIABILITIES

This account is analyzed as follows:

Taxes Payable: Current period’s amount consists of: a) Employee withheld income tax € 2,462,783.78

(31.12.2024 € 1,889,438.75) and b) other third party taxes € 385,200.22 (31.12.2024: € 193,972.89).

Concession Agreement Liability: The liability relates to the variable amount of annual fee with an equal debit

in the expense account “Concession agreement fee” (Note 26) and excludes the fixed minimum annual fee

for the current period of € 3,500,000.00. Regardless of the application of IFRS 16, the Company's contractual

obligation to pay to the Greek State as at 31 December 2025 amounted to € 9,002,463.63 (31.12.2024: €

8,321,446.24 ) and was calculated as a percentage of 3.5% on the total revenue of the current year excluding

financial income.

Payment in advance: The Company receives payments in advance for services rendered on an ordinary basis,

which are then settled on a regular basis. Customer payments in advance amounted to € 5,082,654.77

(31.12.2024: € 5,603,557.57).

Accrued expenses: Accrued expenses include expenses and services that were provided during the reporting

period but had not yet been invoiced. The change in this item mainly stems from accrued construction work

of € 10,081,864.40 as of 31 December 2025 (31.12.2024: € 1,435,940.90), which are included in “Assets in

progress”.

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Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

23. DEFERRED INCOME

The deferred revenue is analyzed as follows:

The deferred revenue derives from the following:

a) On April 27, 2009 “PCT S.A.” paid € 50,000,000.00 as a one-off consideration for the use of port facilities of

Piers II and III of SEMPO of PPA (N.3755/2009). From the aforementioned amount, €

2,930,211.41 was offset with the cost of supplies and parts provided by PCT S.A., while the remaining amount

of € 47,069,788.59 is amortized over the concession period.

The initial concession period was thirty (30) years, which was increased to thirty five (35) years, after the

completion the construction of the port infrastructure on the east side of Pier III.

Following the transfer of the cumulative amount € 21,853,830.71 on revenue of the years 2009 until 2025, in

the income of the respective years, the new balance at December 31, 2025 amounted to € 25,215,957.88

(December 31, 2024: € 26,560,809.16 ), of which the short-term part amounts to € 1,344,851.16.

b) The Company receives Fixed Annual Consideration from PCT S.A based on the length and surface of the land

under concession. Fixed Annual Considerations is invoiced in advance April and October of each fiscal year. As

a result the company has recognized as deferred revenue of € 3,713,907.78, concerning a short-term part

(which invoiced in advance in 2025 and relates to the period 1.1.2026-31.3.2026) and € 3,567,277.63 (which

invoiced in advance in 2024 and relates to the period 1.1.2025-31.3.2025) as at December 31, 2025 and

December 31, 2024 respectively.

c) Additionally as at December 31, 2025, deferred income includes an amount of € 84,677.57, concerning a

short-term part (31.12.2024: € 126,600.79) which relates to the deferred income from rentals.

Page 421 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

24. SEGMENT INFORMATION

The Company operates in Greece, regardless of the fact that its clientele includes international companies.

Additionally, the Company has no other commercial or industrial activities other than the provision of services

solely in the Port area and does not have income or assets from foreign customers (based on the geographical

area in which they operate).

The port of Piraeus is a port complex activity, putting work in many areas of port activity, such as containers

Car-terminal, shipping, cruise, ship repairing, environmental and logistics services.

It is the main port of coastal connecting mainland Greece and the islands, the main cruise port service in the

country, the main port container, the main car – terminal port of the country.

PPA S.A. provides all the requested port services: water, solid and liquid slot tankers, jack residual oil,

electricity, fiber optics and internet, victuals, repairs, environmental services and is fully connected to all

activities with modern computer systems.

The Company's Management considers that there is no market risk for the activities in question, due to the

fact that these services are related to financial assets that do not have a risk of fluctuation due to changes in

their prices, as they are not traded on the market within the meaning of IFRS 7. The Company does not own

any derivative financial instrument related to the mentioned activities, whose

value or future cash flows may fluctuate due to changes in market prices. The prices of the services are specific

and determined by the respective price lists.

The Management of PPA S.A. monitors at the level of results of the above activities and takes business

decisions based on the implemented internal management information system.

Based on the above and in accordance with the provisions of IFRS 8, the Company has determined to disclose

the following segments:

• Container Terminal

• Consession Arrangement Pier II &III

• Car Terminal

• Coasting

• Cruise

• Ship repairing

• Other segments (water supply, space management, merchandise management)

The other segments include activities representing less than 10 % of total revenue and profit in all segments

and therefore are not disclosed as separate operating segments.

The Company level includes revenues and expenses that are not allocated by operating segment because

management monitors them at entity level.

The Company's Management regularly monitors the performance of each operating segment and makes

business decisions based on the results. Management does not make business decisions and does not monitor

periodically the assets and liabilities of the business sectors and for this reason does not make the relevant

disclosures as required by the provisions of IFRS 8.

Page 422 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The segment information for the years ended December 31, 2025 and 2024 is analysed as follows:

EBITDA is used to measure performance because management believes that this information is the most relevant in evaluating the results of the respective

segments relative to the segments that operate in the same Company and is the primary measure reviewed by our Chief Operating Decision Maker.

Of the Company’s total personnel compensation and expenses for year 2025, approximately 44% relates to the “Container Terminal” business segment.

Page 423 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

25. REVENUES

Revenues are analyzed as follows:

The increase in revenue for the current year compared to the same last year is mainly due to the increase in

revenue of loading and unloading by € 7,770,060.35 or 17.4%, of cruise services-main activity by € 5,044,892.80

or 24.8%, as well as in revenue of mooring by € 2,922,536.60 or 17.2%. This increase was partially offset by a

decrease in revenue of ferry services-main activity of € 3,375,844.02 or 36.9%, of storage services of €

2,073,685.28 or 10.0%, as well as of total revenues from the ship repair activity (Docking and Ship Repair

Services) by € 1,145,882.55 or 7.2%.

The increase in revenue from loading/unloading is mainly due to the activities of the Container Terminal.

Throughput at the Container Terminal, Pier I, for the year 2025 reached 664,581 TEUs, recording an increase

of 17.9% compared to the corresponding year 2024 (563,725 TEUs).

In particular, a significant increase was recorded in domestic cargo (imports and exports) from 232,252 TEUs

in 2024 to 254,591 TEUs in 2025 (+9.6%), as well as transshipment cargo by 23.7% from 331,473 TEUs in 2024

to 409,990 TEUs in 2025.

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

total number of passengers recorded an increase of 9.68% (1,863,397 passengers) compared to 2024

(1,698,877 passengers). Specifically, compared to 2024, there was an 8.2% increase (1,091,364 passengers

compared to 1,008,209 passengers) in homeport passengers and an 11.8% increase (772,033 passengers

compared to 690,668 passengers) in transit passengers.

The increase in berthing revenues comes mainly from cruise ships due to an increased number of arrivals,

recording an increase of 6.42% compared to the corresponding last year, but also due to a change in the

berthing and mooring price (an increase of 15% from that in force in 2024).

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

As well as from the increase in the number of RORO ship arrivals at the Car Terminal, recording an increase of

31.1% compared to the corresponding last year.

The decrease in revenue from ferry shipping is mainly because, from May 1, 2025, and for a period of one (1)

year, the Company proceeded to reduce the fees for ships and passengers of Ferry Shipping by 50% in

accordance with the relevant amendment of the Ministry of Shipping & Island Policy. The amendment has a

significant impact on the revenue of the activity for the period of application of the current year, i.e. reduction

by an amount of € 3.4 million compared to the corresponding period last year, as well as a decrease of € 1.1

million resulting from the mooring of coastal shipping and included in the "Mooring" item.

The decrease in storage revenues is mainly due to the Car Terminal sector, where despite the increase in cargo,

both domestic (31.12.2025: 153,213 vehicles, 31.12.2024: 137,825 vehicles) and transshipment cargo

(31.12.2025: 138,074 vehicles, 31.12.2024: 109,775 vehicles), the malfunction of the supply chain (domestic

and international) during the previous year, has resulted in a significant increase in the time spent by cargoes

at the Company's piers.

The resolution of this emergency situation within the current year had a significant impact on in the revenues

of storage which amounted to approximately € 11.2 million in 2025 (31.12.2024: € 14.8 million) more than

covering the benefit from the increase in other revenues, and mainly the increased levels of handling, leading

to the overall decrease in the segment's revenues (Note 24) and more generally the Company's storage

revenues.

The decrease in revenues from Docking and Ship Repair Services is mainly due to the reduced overall dynamics

of ship repair activity due to repair work on one of the floating docks of PPA that was in progress during the

first half of 2025.

The significant increase in revenue from the Pier II + III concession agreement is mainly due to the increase in

the variable consideration, which amounted to € 74,215,831.56 (31.12.2024: € 66,009,391.37). The concession

consideration is calculated and recognized in income for the period in accordance with the terms of the contract

and considered as lease contract based on IFRS 16.

The Company operates in sectors that are highly seasonal. In particular, the revenues of the Cruise sector are

significantly concentrated in the third quarter due to increased tourist traffic.

At the same time, the ferry shipping activity also shows increased activity during the third quarter, without its

seasonality being considered significant in relation to the Company's overall results.

It is noted that there is no seasonality in the Company's other activities.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

26. ANALYSIS OF EXPENSES

Expenses (cost of sales and administrative expenses) are analyzed as follows:

Payroll and employee related costs: : The significant increase in payroll and employee related costs during the

current year compared to the corresponding period last year is mainly due to the additional incremental increase

in payroll of employees and dock workers according to the CBA in force from 1/8/2024 and 1/7/2024

respectively, the implementation from 1/4/2025 of the new Collective Bargaining Agreement of Supervisors &

Foremen, as well as the increased employment (hourly wages) of dock workers to serve the organic growth

presented in most of the Company's activity sectors in year 2025, as well as the increase in personnel during the

current year compared to the previous year.

Third Party Services: The significant increase in third-party fees and expenses during the current year compared

to the corresponding last year is mainly due to the increase in the use of external partners, mainly for loading

and unloading services, by an amount of approximately € 1.8 million.

Various Expenses: The increase in various expenses during the current year compared to the corresponding last

year is mainly due to the increase in cleaning port services expenses by approximately € 1.9 million, as well as

in guard fee expenses by approximately € 1.0 million.

Additionally, third party services include the fees of the companies “Ernst & Young (Hellas) and "KPMG Certified

Auditors S.A." for the years 2025 and 2024 respectively, regarding the services provided related to the statutory

audit fees for the financial statements (2025: € 154,000.00 and 2024: € 169,000.00), the tax audit certificate

based on article 65A of Law 4174/2013 and POL 1124/18.06.2015 (2025: € 35,000.00 and 2024: € 25,000.00) as

well as other non-audit services (2025: € 8,000.00 and 2024: € 47,000.00).

Page 426 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

27. OTHER OPERATING INCOME / EXPENSES

OTHER OPERATING INCOME

The amounts are analyzed as follows:

Rental income concerns land and building rents as well as the investment properties rent (Note 6).

OTHER OPERATING EXPENSES

The amounts are analyzed as follows:

During the current year, in the “Third-party compensation” are mainly included compensations to suppliers for

differences which arose from their relevant project contracts with the Company.

28. FINANCIAL INCOME/EXPENSES

The financial income is analyzed as follows:

Interest income on bank deposits mainly concern provisions for interest of time deposits , accrued (Note 11)

and finalized that have been concluded both in the previous and current year. This change is due to the

decrease to the amount of the time deposits concluded, as well as the relevant interest rates.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The financial income is analyzed as follows:

29. DEPRECIATION AND AMORTISATION

The amounts are analyzed as follows:

30. PAYROLL AND EMPLOYEE RELATED COST

The amounts are analyzed as follows:

31. EARNINGS PER SHARE

The earnings per share for the years 2025 and 2024 are as follows:

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

32. COMMITMENTS, CONTINGENT LIABILITIES AND REQUIREMENTS

(a) Litigation and Claims: On 31.12.25 the Company is currently involved in several legal proceedings and has

various claims against it of a total amount of approximately € 108.3 million (31.12.2024: € 119.9 million),

concerning mainly labour disputes and legal proceedings with municipalities around the port, arising in the

ordinary course of business.

Based on currently available information, Management and its legal department believe that the outcome

of these proceedings will not have a significant effect on the Company’s operating results or financial

position, except for the recorded provisions in Note 18.

These claims concern mainly labour disputes of a total claimed amount of € 86.2 million (31.12.2024: € 86.4

million), disputes with the Greek State of a total claimed amount of € 3,9 million (31.12.2024: € 4.0 million)

and disputes with suppliers and others of a total claimed amount of € 18.2 million (31.12.2024: € 29.5

million).

The employee labour cases are pending litigations against PPA SA before the civil and administrative courts

of all degrees and relate mainly with: a) claims against PPA for additional compensation for the years 2010

and 2011 for the enforcement of the Agreement between PPA and the labour unions to ensure equal

working conditions and renumeration of PPA ‘s employees following the concession of Pier II to PCT SA, b)

claims against PPA for salary reduction based to the laws 3833/2010, 3845/2010 and 4024/2011 cases

before the privatization of PPA, c) claims against PPA for salary reduction based to the laws 3833/2010,

3845/2010 and 4024/2011 cases according after the privatization of PPA SA , d) Few labor accidents and e)

various other (pay grade cases, dockworkers’ overtime cases before the privatization period).

Disputes with Greek State concern litigations before the administrative courts of all degrees, having to do

with decisions, taxes, charges, fines from Municipalities, Prefecture, Public Service Decisions, Ministerial

Decisions, Public Authorities’ Decision etc. The supplier/client dispute cases concern compensation/financial

differences between PPA and its suppliers or customers arising in the normal course of business.

All other kind of cases that cannot be included to the above two categories are characterized as “other”, for

example non labour accident cases, compensation of third parties, real estate cases, lease differences etc.

and additionally accounts payable to suppliers.

Based on currently available information, Management and its legal department believe that the outcome

of these proceedings will not have a significant effect on the Company’s operating results or financial

position, except for the recorded provisions in Note 18.

(b) Liabilities arising from letters of Guarantee: The Company has issued letters of guarantee amounting to €

15,560,341.00 (December 31, 2024: € € 15,560,341.00 ), of which € 495,829.00 (December 31, 2024: €

495,829.00 ) in favor of the General Directorate of Customs (E 'and F' Customs Office) of the Ministry of

Economy for the operation of all warehouses for temporary storage of goods PPA S.A. Under the current

concession agreement of 24.06.2016 between the PPA and the Greek Government, PPA has issued a letter

of guarantee in favor of the Ministry of Finance General Secretariat of Public Property amounted to €

15,000,000.00.

Page 429 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Concession Agreement signed between the Company and the Hellenic Republic dated on 24.06.2016, as

ratified by Law 4404/2016 (Gov. Gazette A '126 / 08.07.2016), the Company has the contractual obligation

for the implementation of investments in projects within the Port of Piraeus for the five

years, August 2016 - August 2021 amounting to € 293.8 million. (First Investment Period) and for the five-

year period August 2021–August 2026 amounting to € 56 million (Second Investment Period).

The Concession Agreement included specific terms regarding the conditions for the imposition of penal

clauses by the Greek State, in case of non-execution of mandatory investments as of August 2021.

The possibility of imposing penalties under the Concession Agreement was assessed by Compamy

Management during the previous period and was deemed remote, as the Company was able to prove that

delays in the execution of mandatory investment projects were outside the Company's reasonable control

and therefore fell within the exemption from the imposition of penalties in Article 16.5 (a) (i) of the Contract

Concession. This assessment was verified with the agreement of 22/09/2021 Amendment the Concession

Agreement between the Company and the Greek State as verified by Law 4838 / 1.10.2021 Government

Gazette 180 A ' (Note 3 o(3)).

The specific amendment, among others, extends the duration of the First Investment Period, as well as

extends the obligation to start and complete the Second Investment Period by five years respectively.

As at December 31, 2025, the mandatory investments comprise of and include price revisions:

• completed mandatory investments of € 96.2 million (31.12.2024: € 96.2 million),

• projects under construction € 210.0 million (31.12.2024: € 57.7 million)

as well as prepayment for a mandatory investment of € 13.8 million (31.12.2024: € 14.4)

(d) Contractual commitments with creditors: with regard to (d) above and other contracts signed, the outstanding

balance of the contractual commitments with suppliers on significant infrastructure projects (construction,

maintenance, improvements, etc.) at December 31, 2025 amounted to approximately € 164.2 million

(December 31, 2024: € 154.0 million) of which approximately € 66.4 million relate to the project "Passenger

Port Expansion - South Zone - Phase A ' (December 31, 2024: approximately € 68.4 million).

Special Contribution to Social Security Institute (IKA – ETAM): On November 7, 2011 the Company notified

the management of IKA its intention to stop paying the special contribution in favor of the supplementary

fund of Company’s employees, since after the merger of IKA with IKA – TEAM Management of the Company

considers that there is no further obligation. From October 2013, The Company decided to cease the

payments to those institutions. The Management of the Company believes that this contingent liability could

be settled without significant adverse effects on its financial position.

(e) Minimum Future Rents: The minimum future concession and rental income receivable, arising from the

existing rental agreements are as follows:

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

33. RELATED PARTIES

The Company has transactions (provides and receives services) in the normal course of its business with

certain companies controlled by its main Shareholders and considered related parties.

The Company’s transactions and account balances with related companies, as these are defined in IAS 24

,are as follows:

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The revenues of € 90,511,252.16 (2024: € 81,706,669.33) (Note 25) from Piraeus Container Terminal S.A. are

related to the fixed and variable revenue from the concession agreement (PIER II & III) and revenues of €

1,852,057.64 (2024: € 805,208.86 ) related mainly loading/unloading and mooring. The Company recharged

energy costs to the related party under the concession agreement until January 14, 2025, amounted to €

376.064,88 (2024: € 9.169.250,06). After that date, the related party acquired its own electrical substation, and

the re-billing process was therefore concluded.

Page 432 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The transactions with COSCO SHIPPING LINES GREECE S.A. of the previous year mainly related to the supply of

ship services (from loading/unloading and berthing), as well as the provision of car transportation services from

China. In the current year, transactions mainly related to loading/unloading , berthing and storage services.

The transaction with COSCO SHIPPING TECHNOLOGY Co. LTD relates to software support costs.

The transactions with COSCO SHIPPING GLOBAL EXH relate to exhibition expenses.The transaction with COSCO

SHIPPING TECHNOLOGY (Beijing) relates to software update .

The transaction with COSCO (HONG KONG) INSURANCE BROKERS L.T.D. of the current and the previous period

relates to the insurance coverage of PPA S.A. regarding third party liability, employer' s liability, property and

business interruption and directors and officers liability, according to article 17 of the Concession Agreement

(Law 4404/2016).

Board of Directors Members Remuneration: During the year ended December 31, 2025, were paid to the Board

of Directors members. remuneration and attendance costs, amounted to € 1,185,793.99 (31.12.2024: €

1,395,877.64 ) Furthermore during the year ended December 31, 2025 emoluments of € 1,174,245.45

(31.12.2024: € 846,326.35 ) were paid to Managers / Directors for services rendered.

34. FINANCIAL INSTRUMENTS

Fair Value: The carrying amounts reflected in the accompanying sheets of financial position for cash and cash

equivalents, trade and other receivables, suppliers and accrued and other current liabilities approximate their

respective fair values due to the relatively short-term maturity of these financial instruments.

The fair value of variable rate loans and borrowings approximate the amounts appearing in the statements of

financial position.

The Company categorized its financial instruments carried at fair value in three categories, defined as follows:

Level 1: Quoted (unadjusted) values from active financial markets for identical negotiable assets or liabilities.

Level 2: Other techniques for which all inflows that have a significant impact on the recorded fair value are

identified or determined directly or indirectly from active financial markets.

Level 3: Techniques that use inflows that have a significant impact on the recorded fair value and are not based

on quoted prices from active financial markets.

Financial risk management:

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

Credit Risk: The Company's Management estimates that its exposure to credit risk is limited towards the

contracting parties, - as a matter of policy - it receives advances payments or letters of guarantee for most of its

provided services . From the above applied policy are excluded customers who belong to the same group of

companies, as mentioned in note 33 "Related Party Transactions". In addition, the transactional activity between

the Company and its related party company, Piraeus Container Terminal SA, which is the Company's largest

customer in terms of volume, is mainly covered by the terms of the concession agreement between them, which

is under the supervision of the Greek State. It should be noted that despite the very significant amount and

range of related parties transactions, no credit event has occurred until now that could raise a credit risk.

In addition, the Company's cash at banks and time deposits are placed in bank financial institutions in Greece

and generally in European Union, with the following ratings (Moody's credit rating):

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Foreign Exchange Risk: The Company is neither involved in international trade nor has any long term loans in

foreign currency and therefore is not exposed to foreign exchange risk resulting from foreign currency rate

variations.

Interest rate risk: The Company's bank lending concerns two loans in Euro and is subject to one fixed rate and

the other to a variable interest rate (Note 19). The Company, during the year does not use bank borrowing and

therefore there is no interest rate risk.

Additionally, in the context of managing its assets as effectively as possible, as well as limiting any possible

impact of increased borrowing interest rates on its results, the Company's Management, taking advantage of its

strong liquidity, implements short-term reinvestments of these, expoiting the increased interest rates on term

deposits.

The table below presents and analyses the sensitivity of the result in relation to financial assets (cash on hand

and in banks) and financial liabilities (loans) of the Company to the interest rate risk changes assuming a

simultaneous change in interest rates by ± 100 basis points on the Company’s profit.

Liquidity risk: The effective management of liquidity risk is ensured by maintaining sufficient cash and the

availability of financing in case of need. Corporate liquidity risk management is based on the proper

management of working capital and cash flows.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

The following table summarizes the maturity dates of the financial liabilities of 31 December 2025 and 2024

respectively, arising from the relevant contracts at unpaid prices.

Τhe above table includes the interest on long-term loans, which were calculated until maturity according to the

European Investment Bank quarterly information note for the 1st quarter of 2025.

* Trade payables do not have interest and are settled in up to 60 days. Other payables also do not bear any

interest and are settled in up to 12 months.

Capital Management

The primary objective of the Company's capital management is to ensure the maintenance of high credit rating,

and healthy capital ratios in order to support and expand the Company's operations and maximize shareholder

value. The Company's policy is to maintain leverage targets, according to an investment grade profile. The

Company monitors capital adequacy using the ratio of total debt to operating profits, which should be lower

than 9.80 based on the loan agreements (Note 19). The debt includes interest-bearing loans and lease liabilities,

while the operating profit includes profit/(loss) before taxes, financing costs and depreciation.

Amounts of fiscal year 2025

Current

portion

Less than

6 months

6-12 months 2 to 5 years >5 years Total

Borrowings - - - - - -

Lease liabilities 4.368,74 3.514.703,69 11.076,00 14.000.000,00 77.437.500,00 94.967.648,43

Trade and other payables* 23.710.719,51 26.084.597,02 12.857.973,91 - - 62.653.290,44

Total 23.715.088,25 29.599.300,71 12.869.049,91 14.000.000,00 77.437.500,00 157.620.938,87

Amounts of fiscal year 2024

Current

portion

Less than

6 months

6-12 months 2 to 5 years >5 years Total

Borrowings - 3.443.636,38 3.389.257,92 21.828.157,50 - 28.661.051,80

Lease liabilities 8.718,00 3.543.657,00 19.148,00 14.000.000,00 80.937.500,00 98.509.023,00

Trade and other payables* 16.438.265,11 18.187.960,56 10.029.851,49 - - 44.656.077,16

Total 16.446.983,11 25.175.253,94 13.438.257,41 35.828.157,50 80.937.500,00 171.826.151,96

Page 435 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

35. SUBSEQUENT EVENTS

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

First Investment Period Duration

In accordance with the provisions of article 7.2 and Annex 7.2a of the Concession Agreement between PPA SA

and the Hellenic Republic (the contracting parties), ratified by law 4404/2016, as amended (law 4838/2021), the

identification and quantification of one or more Suspension Events, by the Independent Engineer, during the

execution of the Mandatory Investment projects, results in a corresponding extension of the First Investment

Period. The identification and quantification of the Suspension Events falls under the competence of the

Independent Engineer and is recorded in the Reports that they submit to the contracting parties. In this case,

the Independent Engineer has identified, quantified and recorded in his Reports, to date, Suspension Events of

a total duration of 1177 days. Consequently, the First Investment Period, which was to expire on August 9, 2026,

has been extended by the corresponding period, i.e. by 1177 days, with a new expiration date (as of this day and

subject to any occurrence of new Suspension Events in the future) on October 29, 2029. The above is established

and recorded in the most recent 35

Quarterly Report of the Independent Engineer referenced to the last

quarter of 2025, which has been duly notified by the Independent Engineer to both parties (PPA SA and the

Greek State) on January 28, 2026.

Evolutions in the Middle East

Following the reporting date, and specifically during February 2026 ,an armed conflict broke out in Iran, forming

part of the broader context of geopolitical instability in the Middle East. This development does not constitute

an adjusting event in accordance with IAS 10 “Events after the Reporting Period”, as the relevant conditions did

not exist at the reporting date.

The Company’s Management closely monitors and continuously assesses the impact of the volatile situation in

the Middle East on the macroeconomic and financial environment , such as potential energy instability and

increase in energy costs, inflationary pressures, and severe disruptions in international shipping and global trade,

in order to ensure that all necessary actions and measures are taken to minimize any potential effects on the

Company’s operations.

As part of the Company’s operations, cargo containers are transported either from or to ports in the countries

involved or neighboring regions. These shipments for the 2025 fiscal year were not significant in relation to the

Company’s overall operations.

At the same time, in the context of developments in international shipping and trade flows in the wider region,

certain changes and diversions in routes and cargoes towards to Piraeus have been observed so far. The nature

of these changes is currently assessed as temporary, as the situation is evolving dynamically and is constantly

being reassessed in light of geopolitical developments, both by the Company and by shipping providers.

As of the date of approval of the financial statements, it is not possible to estimate any potential quantitative

impact of this development on the Company’s results and financial position.

Other than the above, there are no other significant events after December 31, 2025, that may have a

material impact on the company's financial position.

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PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

Piraeus, March 31, 2026

CHAIRMAN OF THE BOARD OF

DIRECTORS

CHIEF EXECUTIVE OFFICER

FINANCIAL MANAGER

HAN CHAO

SU XUDONG

SERAFEIM MARMARIDIS

Passport No. PE3327142

Passport No. PE2263059

License No. Ο.Ε.Ε. 0110075

Page 437 από 437

PIRAEUS PORT AUTHORITY S.A

Annual Financial Report for the year ended December 31, 2025

(amounts in Euro unless stated otherwise)

WEBSITE PLACE OF UPLOADING THE FINANCIAL REPORT

The annual financial report of the Company, the independent auditor’s report and the Management Reports

are available to the website www.olp.gr.