While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources

The proposed project is mainly to invest in decarbonization and energy efficiency measures in the Group’s existing cement plants. The upgrades are being developed in accordance with national regulatory requirements and international standards by a Sponsor, a former IFC client, committed to good environmental and social management as described in the PS1 section. This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on the information reviewed by IFC, the proposed investment will have limited adverse E&S impacts that are few, site-specific, largely reversible, and readily addressed.
The main environmental and social risks associated with the proposed project, as detailed in the following sections, involve ensuring the proper implementation of established systems and technologies related to the use of alternative fuels and raw materials; management of workplace and ambient air quality and noise levels; potential land acquisition; and biodiversity considerations for quarry operations. Mitigation measures for compliance with IFC’s PSs are outlined in the Environmental and Social Action Plan (ESAP).

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

PS1-Assessment and Management of Environmental and Social Risks and Impacts

The Group’s operations are subject to the environmental and safety (E&S) laws and regulations of the countries in which it operates (Business Units – BUs). To ensure the systematic and consistent E&S management across all its operations, Titan Group, headquartered in Greece, has established an overarching E&S management system (ESMS) designed to assess, monitor, and report on E&S matters at all its facilities.

Policy
Titan Group’s commitments to managing E&S risks and opportunities are articulated in a comprehensive
E&S Policy that applies to all operations and subsidiaries under its operational control. The Policy emphasizes the Group’s commitment to continuous improvement in E&S performance and envisages ongoing engagement with stakeholders to address environmental and social matters in line with IFC’s PS1.

While BUs within the Group may implement their individual environmental and social policies, adapted to local legislative requirements, these policies must adhere to the Group Policy. All Group’s cement plants in Target Countries have been certified under international management standards (ISO 14001 (Environmental), ISO 45001 (Occupational Health and Safety) and ISO 50001 (Energy Efficiency). The cement plant in N.Macedonia has obtained a “Zero Waste to Landfill” certification. In two BUs (Albania and Kosovo) there is also a management system for Social Accountability in place, certified according to SA 8000 standard

Titan also commits to Sustainability Charter of the Global Cement and Concrete Association (GCCA): https://gccassociation.org, of which Titan is a full member. The alignment with international industry frameworks ensures adherence to good international industry practices (GIIP) and independent third-party verification.

Policy’s requirements are cascaded down to contractors, suppliers, and business partners along the value chain.

Identification of risks and impacts
The risk management approach towards E&S factors is integrated into the broader Enterprise Risk Management (ERM) framework, which will also be implemented for the Project. E&S risks are categorized as either strategic risks (e.g., climate change) or operational risks (e.g., health and safety, environmental compliance). Strategic risks, such as climate change, are addressed through long-term planning, including the decarbonization roadmap and adaptation of the product portfolio. Operational risks, such as health and safety or environmental compliance, are managed as part of day-to-day operations by business unit management, with oversight from the Group ESG Performance Department and Group Health and Safety Department. The Decarbonization and Engineering & Technology Departments oversee actions to meet climate-related targets.

As specified in ESAP#1, every new project developed with proceeds of Bond within the Target Countries will undergo an environmental and social screening against the applicable laws and regulations and the IFC’s Performance Standards. The projects with the potential significant E&S impacts will be the subject for the Environmental and Social impact assessment (ESIA) that is commensurate with the project’s type, scope, and location, in accordance with applicable laws and regulations (e.g. the EU EIA Directive), GIIP (e.g. GCCA ESIA Guidance), and IFC PS1 requirements. For all projects where an ESIA is required, Titan will publish and Non-Technical Summary (NTS) and Stakeholder Engagement Plan (SEP) and disclose them locally.

Considering that Land Acquisition impacts may potentially occur in the future during acquisition of land or land rights for the yet-to-be specified plans, the company will assess impacts in compliance with PS1. As outlined in ESAP#1, in cases involving land acquisition, Titan will consider alternatives to avoid physical resettlement and economic displacement of individuals and businesses. Should any impacts on land users arise during construction or operation, including informal land users, Titan will provide compensation in accordance with national requirements and IFC’s PS5.

Management Programs
Titan Group’s ESMS encompasses a suite of Management Programs designed to address key environmental and social issues. These programs focus on resource efficiency, reduction of air emissions (including fugitive), noise mitigation, waste and wastewater management, quarry rehabilitation and biodiversity protection, and community engagement. These programs are implemented across all operations and are supported by corporate governance structures that ensure oversight and accountability. Environmental and social management plans are tailored at the BUs level to address particular risks and impacts.

Monitoring and Review
Titan Group’s ESMS includes mechanisms for monitoring and reporting on E&S performance, consistent with PS1 requirements. The effectiveness of programs and actions is reviewed and monitored at the top management level, with adjustments made as needed to achieve corporate objectives and environmental targets. The Group’s E&S Policy is supported by Key Performance Indicators (KPIs) that comply with the GCCA Sustainability Charter and are verified through periodic audits by independent third parties.

Additionally, Titan’s Group Compliance Program provides oversight through an integrated framework of activities, mechanisms, and controls designed to ensure timely identification, assessment, and mitigation of compliance risks. This is complemented by oversight from the Group Legal, Internal Audit, Risk, and Compliance departments.

Organizational Capacity and Competency
Titan Group has a robust corporate governance structure for the E&S matters. The Board of Directors defines the Sustainability Strategy, with the Chief Innovation & Sustainability Officer (CSO) as a board member. The Executive Sustainability Committee, chaired by the CSO, oversees the implementation of the Strategy and monitors progress on ESG targets. The Sustainability Working Group coordinates the Group’s sustainability agenda and related decision-making at both Group and regional levels. Its responsibilities include developing proposals for the Group Sustainability Agenda, communicating targets internally across functions and business units, and coordinating Titan’s partnerships with international organizations, networks, and initiatives. The ESG Performance Department manages the implementation of sustainability commitments at the regional level through a network of ESG liaison delegates in each Business Unit (BU). This structure ensures that E&S considerations are incorporated into the Group’s overall strategy and operations, with clearly defined roles and responsibilities at all levels.

All Titan Group operations have their own environmental, health and safety managers whose role is to ensure compliance with Titan Group corporate principles and local legislation. These managers report to the Country and Regional Directors and provide data to the ESG Performance Department. The corporate structure delivers technical and organizational support, as well as training, to BUs to maintain compliance with national and corporate E&S requirements.

Emergency Preparedness and Response
Titan has Emergency Response Plans (ERPs) for all operations, covering natural disasters (e.g., earthquakes, floods, severe weather) and technological incidents (e.g., mining accidents, power outages, fires and explosions). These plans assign clear roles, outline procedures for emergency equipment use and maintenance, public and agency notifications, and staff training. Specific rescue plans exist for locations like cement silos and crushers. ERPs are kept up-to-date as required by local and national laws.

As part of the emergency response planning, the Group has engaged with climate change risk experts to assess the physical risks stemming from climate change, at both Group and country level. With regards to the mitigation of the effects of possible physical impacts on the Group’s assets from extreme natural events caused by climate change, the Company is implementing a set of proactive protective measures for its assets and is developing continuously updated emergency plans.

According to IFC’s review of available information, Titan Group’s overarching ESMS aligns with the requirements of IFC Performance Standard 1. The Group applies a systematic approach to policy development, risk identification, management programs, organizational capacity, monitoring, stakeholder engagement, and continuous improvement. The corporate ESMS is considered adequate for managing environmental and social risks and impacts of IFC’s Project.
Further information is outlined in the subsequent sections.


PS2- Labor and working conditions

As of December 31, 2024, Titan’s Group employs 6,049 individuals, comprising both regular and temporary staff. The majority of the workforce consists of permanent employees (approximately 98.6% of the total workforce).
Contracted employees make up a small portion of the workforce (approximately 1.4% of the total workforce).
Female representation is slightly higher among temporary employees (26.2%) compared to permanent employees (14%).

Human Resources (HR) Policies
Group’s HR policy framework is compliant with national labor laws and international voluntary guidelines, such as the UN Universal Declaration of Human Rights, International Labor Organization’s Conventions on Labor and the UN Global Compact. Principles on human rights, decent work and economic growth, freedom of association, non-discrimination, diversity equity and inclusion, child and forced labor are incorporated in Corporate Social Responsibility Policy (CSR), Human Rights Policy, Respect in the Workplace Policy, Diversity, Equity and Inclusion Policy, Code of Conduct and Code of Conduct for Procurement. BUs’ HR practices are consistent with national labor and employment laws and largely aligned with IFC PS2 requirements. HR procedures cover the right to fair labor remuneration, rest and vacation time, labor safety and health protection, vocational skills training, access to social insurance and welfare, the right to file grievances as well as right to equal opportunity, anti-harassment, anti-discrimination, whistleblowers protection, etc. All BUs have their own HR managers who ensure the application of HR Policies compliant with Titan Group corporate principles and local legislation.

Workers’ Organizations
Titan acknowledges the significance of freedom of association and collective bargaining in corporate Human Rights Policy. Group companies enter into collective bargaining agreements that establish, among other things, the working conditions, salary adjustments and profit-sharing programmes of the Group’s employees. In countries where there are local federations of cement workers such as Bulgaria, the Group also enters into collective bargaining agreements as a member of the respective local cement employer associations. Group (and operations) annually reports the KPIs of percentage of employees covered by collective bargaining agreements.

Non-discrimination and Equal Opportunities
The Group is committed to fostering an inclusive work environment where diversity is promoted, and all individuals have equal growth opportunities. In 2022, the Group introduced the Diversity, Equity, and Inclusion (DEI) policy, translated into all operational languages, to ensure its principles are understood by all employees. The Group established the DEI Council to oversee strategy, initiatives, communication, and progress, reporting to the Board.

The Group makes ongoing to increase female representation in its workforce, leadership roles, and talent pools. While the workforce remains predominantly male (85.5%), the Group is implementing focused measures in promoting gender equality. In 2023, the Group signed the United Nations Women's Empowerment Principles to enhance gender equality and women's empowerment. The Group met its 2025 ESG target of having at least 1/3 women on the Board and is on track to increase women's participation in senior roles, talent pools, and new hires by 20%. Furthermore, female participation in management roles increased by 28% vs. 2020 level.

In 2024 Group adopted a zero tolerance Policy against any form of violence and harassment in the workplace, promoting a culture of respect, dignity, and mental safety for all employees (Respect in the Workplace Group Policy).

Grievance Mechanisms
All BUs have integrated the group’s Whistleblowing Policy into their operations and translated them into local languages in each country. The Policy together with the EthicsPoint platform provides for a uniform, anonymous, and strictly confidential grievance mechanism and channel for reporting labor-related concerns, which is implemented at each BU and is available to both direct and contracted workers. In 2024, a total of 21 complaints or inquiries related to working conditions were recorded. The majority of these cases were inquiries about possible salary increases, while the rest were related to Health and Safety, and People and Workplace Respect. There were 0 confirmed incidents of discrimination, including harassment, within the workforce. The Group ensured that all inquiries were properly addressed and answered. Action plans for remediation were implemented for all substantiated and partially substantiated cases.

Retrenchment
Although the Titan Group does not anticipate any employee retrenchments in future, as agreed in ESAP #2, Titan will develop a Retrenchment Policy at a corporate level that will be applicable to all its operations/business units. The Policy will be aligned with national legislation in each country of operation and IFC PS2 requirements. It will include a description of how to develop a Retrenchment Action Plan aligned with GIIP prior to any potential organizational change that may require staff optimization/retrenchment in future.

Supply Chain
Supply chain is managed based on Group’s and Regional Procurement Codes of Conduct aligned with GCCA Guidance for Sustainable Supply Chain Management. Titan integrates ESG criteria into its supplier qualification process to promote responsible sourcing and sustainability throughout the supply chain. Suppliers are expected to adhere to Titan's ESG standards, which include compliance with laws, respect for human rights, labor rights, health and safety standards, environmental management, anti-corruption policies, and transparency. Titan engages with suppliers through structured workshops and training programs to raise awareness of upcoming EU regulations, ESG practices, and sustainable financing principles. Titan tracks metrics such as the percentage of local spend, supplier ESG compliance, and training hours provided to suppliers. The Group aims to ensure that 70% of its key suppliers meet Titan ESG supplier standards by the end of 2025.

Based on IFC’s review of available information, Titan’s corporate HR principles are consistent with IFC's PS2 requirements.

Occupational Health and Safety
Ensuring health and safety and preventing accidents at work for own personnel, contractors and visitors is a priority for the Group. Occupational Health and Safety (OHS) is managed as a unified system, which promotes and ensures continuous improvement. Titan’s Group overarching OHS Policy’s requirements apply to all Group’s entities and contractors, suppliers, and business partners along the value chain. Where OHS Policy, procedures, and external commitments are more stringent than local laws, Group operates in accordance with corporate standards.

The Group’s Executive Committee oversees the OHS Policy, sets targets and monitors progress.

The Group’s Policy is supported by thematic policies and detailed procedures, the presence of OHS engineers in all production units; identification of hazards in the workplace and implementation of measures to mitigate risks. Particular emphasis is placed on training and raising safety awareness and on the strict application of safety systems and processes.

Exposure of workers to fine particulates is one of the key OHS hazards in cement production and quarry operation. In particular, exposure to the respirable fraction of active (crystalline) silica dust (SiO2). To minimize exposure of its workers to hazardous dust, Titan Group implements across its operations engineering dust control systems, measures workers’ exposure to hazardous dusts, provides personal protective equipment (PPE) to address residual exposure, and provides periodic medical checks. To align with GIIP for the dust and noise exposures reduction, Titan is implementing the GCCA Health Management Handbook Addressing Occupational Exposures in the Cement Industries. Employees can report health and safety concerns through grievance mechanisms like the EthicsPoint platform, ensuring that workplace risks are addressed promptly.

Titan has adopted a corporate Transport Management Policy, which is aligned with GIIP as outlined in the GCCA Road Safety Handbook.

To improve the OHS performance of subcontractors, the Group has developed and implemented Contractor Health and Safety Management Guideline, integrating OHS requirements and criteria in the contractor selection procedure, performance monitoring and evaluation.

All integrated cement plants and occasionally other selected sites are annually audited by Group Health, Safety & Environment. Audits are also conducted by regional or national health and safety authorities and external bodies. Installations, procedures and personnel (own and contractors) are examined and the recommendations, combined with those resulting from the investigation of accidents and selected near misses, are implemented by operations management.

Titan Group’s commitment to OHS is reflected in its performance metrics, particularly the Lost Time Injuries Frequency Rate (LTIFR). In both 2023 and 2024, there were no fatalities. In 2024, the LTIFR for Titan’s employees decreased to 0.33 lost time injuries per million worked hours, a significant achievement that underscores the effectiveness of the Group’s safety initiatives. This result, well below the international benchmark of LTIFR < 1.0, highlights Titan’s continuous efforts to reduce injuries and improve overall safety performance.

In 2024, the LTIFR for contractors was 1.57 lost time injuries per million worked hours, demonstrating progress in extending safety measures to external partners (LTIFR between 1.0 and 5.0 is Industry Average).
In the first half of 2025, the combined LTIFR for employees and contractors improved further to 0.50, positioning Titan among world-class performers. However, this positive trend was overshadowed by a contractor fatality in Greece in July 2025. A thorough investigation is underway to determine the root causes and ensure that all necessary corrective and preventive actions are implemented, reinforcing the Group’s commitment to achieving a zero-harm workplace.

PS3-Resource Efficiency and Pollution Prevention

Greenhouse Gases
Cement production is associated with significant CO2 emissions. Scope 1 emissions—arising from limestone calcination during clinker manufacturing and fuel burning—constitute approximately 80% of Titan's total greenhouse gas (GHG) emissions. As a result, reducing Gross Scope 1 CO2 emissions is a major focus of Titan’s decarbonization and broader business strategies. The selected key performance indicator (KPI) does not include Scope 2 emissions, which represent about 6% of total CO2 emissions; these are managed through green electricity purchases and investments in energy efficiency.

Titan adheres to the GCCA’s Sustainability Guidelines for monitoring and reporting CO2 emissions. In 2024, Scope 1 Gross CO2 emissions (tCO2/year) in the target countries were as follows: Serbia—363,000; North Macedonia—626,000; Bulgaria—407,000; Albania—700,000; and Kosovo—398,000.

The Group’s 2030 decarbonization roadmap includes such measures as (i) reduction of the amount of clinker used in the production of cement; (ii) increasing the thermal substitution rate (TSR) of fossil fuels with alternative fuels; and (iii) process optimization by reducing specific heat consumption.

Reducing the clinker content in the final product (clinker-to-cement ratio) is achieved by partially substituting clinker with materials such as fly ash, a by-product of coal combustion in power plants, slag, pozzolana and limestone. The proceeds from the Bond may be allocated to the construction of new facilities designed to process fly ash from utility industries. These facilities will remove unburned carbon from fly ash, making it suitable for use in cement and concrete production, while the recovered carbon can be reused as fuel.

Another key direction of Titan’s decarbonization programme involves replacing fossil fuels with alternative fuels, including waste materials. The Group uses a variety of alternative fuels, including: dried sewage sludge, refinery sludge, tires, solid recovered fuel (SRF) / refuse-derived fuel (RDF), agricultural waste. These fuels are used to substitute conventional solid fuels in several of the Group’s plants, including Kosjeric cement plant in Serbia and Zlatna Panega plant in Bulgaria. The Group's alternative fuel substitution rate increased to 21.2% in 2024, up from 19.6% in 2023. This represents a significant step in reducing reliance on conventional fossil fuels and advancing the Group's decarbonization roadmap. The Group has adopted corporate Guidelines for the selection, storage, handling and use of alternative fuels and alternative raw materials, which is aligned with the requirements of WBG’s EHS Guidelines for Cement (2022). Among other measures, the procedure includes monitoring and controlling volatile heavy metal content in input materials and waste fuels. Introduction of AF to existing operations constitutes a material change to the process, necessitating an EIA that includes air dispersion modeling. In most cases, no modifications to the existing air emission treatment systems are required, as the current BAT-compliant systems are typically sufficient to manage the additional emissions from AF and ensure compliance with ambient air quality standards. If air dispersion modeling indicates exceedances of ambient air quality limits, compliance can be achieved through adjustments to operational hours or by upgrading air emission treatment systems, including those associated with other sources under the company’s control (to reduce cumulative impact). The Group will continue to make investments in alternative fuel processing facilities and feeding, storage, and combustion infrastructure.

As outlined in the ESAP #1, all new projects financed with proceeds of the Bond in Target Countries will undergo a documented E&S screening against IFC’s requirements. Projects with potential adverse impacts will require an Environmental and Social Impact Assessment (ESIA) proportionate to the project’s type, scope, and location, in alignment with national legislation, Good International Industry Practice (GIIP) and IFC’s PS1. Affected communities will be informed through locally published Non-Technical Summaries (NTS) and Stakeholder Engagement Plans (SEP).

Air emissions
In addition to CO2, monitoring and reporting other types of air emissions are part of the Group’s effort to mitigate its impact on the environment. Aligning with legal and sectoral requirements, the Group monitors and reports dust (PM), NOx, SOx, TOC, HCl, HF and NH3 emissions, mostly through continuous emissions monitoring systems. Minor emissions such as polychlorinated dibenzodioxins (PCDDs) and dibenzofurans (PCDFs), and heavy metals - are spot measured by accredited independent Laboratories.

The Group’s operations in Europe, in particular, are subject to the Industrial Emissions Directive, which mandates compliance with Best Available Technologies (BAT). All 5 target countries, including Kosovo, are subject to IPPC/Industrial Emissions Directive (IED) and must apply BAT. As part of BAT implementation, Titan has changed Electrostatic Precipitators to Bag Filters (to control PM emissions) and introduced a SNCR technology injecting a reducing agent (urea or ammonia) to control NO? at all kilns. Based on IFC’s review of air emissions monitoring data available for the Target Countries, the operations are in material compliance with the guideline values as specified in the WBG’s EHS Guidelines for Cement Production (2022). Any exceedance of daily limits must be reported to the Environmental Agencies and included in the IPPC reports, which are publicly available.

Titan Group has an Action Plan for fugitive dust, including covered conveyors, closed elevators, leak reduction, vacuum cleaning, and enclosed storage with wind barriers. Additional measures involve water spraying, road wetting, regular housekeeping, and paving where possible. BUs systematically monitor dust emissions to protect both neighboring areas and employee health. The Group maintains equipment rigorously and enforces strict transport rules for materials within and outside its plants.

Water consumption
Effective water management is an important aspect of Titan’s environmental performance and sustainability strategy, under the focus area of responsible sourcing. Titan is operating an Integrated Water Management System at all operations to monitor and optimize water consumption and to disclose water data in a consistent way, according to international practices and cement sector guidelines. The Group’s initiatives and investments in relevant facilities and systems over the past two decades have resulted in a substantial improvement in water management. The use of recycled water as a share of overall water consumption increased achieved the 70 per cent target set for 2025.

Wastewater Management
Wastewater is generated during cement manufacturing processes, including cooling systems and equipment cleaning, dust suppression activities and ready-mix concrete production. Stormwater runoff also requires treatment as it collects contaminants as it flows over industrial sites. Process water treatment includes flow and load equalization with pH adjustment; sedimentation for suspended solids reduction using settling basins; and multimedia filtration for reduction in non-settleable suspended solids. Surface runoff treatment includes sedimentation and oil removal. Treated water is recycled and reused within facilities, reducing freshwater consumption and promoting sustainability.

In 2024, all water effluents were reported to be below local regulatory limits, demonstrating the effectiveness of their wastewater management systems

Wastes
The Titan Group has a comprehensive waste management strategy that aligns with its commitment to sustainability and the principles of the circular economy. Most of waste generated during Titan’s operations is non-hazardous waste. (358,820 tonnes vs 447 tonnes of hazardous wastes). Waste stream from cement production involves the kiln dust removed from the bypass flow and the stack. At Titan’s plants that waste stream is recycled in the process. Only 11% of total waste amount was landfilled through authorized contractors who are licensed to handle waste, including landfilling. In 2024, six integrated cement plants achieved Zero Waste to Landfill certification, with five attaining the prestigious Platinum rating.

PS4-Community Health, Safety and Security

Titan Group is committed to safeguarding community health and safety, as outlined in its CSR and Environmental Policies, and aligned with the UN Sustainable Development Goals (SDGs) and Global Compact Principles. The Group recognizes the fundamental right of local communities to a healthy environment.

Community health and safety risks are identified, assessed through E&S risk assessment and mitigated through a comprehensive set of measures defined within management programs.

Ambient Air Quality and Noise
To mitigate air quality impacts, Titan is implementing advanced air emission technologies across its operations, as detailed in the PS3 section. Additionally, as part of environmental permitting procedure and upon any significant process modifications (like introduction of alternative fuel or raw materials), air emission dispersion studies are conducted to ensure that plant operations do not negatively affect ambient air quality in adjacent areas. These studies take into account local atmospheric and geomorphological conditions and are carried out in collaboration with local academic institutions, ensuring a scientifically robust approach tailored to the specific characteristics of each location.

Titan Group follows a program of periodic measurements to monitor noise levels, aiming to minimize disturbance to neighboring communities. Furthermore, the Group has developed action plans that adopt the most appropriate good industry practices like closing openings, noise traps, and insulation.

Environmental Monitoring Programmes are in place to periodically sample groundwater while base line soil measurements have been performed at specific sites, enabling the company to monitor and control potential impacts on the surrounding environment, including heavy metals. These programmes play a critical role in protecting community health and safety by identifying and addressing any adverse effects stemming from plants’ operations.

Road Safety
To minimize risks associated with road safety, Titan has developed and implemented a Traffic Management Policy applicable to all its operations. This policy is designed to reduce the likelihood of road accidents and ensure safe transportation practices for both employees and local communities.

Emergency Preparedness and Response
As already mentioned in PS1, Titan has Emergency Response Plans for all operations. These plans outline procedures for emergency agencies and public notifications.

Security Management
Furthermore, no potential risks to the community have been identified from the implementation of security measures at Titan’s facilities. For security management the Group engages private security contractors, professional and accredited companies, following the Code of Conduct and Code of Conduct for Procurement The company remains committed to maintaining a safe and secure environment for both its operations and the surrounding communities.

For new projects, as agreed under ESAP #1, Environmental and Social Impact Assessments (ESIAs) will be conducted to evaluate potential risks to communities, particularly those associated with the influx of workers during the construction phase. These assessments will help identify and mitigate any adverse impacts, ensuring that community health and safety remain a priority.

PS6-Biodiversity Conservation and Sustainable Management of Living Natural Resources

Titan’s existing cement plants and associated quarries in Albania are located in Illyrican deciduous forests ecoregion of the Mediterranean Forests, Woodlands and Shrubs biome, while the cement plants and quarries in Bulgaria, Kosovo, North Macedonia and Serbia are all in Balkan mixed forests ecoregion of the Temperate Broadleaf and Mixed Forests biome (Resolve, 2017). The cement plants are in converted land, where there is no overlap with Legally Protected or Internationally Recognized Areas, and they have been in operation for some decades. The Zlatna Panega quarry near the cement plant in Bulgaria partially overlaps with Karlukovo Natura 2000 Site, which is a Site of Community Importance (SCI) designated under the Habitats Directive for the complex of stony habitats, different kinds of forests, meadows and steppes, as well as the Iskur River and its tributaries. The Natura 2000 Site was designated in 2007, when the quarry had been in operation for over 40 years.

All of Titan’s existing quarries are in Natural Habitat, including grasslands and oak woodlands, associated with priority biodiversity values including the European Ground Squirrel (IUCN Red List – Endangered), threatened plant species, and threatened and migratory bird species including raptors. IFC PS6 Natural Habitat values will apply to the types of Natural Habitat where the quarries are located in, and all associated priority biodiversity values.

Titan has a corporate biodiversity management strategy for its quarries that is in line with the GCCA Sustainability Guidelines for Quarry Rehabilitation and Biodiversity Management. In “High Biodiversity Value Areas”, which are defined as Legally Protected and Internationally Recognized Areas by the GCCA, a site-level Biodiversity Management Plan (BMP) is developed and implemented together with a Quarry Rehabilitation Plans (QRPs) to mitigate negative impacts and increase positive impacts, so that at least No Net Loss (NNL) impact is achieved. The Group strategy follows the GCCA’s KPI of adopting quarry BMPs at 100% of their sites in high biodiversity value areas, including Zlatna Panega in Bulgaria. Titan’s subsidiaries engage with relevant stakeholders in the implementation of BMPs and additional conservation actions, specifically in areas overlapping with Protected Areas, including the Zlatna Panega quarry.

In line with GIIP and as outlined in ESAP #3, Titan will review and update its overarching ESMS to further strengthen its approach to biodiversity risk and impact identification. This will include the development and implementation of BMPs and QRPs for quarries located in Natural Habitat, with the goal of achieving No Net Loss for associated priority biodiversity values. This applies to quarries in Target Countries where recent or ongoing quarry expansion in Natural Habitat has occurred and such plans are not yet in place. These efforts will be closely aligned with EU and national legislation, GCCA Guidelines and IFC’s PS6 requirements. Titan Bulgaria will continue stakeholder engagement for the implementation of the Zlatna Panega BMP, Quarry Rehabilitation Plan and additional conservation actions, considering any updates that may be required throughout the operations and closure of the Zlatna Panega quarry.

The Group is reporting on its sustainability performance annually to keep stakeholders regularly and comprehensively informed and engaged. Titan Integrated Annual Report is being prepared in accordance with Belgian law, the 2020 Belgian Code on Corporate Governance, the Non-Financial Reporting Directive 2014/95/EU, the European Taxonomy Regulation (EU) 2020/852, the International Financial Reporting Standards and the International Integrated Reporting Council principles for integrated reporting. Other reporting frameworks followed by the Group include the UN Sustainable Development Goals 2030 (UNSDG 2030), the UN Global Compact Communication on Progress Guidelines, the Charter and Guidelines of the Global Cement and Concrete Association (“GCCA”), the Standards of the Sustainability Accounting Standards Board, the CDP questionnaires for climate change and water security, and the Task Force on Climate-Related Financial Disclosures recommendations. The ESG performance overview and statements are independently verified by ERM Certification and Verification Services, in accordance with the Charter and Guidelines of the GCCA.
Titan reports on the E&S issues that are material to their stakeholders and measure their performance against key sustainability performance indicators, according to internationally recognised reporting standards. At the same time, the Group standardises and supports its business units in publishing annual sustainability reports (or integrated reports), increasing transparency and engagement with stakeholders at local level.
Titan has a corporate level Guidance Framework for Community Engagement Plan and has developed community engagement plans that are aligned with material issues for stakeholders and UNSDGs 2030 at 100% of their key operations. Titan is committed to continuous stakeholder engagement, including informing local communities on the ESG matters, assisting in understanding the problems, alternatives and solutions, and obtaining their feedback related to plant operations and expansion.

External Grievance Mechanisms
Grievance mechanisms for communities are an essential component of Titan’s stakeholder engagement and include a variety of channels such as digital platforms, hotlines, and community liaison officers. These mechanisms provide a structured way for stakeholders to raise concerns, offer suggestions, and seek resolution for environmental or social (E&S) issues.
Titan has ongoing focused communication and awareness campaigns to inform the community about the communication channels, availability of the forms, how to use them, and how their concerns will be addressed. Feedback from the community will be documented and used to refine the mechanism and ensure it continues to meet stakeholder needs.
The effectiveness of the grievance mechanism should be monitored regularly, and data on the number and type of grievances received should be considered for inclusion in the Group’s sustainability reporting.

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	Based on the documented E&S screening process against the applicable laws and regulations and the IFC’s Performance Standards, all new projects with the potential to significantly impact the environment and human health, developed with the proceeds of the Bond in IFC’s Target Countries (Albania, Bulgaria, Kosovo, North Macedonia and Serbia) - must undergo an environmental and social impact assessment (ESIA) appropriate to the project's type, scope, and location. The ESIA must be carried out in accordance with applicable laws and regulations (e.g. the EU EIA Directive), GIIP (e.g. GCCA ESIA Guidance), and the requirements of IFC’s PS1. This applies, but is not limited, to greenfield projects involving alternative fuels (AF) or alternative raw materials, as well as major modifications to existing sites. The ESIA process will address all relevant environmental and social risks and impacts of the projects, including those outlined in Performance Standards 2 through 8, and will consider the interests of stakeholders likely to be affected by these risks and impacts. For all projects where an ESIA is required, publish the Non-Technical Summary (NTS) and Stakeholder Engagement Plan (SEP) and disclose them locallyIn cases involving land acquisition, Titan will consider alternatives to avoid physical resettlement and economic displacement of individuals and businesses. Should any impacts on land users arise during construction or operation, including informal land users, Titan will provide compensation in accordance with national requirements and IFC’s PS5.	12/01/2026
2	Titan will develop a Retrenchment Policy at a corporate level that will be applicable to all its operations/business units. The Policy will be aligned with national legislation in each country of operation and IFC PS2 requirements. It will include a description of how to develop a Retrenchment Action Plan aligned with Good International Industry Practice (GIIP) prior to any potential organizational change that may require staff optimization/retrenchment in future. The company will roll out this Policy across its operations including training to HR team, and informing working representatives, when applicable.	07/15/2026
3	Titan will review and update its overarching Environmental and Social Management System (ESMS) to strengthen its approach to biodiversity risk and impact identification. This includes the development and implementation of Biodiversity Management Plans (BMPs) and Quarry Rehabilitation Plans (QRPs) for quarries located in Natural Habitat, ensuring alignment with EU and national legislation, GIIP (GCCA Guidelines) and PS6 requirements. This commitment applies to quarries in Target Countries where recent or ongoing quarry expansion in Natural Habitat has occurred and such plans are not yet in place according to the EU legislation and PS6 requirements.	07/15/2026