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
Environmental and Social Assessment and Management System (ESMS). Enel’s ESMS is substantively aligned with the requirements of IFC PS1. The framework is anchored in Enel Group’s Policy 1288 on Environmental and Social Impact Assessment and Management, which governs the identification, assessment, and management of environmental and social risks and impacts across the Group's global operations. Policy 1288 references IFC Performance Standards as a governing benchmark and is supported by a suite of complementary policies that define the rules of conduct and general working methods that are applicable throughout the Group. Together, these policies provide a framework for managing risks related to labor and working conditions, resource efficiency, community relations, human rights, land acquisition and resettlement, biodiversity protection and conservation, indigenous peoples, and cultural heritage. Group Policies may be deployed at the level of global business line (Generation, Grids, Commercial and Global Services) and/or at Country level. Operative Procedures and Technical Documents provide guidance for the application of the rules and principles established by Group Policies considering the peculiarity of each business line and the applicable country’s context, laws and regulations. Enel operations are certified to ISO 9001, 14001 and 45001 in all countries where it operates, including Argentina, Brazil, Colombia and Chile.
Identification of Risks and Impacts. Policy 1288 applies across all of Enel's global operations and project activities. It establishes a project categorization system consistent with IFC's framework, distinguishing between Category A, B, and C projects based on the significance and scale of potential environmental and social impacts. For Category A and B projects, a complete Environmental and Social Impact Assessment (ESIA) is required. Policy 1288 requires that ESIA findings inform internal decision-making and that findings, agreements, and action plans be publicly disclosed. The policy explicitly references IFC Performance Standards, the WBG Environmental, Health and Safety (EHS) Guidelines, and the Voluntary Principles on Security and Human Rights as governing benchmarks and applies the mitigation hierarchy as the organizing principle for impact management. Human rights due diligence is conducted at Group level and at country level on a three-year assessment cycle, covering freedom of association, forced labor, child labor, non-discrimination, and community rights.
Organizational Capacity and Competency. Enel's ESMS is supported by a three-tier governance structure at the Group, Business Line, and Country levels. At the Group level, a central Health, Safety, Environment and Quality (HSEQ) function defines environmental and health and safety policies, provides Group-wide guidance, and coordinates performance across the organization. Within this function, a dedicated unit provides specialized training for staff on safety, health, and environment matters. At the Business Line level, dedicated HSEQ functions coordinate environmental management, monitor performance, and provide specialist support in line with Group guidelines. At the country level, including Argentina, Brazil, Chile and Colombia, designated managers and contact persons within operating units oversee site-specific environmental and social matters.
The Sustainability function is structured through a multi-level governance model with clear roles across Holding and Country Sustainability Units, ensuring global consistency and local implementation. At Holding level, Sustainability provides strategic oversight, policy definition, and validation, while Countries and ensure implementation, monitoring, and reporting. The organization is supported by the Integrated Sustainability Model (Policy 1351), which embeds E&S management across the value chain and project lifecycle. Overall, the model ensures adequate capacity through defined accountability, technical expertise, integrated processes, and supporting digital tools for monitoring and reporting.
Roles and responsibilities are formally defined in company organizational charts. Board-level oversight and committee structures provide senior accountability for E&S performance.
Emergency Preparedness and Response. Emergency preparedness and response is governed by Policy 1293, which requires site-specific risk assessments, emergency plans covering HSE and security scenarios, including chemical spills, and trained emergency teams with mandatory drills. Policy 1293 also requires coordination with local authorities; coordination with communities is required where emergency scenarios have the potential to affect external stakeholders. Requirements for chemical spill response and environmental remediation requirements are further detailed and cover containment, site characterization, authority notification, and soil and groundwater restoration. Contractor’s emergency system management are reviewed as part of contractor safety assessments.
Monitoring and Review. Enel has established comprehensive environmental and social Key Performance Indicators (KPIs), supported by clear policies and methodological guidelines. KPIs cover greenhouse gas (GHG) emissions, water consumption, waste management, pollutant tracking, workforce training and inclusion, community impacts and supplier performance, all monitored and reported at the Group level. Furthermore, Enel maintains a robust incident classification and reporting system for environmental and safety events, with defined thresholds, communication protocols, root cause investigation requirements, and tracked corrective action plans.
In accordance with ESAP Item 1, Enel will develop and implement selection criteria for eligible expenditures, based on the screening of assets and operations whose equipment and services financed through the transaction will be deployed and implemented, in order to confirm alignment with the eligibility criteria outlined above, under E&S Categorization and Rationale.
PS2: Labor and Working Conditions
As of December 31, 2025, Enel Group employed 61,634 direct employees globally, of which 15.5% in Brazil, 6% in Argentina, 3.5% in Colombia and 3% in Chile. In 2024, contracting and subcontracting companies engaged by the Group employed 131,851 workers globally.
Enel's approach to labor and working conditions is governed by a comprehensive set of group-level policies and organizational procedures applied worldwide. The framework is anchored in the Enel Code of Ethics; the Human Rights Policy; the Enel Group Health and Safety Policy; the Enel Stop Work Policy; and the Diversity, Equity, Inclusion and Belonging Policy. These policies provide comprehensive coverage of topics related to non-discrimination and equal opportunity, sexual harassment, child labor, forced labor, freedom of association and collective bargaining. They also require compliance with applicable laws and collective agreements on maximum working hours, rest periods, and annual paid leave. The principle of fair compensation applies across the Group, with minimum pay required to meet or exceed levels established by collective agreements and applicable legal frameworks, including the requirement for equal pay for work of equal value between male and female workers. All employment engagements must be formalized through a proper employment agreement.
Enel aims to avoid retrenchment wherever possible during business transformation. When workforce adjustments are necessary, the Group prioritizes intra-group mobility as well as training, reskilling, and upskilling programs designed to preserve employability. Transition processes are managed, where possible, in cooperation with trade union organizations, with the aim of minimizing impacts on employees and identifying mutually agreed solutions.
Occupational Health and Safety (OHS). The Group’s corporate Health and Safety Policy is applied across the organization. OHS management systems are implemented and maintained in line with ISO 45001. The Group record and report on OHS KPIs at the corporate level and at the country level, with a Lost Time Injury Frequency Rate (LTIFR) of 0,67 per million hours worked for direct employees and 0,44 for contractor personnel in 2025. When incidents or near-misses occur, root cause analysis is conducted under clear procedures with findings used to define corrective and improvement actions across all business areas and countries. Personal protective equipment (PPE) management is also governed by policies which establish global guidelines for the identification, assignment, use, and maintenance of PPE across the Group. The Stop Work Policy empowers every employee and contractor to immediately halt any work activity that presents an imminent and manifest danger to health, safety, or the environment, without fear of retribution.
Workers Engaged by Third Parties. Contractor and subcontractor management is governed through instruments including HSE verification of subcontracting, safety assessments, contractor exclusion for critical safety situations, and HSE contractual requirements (HSE Terms). Enel's contracts require contractors to cascade the same ethical, labor, environmental, and health and safety standards to their subcontractors and suppliers. Only one level of subcontracting is permitted, and further subcontracting is expressly prohibited without Enel's written approval. Enel reserves the right to conduct audits, field reviews, and interviews with contractor personnel to verify compliance with labor and social security obligations throughout contract execution.
Supply Chain. Enel maintains a comprehensive supply chain management system designed to effectively manage risks associated with both its direct suppliers as well as sub-suppliers in its primary supply chain. Their Sustainability Integrated Model formally integrates sustainability including environmental, social, and ethical standards into every phase of the supply management cycle: supplier qualification, tendering, contract execution, and monitoring. Specific attention is given to child labor, forced labor, or significant safety risks and issues in the supply chain. Furthermore, the Group's due diligence framework is aligned with the UN Guiding Principles on Business and Human Rights.
The Group's Global Procurement Supplier Qualification procedure requires all suppliers to undergo a structured qualification process covering technical, health and safety, human rights, environmental, and reputational criteria prior to engagement. Suppliers are categorized by risk class, with those rated or belonging to a Merchandise group rated at high or medium HSE risk subject to mandatory on-site verification visits. Human rights and labor standards are an explicit component of the Sustainability Requirements assessed at qualification. HSE compliance clauses are included in the standard contract terms as well as prohibitions against child labor and forced labor.
Supplier sustainability requirements are structured into two tiers: mandatory conditions ("Sustainability R") for admission to a tenders, and rewarding criteria ("Sustainability K") that provide additional evaluation points for companies that meet higher standards. This approach encourages continuous improvements across the supply chain that meets or exceeds PS2 supply chain requirements.
Once selected, suppliers are bound by contractual sustainability requirements that must be cascaded to sub-suppliers and monitored throughout the contract period. Monitoring is conducted through a combination of sustainability questionnaires and on-site visits (for high-risk suppliers) resulting in the scoring of suppliers using a Supplier Performance Index (SPI). Where suppliers fail to meet sustainability requirements, Enel applies a gradual corrective framework that may include mandatory training, environmental or social support, the formulation and implementation of a remedial plan, or, in cases of serious or unresolved non-compliance, suspension of qualification or contract termination.
PS3: Resource Efficiency and Pollution Prevention
Enel's approach to resource efficiency and pollution prevention is established through a robust suite of group wide policies that explicitly reference IFC Performance Standards and WBG EHS Guidelines as guiding frameworks. The Enel Group Environmental Policy sets ten strategic goals covering greenhouse gas (GHG) emissions reduction, water and soil preservation, waste management, circular economy, and pollution prevention. The Integrated HSE Policy further commits the Group to the efficient use of energy, water, and raw materials, and to promoting circular economy initiatives.
Resource Efficiency. Enel quantifies its direct and indirect GHG emissions using internationally recognized methodologies and tracks emissions as part of its corporate environmental KPIs. Scope 1 emissions for Argentina, Brazil, Chile and Colombia amount to 57.821,99 tCO2eq, 122.992,21 tCO2eq, 2.903.272,35 tCO2eq, and 366.237,30 tCO2eq, respectively. Scope 2 emissions for Argentina, Brazil, Chile and Colombia amount to 319.675,70 tCO2eq, 199.899,93 tCO2eq, 4.655,21 tCO2eq, and 10.574,23 tCO2eq, respectively.
Enel targets an 80% reduction in Scope 1 generation intensity by 2030, relative to a 2017 baseline, and it has committed to achieving net-zero emissions across Scopes 1, 2, and 3 by 2040. This pathway is supported by the progressive phase-out of thermoelectric and coal-fired capacity, with full elimination target by 2040.
SF6 emissions due to leaks in plants and distribution networks are also monitored and included in GHG accounting and reporting. Energy efficiency measures include the reduction of distribution losses and SF6 management programs aimed at minimizing emissions from equipment, such as SF6-free solutions for distribution network infrastructure components.
All distribution system operators, including those in Argentina, Brazil, Chile and Colombia, hold ISO 50001 energy management certifications. Enel implements an effective control of its processes through the adoption of a certified ISO 50001 Energy Management System, comprising both internal audits and third-party external audits. This system enables the implementation of continuous improvement actions aimed at enhancing energy performance.
The Water Management Policy establishes a mitigation hierarchy for all water-related impacts, requires site-level monitoring, and commits to reducing freshwater withdrawals while prohibiting competition with local communities for access to drinking water. It also establishes requirements for containment measures, hazardous substance phase-out, and emergency stop-work protocols in the event of potential contamination. Enel monitors water consumption as part of its environmental KPIs and applies measures to optimize water use where relevant.
Pollution Prevention. Enel has set voluntary targets to reduce specific emissions of the main pollutants emitted by its thermoelectric generating plants, including sulfur oxides (SO2), nitrogen oxides (NOx), dust and mercury. These targets call for reductions by 2030 of 85% for SO2, 70% for NOx and 60% for dust, compared to a 2017 baseline. In 2025, reported emissions were 0.05 g/kWh for SO2, 0.24 g/kWh for NOx, and 0.004 g/kWh for particulate matter, indicating progress towards the 2030 targets.
Enel has also established waste management guidelines based on the principles of waste hierarchy, polluter pays, life-cycle thinking, and proper segregation, handling, storage, traceability and disposal. The Group is also implementing circular economy initiatives aimed at reducing waste generation and improving resource recovery. Approximately 87% of waste generated across the Group is recovered or recycled. Enel's Environmental Policy further commits to a waste reduction hierarchy and to phasing out substances of very high concern. Environmental remediation and decontamination activities are typically site-specific and triggered by regulatory requirements, legacy conditions, or asset decommissioning processes. Where potential contamination is identified, remediation measures are defined in coordination with the competent authorities. In the context of asset decommissioning and repurposing, the Group applies a structured site closure and rehabilitation process. This includes verification of soil and groundwater quality, implementation of safety or remediation measures that are subject to oversight, documentation and reporting within the ESMS.
PS4: Community Health, Safety and Security
Enel's approach to community health, safety and security is addressed through Enel’s Code of Ethics, Human Rights Policy, and Policy 1288 (Environmental and Social Impact Assessment and Management System), Policy 106 (Classification, Communication, Analysis and Reporting of HSE Events), and Policy 1293 (HSE and Security Emergency Preparedness, Management and Response).
Community Health and Safety. Community health and safety risks are systematically identified and assessed within the framework of project specific Environmental and Social Impact Assessments (ESIAs), addressing potential adverse effects such as workforce and community interactions, exposure to noise, fire hazards, potential leakages, environmental incidents, road accidents, and community exposure to diseases. Based on this risk analysis, proportionate mitigation and management measures are defined as part of each project’s social management framework. In facilities where an ESIA is not required, works are carried out in compliance with applicable local laws, regulations and permitting requirements.
Infrastructure and Equipment Design and Safety, including the management of potential impacts on surrounding communities, is addressed within Enel Group through Policy 1293, which applies to all Enel worksites and explicitly covers safety risks local communities. Policy 106 governs the structured management of HSE events once they occur to ensure timely escalation, root-cause analysis and definition of corrective/improvement actions, and experience sharing across the organization to prevent recurrence and strengthen prevention measures. Through the combined application of these two policies, Enel ensures that worksite safety risks are: systematically assessed and managed; effectively addressed through preparedness and response measures; monitored through a structured incident reporting and analysis process; continuously improved, with due consideration to the protection of workers, third parties, and local communities.
Emergency Preparedness and Response. Enel has corporate procedures for emergency preparedness and response that cover environmental, health, safety, and security risks. These include risk identification, development of site-specific emergency response plans, and coordination with local authorities where required. Incidents and accidents involving Enel personnel, contractors, and third parties are recorded, classified, communicated, analyzed, and used to define corrective and preventive actions. Enel requires its contractors to develop emergency and incident response plans as part of their own management systems. All operations have implemented and installed applicable fire prevention measures and equipment for site-specific risks.
Hazardous Materials Management and Safety. Risks associated with hazardous materials management and leakage risks are addressed through established operational procedures and contractor requirements. Site-specific Emergency Plans must cover scenarios including spills or leaks of hazardous substances with possible interaction with soil, groundwater, or surface water. Trained Emergency Teams are appointed at each site and are responsible for managing such events and activating external emergency services when necessary. Periodic emergency drills are mandatory, with high-risk scenarios simulated at least once every two years. Where an emergency scenario could potentially affect local communities, the policy requires involvement of local organizations in drills. If a contamination incident occurs, Enel or its contractors apply the stop work policy and Enel investigates and remediates the site in coordination with the competent authorities as necessary. Asset operation and maintenance activities are subject to compliance checks and monitoring plans in accordance with ISO 14001-certified environmental management systems (EMS).
Site Security and Security Personnel. Enel’s Policy 1205 (Infrastructure Security) and Policy 1206 (Risk Assessment Methodology for Enel Group’s physical assets security protection) define the approach to security risk assessment for Enel’s physical assets and infrastructure and address site accessibility and other security threats, consistent with ISO 31000:2018. Enel has included references to the Voluntary Principles on Security and Human Rights into its Human Rights Policy and all contractors are required to comply with the latter, the International Labor Organization conventions, and local laws and regulations. However, Enel has not yet formalized specific protocols governing interactions between security personnel and communities fully in line with PS4 requirements.
In accordance with ESAP Item 2, Enel will develop and implement, for the Project, a protocol for the screening, selection and management of direct, if any, and contracted security personnel on site, including rules of engagement and a code of conduct towards workers and affected communities.
