ESG Policy

Altano Energy (“Altano”) is a diversified renewables platform with the strategy to build a large-scale portfolio of renewable energy assets in Southern Europe.

Altano builds and operates renewable energy assets within solar, wind, hydropower, and storage technologies (battery energy storage systems (“BESS”) and pumped storage). In combination, the assets contribute to the transitioning of society to renewable energy, increasing the share of renewables in the energy mix, reducing greenhouse gas (“GHG”) emissions and achieving a carbon neutral economy by 2050 to limit global warming.

Altano emphasises the importance of respect for human rights, equal opportunities, and environmental sustainability.

Altano adheres to laws and regulations that apply where we perform our activities. In addition, we align our activities with established and recognised international guidelines and recommendations, in particular:

• OECD Guidelines for Multinational Enterprises
• UN Guiding Principles on Business and Human Rights
• International Bill of Human Rights
• The eight fundamental conventions identified in the ILO Declaration

This ESG Policy outlines Altano’s procedures for how to adhere to these international standards.

The ESG Policy applies to the investment process of Altano and is implemented in assets where Altano holds majority ownership. In minority ownership situations, Altano is guided by this ESG Policy, but could potentially be limited in implementing requirements in the assets.

To ensure adherence to the ESG Policy and all associated policies (such as the Code of Ethics and Principles of Actions, Health, Safety and Environmental Policy, and Anti-Corruption Policy) which all guide Altano employees in responsible business conduct, Altano ensures appropriate training is completed for all employees.

HOW TO REPORT A CONCERN

Altano encourages internal and external stakeholders to report any breaches of the ESG Policy through the established Whistleblower Channel, details of which are described in the Code of Ethics and Principles of Actions.

Altano will not tolerate any retaliation against anyone who, in good faith, communicates facts or situations that could be interpreted as breaches or violations of the ESG Policy.

ENVIRONMENTAL PROTECTION

Altano is committed to the preservation of the environment, respecting the applicable legislation and adopting procedures to reduce the environmental impact of our assets. The environmental impacts of our assets differ across solar, wind, hydropower, and storage technologies. Therefore, Altano identifies material environmental risks related to each asset and mitigates these material risks, where relevant.

Altano will ensure the responsible use of natural resources and the prevention or reduction of negative environmental impacts such as GHG emissions, energy efficiency, hazardous waste, waste management, water use, and pollution.

What we do to ensure environmental protection:

• We implement our Health, Safety and Environmental Policy in all assets.
• We set clear environmental expectations and requirements to suppliers and contractors (EPCs, O&Ms) through our Supplier Code of Conduct.
• We ensure that all assets monitor and report on environmental incidents and accidents.
• It is our ambition to align majority owned assets with the Do No Significant Harm criteria included in the EU Taxonomy. These criteria aim to protect the environment on specific material environmental risks within solar, wind, hydropower, and storage technologies projects.

Altano acknowledges that ecological issues, such as the migration of fish or change in river and water characteristics, are particularly relevant to hydropower assets. We manage this through a half yearly environmental monitoring carried out by an external expert focused, amongst others, in water quality, reservoirs level variations, waste management.

HEALTH AND SAFETY

Altano prioritises the well-being of employees, suppliers, and contractors during the entire lifecycle of our assets.

As an employer we provide a healthy and safe work environment to every employee. Our ambition is to have zero accidents at our workplaces and in our assets.

What we do to ensure health and safety:

• Our Health, Safety and Environmental Policy applies to all Altano employees and all Altano assets.
• We set clear health and safety expectations and requirements to suppliers and contractors (EPCs, O&Ms) through our Supplier Code of Conduct.
• We ensure that all assets monitor and report on health and safety incidents and accidents.
• We ensure that employees, suppliers and contractors have the necessary competence and qualifications to perform their tasks safely.

Thermal runaway is a specific risk in BESS projects. To mitigate adverse impacts from this type of risk, we develop and communicate site-specific emergency response plans to enforce fire protection systems and to address accidents, incidents, and potential natural disasters. The emergency response plans include fire safety drills and evacuation procedures.

Altano supports the protection of human rights and labour standards as defined in the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, and the eight fundamental conventions identified in the ILO Declaration. We will not knowingly engage, directly or indirectly, in any activity which harms the human rights or labour standards of others. We will take appropriate and reasonable steps to avoid violations and take remedial action on any identified human rights issues which Altano is directly linked to.

We strive to create a safe and respectful workplace, free from discrimination or harassment due to gender, race, ethnic, national or social origin, age, religion, political or sexual orientation, physical or mental disability, or other characteristics. We are committed to protect the right to equal treatment and opportunities.

What we do to ensure human rights and labour standards:

• Altano has adopted a Human Rights Policy that expands on our policies and commitments to protecting human rights and labour standards.
• Our suppliers and contractors play a key role in our efforts to live up to these principles. Therefore, we set clear expectations and requirements to suppliers and contractors (EPCs, O&Ms) through our Supplier Code of Conduct.
• We evaluate human rights and labour standards as part of the ESG due diligence, as relevant, and manage these through monitoring, reporting, and engagement with our employees and suppliers.
• At least annually, we conduct a human rights assessment of our activities based on the assets and geographies in which we and our suppliers operate.
• The human rights assessment is presented to, and evaluated by, Altano’s top management. The Board of Directors is responsible for the monitoring, updating and control of the Human Rights Policy, which shall be reviewed at least annually.

For onshore wind and solar projects, Altano engages actively with the local communities to ensure that the project contributes to the local communities and develops the community and advantages the people.

Altano recognises that the global photovoltaic supply chain is complex and entails potential risks, especially in relation to human rights. Consequently, Altano monitors and manages risks arising from the sola

SOUND MANAGEMENT STRUCTURES

Altano’s Code of Ethics and Principles of Action serves as guidance for our policies and outlines the key rules, expectations and values that govern our behaviour. The principles are based on sound business practice, responsibility and common sense and are intended to encourage a high degree of personal and professional integrity internally in Altano and in the management of our assets. Additionally, our employees, including executive management, are guided by our internal policies and procedures as described in Altano’s Anti-Corruption Policy, Communication Policy with Public Authorities, Human Resources Manual, Procurement Procedure and Criminal Risk Prevention Policy.

EMPLOYEE RELATIONS

Altano’s approach to respect labour standards and ensure constructive employee relations across workplaces are described in the ‘Human rights and labour standards’ and ‘Health and Safety’ sections of this ESG Policy. Additionally, this is supported by our Code of Ethics and Principles of Action and Human Resources Manual.

REMUNERATION

Our remuneration of staff considers the risk profiles, values and long-term interest of Altano. Our approach to compensation arrangements does not in any way hinder the implementation of the ESG principles and commitments as set forth in this ESG Policy.

TAXATION

Altano complies with both the letter and the spirit of the tax laws and regulations of the countries in which we operate. We treat tax governance and tax compliance as important elements of our oversight and risk management structures (refer to ‘Actions implemented to integrate good governance in governance procedures’).

ANTI-CORRUPTION

Altano rejects all types of corruption. We comply with the laws and regulations in force and base our actions on the highest ethical and responsible standards. Altano staff are guided by our Anti-Corruption Policy, which is aligned with international standards. Corruption prevention measures are part of the Prevention Model which is described in our Criminal Risk Prevention Policy.

FAIR COMPETITION

Altano competes fairly and supports free and fair competition. We will comply with all applicable antitrust laws in the jurisdictions in which we operate. We treat fair competition as an important element of our oversight and risk management structures.

What we do to ensure governance principles:

• Altano staff receive training in relevant policies and procedures.
• The governance principles are integrated in our risk management structures and are addressed at least annually at Board of Directors meetings.
• Internal controls are maintained and updated based on the conclusions of findings in the risk management structures.
• Altano’s Board of Directors has adopted a tax and fair competition management strategy to identify and assess tax and fair competition risks, and implement appropriate risk mitigation measures, and monitor and review tax and fair competition risks at least annually.
• Altano requests all business partners, including suppliers and contractors, as a requisite to entering into business, to acknowledge and accept the principles stated in this ESG Policy and as set forth in its Supplier Code of Conduct.

PRE-INVESTMENT

Altano only considers investments in renewable energy assets that supports the transition to a low-carbon economy and that are eligible within the EU Taxonomy for sustainable activities. In the initial ESG screening phase an analysis is conducted to assess if the potential investment appears to be eligible with the EU Taxonomy’s criteria.

If the initial deal memo is approved by the senior management of Altano, a thorough ESG due diligence process is conducted to identify actual and potential adverse impacts and sustainability risks or opportunities. Adverse impacts and sustainability risks are assessed and recommendations for risk mitigation are developed. The ESG due diligence also assesses how the potential investment is aligned with the EU Taxonomy’s criteria. The outcomes of the ESG due diligence are integrated into the final investment presentation. The primary purpose of the ESG due diligence is to identify and recommend the mitigation of specific ESG risks for each investment opportunity.

During ESG due diligence, third party advisers are engaged to produce expert reports to assist the investment decision. Such advisers typically have expertise on such matters as financial, legal, technical, health, safety and environmental. The advisers are selected for their knowledge of the relevant asset type and location, thereby enabling them to effectively identify risks and provide qualitative and quantitative analysis that is included in the final investment committee presentation and incorporated into the valuation. For example, a technical report may contain information regarding the environmental authorisation terms required for the project, and/or an assessment of the project according to the Equator Principles. A legal due diligence report may contain information on environmental and social litigation, such as contractor health and safety disputes.

NEGOTIATION AND CLOSING

If a material ESG risk is detected in the due diligence phase, the relevant mitigating actions are developed and described, and Altano will integrate, as appropriate, these mitigating actions in the negotiation process. For example, it may be appropriate for Altano to incorporate seller indemnities regarding potential environmental or social-related damages into the share purchase agreement, that have been identified through the ESG due diligence process.

Altano often pursues co-development agreements with developer partners, as opposed to buying projects outright. In this situation, Altano takes a proactive approach to governance, typically aiming to secure majority board positions of the co-development special purpose vehicles and introducing board reserved matters that are triggered by project milestones, such as environmental approval.

ASSET MANAGEMENT AND MONITORING

Altano has deep in-house asset management capabilities, including active energy management and technical management. The operations and maintenance of the hydro assets is handled by Altano employees, whilst the construction, operations and maintenance for solar, wind and storage assets are outsourced to third parties. Altano ensures that suppliers, such as operations and maintenance contractors, are directed to comply with the Supplier Code of Conduct. With this approach, Altano conducts active oversights of such third parties and ensures that our suppliers are operating with good governance, rigorous health, safety and environmental standards and following high ethical standards of behaviour.

During asset management, we ensure that the actions described throughout this ESG Policy are implemented to ensure compliance with our principles and commitments. This includes monitoring of human rights breaches or violations in our operations, identifying material ESG risks as part of our risk management framework, and reporting and monitoring of environmental and health and safety incidents.

For wind and solar projects, compliance with health, safety and environmental requirements is included in the contract with the O&Ms. Requirements on compliance with applicable laws are extended to the sub-contractors.

The Board of Directors of Altano is responsible for oversight of the adherence to the commitments set forth in this ESG Policy. The adoption of this ESG Policy is the responsibility of the Board of Directors.

The executive management of Altano is responsible for its implementation and for monitoring the procedures as set forth in this ESG Policy.

It is the responsibility of the Altano staff to implement the principles, commitments and procedures as set forth in the ESG Policy by the mandate of the executive management in everyday actions.

This ESG Policy has been approved by Altano Energy’s Managing Directors on 19th of January of 2024 and ratified by the Board of Directors on 21st of February of 2024.