Acciona SA

ACCIONA has had a Sustainability Committee on the Board of Directors since 2009, as the body responsible for leading actions in climate action and sustainability. In 2021, ACCIONA has created an Audit and Sustainability Committee to serve as an instrument and provide support to the Board of Directors in supervising the accounting, financial and non-financial information, best practice in sustainability including climate change matters, the internal and external audit services and risk management. The Committee meets depending on its needs, at least quarterly. [...] The Global Sustainability Department is the corporate area that organises and promotes the initiatives and commitments of the SMP 2020, which are translated into specific objectives for the different business lines. This area reports directly to the Sustainability Committee and the Chief Financial & Sustainability Officer and the Audit and Sustainability Committee. Every business division has appointed individuals responsible for sustainability whose teams drive and monitor their specific initiatives.

Governance that Sustainability Governance respects the environment, serves ACCIONA's Board of Directors formed a Sustainability the common good Committee back in 2009 and was the body in charge of leading sustainability-related actions. [...] In 2021, this Committee merged with the Audit Committee to create the Audit and Sustainability Committee that helps the Board members supervise accounting, financial and non-financial information, the best practices in sustainability, internal and external audit services and risk management. The Committee meets, depending on its needs, at least four times a year. [...] The purpose of SUSTAINABILITY MASTER PLAN 2025 the Sustainability Since 2010, ACCIONA's sustainability strategy has been based on five-year Sustainability Master Plans (SMPs). The actions and targets contained in these plans are promoted, approved and supervised by the Board of Directors' Audit and Sustainability Committee.

The Board of Directors agreed in 2021 to unify the Audit Committee and the Sustainability Committee in a single body, the Audit and Sustainability Committee, owing to the importance of sustainability and its close link to the financial activity and ordinary management of the company. This new body is composed of five members, all of them external, being four of them independent, with knowledge in accounting, audit, internal control, risk management, both financial and non-financial, apart from economic, financial, corporate and ESG knowledge. [...] The Compliance Management and Internal Audit Management supervise the functioning and the effectiveness of the internal procedures, controls and commitments established to ensure that the obligations are fulfilled, whether imposed by law or voluntary, of an ethical, organisational, environmental or social nature, and that any associated risks are prevented, identified and mitigated. The Compliance Department reports to the Audit and Sustainability Committee of the Board of Directors. [...] ACCIONA has adopted and implemented an Organisation and Management Model for Crime Prevention and Anti-Corruption (MPDYA), the characteristics of which are as follows: > It is designed in accordance with the organisational structure of the group, assigning each department with specific risks of a crime being committed and the corresponding monitoring of those risks. > Each risk has been linked to internal controls that to some extent reduce the probability of involving a criminal risk. > It gives these internal controls a number of specific attributes determined, amongst others, by the area or department responsible for performing them and the precise description of the monitoring activity. > In addition, the MPDYA includes the Internal Financial Reporting Control System (ICFR) appropriate for preventing the commission of certain crimes.

###### GOVERNANCE

The Board of Directors is responsible for managing the risks and opportunities related to climate change, which, through the Risk Management System, drives the identification, assessment, treatment, mitigation and control of the relevant risks and opportunities.

[Managing the risks and opportunities related to climate change is a principle of](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
[ACCIONA´s](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf) [Climate Change Policy, aimed at adopting the measures required to](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
guarantee that the company's businesses are adapted to and can provide a response
to the potential effects of climate change.

**BOARD OF DIRECTORS**

**AUDIT AND SUSTAINABILITY COMMITTEE**

**STEERING COMMITTEE**

**GENERAL ECONOMIC-FINANCIAL AND SUSTAINABILITY**
**MANAGEMENT**

[...]

###### Management responsibilities of the risks and opportunities associated with climate change

[The Global Sustainability Management is responsible for preparing ACCIONA's Climate](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
[Change Policy, then is approved and supervised by the Audit and Sustainability](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
Committee.

The policy includes the principle of managing risks and opportunities related to
with climate change, with the aim of adopting the measures required to guarantee
the adaptation of the company's businesses to the potential physical and transitional
changes that may occur.

FLOWCHART FOR THE ESTABLISHMENT OF THE RISK MAP

ACCIONA's Risk Management System is integrated into the company's strategy,
allowing to identify, assess and manage the events with a potential impact on the
Group (including those related to climate change) from a strategic point of view.
With this approach, it guarantees the suitable treatment and control of risks, which
would remain within the tolerance thresholds catalogued as acceptable.

Risk management is a cyclical process that requires regular updating due to changes in
the organisation and its environment. The Climate Change Risk Management process
(including the analysis of risks and opportunities and the internal communication) is
carried out annually and it includes the following processes:

**BOARD OF DIRECTORS**

Submission of
the reports

**STEERING COMMITEE**
Determine the risk tolerability.
Ensure the implementation of treatment
measures with regard to priority risks.

**AUDIT AND SUSTAINABILITY COMMITEE**
Review the Risk Management Systems on a regular basis.
Ensure that risks are identified, managed and communicated.
Identify and guide the policies, rules, commitments, objectives, strategies and best practices.

Presentation of
the Company´s
Risk Map

**GENERAL ECONOMIC-FINANCIAL AND SUSTAINABILITY MANAGEMENT**
Supervise and approve the Climate Change Risks Maps and the Risk Management process.

Internal
communication

**CORPORATE RISK MANAGEMENT UNIT**
Design, define, guide and supervise the implementation of the company´s Risk Management System. Communicate the
results of the Risk Management System to third parties (externally). Communicate the results of the Risk Management
System to the company´s Divisions and Business Units (internally).

**DIVISIONS AND BUSINESS UNITS**
Identify and analyse the risks associated with
climate change. Propose measures to mitigate
and treat the risks identified.

Submission of
the Climate Change
Risk Maps.

**GLOBAL SUSTAINABILITY MANAGEMENTDE SOSTENIBILIDAD**
Consolidate the Risk Maps associated with climate change of each business.
Analyse inconsistencies. Submit the updated Risk Maps to the Corporate Risk Management Unit.
Review the corporate standard regarding climate change risk management when required.

Implementing
measures

###### — The Corporate Risk Management Unit, which is part of the Finance Control
& Tax Directorate and reports directly to the General Economic-Financial
and Sustainability Management (part of ACCIONA's Steering Committee),
is the executive body responsible for centralising the risk management
activities in ACCIONA and for designing, defining, guiding, monitoring,
and communicating the implementation of the Risk Management System,
appointing the team required to achieve this.

###### — The Global Sustainability Management, which is part of the General
Economic-Financial and Sustainability Management, is the executive body
to which the Corporate Risk Management Unit reports, for the identification
and assessment of the risks related to climate change.

###### — The Divisions and Corporate Departments, which fulfil a two-fold role in the
Risk Management System, provide the necessary information to identify and
assess the risks affecting the company and implement measures to address
priority risks, together with the Finance Control & Tax Directorate.

ACCIONA fully shares the objectives of total decarbonisation of the economy through public commitments, policies, specific procedures, public targets, and a model of economic incentives linked to the achievement of GHG emission reductions for directors, managers, technical and support staff. [...] ACCIONA intends to provide aggregated reporting for all of its sustainable financing instruments and any other outstanding sustainable financing. This reporting will be published pre- and post-issuance and the transparency measures will be specified as follows: PRE-ISSUANCE - Definition of KPI(s) and SPT(s) (including calculation methodologies); - Detailed description of the potential variation of the financial and/or structural characteristics of the Sustainability-Linked Finance Instruments (SLFI); - Explanation of the planned back-up mechanisms for the event that the SPTs cannot be calculated or observed, or is unsatisfactory; - Exceptional events (such as significant change in consolidation scope as a result of material M&A activities or drastic changes in regulatory environment or extreme events) that might substantially impact the calculation of the KPI, restatement of the SPT and/or pro-forma adjustments of baselines or KPI scope After one year has elapsed from the issuance of the applicable sustainable financing instruments, ACCIONA will draw up and keep readily available information on the corporate website. POST-ISSUANCE - Up-to-date information on the performance of the selected KPI(s), including baselines; - Any information enabling investors to monitor the level of ambition of the SPTs (e.g., any update in the issuer's sustainability strategy or on the related KPI/ESG governance and, more generally, any information relevant to the analysis of the KPIs and SPTs); - Illustration of the positive sustainability impacts of the performance improvement; - Verification / Assurance report: Reports on verified SPTs will be made publicly available, outlining the performance vs. SPTs and the related impact, and timing of such impact, on the bond's financial and/or structural characteristics; - In the event of non-compliance with the SPTs, in the terms defined in the Framework, information will be reported on the contribution to the UNEP - UN Environment Program (or an similar organization of the UN system) and projects carried out to generate the impact committed by ACCIONA. The Sustainability-Linked Financing Framework and the transparency report will be published on ACCIONA's website and will remain available until the maturity of such sustainable financing instruments, unless replaced by further reports in the event of material changes of allocation. They will also be available in a specific appendix of the Integrated Report focused on accountability for sustainable finance transactions. [...] VERIFICATION (POST-ISSUANCE) One year after issuance or after full allocation, ACCIONA intends to request verification by its external auditor of a management statement on the performance level against each SPT for each KPI. It will also be externally verified each year by an audit firm using accountancy procedures for assurance engagements other than audits or reviews of historical financial information (ISAE 3000). In case of local communities targets related to access, this verification can be performed by certification of non-governmental organizations or local regulators authorities. The report and the assurance/certification statement will be part of ACCIONA's Sustainable Finance Report, available yearly in the corporate website.

ACCIONA's strategy against climate change is supervised and adopted by the Board of Directors through the Audit and Sustainability Committee. This is reviewed in line with the corporate standards on the management system, which prioritises becoming leaders in the transition to low-carbon business models. [...] ACCIONA's climate agenda is embodied in the objectives of the five-year Sustainability Master Plan (SMP), which gathers a series of initiatives and commitments managed by the General Financial and Sustainability Management and reported directly to the Audit and Sustainability Committee.

ACCIONA has had a Sustainability Committee on the Board of Directors since 2009, as the body responsible for leading actions in climate action and sustainability. In 2021, ACCIONA has created an Audit and Sustainability Committee to serve as an instrument and provide support to the Board of Directors in supervising the accounting, financial and non-financial information, best practice in sustainability including climate change matters, the internal and external audit services and risk management. The Committee meets depending on its needs, at least quarterly. [...] The Global Sustainability Department is the corporate area that organises and promotes the initiatives and commitments of the SMP 2020, which are translated into specific objectives for the different business lines. This area reports directly to the Sustainability Committee and the Chief Financial & Sustainability Officer and the Audit and Sustainability Committee. Every business division has appointed individuals responsible for sustainability whose teams drive and monitor their specific initiatives.

ACCIONA's Board of Directors formed a Sustainability Committee back in 2009 and was the body in charge of leading sustainability-related actions.

In 2021, this Committee merged with the Audit Committee to create the Audit and Sustainability Committee that helps the Board members supervise accounting, financial and non-financial information, the best practices in sustainability, internal and external audit services and risk management. The Committee meets, depending on its needs, at least four times a year.

Functions of the Audit and Sustainability Committee in terms of ESG[1]
– Regularly review the effectiveness of the internal control and non-financial risk management systems.
– Supervise and evaluate the preparation process, integrity and market presentation of the mandatory non-financial information, both annual and interim, revising compliance with regulatory requirements, the appropriate delimitation of the consolidation perimeter and the proper application of accounting criteria, as well as raise its reports to the Board of Directors.
– Identify and guide the sustainability policies, rules, commitments, objectives, strategy and best practices. Ensure that Company procedures in environmental and social matters are in line with the strategy and policies set.
– Identify and guide the policies and rules on corporate governance before they are submitted to the Board of Directors. Supervise compliance with the policies and standards and the internal rules of conduct applicable to the company and its group, ensuring at the same time that the corporate culture is in line with its purpose and values.

The main Environment, Social and Governance (ESG) matters discussed at the 2023 meetings were:
– Monitoring progress in AENOR certification in cybersecurity matters and establishment of the Cybersecurity Framework with more than 700 internal controls.
– Revisions of Corporate Policies and approval of the Document Management and Preservation Policy.
– Monitoring sustainability performance, especially in matters related to greenhouse gas emissions and compliance with greenhouse gas reduction targets, and presentation of the new Sustainable Financing Framework.
– On reporting matters: follow-up of the 2023 ESG reporting roadmaps, changes to the DJSI scoring system and key ESG ratings.

The Non-financial Information Statement is checked and put to the vote at the Annual General Meeting (AGM) as required in Spanish Law 11/2018. Shareholders have the opportunity to express their opinion on the initiatives and performance described above. In 2023, the AGM approved the 2022 report with the votes in favour of 99.95 % of the share capital in attendance."
"ACCIONA follows the Corporate Donations and Sponsorship Standard overseen by ACCIONA's Compliance Division. The aim of this standard is to establish an action framework that allows the group to ensure that donations and sponsorship to charity or non-profit organisations are not a front for illegal payments to civil servants or other people, which would be an infringement of the company's Anti-corruption Standards. Any contribution of this type made by ACCIONA should not give rise to any doubt whatsoever as to its appropriateness and, of course, it should not involve the infringement of any applicable law. These rules must be complied with by all the companies and employees of the group, and also by any third parties acting on their behalf. Similarly, ACCIONA makes no donations to any political party or candidate nor any foundation that could be considered as political contributions in the terms established in the Code of Conduct. [...] Within the European Union, ACCIONA has been registered since 2013 in the EU Transparency Register, which records in a transparent manner, the interests organisations pursue, who defends them and budget allocated to those interests.

Since 2009, the Board of Directors at ACCIONA has a Sustainability Committee as the body responsible for leading sustainability-related actions.. [...] The corporate sustainability function has evolved from an ESG (environment, social and governance) reporting approach to one that is geared towards maximising the impact of the company's solutions. [...] Every division has appointed individuals responsible for sustainability whose teams drive and monitor the specific initiatives they each have within the framework of the SMP 2020. Those responsible for business sustainability, together with the Corporate Sustainability Area, form a group of around 100 professionals who meet monthly at the Global Sustainability Leaders Meeting. Corporate strategy is coordinated and the group's most important projects are analysed at these meetings. [...] Functions of the Sustainability Committee[1] › Identify and guide the group's policies, objectives, good practices, and sustainability and corporate social responsibility programmes. › Evaluate, monitor and review the execution plans for the policies formulated by the group's executive. › Periodically review the internal control and management systems and the degree of compliance with these policies. › Draft the annual Sustainability Report, which is submitted to the Board of Directors for approval. › Submit the sustainability and corporate social responsibility programmes, objectives and policies to the Board of Directors along with the corresponding expenditure budgets for the execution of such programmes."
"In accordance with its Code of Conduct, ACCIONA does not make financial contributions for political purposes or to obtain preferential treatment. Nor does the company use sponsorship or donations as a means of achieving this. Within the European Union, ACCIONA has been registered since 2013 in the EU Transparency Register[13], where the interests it pursues, who defends them and the related budget are published in a transparent manner. In 2020, the group's dialogue with the institutions and business associations focused primarily on contributing to public consultation processes and supporting policy development in the following areas: [Actions that apply to the whole group] Basic lines Examples Incentives for non-polluting behaviour - Contribution to the European Commission's public consultation activities on the EU Green deal and other initiatives, supporting public policies and rules focused on promoting rapid ecological transition. - Participating and contributing ideas for the debate on the elaboration process of the Climate Change and Energy Transition Act and implementation rules. - Support for measures to implement the national integrated energy and climate plan. - Proposals to improve taxation to implement the polluter pays' principle. To develop these policies, ACCIONA participates in sectorial associations at regional and national levels (e.g. AEE, APPA and UNEF), and also at European (WindEurope and CLG Europe) and international levels (GWEC). The company is an active participant and holds positions of responsibility in their governing bodies."
"415-1 Political contributions 82-83 [...] Exponential Leadership GRI 103-2 GRI 102-16 GRI 102-17 GRI 205-2 [...] Measures adopted to prevent corruption and bribery [...] Measures for the prevention of money laundering [...] Contributions to foundations and non-profit organisations [...] Exponential Leadership and GRI content index [...] GRI 103-2 GRI 102-16 GRI 102-17 GRI 205-2 [...] Information about the company [...] Integrate to transform, Energy Business and Infrastructure Businesses [...] Relations with key members of local communities and ways of dialogue with them [...] Inclusion of social, gender equality and environmental issues in the procurement policy [...] Consideration of social and environmental responsibility in relations with suppliers and subcontractors [...] Supervision systems and audits and their result [...] Partnership and sponsorship actions Integrate to transform GRI 103-2 GRI 201-1 [...] Exponential Leadership GRI 103-2 90-98 [...] Exponential Leadership GRI 102-9 GRI 308-1 [...] Exponential Leadership GRI 102-9 GRI 308-2 [...] 90-98 [...] 95-96 [...] Measures to promote consumer health and safety [...] Complaint procedures, complaints received and complaint resolution [...] Exponential Leadership GRI 103-2 72-73 [...] Exponential Leadership GRI 103-2 GRI 418-1 [...] 71-72 [...] Tax information [...] Profits earned country-by-country Exponential Leadership GRI 201-1 [...] Corporate income tax paid Exponential Leadership GRI 207-4 [...] Public grants received Exponential Leadership GRI 201-4 [...]

The Social Safeguards System (SCISS) integrates within the company the culture of risk assessment and management of compliance with international human rights regulations and principles. The system is based on the internal control models developed by COSO (Committee of Sponsoring Organizations of the Treadway Commission). During the first half of 2023, the internal monitoring procedure of the SCISS was completed. The results of this monitoring have been reported to the Audit and Sustainability Committee of the Board of Directors through the Corporate Internal Audit Department. The Corporate Sustainability Department is in the process of updating the risk assessment and control activities according to the results of the monitoring process.

ACCIONA's strategy against climate change is supervised and adopted by the Board of Directors through the Audit and Sustainability Committee. This is reviewed in line with the corporate standards on the management system, which prioritises becoming leaders in the transition to low-carbon business models. [...] ACCIONA's climate agenda is embodied in the objectives of the five-year Sustainability Master Plan (SMP), which gathers a series of initiatives and commitments managed by the General Financial and Sustainability Management and reported directly to the Audit and Sustainability Committee."
"ACCIONA keeps a transparent and constant relationship with public administrations in all the countries where it operates. The company considers public participation in the process of adopting any regulatory initiative to be important in order to ensure that the interests of everyone who will be affected by the measures to be adopted are seen to be duly weighed and reflected. ACCIONA encourages constant dialogue with regulatory authorities, getting involved in each case and always cooperating with them. As a result, the company is actively involved in the development of public policies that affect the areas and sectors it operates in, contributing to lawmakers its experience in the private sector. Some of the practices aimed at raising awareness are the analysis, studies and dissemination of the results, as well as the participation in putting forward proposals and giving feedback or reasons during the public information stages in the different procedures aimed to set the regulatory framework for each sector. The company's position is always consistent with its commitment to protect and respect the environment, support renewable energies and sustainability in the use of resources. Furthermore, it encourages participation in forums, associations and different groups, providing knowledge, ideas, initiatives and experiences acquired for many years, aiming to drive public policies towards a sustainable development and growth, in the social as well as the economic and environmental aspects. In accordance with its Code of Conduct, ACCIONA does not make financial contributions for political purposes or to obtain preferential treatment. Nor does the company use sponsorship or donations for those purposes.

ACCIONA Energía's climate change strategy is approved and supervised by the Board of Directors through the Audit and Sustainability Committee. The review reflects ACCIONA Energy's overriding priority to remain at the forefront of the transition to low-carbon business models. ACCIONA Energía's climate agenda is embodied in the objectives established in the five-year Sustainability Master Plan (SMP), which includes a series of initiatives and commitments that are managed by the Economic-Financial and Sustainability Department, and which are reported directly to the Audit and Sustainability Committee.

###### GOVERNANCE

The Board of Directors is responsible for managing the risks and opportunities related to climate change, which, through the Risk Management System, drives the identification, assessment, treatment, mitigation and control of the relevant risks and opportunities.

[Managing the risks and opportunities related to climate change is a principle of](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
[ACCIONA´s](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf) [Climate Change Policy, aimed at adopting the measures required to](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
guarantee that the company's businesses are adapted to and can provide a response
to the potential effects of climate change.

**BOARD OF DIRECTORS**

**AUDIT AND SUSTAINABILITY COMMITTEE**

**STEERING COMMITTEE**

**GENERAL ECONOMIC-FINANCIAL AND SUSTAINABILITY**
**MANAGEMENT**

[...]

###### Management responsibilities of the risks and opportunities associated with climate change

[The Global Sustainability Management is responsible for preparing ACCIONA's Climate](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
[Change Policy, then is approved and supervised by the Audit and Sustainability](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
Committee.

The policy includes the principle of managing risks and opportunities related to
with climate change, with the aim of adopting the measures required to guarantee
the adaptation of the company's businesses to the potential physical and transitional
changes that may occur.

FLOWCHART FOR THE ESTABLISHMENT OF THE RISK MAP

ACCIONA's Risk Management System is integrated into the company's strategy,
allowing to identify, assess and manage the events with a potential impact on the
Group (including those related to climate change) from a strategic point of view.
With this approach, it guarantees the suitable treatment and control of risks, which
would remain within the tolerance thresholds catalogued as acceptable.

Risk management is a cyclical process that requires regular updating due to changes in
the organisation and its environment. The Climate Change Risk Management process
(including the analysis of risks and opportunities and the internal communication) is
carried out annually and it includes the following processes:

**BOARD OF DIRECTORS**

Submission of
the reports

**STEERING COMMITEE**
Determine the risk tolerability.
Ensure the implementation of treatment
measures with regard to priority risks.

**AUDIT AND SUSTAINABILITY COMMITEE**
Review the Risk Management Systems on a regular basis.
Ensure that risks are identified, managed and communicated.
Identify and guide the policies, rules, commitments, objectives, strategies and best practices.

Presentation of
the Company´s
Risk Map

**GENERAL ECONOMIC-FINANCIAL AND SUSTAINABILITY MANAGEMENT**
Supervise and approve the Climate Change Risks Maps and the Risk Management process.

Internal
communication

**CORPORATE RISK MANAGEMENT UNIT**
Design, define, guide and supervise the implementation of the company´s Risk Management System. Communicate the
results of the Risk Management System to third parties (externally). Communicate the results of the Risk Management
System to the company´s Divisions and Business Units (internally).

**DIVISIONS AND BUSINESS UNITS**
Identify and analyse the risks associated with
climate change. Propose measures to mitigate
and treat the risks identified.

Submission of
the Climate Change
Risk Maps.

**GLOBAL SUSTAINABILITY MANAGEMENTDE SOSTENIBILIDAD**
Consolidate the Risk Maps associated with climate change of each business.
Analyse inconsistencies. Submit the updated Risk Maps to the Corporate Risk Management Unit.
Review the corporate standard regarding climate change risk management when required.

Implementing
measures

###### — The Corporate Risk Management Unit, which is part of the Finance Control
& Tax Directorate and reports directly to the General Economic-Financial
and Sustainability Management (part of ACCIONA's Steering Committee),
is the executive body responsible for centralising the risk management
activities in ACCIONA and for designing, defining, guiding, monitoring,
and communicating the implementation of the Risk Management System,
appointing the team required to achieve this.

###### — The Global Sustainability Management, which is part of the General
Economic-Financial and Sustainability Management, is the executive body
to which the Corporate Risk Management Unit reports, for the identification
and assessment of the risks related to climate change.

###### — The Divisions and Corporate Departments, which fulfil a two-fold role in the
Risk Management System, provide the necessary information to identify and
assess the risks affecting the company and implement measures to address
priority risks, together with the Finance Control & Tax Directorate.

In terms of climate change governance, the body responsible is the Board of Directors' Audit and Sustainability Committee, which has performed the following functions, amongst others: identify and guide the group's climate change policies, objectives, best practices and programmes; evaluate, monitor and review the plans for implementing these strategies drawn up by group executives; periodically review internal control and management systems and the degree of compliance with these strategies and report to the Board of Directors on climate change policies, objectives and programmes, and the corresponding budgets for their performance. [...] ACCIONA's Climate Change Policy, which has been approved by the Board of Directors, is reviewed in accordance with the corporate management system standards and one of its priorities is to lead the transition towards low-carbon business models. This climate agenda is embodied in the objectives of the Sustainability Master Plan (SMP), whose initiatives and commitments are managed by the Finance and Sustainability General Management, directly reporting to the Audit and Sustainability Committee.

ACCIONA applies a set of minimum ESG requirements (Policy Book approved by the Board of Directors Audit & Sustainability Committee), applicable EU and national environmental and social regulations to all its activities, including those financed with the proceeds from green financing instruments. All projects that are financed and/or refinanced with proceeds from green financing instruments are selected by the ACCIONA's Sustainable Finance Committee. The Committee evaluates and supervises quarterly the alignment of all projects with the eligibility criteria and the environmental objectives included in the EU Taxonomy.

###### GOVERNANCE

The Board of Directors is responsible for managing the risks and opportunities related to climate change, which, through the Risk Management System, drives the identification, assessment, treatment, mitigation and control of the relevant risks and opportunities.

[Managing the risks and opportunities related to climate change is a principle of](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
[ACCIONA´s](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf) [Climate Change Policy, aimed at adopting the measures required to](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
guarantee that the company's businesses are adapted to and can provide a response
to the potential effects of climate change.

**BOARD OF DIRECTORS**

**AUDIT AND SUSTAINABILITY COMMITTEE**

**STEERING COMMITTEE**

**GENERAL ECONOMIC-FINANCIAL AND SUSTAINABILITY**
**MANAGEMENT**

[...]

###### Management responsibilities of the risks and opportunities associated with climate change

[The Global Sustainability Management is responsible for preparing ACCIONA's Climate](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
[Change Policy, then is approved and supervised by the Audit and Sustainability](https://mediacdn.acciona.com/media/5h0ddpd1/climate-change-policy-2018.pdf)
Committee.

The policy includes the principle of managing risks and opportunities related to
with climate change, with the aim of adopting the measures required to guarantee
the adaptation of the company's businesses to the potential physical and transitional
changes that may occur.

FLOWCHART FOR THE ESTABLISHMENT OF THE RISK MAP

ACCIONA's Risk Management System is integrated into the company's strategy,
allowing to identify, assess and manage the events with a potential impact on the
Group (including those related to climate change) from a strategic point of view.
With this approach, it guarantees the suitable treatment and control of risks, which
would remain within the tolerance thresholds catalogued as acceptable.

Risk management is a cyclical process that requires regular updating due to changes in
the organisation and its environment. The Climate Change Risk Management process
(including the analysis of risks and opportunities and the internal communication) is
carried out annually and it includes the following processes:

**BOARD OF DIRECTORS**

Submission of
the reports

**STEERING COMMITEE**
Determine the risk tolerability.
Ensure the implementation of treatment
measures with regard to priority risks.

**AUDIT AND SUSTAINABILITY COMMITEE**
Review the Risk Management Systems on a regular basis.
Ensure that risks are identified, managed and communicated.
Identify and guide the policies, rules, commitments, objectives, strategies and best practices.

Presentation of
the Company´s
Risk Map

**GENERAL ECONOMIC-FINANCIAL AND SUSTAINABILITY MANAGEMENT**
Supervise and approve the Climate Change Risks Maps and the Risk Management process.

Internal
communication

**CORPORATE RISK MANAGEMENT UNIT**
Design, define, guide and supervise the implementation of the company´s Risk Management System. Communicate the
results of the Risk Management System to third parties (externally). Communicate the results of the Risk Management
System to the company´s Divisions and Business Units (internally).

**DIVISIONS AND BUSINESS UNITS**
Identify and analyse the risks associated with
climate change. Propose measures to mitigate
and treat the risks identified.

Submission of
the Climate Change
Risk Maps.

**GLOBAL SUSTAINABILITY MANAGEMENTDE SOSTENIBILIDAD**
Consolidate the Risk Maps associated with climate change of each business.
Analyse inconsistencies. Submit the updated Risk Maps to the Corporate Risk Management Unit.
Review the corporate standard regarding climate change risk management when required.

Implementing
measures

###### — The Corporate Risk Management Unit, which is part of the Finance Control
& Tax Directorate and reports directly to the General Economic-Financial
and Sustainability Management (part of ACCIONA's Steering Committee),
is the executive body responsible for centralising the risk management
activities in ACCIONA and for designing, defining, guiding, monitoring,
and communicating the implementation of the Risk Management System,
appointing the team required to achieve this.

###### — The Global Sustainability Management, which is part of the General
Economic-Financial and Sustainability Management, is the executive body
to which the Corporate Risk Management Unit reports, for the identification
and assessment of the risks related to climate change.

###### — The Divisions and Corporate Departments, which fulfil a two-fold role in the
Risk Management System, provide the necessary information to identify and
assess the risks affecting the company and implement measures to address
priority risks, together with the Finance Control & Tax Directorate.

During the first half of 2024, the internal monitoring procedure of the SCISS was completed. The results of this monitoring have been reported to the Audit and Sustainability Committee of the Board of Directors through the Corporate Internal Audit Department.

In terms of climate change governance, the body responsible is the Board of Directors' Audit and Sustainability Committee, which has performed the following functions, amongst others: identify and guide the group's climate change policies, objectives, best practices and programmes; evaluate, monitor and review the plans for implementing these strategies drawn up by group executives; periodically review internal control and management systems and the degree of compliance with these strategies and report to the Board of Directors on climate change policies, objectives and programmes, and the corresponding budgets for their performance. [...] ACCIONA's Climate Change Policy, which has been approved by the Board of Directors, is reviewed in accordance with the corporate management system standards and one of its priorities is to lead the transition towards low-carbon business models. This climate agenda is embodied in the objectives of the Sustainability Master Plan (SMP), whose initiatives and commitments are managed by the Finance and Sustainability General Management, directly reporting to the Audit and Sustainability Committee.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes