ACS Actividades de Construccion y Servicios SA

The overall responsibility for the climate change strategy in the Group rests with the ACS Board of Directors, which approves and monitors policy development to minimize the impact in this area, which each of the companies of the ACS Group will prepare and develop according to their type of activity and geographical area, but always following the basic principles defined in the Group's Environmental Policy. Without prejudice to the responsibility of the Board of Directors, the Audit Committee ensures compliance with the transparency obligations of the Company, and in particular ensures that the information contained in the Non Financial Information Statement (NFIS) and in the Annual Corporate Governance Report is sufficient for the market and investors to understand the scope and importance of the corresponding facts and risks with regard to nonfinancial information. These obligations include the ongoing review of the implementation and development of the Group's Environmental Policy, through action plans, procedures and improvement programs implemented by the Environment Department of each of the Group's divisions, with particular regard to issues related to climate change. [...] For the supervision of this risk control system within the ACS Group, it is the Audit Committee that, among other functions, provides support to the Board of Directors in relation to the general monitoring of compliance with the established procedures and effective general supervision of compliance with the established risk levels for each business activity. Also within its function is the review, monitoring and evaluation of the Company's Corporate Social Responsibility Policy and its practices, being therefore responsible for the ongoing review of the implementation and development of the Group's Environmental Policy, through action plans, procedures and improvement programs implemented by the Environment Department of each of the Group's divisions, with particular regard to issues related to climate change.

The Board of Directors of the ACS Group, as the highest governance body, is responsible for overseeing the overall climate change strategy. Through its functions, it approves the development of the policies required to meet the climate challenges of the business, leaving the Group companies responsible for developing their own management mechanisms depending on the type of activity and geographic area. [...] In addition, the ACS Group's Audit Committee is responsible for monitoring aspects related to climate change, as it has been given the function of supervising internal regulations, which includes the Sustainability Policy and the Environmental Policy, as well as managing financial and non-financial risks. The Committee's responsibilities include the ongoing review of the implementation and development of the Group's Environmental Policy, of the action plans, procedures and improvement programmes implemented by the Environmental Department of each one of the Group's divisions, with a special focus on climate change issues [...] Likewise, to ensure adequate control, supervision and monitoring of these aspects, the risks associated with them were integrated into the Group's risk management system in 2020. The main risks associated with this material issue that forms part of the group's risk management system are:  Climate change and energy efficiency. [...] The ACS Board of Directors has overall responsibility for the climate change strategy through the Audit Committee, which is responsible for monitoring the ACS Group's sustainability policy.  The company is working to establish objectives related to the variable remuneration of the Senior Management in regard to climate change performance that will apply in 2021.

In addition, the ACS Group actively participates in industry associations, working groups and discussion forums. The aim of this participation is to promote the sectors in which ACS and its Group participate, and to establish dialogue initiatives to improve relationships with its stakeholders. To delineate this participation, on 27 July 2023 the ACS Group's Board approved the "Industry Association Engagement and Tracking Policy", which sets out the procedure to be followed by ACS and its Group in selecting and participating in these associations, so as to comply with the principles established by national and international law, and those voluntarily assumed by ACS and its Group in its internal regulations. [...] **Industry Association Engagement and Tracking Policy**

The overall responsibility for the climate change strategy in the Group rests with the ACS Board of Directors, which approves and monitors policy development to minimize the impact in this area, which each of the companies of the ACS Group will prepare and develop according to their type of activity and geographical area, but always following the basic principles defined in the Group's Environmental Policy. Without prejudice to the responsibility of the Board of Directors, the Audit Committee ensures compliance with the transparency obligations of the Company, and in particular ensures that the information contained in the Non Financial Information Statement (NFIS) and in the Annual Corporate Governance Report is sufficient for the market and investors to understand the scope and importance of the corresponding facts and risks with regard to nonfinancial information. These obligations include the ongoing review of the implementation and development of the Group's Environmental Policy, through action plans, procedures and improvement programs implemented by the Environment Department of each of the Group's divisions, with particular regard to issues related to climate change. [...] For the supervision of this risk control system within the ACS Group, it is the Audit Committee that, among other functions, provides support to the Board of Directors in relation to the general monitoring of compliance with the established procedures and effective general supervision of compliance with the established risk levels for each business activity. Also within its function is the review, monitoring and evaluation of the Company's Corporate Social Responsibility Policy and its practices, being therefore responsible for the ongoing review of the implementation and development of the Group's Environmental Policy, through action plans, procedures and improvement programs implemented by the Environment Department of each of the Group's divisions, with particular regard to issues related to climate change.

Finally, it has to be highlighted that, based on the LEAP recommendations, the ACS team is already working on improving the integration of nature-related risk and opportunities into the existing General Risk Management and Control policy, as well as into the Comprehensive Risk Management Control System by the implementation of a fully standardize approach

The Comprehensive Risk Control and Management System covers all types of risks that may threaten the fulfillment of the objectives of the organization and of the Group's companies. ACS has founded this system on a range of strategic and operational actions to mitigate risks and fulfil the objectives set by the Board. Therefore, it is the Group main risk management instrument in which nature-related risks are to be included.

The necessary adjustments, including the definition of appropriate assessment metrics or the internal collaboration to develop centralized nature-related datasets that fit into the current system are ongoing.

The full Integration of nature-related risk and opportunities will constitute the fourth pillar of ACS response to our interactions with biodiversity.

The ACS Group's Audit Committee is responsible for monitoring aspects related to climate change, as it has been given the function of supervising internal regulations, which includes the Sustainability Policy and the Environmental Policy, and managing financial and non-financial risks. The Committee's responsibilities include the ongoing review of the implementation and development of the Group's Environmental Policy, of the action plans, procedures and improvement programmes implemented by the Environmental Department of each one of the Group's divisions, with a special focus on climate change issues. [...] The functions attributed to the Audit Committee of the Group's Board include the review, monitoring and assessment of the Group's Sustainability Policy, and the supervision of the Group's Environmental Policy. Secondly, the responsibility of overseeing environmental performance and performing the appropriate action plans and improvement programmes lies with the Environmental Department of each group of companies, along with adopting the necessary measures to reduce and mitigate the environmental impacts related to the Group's activities, always following the principles established in the Group's Environmental Policy.

The Board of Directors of the ACS Group, as the highest governance body, is responsible for overseeing the overall climate change strategy. Through its functions, it approves the development of the policies required to meet the climate challenges of the business, leaving the Group companies responsible for developing their own management mechanisms depending on the type of activity and geographic area. [...] In addition, the ACS Group's Audit Committee is responsible for monitoring aspects related to climate change, as it has been given the function of supervising internal regulations, which includes the Sustainability Policy and the Environmental Policy, as well as managing financial and non-financial risks. The Committee's responsibilities include the ongoing review of the implementation and development of the Group's Environmental Policy, of the action plans, procedures and improvement programmes implemented by the Environmental Department of each one of the Group's divisions, with a special focus on climate change issues.

Approval of the Policy on Participation in and Monitoring of Sector Associations, within the framework of the growing interest on the part of stakeholders, specifically sustainability and ratings indexes, in learning about how the ACS Group manages its participation in sector associations and how it monitors and supervises them. The interest in this issue comes, on the one hand, from the need to ensure that the Group, through its participation in these associations, is adhering to its compliance policies, and on the other hand the need to assess whether the associations it participates in are aligned with the Group's policies and principles. [...] Therefore, the Board approved, in its Plenary Meeting held on 28 July 2022, the General Compliance Policy as a formal means of adopting and implementing the Global Compliance Management System and, through the Audit Committee and the Compliance Committee, it has taken charge of regularly assessing its effectiveness, changing it, if necessary, when it becomes aware, through any channel, of the existence of serious breaches or when there are significant changes in the circumstances that concern the organisation, in the assessment of compliance risks or in the compliance targets set by the Compliance Committee.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]ACS Group has a clear commitment to support the Paris Agreement , as it is stated in its Sustainability Policy and its Environmental Policy. This commitment is reflected in the Sustainability Master Plan 2025 of the ACS Group being one of the targets to anticipate climate neutrality by 2045. To this end, we are focused on making our business sustainable and offering Green products and services.

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