Tubacex S A : Non Financial information statement 2024

Independent Limited Assurance Report on the Consolidaled Non-Financial Information Stalement and Sustainability Information for the year ended December 3l, 2024

TUBAC EX, S.A. A ND SUBSIDI ARIES

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INDEPENDENT LTMT TED A66URANCE YES@RT ON THE CON6OLTDATED NON -WNANCT AL TN RMA¥T@N 6TA¥EMENI AND 6U6¥ATNABTLTTY TNFORMAT NON

Translation of a report originally issued in 5gani. Tn the event of discrepancy, the Spanish-language version pevailml

To the shareholders of TUBACE X S.A.

conclusion of limited assurance

In accordaixe with artic Ie 4o of the Commercial Code, we have performed a limited verification engagement on the consolidated Non-FinaixiaI Information statement {'^HFTS'"} for the year ended necember at, zoz<, of TUBACEX, s.o. {the "Entity'0 and subsidiaries {the "croup"}, which is part of the Group's consolidated Management Report.

The content of the NFIS iixludes information in addition to that rerpired by prevailing company law in respect of non-finaixial information, specifically the sustainability Information prepared by the croup for the year ended December u1, zoz< {the "sustainability information"} in accordance with

Directive {Eu› zozz/z464 of the European Parliament and of the council of 14 December zozz, as regards corporate sustainability reporting {the "CsRD^'J. The sustainability information wa also subject to limited verification.

Based on the procedures applied and the evidence obtained, rothing has come to our attention that causes us to believe that:

a) The Group's NFIS for the year ended December of", 2024 has not been prepared, in all material respects, in accordance with the contents required by prevailing company law and the criteria selected in European sustainability Reporting standards {'^ES'RS'^'}, as well as other criteria described a eaplained for each subject matter in table: annes I: Rerpirements under Law I I/zoa on Non-rinancial Information {HFTS').

b} The sustainability information, taken as a whole, has rot been prepared, in all material respects, in accordance with the sustainability reporting framework applied by the croup and identified In the section lRo 2 - oisclosure requirements covered established in the NEIS, covered by the attached cc+npany's sustainability statement, including:

That the description of the process for identifying the sustainability information to be disclosed included In section 1.4 Management of material impacts, risks and opportunities is consistent with the process implemented and that it enables the identification of the material information to be disclosed in accordaixe with the requirements of ESRS.

Compliance with ESRS.

Cc+npliance of the disclosure requirements included in section s: raxonomy, on the environment in the sustainability information with article s of Reputation {Eu› zozoyasz of the European Parliament and of the council of is June zozo, on the establishment of a framework to facilitate sustainable investment.

easis of conclusion

we have performed our limited verification engagement in accordance with generally accepted professional standards applicable in spain and specifically with the guidelines contained in the cuidelines 47 revi and ss issued by the spanish Institute of chartered accountants on nonfinancial information assurance engagements and considering the contents of the rote issued by the spanish accounting and auditing Institute {icoc› on December la, 2024 {the "generally accepted professional standards").

The procedures performed in a limited verification engagement are less in extent than for a reaonable verification enga ment. consequently, the level of assurance obtained in a limited verification engagement is lower than the asurance that would have been obtained had a reasonable assurance engagement been performed.

our responsibilities under those regulations are further described in the F'ract/tiouer's respons/6i/itiés section of our report.

we have complied with the independeixe and other ethics rerpirements of the International code of Ethics for Professional Accountants 0ncluBng international standards on independence} of the International Ethics standards Board for accountants {IESBA}, which is based on the fundamental principles of integrity, objectivity, professional competence and due care, confidentiality, and professional behavior.

our firm applies International standard on quality Management {IS'OMJ 1, which requires us to design, implement, and operate a system of quality management including policies and procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.

we believe that the evidence obtained is sufficient and appropriate to provide a basis for our conclusion.

responsibilities of the directors

The preparation of the NFIs included in the Group's consolidated management report is the responsibility of the directors of TUBACEX, S'.A. The HFIS ha been prepared in accordance with the content required by prevailing company law and the criteria selected in Eses, as well as other criteria described a explained for earh subject matter in table Annes I: Requirements under Law I I/zoa on non-Financial Information {NFISJ. of the NFiS.

This responsibility also includes the design, implementation, and maintenance of such internal contrd as considered necessary to ensure that the HFIS' is free of material misstatement, whether due to fraud or error.

The directors of TUBACEx, s.a. are also responsible for defining, implementing, adapting, and maintaining the management systems from which the necessary information for preparing the HFls is obtained.

In relation to the sustainability information, the entity's directors are responsible for developing and implementing a process for identifying the information to be iixluded in the sustainability information in accordance with the csRD, the EsRs and article s of Regulation {Eu› zozoyasz of the European arliament and of the council, of la June zozo, and for disclosing information about this process in the sustainability information itself in section 1.4 Management of material impacts, risks and opportunities. This responsibility includes:

understanding the contest in which the croup carries out its activities and business relationships, as well as its stakeholders, in relation to the croup's impact on people and the environment.

Identifying the actual and potential impacts {both negative and positive), as well as risks and oggortunities that could affect, or could reasonably be eapected to affect, the Group's financial position, finaixial performance, cah flows, access to finaixing, or cost of capital in the short, medium or long term.

assessing the materiality of the identified impacts, risks and opportunities.

MaLinq assumptions and estimates that are reasonable under the circumstances.

The directors are also responsible for the preparation of the sustainability information, which iixludes the information identified by the process, in accordaixe with the sustainability reporting framework used, including compliance with the csRD, the Eses, and cc+npIiance of the Bsclosure requirements included in section s: Taxonomy, of the section on the environment in the sustainability information with article s of Regulation {EUj zozoyasz of the European Parliament and of the Couixil, of 1s June zozo, on the establishment of a framework to facilitate sustainable investment.

This responsibility includes:

Designing, implementing and maintaining such internal control a the directors consider relevant to enable the preparation the sustainability information that is free frc+n material misstatement, whether due to fraud or error.

selecting and applying appropriate methods for the presentation of sustainability information and the bais of asumptions and estimates that are reasonable, considering the circumstances, about specific disclosures.

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lnher ent limitations in the preparation of the information

In accordaixe with ES'Ps, the entity's directors are required to prepare forward-looking information on the basis of assumptions and hypothetical assumptions, which must be included in the sustainability information, about potential future events and possible future actions, if any, that the croup could take. actual results may differ significantly from estimated results, a the reference is to the future and future events frequently do not occur as expected.

In determining the disclosures in the sustainability information, the entity's directors interpret legal and other terms that are not clearly defined and that may be interpreted differently by others, iixluding the legal conformity of siJch interpretations, and, accordingly, are subject to uixertainty.

practitioner's responsibilities

our adjectives are to plan and perform the verification engagement to obtain limited assurance about whether the NFIs and sustainability information are free from material misstatement, whether due to fraud or error, and to issue a limited verification report that iixludes our conclusions. Misstatements can arise frc+n fraud or error and are considered material if, individually or in the aggregate, they could reaonably be eapected to influence the economic decisions of users taken on the basis of this information.

as part of a limited verification engagement, we exercise professional judgment and maintain professional skepticism throughout the engagement. we also:

Design and perform procedures to assess whether the process for identifying the disclosures to be included in the HFis and sustainability information is consistent with the description of the process followed by the Group and enables, where appropriate, the identification of the material information to be disclosed a required in the ESRs.

Perform risk procedures, iixluding obtaining an understanding of internal control relevant to the engagement, to identify disclosures where material misstatements are more likely to arise, whether due to fraud or error, but not for the purpose of providing a conclusion on the effectiveness of the croup's internal control.

Design and perform procedures responsive to disclosures in the HFIs and sustainability information where material misstatements are likely to arise. The risk of rot detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.