EUROKAI GmbH : Non-Financial Group Declaration 2023,

EUROKAI Non-Financial Group Report for 2023

Introduction

This non-financial Group report is produced pursuant to Sections 315b and 315c in conjunction with Sections 289c to 289e of the German Commercial Code (HGB) and relates to the EUROKAI Group for the financial year 2023.

In the 2023 financial year, the EUROKAI Group reports in full on key performance indicators that are required to be disclosed on the basis of Regulation (EU) 2020/852 of the European Parliament and the Council of 18 June 2020 (EU Taxonomy Regulation) and the associated published Delegated Acts (see section EU Taxonomy).

The non-financial Group report is available publicly on our website at:

https://www.eurokai.de/eurokai_en/Investor-Relations/Corporate-Governance

Group entity and business model

The focus of the business activities of the companies consolidated in the EUROKAI Group is on container handling in continental Europe as well as North Africa. These companies operate container terminals, in some cases with partners, in La Spezia, Ravenna and Salerno (Italy), in Hamburg, Bremerhaven and Wilhelmshaven (Germany), as well as in Tangier (Morocco) and in Limassol (Cyprus). The EUROKAI Group also has shareholdings in a number of inland terminals and railway operating companies.

Secondary services are also provided in the form of intermodal services (carriage of sea containers to and from terminals), repairs, depot storage and trading of containers as well as cargomodal services and technical services.

Control of the EUROKAI Group is vested in three business segments, "CONTSHIP Italia" "EUROGATE" and "EUROKAI", with the EUROGATE joint venture being included in the consolidated EUROKAI financial statements using the equity method of accounting in line with the provisions of IFRS 11. EUROKAI is a financial holding company.

About this report

All information refers to the parent company, including those domestic and foreign companies which EUROKAI incorporates into its consolidated financial statements or which are classified as associated companies.

This report covers the operating companies active in the core business of the Group. It does not report on minority interests that are not directly involved in the core business, or on companies in which the Group has a stake through minority interests outside Germany, as

these are not classified as material in relation to the non-financial impact of their activities and the potential for exerting influence.1

This report focuses on topics that are necessary for an understanding of the business development, the performance of the business and the position of the Group, as well as the impact of its business activities on non-financial aspects. It follows the Sustainability Reporting Standards published by the Global Reporting Initiative (GRI). The description of the concepts presented here was also prepared in accordance with the GRI Standards. Management of non-financial aspects does not follow a Group-wide approach. Instead, the topics are managed decentrally within each of the corporate groups. Accordingly, the following pages set out both the concept for CONTSHIP Italia and the concept for EUROGATE. For the disclosure of the aspects, non-financial key performance indicators are reported on that are selected according to the thematically related GRI Standard. As part of the reporting process, EUROKAI examined whether risks exist that are linked to the company's own business activities, business relationships, or products and services and that have or can have a serious negative impact on the non-financial aspects defined by law and have a high likelihood of occurrence. On balance, there are no reportable net risks as defined in the German CSR Implementation Act (CSR-RUG).

Statutory disclosure requirements are continuing to increase. The Corporate Sustainability Reporting Directive (CSRD) was published in the EU Official Journal on 16 December 2022. The CSRD will replace the existing EU Directive on non-financial reporting (NFRD) and will, among other things, extend the scope, increase the specificity and broaden the requirements for sustainability reporting as well as the external audit obligation for financial years from 2024. On 31 July 2023, a Delegated Regulation adopted by the European Commission was published, which contains revised European Sustainability Reporting Standards (ESRS) in Annex I, which will form the basis for the content of EUROKAI's sustainability reporting from the 2024 financial year onwards.

EUROKAI is actively preparing for adoption of the new reporting requirements. The materiality analysis is being revised in accordance with the principle of dual materiality contained in the CSRD to determine the scope of the report. Furthermore, the data points contained in the ESRS will be mapped against the status quo of our own reporting. EUROKAI will prepare its next sustainability report (financial year 2024) in accordance with the requirements of the CSRD and ESRS.

1Companies not classified as material are: boxXpress.de GmbH, "Brückenhaus" Grundstücksgesellschaft m.b.H., DHU Gesellschaft Datenverarbeitung Hamburger Umschlagsbetriebe mbH, driveMybox logstics GmbH, EUROGATE Beteiligungs-GmbH, EUROGATE City Terminal GmbH, EUROGATE Container Terminal Wilhelmshaven Beteiligungsgesellschaft mbH, EUROGATE Geschäftsführungs-GmbH & Co. KGaA, EUROGATE International GmbH, EUROGATE KV-Anlage Wilhelmshaven GmbH, EuroXpress HGF GmbH, HVCC Hamburg Vessel Coordination Center GmbH, IPN Inland Port Network GmbH & Co. KG, IPN Inland Port Network Verwaltungsgesellschaft mbH, J.F. Müller & Sohn AG, MSC Gate Bremerhaven Verwaltungsgesellschaft mbH, North Sea Terminal Bremerhaven Verwaltungsgesellschaft mbH, PCO Stauereibetrieb PAETZ & Co. Nfl. GmbH, TRIMODAL LOGISTIK GmbH, Contrepair S.r.l., Immobiliare Rubiera S.r.l., La Spezia Shunting Railways S.p.A., Spedemar S.r.l., Terminal Container Ravenna S.p.A., boxXagency Kereskedelmi és Szolgáltató Kft, CONTRAIL Logística S.A., EUROGATE Container Terminal Limassol Ltd., EUROGATE Tanger S.A., EUROGATE Damietta GmbH, Damietta Alliance Container Terminal S.A.E., Contship Damietta S. r. l., Tanger Alliance S.A., TangerMedGate Management S.a.r.l., OJSC Ust-Luga Container Terminal and EUROGATE Rail Hungary Zrt.

Importance of sustainability

For EUROKAI, sustainability means, above all, ensuring the future viability of the corporate Group. Within the scope of its business activities and on the basis of internal processes, EUROKAI gives equal consideration to economic efficiency, environmental protection and social responsibility. Compliance with laws and internal policies and guidelines forms the natural basic prerequisite for day-to-day business operations. Container terminals are hubs of international trade; therefore efficient seaport operations are key to enabling EUROKAI to ensure that its customers benefit from reliable goods transport. At the same time, EUROKAI strengthens the local economy and provides jobs. Its business activities impact on both people and the environment, for instance through the Group's consumption of resources.

Process for determining materiality

The decentralised structure of the Group essentially governs the process of assessing materiality for identifying, prioritising and validating the contents of this report. In a first step, relevant topics are identified at the level of CONTSHIP Italia and at the level of EUROGATE based on the GRI Standards. If a topic is deemed to be fundamentally relevant for one of the segments, a materiality analysis is carried out from the perspective of the EUROKAI Group as a whole based on the materiality threshold in accordance with Section 289c (3) of the German Commercial Code (HGB). Accordingly, the Group reports on topics that on the one hand are of high relevance for gaining an understanding of the development, performance and position of EUROKAI and on the other hand where EUROKAI exerts material influence through its business activities. The materiality analysis is reviewed annually through a survey of internal experts and decision-makers who are able both to assess the non-financial aspects from an internal standpoint and from the perspective of external stakeholders.

Within the scope of this review, the four previously identified material non-financial aspects remained unchanged for the 2023 financial year. These were: energy consumption and CO2 emissions (environmental matters), occupational health and safety (employee dimension), anti-corruption and anti-bribery, and IT security.

External audit

The contents of this non-financial report were audited in accordance with ISAE 3000 (revised) to obtain limited assurance. The scope of the audit and the auditor's assessment can be found in the Auditor's Limited Assurance Report on pages 31-34.

Environmental matters - energy consumption and CO2 emissions

The Group's business activities consume large amounts of energy. Energy consumption is a key performance indicator for the management of resources and has a direct impact on incurred costs, and hence on financial performance. Most of this energy consumption is due to the use of diesel fuel, mainly for the operation of straddle carriers and tractor units used for

container transport at the terminals. Other energy consumers are container gantries, buildings and area lighting. Electricity and gas are used as energy sources in these areas.

At the same time, energy consumption substantially impacts on the environment, because it uses natural resources and produces greenhouse gas emissions. Efforts to limit climate change and minimise the Group's own carbon footprint are a socially significant issue. Together with the cost aspect associated with energy consumption these drive EUROKAI's energy management activities.

The strategic orientation of the two segments that characterise the EUROKAI Group, CONTSHIP Italia and EUROGATE, differs as regards energy consumption and CO2 emissions both from a conceptual perspective and in terms of progress.

CONTSHIP Italia: Apart from the purchase of energy, CONTSHIP Italia manages its concept for energy reduction decentrally. Only energy procurement is managed centrally. All companies in the CONTSHIP Italia Group have a code of conduct which defines Group values and policies. This also covers the reduction of energy consumption. Each employee is required to declare their adherence to this principle.

A quality policy (with ref. to ISO 9001) governs compliance with statutory regulations and helps to raise awareness of the importance of a sustainable business development across the CONTSHIP Italia Group. The policy further comprises principles governing the avoidance of accidents and contamination, the monitoring and control of environmental impacts and an efficient use of resources, with the aim of continually improving processes and performance. Furthermore, the maritime terminal in La Spezia is also certified in accordance with the ISO 14001 environmental management system standard and ISO 45001 health and safety management system.

Line managers and management bodies are expected to encourage and promote a resource- saving attitude. The Group intends to steadily reduce the carbon footprint resulting from the consumption of energy by investing in high-quality transport equipment and technologies. Local management is involved in this process and within the context of the management system. Energy consumption and the financial impact of achieved savings are analysed at the level of the individual companies. No formal, quantitative reduction targets are set; however, the Group pursues the qualitative goal to reduce energy and CO2 emissions in absolute terms compared with the previous year.

Energy audits pursuant to EU Resolution 2012/27 are performed every four years; the first audit took place in 2015. In December 2023 a new energy audit was carried out and the related report was produced with reference to the year 2022. These audits deliver proposals on further possible measures to reduce energy consumption.

EUROGATE: In 2022, a central energy management system was established on the basis of DIN EN 50001 aimed at achieving a structured improvement in energy efficiency. Responsibility for the central energy management system lies with the Managing Director of EUROGATE Technical Services GmbH. In parallel, an energy audit pursuant to DIN EN 16247 is carried out on a rotating basis across the various sites, which identifies efficiency potential. This flows into the central energy management. The energy audit is conducted every four years, and in addition the individual energy management system comprising key performance indicators, targets, regular energy efficiency assessments, a list of technical measures,

technical inspections, process audits and management reviews is further enhanced. In this context, EUROGATE is investing in renewable energy sources to enable it to meet its own energy needs. Energy efficiency is a decision criterion when making capital expenditure and purchasing decisions.

Various large and smaller measures aim to achieve improvements by tackling the energy efficiency of the major energy consumers. Measures and projects are regularly implemented that focus on utilising savings potential, for example with in-depth capture and analysis of straddle carrier consumption data. The goal is to achieve a continuous reduction in the consumption of fossil fuels. Energy efficiency measures have both a technical and an operational focus. EUROGATE remains committed to appealing to its employees' sense of responsibility with regard to saving resources and involves them in drives to cut energy consumption. EUROGATE regularly examines options for using more energy-efficient technologies. Thus the 2023 financial year saw renewed investments made in additional more energy-efficient equipment (hybrid straddle carriers). The Group-wide transformation process launched in the 2020 financial year continued in 2023 with the goal to improve operational workflows and potentially have a positive impact on energy efficiency in subsequent years.

Moreover, EUROGATE generates its own renewable energy from two wind turbines, three photovoltaic plants, and one wood-chip power station. It also runs three combined heat and power plants for energy generation.

The most important key performance indicator at CONTSHIP Italia and EUROGATE in the area of energy consumption is consumption in total megawatt hours.

Energy consumption is regularly monitored. The following table shows the current status of target attainment:

	CONTSHIP Italia*	EUROGATE**
Target	Lower energy consumption
Status 2022	62,363 MWh (of which 12,867 MWh	407,075 MWh (of which 13,358
	renewables - due to energy mix by	MWh renewables)***
	the supplier)****
Status 2023	54,396 MWh (of which 11,865 MWh	332,760 MWh (of which 11,780
	renewables - due to energy mix by	MWh renewables)
	the supplier)
Comment	The increase in the share of	In view of the increasing importance
	renewables is attributable to the	of the carbon footprint, the goal is to
	change of supplier and the resulting	further	expand	renewables and
	change in the energy mix. There was	further reduce energy consumption.
	a slight decrease in energy	Energy consumption was down in
	consumption as a result of the	the 2023 financial year. The decline
	development in handling volumes.	in container handling is the main
		reason	for	this.	Some	energy-
		reducing measures, such as the
		investment	in	hybrid	straddle
		carriers, are already having an
		effect.

*Excluding fuel volumes from purchased intermodal services and excluding heating energy consumption in office buildings in La Spezia.

**When calculating the key performance indicator MWh, the consumption figures for the principal companies (the German EUROGATE terminal operations in Hamburg, Bremerhaven and Wilhelmshaven and the respective service companies at each location, as well as the EUROGATE holding company) were taken into consideration.

***The data published in the non-financial Group report for the 2022 financial year has since been revised and adjusted, resulting in lower energy consumption.

****The data published in the non-financial Group report for the 2022 financial year has since been recalculated to include the energy consumption of OCEANOGATE (operation of locomotives), resulting in higher energy consumption.

The most important key performance indicator at CONTSHIP Italia and EUROGATE in the area of emissions is total CO2 emissions in tonnes (t CO2).

CO2 emissions (Scope 1 and Scope 2) are regularly reviewed. The following table shows the current status of target attainment:

	CONTSHIP Italia*		EUROGATE**
Target	Lower CO2 emissions		1. CO2 neutrality by 2040 (relating
					to Scope 1 and Scope 2 emissions)
					2. 50% reduction of CO2 emissions
					by 2030 compared to the 2022 base
					year (relating to Scope 1 and Scope
					2 emissions).
Status 2022	15,896*** t CO2		130,832**** t CO₂
Status 2023	14,131 t CO₂			106,111 t CO₂
Comment	The emission factor was applied to	EUROGATE has set the target to be
	the	full	electrical	energy	CO2 neutral by 2040 (relating to
	consumption, as it already takes into	Scope 1 and Scope 2 emissions).
	consideration	the energy mix	CO2 emissions (Scope 1 and Scope
	supplied by the energy provider	2) were lower in 2023 than in the
	(Enel Green Power).		previous year. The decline in
	The calculation also includes the	container handling is the main
	CO2 reduction due to solar energy	reason for this. Some emission-
	autoproduction at Sogemar.		reducing measures, such as the
					investment in hybrid straddle
					carriers, are already having an
					effect.

*When calculating total CO2 emissions, direct emissions (Scope 1) from diesel combustion as fuel for the vehicles of the various companies were taken into account, as well as indirect emissions (Scope 2) that result from electricity consumption. The CO2 emissions resulting from the consumption of natural gas are not included in the calculation due to its limited use (exclusively in the canteens of the intermodal terminals).

**When calculating the key performance indicator t CO2, the consumption figures for the principal companies (the German EUROGATE terminal operations in Hamburg, Bremerhaven and Wilhelmshaven and the respective service companies at each location, as well as the EUROGATE holding company) were taken into consideration.

***In the non-financial Group report for the 2022 financial year, CO2 emissions for CONTSHIP Italia were recognised with 12,910 t CO2. By contrast, in the present version the previous year's figure has been adjusted to 15,896 t CO2 to include the business activities of OCEANOGATE.

****The data published in the non-financial Group report for the 2022 financial year was revised in 2023 and the calculation is now based on CO2 emission factors including upstream chain emissions. As a result, the CO2 emissions for 2022 are higher year on year.

Employee dimension - occupational health and safety

Protecting the Group's own employees and employees of external companies against work- related injuries or sickness and safeguarding their health and well-being has long been a top priority. Most work is performed using heavy equipment at the terminals (mainly straddle carriers and container gantries), and is susceptible to prevailing weather conditions. Considering the manual nature of this work and the deployment of much of the workforce in a three-shift system, promoting and protecting their health is especially important.

Occupational health and safety concerns not just the health and well-being of our employees, but also has a vital impact on their performance. Especially goods handling operations at our seaports require a high level of safety awareness.

Management of occupational health and safety is the responsibility at both CONTSHIP Italia and EUROGATE of the individual companies and their respective managing directors, since it is influenced particularly by local factors. This is implemented through the EUROKAI Group's overarching goal to reduce the number of industrial accidents to a minimum and to eliminate accidental deaths altogether.

CONTSHIP Italia: In Italy strict statutory requirements are in force aimed at protecting workers' health. For example, in the event of proven malpractice, the management personally, as well as companies, may face prosecution. On the back of these requirements, various structural and organisational measures have been established. Each individual company analyses, documents and reports accidents to the respective occupational safety officer and the competent government departments pursuant to the statutory requirements in Italy. Accidents and near-misses are monitored and evaluated. These evaluations serve as vital information input for health-and-safety risk assessments. Regular training courses address the areas of risk identified and a health programme launched in 2019 addresses how to cope with stress and mental strain in the workplace and is designed to provide information about a healthy diet and a healthy lifestyle. The La Spezia container terminal of the CONTSHIP Italia Group is certified in accordance with DIN EN ISO 45001. The certification audits deliver proposals for potential measures to prevent industrial accidents and improve occupational health and safety.

EUROGATE: The management boards of the individual EUROGATE companies draw up and regularly update guidelines and operating instructions for occupational health and safety

based on their specific workflows. As part of their duty of care, managers are tasked with assessing hazards and monitoring compliance with the guidelines and operating instructions in their area of responsibility. Each location has an occupational health physician, an occupational safety expert and a safety officer.

At EUROGATE, various technical and organisational measures have been put in place to lower risk exposure and reduce accidents. Ongoing measures include regular training and instruction courses on safety standards and accident prevention guidelines, as well as monitoring whether these regulations are observed. Standards are in force governing compliance with occupational safety rules, for example mandatory wearing of personal protective clothing and equipment at the terminal site. Workplaces are regularly inspected to assess hazards at the workplace and to advise on measures to minimise risk. Any injuries and accidents that occur are categorised and evaluated.

At the German terminals, along with regular training and briefings, a number of events with a focus on occupational health and safety are also organised. These are also attended by executive managers, since they bear particular responsibility to lead by example. These activities are regularly organised in cooperation with external partners. For example, at the Hamburg and Bremerhaven sites, rescue exercises at heights were carried out with the local fire brigades. Building evacuation drills were also conducted on the basis of practice runs of a fire alarm being activated. Regular health and safety briefings, site inspections and systematic accident evaluations are carried out at all sites as the basis for developing preventive measures and adapting risk assessments.

The key ratios for CONTSHIP Italia and EUROGATE in the area of occupational health and safety are the number of reportable work-related accidents (accidents at the workplace and on the way to/from work) and the number of accidental deaths (as a result of accidents at the workplace and on the way to/from work).

The number of work-related accidents is regularly monitored as an indicator of occupational safety. The following table shows the current status of target attainment:

	CONTSHIP Italia*	EUROGATE**
Target	Minimise the number of work-related accidents and prevent accidental
	deaths.
Status	Work-related accidents: 23	Work-related accidents: 268
2022	Accidental deaths: 1	Accidental deaths: none
Status	Work-related accidents: 18	Work-related accidents: 250
2023	Accidental deaths: none	Accidental deaths: 1
Comment	The decreased number of accidents	The target to lower the number of
	reflects the improved safety	work-related accidents was met;
	awareness of employees as a result	however, in January 2023 there was
	of the training and measures	one accidental death. The drop in the
	implemented to handle near misses.	number of work-related accidents is
		attributable on the one hand to the
		lower number of containers handled.
		On the other hand, the lower number
		of work-related accidents for this

financial year is within the range of natural statistical fluctuations.

*In Italy all accidents must be reported that result in death or injury that prevents a person from working for more than one day. Some processes at the operating facilities are carried out by external contractors. Their employees account for around 40% of the total workforce on site. The CONTSHIP Italia figure does not include accidents involving temporary contract workers and external contractors.

**In Germany all accidents must be reported that result in death or injury that prevents a person from working for more than three days. The EUROGATE figure includes accidents involving not only the company's own employees, but also temporary contract workers. It does not record accidents involving employees of external contractors.

Anti-corruption and anti-bribery

To achieve long-term success, a company must conduct its activities in a compliant, fair and reliable way. Within the EUROKAI Group, the umbrella term "compliance" relates to the adherence to statutory standards as well as internal corporate guidelines and policies and working to ensure their observance in the EUROKAI Group companies. These include the relevant policies and principles for preventing bribery and corruption.

CONTSHIP Italia: CONTSHIP Italia has a code of conduct in place which defines the Group's core values. Corresponding guidelines for conduct which reflect these values supplement this code. The code states that all activities of the CONTSHIP Italia Group shall comply with the legislative framework, the principles of fair competition, honesty, integrity, fairness, good faith, and respect the legitimate interests of customers, employees, shareholders, business and financial partners.

In 2018, CONTSHIP Italia voluntarily implemented a surveillance and monitoring system to prevent crimes identified by Legislative Decree 231/2001 ("Discipline of the administrative liability of legal persons, companies and associations, including those without legal personality") for La Spezia Container Terminal and OCEANOGATE. In accordance with this Legislative Decree, the required organisational, management and control model as well as bodies for monitoring compliance with the guidelines were established. CONTSHIP Italia and Rail Hub Milano have established a surveillance and monitoring system, together with corresponding processes and control bodies. In 2019, a Group-wide whistleblowing system was rolled out. All internal stakeholder groups were informed of this procedure as part of a comprehensive communication process. An external ombudsperson was appointed to manage the procedure. In November 2023, a new whistleblowing procedure was approved for all Group companies as a requirement of the new Italian Legislative Decree no. 24/2023 (transposition of the EU Directive 2019/1937 on the protection of persons who report breaches of Union law). The amendment has also been included in the Organisational, Management and Control Model of those companies that have already adopted it.

Responsibility for adherence to compliance-related issues lies with the Management Board of Contship Italia S.p.A., the holding company of the CONTSHIP Italia Group, and the management boards of the respective companies in the CONTSHIP Italia Group. Internal

audits support the identification of improvement potential with regard to compliance with the Group's guidelines. On the basis of the audit results, each company develops an action plan to close identified gaps.

EUROGATE: EUROGATE has established a compliance management system, which comprises a compliance policy with several sections, a code of conduct, a self-declaration of compliance with sanctions and an anti-corruption policy. The compliance policy, code of conduct and the anti-corruption policy came into force on 1 January 2017 and apply to all EUROGATE Group entities in which EUROGATE directly or indirectly holds more than 50% of the shares or exercises entrepreneurial control, as well as to the MSC Gate Bremerhaven GmbH & Co. KG joint venture operated by EUROGATE and Terminal Investment Limited S.à.r.l ("TiL"). The self-declaration of compliance with sanctions was adopted in 2022. The code of conduct and the anti-corruption policy are currently being revised. Cementing the Group's commitment to fair and free competition, the guidelines and the code of conduct summarise the Group's values and provide the basis for our understanding of entrepreneurial compliance. These documents state that EUROGATE neither tolerates corruption nor permits discrimination. All commercial decisions must comply with the law and meet EUROGATE's standards of ethics and integrity as described in the policies and guidelines.

Technical competence for the compliance management system lies with the legal department of the EUROGATE holding company and the compliance officer. Responsibility for compliance with the anti-corruption policy lies with the Group Management Board and the management board of the respective EUROGATE Group company. On introduction of the compliance management system, EUROGATE also appointed a compliance officer. Furthermore, an external ombudsperson was appointed to receive anonymous information. If necessary, independent external consultants are called in for advice, audits and assessments. Once a year, the compliance officer presents an internal report to the Group Management Board and the supervisory bodies. Among other points, this contains the current status of the main compliance risks as well as proposals for new measures or changes.

When the compliance regulations came into force, all employees received a copy of the anti- corruption policy and the code of conduct. In 2019, following on from the in-person training courses conducted in 2017 when the compliance management system was introduced, workshops were held for employees in particularly sensitive areas of the company. Group- wide compliance training sessions in the white-collar area is planned for the 2024 financial year.

Compliance management at North Sea Terminal Bremerhaven GmbH & Co. (NTB), which is operated as a joint venture between EUROGATE and APM, is conducted separately. The shareholders' guidelines and policies are discussed with the relevant employee groups within the scope of regular compliance training courses. This means that the compliance regulations of both partners are also observed at NTB. Responsibility for this lies with the NTB Management Board. There is an internal control manual that defines the company's main