Untitled

Annual Financial Report of 31 December 2021

ELVALHALCOR HELLENIC COPPER AND ALUMINIUM INDUSTRY S.A.

G.C. Registry: 303401000

LEI: 213800EYWS2GY56AWP42

S.A. Registry No.: 26/06/B/86/48

Seat: Athens Tower, Building B, 2-4 Mesogeion Ave., 11527 Athens

According to the International Financial Reporting Standards

and according to Law 3556/2007

Annual Financial Report

of 31

December 2021

  
Annual Financial Report of 31 December 2021 
Page | 1  
 
Table of Contents 
STATEMENTS BY MEMBERS OF THE BOARD OF DIRECTORS  4 
BOARD OF DIRECTORS ANNUAL REPORT  5 
1.  Financials - Business report - Major events  5 
2.  Financial standing  7 
3.  Main risks and uncertainties  11 
4.  Outlook and targets for 2022  15 
5.  Transactions with related parties  16 
6.  Subsequent events  20 
ELVALHALCOR– NON-FINANCIAL REPORTING  21 
BOARD OF DIRECTORS EXPLANATORY REPORT  35 
1.  Structure of share capital  35 
2.  Restrictions on the transfer of shares of the Company  35 
3.  Major direct or indirect holdings within the meaning of Articles 9 to 11 of Law 3556/2007  35 
4.  Shares granting special rights of control  35 
5.  Restrictions on voting rights  35 
6.  Agreements between Company’s shareholders  35 
7.  Rules on the appointment and replacement of Board members and amendment of the Articles of 
Association  35 
8.  Powers of the Board of Directors to issue new shares or purchase own shares  35 
9.  Major agreements which take effect have been amended or expire in the case of change in 
control  36 
10.  Agreements with Board of Directors members or Company’s staff  36 
CORPORATE GOVERNANCE STATEMENT  37 
Rules of Operation – Corporate Governance Code  37 
Main features of the Internal Audit System in relation to the Process of Preparation of Financial 
Statements and financial reports.  39 
Public Takeover Offers – Information  41 
General Meeting of the Shareholders and rights of shareholders  41 
Composition and operation of the Board of Directors, the Supervisory Bodies and the Committees of 
the Company  41 
ACTIVITY REPORT OF THE AUDIT COMMITTEE ON THE AUDITED FINANCIAL 
YEAR 2021  49 
CVS OF MEMBERS OF THE BOARD OF DIRECTORS AND KEY EXECUTIVES OF THE 
COMPANY  56 
NUMBER OF SHARES HELD BY MEMBERS OF THE BOARD OF DIRECTORS AND 
KEY EXECUTIVES AS OF THE DATE HEREOF  60 

  
Annual Financial Report of 31 December 2021 
Page | 2  
 
INDEPENDENT AUDITOR’S REPORT  61 
ANNUAL FINANCIAL STATEMENTS (GROUP AND COMPANY) AS AT 31 
DECEMBER 2021 ACCORDING TO INTERNATIONAL FINANCIAL REPORTING 
STANDARDS  67 
I.  Statement of Financial Position  68 
II.  Income Statement  69 
III.  Statement of Other Comprehensive Income  70 
IV.  Statement of Changes in Equity  71 
V.  Statement of Cash-Flows  73 
1.  Incorporation and Group Activities:  74 
2.  Basis of preparation of the Financial Statements  74 
3.  New principles  75 
4.  Significant accounting principles  78 
5.  Operating segments  89 
6.  Income  93 
7.  Other operating income and expenses  93 
8.  Expenses by nature  94 
9.  Finance income and cost  95 
10.  Property, plant and equipment  96 
11.  Intangible assets  101 
12.  Investment property  103 
13.  Investments  105 
14.  Other investments  111 
15.  Income tax  112 
16.  Inventories  117 
17.  Trade and other receivables  118 
18.  Derivatives  118 

  
Annual Financial Report of 31 December 2021 
Page | 3  
 
 Cash and cash equivalents  119 
 Share capital and reserves  120 
 Earnings per share  121 
 Loans and obligations from financial leasing  122 
 Liabilities for employee’s retirement benefits  123 
 Grants  125 
 Provisions  125 
 Trade payables and other liabilities  125 
 Financial assets  126 
 Fair value of financial assets  137 
 Commitments  138 
 Contingent liabilities / assets  139 
 Related parties  140 
 Auditor’s fees  142 
 ROU  143 
 Non-current and current loan receivables  145 
 EBITDA and a-EBITDA  145 
 Effect in the Profit and Loss from distribution in kind  148 
 Effect from implementation of IAS 19  149 
 Subsequent events  153 
 
 
   
 
The annual financial statements of the Company (in consolidated and non-consolidated basis), the Auditor’s 
Report  and  the  management  report  of  the  Board  of  Directors  are  posted  on  the  Company's  website 
(www.elvalhalcor.com) and the Athens Exchange website (www.helex.gr).

Annual Financial Report of 31 December 2021

Page | 4

STATEMENTS BY MEMBERS OF THE BOARD OF DIRECTORS

(pursuant to Article 4 par. 2 of Law 3556/2007)

The undersigned in our capacity as members of the Board of Directors of the company with the name

ELVALHALCOR HELLENIC COPPER AND ALUMINIUM INDUSTRY S.A, trading as ELVALHALCOR S.A., whose

registered offices are in Athens, at 2-4 Mesogeion Avenue, do hereby declare and confirm that as far as we

know:

(a) the attached annual company and consolidated financial statements for the company ELVALHALCOR S.A.

for the period from 1 January to 31 December 2021, which were prepared in accordance with the applicable

International Financial Reporting Standards (IFRS), as adopted by the European Union, accurately present the

assets, liabilities, equity and results for the period ended on 31 December 2021 for ELVALHALCOR S.A. and the

entities included in the consolidation taken as a whole, in line with the provisions of Article 4, paragraphs 3 to

5, of Law 3556/2007; and

(b) the attached annual report of the Board of Directors of ELVALHALCOR S.A. contains the true information

required by Article 4, paragraphs 6 to 8, of Law 3556/2007.

Athens, 15

of March 2022

Confirmed by

The Vice-Chairman of the Board

The Board-appointed Member

DIMITRIOS KYRIAKOPOULOS

LAMPROS VAROUCHAS

PANAGIOTIS LOLOS

ID Card No. AK 695653

ID Card No. AB 535203

ID Card No. ΑΗ 131173

Annual Financial Report of 31 December 2021

Page | 5

BOARD OF DIRECTORS ANNUAL REPORT

This Annual Report of the Board of Directors set out below (hereinafter referred to for the purpose of brevity

as "Report") concerns year 2021 (1 January – 31 December 2021). This report was prepared in line with the

relevant provisions of Codified Law 4548/2018, the provisions of Law 3556/2007 (Government Gazette

91A/30.4.2007) and of Law 4374/2016 (Government Gazette 50Α/01.04.2016) and the decisions of the Hellenic

Capital Market Commission (HCMC) issued pursuant to it, and in particular Decision No. 7/448/11.10.2007 of

HCMC.

This report details financial information on the Group and the Company of ELVALHALCOR HELLENIC COPPER

AND ALUMINIUM INDUSTRY S.A (hereinafter referred to for the purpose of brevity as "Company" or

"ELVALHALCOR") for the year 2021, important events that took place during the said year and their effect on

the annual financial statements. It also points out the main risks and uncertainties which Group’s companies

were faced against and finally sets out the important transactions between the issuer and its affiliated parties.

The principal activities of the Group lie in the production and trade of rolling and extrusion products made of

copper, aluminium and their alloys, zinc rolling products and copper and aluminium winding (enamelled) wires.

1. Financials - Business report - Major events

Starting from the last quarter of 2020, signs of growth were evident, especially in markets that were directly

affected by the pandemic in the previous year, and growth remained strong throughout 2021, with industrial

production reaching pre-pandemic levels. Supply chain bottlenecks affected by the pandemic do not seem to

be resolved at a fast pace, and the supply chain is slowly returning to normal, leading many companies to

redesign their supply chain and policies, preferring local suppliers and increasing safety stocks. On the other

hand, inflation and the increased prices of energy that apearred in the last quarter, threaten the positive

outlook and put cost, retail consumption and profitability under pressure.

The metal prices which the Group processes fluctuated at significantly higher levels, with the average price of

aluminium at around Euro 2,101 per ton versus Euro 1,490 per ton for 2020, the average price of copper at

Euro 7,881 per ton versus 5,395 per ton for 2020 and the average price of zinc at Euro 2,548 per ton versus

Euro 1,980 per ton for the fiscal year 2020.

In regards to volumes, the aluminium segment presented a remarkable increase by 21.3% with volumes

exceeding 362 thousand tons (including the impact by 9 thousand tons of the newly acquired Group of ETEM),

surpassing the pre pandemic levels. The segment gradually took advantage of the increased capacity brought

by the integration of the new four-stand tandem hot rolling mill in the production process of the parent

company, achieving new production and sales record. The increase was significant in the US market after the

final decision on 02.03.2021, when the authorities announced a final dumping margin of 0% for imports from

ELVALHALCOR, justifying the Group and the Company, which remain committed in the principles of fair trade,

while paving the way for further business development in the USA market. Concerning the sales mix, 51% of

sales was directed to food packing industry (flexible and rigid), with the most of the new capacity directed

towards there, 14% to the transportation industry and 18% to the construction and industrial applications and

the remaining to other industrial applications industry.

Sales volumes of the copper segment increased by 7.9% for the fiscal year 2021, exceeding 190 thousand tons

driven by the sales of brass rods and tubes, which increased by 36.3%, mainly due to the significant recovery

of markets that suffered the most from the pandemic during 2020. Continuous rise was maintained for another

year for the sales of copper and alloys rolled products of subsidiary SOFIA MED, which recorded an increase by

8.9%. Also, sales of copper bars, that the latter produces, grew by 7.9%, while the copper tubes segment of the

parent company remain stable, growing by 0.9%, as the production capacity was limited due to a production

stoppage for unscheduled maintenance. Sales of copper tubes leads the sales mix which represent 42% of total

sales, followed by copper and alloys rolled products for industrial application participating in the product mix

by 32%, copper bars by 15%, brass rods and tubes by 8%, enameled wires by 2% and the products of Epirus

Metalworks by 1%.

https://www.ecb.europa.eu/pub/pdf/ecbu/eb202201.en.pdf

Annual Financial Report of 31 December 2021

Page | 6

Driven by the increased uptrend both in volumes and prices, consolidated revenue reached Euro 2,883

compared to Euro 2,029 in the previous year 2020, increased by 42.1%, setting a historic record for the

consolidated figures of ElvalHalcor. As a result of the uptrend in sales volumes and revenue, consolidated gross

profit increased by 74.3% and amounted to Euro 235 million compared to Euro 135 million in the prior year.

This increase is attributable to the positive impact from the higher metal prices as the metal result recorded

gains of Euro 56.1 million vs losses of Euro 9.0 million in the previous year, as well as the increased volumes

from all of the activities and products of the Group. Consolidated earnings before taxes, interest and

depreciation (EBITDA) amounted to Euro 215.3 in 2021 compared to Euro 121.4 million, i.e increased by 93.9

million, while the consolidated earnings before taxes and interest (ΕΒΙΤ) amounted to profits of Euro 146.9

million compared to 59.4 million in the respective prior year. Finally, consolidated earnings before taxes

reached to profits of Euro 132.4 million, affected by the result of the valuation of the dividend in kind of Cenergy

shares to the shareholders which was Euro 22.2 million, compared to Euro 38.8 million in 2020, with

consolidated earnings after tax and non-controlling interest amounting to profits of Euro 111.7 million, i.e

0.2976 per share, compared to Euro 28.3 million, i.e 0.0754 per share in the prior year. It is worth to be noted,

that adjusted earnings before taxes, interest depreciation and amortization (a-EBITDA) which isolates the

impact of metal prices amounted to Euro 166.9 million for 2021 versus Euro 135.8 million in the corresponding

previous year, i.e. increased by 22.9%.

Regarding the structure of the Group it is noted that on 30.03.2021 the Group incorporated ETEM GR and its

subsidiaries after acquiring 80% of its share capital, by participating in a capital increase of “ETEM S.A.”. Some

days later, on April, the listed securities of Cenergy Holdings were distributed by ElvaHalcor to its shareholders

pursuant to Law 4548/2018, and this raised the total distributed dividends to Euro 94 million or 0.25 per share,

including the amount of the dividend for the fiscal year 2020 that was distributed in June), and resulted to

cessation of the consolidation of the Cenergy Group with the equity method, due to the fact that after the

distribution in kind, the company retained only 3,034 shares, i.e 0.002% of the share capital of Cenergy. At the

end of the same month, the major shareholder of ElvalHalcor carried out a placement of 6.6% of the Company’s

shares, resulting in increasing free float to 15.2% and the share of ElvaHalcor entered the basic indexes of the

Athens Exchange. Finally, concluding the corporate transformations, on 01.07.2021 the merger by absorption

of the 100% subsidiary Fitco SA was completed with the ultimate goal of achieving further economies of scale.

The year 2021, however, was a milestone for one more reason. On 17.11.2021, the issuance of a listed bond

loan amounting to Euro 250 million was successfully completed, with the commencement of trading of the

bonds on the Athens Exchange. The final yield (interest rate) of the Bonds was set at 2.45%, one of the lowest

in the market, confirming investors' confidence in the value of ELVALHALCOR. The raised funds aim to purchase

properties to serve the needs for the investment programme, meet the needs for working capital and

refinancing of loans. Finally, on December 2021 the Company signed two bond loans for the amounts of Euro

140 million and Euro 130 million for the refinancing of existing bond loans and financing general business

operations with more favourable terms.

At the Company level, revenue for 2021 amounted to Euro 1,970 million versus Euro 1,406 million for 2020,

recording an increase by 40.1%. Gross profit rose by 72.3% to Euro 149.2 million versus Euro 86.6 million for

the fiscal year 2020, and earnings before taxes, interest and depreciation and amortization (EBITDA) amounted

to Euro 145.0 million versus Euro 82.2 million with the metal result amounting to gain of Euro 36.8 million

versus loss of Euro 2.7 million for the prior year. Adjusted EBITDA (a-EBITDA), which isolates the effect from

the metal prices and presents in a better way the operational profitability of the Company amounted to Euro

113.6 million versus Euro 89.3 million in 2020, increased by 27.2%. Finally, earnings before taxes reached Euro

100.4 million compared to Euro 22.4 million with the Company’s overall performance being positively affected

by the extraordinary result of the valuation of the dividend in kind of Cenergy shares of Euro 32.6 million.

In 2021 ELVALHALCOR Group carried out total investments of Euro 145.4 million, out of which the amount of

Euro 106.8 million was dedicated to the upgrade of the parent company facilities at Oinofyta, distributed in

Euro 99.5 million for the aluminium rolling division, mainly for the investment regarding the increase in

production capacity (new cold mill and lacquering line) and Euro 7.3 million for the copper and alloys extrusion

division. Finally, the subsidiaries of the copper segment invested Euro 7.8 million and the aluminium

subsidiaries invested Euro 30.8 million, aiming at increasing production capacity, as well as at the production

of high-added-value products.

Annual Financial Report of 31 December 2021

Page | 7

2. Financial standing

ELVALHALCOR’s management has adopted, measures and reports internally and externally Ratios and

Alternative Performance Measure. These measures provide a comparative outlook of the performance of the

Company and the Group and constitute the framework for making decisions for the management.

Liquidity: This is the measure of coverage of the current liabilities by the current assets and can be calculated

by the ratio of the current assets to current liabilities. The amounts are drawn by the Statement of Financial

Position. For the Group and the Company for the closing year and the comparative prior year are as follows:

GROUP €'000

31.12.2021

31.12.2020

Liquidity =

Current Assets

1,106,940

1.71

797,900

1.52

Current Liabilities

648,591

524,331

COMPANY €'000

31.12.2021

31.12.2020

Liquidity =

Current Assets

765,522

1.70

557,343

1.34

Current Liabilities

450,655

416,430

Leverage: This is an indication of the leverage and can be calculated by the ratio of Equity to Debt. The amounts

are used as presented in the statement of financial position. For 2021 and 2020 the index is as follows:

GROUP €'000

31.12.2021

31.12.2020

Leverage =

Equity

808,316

0.92

784,534

1.18

Loans & Borrowings

878,198

656,849

COMPANY €'000

31.12.2021

31.12.2020

Leverage =

Equity

725,428

1.02

738,898

1.42

Loans & Borrowings

713,946

521,834

Return on Invested Capital: It is an indication of the returns of the equity and the loans invested and is

measured by the ratio of the result before financial and tax to equity plus loans and borrowings. The amounts

are used as presented in the statement of profit and loss and the statement of financial position. For the fiscal

year 2021 and the prior year, the index for the Group and the Company is as follows:

GROUP €'000

31.12.2021

31.12.2020

Return on Invested Capital =

Operating profit / (loss)

146,909

8.71%

59,421

4.12%

Equity + Loans & Borrowings

1,686,514

1,441,383

COMPANY €'000

31.12.2021

31.12.2020

Return on Invested Capital =

Operating profit / (loss)

98,554

6.85%

40,192

3.19%

Equity + Loans & Borrowings

1,439,732

1,260,732

Annual Financial Report of 31 December 2021

Page | 8

Return on Equity: It is a measure of return on equity of the entity and is measured by the net profit / (loss)

after tax to the total equity. The amounts are used as presented in the Statement of Profit and Loss and the

Statement of Financial Position. For the closing years 2021 and 2020, the index is as follows:

GROUP €'000

31.12.2021

31.12.2020

Return on Equity =

Net Profit / (Loss)

113,915

14.09%

29,366

3.74%

Total Equity

808,316

784,534

COMPANY €'000

31.12.2021

31.12.2020

Return on Equity =

Net Profit / (Loss)

88,245

12.16%

16,954

2.29%

Total Equity

725,428

738,898

Pursuant to the 8.11.2021 issuance of the Common Bond Issue of EUR 250 million tradeable in the Athens Stock Exchange

in the Bonds Category/Main Market under ISIN: GRC281121BD8, the Group undertook the commitment of reporting the

following ratios at consolidated level. For reasons of transparency and uniformity the ratios are presented at company level

as well.

Net Debt to a-EBITDA ratio: Is the measure of the number of years that will take for the entity to repay the Net Debt if the

Net Debt and the a-EBITDA remain constant. Net Debt is the sum of “Loans and Borrowings” and “Lease Liabilities” as

reported in the Non-current liabilities and Current liabilities, reduced by the “Cash and cash equivalents” as reported in the

Financial Statements. For the fiscal year 2021 and 2020 stands as follows:

GROUP €'000

31.12.2021

31.12.2020

Net Debt / a-EBITDA

Net Debt

787,054

4.72

623,011

4.59

a-EBITDA

166,835

135,782

COMPANY €'000

31.12.2021

31.12.2020

Net Debt / a-EBITDA

Net Debt

656,703

5.78

509,208

5.70

a-EBITDA

113,602

89,325

Where Net Debt:

GROUP €'000

31.12.2021

31.12.2020

Net Debt

Non-Current Liabilities

Plus: Loans and Borrowings

662,111

452,706

Plus: Lease Liabilities

10,392

10,480

Current Liabilities

Plus: Loans and Borrowings

200,910

189,671

Plus: Lease Liabilities

4,785

3,992

(Less): Cash and cash equivalents

(91,144)

(33,838)

787,054

623,011

Annual Financial Report of 31 December 2021

Page | 9

COMPANY €'000

31.12.2021

31.12.2020

Net Debt

Non-Current Liabilities

Plus: Loans and Borrowings

599,191

382,339

Plus: Lease Liabilities

6,543

9,222

Current Liabilities

Plus: Loans and Borrowings

104,801

126,996

Plus: Lease Liabilities

3,412

3,278

(Less): Cash and cash equivalents

(57,242)

(12,627)

656,703

509,208

Total Liabilities to Total Equity ratio: Is the measure of leverage of an entity. For the fiscal year 2021 and 2020 stands as

follows:

GROUP €'000

31.12.2021

31.12.2020

Total Debt / Total Equity

Total Debt

1,422,425

1,80

1,073,787

1.37

Total Equity

808,316

784,534

COMPANY €'000

31.12.2021

31.12.2020

Total Debt / Total Equity

Total Debt

1,137,342

1,57

873,532

1.18

Total Equity

725,428

738,898

a-ΕΒΙΤDΑ to Net Finance Expenses: Is the measure of the financial expenses coverage. More specifically, Net Finance

Expenses is calculated by “Finance Costs” minus “Finance Income”, as reported in the Financial Statements. For the fiscal

year 2021 and 2020 stands as follows:

GROUP €'000

31.12.2021

31.12.2020

a-EBITDA / Net Finance Expenses

a-EBITDA

166,835

5.38

135,967

5.38

Net Finance Expenses

30,987

25,218

COMPANY €'000

31.12.2021

31.12.2020

a-EBITDA / Net Finance Expenses

a-EBITDA

113,602

4.74

89,325

4.70

Net Finance Expenses

23,987

19,014

Net Finance expenses:

GROUP €'000

31.12.2021

31.12.2020

Net Finance Expenses

Finance Costs

31,266

25,506

(Less): Finance Income

(279)

(288)

30,987

25,218

COMPANY €'000

31.12.2021

31.12.2020

Net Finance Expenses

Finance Costs

24,434

19,414

(Less): Finance Income

(446)

(400)

23,987

19,014

Annual Financial Report of 31 December 2021

Page | 10

EBITDA: It is the measure of profitability of the entity before taxes, financial, depreciation and amortization. It

is calculated by adjusting the depreciation and amortization to the operating profit, as this is reported in the

statement of profit and loss. For the period including the results of the absorbed after the transaction date for

the prior year comparatives, it was calculated as follows:

€ '000

GROUP

COMPANY

2021

2020

2021

2020

Operating profit / (loss)

146,909

59,421

98,554

40,192

Adjustments for:

+ Depreciation of tangible assets

65,667

60,057

44.086

39,632

+ Depreciation of right of use assets

3,003

2,458

1.686

1,659

+ Amortization

1,226

1,024

649

701

+ Depreciation of investment property

100

207

1.215

1,216

- Amortization of Grants

(1,593)

(1,757)

(1.202)

(1,221)

EBITDA

215,312

121,409

144,988

82,179

a – EBITDA: adjusted EBITDA is a measure of the profitability of the entity after adjustments for:

• Metal result

• Restructuring Costs

• Special Idle costs

• Impairment of fixed assets

• Impairment of Investments

• Profit / (Loss) of sales of fixed assets, investments if included in the operational results

• Other impairment

For the fiscal year:

€ '000

GROUP

COMPANY

2021

2020

2021

2020

EBITDA

215,312

121,409

144,988

82,179

Adjustments for:

+ Loss / - Profit from Metal Lag

(56,135)

9,016

(36,819)

2,672

+ Losses from Fixed assets write-offs or impairments

2,941

1,888

2,797

1,846

- Profit / + Loss from sales of Assets

558

(569)

(138)

(313)

+ Expenses for Covid-19 pandemic

4,159

4,038

2,774

2,941

a - EBITDA

166,835

135,782

113,602

89,325

Regarding the expenses for the treatment of the Covid-19 pandemic, the Group and the Company adjusted

expenses of EUR 4.2 million (2020: EUR 4.0 million) and EUR 2.8 million (2020: EUR 2.9 million) respectively for

the calculation of a-EBITDA. These expenses are directly linked to the pandemic and due to the special

circumstances caused and are not expected to reoccur after it subsides.

The metal results stems from:

1. The time period that runs between the invoicing of the purchase, holding time and metal processing

versus the invoicing of sales.

2. The effect of the beginning inventory (which is affected by the metal prices of prior periods) in the

cost of sales, from the valuation method which is the weighted average.

3. Specific contracts with customers with closed prices that end in exposure to metal prices fluctuations

between the period that the price was closed and the date that the sale took place.

Annual Financial Report of 31 December 2021

Page | 11

ELVALHALCOR and its subsidiaries use derivatives to reduce the effect of the fluctuation of metal prices.

However, there will always be a positive or negative effect in the result due to the safety stock that is held. The

calculation of the metal price lag as derived from the financial statements after the acquisition date can be

analysed as follows:

GROUP

COMPANY

31.12.2021

31.12.2020

31.12.2021

31.12.2020

€ '000

(Α) Value of Metal in Sales

2,225,743

1,460,594

1,385,188

921,455

(B) Value of Metal in Cost of Sales

(2,176,246)

(1,463,182)

(1,361,423)

(916,602)

6,638

(6,428)

13,054

(7,525)

(A+B+C) Metal Result in Gross Profit

56,135

(9,016)

36,819

(2,672)

3. Main risks and uncertainties

The Group is exposed to the following risks from the use of its financial instruments:

Credit risk

The Group and the Company exposure to credit risk is primarily affected by the features of each customer. The

demographic data of the Group’s clientele, including payment default risk characterizing the specific market

and the country in which customers are active, affect credit risk to a lesser extent since no geographical

concentration of credit risk is noticed. No client exceeds 10% of total sales (for the Group or Company), and,

consequently, the commercial risk is spread over a large number of clients. More specific, should be noted that

INTERNATIONAL TRADE S.A trades products of the Group to various foreign countries, with the delivery

provided directly from the production facilities of the Group to customers, the majority of them does not

represent 10% of total sales. ElvalHalcor’s transactions with INTERNATIONAL TRADE are approved by the Board of

Directors and are published to G.E.MI. (ΓΕΜΗ), pursuant to art. 99-101 of the Law L4548/2018.

Based on the credit policy adopted by the Board of Directors, each new customer is tested separately for

creditworthiness before normal payment terms are proposed. The creditworthiness test made by the Group

and the Company includes the examination of bank sources. Credit limits are set for each customer, which are

reviewed in accordance with current circumstances and the terms of sales and collections are readjusted, if

necessary. In principal, the credit limits of customers are set on the basis of the insurance limits received for

them from insurance companies and, subsequently, receivables are insured according to such limits.

When monitoring the credit risk of customers, the latter are grouped according to their credit characteristics,

the maturity characteristics of their receivables and any past problems of collectability they have shown. Trade

and other receivables include mainly wholesale customers of the Group and the Company. Customers

characterized as being of “high risk” are included in a special list of customers and future sales should be

collected in advance and approved by the Board of Directors. Depending on the background of the customer

and his properties, the Group and the Company demands collateral demand collateral securities or other

security (e.g. letters of guarantee) in order to secure its receivables, if possible.

Bearing in mind that there is no official definition of default, ElvalHalcor considers as default the occurrence of

one or both of the following events: i) The Company assumes that the counterparty is unlikely to fully recover

its obligation to the Company, unless the Company obtain measures, such as the liquidation of any collateral

provided in favor of the insurance company. ii) The counterparty is overdue for payment / fulfillment of its

obligation to the Company for a period of more than 30 days (provided that the terms of the credit have not

been changed by agreement of the Company). Any write-off is carried out following the completion of the legal

actions.

Annual Financial Report of 31 December 2021

Page | 12

The Group and the Company record impairment allowances that reflect its assessment of losses and expected

credit losses from customers, other receivables and investments in securities. This allowance mainly consists

of impairment losses of specific receivables that are estimated based on given circumstances that they will be

materialized though they have not been finalized yet, as well as an allowance for expected credit losses

according to the Group’s analysis which was formulated for the implementation of IFRS 9.

Investments

These items are classified by the Group pursuant to the purpose for which they were acquired. The

Management decides on the proper classification of the investment at the time of the acquisition and reviews

classification on each presentation date.

The Management estimates that there will be no payment default for such investments.

Guarantees

Group’s and the Company’s policy consists of not providing any financial guarantees unless the Board of

Directors decides so on an exceptional basis, and as considered in article 99-101 of law 4548/2018; The

guarantees provided by the Group do not pose a significant risk.

Liquidity risk

Liquidity risk is the inability of the Group to discharge its financial obligations when they mature. The approach

adopted by the Group to manage liquidity is to ensure, by holding the necessary cash and having adequate

credit limits from cooperating banks, that it will always have adequate liquidity in order to cover its obligations

when they mature, under normal or more difficult conditions, without there being unacceptable losses or its

reputation being jeopardized. It is noted that the Group held cash and cash equivalents on 31 December 2021,

which amounted to Euro 91.1 million and the Company Euro 57.2 million as well as approved but not utilized

lines of credit to cover current and medium-term liabilities. As far as investments are concerned, the Group

and the Company take new loans according to their needs (see note 22). Moreover, the Group communicates

with the banks to secure proper refinancing of loans that expire.

For the avoidance of liquidity risk, the Group and the Company makes a cash flow projection for one year while

preparing the annual budget as well as a monthly rolling projection for three months to ensure that it has

adequate cash to cover its operating needs, including the fulfilment of its financial obligations. This policy does

not take into account any impact of extreme conditions which cannot be foreseen.

Market risk

Market risk is the risk related to fluctuations in raw material prices, exchange rates and interest rates, which

affect the Group’s results or the value of its financial instruments. The purpose of risk management in respect

of market conditions is to control Group exposure to such risks in the context of acceptable parameters while

at the same time improving performance.

The Group enters into transactions that include derivative financial instruments so as to hedge a part of the

risks arising from market conditions.

Risk from the fluctuation of metal prices (aluminium, copper, zinc, other metals, gas)

The Group and the Company base both their purchases and sales on stock market prices/ indexes for the price

of copper and other metals used and incorporated in its products. In addition, the Company is exposed to risk

from the fluctuation of gas prices, as part of its production cost. The risk from metal prices and gas fluctuation

is covered by hedging instruments futures on (London Metal Exchange-LME) and Commodity Forward Start Swaps

(Title Transfer Facility - TTF) respectively. The Group, however, does not hedge the entire working stock of its

operation and, as a result, any drop-in metal prices may have a negative effect on its results through the

impairment of inventories.

Annual Financial Report of 31 December 2021

Page | 13

Exchange rate risk

The Group is exposed to foreign exchange risk in relation to the sales and purchases carried out and the loans

issued in a currency other than the functional currency of Group companies, which is mainly the Euro. The

currencies in which these transactions are held are mainly the Euro, the USD, the GBP and other currencies of

S/E Europe.

Over time, the Group and the Company hedge part of their estimated exposure to foreign currencies in relation

to the anticipated sales and purchases and the greatest part of receivables and liabilities in foreign currency.

The Group enters mainly into currency forward contracts with external counterparties so as to deal with the

risk of the exchange rates variation, which mainly expire within less than a year from the balance sheet date.

When deemed necessary, these contracts are renewed upon expiry. As the case may be, foreign exchange risk

may be hedged by taking out loans in the respective currencies.

Loan interest is denominated in the same currency with that of cash flows, which arises from the Group’s

operating activities and is mostly the Euro.

The investments of the Group in other subsidiaries are not hedged because these exchange positions are

considered to be long-term.

Interest rate risk

The Group finances its investments and its needs in working capital through bank and bond loans, thus interest

charges burden its results. Rising interest rates have a negative impact on results since borrowing costs for the

Group rise.

The Group and the Company may undertake loans issued at fixed rates for the reduction of the Interest rate

risk when it is deemed necessary.

Capital management

The Groups’ policy is to maintain a strong capital base to ensure investors’, creditors’ and market’s trust in the

Group and to allow Group activities to expand in the future. The Board of Directors monitors the return on

capital which is defined by the Group as net results divided by total equity save non-convertible preferential

shares and minority interests. The Board of Directors also monitors the level of dividends distributed to holders

of common shares.

The Board of Directors tries to maintain equilibrium between higher returns that would be feasible through

higher borrowing levels and the advantages and security offered by a strong and robust capital structure.

The Group does not have a specific plan for own shares purchase.

There were no changes in the approach adopted by the Group in how capital was managed during the financial

year.

Cash Flow Hedging

The Group and the Company base both their purchases and sales on metals exchange prices for the price of

copper, aluminium and other metals used and contained in their products and may invoice customers distinctly,

but also to proceed to purchases from suppliers, regarding the quantities of metal required for their operation.

Consequently, for each sale of a product or other inventory item that contains metal, at the point of time the

LME price is agreed with the customer, a long position is opened on the LME for the corresponding quantity

contained using derivatives, and for each order of raw materials from suppliers, at the point of time the LME

price is agreed with the suppliers, a short position is taken on the LME for the corresponding quantity using

derivatives, where and if these daily purchases and sales cannot be offset by each other (back-to-back). Thus,

the Group and the Company cover purchases and sales with cash-flow hedging operations, ensuring that the

fluctuation of the price of metals in the international markets will not affect the operating cash flows and

consequently the regular, sustainable and optimal operation of the Group and the Company.

Annual Financial Report of 31 December 2021

Page | 14

More specific, for cash flows hedges related to natural gas, the Group and the Company conduct Commodity

Forward Start Swaps to hedge the risk of fluctuations in natural gas prices, that is embedded in future gas

purchases. Also, the Company, from its operations, is exposed to fluctuations in gas prices as a component of

production costs. The risk of natural gas price fluctuations is covered by cash flow hedging using Commodity

Forward Start Swaps derivative contracts traded on the Title Transfer Facility (TTF). In particular, the Company

assumes a long position for predetermined quantities of natural gas that will be consumed in its future

production. Upon the commencement of the hedging transaction, the Group and the Company shall document

the hedging relationship between the hedged item and the hedging instrument in relation to risk management

and the strategy for future gas transactions. The Group and the Company document the assessment of the

effectiveness of the hedging relationships in terms of offsetting changes in the fair value of cash flows of the

hedged items, both at the inception of the hedging relationship and on an ongoing basis.

Macro-economic environment

Covid 19

The evolvement of the Covid-19 pandemic has had an adverse impact on global economic conditions.

ElvalHalcor and its subsidiaries responded swiftly to the pandemic, prioritising the health and safety of all

employees, suppliers and customers, and social distancing measures were successfully implemented without

disrupting production activity, according to the recommendations of health authorities and international health

protocols. For the additional measures and means of personal protection, according to the recommendation

of health committees, the Group and the Company undertook expenses of Euro 4.2 million (2020: Euro 4.0

million) and Euro 2.8 million (Euro 2.9 million) respectively, which negatively affected the profitability.

In addition, the slowdown of the world economic outlook is expected to negatively affect a number of

companies operating in different segments. The Group and the Company increased the posting of the

“impairment loss on receivables and contract assets” for the expected credit losses (IFRS 9) following the

increase of the risk factors, hence impacting financial results negatively, in order to include the new short-term

conditions of the global market. It is noteworthy that the sales of ElvalHalcor are made to companies with long

term commercial ties and presence in the local market, and they do not face any risks deriving from the

macroeconomic environment. In spite of that, the Management constantly evaluates the situation and its

possible ramifications in order to secure that all necessary measures and actions have been taken for the

mitigation of any impact to the Group’s and the Company’s activities.

In spite of the lockdowns in the global economy, the materialization of the investment programmes was

completed with minor delays, and the unhindered operation of the production facilities throughout the

pandemic provided an advantage over many European producers. The availability and the prices of the basic

raw materials follow the international market and are not affected by the domestic situation in any country.

The extensive measures of the lockdowns in many economies reduced temporarily the availability of scrap of

copper, while the traffic of raw materials was disrupted for a short period in certain major shipping ports.

ElvalHalcor has access to multiple sources for raw materials, and acted proactively by increasing the safety

stock in critical materials handling any supply chain irregularities, if any observed.

US anti-dumping investigation

ElvalHalcor participated in the investigation of US Department of Commerce as a Greek producer of aluminium

sheets and cooperated with the authorities, with continuous transmission of information for the development

of investigations. On 02.03.2021 the US Department of Commerce calculated a final dumping margin of 0%, for

imports from ElvalHalcor.

Following issuance of the final determination by the DoC, the investigation concerning ElvalHalcor’s imports is

terminated without imposition of an antidumping duty and the US International Trade Commission (ITC) will

not make an injury determination with respect to imports from Greece.

Annual Financial Report of 31 December 2021

Page | 15

Considering the above and the fact that for most of the other participants in the investigations a dumping

margin has been calculated, and in some cases a high margin

, the Company and the Group reasonably believe

that the decision accommodates the continuation and expansion of the activity in the US market.

Disclosure for conflicts in the region of Ukraine

Regarding the developments in Ukraine region, the Group’s sales for 2021 corresponding to 0.9% of its total

turnover to the Russian market and 0.6% to the Ukrainian market, while at company level sales reached to 1%

to the Russian market and 0.6% in the Ukrainian market. Both markets are not significant, and quantities are

easily absorbed by other markets where there is demand for the Group’s and the Company’s products. It is

worth to be noted that the Group and the Company procure raw materials from the Russian market, mainly

primary aluminium, but this supplier represents 5% -7% of the value of the total purchases and can be replaced

by others without significant impact in the smooth and uninterrupted operation of the Company and the

Group. Finally, it is noted that the consolidated ETEM SYSTEMS LLC, based in Ukraine is a trading company with

total assets of 274 thousand euros, turnover of 1,054 thousand euros and net profit after taxes of 30 thousand

euros for the closing year 2021. Therefore and taking into account the size of the consolidated entity, it is

reasonably estimated that they may not affect the size of the Group or the Company.

4. Outlook and targets for 2022

For 2022, and although the messages from the development of the pandemic seem optimistic, ELVALHALCOR

is closely following these developments and is ready to react to any temporary fluctuations in demand.

Increased energy prices and raw materials from inflationary pressures will occupy the world market for 2022,

especially after the developments in the region of Ukraine. It is worth to be noted that in most of the sub-

industries in which the company operates, metal prices are fully passed through, while the Company and its

subsidiaries use a cash flow hedging strategy to deal with fluctuations between purchases and sales.

Respectively, the Company uses hedging strategy techniques for a portion of its energy cost in respect of long-

term product sales contracts, while demand for most products remains strong, allowing the increased energy

costs to be passed to sales. The possible stabilisation of metal prices at increased levels will affect working

capital, but the company has sufficient credit lines to meet its needs of increased production and sales

programs. Also, it will exploit the most of its strategic advantages, such as the customer-centric philosophy,

investments, production capacity and high flexibility that enable it to take advantage of any future opportunity.

In particular, the Aluminium segment after the completion of the Euro 150 million investment plan and

responding to the growing demand for aluminium products from its customers, is in the process of

implementing an investment that includes a 6-high aluminium cold rolling mill for aluminium segment, and the

expansion of its existing infrastructure of lacquering and pre-lubricating lines at the Company's facilities in

Oinofyta with the order of a new fully-automated lacquering line. Both of the investments are part of the initial

stage of a wider investment programme of Euro 100 million, which will be carried out in the course of the next

two years for production equipment and R&D infrastructure. The new investments are a confirmation of the

commitment of the aluminium segment for sustainable, innovative solutions for the packing for food and

beverages industries and fortify the Company’s position and the Group among the leading aluminium rolling

industries in the world with significant contribution in the value chain of aluminium as part of the cyclical

economy.

In regards to the Copper segment, demand for 2022 is expected to fluctuate in satisfactory levels, which will

help with the absorption of the production capacity of the copper and copper alloy rolling division of the

subsidiary in Bulgaria, Sofia Med, which is growing fast by gaining market shares. At the same time, the copper

tube division is expected to remain near full capacity level by testing the limits of the production capacity.

Moreover, it is worth noting that the investment program of the joint venture of Nedzink, with the purpose of

increasing the production of titanium-zinc, following the completion of its production facilities in 2021, it is

expected to commence during 2022, when the first positive signal of the improvements in cost and capacity

will affect its financial results of the related party.

https://www.trade.gov/faq/final-determinations-antidumping-and-countervailing-duty-investigations-common-alloy-aluminum

Annual Financial Report of 31 December 2021

Page | 16

Finally, the Group and the Company retain their long term expansion strategy through the increase of exports

in Europe and in other markets outside Europe, as well as the production capacity and the market shares in

products with dynamic prospects for development in the context of circular economy and sustainable

development.

5. Transactions with related parties

Transactions with affiliated parties mainly concern purchases, sales and processing of copper and zinc products

(finished and semi-finished). Through such transactions, the companies take advantage of the Group's size and

attain economies of scale.

Transactions between affiliated parties within the meaning of IAS 24 are broken down as follows:

Transactions of the parent company with subsidiaries (amounts in thousands Euro)

COMPANY

Sales of goods,

services, fix assets

Purchases of goods,

services, fix assets

Receivables

Payables

SYMETAL SA

148,659

20,926

1,728

SOFIA MED AD

50,648

10,383

21,159

ELVAL COLOUR SA

25,352

1,076

10,635

FITCO SA *

13,499

2,902

VIOMAL SA

9,622

115

2,479

VEPAL SA

348

33,019

9,876

ANOXAL SA

841

10,495

4,639

TECHOR ROMANIA SA

EPIRUS METALWORKS SA

464

3,809

199

CABLEL WIRES SA

246

TECHOR SA

110

UACJ Elval Consulting (Associate)

ETEM COMMERCIAL SA

17,967

5,106

31,812

ETEM BG SA

164

154

ETEM ALBANIA SA

ETEM SCG DOO

505

156

TOTAL

268,316

84,324

76,568

10,151

*For the first six months till the abortion from ElvalHalcor.

Sofia Med SA purchases from ELVALHALCOR raw materials and semi-finished products of copper and copper

alloys, depending on its needs, as well as finished products which distributes to the Bulgarian market. In

addition, ELVALHALCOR provides technical, administrative and commercial support services to Sofia Med.

Respectively, ELVALHALCOR buys from Sofia Med raw materials, semi-finished products according to its needs,

as well as finished products which distributes to the Greek market.

ELVALHALCOR sells semi-finished products that Symetal uses as raw materials and purchases aluminium scrap

from the production process of Symetal, which is re-used as raw material (re-casting). ELVALHALCOR,

occasionally, sells spare parts and other materials to Symetal and provides other supportive services.

ELVALHALCOR S.A. sells final aluminium products to Viomal, which constitute raw material for the latter and

Viomal sells back to ELVALHALCOR the returns from its production process.

Elval Colour S.A. buys final products from ELVALHALCOR, which are used as raw material by the latter and

ELVALHALCOR processes Elval Colour’s materials.

Annual Financial Report of 31 December 2021

Page | 17

Vepal S.A. processes ELVALHALCOR’s products and delivers semi-finished products. ELVALHALCOR sells raw

materials to Vepal and also provides supporting administrative services to the latter.

Anoxal S.A., also, processes ELVALHALCOR’s raw materials and ELVALHALCOR provides administrative support

to Anoxal. Furthermore, Anoxal purchases from ELVALHALCOR other materials (spare parts and other

consumables) for its production process.

Epirus Metalworks purchases raw materials from ELVALHALCOR, proceed with the process and then sales

finished products to ELVALHALCOR. ELVALHALCOR provides administrative services to Epirus Metalworks.

ETEM COMMERCIAL SA rents industrial facilities from ELVALHALCOR, purchases aluminium billets and sells in

its turn aluminium scrap from its production process to ELVALHALCOR.

Transactions of the parent company with other affiliated companies (amounts in thousands of Euro)

Company

Sales of Goods,

Services and Assets

Purchases of Goods,

Services and Assets

Receivables

Payables

CENERGY GROUP

939

27,050

375

122

STEELMET GROUP

17,198

2,465

INTERNATIONAL TRADE

487,375

36,137

METAL AGENCIES LTD

77,892

304

6,102

TEPROMKC GMBH

86,650

1,934

6,953

211

REYNOLDS CUIVRE SA

65,629

773

7,195

166

ETEM Aluminium Extrusions SA

33,947

16,051

11,094

1,017

ETEM Automotive Bulgaria SA

2,124

865

UEHEM

49,836

148

2,052

STEELMET ROMANIA SA

15,292

322

148

724

GENECOS SA

5,391

402

1,039

BRIDGNORTH LTD

13,567

556

10,675

402

NEDZINK B.V.

172

5,778

200

BASE METAL TICARET VE SANAYI A.S.

853

338

ANAMET SA

696

597

299

ALURAME SPA

1,529

117

HC ISITMA

185

METALIGN S.A.

477

SIDMA S.A

346

13,348

737

TEKA SYSTEMS SA

8,550

2,426

ELKEME SA

217

1,502

467

VIEXAL SA

3,824

224

VIENER SA

2,650

333

SIDENOR INDUSTRIAL S.A

426

1,896

SOVEL SA

23,755

4,271

OTHER

345

1,856

1,403

276

ΣΥΝΟΛΟ

862,535

102,332

95,812

11,055

Cenergy Group purchases raw materials from ELVALHALCOR according to their needs. In its turn, it sells copper

scrap to ELVALHALCOR from the products returned during its production process.

Steelmet Group provides ELVALHALCOR with administration and organization services.

INTERNATIONAL TRADE S.A trades products of the Group to various foreign countries, with the delivery

provided directly from the production facilities of the Group to customers, the majority of them does not

represent 10% of total sales. ElvalHalcor’s transactions with INTERNATIONAL TRADE are approved by the Board

of Directors and are published to G.E.MI. (ΓΕΜΗ), pursuant to art. 99-101 of the Law L4548/2018.

Metal Agencies LTD acts as a merchant - central distributor of ELVALHALCOR Group in Great Britain.

TEPROMKC Gmbh trades ELVALHALCOR’s products in the German market.

Annual Financial Report of 31 December 2021

Page | 18

Steelmet Romania trades ELVALHALCOR’s products in the Romanian market.

Teka Systems S.A. undertakes to carry out certain industrial constructions for ELVALHALCOR and provides

consulting services in IT issues and SAP support and upgrade.

Anamet S.A. provides ELVALHALCOR with considerable quantities of copper and brass scrap.

Viexal SA provides ELVALHALCOR with travelling services.

Tepro Metall AG trades (through its subsidiary MKC) ELVALHALCOR products and represents the latter in the

German market.

Genecos, as well as its subsidiary Reynolds Cuivre sell ELVALHALCOR’s products and represent ELVALHALCOR

in the French market.

ETEM Gestamp Aluminium Extrusions purchases from ELVALHALCOR aluminium billets and sells in its turn

aluminium scrap from its production process to ELVALHALCOR.

Η GESTAMP Etem Automotive Bulgaria sells aluminium scrap from ELVALHALCOR’s production process.

UACJ ELVAL HEAT EXCHANGER MATERIALS purchases from ELVALHALCOR finished aluminium products and

distributes them to international markets.

Transactions of ELVALHALCOR’s Group with other affiliated companies (amounts in thousands of Euro)

Company

Sales of Goods,

Services and

Assets

Purchases of

Goods,

Services and

Assets

Receivables

Payables

CENERGY GROUP

7,085

75,251

1,913

2,512

STEELMET GROUP

19,182

2,910

INTERNATIONAL TRADE

652,340

51,393

METAL AGENCIES LTD

125,704

375

8,403

TEPROMKC GMBH

147,931

4,126

11,451

558

REYNOLDS CUIVRE SA

91,961

1,276

9,425

194

STOMANA IDUSTRY SA

853

304

365

STEELMET ROMANIA SA

24,620

656

1,018

811

GENECOS SA

9,674

523

1,584

BRIDGNORTH LTD

13,567

670

10,675

402

UEHEM (UACJ ELVAL HEAT

EXCHANGER MATERIALS GmbH)

51,217

148

2,052

NEDZINK B.V.

370

5,857

219

ELKEME SA

235

1,951

584

ANAMET ΑΕ

960

782

374

ETEM Aluminium Extrusions SA

34,204

18,875

11,157

1,463

ALURAME SPA

2,359

220

ETEM Automotive Bulgaria SA

246

2,124

865

SOVEL SA

23,755

4,271

VIEXAL SA

4,527

316

VIENER SA

14,832

2,291

2,796

SIDMA SA

346

14,051

918

TEKA SYSTEMS SA

11,729

363

3,787

BASE METAL TICARET VE SANAYI

A.S.

247

1,238

383

OTHER

967

5,754

3,428

1,016

TOTAL

1,186,339

180,774

126,172

20,215

Annual Financial Report of 31 December 2021

Page | 19

Fees of Executives and Board members (amounts in thousands Euro)

The table below sets out the fees paid to executives and members of the Board of Directors:

Group Company

Total fees of Board members 1,812 585

Total fees of management executives 10,630 4,772

The company considers as management executives the General Manager of each division and subsidiary and

all others that report directly to them.

Annual Financial Report of 31 December 2021

Page | 20

6. Subsequent events

1. On 13.01.2022 ELVALHALCOR participated in the share capital increase of the joint venture Nedzink BV,

with Euro 1.5 million, maintaining its share to 50%. On 28.02.2022, the amount of Euro 1.25 million from

the loan provided to Nedzink BV, was converted to capital.

2. In regards to the developing events in Ukraine, the Group during 2021 had a 0.9% of the Turnover

directed to Russia and 0,6% directed to Ukraine, while at company level the sales stood at 1% for the

market of Russia and 0.6% for the Ukrainian market. Both markets are not significant in size and the

respective quantities can be easily be replaced by other markets where there is demand for the products

of the Group and the Company. It is worth noting that he Group and the Company purchase raw

materials from the Russian market, mostly primary aluminium, but the specific vendor accounts for the

5%-7% of the required materials and can be easily be replaced by others without any repercussions to

the orderly and unhindered operation of the Company and the Group. Finally, it is noted that the entity

ΕΤΕΜ SYSTEMS LLC, based in Ukraine, is as commercial company with total assets amounting to Euro

274 thousand, turnover of Euro 1,054 thousand and net profit after tax of Euro 30 thousand for the year

2021. As a consequence, and considering the financial figures of the said entity, it is reasonably

estimated that the aforementioned financial figures cannot affect the consolidated figures of the Group

or the Company, while the said entity can restart operations swiftly after the turbulence ends.

Annual Financial Report of 31 December 2021

Page | 21

ELVALHALCOR– Non-financial reporting

Business model

The ELVALHALCOR Hellenic Copper and Aluminium Industry S.A. (ElvalHalcor) business model aims to create

value for all stakeholders, shareholders, customers, employees, suppliers and society as a whole.

ElvalHalcor operates in the aluminium and copper segments, boasting experience and know-how exceeding

80 years and offering innovative solutions of high added value perfectly suited to the modern requirements

of its international customers. ElvalHalcor's success is derived from its commercial export orientation,

customer-focused philosophy and continuous innovation with a strong focus on research and technology.

Following its continuous strategic investments in research and development of new technologies, the

Company currently owns state-of-the-art production facilities and is capable of creating new and innovative

products and solutions, thus accomplishing its goal for continuous innovation at both domestic and

international level.

Annual Financial Report of 31 December 2021

Page | 22

Material issues (Materiality assessment)

ElvalHalcor's material issues evaluation process is based on the GRI global standards for sustainability

reporting, as well as SASB industry specific standards. During the preparation of the 2021 Sustainable

Development Report, the Company took into account and integrated new sectoral and global emerging

trends and scaled and grouped the material issues in terms of their double materiality. ElvalHalcor evaluated

its material issues and how they impact the economy, the environment and society, as well as their impact

on the Company's business value and operation (dual materiality), while incorporating the evaluation data

and information that it received from its stakeholders.

ElvalHalcor's "most important material issues" are presented in the table below and by ESG thematic pillar (E

- Environment, S - Social, G - Governance).

ElvalHalcor’s material issues

Relevant SDG's

Relevant target

(SDG's target)

Climate change

9.4

Circular economy - Promote aluminium

and copper recycling

9.4, 12.5

Waste and wastewater management

12.5

Energy efficiency and GHG emissions

7.2

Air emissions

9.4, 9.4.1

Water use

6.4, 6.3

Occupational Health and Safety

8.8

Employee training and development

Supply chain responsibility

9.3, 12.1

Human and equal rights, diversity and inclusion

4.3, 8.5

Corporate Governance and Business Ethics

16.5

Risk and crisis management

Information security & personal data privacy

Creating shared value

Supporting local communities

9.3

Research, development, and innovation

9.5

Sustainability enabling products

Digitalisation

SDG's: The 17 Global Sustainable Development Goals adopted in September 2015 by the 193 UN Member States (2030 Agenda) on achieving a sustainable

future for all: https://sdgs.un.org/goals

The table above shows how ElvalHalcor's important material issues correlate with the global goals of sustainable development that are directly related to

the activities and practices of the Company that contribute to the achievement of the goals.

In ElvalHalcor's 2021 Sustainability Report, an extensive presentation of the important issues, their key

performance indicators and their relevance to the U.N. Sustainable Development Goals (agenda 2030) are

included. ElvalHalcor's Sustainability Report will be available (end of May 2022) on the corporate website:

https://www.elvalhalcor.com/el/sustainability/reporting/overview/.

Impact of Covid-19 pandemic on non-financial matters

The pandemic posed a great challenge not only at a professional level but also on a personal level. ElvalHalcor

and its subsidiaries acted in a responsible manner supporting, except its workforce, society as a whole as well,

through an extensive list of donations in medical equipment as well as protective gear for medical centres

and hospitals in need.

Annual Financial Report of 31 December 2021

Page | 23

Since the beginning of the epidemiological crisis, we have faithfully followed all the instructions and

prevention measures recommended by the State and the competent bodies while taking additional measures

and initiatives to limit the spread of the virus based on the following three guidelines:

• Taking precautionary measures to protect the health and safety of our people and partners

• Supporting the National Health System and caring for our society

• Ensuring business continuity.

ElvalHalcor launched a series of emergency actions that included risk analysis and risk mitigation measures

related to the health of employees and their families while closely monitoring the impact of Covid-19 on the

supply chain.

Throughout 2021, over 104.000 PCR tests were performed on ElvalHalcor's workforce (and its subsidiaries)

in regular intervals in order to allow for early detection and quarantine of positive cases as well as their close

contacts. This approach allowed for minimal spread of Covid-19 within company premises and also helped

the workforce protect their families and close social network due to the early warning from the mandatory

proactive testing. As a result, all companies were able to continue their operations smoothly and without

interruptions throughout 2021.

Measures to mitigate potential supply chain risk were put in place in order to ascertain business continuity

(orders for critical materials placed in advance, alternative suppliers identified, safety stocks were

increased). As a result, no interruption of regular operation or delays in projects under

construction/commissioning was experienced throughout 2021.

To date, the Company and its subsidiaries have managed to take the measures to cope with the difficult

pandemic crisis and to operate smoothly without compromising any business continuity. We are optimistic

that in 2022- with the implementation of solutions created by the international community we will be able

to overcome this crisis, and normalcy will soon return to all of us. Until then, we remain on standby and will

take all the necessary measures to protect our people, our partners, supporting the local community and

society at large.

Taxonomy-related disclosures

Reporting requirements include the eligibility percentage of the Turnover, CAPEX and OPEX for the companies

that are already included in the Sustainable Finance E.U. law. Article 10(1) of the Disclosures Delegated Act

explicitly requires that in the first year of implementation, non-financial undertakings should disclose "the

proportion of Taxonomy-eligible and Taxonomy non-eligible economic activities in their total turnover,

capital and operating expenditure".

We engage in secondary aluminium production (3.8), through the separate aluminium companies within the

aluminium segment of ElvalHalcor. Below are the necessary KPIs for the eligible companies of Aluminium,

based on Article 8 reporting requirements.

Aluminium segment

Aluminium Environmentally Sustainable - Eligible activities (Aluminium rolling division of ElvalHalcor,

Anoxal)

% of turnover: 60.82%

Turnover (EUR million): 815

% CAPEX: 11.76%

CAPEX (EUR million): 18

% OPEX: 23.12%

OPEX (EUR million): 9

Aluminium Non – Eligible activities (Aluminium rolling division of ElvalHalcor, Anoxal)

% of turnover: 39.18%

Turnover (EUR million): 525

% CAPEX: 88.24%

CAPEX (EUR million): 135

% OPEX: 76.88%

OPEX (EUR million): 29

Annual Financial Report of 31 December 2021

Page | 24

Turnover KPI

Definition

The proportion of Taxonomy-eligible economic activities has been calculated as the part of turnover derived

from activity 3.8 - secondary aluminium production (numerator) divided by the turnover of aluminium

segment (denominator) for financial year 2021.

For further details on our turnover accounting policy please refer to page 86 of our Annual Financial Report

2021.

Reconciliation

Turnover of aluminium segment can be reconciled to our consolidated financial statements, in “Operating

segments” section, on page 89 of our Annual Financial Report 2021.

Capex KPI

Definition

The Capex KPI is defined as Taxonomy-eligible Capex (numerator) divided by aluminium segment Capex

(denominator).

The numerator consists of Taxonomy-eligible Capex related to assets or processes that are associated with

activity 3.8 - secondary aluminium production.

We consider that assets and processes are associated with Taxonomy-eligible economic activities when they

are essential components necessary to execute an economic activity. Consequently, all Capex invested into

machinery for secondary aluminium production have been included in the numerator of the Capex KPI.

More specifically, secondary aluminium Capex includes Capex related to the production of aluminium from

secondary raw materials (including scrap and metal-bearing materials) and the remelting and alloying

processes.

The denominator consists of Aluminium segment additions to tangible and intangible fixed assets during

financial year 2021, before depreciation, amortisation and any re-measurements, including those resulting

from revaluations and impairments. It includes acquisitions of tangible fixed assets (IAS 16), intangible fixed

assets (IAS 38) and investment properties (IAS 40). Additions resulting from business combinations are also

included. Goodwill is not included in Capex, as it is not defined as an intangible asset in accordance with IAS

38. For further details on our accounting policies regarding Capex please refer to page 82 of our Annual

Financial Report 2021.

Reconciliation

Capex of aluminium segment can be reconciled to our consolidated financial statements, in “Operating

segments” section, on page 89 of our Annual Financial Report 2021.

Opex KPI

Definition

The Opex KPI is defined as Taxonomy-eligible Opex (numerator) divided by total aluminium segment Opex

(denominator).

The numerator consists of Taxonomy-eligible Opex related to assets or processes that are associated with

activity 3.8 - secondary aluminium production.

Annual Financial Report of 31 December 2021

Page | 25

Total Opex (denominator) consists of direct non-capitalised costs that relate to research and development,

building renovation measures, short-term lease, maintenance and repair, and any other direct expenditures

relating to the day-to-day servicing of assets of property, plant and equipment. This includes:

• Research and development expenditure recognised as an expense during the reporting period. Τhis

includes all non-capitalised expenditure that is directly attributable to research or development activities.

• The volume of non-capitalised leases was determined in accordance with IFRS 16 and includes

expenses for short-term leases and low-value leases.

• Maintenance and repair and other direct expenditures relating to the day-to-day servicing of assets

of property, plant and equipment were determined based on the maintenance and repair costs allocated to

our internal cost centers. The related cost items constitute a portion of “Cost of sales” line item of our

Aluminium segment income statement (please refer to “Operating segments” section, on page 89 of our

Annual Financial Report 2021).

This also includes building renovation measures. In general, this includes staff costs, costs for services, and

material costs for daily servicing as well as for regular and unplanned maintenance and repair measures.

These costs are directly allocated to our PP&E including an appropriate allocation of overhead costs.

This does not include expenditures relating to the day-to-day operation of PP&E such as raw materials, cost

of employees operating the machine, electricity or fluids that are necessary to operate PP&E.

Direct costs for training and other human resources adaptation needs are excluded from the denominator

and the numerator. This is because Annex I to Art. 8 Delegated Act lists these costs only for the numerator

which does not allow a mathematically meaningful calculation of the Opex KPI.

This section is included for the first time in the section “Non-Financial Reporting”, pursuant to Regulation (EU)

2020/852. The information contained follow the requirements of the Regulation, and the Group and the

Company will follow the developments and they will adapt their approach accordingly.

Management of Sustainability matters

The Company has put in place mechanisms and procedures to highlight and manage sustainability issues

focusing on occupational safety, respect for the environment and society as well as its financial and

economically viable operations. Management commitment and the management framework of responsible

operation matters are reflected on the Sustainability Policy established and implemented by ElvalHalcor.

Seeking to ensure its continuous improvement in relevant matters, the Company sets specific goals and

monitors their progress on an annual basis, based on the relevant key performance indicators it has

developed. To attain these KPI's and goals, the Company prepares and implements adequate plans and

actions of responsible operation.

Policies and Systems

Wishing to reinforce its sound operation driven by Sustainable Development, ElvalHalcor has established

specific policies and puts into practice adequate management systems and procedures that uphold

responsible operation and define the way in which the Company's goals are achieved. More specifically, the

Company has established and implements, among others, the following policies and codes:

• Internal Rules of Operation

• Sustainability Policy

• Health and Safety Policy

• Environmental, Energy and Climate Change Policy

• Business Ethics and Anti-Corruption Policy

• Labour and Human Rights Policy

• Code of Conduct and Business Ethics

• Supplier Code of Conduct.

Annual Financial Report of 31 December 2021

Page | 26

Integrated management of ElvalHalcor's important matters is ensured through the Management Systems

implemented by the Company. More specifically, ElvalHalcor implements the following certified systems:

• Environmental Management System (ISO 14001:2015).

• Energy Management System (ISO 50001:2018).

• Occupational Health and Safety Management System (ISO 45001:2018).

All production facilities of the Company have put in place the above certified Management Systems.

New certifications - ASI Performance Standard and ASI Chain of Custody Standard (CoC)

ElvalHalcor was the first company in Greece that in 2019 joined forces with the Aluminium Stewardship

Initiative - ASI (https://aluminium-stewardship.org/), together with the other leading aluminium production

and processing companies, organisations and social bodies that are also its members.

To date, ElvalHalcor is the first and only company in Greece, which has been certified

according to the model of sustainable development in the aluminium supply chain, the

ASI Performance Standard. ElvalHalcor's certification, according to this standard, was

successfully completed in July 2020 and concerns the entire production activity of the

aluminium rolling sector. In addition, in 2021, the aluminium rolling division of

ElvalHalcor, was successfully completed the certification, according to the ASI

Chain of Custody Standard (CoC).

The first certification confirms the Company's excellent performance in the whole

range that governs the responsible production of aluminium, specifically in the

three ESG pillars:

Certification pillars

Certification performance in ESG issues

Environmental protection

and biodiversity

• Greenhouse gas emissions and other atmospheric emissions

• Water emissions and waste management

• Responsible water usage

• Protection of biodiversity and prevention of the introduction and spread

of invasive species

Social responsibility

• Protecting human and workers' rights

• Supporting local communities and taking responsible action towards the

community

• Promoting safety and health at work (employees, co-workers and visitors)

and making a commitment to continuous improvement

Good corporate governance

• Implementing policies aimed at good, fair, lawful and ethical governance

towards employees, partners and society

• Application of responsible procurement and aluminium production

methods

The ASI CoC certification allows ElvalHalcor to offer its customers ASI-certified aluminium products,

manufactured from material sourced and processed within the responsible supply chains that are certified

by the Aluminium Stewardship Initiative. This certification confirms ElvalHalcor's commitment to sustainable

development and strengthens its ability to offer aluminium products, ensuring that they originate from

material that has been sourced and processed responsibly, in conformance with the criteria set out by the

ASI standards, in every stage of their manufacturing process.

About main production subsidiaries

This Non-Financial Reporting includes a respective update on the main production subsidiaries that are

consolidated. Specifically with respect to the production subsidiaries of the aluminium segment: Symetal S.A.,

Vepal S.A., Elval Colour S.A., Anoxal S.A., Viomal S.A., Etem S.A., and the copper segment: Sofia Med SA, Cablel

Wires S.A. and Epirus Metalworks SA. Subsidiaries are also presented in the Sustainability Report in

compliance with the Sustainability Reporting Guidelines of Global Reporting Initiative (GRI-Standards).

Annual Financial Report of 31 December 2021

Page | 27

ElvalHalcor's subsidiaries have established and apply respective policies which strictly abide by the principles

of the Company's policies, with the Management of each subsidiary being responsible for their

implementation. Meanwhile, ElvalHalcor's subsidiaries have their own internal controls, procedures and

management systems with respect to sustainable development matters and monitor their respective

performance through the relevant indicators, the results of which are presented in this report. The entirety

(100%) of ElvalHalcor production companies under the scope of this report are certified with the

environmental Management System ISO 14001:2015 and the Occupational Health and Safety Management

System ISO 45001:2018, while 50% of the companies under the scope are certified with the Energy

Management System 50001:2015.

The following sections present the results of the policies and procedures implemented by ElvalHalcor and cite

the relevant reports on performance in risk management in the relevant issues (presentation of relevant non-

financial indicators) of both the Company and its main production subsidiaries. It is noted that due to the

disparate production activity, the different geographical location of the companies, as well as the different

degree of material issues that each company may face, it was deemed as necessary to present the important

issues that are common to ElvalHalcor and its main production subsidiaries.

Environmental matters

Environmental protection is at the top of the Company's list of priorities. ElvalHalcor cultivates environmental

responsibility as an integral part of its corporate philosophy, having integrated in its strategy the responsible

management of all environmental matters associated with its activities.

Management's strong commitment in this field is reflected in the Environmental Policy

(www.elvalhalcor.com, section «Sustainable Development/Environment). Management takes steps to

implement good practices aiming at environmental protection and management of any environmental

impacts arising from the Company's operation. The Company operates in accordance with the applicable

environmental laws (applicable National and European laws). Wishing to reduce its environmental footprint

on an ongoing basis with concrete actions, ElvalHalcor:

• implements an Environmental Management System (ISO 14001:2015) in all its production facilities

aiming at the integrated;

• management of its environmental matters;

• implements targeted environmental management plans (e.g. energy-saving plans, actions and initiatives

to reduce air emissions, etc.);

• seeks the rational use of natural resources and operates in accordance with the principles of circular

economy, when possible;

• implements an integrated waste management system (which focuses primarily on waste management

according to the appropriate hierarchy and on the adoption of good practices aiming to prevent their

generation);

• makes continuous investments in environmental protection infrastructure;

• focuses on continuous training and awareness-raising of its employees and partners in environmental

matters.

Climate change and air emissions management

Climate change is a global environmental challenge, the effects of which affect many sectors. Therefore,

ElvalHalcor aims to continuously reduce carbon emissions through implementing specific procedures and

initiatives.

The Company's carbon footprint is due to a greater extent to indirect emissions (generated from the

electricity supplier) and to a lesser extent to direct emissions (from the combustion of hydrocarbons). In

addition, ElvalHalcor and its subsidiaries have improved their carbon footprint through a combination of

energy efficiency and energy-saving measures. The improvement of the emissions factor of energy mixtures

(indirect emissions) in combination with the energy-saving actions have led to a gradual improvement of the

overall carbon footprint.

Annual Financial Report of 31 December 2021

Page | 28

ElvalHalcor (consolidated date)

Year

2019

2020

2021

Total Carbon Emissions

(tn CO

/tn products)

(1)

0.798

0.736

0.702

(1) Based on the "location based" method according to the GHG Protocol Directive. Total C0

emissions are equal to the sum of direct and indirect

emissions (tn CO

/tn of products).

Note: For the calculation of the direct CO

emissions for the years 2020, 2021 the coefficients of the year 2020 have been used by the European Residual

Mixes 2020, AIB. As the numbers of the above indices may change according to changes in the reference indices, the final emission indicators for 2021 will

be published in ElvalHalcor's Sustainable Development Report.

Energy consumption and saving

With respect to energy consumption, its main pursuit is to reduce its energy footprint, whenever possible,

and ensure its increasingly efficient use. Concurrently, through the certified Energy Management System (ISO

50001:2018), the Company aims at the integrated management of energy matters and seeks to develop a

continuous improvement culture. ElvalHalcor monitors, records the gas emissions and ensures full

compliance with the relevant legislation.

ElvalHalcor and its subsidiaries purchase electricity from the main energy suppliers in the countries in which

they operate as none of the companies has its own power generation.

Water and wastewater management

The two critical issues regarding water management are the issues of adequate treatment of wastewater and

the water intensity, especially in water stressed areas. The Company takes all necessary steps to ensure its

efficient use and limit its consumption in compliance with its environmental policy. At the same time,

whenever possible, reuse practices are applied.

As part of the long-term environmental footprint improvement regarding both ElvalHalcor and its

subsidiaries, continuous efforts are being made to reduce water consumption. The increase of the total

production in both segments contributed to the improvement of the water consumption intensity for 2021.

ElvalHalcor (consolidated data)

Year

2019

2020

2021

Water consumption intensity

/tn products)

2.85

2.81

2.73

With regards to ElvalHalcor's and its subsidiaries' water waste treatment, in 2021, all wastewater fell within

the established limits of being discharged to specific water body recipients or sewerage networks, resulting

in a 100% compliance rate.

Waste management and circular economy

ElvalHalcor has an integrated waste management system, covering all production stages right up to final

waste disposal. Our approach to waste management focuses on techniques for waste volume reduction and

reuse, either within the plant or in licensed external partners. ElvalHalcor applies Best Available Waste

Management Techniques and, as a consequence, most of the waste generated is led to recycling and energy

recovery.

Although waste generation intensity varies significantly depending on the production process, the waste

intensity per company has remained at similar levels in the past three years with fluctuations due to the

product mix and shipments of waste accumulated over time that may affect the waste intensity for a single

year. However, the portion of the generated waste that is sent for recycling or recovery is steadily increasing

in the majority of the companies supporting the transformation to a circular economy. In 2021, almost 96%

of ElvalHalcor waste was recycled and reused.

Annual Financial Report of 31 December 2021

Page | 29

ElvalHalcor (consolidated data)

Year

2019

2020

2021

Waste generation (Kg/tn product)

0.18

0.17

Waste recovered and recycled (%)

(1)

97%

94%

96%

(1)

Waste recovered and recycled measured versus total waste generated.

Using scrap and promoting aluminium and copper recycling

The Company's primary raw materials are aluminium and copper. As the benefits (reduction in energy

consumption, greenhouse gas emissions and water use) of scrap use are significant (in relation to the use of

primary metals), we focus on practices that maximise the efficient use of raw materials and scrap.

ElvalHalcor promotes and actively implements the principles of the circular economy, constantly increasing

in the production of new products the use of aluminium and copper that comes from collecting products at

the end of their life cycle.

Labour and social issues

This section presents all the issues that the Company recognises as being important and concerns its human

resources and the interaction with the local community in which ElvalHalcor and its main subsidiaries operate.

ElvalHalcor recognises the determined contribution of their people in Company's successful business

performance and future growth. In recognition of this, the Company invests materially and systematically in

its people. ElvalHalcor's management places particular emphasis on human resources development and

strives to maintain a working environment based on equal opportunities that respects each employee and

rewards hard work. ElvalHalcor's human resources practices and policies focuses on empowering employees,

strengthening leadership skills and promoting talent. Steadily oriented to human values, the Company strives

to implement responsible management practices with regard to human resources. The Company focus on

material issues such as:

• ensuring its employees and associates' health and safety;

• creating a rewarding work environment, respecting human rights and diversity;

• providing equal opportunities for all employees;

• applying objective evaluation systems;

• highlighting and exploiting all employees' skills;

• training and developing employees on an ongoing basis.

In 2021, ElvalHalcor's human resources amounted to 3,885 employees (data 31/12). The ratio between male

and female workers is approximately 89% to 11% respectively. The percentage of female employees appears

small because female professionals are not traditionally attracted to industry. As a result, the percentage of

women in positions of responsibility (Managers and senior executives) is low, amounting to about 13%

(percentage of the total number of the Company's executive staff). The participation rate of women in human

resources varies, based on the geographical location of the companies. Specifically in the copper segment

subsidiaries, the index is higher, due to the subsidiary Sofia Med which is located in Bulgaria (attributed to

the cultural acceptance of women in positions related to industry).

Labour KPI's (ElvalHalcor consolidated data)

Year

2019

2020

2021

Employee turnover

(1)

8.5%

6.6%

14%

% of women in total workforce

10.4%

10,8%

11.2%

% of women in management

11.1%

12.2%

12.9%

(1)

Τurnover rate: Percentage of employees who left the company (due to resignation, dismissal, retirement or death) in total company's workforce (31/12

data).

Annual Financial Report of 31 December 2021

Page | 30

It is our constant commitment to maintain a culture that encourages development and makes the most of

the knowledge and skills of our people. We consistently invest in our people, focusing on continuing

education, designing and implementing high value-added training programs. During 2021, the Company

proceeded with redesigning its existing training programs so they can take place through e-learning

platforms, due to the special conditions created by Covid-19 and the restrictive measures which were

implemented for everyone's health and safety.

ElvalHalcor consolidated data

Year

2018

2019

2020

Total training hours per employee

(2)

12.2

7.8

9.4

(2)

Total training hours implemented (and concerning Company employees) during the year for the total number of Company employees (data 31/12).

Remuneration and benefits policy and systems have been developed with a view to recruiting, employing and

retaining experienced personnel with the necessary capabilities and skills which lead to optimisation of

individual and, by extension, overall performance. The remuneration of each employee reflects the

educational background, experience, responsibility as well as the value/importance of the post in the labour

market. In addition, as part of its employee reward and satisfaction system, the Company provides a number

of additional benefits.

Occupational Health and Safety

Ensuring the Health and Safety (H&S) of our employees, our partners and third parties is a firm priority and

commitment of ElvalHalcor. This view is highlighted through the H&S Policy established and implemented by

the Company, thus clearly reflecting Management commitment in this field.

Company Management is instantly notified of any issue relating to H&S and takes steps to ensure seamless

implementation of the policy. This policy is defined by Management, is based on cooperation and

involvement of all personnel and is binding on each employee and partner. The Company fully complies with

the relevant laws and regulations with respect to working conditions and occupational H&S and focuses on

the implementation of preventive measures and actions to avoid any incidents at work.

The goal of «zero accidents» remains the Company's top priority. For this reason, the Company makes

substantial and systematic investments in measures aiming at the continuous improvement of working

conditions, and focusing on prevention and infrastructures reinforcing occupational safety. The Company's

approach to the management of occupational H&S matters includes:

• Implementation of a H&S Management System (ISO 45001:2018) in all its premises with the involvement

of all employees and administration.

• Continuous investments in infrastructure projects to reinforce safety at work (zero access).

• Behavioural audits in order to create a «safety climate».

• In-depth investigation and recording of all incidents, as well as near misses by implementing

improvement measures aiming to reduce accidents.

• Employee targeted training and awareness raising so as to create a safety culture.

ElvalHalcor and its main production subsidiaries in an effort to improve their risk capacity realisation, develop

detailed risk assessments by conducting a systematic hazard identification associated risks evaluation,

facilitating subsequently the implementation of reasonable control measures. Emphasis is also given in

performing accurate incidents analysis to ensure there is a robust framework in place which provides for a

systematic approach to incident reporting, management and investigation, thereby enabling effective

corrective and preventive actions to be set.

ElvalHalcor and its main production subsidiaries implement internationally applicable and measurable

indicators to monitor and evaluate performance in the field of Occupational Health and Safety.

We recognize that there is room for improvement and that much remains to be done in order to create

a safer work environment. We strive to implement targeted programs related to health and safety at work

and continue to work methodically in this area in order to achieve our goal of "zero accidents".

Annual Financial Report of 31 December 2021

Page | 31

Health and safety KPI's

ElvalHalcor consolidated data

Year

2018

2019

2020

Lost time incident rate (LTIR)

(1)

6.7

5.8

7.1

Severity rate (SR)

(2)

194

134

174

# fatalities

(1)

LTIR: Lost time incident rate (number of LTI incidents per million working hours)

(2)

S.R.: Severity rate (number of lost workdays per million working hours)

Supporting local communities

ElvalHalcor's (and its subsidiaries) growth and operation is inextricably linked to its local communities. The

Company wishes to have its business activities interact in a positive and constructive manner with the

communities in which it operates, contribute to the overall economic development of Greece and benefit

local communities by creating jobs and offering business opportunities. It is worth mentioning that more than

55% of ElvalHalcor total workforce originates from local communities (broader region of Viotia and Evia, as

well as the regions of the North Attica: Avlona, Malakasa, Oropos, Chalkoutsi). In addition, the Company (and

its subsidiaries) has a long tradition of fostering local entrepreneurship as it seeks to cooperate, when

possible, with local suppliers.

As a Company operating responsibly, ElvalHalcor provides its support on an annual basis to a number of

bodies, organisations and associations through various sponsorships while also supporting and promoting the

voluntary activities of its employees.

Through its operations, ElvalHalcor and its subsidiaries generate multiple benefits for the society. In addition

to the payment of salaries and other benefits to its employees, the Company pays the State the corresponding

taxes and levies and makes continuous investments and payments to the collaborating suppliers of materials

and services. Thus, the overall positive impact of the Company on both local and broader communities is

important.

Responsible supply chain management

ElvalHalcor selects and treats its suppliers in a responsible manner. Having built long-standing partnerships

and trust in its relationships with its customers and partners, the Company seeks to collaborate with suppliers

showing respect for the environment and implementing responsible practices. Seeking to promote the

principles of sustainable development across the supply chain, ElvalHalcor prepared a «Supplier Code of

Conduct». ElvalHalcor communicates this Code to its suppliers and contractors (existing and new ones), who

should be aware of and adopt the responsible practices applied by the Company in the context of Sustainable

Development.

The Code describes the Company's expectations from its supply chain (suppliers and partners) in terms of

responsible operation (environmental protection, occupational health and safety, labour practices, ethics and

integrity, respect for competitiveness, merit-based advancement, equal opportunities, safeguard of human

rights, etc.). The last revision of the Code took place in 2021.

Within the framework of the certified Management Systems (ISO 9001, ISO 45001, ISO 14001, ISO 50001),

ElvalHalcor implements supplier evaluation processes. The Company's procurement policy applies a strategy

aiming to boost the local economy, offering business opportunities and employment to local suppliers. When

evaluating and selecting suppliers, local origin is a criterion factored in.

Annual Financial Report of 31 December 2021

Page | 32

Human rights

With respect to human rights and acting responsibly toward its people, the Company implements a human resources

management policy based on equal opportunities without any discrimination on the basis of gender, nationality, religious

belief, age or educational background. ElvalHalcor opposes child labour and condemns all forms of forced and compulsory

labour. In addition, the Company condemns and does not tolerate any behaviours that could lead to discrimination,

unequal treatment, bullying or moral harassment, gestures and verbal or physical threats.

As a result of the control policies, procedures and mechanisms put in place, during 2021 like also in previous years, no

incident of child or forced labour was identified, and no incident related to violation of human rights has taken place.

Anti-corruption and bribery-related issues

ElvalHalcor implements an integrated framework of corporate governance (relevant details are given in the

section «Corporate Governance Declaration» of this report), which aims to ensure transparent, proper and

effective management of the Company, which leads to business and economic development in the long run.

In addition, ElvalHalcor's Code of Conduct and Business Ethics, Supplier Code of Conduct and Business Ethics

and Anti-Corruption Policy reflect the Company's commitment and views on transparency, anti-corruption

and anti-bribery issues. Exposure to the risk of corruption is systematically monitored. The Company is fully

opposed to any type of corruption and is committed to operating in an ethical and responsible manner. The

Company takes all necessary preventive measures and implements procedures and controls in order to

ensure the combating of corruption cases. As a result of the Company's practices and policies, during 2021

(as in previous years), no incident of corruption or bribery was recorded or reported. In addition, there were

no fines paid due to settlements for unethical business practices or corruption matters.

Information security & personal data privacy

ElvalHalcor respects the personal data protection and undertakes the appropriate measures according to the

provisions of the General Data Protection Regulation 679/2016 of the European Union and the national

implementation law 4624/2019. Aiming the attunement with the international standards and best practices,

it adapted a Personal Data Protection Policy and established strict procedures for the protection of personal

data throughout its spectrum of activities. Moreover, the provision of "by design and by default"

technological means, the formation of procedures, business activities and information systems, but also

fostering a data protection culture is our primary concern and a continuous improvement goal. During 2021,

there were no incidents of data privacy breaches.

Key non-financial risks

The Company operates in an economic and social environment characterised by various risks, financial and

others (all financial risks are laid down in the section «Risks and Uncertainties» of this report). Within this

framework, the Company has established procedures to control and manage non-financial risks. The main

categories of non-financial risks facing the Company are environmental risks and risks related to occupational

H&S. Managing these risks is considered as very important by the Management of the Company since they

have the risk of directly or indirectly affecting the smooth operation of the Company.

Managing the non-financial risks is considered to be a very critical task by the companies' management as

these risks have the potential to create a direct or indirect impact on the companies' continuous operation

as well as to create future liabilities. The companies have their own skilled personnel and consultants

managing these matters, and they implement certified management systems ISO 14001:2015, ISO

45001:2018, as well as the energy management system ISO 50001:2018, thus providing an additional

management tool for all related risks. The management systems are the pillars for taking the proper

preventive steps, specific plans, and actions, and provide the continuous improvement culture necessary to

ensure improving performance and risk management. The risks associated with the non-financial matters

reported above are described below.

Annual Financial Report of 31 December 2021

Page | 33

Environment

The major risks related to environmental issues are climate change and water supply and management. These

risks are also critical to the supply chain of companies (ElvalHalcor and its subsidiaries) as the raw materials

used by the companies carry more than 80% of the environmental footprint of the final products, while in

certain cases, the footprint is close to 90% (aluminium rolled and extruded products).

Climate change

The companies (ElvalHalcor and its subsidiaries) consider that climate is an area with a material impact not

only in respect of financial materiality (negative impact on Business segments Aluminium) but also from an

environmental and social perspective (negative impact to climate, hence to the environment and society).

The financial materiality stems from the fact that the companies have transition as well as physical risks.

Transition risks relate to risks arising from the transition to a low carbon economy such as policies that:

• require demanding energy efficiency measures,

• impose carbon pricing mechanisms that intend to increase carbon price, thus, increase cost of

electricity

• impose carbon border adjustments that can disrupt supply chains as well as cause retributions from

other countries where customers are currently located.

Physical risks relate to risks associated with long chronic effects such as rising sea levels and reduced

freshwater availability.

The risk mitigation measures taken by the companies are, among others, the following:

• early policy trend identification;

• close cooperation with national and European federations for proper representation of the matters

faced by ElvalHalcor and the subsidiaries;

• development of action plans and long term targets for investments in energy-efficient equipment

and carbon abatement measures;

• procurement of electricity from producers of clean, renewable energy;

• increase of capacity for utilisation of secondary raw materials instead of primary; and

• proper budget management practices that incorporate projected carbon costs.

From an environmental and social perspective, the companies (ElvalHalcor and its subsidiaries) directly emit

greenhouse gases in the atmosphere due to their routine production operations and indirectly through the

consumption of electricity. ElvalHalcor and its subsidiary Sofia Med are currently in the European Trading

Scheme, and these companies have made a series of investments in the past 15 years for carbon emissions

reduction.

Upstream activities include raw materials extraction, such as aluminium and copper amount to significant

emissions to the environment. Selection of raw materials suppliers is critical to identify areas of improvement

and is considered the highest contributor to the overall emissions of the subsidiaries' products. As mentioned

earlier, the carbon footprint attributed to upstream activities amount to over 80% in most cases. ElvalHalcor

is in the process of identifying and evaluating different suppliers and their potential exposure to higher carbon

costs as the increasing cost of carbon will eventually affect their competitiveness.

Water management

Water management-related risks include the availability of freshwater for production purposes and the

quality of wastewater discharged to water receptors. Certain companies are relatively water-intensive as

shown in the performance and KPIs section. These companies treat the water supply risk as a business

continuity issue that can ultimately have a financial materiality (negative impact on the company). The risk is

mainly mitigated through continuous efforts to improve the water footprint of the companies and have

multiple sources of water, so there are alternative sources of supply. As for the quality of wastewater

discharge, companies have made the appropriate investments in modern equipment in order to have the

ability to meet and comply with very strict discharge limits.

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Social and labour issues

The major risks related to social and labour matters are the occupational health and safety of the labour force

and employee matters. With regards to occupational health and safety risks, ElvalHalcor and its subsidiaries

have management systems in place following a comprehensive approach for improvement, which is

translated into equipment upgrading, implementation of management principles (safety audits, guidelines,

work instructions, etc.), the establishment of a targeted safety training program and the direct involvement

of management. The companies' management have a clear understanding of the importance of providing a

safe working environment to the labour force and how vital it is to continuously strive for improvement, as

this is fundamental for good labour relations and business performance. Employee related risks entail

potential violations of equal treatment and statutory working hours as social action by personnel that may

lead to operation interruption risks. These risks are mitigated by the companies through a comprehensive

employee Code of Conduct and Business Ethics, personnel evaluation and training, and regular internal

audits.

Human rights

The major risks related to human rights are related to the supply chain of the companies provided that many

suppliers are not located in Europe or North America. ElvalHalcor and its subsidiaries are in the process of

developing a proper and comprehensive supplier evaluation management system in order to ascertain that

all major suppliers meet certain sustainability standards such as standards in minimum environmental

performance and compliance, worker safety, labour conditions, human rights and business ethics.

Anti-bribery and corruption

The risks related to anti-bribery and corruption lies in the failure to conduct business/operations ethically and

comply with the laws and regulations in the jurisdictions in which ElvalHalcor and its subsidiaries operate. To

prevent and mitigate these risks, ElvalHalcor ensures that the Sustainability Policy is properly implemented

and that its employees are aware of ElvalHalcor's corporate values and related anti-corruption practices. The

internal audit function is responsible for monitoring and reporting timely and properly any related deviation

or misconduct. Simultaneously, subsidiaries separately organise training courses and communication actions

in order to increase awareness and encourage compliance.

NOTE:

The non-financial KPI's for 2021 which are presented in this report are compliant with the Sustainability Reporting

Guidelines of Global Reporting Initiative (GRI-Standards). These KPI's were chosen strictly on the basis of their relevance

to the Company's business (according to the materiality analysis conducted by the Company). Details on the performance

in terms of sustainable development, and the actions of the Company's responsible operation will be set forth in the 2021

Sustainability Report of ElvalHalcor (May 2022). The Sustainable Development Report is an important tool as it reflects

the way in which the Company responds to major issues and to the expectations of all its stakeholders. All the ElvalHalcor's

Sustainability Reports (according to the GRI Guidelines) are available on the Company's website

http://www.elvalhalcor.com/sustainability.

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BOARD OF DIRECTORS EXPLANATORY REPORT

(Article 4(7) and (8) of Law 3556/2007)

1. Structure of share capital

The Company’s share capital following the 22.11.2017 decision of the General Meetings and the 131569/30-11-2017

decision of the Ministry of Economy and Development, amounts to Euro 146,344,218.54 divided in 375,241,586 common,

dematerialized, bearer shares with nominal value of Euro 0.39 each. All the shares are listed in the Athens Stock Exchange,

included in the “Basic Resources” sector and the “Metal Fabricating” Subsector. Pursuant to the decisions of the General

Meetings of 30.09.2019 and the 106722/21.10.2019 decision of the Ministry of Development and Investments (ΑΔΑ:

97ΔΔ465ΧΙ8-9Υ0), the Company’s shares converted to dematerialized, registered with voting rights, in compliance with

articles 40 and 184 of the L.4548/2018, as in force.

According to the Company’s Articles of Associations, the rights and obligations of shareholders are as follows:

• Right to obtain a dividend from the Company's annual profits. The dividend to which each share is entitled shall be

paid to the shareholder within two (2) months from the date of approval by the General Meeting of the financial

statements. The right to collect a divided shall be deleted after the elapse of five (5) years from the end of the year

in which the General Meeting approved distribution.

• Pre-emptive right in any share capital increase, which is not carried out by contribution in kind and in any case of

issuance of bonds convertible into shares.

• Right to participate and vote in the General Meeting of Shareholders.

• Subject to the provisions on the community, pledge and usufruct, securities are only issued and transferred

accompanied by the total of the rights they include and any separate disposal of rights is prohibited. Exceptionally,

the profit sharing, interest or capital payments, as well as other independent rights generated by securities, are freely

transferred, upon condition that the relevant securities terms of issuance do not provide for otherwise.

• Shareholder liability is limited to the nominal value of each share they hold.

2. Restrictions on the transfer of shares of the Company

The transfer of the shares of the Company is made as provided by Law and there exist no restrictions in the transfer

pursuant to its Articles of Association.

3. Major direct or indirect holdings within the meaning of Articles 9 to 11 of Law 3556/2007

The major holdings (over 5%) known on 31 December 2021 were as follows:

• VIOHALCO SA/NV: 84,78% of voting rights.

4. Shares granting special rights of control

There are no shares in the Company granting το their holders special rights of control.

5. Restrictions on voting rights

The Company’s Articles of Association contain no restrictions on voting rights deriving from its shares.

6. Agreements between Company’s shareholders

The Company is not aware of the existence of agreements between its shareholders which entail restrictions on the

transfer of its shares or the exercise of voting rights deriving from its shares.

7. Rules on the appointment and replacement of Board members and amendment of the Articles of

Association

The rules contained in the Company’s Articles of Association on appointment and replacement of members of the Board

of Directors and amendment of the provisions of the latter are not different from those contained in L. 4548/2018.

8. Powers of the Board of Directors to issue new shares or purchase own shares

• Article 6 § 1 of the Company’s Articles of Association states that for the capital increase of the Company’s capital

the General Shareholders Meeting is required with an increased quorum and majority of the shareholders, according to

the provisions of article 27 § 1 and 2 of the Company’s Articles of Association (regular increase), unless the increase takes

Annual Financial Report of 31 December 2021

Page | 36

place according to article 24 of the L.4548/2018 as in force, under the provisions of paragraph 2 of article 6 of the

Company’s Articles of Association. In any case of increase the decision of the competent body is subject to publicity.

• According to paragraph 2 of Article 6 of the Company’s Articles of Association: a) for a period of no longer that

five years of the incorporation of the Company, the Board of Directors has the right, with its decision, taken by a 2/3

majority quorum to increase the share capital in part or in total with the issuance of new shares, for an amount that may

not exceed three-times the initial capital. b) The aforementioned power can be granted to the Board of Directors with

decision of the Shareholders’ General Meeting, for time period no longer than five years. In this case, the capital can be

increased by an amount no greater than three times the amount of the capital, which exists at the date when the power

to capital increase was granted to the Board of Directors. c) The said power of the Board of Directors can be renewed

with decision of the Shareholders’ General Meeting for a period no longer than five years for every renewal granted. Each

renewal applies from the expiry of the term of the previous. The decisions of the General Meeting for the grant or renewal

of the capital increase power to the Board of Directors are subject to publicity. d) For a time period not exceeding five

years from the incorporation of the company, the General Meeting may, by its decision, adopted by simple quorum and

majority, increase the capital, wholly or partially, by the issue of new shares, in total up to eight-times the initial capital.

• The Board of Directors may acquire own shares in implementation of a decision of the General Meeting taken

under Article 49 of L. 4548/2018, as in force.

9. Major agreements which take effect have been amended or expire in the case of change in control

The bank loans of both the Company and ELVALHALCOR Group, taken out fully by Banks and set out in Note 22 of the

Annual Financial Report include clauses of change in control granting lenders the right to early terminate them.

Furthermore, the Company (pursuant to the decision of its Board of Directors of 05.11.2021, by authorization and in

execution of the resolution of the extraordinary General Meeting of its shareholders of 05.11.2021) has issues an ordinary

bond loan of a total principal amount of €250.000.000, divided into 250.000 dematerialised, ordinary bonds of nominal

value of €1.000 each, listed for negotiation in the category of Fixed Income Titles of the Regulated Market of the Athens

Exchange, offered by a public offer and the negotiation of which started on 17.11.2021 (“Bond Loan”). According to the

Program (clause 9.4) of the Bond Loan, in case of, among others, occurrence of Notification of Change of Control (as

defined in the said Program, i.e. notification of the Company to the investor community, on the basis of the provisions of

Law 3556/2007, in relation with (a) failure to keep the direct or indirect participation of Viohalco in the Company by a

percentage higher than fifty percent (50%) of the shares and voting rights, or (b) loss by Viohalco of the control of the

Company), each Bondholder shall have, under the other relevant terms and conditions provided in the above Program of

the Bond Loan, the right to demand from the Company the early repayment of all or part of the Bonds held by them (Put

Option).

There are no other significant agreements which take effect, have been amended or expire in the case of change in control

of the Company.

10. Agreements with Board of Directors members or Company’s staff

There are no agreements between the Company and members of the Board of Directors or staff which provide for the

payment of remuneration specifically in the case of resignation or dismissal without just cause or termination of service

or employment.

Annual Financial Report of 31 December 2021

Page | 37

CORPORATE GOVERNANCE STATEMENT

Rules of Operation – Corporate Governance Code

On July 17, 2020, Law 4706/2020 was published in the Official Gazette A '136 / 17-07-2020 ("Corporate governance of

public limited companies, modern capital market, incorporation into Greek legislation of Directive (EU) 2017/828 of the

European Parliament and the Measures to implement Regulation (EU) 2017/1131 and other provisions"), the provisions

of articles 1 - 24 of which, in accordance with article 92 par. 3 thereof, entered into force twelve (12) months after

publication in the Government Gazette, i.e. on 17.07.2021, unless otherwise specified in the individual provisions. This

law changed the current corporate governance legislation and introduced new provisions.

The Company, responding to the new legislative framework, while respecting the existing one as provided by Law

4449/2017 and Law 4548/2018, proceeded, based on the decision of its Board of Directors dated 12.07.2021, to update,

revise, amend and replacement of the (internal) Rules of Operation for its adaptation to the provisions of Law 4706/2020.

The said Rules of Operation of the company include, in particular, the organizational structure of the Company, its Units

and Committees, their object, the policies and procedures applied by the Company, the characteristics of the Company's

Internal Control System (BCC) etc., while a summary of the Regulation has been published on the Company's website

https://www.elvalhalcor.com/investor-relations/corporate-governance/rules-of-operation, in accordance with the

provisions of article 14 par. 2 point b) of Law 4706/2020.

Also, the Company, based on the above decision of its Board of Directors, decided to adopt and implement the Greek

Corporate Governance Code issued in June 2021 by the Hellenic Corporate Governance Council (HGCC), as recognized by

the Board of Directors of the Committee Capital Market during its 916

/7.6.2021 meeting (see press release of the

Capital Market Commission of 07.06.2021), as a National Authority of Recognized Validity for the issuance of a Corporate

Governance Code, according to the provisions of law 4706/20120 and no. 2/905/3.3.2021 Decision of the Board of

Directors of the Hellenic Capital Market Commission (hereinafter the "Code"), which is available on the internet at the

following link:

https://www.esed.org.gr/documents/20121/62611/Hellenic+Corporate+Governance+Code+2021.pdf/f1a35fbf-1126-

ca0e-160c-dbdc55c7198a?t=1626350753153.

The Company decided, as above, its compliance with the Code, with deviations from paragraphs 1.14, 2.3.4, 3.1.5, 3.3.4,

3.3.8, 3.3.12, regarding the Managing Director, and 1.17, 2.2.15, 2.2.21, 2.3.1, 2.4.7, 3.3.3, 3.3.4, 3.3.5, 3.3.8, 8.4 and 8.5

of what, according to the Code, relate to “Special Practices” Governed by the Comply or Explain principle. According to

the decision of the Board of Directors dated 15.03.2022, these deviations are justified (article 152 par. 1 per. B) Law

4548/2018) and are explained as follows:

− Regarding the Special Practices of par. 1.14, 2.3.4, 3.1.5, 3.3.4, 3.3.8 and 3.3.12 of the Code: These Special Practices

concern the Managing Director. By decision of the Ordinary General Meeting of Shareholders of the Company of

24.05.2021, the Articles of Association (article 13 par. 1) of the Company were amended and the possibility of electing

one or more Managing Directors by the Board of Directors of the Company was provided, defining at the same time their

responsibilities. The current Board of Directors of the Company elected by the Ordinary General Meeting of Shareholders

of the Company of 24.05.2021, has not appointed a Managing Director (whose appointment is not mandatory under law),

and has assigned specific powers of management and representation of the Company to one or more persons, members

of the Board of Directors (authorized Directors) or not, reserving otherwise to the Board of Directors itself the

management and representation of the Company collectively. Therefore, the corresponding deviations from the above

Special Practices exist, as long as the Board of Directors has not elected a Managing Director. According to the current,

updated with Law 4706/2020, Rules of Operation of the Company, in the absence of a Managing Director, the

responsibilities provided for by the Managing Director according to Law 4706/2020 (e.g. a person, to whom

administratively reports the Head of the Internal Audit Unit) are exercised by the Vice President of the Board of Directors

of the Company who is an executive member. It is therefore considered that there is no risk from this deviation.

− Regarding the Special Practice of par. 1.17 (meeting calendar and annual action plan of the Board of Directors): The

Company, based on the decision of its Board of Directors dated 15.03.2022, approved and adopted a meeting calendar

and annual action plan for the current year 2022 and, therefore, complies with this Special Practice and there is no

deviation from it.

− Regarding the Special Practice of par. 2.2.15 (diversity criteria for senior senior executives with specific gender

representation goals, as well as timetables for achieving them): In accordance with the Company’s Suitability Policy, the

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Page | 38

Company applies diversity policy in order to promote an appropriate level of differentiation in the Board of Directors and

a diverse group of members. Through the accumulation of a wide range of qualifications and skills in the selection of the

members of the Board of Directors, the variety of views and experiences is ensured in order to make the right decisions.

The Suitability Policy is included / referred to in the diversity policy, to ensure that it has been taken into account when

appointing new members of the Board. Adequate gender representation of 25% of all members of the Board of Directors

is explicitly provided, and based on the current fifteen-member Board of Directors the minimum number of women or

men is three (3) and no exclusion is applied due to gender, race, color, ethnic or social origin, religion or belief, property,

birth, disability, age or sexual orientation. The Company elaborates and investigates the terms and conditions of further

specialization of these diversity criteria and the relevant objectives and schedule, the finalization of which, due to the

scope and nature of the Company's activities, is estimated to require additional time from the leaked adoption of the

Code to date. It is estimated that there is no risk from this deviation, as long as it exists.

− Regarding the Special Practice of par. 2.2.21 - 2.2.23 (on the election of the Chairman of the Board of Directors from

among the independent non-executive members, otherwise the appointment of one of the independent non-executive

members, either as vice chairman (Senior Independent Director), in case the President is elected by the non-executive

members): The current Board of Directors of the Company, of which the Chairman is a non-executive member, and the

Vice-Chairman is an executive member, was elected by the Ordinary General Meeting of Shareholders of the Company

on 24.05.2021, i.e. before the entry into force of Law 4706/2020 (17.07.2021). The capacity of the Chairman as a non-

executive member is in accordance with the provision of par. 1 of article 8 of Law 4706/2018 which stipulates that the

Chairman of the Board of Directors is a non-executive member. In view of the next election of a new Board of Directors

of the Company, after the end of the current term, the Company will examine, whether it is appropriate and under what

conditions it is possible, to comply with the above Special Practice. It is estimated that there is no risk from this deviation,

for as long as it exists.

− Regarding the Special Practice of par. 2.3.1 - 2.3.3 (regarding a framework for filling positions and succession of the

members of the Board of Directors): The Company is in the process of elaborating and designing a framework / plan for

filling positions and succession of its members Board of Directors, for adoption and implementation, to comply with the

above Special Practice, which is estimated to be completed within the current year. Until then, according to the

consistently followed practice of the Company in all cases of replacement of missing members of its Board of Directors,

for the executive members of the Board of Directors who are in charge of the management and the achievement of the

Company's purpose and are mainly Company executives with a paid employment relationship, the Human Resources

Divisions of the Company ensure the permanent availability of candidates, from the existing executive staff of the

Company, to fill the positions of the executive members of the Board of Directors. As for the succession of the

independent, in particular, members of the Board of Directors and the members of the Company's Committees (which

are composed by a majority of independent members) the Remuneration and Nomination Committee of the Company

takes care of the identification and evaluation, according to principles of the approved Suitability Policy of the Company,

of persons as possibly available as suitable candidates for members of the Board of Directors, whenever there is a

question of replacement of existing members of the Board of Directors, in combination with the periodic evaluation of

the fulfillment of suitability requirements and, above all, independence. It is estimated that there is no risk from this

deviation, for as long as it exists, according to the above.

− Regarding the Special Practice of par. 2.4.7 (regarding the fact that the member of the remuneration committee

who will be appointed as its Chairman, must have served in the committee as a member for at least one year): The

Chairman of the Remuneration and Nomination Committee of the Company (appointed by the Board of Directors of the

Company on 26.05.2021 and formed in a body on 28.05.2021, after the election of the existing Board of Directors of the

Company by the Ordinary General Meeting of its shareholders on 24.05.2021) is an independent non-executive member

of the Board of Directors, elected for the first time as a member of the Board of Directors of the Company. Therefore, he

has not served on the Remuneration and Nomination Committee of the Company as a member for at least one year

before his appointment as Chairman. The same applies to all existing independent non-executive members of the Board

of Directors, none of whom has served in the Remuneration and Nomination Committee of the Company as a member

for at least one year. Therefore, based on the existing composition of the Board of Directors, it is not possible to comply

with the above Special Practice. It is estimated that there is no risk from this deviation, for as long as it exists.

− Regarding the Special Practice of par. 3.3.3, 3.3.4, 3.3.5 and 3.3.8 (regarding the annual evaluation of the Board of

Directors), it is noted that the planned evaluation of the Board of Directors on an annual basis mainly concerns Boards of

Directors with a term of office longer than one year. In the case of the Company, the relevant discrepancy does not exist

in principle, but may occur, for practical reasons, due to the fact that the term of the Board of Directors of the Company,

Annual Financial Report of 31 December 2021

Page | 39

according to article 11 par. 1 of its articles of association, is annual (extended automatically until the expiration of the

deadline within which the next Ordinary General Meeting must convene and until the relevant decision is taken, not

exceeding two years). Therefore, with the lapse of one year from the election of the Board of Directors of the Company,

when it is foreseen that its evaluation take place according to the above Special Practice, as a rule, its term expires, and

in any case if a new Board of Directors is elected. In this case, that assessment becomes, in principle, devoid of purpose.

It is estimated that in this case there is no risk of this deviation, as a new Board of Directors will be elected, following the

evaluation process of the candidates to be elected members from the beginning, in accordance with the Company

Suitability Policy. If in any way the term of the Board of Directors of the Company is extended beyond one year, the

Company will arrange for the annual evaluation of the Board of Directors, in accordance with the above Special Practice.

In the present case, from the election of the existing Board of Directors by the Ordinary General Meeting of its

shareholders on 24.05.2021 until the date of the present, less than one year has lapsed. Therefore, upon the completion

of one year from the election of the current Board of Directors and depending on whether his term of office will expire

or be extended as mentioned above, the Company will consider whether it is appropriate for such an evaluation to take

place.

− Regarding the Special Practice of par. 8.4, 8.5 (regarding the use of a communication platform to ensure a

constructive dialogue between the Company and its shareholders): The Company, under the responsibility of the

Shareholder Service Unit and Corporate Announcements, uses basically the corporate website to provide shareholders

with adequate and equal access to information and generally to communicate with them on a regular basis. The Company

is in the process of reforming and upgrading the content and in general environment of its website and exploring the

existing available tools, possibly by enriching it with a communication platform, in order to find the best possible technical

solution for the empowerment of its communication with its shareholders and its absolute compliance with the above

Special Practice.

The Company will examine periodically on whether the above deviations continue to serve the corporate interest and will

proceed to the necessary adjustments.

Main features of the Internal Audit System in relation to the Process of Preparation of Financial Statements and

financial reports.

i. Description of the main features and components of the Internal Audit System (internal audit, risk management,

regulatory compliance).

The Company has an adequate and effective Internal Audit System, which consists of all the internal control mechanisms

and procedures, including risk management, internal control and regulatory compliance, and covers on a continuous basis

every activity of the Company and contributes to the safe and effective its operation. The Company's Internal Audit System

aims at the following objectives, in particular:

a) Consistent implementation of the business strategy, with the effective use of available resources.

b) The efficient operation of the Internal Audit Unit, whose organization, operation and responsibilities are defined in the

law and its Rules of Operation.

c) In the effective risk management, through the recognition and management of the essential risks related to the business

activity and operation of the Company.

d) Ensuring the completeness and reliability of the data and information required for the accurate and timely determination

of the financial situation of the Company and the preparation of reliable financial statements, as well as its non-financial

statement, in accordance with article 151 of Law 4548 / 2018.

e) The effective compliance of the Company with the regulatory and legislative framework, as well as the internal

regulations governing the operation of the Company (regulatory compliance).

The Board of Directors ensures that the functions that make up the Internal Audit System are independent of the business

sectors they control, and that they have the appropriate financial and human resources, as well as the powers to operate

them effectively, as required by their role. The reporting lines and the division of responsibilities are clear, enforceable and

duly documented.

The Internal Audit Unit of the Company controls the correct implementation of each process and internal control system

regardless of their accounting or non-accounting content and evaluates the company through a review of its activities,

acting as a service to the Management. Its main mission is to monitor and improve the operations and policies of the

Annual Financial Report of 31 December 2021

Page | 40

Company and its subsidiaries (hereinafter the "Group") and to provide advisory support by submitting relevant proposals

to the Board of Directors regarding the Internal Audit System. The Internal Audit Unit also aims to provide reasonable

confirmation to shareholders to achieve the goals and objectives of the Group. The Head of the Internal Audit Unit meets

all the formal and substantive selection criteria provided by law.

The Internal Audit System aims, among other things, at ensuring the completeness and reliability of the data and

information required for the accurate and timely determination of the Company's financial situation and the production of

reliable financial statements.

Regarding the preparation of financial statements, the Company reports that the financial reporting system of the Issuer

uses an accounting system that is adequate for reporting to Management and external users. The financial statements and

other analyses reported to Management on a quarterly basis are prepared on an individual and consolidated basis in

compliance with the International Financial Reporting Standards, as adopted by the European Union for reporting purposes

to Management, as well as for publication purposes in line with the applicable regulations and on a quarterly basis. Both

administrative information and financial reports to be published include all the necessary details about an updated internal

control system including analyses of revenue, cost/expenses and operating profits as well as other data and indexes. All

reports towards the Management include the data of the current period compared to the respective data of the budget, as

the latter has been approved by the Board of Directors, along with the data of the respective period of the previous year.

All published interim and annual financial statements include all necessary information and disclosures about the financial

statements, in compliance with the International Financial Reporting Standards, as adopted by the European Union, are

reviewed by the Audit Committee and respectively approved in their entirety by the Board of Directors.

Audit controls are implemented with respect to: a) risk identification and evaluation as for the reliability of financial

statements; b) administrative planning and monitoring of financial figures; c) fraud prevention and disclosure; d) roles and

responsibilities of executives; e) year-end closing procedure including consolidation (e.g. recorded procedures, access,

approvals, agreements, etc.) and f) safeguarding the data provided by information systems.

The preparation of the internal reports towards the Management and the reports required under L. 4548/2018 and by the

supervisory authorities is conducted by the Financial Services Division, which is staffed with adequate and experienced

executives for this purpose. Management takes steps to ensure that these executives are adequately updated about any

changes in accounting and tax issues concerning both the Company and the Group.

The Company has established separate procedures regarding the collection of the necessary data from its subsidiaries, and

ensures the reconciliation of individual transactions and the implementation of the same accounting principles by the

companies of the Group.

The Risk Management Unit of the Company aims, through appropriate and effective policies, procedures and tools, to

assist the Board in identifying, evaluating and managing the substantial risks associated with the business and operation

of the Company and the Group, with adequate and effectiveness.

The Company's Regulatory Compliance Unit aims to assist the Board of Directors in the full and continuous compliance

of the Company with the current legal and regulatory framework and the internal Regulations and Policies that govern its

operation, providing at all times a complete picture of the degree of achievement of this purpose.

ii. Evaluation of corporate strategy, main business risks and Internal Audit System

The Company’s Board of Directors states that it has examined the main business risks that the Group faces as well as the

Internal Audit System. On an annual basis, the Board of Directors reviews the corporate strategy, main business risks and

Internal Control System, on the basis of a relevant proposal by the Audit Committee.

According to article 14 par. 3 case j of Law 4706/2020 and No. 1/891/ 30.9.2020 decision of the Board of Directors of the

Hellenic Capital Market Commission, as amended by no. 2/917/17.6.2021 decision of the Board of Directors of the

Hellenic Capital Market Commission, a periodic evaluation of the Internal Audit System takes place, in particular as to the

adequacy and effectiveness of the financial information, on an individual and consolidated basis, in terms of risk

management and regulatory compliance, in accordance with recognized standards of evaluation and internal control, as

well as the implementation of the provisions on corporate governance of Law 4706/2020. This evaluation is carried out

by an independent evaluator who meets the provisions of the above provision of Law 4706/2020 and the above decision

of the Board of Directors of the Hellenic Capital Market Commission, in accordance with the relevant policy / procedure

of evaluation the Company's Internal Control System. According to the above decision of the Board of Directors of the

Hellenic Capital Market Commission, as amended and in force, the first evaluation of the Internal Audit System must be

Annual Financial Report of 31 December 2021

Page | 41

completed by 31.03.2023 with a reference date of 31.12.2022 and a reference period from the entry into force of Article

14 of Law 4706/2020 (17.07.2021).

iii. Provision of non-audit services to the Company by its statutory auditors and evaluation of the effect that this fact

may have on the objectivity and effectiveness of mandatory audit, taking also into consideration the provisions of Law

4449/2017

The statutory auditors of the Company for the fiscal year 2021, “PriceWaterHouseCoopers Auditing Company SA” (AM

SOEL 113) (268 Kifisias Av. PC:15232, Chalandri, tel: 2106874400) have been elected by the Ordinary General Assembly

of the Company’s Shareholders on 24.05.2021.

Regarding year 2021, the fees of our auditor’s PriceWaterhouseCoopers S.A. for the Group and for the Company in respect

of audit of the financial statements of the Company amounted to Euros 213.000 plus VAT (2021: Euros 202.000), for tax

audit to Euros 44.800 plus VAT (2020: Euros 42.000) and fees for other services to Euros 4.000 plus VAT (2020: Euros

4.000). At a Group level amounted to Euros […] thousand (2020: Euros 312 thousand), for tax audit Euros […] thousand

(2020: Euros 69 thousand) and fees for other services to Euros […] thousand (2020: Euros 4 thousand).

iv. Head of Internal Audit Unit

The Company has appointed as Head of the Internal Audit Unit Mr. Epameinondas Batalas. Mr. E. Batalas holds a

bachelor’s degree in Economics and a postgraduate degree in Applied Economics and Finance from Athens University of

Economics and Business (AUEB). Moreover, holds the Diploma in IFRS from the Association of Chartered Certified

Accountants (ACCA). He initially joined STEELMET S.A. as a member of the Internal Audit in 2008 and was involved in the

audit procedures which were performed in the subsidiaries of VIOHALCO, serving for a number of years as internal audit

manager.

Public Takeover Offers – Information

− There are no binding takeover bids and/or rules of mandatory assignment and mandatory takeover of the Company's

shares or any statutory provision on takeover.

− There are no third-party public offers to take over the Company’s share capital during the last and current year.

− In case the Company takes part in such a procedure, this will take place in accordance to applicable laws (European

and Greek legislation).

General Meeting of the Shareholders and rights of shareholders

The General Meeting of the shareholders of the Company is, according to the Law, the supreme body of the Company

and is entitled to resolve on any affair that involves the Company. It is convened and operates in compliance with the

provisions of the Articles of Association and the relevant provisions of Law 4548/2018, as amended and in force today.

The Company makes the necessary publications and generally takes all steps required for the timely and thorough

information of shareholders in regard to the exercise of their rights. The latter is ensured by publishing the invitations to

General Meetings and uploading them on the Company’s website, the text of which contains a detailed description of

shareholders rights and how these can be exercised.

Composition and operation of the Board of Directors, the Supervisory Bodies and the Committees of the Company

Board of Directors

Roles and responsibilities of the Board of Directors

The Company’s Board of Directors manages the Company and is responsible for the long-term strategy and operational

goals of the Company and generally for the control and decision-making within the framework of the provisions of Law

4548/2018 and the Articles of Association, and for compliance with corporate governance principles.

The Board of Directors convenes at the necessary intervals so as to perform its duties effectively.

More specifically and indicatively, the Board has the following responsibilities:

▪ Defines the long-term strategy and operational goals of the Company.

▪ Has the responsibility of controlling and making decisions within the framework of the provisions of the current

legislation and the Articles of Association, as well as the observance of the principles of corporate governance.

Annual Financial Report of 31 December 2021

Page | 42

▪ Defines the corporate governance system of articles 1 to 24 of law 4706/2020, supervises its implementation and

monitors and evaluates periodically, every three (3) financial years, its implementation and effectiveness.

▪ Ensures the adequate and efficient operation of the Company's Internal Control System, which aims at the following

objectives, in particular:

(a) the consistent implementation of the operational strategy, making effective use of the resources available;

(b) the identification and management of substantial risks associated with its business and operation;

(d) to ensure the completeness and reliability of the data and information required for the accurate and timely

determination of the financial situation of the Company and the preparation of reliable financial statements,

as well as the non-financial situation of the Company, according to article 151 of law 4548 / 2018,

(e) the compliance with the regulatory and legislative framework, as well as the internal regulations governing

the operation of the Company.

Composition – Term of Office of the Board of Directors

The existing Board of Directors of the Company was elected by the Ordinary General Meeting of the Company held on

24.5.2021, with an annual term (according to article 11 par. 1 of its articles of association) until 24.5.2022, which is

extended, according to article 85, par. 1, par. c of Law 4548/2018, as in force, and article 11 par. 2 of the Company's

Articles of Association, until the expiration of the deadline, within which the next Ordinary General Meeting must be

convened in 2022 and until the receipt of the relevant decision, not exceeding two years. The above elected Board of

Directors was formed in a body during its meeting on 24.05.2021, when the representation of the Company was

determined.

On 30.06.2021 Mr. Nikolaos Galetas, an independent non-executive member of the Board of Directors of the Company,

submitted his resignation from the above position, for personal reasons, with effect from 10.07.2021.

Subsequently, following the decision of the Company's Board of Directors dated 12.07.2021, Mr. George Lakkotrypis was

elected, replacing the resigned Mr. Nikolaos Galetas of Ioannis, as a temporary independent non-executive member of

the Company's Board of Directors, until the first (immediately following) General Meeting of the Company's shareholders,

which would be called to definitively return the status of independent non-executive member to Mr. Georgios

Lakkotrypis.

Subsequently, the Extraordinary General Meeting of the Company's shareholders of 05.11.2021 (as the next General

Meeting of the Company's shareholders after the aforementioned election of a temporary independent non-executive

member of the Company's Board of Directors to replace the resigned independent non-executive Director) definitively

assigned the status of independent non-executive member of the Board of Directors to Mr. Georgios Lakkotrypis of

Antonios for the period from then on until the end of the term of office of the resigned, Mr. Nikolaos Galettas of Ioannis,

that is, until 24.05.2022, extended (of the term), according to article 85, par. 1, par. c of Law 4548/2018, as in force, and

article 11 par. 2 of the Company's Articles of Association, until the expiration of the deadline, within which the next

Ordinary General Meeting of the Company's Shareholders must be convened in 2022 and until the relevant decision, not

exceeding two years.

Subsequently, following the resignation of Mr. Periklis Sapountzis of Christos from 24.11.2021 from the position of

executive member of the Board of Directors (and the General Manager of the Copper Division of the Company), with the

effective date of his resignation on 29.11.2021, the Administrative Council, at its meeting of 29.11.2021, in replacement

of the resigned Mr. Periklis Sapountzis, elected Mr. Panagiotis Lolos of Charalambos for the rest of the term of the

resigned, that is, until 24.05.2022, such term being extended, according to article 85, par. 1, par. c of Law 4548/2018, as

in force, and article 11 par. 2 of the Company's Articles of Association, until the expiration of the deadline, within which

the next Ordinary General Meeting of the Company's Shareholders must be convened in 2022 and until the relevant

decision, not exceeding two years.

The current Board of Directors of the Company (elected by the Ordinary General Meeting of the Company's shareholders

from 24.05.2021, following the replacements of its members from 12.07.2021 and 29.11.2021, as mentioned above),

consists of 15 members, of which :

▪ 4 are executive members (Vice President & 3 Members).

▪ 6 are non-executive members (Chairman and 5 Members).

▪ 5 are independent non-executive members.

Annual Financial Report of 31 December 2021

Page | 43

12 of the members of the Board of Directors are men and 3 are women.

The composition of the current Board of Directors is as follows:

(1) Michael N. Stassinopoulos, Chairman, Non-Executive member

(2) Dimitrios Kyriakopoulos, Vice-chairman, Executive member

(3) Lampros Varouchas, Executive member and General Manager of the Aluminium Segment

(4) Panagiotis Lolos, Executive member and General Manager of the Copper Segment

(5) Konstantinos Katsaros, Executive member

(6) Christos-Alexis Komninos, Non-executive Member

(7) Nikolaos Koudounis, Non-executive member

(8) Elias Stassinopoulos, Non-executive member

(9) Aikaterini-Nafsika Kantzia, non-executive member

(10) Athanasia Kleniati Papaioannou, Non-executive member

(11) Vasileios Loumiotis, Independent Non-executive member

(12) Ploutarchos Sakellaris, Independent Non-executive member

(13) Ourania Ekaterinari, Independent, Non-executive member

(14) Thomas George Sofis, Independent, Non-executive member

(15) Georgios Lakkotrypis, Ιndependent Νon-executive member

The Board of Directors meets whenever the law, the articles of association or the needs of the Company require it.

Suitability Policy

The current Suitability Policy of members of the Board of Directors of the Company (according to article 3 of Law

4706/2020, hereinafter "Suitability Policy") was approved by the Ordinary General Meeting of its shareholders from

24.05.2021. The Suitability Policy is an essential part of the Company's Corporate Governance System. Aims to ensure the

quality staffing, efficient operation and fulfillment of the role of the Board of Directors based on the overall strategy and

medium-term business aspirations of the Company in order to promote the corporate interest. Through its

implementation, the acquisition and retention of persons with skills, knowledge, skills, experience, crisis independence,

guarantees of morality and good reputation that ensure the exercise of good and effective management for the benefit

of the Company, shareholders and all stakeholders. The Suitability Policy, as well as any substantial modification, is

proposed to the Board of Directors of the Company by the Remuneration and Promotion Committee of the Company, in

collaboration with the Internal Audit Unit and the Legal Service of the Company, then approved by the Board of Directors

and is submitted for approval to the General Meeting of the Company. The Company has and implements a diversity

policy in order to promote an appropriate level of differentiation in the Board of Directors and a diverse group of

members. Through the accumulation of a wide range of qualifications and skills in the selection of the members of the

Board of Directors, the variety of views and experiences is ensured in order to make the right decisions. The Eligibility

Policy is included / referred to in the diversity policy, to ensure that it has been taken into account when appointing new

members of the Board. Adequate gender representation of 25% of all members of the Board of Directors is explicitly

provided, and based on the current fifteen-member Board of Directors, the minimum number of women or men is three

(3) and no exclusion is applied due to gender, race, color, ethnic or social origin, religion or belief, property, birth,

disability, age or sexual orientation. The Suitability Policy is available on the Company's website at the following link:

https://www.elvalhalcor.com/investor-relations/corporate-governance/board-of-directors/suitability-policy-bod.

The composition of the existing Board of Directors of the Company (from its election by the Ordinary General Meeting of

the Company's shareholders from 24.05.2021 and then from the replacements of its members from 12.07.2021 and

29.11.2021, according to the above) meets the requirements and the criteria of suitability (individual and collective) and

diversity, as provided in Law 4706/2020 and the Suitability Policy, as determined by the Remuneration and Promotion

Committee of the Company at the level of candidate members, before the election of the Board of Directors and each

member to replace a missing person, as well as by the Board of Directors, during the respective election.

Annual Financial Report of 31 December 2021

Page | 44

Also, the Board of Directors during its meeting of 15.03.2021, following a relevant proposal of the Remuneration and

Nomination Committee of the Company, reviewed and found the fulfillment of the conditions of independence of article

9 par. 1 and 2 of Law 4706/2020 of the existing independent non-executive members of the Board of Directors.

Participation of members of the Board of Directors in its meetings

In 2021, a total of 39 meetings of the Board of Directors were held. The frequency of participation of the members of the

Board of Directors in its meetings in the year 2021 is as follows:

DIRECTOR

DIRECTOR’S TERM OF

OFFICE

NR. OF

MEETINGS

DURING

DIRECTORSHIP

TOTAL

PRESENCES

PRESENCE

PERCENTAGE

FROM

UNTIL

CHAIRMAN – NON-EXECUTIVE

Papageorgopoulos Theodosios

1/1/2021

24/5/2021

31,82%

Stassinopoulos Michael

24/5/2021

31/12/2021

100,00%

VICE-CHAIRMAN – EXECUTIVE

Kyriakopoulos Dimitrios

1/1/2021

31/12/2021

100,00%

EXECUTIVE MEMBERS

Varouchas Lambros

1/1/2021

31/12/2021

100,00%

Sapountzis Periklis

1/1/2021

29/11/2021

100,00%

Kotsabasakis Eytychios

1/1/2021

12/1/2021

100,00%

Katsaros Konstantinos

1/1/2021

31/12/2021

100,00%

Voloudakis Stavros

1/1/2021

24/5/2021

100,00%

Kokkolis Spyridon

1/1/2021

24/5/2021

95,45%

Lolos Panagiotis

29/11/2021

31/12/2021

100,00%

NON-EXECUTIVE MEBERS

Katsambas Georgios

1/1/2021

24/5/2021

100,00%

Koudounis Nikolaos

1/1/2021

31/12/2021

100,00%

Stassinopoulos Elias

1/1/2021

31/12/2021

43,59%

Komninos Christos - Elias

19/1/2021

31/12/2021

80,56%

Aikaterini-Nafsika Kantzia

24/5/2021

31/12/2021

100,00%

Kleniati Papaioannou Athanasia

24/5/2021

31/12/2021

100,00%

INDEPENDENT NON-EXECUTIVE

Loumiotis Vasileios

4/1/2021

31/12/2021

100,00%

Sofis Thomas George

1/1/2021

31/12/2021

48,72%

Galetas Nikolaos

1/1/2021

12/7/2021

96,43%

Ekaterinari Ourania

24/5/2021

31/12/2021

64,71%

Sakellaris Ploutarchos

24/5/2021

31/12/2021

64,71%

Lakkotrypis Georgios

12/7/2021

31/12/2021

72,73%

CVs of the members of the Board of Directors

The CVs of the members of the Board of Directors of the Company (from which it appears that the composition of the

Board of Directors reflects the knowledge, skills and experience required to exercise its responsibilities, in accordance

with the Suitability Policy and the professional model and Company strategy) are set out below.

Annual Financial Report of 31 December 2021

Page | 45

Audit Committee

i. Description of the composition, operation, work, responsibilities and of the issues discussed during the Audit

Committee meetings

The Audit Committee, according to its current Rules of Operation, which consists of at least three (3) members, can be a)

a committee of the Board of Directors, consisting of non-executive members, or b) an independent committee, which

consists of non-executive members of the Board of Directors and third parties, or c) an independent committee, which

consists only of third parties. Third party means any person who is not a member of the Board of Directors. The type of

the Audit Committee, the term of office, the number and the qualities of its members are decided by the general meeting

of the Company's shareholders. The term of office of the members of the Audit Committee is the same as the term of

office of the members of the Board of Directors. The re-election of the members of the Audit Committee is possible. The

members of the Audit Committee are appointed by the Board of Directors, when it is a committee, or by the general

meeting of shareholders of the Company, when it is an independent committee, and are in their majority independent of

the Company, in accordance with applicable provisions ( article 9 of Law 4706/2020). The Chairman of the Audit

Committee is appointed by its members, at its meeting, to form it in a body, and is independent of the Company.

The members of the Audit Committee as a whole have sufficient knowledge in the field in which the Company operates.

At least one (1) member of the Audit Committee, who is independent of the Company, with sufficient knowledge and

experience in auditing or accounting, is required to attend the meetings of the Audit Committee regarding the approval

of the annual corporate and consolidated financial statements.

Following the decision of the Ordinary General Meeting of the Company's shareholders dated 24.05.2021, which decided

the appointment of the Company's Audit Committee, as a committee of the Board of Directors, consisting of non-

executive members of the Company's Board of Directors, in accordance with article 44 of Law 4449/2017, as in force, the

Board of Directors of the Company, during its meeting of 26.05.2021, ascertaining the fulfillment of all the criteria and

conditions of par. 1 of article 44 of Law 4449/2017, as in force after its amendment by article 74 of Law 4706/2020,

appointed as members of the Company's Audit Committee Messrs. Vassilios Loumiotis, independent non-executive

member of the Board of Directors, Plutarch Sakellaris, independent non-executive member of the Board of Directors, and

Nikolaos Koudounis, independent non-executive member of the Board of Directors. All members of the Audit Committee

have proven sufficient knowledge and experience of the sector in which the Company operates. The Audit Committee

during its meeting of 28.05.2021 was formed in a body and appointed as its Chairman Mr. Vassilios Loumiotis, an

independent non-executive member of the Board of Directors, who has sufficient knowledge and experience in auditing

and accounting.

The main mission of the Audit Committee is to assist the Board of Directors in the execution of its duties, supervising the

financial reporting procedures, the completeness and correctness of the annual corporate and consolidated financial

statements, the policies and the internal control system of the Company (Article 2 of Law 4706/2020) and evaluating the

adequacy, efficiency and effectiveness of the internal control systems (article 44 par. 3 par. c L.4449 / 2017), the audit

function of the internal audit work and the external auditors, in order to ensure the independence of the quality, formal

qualifications and performance of the auditors.

The Audit Committee receives from the Internal Audit Unit the following reports for the audit activity:

− Ad-hoc reports.

− Semi-annual financial audit reports.

− Ordinary annual audit reports.

− Corporate Governance Reports.

− Stock exchange reports.

− Inventory-counting reports.

− Productivity Efficiency reports.

− Audit Opinion .

The Audit Committee examines and ensures the independence of the Company’s external auditors and takes

consideration of their findings and the Audit Reports on the annual or interim financial statements of the Company. At

the same time, it recommends corrective actions and procedures so as to deal with any findings or failures in areas of

financial reports or other important functions of the Company.

Annual Financial Report of 31 December 2021

Page | 46

The Audit Committee meets at the Company's headquarters or where its Articles of Association provide, in accordance

with article 90 of Law 4548/2018, as in force. The Audit Committee meets regularly and, however, at least as many times

in each year, to consider and take decisions on all matters within its competence.

ii. Number of meetings of the Audit Committee and frequency of participation of each member in the meetings

The Audit Committee met 16 times in 2021. The frequency of participation of the members of the Audit Committee in its

meetings in the year 2021 is as follows:

AUDIT COMMITTEE MEMBER

MEMBER’S TERM OF OFFICE

NR. OF

MEETINGS

DURING

DIRECTORSHIP

TOTAL

PRESENCES

PRESENCE

PERCENTAGE

FROM

UNTIL

Loumiotis Vasileios

4/1/2021

31/12/2021

100,00%

Galetas Nikolaos

1/1/2021

24/5/2021

75,00%

Sakellaris Ploutarchos

24/5/2021

31/12/2021

100,00%

Koudounis Nikolaos

1/1/2021

31/12/2021

100,00%

iii. Work of the Audit Committee

Regarding the activities of the Audit Committee, please refer to the annual Report of the Acts of the Audit Committee to

the Ordinary General Meeting of the Company's shareholders (article 44 par. 1 per. i. of Law 4449/2017) to be convened

in 2022, as approved at the meeting of the Audit Committee of 15.03.2022 and included here below, which includes all

issues on the which the Audit Committee consulted and resolved during the financial year 2021.

Remuneration and Nomination Committee

i. Description of the composition, operation, work, competences

According to its current Rules of Operation, the Remuneration and Nomination Committee (hereinafter "RNC") exercises,

as a single committee, the responsibilities of both the remuneration committee (article 11 of law 4706/2020) and the

candidacy committee (of article 12 of law 4706/2020), which have been assigned to the RNC, according to par. 2 of article

10 of law 4706/2020, based on a relevant decision of the Board of Directors of the Company. The RNC has three members

and consists entirely of non-executive members of the Board of Directors of the Company, at least two (2) of which must

be independent. The term of office of the Committee is equal to the term of office of the Board of Directors.

With its decision of 26.05.2021, the Board of Directors appointed Mr. Plutarchos Sakellaris, an independent non-executive

member of the Board of Directors of the Company, as members of EAAY. Ourania Aikaterinari, independent non-executive

member of the Board of Directors, and Mrs. Ekaterini - Nafsika Kantzia, non-executive member of the Board of Directors.

During its meeting of 28.05.2021, the EAW was formed into a body and appointed as its Chairman Mr. Ploutarchos

Sakellaris, an independent non-executive member of the Board of Directors. The members of the RNC have in their

entirety sufficient knowledge in the field in which the Company operates.

The main responsibilities of the RNC are the following:

▪ In terms of the remuneration:

− Formulates proposals to the Board of Directors regarding the remuneration policy of the Company (article 110

of law 4545/2018, hereinafter "Remuneration Policy") which is submitted for approval to the General Meeting

(according to article 110 par. 2 law 4548/2018), and the remuneration of the persons that fall within the scope

of the Remuneration Policy, according to article 110 of law 4548/2018, the remuneration of the Company's

executives and the remuneration of the Head of the Internal Audit Unit, according to the existing provisions

(article 11 par. b L.4706/2020).

− Evaluates, on a periodic basis, the need to update the company's Remuneration Policy taking into account the

legislative developments, best practices, as well as the relevant findings / reports / reports of the Internal Audit

Unit.

− Reviewes, on a periodic basis, the level of benefits of the Company based on the best practices and the levels

of remuneration of the respective branch, proposing, if necessary, the necessary changes in the level of benefits

and the Remuneration Policy.

− Examines the information included in the final draft of the annual remuneration report of the Company (article

112 of law 4548/2018, hereinafter "Remuneration Report") and issues an opinion to the Board of Directors on

Annual Financial Report of 31 December 2021

Page | 47

it, before submitting the Remuneration Report to the General Assembly (according to article 112 of law

4548/2018).

▪ Regarding the nomination of candidates:

− Monitors the effectiveness and reviews the design and implementation of the Company Suitability Policy and

conducts its periodic evaluation, at regular intervals, or when significant events or changes take place.

− Locates and proposes to the Board of Directors persons suitable for the acquisition of the status of member of

the Board of Directors, the Company Audit Committee (article 44 of law 4449/2017) and any other committees

of the Board of Directors, taking into account the factors and criteria of individual and collective suitability

determined by the Company, in accordance with the Suitability Policy it adopts and based on the relevant

procedure provided in its Rules of Operation.

− Evaluates the performance of the members of the Board of Directors and the committees of the Company,

evaluating the skills, knowledge and experience of the members of the Board of Directors and the committees

of the Company and informs the Board of Directors accordingly.

− Evaluates the structure, composition and size of the Board of Directors of the Company and submits proposals

for appropriate changes.

− Monitors on an ongoing basis the suitability of the members of the Board of Directors, in particular to identify,

in the light of any relevant new event, cases in which it is deemed necessary to re-evaluate their suitability, in

accordance with the relevant definitions of the Suitability Policy.

− Examines the independence of the independent non-executive members of the Board of Directors, periodically,

at least once a year, as well as in case of election of a new Board of Directors or election of a member to replace

a deceased independent member, and exceptionally, when required and submits proposals to the Board as to

the appropriate actions and/or changes in its composition.

− Examines the selection policy of the senior executives (key management personnel, within the meaning of

article 2 per. 13 of Law 4706/2020) of the Company.

The RNC meets at the Company's registered office or where it provides for its Articles of Association, as in force, in

accordance with article 90 of Law 4548/2018, as in force, at regular intervals and extraordinarily, whenever deemed

necessary by the President or any of its members.

ii. Number of meetings of the RNC and frequency of participation of each member in the meetings – activities

The RNC met 10 times in 2021 with a full quorum (all its members participated in all the meetings). The main issues

addressed by the RNC at its meetings are as follows:

− Establishment of the RNC in a body and election of its President.

− Examination of the periodically submitted statements of independence of the independent members of the Board of

Directors.

− Determination of remuneration and benefits in accordance with the approved Remuneration Policy of the Company.

− Determination of remuneration of the members of the Board of Directors of the Company for the year 2020 - advance

payment of remuneration of the members of the Board of Directors of the Company (article 109 par. 4 Law 4548/2018

as in force).

− Submission of opinion - suggestion to the Board of Directors of the Company on the draft Remuneration Report of

the corporate year 2020 regarding its approval and submission by the Board of Directors to the Ordinary General

Meeting of Shareholders for discussion and approval by advisory vote, according to articles 117 par. 1 par. c and 112

par. 3 of Law 4548/2018.

− Recommendation to the Board of Directors of the Company for the election (re-election or not) of members of the

Board of Directors from the next Ordinary General Meeting of the Company's shareholders.

− Recommendation to the Board of Directors of the Company regarding the type of Audit Committee, the term of office,

the number and the qualities of its members, according to article 44 of Law 4449/2017, as in force.

Annual Financial Report of 31 December 2021

Page | 48

− Recommendation to the Board of Directors of the Company for the appointment (re-election or not) of members of

the Audit Committee, the Remuneration and Nomination Committee of Candidates and any other committees of the

Board of Directors, from the members of the Board of Directors proposed for election (and if elected) ) from the next

Ordinary General Meeting of the Company's shareholders.

− Recommendation to the Board of Directors of the Company for the (election of a temporary independent non-

executive member of the Board of Directors in) replacement of a resigned independent non-executive member.

− Recommendation to the Board of Directors of the Company for the (election of an executive member of the Board of

Directors in) replacement of a resigned executive member (or the continuation of the term of office without his

replacement).

− Evaluation of fulfillment of duties of the Audit Committee.

− Approval of a draft of the revised Rules of Operation of EAAY in order to adapt it to Law 4706/2020 and a relevant

proposal - proposal to the Board of Directors of the Company for the revision thereof.

− Approval of (a) policy / process of recruitment & performance appraisal of senior executives and (b) procedure of

notification of dependent relations of the independent non-executive members of the Board of Directors, as part of

the Company's Rules of Operation and relevant recommendation – proposal to the Company Board of Directors the

corresponding revision of that Regulation.

− Defining and approving agenda items and schedule of meetings of the RNC during the remainder of its term.

Annual Financial Report of 31 December 2021

Page | 49

AUDIT COMMITTEE OF ELVALHALCOR S.A.

Vasileios Loumiotis, President

Ploutarchos Sakellaris, Member

Nikolaos Koudounis, Member

Athens, March 15

, 2022

To: The Shareholders of the Ordinary General Meeting of the Company ELVALHALCOR S.A. of 2022

Activity Report of the Audit Committee on the audited financial year 2021

Dear Shareholders,

In our capacity as Members of the Audit Committee of the Company under the name "ELVALHALCOR

HELLENIC COPPER AND ALUMINUM INDUSTRY SOCIETE ANONYME" (hereinafter referred to as the

“Company”), and in accordance with article 44 of L. 4449/2017 (the "Law") on the one hand, and as referred

to in detail in reference numbers 1302/28-4-2017 and 1508/17.7.2020 Announcements of the Directorate of

Listed Companies / Department of Supervision of Listed Companies of the Hellenic Capital Market

Commission (hereinafter the "Announcements") on the other hand, we state our Report below and we bring

to your attention, within the responsibilities of the Audit Committee, findings regarding the objects regulated

by the Law and the aforementioned announcements.

Specifically:

A) In relation to the mandatory audit (external audit) (article 44, par. 3, case a of the Law). Particularly:

a) Regarding the performance of the statutory audit (external audit) of the corporate and consolidated

financial statements of the Company for the year ended December 31, 2021, we did not find significant

deviations in the recognition, valuation and classification of assets and liabilities and we consider that the

Management's assumptions and estimates are reasonable. We have found that the relevant disclosures in

the notes to the financial statements are adequate.

b) During the mandatory inspection, we performed the following matters:

1. Review of health, safety and environmental issues.

2. Review of the process of registration and accounting of expenses, fixed assets, sales and other

accounting circuit.

3. Review of tax and customs issues.

4. Review of production and export procedures and processes.

5. Visit and briefing at the premises of two of the Company's significant subsidiaries, SYMETAL S.A. and

ANOXAL S.A., in Inofyta, Attica.

6. Review of processes and procedures of Financial Services of Hedging department.

7. Internal Audit Unit Reports.

8. Report of the group of External Auditors.

9. Review of processes and procedures of Human Resources

10. Examination of pending litigation risks.

Annual Financial Report of 31 December 2021

Page | 50

In the exercise of our responsibilities, we have not identified any significant weaknesses that need

improvement.

It is noted that the Audit Committee always takes into account the content of any additional reports

submitted to it by the chartered accountant of the auditing company hired by the Company, which contains

the results of the statutory audit performed and meets at least the specific requirements in accordance with

Article 11 of Regulation (EU) No 537/2014 of the European Parliament and of the Council of 16 April 2014.

c) Within the framework of our responsibilities, we were informed about the procedure and the

schedule of preparation of the financial information by the management of the Company, as well as we were

informed by the chartered accountant on the statutory audit program for the year 2021 before its

implementation. We evaluated it and made sure that this program covered the most important areas of

control, taking into account the key areas of business and financial risk of the Company. We also held

meetings with the Company's management / responsible executives and the chartered accountant, during

the preparation of the financial statements, during the planning stage of the audit, its execution and during

the stage of preparation of the audit reports, respectively.

d) We have taken into account and examined the most important issues and risks that may have an

impact on the Company's financial statements, as well as the significant judgments and estimates of

management during their preparation. Specifically, we examined and evaluated in detail the following issues

with reference to specific actions on these issues:

d1) Regarding the important judgments, assumptions and estimates in the preparation of the financial

statements, we found that they are reasonable (reasonable).

d2) Regarding the accounting treatment of the acquisition of ETEM EMPORIKI SA through the participation

in the share increase, we evaluated the correctness of the accounting of the transaction in accordance

with the provisions of IFRS 3 "Business Combinations" and we assessed that the recognition criteria

provided by IAS 38 "Intangible Assets" regarding the recognition of intangible assets.

d3) In addition, regarding the above transaction, in terms of the distribution of consideration in the

identifiable assets acquired and the liabilities assumed as well as the calculation of goodwill, from the

difference between the consideration and the net identifiable assets, no exceptions were identified.

d4) Regarding the accounting for the dividend distribution in kind of shares of Cenergy Holdings S.A.

ownership of ELVALHALCOR, we assessed the correctness of the accounting treatment, given the

absence of specific provision of IFRS / IAS that provides for the handling of such cases. We reviewed

and evaluated the correct application of IAS 8 in conjunction with the use of standards with a similar

conceptual framework, such as "IFRIC 17 Interpretation of Non-Cash Assets to Owners" and "ASC 845

US GAAP" – “Non-monetary transactions”, and the treatment applied by the Company was judged to

reflect the transaction in every fair and reasonable way.

d5) We examined and evaluated the accounting treatment for the change in accounting policy, applying

the change retrospectively from the beginning of the first comparative period, i.e. 2020, in accordance

with paragraphs 19 - 22 of IAS 8, following the final decision of the IFRS Interpretations Committee

regarding the International Accounting Standard (IAS) 19 "Attributing benefit to periods of service".

d6) Regarding the disclosures on the above issues required by IAS / IFRS, we found that the disclosures

included in the financial statements are sufficient.

d7) Regarding the transactions with related parties, as shown in the Annual Financial Report for the year

2021, we did not find any significant unusual transactions.

e) Finally, we had timely and substantial communication with the chartered accountant in view of the

preparation of the audit report and its supplementary report to the Audit Committee, while we point out that

we reviewed the financial reports before their approval by the Company's Board of Directors and consider

that is complete and consistent in relation to the information that was brought to our attention, as well as to

the accounting principles applied by the Company.

Annual Financial Report of 31 December 2021

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Β) In relation to the financial information process (article 44, par. 3, per. B' of the Law). Particularly:

In relation to the process of preparing the financial information, the Audit Committee monitored, examined

and evaluated:

(a) the mechanisms and systems of production, flow and dissemination of financial information produced by

the involved organizational units of the Company and

(b) other disclosed information in any way (e.g. stock market announcements, press releases) in relation to

financial information.

In the exercise of our responsibilities, we did not find any weaknesses in the process of compiling the financial

information that need to be improved.

C) In relation to the procedures of internal control and risk management systems and the internal control

unit (article 44, par. 3, point B' of the Law). Particularly:

In connection with the monitoring, examination and evaluation of the adequacy and effectiveness of all the

policies, procedures and safety controls of the Company regarding the internal control system and the

assessment and management of risks, in relation to the financial information, the Audit Committee

proceeded to actions below:

(a) Evaluation of the proper functioning of the Internal Audit Unit according to the professional standards

as well as the current legal and regulatory framework and evaluation of the work it performs, its

adequacy and effectiveness, without however affecting its independence,

(b) Overview of the disclosed information regarding the internal audit and the main risks and

uncertainties of the Company in relation to the financial information,

i.e. if it does not have the necessary means, if it is insufficiently staffed with insufficient knowledge,

experience and training,

(d) Assessing the existence or non-existence of restrictions on the work of the Internal Audit Unit, as well

as the independence that it must have, in order to perform its work unobstructed,

(e) Evaluation of the annual control program of the Internal Audit Unit before its implementation, taking

into account the main areas of business financial risk as well as the results of previous audits,

(f) Considering that the annual audit program, in conjunction with any corresponding medium-term

programs, covers the most important areas of control and financial information systems,

(g) Organizing regular meetings with the Head of the Internal Audit Unit on matters within its competence

and gaining knowledge of its work and its regular and extraordinary reports,

(h) Monitoring the effectiveness of internal control systems through the work of the Internal Audit Unit

and the work of the chartered accountant;

(i) Overview of the management of the main risks and uncertainties of the Company and their periodic

review, evaluating the methods used by the Company to identify and monitor the risks, the treatment

of the main ones through the internal audit system and the Internal Audit Unit as well as their

disclosure to the disclosed financial information in a proper manner.

Annual Financial Report of 31 December 2021

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The Audit Committee was informed and has evaluated the reports of the audit program for the current year,

while it was also informed and evaluated the audit program of the coming year. The following is what the

Audit Committee has learned and evaluated:

• 2021 Audit Program Review.

• Summary of the Annual Audit Program of 2022.

• Human Resources of Internal Audit.

• Resource Allocation Guides.

• Risk Assessment.

During the internal audit process, the Audit Committee became aware of the following actions of the Internal

Audit Unit:

• Audit of health and safety issues, as well as environmental issues.

• Audit of the process of registration and accounting of expenses, fixed assets, sales and other

accounting circuit.

• Financial management audit (Copper Division).

• Audit of tax and customs issues.

• Audit of personnel management issues and GDPR.

• Adherence to Internal Rules of Operation.

• Inventory control.

• Industrial Production Control.

• Audit of warehousing & costing procedures and gate-weighing.

• Audit of the efficiency of production resources.

• Night surveillance audit.

• Premises security audit.

The Audit Committee, having taken into account the effects and risks of the pandemic due to coronavirus

COVID-19, was informed of the following main risks for the year 2022:

1. Commercial Risk - Distribution Risk, associated with:

• Additional quantities of final products to be available for sale in the year 2022, due to increased

production capacity (Aluminum Sector).

• Maintaining high stocks - Slow moving products (Copper & Aluminum Sector).

• Additional costs after the completion of the production process, transportation and handling costs,

etc. (Aluminum Sector).

• Logistics for sales abroad (Aluminum Sector).

2. Information Systems Risk, related to:

• Data Security (Cyber Security) (Copper & Aluminum Segment).

• Multiple Information Programs (Copper & Aluminum Segment).

• Information System Users Access / Authorization (Copper & Aluminum Segment).

3. Foreign Exchange Risk, related to the risk of exchange rate fluctuations, British Pound and US Dollar

(Copper & Aluminum).

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4. Compliance risk, related to:

• Environmental Risk (Possible non-compliance with environmental legislation). (Copper & Aluminum

Segment).

• Health & Safety Risk (Possible non-compliance with Health & Safety rules). (Copper & Aluminum

Segment).

• Risk of application of GDPR provisions (Copper & Aluminum Segment).

• Risk of an increase in contractor’s staff due to new investments (Copper & Aluminum Segment).

5. Legal risk, related to the risk of:

• Pending legal claims against third parties.

• Legal claims of third parties.

In the exercise of our responsibilities on the above-mentioned issues, we have not identified any weaknesses

that need to be improved.

D) Sustainable development policy followed by the Company

In accordance with the provisions of article 44 par. 1 of Law 4449/2017, as replaced by the provisions of

article 74 par. 4 case 9 of L.4706/2020, the Audit Committee is obliged to include in the annual report of the

proceedings to the ordinary general meeting also a description of the sustainable development policy

followed by the Company.

Large modern companies implement a Sustainable Development Policy, in accordance with the international

best practice. This policy empowers companies, gives them a social dimension and perspective for the future

and makes them real cells of the national economy.

The Company and consequently the ELVALHALCOR Group, following the policy of the broader VIOHALCO

group, implements a Sustainable Development Policy and seeks, over time, to create value for its participants,

i.e. shareholders, customers, employees and society in general.

To achieve this goal, the Group places particular emphasis on, among others, the training and development

of human resources, health and safety at work, as well as respect for the environment, following the

principles of sustainable operation and development.

The Sustainable Development Policy of the Company reflects the approach and commitment of the

Management to the issues of sustainable development and responsible operation. Responsible operation is

a continuous commitment to action of substance, in order to generate value for all stakeholders that meet

the modern needs of society and contribute in general to its prosperity. The Company has a specific strategy,

which focuses on the important issues related to its activity and seeks its continuous responsible

development, focusing on the critical pillars of business responsibility: Economy, Society, Environment.

Sustainable development policy is an integral part of the Company's business practice model and culture. In

the context of the implementation of Sustainable Development policy, the Company develops activities,

among others, in the following areas:

a) Staff health and safety

The Company has set as an unnegotiable priority and primary concern the protection of the health and safety

of its staff. In the context of the implementation of this policy, the Company has established every best

international practice that contributes to the reinforcement and improvement of the safety culture and the

achievement of the goal of "zero accidents" and at the same time organizes training programs, both for the

knowledge of the risks in the production process and for the cultivation of a common consciousness and

safety behavior among employees.

Annual Financial Report of 31 December 2021

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Promoting the protection of health as a maximum good, the Company treats the current situation, regarding

the COVID-19 pandemic, with due seriousness, aiming at the health and safety of the employees. At the same

time, with a high sense of social responsibility and in order to contribute to tackling the crisis facing our

country from the spread of the coronavirus, he participated with a significant amount in strengthening the

National Health System in hospital equipment and consumables.

b) Training and development of human resources

The Company recognizes the decisive contribution of the staff in its successful business path so far. The great

experience, the high specialization, the know-how and the creativity of the staff support the course of the

Company for a stable, dynamic and continuous development. The Company attaches great importance to the

objective evaluation of the staff, to the detection and development of talent, as well as to the continuous

training, designing and implementing training programs of high added value. The Company encourages

professional development and makes the most of the knowledge and skills of the staff. The Academy of the

Company, which has been operating for four years, aims to effectively develop the skills, knowledge and

know-how of employees, through educational programs, which are based on structured methodology,

selected subjects and educational material that meet specific needs and cover a wide range of knowledge

fields. Within the Academy, in the year 2021, educational programs were implemented giving the opportunity

to participants to take part and reap the benefits of learning provided by highly qualified instructors. Some

of these programs were implemented on a recurring basis.

c) Responsibility for society

The Company seeks the sustainability of the local community and therefore maintains a bilateral, continuous

cooperation with it. The Company draws from the local community that operates a significant part of its

needs in human resources and suppliers. Of the total workforce, 56% concerns workers from local

communities, thus contributing to the local and national economy.

Regarding the Company's social contribution initiatives, notable are the support of vulnerable groups, the

strengthening of local health centers and hospitals with the provision of appropriate equipment, the response

to emergencies (e.g. natural disasters), the voluntary blood donations in the facilities are noted, donations to

charities, support to schools, sports and cultural organizations and other initiatives that promote common

values for progress, development and social contribution.

d) Environmental protection

For the Company, the protection of the environment is a key element of its Sustainable Development Policy

and is a key pillar of its business strategy, which is adjusted to the ever changing international business

environment. Environmental awareness is expressed through targeted, environmental protection

investments and systematic and daily practices, which combine responsible environmental management with

the effort to constantly reduce the environmental footprint. In the context of environmental protection, the

Company implements the current legislation and in particular:

• Implements targeted environmental management programs (e.g. energy saving programs, actions

and initiatives to reduce air emissions, etc.).

• It seeks the rational use of raw materials and natural resources (eg rainwater, etc.) and promotes

the recycling of aluminum and copper.

• Implements an integrated waste management system (with emphasis on prevention to avoid their

production).

• Monitors technology developments and regularly upgrades environmental protection

infrastructure.

• Provides for the continuous training and awareness of employees on environmental issues.

• Ensures that there is an appropriate risk analysis and incident response organization.

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The Company has adopted an environmental management policy to protect the environment from its

operation.

e) Protection of personal data

We found that the Company respects the protection of personal data not only as an obligation of legal

compliance with the General Regulation of Personal Data Protection but also takes appropriate measures in

accordance with the provisions of the General Regulation of Personal Data Protection (EU) 679/2016 and the

implementing internal law 4624/2019. In order to harmonize with international standards and best practices,

the Company has adopted a Personal Data Protection Policy of employees, customers, suppliers and partners

by setting specific roles, procedures and mechanisms for the full range of activities. At the same time,

ensuring the appropriate technological means, planning its processes with a view to protecting from the

outset and planning of business activities and information systems, but also the formation of a similar culture

is a primary concern and goal of continuous improvement but also for added value and the competitive

advantage it offers to the Company. The protection of personal data is a commitment.

f) Corporate governance

The Company, recognizing the importance of corporate governance principles but also the advantages

deriving from their adoption, follows international best practices and international standards that apply in its

areas of activity, in order to maximize the benefit for its shareholders and the production of value in general

for all participants and for society as a whole.

As a listed company on the Athens Stock Exchange, it implements the current corporate governance

legislation. In order to enhance corporate transparency and control mechanisms, effective management and

optimal operational efficiency, the Company implements an Internal Operating Regulation and has adopted

the Hellenic Corporate Governance Code issued by the Hellenic Corporate Governance Council (HCGC) of

June 2021. In addition, the Code of Ethics and Business Ethics, the Code of Conduct for Suppliers / Partners

of the Company and the Business Ethics and Anti-Corruption Policy reflect its commitment and position on

the issues of transparency, anti-corruption and gift. The Company's exposure to the risk of corruption is

systematically monitored.

It is pointed out that in order to achieve the above mentioned objectives of the Sustainable Development

policy, the Company has established and operates the following Directorates, which are fully staffed with

sufficient and appropriate staff:

• Directorate of Health and Safety.

• Environment Department.

• Directorate of Sustainable Development.

• Human Resources Department.

• Directorate of Quality Assurance and Environment.

We remain at your disposal for any additional information or clarification.

With kind regards,

THE MEMBERS OF THE AUDIT COMMITTEE

VASILEIOS LOUMIOTIS

PRESIDENT

PLOUTARCHOS SAKELLARIS

MEMBER

NIKOLAOS KOUDOUNIS

MEMBER

Annual Financial Report of 31 December 2021

Page | 56

CVs OF MEMBERS OF THE BOARD OF DIRECTORS AND KEY EXECUTIVES OF THE COMPANY

Michael N. Stassinopoulos, Chairman, Non-executive member

Mr. Michael Stassinopoulos was born in Athens in 1967. He graduated from Athens College (1985) and holds a Bachelor’s

Degree in Management Sciences from London School of Economics (1989). He also holds a postgraduate diploma (MSc)

in Shipping, Trade and Finance from City University Business School UK. Mr. Stassinopoulos is a member of the Board of

Directors of Viohalco SA. since 2013. He was a member of the Board of Directors of Elval SA Aluminium Industry for 11

years. He also participates in the Board of Directors of the Hellenic Federation of Enterprises since 2016 and was

previously a member during 1996-2006. He is a member of the Board of Directors of the Hellenic Production - Industry

Roundtable for Growth, a newly established nongovernmental organization.

Dimitrios Kyriakopoulos, Vice-chairman, Executive member

Mr. Kyriakopoulos studied Business Administration at AUEB and holds a Diploma in Business Studies from the City of

London College and Marketing from the British Institute of Marketing. He holds the position of the executive Vice-

chairman of ElvalHalcor and the executive Vice-chairman Cenergy Holdings S.A He works for Viohalco since 2006, and

since holds various managerial positions, among them financial manager of Viohalco and vice-chairman of the non-ferrous

metals. Prior to Viohalcor, he had a long standing carreer in Pfizer/Warner/Lambert holding the position of Regional

Director of Europe / Middle East / Africa of ADAMS (Confectionery Division of Pfizer), chairman of the consumer products

of Warner Lambert for Italy/ France/ Germany, and President and CEO of Warner Lambert in Greece. He was also

appointed Deputy Managing Director of Duty Free SA.

Lampros Varouchas, Executive member and General Manager of the aluminium segment

Mr. Varouchas is an Electrical Engineer of NTUA and he has been working in the aluminium rolling division of ElvalHalcor

(former Elval) since 1969. He has served as Factory Manager and from 1983 to 2004 he was the Technical Director

responsible for the implementation and design of the Company’s Investment Program. Since 2005 he has been General

Manager at the aluminium rolling division of ElvalHalcor. At the same time, he is a member of the BoD and Technical

Officer of Bridgnorth Aluminium Ltd.

Panos Lolos, Executive BoD Member & General Manager of the Copper Segment

Mr. Panos Lolos was born in 1972. He holds a B.A. in Political Science & International Studies from Panteion University,

an M.A. in International Economics from North Carolina State University and an MBA from the University of Piraeus.

From 2000 until 2001 he worked in AV VASSILOPOULOS S.A., a subsidiary of the Belgian food retailer DELHAIZE. Since

2001, he joined the heavy industry, having an experience in the domestic and exports sales of former “HALCOR S.A.” and

now “ELVALHALCOR HELLENIC COPPER AND ALUMINIUM INDUSTRY S.A.” (Copper Segment / Copper & Alloys Extrusion

Division – “HALCOR”) a leading European manufacturer that specializes in the production, processing and marketing of

copper and copper alloy products with dynamic commercial presence in the European and global markets. He undertook

the position of the General Manager of the Copper & Alloys Extrusion Division of ELVALHALCOR S.A. in 2020, whereas

today he also holds the position of the General Manager of the Copper Segment of the same company.

Mr. Lolos is the Chairman of the ASSOCIATION OF INDUSTRIES OF CENTRAL GREECE, member of the BoD of ELVALHALCOR

S.A., SOFIA MED A.D., ΕANEP-Ο.Α. S.A., ΕDEP-Ο.Α. S.A., the HELLENIC FEDERATION OF ENTERPRISES (SEV), in which he

holds the position of the Chairman of the International Trade Committee, the HELLENIC PRODUCTION – Industry

Roundtable for Growth, and registered member of the ECONOMIC CHAMBER OF GREECE.

He has a strong interest in technology, competition, pricing techniques, regulation, market analysis and marketing

strategies in the heavy industry.

Apart from industry-related topics, his pubic presence and his published articles in Greek and English are related to the

economy and the regulation policies.

Konstantinos Katsaros, Executive member

Mr. Katsaros is a Mechanical and Electrical Engineer of the National Technical University of Athens. He is an Aeronautical

Engineer of the Ecole Nationale Superieure d 'Aeronautique (Paris) and a Ph.D. Engineer of the University of Paris. He has

been working in the aluminium rolling division of ElvalHalcor (former Elval) since 1974 and he is mainly engaged in the

international development of the division. Previously he worked in Pechiney in France for 6 years. He is a member of the

Board of Directors of many companies, chairman and vice chairman of the Hellenic Aluminium Association and today is a

member of the Board of the European Union of Aluminium.

Annual Financial Report of 31 December 2021

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Nikolaos Koudounis, Non-executive member

Mr. Nikolaos Koudounis is a graduate of the Athens University of Economics and Business. He has been working in

subsidiaries of the VIOHALCO group since 1968 and served as the Financial Director of the aluminum-rolling sector of

ELVALHALCOR SA. (former ELVAL SA) (1983), General Manager of the aluminum-rolling sector of ELVALHALCOR SA

(former ELVAL SA) (2000) and CEO of FITCO SA (2004). Currently, he is the Vice Chairman of the BoD of SYMETAL SA, the

Chairman of the BoD of FITCO SA, a non- executive member of the BoD of ELVALHALCOR SA and a member of the Audit

Committee and the Remuneration and Nomination Committee of ELVALHALCOR SA. During his long-standing career, he

has performed audits for corporations operating in the production and processing of metal products. In addition, he has

published numerous articles in magazines and in the regional and Athenian press on development issues, spatial planning

issues, business parks and business taxation.

Furthermore, Mr. Koudounis has been the Chairman of the BoD of the Association of Industries of Central Greece (ΣΒΣΕ)

since 2003, Chairman of the BoD of the Managing Body of the Thisvi Industrial Area (DIA.VI.PE.THI.V SA), Chairman of the

BoD of the Inofyta Asopou Business Park Management Company (Ε.Δ.Ε.Π. Ο.Α. Α.Ε) and Vice Chairman of the BoD of the

Development Company of the Region of Central Greece (ΑΝΔΙΑ Α.Ε.). He is a member of the BoD of the Hellenic

Federation of Enterprises (SEV), of the Hellenic Association of Business Parks (ΕΣΕΠΠΑ), of the AgriFood Partnership (ΑΣΣΕ)

as well as of all the Regional Councils of the Region of Central Greece.

Christos-Alexis Komninos, Non-executive Member

Mr. Christos Komninos is a Graduate (MSc) of the Department of Chemical Engineering of the Technical University of

Istanbul (1971). During his career he has worked in many firms, like COCA-COLA 3E (1972-1987), where he assumed a

leading position, as CEO of Coca-Cola Bottlers Ireland (a subsidiary of COCA COLA 3E) in 1987-1990 and later as CEO of

the above said COCA COLA 3E until 2000, as Chairman and CEO, of PAPASTRATOS SA (2000-2004), as Executive Vice

Chairman of SHELMAN SA, ELMAR S.A., (2005-2010) and as Chairman of the BoD of Hellenic Petroleum SA (2011-2014).

In addition to the above, Mr. Komninos has been Vice Chairman of the BoD and member of the Executive Committee of

the Hellenic Federation of Enterprises (SEV) and he has been a member of the BoD of FINANSBANK (Turkey), of the BoD

of ANADOLU EFES (Turkey) and of the BoD of HALCOR SA.(current ELVALHALCOR SA) while today he is Vice Chairman of

the BoD of TRACE PLASTICS CO S.A.

During his career, Mr. Komninos has taken on important administrative duties and has gained experience in managing

companies with international activities. He is fluent in English, French, Italian and Turkish.

Elias Stassinopoulos, Non-executive member

Mr. Elias Stasinopoulos holds a Ph.D. from the Technical University of Clausthal-Zellerfeld in Germany and has been

working in the LHoist Group since 1994 in leading positions of responsibility. He speaks in addition to Greek, English,

French, German.

Aikaterini-Nafsika Kantzia, Non-executive member

Mrs. Aikaterini-Nafsika Kantzia holds a Degree in Law from National and Kapodistrian University of Athens; Upper Second-

Class Honours. As far as her professional experience, she practiced law from 1974-1993 at The Hellenic Chemical Products

and Fertilizers Company S.A., Chemical Industries of the BODOSSAKI Group, and at the Greek Wine and Spirits Company

S.A. and Larco S.A., belonging to the same group of companies. Within 1993-1996 she only worked for the Greek Wine

and Spirits Company S.A. and Larco S.A., due to the fact that The Hellenic Chemical Products and Fertilizers Company S.A.,

of the BODOSSAKI Group was put into liquidation. In 1988, she began collaborating with VIOHALCO group of companies

and offered her services as a freelancer to various subsidiary companies namely SIDENOR S.A., HELLENIC CABLES S.A.,

METEM S.A., VET S.A., VIOTIA CABLES S.A., ALUMINIUM OF ATHENS S.A., ELLINIKI XALIVDEMPORIKI S.A., ERLIKON S.A.,

VECTOR S.A., DEPAL S.A., SIDEP S.A, VIEM S.A., TELECABLES S.A., and STEELMETAL S.A. From 1995 until today she

stipulates services as an in - house attorney to the companies SIDENOR S.A. and STEELMET S.A. Furthermore, Mrs. Kantzia

has language diplomas in both German (Grosses Sprachdiplom) and French (Sorbonne II). She attains intermediate

knowledge of the English language.

Athanasia Kleniati Papaionnou, Non-executive member

Ms. Athanasia Kleniati Papaioannou is a graduate of the School of Economics of the University of the Rhine "Frederick -

William" in Bonn. The subject of her thesis was the comparison of regional productivity by industry in Greece and the

conducting of economic policy conclusions. As a professional, she has participated in companies active in the retail and

wholesale trade. She was a research associate at the University of Piraeus (Department of Economics) between 1980 and

1998 and in this setting she participated in the University's research programs and taught macroeconomic and

Annual Financial Report of 31 December 2021

Page | 58

microeconomic theory courses. Moreover, she has been involved for two years in conducting and compiling studies in

various industries under her role as a research associate of the ICAP Group. She has knowledge of German and English.

Vasileios Loumiotis, Independent Non-executive member

Mr. Vasileios Loumiotis is a graduate of the Department of Business Administration and Management (1973) of the

Athens University of Business and Economics (formerly ASOEE) and holds a Master’s Degree in Business Administration

(M.B.A.) from Roosevelt University in Chicago (1979). He is an auditor since 1980 and especially as a member of the

Institute of Chartered Accountants of Greece (ΣΟΛ) from 1980 until 1992 and the Institute of Certified Public Accountants

of Greece (ΣΟΕΛ) since 1993 until today. From 1993, under his capacity of the Certified Public Accountant, Mr. Loumiotis

participates in “Associated Certified Public Accountants S.A.” (“SOL S.A.”) a partner. During his career as a Certified Public

Accountant, he was elected, as auditor, by a significant number of companies to perform audits of annual financial

statements. During his tenure as an auditor, he completed projects, as special audits for the initial public offering of

companies in the Athens Exchange, corporate valuations, application of International Financial Reporting Standards, for

a substantial number of companies. In addition, he served as a member of the technical desk of “SOL S.A.” from 2006

until March of 2009. In regards to his teaching experience, he is serves as a professor for the Training Institute of Certified

Public Accountants of Greece (Ι.Ε.Σ.Ο.Ε.Λ.) since 1997, a professor for National and Kapodistrian University of Athens, for

the post-graduate course “Master in Applied Auditing”, from 2006 until today and a professor for the University of

Macedonia for the post-graduate course “Master in Applied Accounting and Auditing” since 2011 to date. In addition to

the above, he serves as a professor of “SOL S.A.” for the subjects of International Financial Reporting Standards,

International Auditing Standards and Consolidated Financial Statements.

Ploutarchos Sakellaris, Independent, Non-executive member

Mr. Ploutarchos Sakellaris is Professor of Economics and Finance at Athens University of Economics and Business, focusing

his research and teaching on macroeconomics, finance and banking. In parallel, Mr. Sakellaris is a member of the Board

of Directors and Chairman of the Audit Committee of CEPAL Hellas, a company servicing loans and credit claims, and a

member of the Board of Directors of Hellas Capital Leasing. Mr. Sakellaris was Vice-President and Member of the

Management Committee of the European Investment Bank (2008-2012), where he was responsible for risk management

and financing in the energy sector. During the period 2004-2008, he was Chairman of the Council of Economic Advisers

at the Ministry of Finance, Deputy to the Minister of Finance in the European Union Councils of Eurogroup and ECOFIN,

and a member of the EU Economic and Financial Committee (EFC) and the Eurozone Working Group (EWG). He has been

a member of the Board of Directors and the Audit Committee of the TITAN Group (2013-2019), a member of the Board

of Directors of CreditM (2013-2018), a member of the Board of Directors, the Audit Committee and the Corporate

Governance and Nominations Committee of the National Bank of Greece (2004-2008), member of the Board of Directors

of the Public Debt Management Agency (2004-2008), as well as Deputy Governor for Greece at the World Bank (2004-

2008). His professional career includes the positions of economist at the US Federal Reserve Board (1998-2000), visiting

expert at the European Central Bank (2001-2003) and professor at the University of Maryland (1991-2004). Mr. Sakellaris

holds a Ph.D. in economics and a M.A. and a M. Phil. from Yale University. He also holds a B.A. degree in economics and

computer science from Brandeis University.

Ourania Ekaterinari, Independent Non-executive member

Ourania Ekaterinari holds a degree in electrical engineering from Aristotle University and an MBA from City University

Business School. During the period 2017-2021, Ourania Ekaterinari served as CEO and member of the Board of Directors

of the Hellenic Corporation of Assets and Participations SA (‘’HCAP’’). HCAP is a holding company, owning a big portfolio

of state real estate assets as well as participations in large state-owned enterprises active in key sectors of the Greek

economy with the aim to optimize their operations but also develop and exploit them so as to generate more revenues

for the State. Before these positions, Ourania was Partner at Ernst & Young (EY) in Transaction Advisory Services and also

Energy Sector leader for Southeast Europe. Between 2010 - 2015, she was Deputy CEO of Public Power Corporation (PPC),

the largest Greek electric utility, and member of its Board of Directors. She has also worked for more than 10 years in

corporate & investment banking, in London and in Athens for Deutsche Bank, BNP Paribas and Eurobank. In the 90s, she

worked in the oil industry in the Caspian region for Texaco in London as well as an electrical engineer in Greece and

Denmark. Mrs. Ekaterinari is member of the European Network for Women in Leadership (WIL), member of the Advisory

Board of Dianeosis, member of the Leadership Committee of American Hellenic Chamber of Commerce (AmCham),

member of the Council for Competitiveness of Greece (COMPETEGR) and until recently member of the Hellenic Corporate

Governance Council (HCGC). She was also member of the Energy Committee of the American-Hellenic Chamber of

Commerce, member of the Board of the Greek Independent Transmission Operator and Deputy Chairman of the Energy

Committee of the Technical Chamber of Greece.

Annual Financial Report of 31 December 2021

Page | 59

Thomas George Sofis, Independent Non-executive member

Mr. Thomas George Sofis is graduate of the West Point military academy in the USA, and started his career as a pilot of

the US Air Force. After that, he assumed various administrative positions in the procurement department of ACF

Industries and Westinghouse Corporation. During his long-standing professional career assumed managerial positions in

Reynolds Metal Co., Findal SRL and served as sales representative of ELVAL’s products in Italy.

Georgios Lakkotrypis, Independent Νon-executive member

Mr. Georgios Lakkotrypis holds a BSc. degree in Computer Science and Mathematics from the University of Keele in the

United Kingdom (1988-1991) and an MBA in Business Administration, from the University of Colorado in the United States

(1993-1995). Between 1991 and 1993 he served as IT Systems Administrator for J & P, one of the top construction

companies in the world, where he overlooked the company’s IT systems in Benghazi, Libya. Subsequently, he became

part of the IBM team in Nicosia, Cyprus (1996-2002) where he worked in sales, and customer and partner relationships.

He then worked for eleven years at Microsoft Corporation, as Cyprus & Malta Business Development Manager (2002-

2004), Cyprus Country Manager (2004-2008), Cyprus & Malta Regional Country Manager (2008-2011) and CEE Multi-

Country Public Sector Director (2011-2013). During this time, he also served as a non-executive member of the Board of

Directors of the then newly established University of Nicosia Research Foundation (2008-2013), the first Board of

Directors of the Cyprus Investment Promotion Agency (2007-2011) and the first Board of Directors of the Natural Gas

Public Company (2009-2013). In March 2013, Mr. Lakkotrypis was appointed as Minister of Energy, Commerce, Industry

and Tourism of the Republic of Cyprus, a position in which he was reappointed in March 2018. He concluded his term in

office in July 2020. Currently, through his private firm, LMA Advisory Ltd, Mr. Lakkotrypis is providing consultancy services

in areas such as digital transformation and energy transition, while he serves on the board of directors of Ronin Europe

Ltd as a non-executive member.

KEY EXECUTIVES OTHER THAN MEMBERS OF THE BOARD OF DIRECTORS

Spyridon Kokkolis, Group CFO

Mr. Kokkolis is an economist, graduate of Athens University of Economics. Mr. Kokkolis has worked for the internal

auditing department of Viohalco Group since 1993. His professional career includes the positions of Head of Financial

Planning and reporting (2001-2003) and Group CFO (2004-2017) of HALCOR S.A., where he was responsible for M&A

activities and projects, including the merger with FITCO in 2006 and subsequent spin-off in 2010, the acquisition of 50%

of NEDZINK in 2017 and the merger with ELVAL within the same year. He currently holds the position of Group CFO of

ELVALHALCOR S.A. since the merger with ELVAL and his responsibilities include, among others, the supervision of the

Supply Chain Department of the Copper Tubes Division, the Preparation for Bond Issuance and Risk and Inventory

management of metals exposure. He also served as BoD member of ELVALHALCOR S.A. during the period 2017-2021.

Nikolaos Karabateas, Deputy General Manager of the Aluminium Segment

Mr. Nikolaos Karabateas holds a degree in Mechanical Engineering from the National Technical University of Athens

(1988-1993) and a Ph.D. in Mechanical Engineering from Imperial College London (1993-1997). He has been working in

the Aluminum Rolling Segment of ELVALHALCOR (formerly ELVAL) since 1999. In 2012 he took over the position of

Commercial Director where he was responsible for the sales, marketing and development strategy in the international

markets. In 2021 he took over the position of Deputy General Manager of the Aluminum Segment of ELVALHALCOR.

Stavros Voloudakis, Aluminum Segment Subsidiaries Coordinator

Mr. Stavros Voloudakis is a graduate Production & Management Engineer from the Technical University of Crete (1989),

holder of a postgraduate degree M.Sc. in Artificial Intelligence (AI) from UGA University USA (1992) as well as

postgraduate programs for senior executives from IMD (2007). Between 1996-2001 he was the coordinator of central

procurement agreements for Intracom Telecom SA. From 1994-2004 he was a professor (Part Time) at the American

College of Greece (Deree College) while from 2001 he took over the General Management of TOP ELECTRONIC

COMPONENTS SA. Since September 2003 he has been a member of the VIOHALCO Group and has been the Director of

Central Procurement of the Group. Then, from 2015 and for the next 16 years, he was the Deputy General Manager,

initially of ELVAL SA. and then ELVALHALCOR SA while at the same time from 2015 until May 2021 he was an Executive

Member of the Board of Directors of these companies. Since the beginning of 2021, he has taken over as Coordination

Director of the Aluminum Subsidiaries of ELVALHALCOR as well as General Manager of the Subsidiary ANOXAL SA. At the

same time, Mr. Voloudakis is the Executive Chairman of the subsidiary VIOMAL SA as well as the Executive Board Member

of the subsidiaries SYMETAL SA, VEPAL SA, ANOXAL SA, ELVAL COLOR SA and ELVIOK SA.

Annual Financial Report of 31 December 2021

Page | 60

NUMBER OF SHARES HELD BY MEMBERS OF THE BOARD OF DIRECTORS AND KEY EXECUTIVES AS

OF THE DATE HEREOF

(Article 18 par. 3 Ν. 4706/2020 and protocol nr. 425/21.02.2022 letter of the Hellenic Capital Market Commission to the

listed companies)

On the date hereof, the number of shares held by each member of the Board of Directors and each key executive officer

of the Company is as follows:

FULL NAME

CAPACITY

NR. OF SHARES

Michael N. Stassinopoulos

Chairman, non-executive Director

1,294,771

Spyridon Kokkolis

Group CFO

50,000

Stavros Voloudakis

Aluminum Segment Subsidiaries

Coordinator

15,000

Vice-Chairman of the

BoD

General Manager of

the Aluminium

Segment & Member of

the BoD

General Manager of

the Copper Segment &

Member of the BoD

Group Chief Financial

Officer

DIMITRIOS

KYRIAKOPOULOS

LAMPROS VAROUCHAS

PANAGIOTIS

LOLOS

SPYRIDON KOKKOLIS

PricewaterhouseCoopers S.A., T: +30 210 6874400, www.pwc.gr

Athens: 268 Kifissias Avenue, 152 32 Halandri | T: +30 210 6874400

Thessaloniki: Agias Anastasias & Laertou 16 str., 55535 Pylaia | T: +30 2310 488880

[Translation from the original text in Greek]

Independent auditor’s report

To the Shareholders of “Elvalhalcor Hellenic Coppers and Aluminium Industry SA”

Report on the audit of the separate and consolidated financial statements

Our opinion

We have audited the accompanying separate and consolidated financial statements of Elvalhalcor Hellenic

Coppers and Aluminium Industry SA (Company and Group) which comprise the separate and consolidated

statement of financial position as of 31 December 2021, the separate and consolidated income statement and

statement of comprehensive income, statement of changes in equity and cash flow statements for the year then

ended, and notes to the separate and consolidated financial statements, including a summary of significant

accounting policies.

In our opinion, the consolidated financial statements present fairly, in all material respects the separate and

consolidated financial position of the Company and the Group as at 31

December 2021, their separate and

consolidated financial performance and their separate and consolidated cash flows for the year then ended in

accordance with International Financial Reporting Standards, as adopted by the European Union and comply

with the statutory requirements of Law 4548/2018.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (ISAs), as they have been

transposed into Greek Law. Our responsibilities under those standards are further described in the Auditor’s

responsibilities for the audit of the separate and consolidated financial statements section of our report.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our

opinion.

Independence

During our audit we remained independent of the Company and the Group in accordance with the International

Ethics Standards Board for Accountants’ Code of Ethics for Professional Accountants (IESBA Code) that has

been transposed into Greek Law, and the ethical requirements of Law 4449/2017 and of Regulation (EU) No

537/2014, that are relevant to the audit of the separate and consolidated financial statements in Greece. We

have fulfilled our other ethical responsibilities in accordance with Law 4449/2017, Regulation (EU) No 537/2014

and the requirements of the IESBA Code.

We declare that the non-audit services that we have provided to the Company and its subsidiaries are in

accordance with the aforementioned provisions of the applicable law and regulation and that we have not

provided non-audit services that are prohibited under Article 5(1) of Regulation (EU) No 537/2014.

The non-audit services that we have provided to the Company and its subsidiaries, in the period from 1

January 2021 to 31

December 2021 during the year ended as at 31 December 2021, are disclosed in the note

32 to the separate and consolidated financial statements.

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of

the separate and consolidated financial statements of the current period. These matters were addressed in the

context of our audit of the separate and consolidated financial statements as a whole, and in forming our

opinion thereon, and we do not provide a separate opinion on these matters

Key audit matter

How our audit addressed the key audit matter

Loan Liabilities

(Separate and Consolidated financial

statements)

As disclosed in Note 22 of the attached financial

statements, as at 31

December 2021 the

Group had loan liabilities amounting to Euro 878

million, of which amount Euro 113,4 million

related to instalments of long-term and

syndicated loans and finance lease liabilities,

expiring in the short-term as at the balance

sheet date.

The contracts of the long-term syndicated loans

contain financial covenants and other terms,

such as change of control clauses.

As disclosed in Note 22 of the attached financial

statements, in 2021 the Group has obtained

new loan contracts of Euro 290 million.

For the evaluation of refinancing and the

available future cash flows of the Group,

management applied assumptions and

estimates. The risk of non-compliance to the

terms of the loan agreements was considered a

significant audit risk. For these reasons, we

consider this area to be a key audit matter.

We performed the following audit procedures:

• We obtained the agreements of the long term and syndicated

loans and gained understanding of the terms of the

agreements.

• We recomputed financial loan covenants ratios and

confirmed the assessment of the management in relation to

compliance with those covenant ratios.

• We examined the accounting classification of the new and

amended contract relating to the main loans.

• We tested the key assumptions used by the Group in the

future cash flows. We utilised our internal valuation experts

to assess the reasonableness of the assumptions used by

management.

• We assessed the reliability of management’s forecast by

reviewing actual performance against previous forecasts.

• We tested the mathematical accuracy of the cash flow

models and agreed relevant data to approved financial

budgets.

• We assessed management’s estimate as regards the

adequacy of future cash flows relating to the repayment of

loan obligations of the Group.

• As a result of our work, we did not identify exceptions as

regards, recognition, measurement and classification of the

loan liabilities and considered that the assumptions and

estimates of management are within reasonable range. We

found that the related disclosures included in the financial

statements were adequate.

Other Information

The members of the Board of Directors are responsible for the Other Information. The Other Information, which

is included in the Annual Report in accordance with Law 3556/2007, is the Explanatory Report of the Board of

Directors, the Corporate Governance Report, the Non-financial statements, the Statement of Members of the

Board of Directors and the Report of the Board of Directors (but does not include the financial statements and

our auditor’s report thereon), which we obtained prior to the date of this auditor’s report.

Our opinion on the separate and consolidated financial statements does not cover the Other Information and

except to the extent otherwise explicitly stated in this section of our Report, we do not express an audit opinion

or other form of assurance thereon.

In connection with our audit of the separate and consolidated financial statements, our responsibility is to read

the Other Information identified above and, in doing so, consider whether the Other Information is materially

inconsistent with the separate and consolidated financial statements or our knowledge obtained in the audit, or

otherwise appears to be materially misstated.

We considered whether the Board of Directors Report includes the disclosures required by Law 4548/2018 and

the Corporate Governance Statement required by article 152 of Law 4548/2018 has been prepared.

Based on the work undertaken in the course of our audit, in our opinion:

● The information given in the the Board of Directors’ Report for the year ended at 31

December 2021 is

consistent with the separate and consolidated financial statements,

● The Board of Directors’ Report has been prepared in accordance with the legal requirements of articles

150,151,153 and 154 of Law 4548/2018,

● The Corporate Governance Statement provides the information referred to items c and d of paragraph 1 of

article 152 of Law 4548/2018.

In addition, in light of the knowledge and understanding of the Company and Group and their environment

obtained in the course of the audit, we are required to report if we have identified material misstatements in the

Board of Directors’ Report and Other Information that we obtained prior to the date of this auditor’s report. We

have nothing to report in this respect.

Responsibilities of Board of Directors and those charged with governance for the separate and

consolidated financial statements

The Board of Directors is responsible for the preparation and fair presentation of the separate and consolidated

financial statements in accordance with International Financial Reporting Standards, as adopted by the European

Union and comply with the requirements of Law 4548/2018, and for such internal control as the Board of Directors

determines is necessary to enable the preparation of separate and consolidated financial statements that are

free from material misstatement, whether due to fraud or error.

In preparing the separate and consolidated financial statements, the Board of Directors is responsible for

assessing the Company’s and Group’s ability to continue as a going concern, disclosing, as applicable, matters

related to going concern and using the going concern basis of accounting unless Board of Directors either intends

to liquidate the Company and Group or to cease operations, or has no realistic alternative but to do so.

Those charged with governance are responsible for overseeing the Company’s and Group’s financial reporting

process.

Auditor’s responsibilities for the audit of the separate and consolidated financial statements

Our objectives are to obtain reasonable assurance about whether the separate and consolidated financial

statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an

auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a

guarantee that an audit conducted in accordance with ISAs will always detect a material misstatement when it

exists. Misstatements can arise from fraud or error and are considered material if, individually or in the

aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis

of these separate and consolidated financial statements.

As part of an audit in accordance with ISAs, we exercise professional judgment and maintain professional

scepticism throughout the audit. We also:

● Identify and assess the risks of material misstatement of the separate and consolidated financial

statements, whether due to fraud or error, design and perform audit procedures responsive to those

risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The

risk of not 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.

● Obtain an understanding of internal control relevant to the audit in order to design audit procedures that

are appropriate in the circumstances, but not for the purpose of expressing an opinion on the

effectiveness of the Company’s and Group’s internal control.

● Evaluate the appropriateness of accounting policies used and the reasonableness of accounting

estimates and related disclosures made by the Board of Directors.

● Conclude on the appropriateness of Board of Directors’ use of the going concern basis of accounting

and, based on the audit evidence obtained, whether a material uncertainty exists related to events or

conditions that may cast significant doubt on the Company’s and Group’s ability to continue as a going

concern. If we conclude that a material uncertainty exists, we are required to draw attention in our

auditor’s report to the related disclosures in the separate and consolidated financial statements or, if

such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence

obtained up to the date of our auditor’s report. However, future events or conditions may cause the

Company and Group to cease to continue as a going concern.

● Evaluate the overall presentation, structure and content of the separate and consolidated financial

statements, including the disclosures, and whether the separate and consolidated financial statements

represent the underlying transactions and events in a manner that achieves fair presentation.

● Obtain sufficient appropriate audit evidence regarding the financial information of the entities or business

activities within the Group to express an opinion on the consolidated financial statements. We are

responsible for the direction, supervision and performance of the Company and Group audit. We remain

solely responsible for our audit opinion.

We communicate with those charged with governance regarding, among other matters, the planned scope and

timing of the audit and significant audit findings, including any significant deficiencies in internal control that we

identify during our audit.

We also provide those charged with governance with a statement that we have complied with relevant ethical

requirements regarding independence, and to communicate with them all relationships and other matters that

may reasonably be thought to bear on our independence, and where applicable, related safeguards.

From the matters communicated with those charged with governance, we determine those matters that were of

most significance in the audit of the separate and consolidated financial statements of the current period and

are therefore the key audit matters. We describe these matters in our auditor’s report.

Report on other legal and regulatory requirements

1. Additional Report to the Audit Committee

Our opinion on the accompanying separate and consolidated financial statements is consistent with our

Additional Report to the Audit Committee of the Company.

2. Appointment

We were first appointed as auditors of the Company by the decision of the annual general meeting of

shareholders on 26/5/2017. Our appointment has been renewed annually by the decision of the annual general

meeting of shareholders for a total uninterrupted period of appointment of 5 years.

3. Operating Regulation

"The Company has an Operating Regulation in accordance with the content provided by the provisions of

article 14 of Law 4706/2020".

4. Assurance Report on the European Single Electronic Format

We have examined the digital files of ABC (hereinafter referred to as the “Company and / or Group”), which

were compiled in accordance with the European Single Electronic Format (ESEF) defined by the Commission

Delegated Regulation (EU) 2019/815, as amended by Regulation (EU) 2020/1989 (hereinafter “ESEF

Regulation”), and which include the separate and consolidated financial statements of the Company and the

Group for the year ended December 31, 2021, in XHTML format «213800EYWS2GY56AWP42-2021-12-31-

el.xhtml», as well as the provided XBRL file «213800EYWS2GY56AWP42-2021-12-31-el.xhtml» with the

appropriate marking up, on the aforementioned consolidated financial statements.

Regulatory framework

The digital files of the European Unified Electronic Format (ESEF) are compiled in accordance with ESEF

Regulation and 2020 / C 379/01 Interpretative Communication of the European Commission of 10 November

2020, as provided by Law 3556/2007 and the relevant announcements of the Hellenic Capital Market

Commission and the Athens Stock Exchange (hereinafter “ESEF Regulatory Framework”).

In summary, this Framework includes the following requirements:

• All annual financial reports should be prepared in XHTML format.

• For consolidated financial statements in accordance with International Financial Reporting Standards, the

financial information stated in the Statement of Comprehensive Income, the Statement of Financial Position,

the Statement of Changes in Equity and the Statement of Cash Flows should be marked-up with XBRL 'tags',

according to the ESEF Taxonomy, as in force. The technical specifications for ESEF, including the relevant

classification, are set out in the ESEF Regulatory Technical Standards.

The requirements set out in the current ESEF Regulatory Framework are suitable criteria for formulating a

reasonable assurance conclusion.

Responsibilities of the management and those charged with governance

The management is responsible for the preparation and submission of the separate and consolidated financial

statements of the Company and the Group, for the year ended December 31, 2021, in accordance with the

requirements set by the ESEF Regulatory Framework, as well as for those internal controls that management

identifies as necessary, to enable the compilation of digital files free of material error due to either fraud or

error.

Auditor’s responsibilities

Our responsibility is to plan and carry out this assurance work, in accordance with no. 214/4 / 11.02.2022

Decision of the Board of Directors of the Hellenic Accounting and Auditing Standards Oversight Board

(HAASOB) and the "Guidelines in relation to the work and the assurance report of the Certified Public

Accountants on the European Single Electronic Format (ESEF) of issuers with securities listed on a regulated

market in Greece" as issued by the Board of Certified Auditors on 14/02/2022 (hereinafter "ESEF Guidelines"),

providing reasonable assurance that the separate and consolidated financial statements of the Company and

the Group prepared by the management in accordance with ESEF comply in all material respects with the

applicable ESEF Regulatory Framework.

Our work was carried out in accordance with the Code of Ethics for Professional Accountants of the

International Ethics Standard Board for Accountants (IESBA Code), which has been transposed into Greek Law

and in addition we have fulfilled the ethical responsibilities of independence, according to Law 4449/2017 and

the Regulation (EU) 537/2014.

The assurance work we conducted is limited to the procedures provided by the ESEF Guidelines and was

carried out in accordance with International Standard on Assurance Engagements 3000, “Assurance

Engagements other than Audits or Reviews of Historical Financial Information''. Reasonable assurance is a

high level of assurance, but it is not a guarantee that this work will always detect a material misstatement

regarding non-compliance with the requirements of the ESEF Regulation.

Conclusion

Based on the procedures performed and the evidence obtained, we conclude that the separate and

consolidated financial statements of the Company and the Group for the year ended December 31, 2021, in

XHTML file format «213800EYWS2GY56AWP42-2021-12-31-el.xhtml», as well as the provided XBRL file

«213800EYWS2GY56AWP42-2021-12-31-el.xhtml» with the appropriate marking up, on the aforementioned

consolidated financial statements have been prepared, in all material respects, in accordance with the

requirements of the ESEF Regulatory Framework.

PricewaterhouseCoopers S.A.

Certified Auditors – Accountants Athens, 15 March 2022

268, Kifissias Avenue The Certified Auditor Accountant

152 32 Halandri Konstantinos Michalatos

SOEL Reg. 113 SOEL Reg. No 17701

Annual Financial Report of 31 December 2021

Page | 61

[Translation from the original text in Greek]

Independent auditor’s report

To the Shareholders of “Elvalhalcor Hellenic Coppers and Aluminium Industry SA”

Report on the audit of the separate and consolidated financial

statements

Our opinion

We have audited the accompanying separate and consolidated financial statements

of “Elvalhalcor Hellenic Coppers and Aluminium Industry SA” (Company and the

Group) which comprise the separate and consolidated statement of financial

position as of 31 December 2019, the separate and consolidated income statement

and statement of comprehensive income, statement of changes in equity and

statement of cash flow for the year then ended, and notes to the separate and

consolidated financial statements, including a summary of significant accounting

policies.

In our opinion, the consolidated financial statements present fairly, in all material

respects the separate and consolidated financial position of the Company and the

Group as at 31 December 2019, their separate and consolidated financial

performance and their separate and consolidated cash flows for the year then ended

in accordance with International Financial Reporting Standards, as adopted by the

European Union and comply with the statutory requirements of Law 4548/2018.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing

(ISAs), as they have been transposed into Greek Law. Our responsibilities under

those standards are further described in the Auditor’s responsibilities for the audit

of the separate and consolidated financial statements section of our report.

We believe that the audit evidence we have obtained is sufficient and appropriate to

provide a basis for our opinion.

Independence

During our audit we remained independent of the Company and the Group in

accordance with the International Ethics Standards Board for Accountants’ Code of

Ethics for Professional Accountants (IESBA Code) that has been transposed into

Greek Law, and the ethical requirements of Law 4449/2017 and of Regulation (EU)

No 537/2014, that are relevant to the audit of the separate and consolidated

financial statements in Greece. We have fulfilled our other ethical responsibilities in

accordance with Law 4449/2017, Regulation (EU) No 537/2014 and the

requirements of the IESBA Code.

We declare that the non-audit services that we have provided to the Company and

Annual Financial Report of 31 December 2021

Page | 62

its subsidiaries are in accordance with the aforementioned provisions of the

applicable law and regulation and that we have not provided non-audit services that

are prohibited under Article 5(1) of Regulation (EU) No 537/2014.

The non-audit services that we have provided to the Company and its subsidiaries,

in the period from 1

January 2018 to 31 December 2018 during the year ended as

at 31 December 2018, are disclosed in the note 32 to the separate and consolidated

financial statements.

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most

significance in our audit of the separate and consolidated financial statements of the

current period. These matters were addressed in the context of our audit of the

separate and consolidated financial statements as a whole, and in forming our

opinion thereon, and we do not provide a separate opinion on these matters.

Key audit matters

How our audit addressed the key audit

matters

Loan Liabilities

(Separate and Consolidated financial

statements)

As disclosed in Note 22 of the attached financial

statements, as at 31 December 2019 the Group had loan

liabilities amounting to Euro 615mn, of which amount

Euro 74.6mn related to instalments of long-term and

syndicated loans and finance lease liabilities, expiring in

the short-term as at the balance sheet date.

The contracts of the long-term syndicated loans contain

financial covenants and other terms, such as change of

control clauses.

As disclosed in Note 22 of the attached financial

statements, in 2019 the Group has obtained new loan

contracts of Euro 87 mn, and agreed the maturity

extension of existing loans amounting to Euro 70.5mn.

For the evaluation of refinancing and the available

future cash flows of the Group, management applied

assumptions and estimates. The risk of non-compliance

to the terms of the loan agreements was considered a

significant audit risk. For these reasons, we consider

this area to be a key audit matter.

We performed the following audit procedures:

• We obtained the agreements of the long term and

syndicated loans and gained understanding of the

terms of the agreements.

• We recomputed financial loan covenants ratios

and confirmed the assessment of the management

in relation to compliance with those covenant

ratios.

• We examined the accounting classification of the

new and amended contract relating to the main

loans.

• We tested the key assumptions used by the

Group in the future cash flows

• We assessed the reliability of management’s

forecast by reviewing actual performance

against previous forecasts.

Annual Financial Report of 31 December 2021

Page | 63

• We tested the mathematical accuracy of the

cash flow models and agreed relevant data to

approved financial budgets.

• We assessed management’s estimate as regards

the adequacy of future cash flows relating to the

repayment of loan obligations of the Group.

• As a result of our work, we did not identify

exceptions as regards, recognition, measurement

and classification of the loan liabilities and

considered that the assumptions and estimates of

management are within reasonable range. We

found that the related disclosures included in the

financial statements were adequate.

Other Information

The members of the Board of Directors are responsible for the Other Information.

The Other Information, which is included in the Annual Report in accordance with

Law 3556/2007, is the Statement of Members of the Board of Directors, Report of

the Board of Directors, Explanatory Report of the Board of Directors, Corporate

Governance Report and the Non-financial statements (but does not include the

financial statements and our auditor’s report thereon), which we obtained prior to

the date of this auditor’s report.

Our opinion on the separate and consolidated financial statements does not cover

the Other Information and except to the extent otherwise explicitly stated in this

section of our Report, we do not express an audit opinion or other form of assurance

thereon.

In connection with our audit of the separate and consolidated financial statements,

our responsibility is to read the Other Information identified above and, in doing so,

consider whether the Other Information is materially inconsistent with the separate

and consolidated financial statements or our knowledge obtained in the audit, or

otherwise appears to be materially misstated.

We considered whether the Board of Directors Report includes the disclosures

required by Law 4548/2018 and the Corporate Governance Statement required by

article 152 of Law 4548/2018 has been prepared.

Annual Financial Report of 31 December 2021

Page | 64

Based on the work undertaken in the course of our audit, in our opinion:

• The information given in the the Board of Directors’ Report for the year ended at 31 December

2019 is consistent with the separate and consolidated financial statements,

• The Board of Directors’ Report has been prepared in accordance with the legal requirements of

articles 150,151,153 and 154 of Law 4548/2018,

• The Corporate Governance Statement provides the information referred to items c and d of

paragraph 1 of article 152 of Law 4548/2018.

In addition, in light of the knowledge and understanding of the Company and Group

and their environment obtained in the course of the audit, we are required to report

if we have identified material misstatements in the Board of Directors’ Report and

Other Information that we obtained prior to the date of this auditor’s report. We

have nothing to report in this respect.

Responsibilities of Board of Directors and those charged with

governance for the separate and consolidated financial statements

The Board of Directors is responsible for the preparation and fair presentation of

the separate and consolidated financial statements in accordance with International

Financial Reporting Standards, as adopted by the European Union and comply with

the requirements of Law 4548/2018, and for such internal control as the Board of

Directors determines is necessary to enable the preparation of separate and

consolidated financial statements that are free from material misstatement, whether

due to fraud or error.

In preparing the separate and consolidated financial statements, the Board of

Directors is responsible for assessing the Company’s and Group’s ability to continue

as a going concern, disclosing, as applicable, matters related to going concern and

using the going concern basis of accounting unless Board of Directors either intends

to liquidate the Company and Group or to cease operations, or has no realistic

alternative but to do so.

Those charged with governance are responsible for overseeing the Company’s and

Group’s financial reporting process.

Auditor’s responsibilities for the audit of the separate and consolidated

financial statements

Our objectives are to obtain reasonable assurance about whether the separate and

consolidated financial statements as a whole are free from material misstatement,

whether due to fraud or error, and to issue an auditor’s report that includes our

opinion. Reasonable assurance is a high level of assurance, but is not a guarantee

that an audit conducted in accordance with ISAs will always detect a material

misstatement when it exists. Misstatements can arise from fraud or error and are

considered material if, individually or in the aggregate, they could reasonably be

expected to influence the economic decisions of users taken on the basis of these

separate and consolidated financial statements.

As part of an audit in accordance with ISAs, we exercise professional judgment and

maintain professional scepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the separate and consolidated

financial statements, whether due to fraud or error, design and perform audit procedures

responsive to those risks, and obtain audit evidence that is sufficient and appropriate to

provide a basis for our opinion. The risk of not detecting a material misstatement resulting

Annual Financial Report of 31 December 2021

Page | 65

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.

• Obtain an understanding of internal control relevant to the audit in order to design audit

procedures that are appropriate in the circumstances, but not for the purpose of expressing

an opinion on the effectiveness of the Company’s and Group’s internal control.

• Evaluate the appropriateness of accounting policies used and the reasonableness of

accounting estimates and related disclosures made by the Board of Directors.

• Conclude on the appropriateness of Board of Directors’ use of the going concern basis of

accounting and, based on the audit evidence obtained, whether a material uncertainty exists

related to events or conditions that may cast significant doubt on the Company’s and Group’s

ability to continue as a going concern. If we conclude that a material uncertainty exists, we

are required to draw attention in our auditor’s report to the related disclosures in the

separate and consolidated financial statements or, if such disclosures are inadequate, to

modify our opinion. Our conclusions are based on the audit evidence obtained up to the date

of our auditor’s report. However, future events or conditions may cause the Company and

Group to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the separate and consolidated

financial statements, including the disclosures, and whether the separate and consolidated

financial statements represent the underlying transactions and events in a manner that

achieves fair presentation.

• Obtain sufficient appropriate audit evidence regarding the financial information of the

entities or business activities within the Group to express an opinion on the consolidated

financial statements. We are responsible for the direction, supervision and performance of

the Company and Group audit. We remain solely responsible for our audit opinion.

We communicate with those charged with governance regarding, among other

matters, the planned scope and timing of the audit and significant audit findings,

including any significant deficiencies in internal control that we identify during our

audit.

We also provide those charged with governance with a statement that we have

complied with relevant ethical requirements regarding independence, and to

communicate with them all relationships and other matters that may reasonably be

thought to bear on our independence, and where applicable, related safeguards.

From the matters communicated with those charged with governance, we determine

those matters that were of most significance in the audit of the separate and

consolidated financial statements of the current period and are therefore the key

audit matters. We describe these matters in our auditor’s report.

Report on other legal and regulatory requirements

1. Additional Report to the Audit Committee

Our opinion on the accompanying separate and consolidated financial statements is consistent

with our Additional Report to the Audit Committee of the Company.

2. Appointment

We were first appointed as auditors of the Company by the decision of the annual general meeting

of shareholders on 26/5/2017. Our appointment has been renewed annually by the decision of the

annual general meeting of shareholders for a total uninterrupted period of appointment of 3 years.

Annual Financial Report of 31 December 2021

Page | 66

Annual Financial Report of 31 December 2021

Page | 67

Annual Financial Statements (Group and Company) as at 31 December 2021 according to International

Financial Reporting Standards

THE VICE-CHAIRMAN OF

THE BOARD OF

DIRECTORS

THE GENERAL MANAGER

OF THE ALUMINIUM

SEGMENT AND MEMBER

OF THE BOD

THE GENERAL MANAGER

OF THE COPPER

SEGMENT AND MEMBER

OF THE BOD

THE GROUP CHIEF

FINANCIAL OFFICER

DIMITRIOS KYRIAKOPOULOS

ID Card No. AK 695653

LAMPROS VAROUCHAS

ID Card No. AB 535203

PANAGIOTIS LOLOS

ID Card No. ΑΗ 131173

SPYRIDON KOKΚOLIS

ID Card No. AN 659640

Reg.Nr. A’ Class 20872

ELVALHALCOR SA

G.C.Registry.: 303401000

SA Registry No: 2836/06/B/86/48

SEAT: Athens Tower, Building B, 2-4Mesogeion Avenue

Annual Financial Report of 31 December 2021

Page | 68

I. Statement of Financial Position

GROUP

COMPANY

EUR

2021

2020

2021

2020

ASSETS

Note

€ '000

Non-current assets

Property, plant and equipment

967,684

851,942

685,581

582,956

Right of use assets

22,021

19,734

16,989

17,838

Intangible assets and goodwill

89,929

79,474

70,329

70,627

Investment property

3,244

6,267

17,499

18,714

Investments in Viohalco subsidiaries

269,353

271,359

Investments in Viohalco associates

29,964

91,745

30,417

84,965

Other Investments

4,231

4,301

4,189

2,185

Deferred income tax assets

1,679

172

Derivatives

Trade and other receivables

5,048

2,748

2,890

2,403

Non-current loan receivables

3,975

1,123,801

1,060,421

1,097,248

1,055,086

Current Assets

Inventories

697,605

503,773

436,739

308,816

Trade and other receivables

298,243

254,606

251,758

232,555

Income tax receivables

206

Loan Receivables

5,746

8,746

Derivatives

14,125

5,477

11,037

3,346

Cash and cash equivalents

91,144

33,838

57,242

12,627

1,106,941

797,900

765,522

557,343

Total assets

2,230,742

1,858,321

1,862,770

1,612,430

EQUITY

Capital and reserves attributable to the Company's equity holders

Share capital

146,344

Share premium

65,030

Other reserves

291,419

310,790

287,424

319,045

Retained earnings/(losses)

286,426

248,017

226,629

208,478

Equity attributable to owners of the company

789,219

770,182

725,428

738,898

Non-Controlling Interest

19,098

14,352

Total equity

808,316

784,534

725,428

738,898

LIABILITIES

Non-current liabilities

Loans and Borrowings

662,111

452,706

599,191

382,339

Lease liabilities

10,392

10,480

6,543

9,220

Derivatives

3,205

270

3,205

270

Deferred tax liabilities

57,006

57,421

46,963

47,521

Employee benefits

23,37

12,585

11,176

8,836

7,902

Grants

15,233

15,607

9,044

8,590

Provisions

1,608

1,597

1,411

1,260

Trade and other payables

11,695

200

11,495

773,835

549,456

686,687

457,102

Current liabilities

Trade and other payables

412,266

309,706

319,647

269,597

Contract Iiabilities

9,267

8,826

4,562

6,427

Current tax liabilities

18,093

10,062

15,685

8,926

Loans and Borrowings

200,910

189,671

104,801

126,996

Lease liabilities

4,785

3,992

3,412

3,278

Derivatives

3,108

1,912

2,439

1,097

Provisions

162

110

648,591

524,331

450,655

416,430

Total liabilities

1,422,425

1,073,787

1,137,342

873,532

Total equity and liabilities

2,230,742

1,858,321

1,862,770

1,612,430

The notes on pages 74 to 153 constitute an integral part of these Financial Statements. 2020 is restated pursuant to the

implementation of IAS 19. (Please see note 37).

Annual Financial Report of 31 December 2021

Page | 69

II. Income Statement

GROUP

COMPANY

2021

2020

Restated

2021

2020

Restated

EUR

Note

€ '000

Revenue

2,883,042

2,028,588

1,969,822

1,405,660

Cost of sales

(2,648,216)

(1,893,826)

(1,820,663)

(1,319,072)

Gross profit

234,826

134,762

149,159

86,588

Other Income

15,636

10,785

12,869

10,690

Selling and Distribution expenses

(28,455)

(21,430)

(11,370)

(11,772)

Administrative expenses

(61,761)

(54,306)

(43,420)

(37,954)

Impairment loss on receivables and contract assets

(489)

(485)

(131)

(112)

Other Expenses

(12,846)

(9,904)

(8,554)

(7,248)

Operating profit / (loss)

146,911

59,421

98,554

40,192

Finance Income

279

288

446

400

Finance Costs

(31,266)

(25,506)

(24,434)

(19,414)

Dividends

113

2,822

1,208

Net Finance income / (cost)

(30,874)

(25,218)

(21,166)

(17,806)

Share of profit/ (loss) of equity-accounted investees,

net of tax

4,580

Impairment of participations

(5,865)

(9,535)

Profit / (Loss) from distribution in kind

22,157

32,603

Profit/(Loss) before income tax

132,418

38,783

100,456

22,386

Income tax expense

(18,504)

(9,417)

(12,211)

(5,432)

Profit/(Loss) for the year

113,914

29,366

88,245

16,954

Attributable to:

Owners of the Company

111,689

28,309

88,245

16,954

Non-controlling Interests

2,226

1,057

113,914

29,366

88,245

16,954

Shares per profit to the shareholders for period

(expressed in € per share)

Basic and diluted

0.2976

0.0754

0.2352

0.0452

The notes on pages 74 to 153 constitute an integral part of these Financial Statements. 2020 is restated pursuant to the

implementation of IAS 19. (Please see note 37)

Annual Financial Report of 31 December 2021

Page | 70

III. Statement of Other Comprehensive Income

GROUP

COMPANY

Note:

2021

2020

Restated

2021

2020

Restated

€ '000

Profit / (Loss) of the period from continued operations

113,914

29,366

88,245

16,954

Items that will never be reclassified to profit or loss

Remeasurements of defined benefit liability

23,37

(343)

(424)

(335)

(237)

Equity investments in FVOCI - net change in fair value

178

Related tax

102

Total

(241)

(197)

(262)

(180)

Items that are or may be reclassified to profit or loss

Foreign currency translation differences

(132)

(1,145)

Gain / (Loss) of changes in fair value of cash flow

hedging - effective portion

3,300

3,899

4,144

2,642

Gain / (Loss) of changes in fair value of cash flow

hedging - reclassified to profit or loss

(433)

(2,033)

(235)

Other movements

(314)

Related Tax

(474)

(655)

(422)

(578)

Total

2,310

1,794

1,689

1,830

Other comprehensive income / (expense) after tax

2,069

1,597

1,427

1,649

Total comprehensive income / (expense) after tax

115,983

30,962

89,672

18,603

Attributable to:

Owners of the company

113,653

29,728

89,672

18,603

Non-controlling interests

2,329

1,234

Total comprehensive income / (expense) after tax

115,983

30,962

89,672

18,603

The notes on pages 74 to 153 constitute an integral part of these Financial Statements. 2020 is restated pursuant to the

implementation of IAS 19. (please see note 37)

Annual Financial Report of 31 December 2021

Page | 71

IV. Statement of Changes in Equity

GROUP

€ '000

Paid-in

Capital

Premium

Acquisition

Reserve

Other

Reserves

Results carried

forward

Foreign

Exchange

translation

reserve

Total

Non-

Controlling

Interest

Total Equity

Balance as at 1 January 2020

146,344

65,030

69,588

235,969

230,555

(295)

747,190

14,084

761,274

Effect from implementation of IAS 19

5,752

Restated Balance as at 1 January 2020

146,344

65,030

69,588

235,969

236,307

(295)

752,942

14,084

767,026

Net Profit / (Loss) for the period

28,309

1,057

29,366

Other comprehensive income

3,252

(689)

(1,145)

1,419

177

1,597

Total comprehensive income

3,252

27,620

(1,145)

29,728

1,234

30,962

Transactions with the shareholder's directly in equity

Transfer of reserves

3,418

(3,418)

Dividend

(11,257)

Acquisition of NCI

(1,234)

(1,230)

(966)

(2,196)

Total transactions with the shareholders

3,422

(15,909)

(12,487)

(966)

(13,453)

Balance as at 31 December 2020

146,344

65,030

69,588

242,643

248,019

(1,440)

770,183

14,352

784,534

Balance as at 1 January 2021

146,344

65,030

69,588

242,643

248,019

(1,440)

770,183

14,352

784,534

Net Profit / (Loss) for the period

111,689

2,225

113,914

Other comprehensive income

2,392

(295)

(132)

1,965

104

2,069

Total comprehensive income

2,392

111,394

(132)

113,654

2,329

115,983

Transactions with the shareholder's directly in equity

Transfer of reserves

(23,444)

1,809

21,634

Dividend

(94,619)

Change in ownership interests

2,416

2,419

Total of transactions with the Shareholder's

(23,444)

1,812

(72,985)

(94,617)

2,416

(92,201)

Balance as at 31 December 2021

146,344

65,030

46,144

246,847

286,427

(1,572)

789,221

19,097

808,316

The notes on pages 74 to 153 constitute an integral part of these Financial Statements. 2020 is restated pursuant to the implementation of IAS 19. (Please see note 37)

Annual Financial Report of 31 December 2021

Page | 72

COMPANY

€ '000

Paid-in Capital

Premium

Acquisition

Reserve

Reserves

Results carried

forward

Total

Balance as at 1 January 2020

146,344

65,030

83,153

232,439

200,460

727,427

Effect from implementation of IAS 19

4,126

Balance as at 1 January 2020

146,344

65,030

83,153

232,439

204,586

731,553

Net Profit / (Loss) for the period

16,954

Other comprehensive income

1,829

(180)

1,649

Total comprehensive income

1,829

16,773

18,603

Transactions with the shareholder's directly in equity

Transfer of reserves

1,623

(1,623)

Dividend

(11,257)

Total transactions with the shareholders

1,623

(12,881)

(11,257)

Balance as at 31 December 2020

146,344

65,030

83,153

235,892

208,478

738,898

Balance as at 1 January 2021

146,344

65,030

83,153

235,892

208,478

738,898

Net Profit / (Loss) for the period

88,245

Other comprehensive income

1,689

(262)

1,427

Total comprehensive income

1,689

87,984

89,672

Transactions with the shareholder's directly in equity

Transfer of reserves

(22,826)

22,826

Dividend

(94,620)

Mergers and absorptions

(10,484)

1,961

(8,522)

Total transactions with the shareholders

(33,310)

(69,833)

(103,142)

Balance as at 31 December 2021

146,344

65,030

49,843

237,581

226,630

725,428

The notes on pages 74 to 153 constitute an integral part of these Financial Statements. 2020 is restated pursuant to the implementation of IAS 19. (please see note 37)

Annual Financial Report of 31 December 2021

VI. NOTES TO THE FINANCIAL STATEMENTS AS AT 31 DECEMBER 2021

Page | 73

V. Statement of Cash-Flows

GROUP

COMPANY

Note

2021

2020

Restated

2021

2020

Restated

Cash flows from operating activities

€ '000

Profit / (loss) after taxes

113,914

29,366

88,245

16,954

Adjustments for:

Tax

18,502

9,417

12,211

5,432

Depreciation and Amortization

68,403

61,988

46,434

41,987

Depreciation of tangible assets

65,667

60,057

44,086

39,632

Depreciation of right of use assets

3,003

2,458

1,686

1,659

Depreciation of intangible assets

1,226

1,024

649

701

Depreciation of Investment Property

100

207

1,215

1,216

Amortization of grants

(1,593)

(1,757)

(1,202)

(1,221)

Finance Income

(279)

(288)

(446)

(400)

Dividends

(113)

(2,822)

(1,208)

Share of profit/ (loss) of equity-accounted investees, net of tax

(89)

(4,580)

Impairment loss on investments

5,865

9,535

Interest charges & related expenses

31,266

25,506

24,434

19,414

(Profit) / loss from sale of tangible assets

558

(569)

(1,009)

(313)

(Reversal) of dividend in kind

(22,157)

(32,603)

Impairment/ (Reversal of Impairment) on tangible assets

2,057

Loss from assets and investment property write off

884

1,887

740

1,846

Impairment of inventories

(513)

(1,342)

Impairment/ (Reversal of Impairment) of receivables

696

485

131

112

218,994

121,871

146,907

83,824

Decrease / (increase) in inventories

(193,319)

(32,480)

(127,923)

(8,758)

Decrease / (increase) in receivables

(43,148)

(39,025)

(29,620)

(36,936)

(Decrease) / Increase in liabilities (minus banks)

68,867

70,097

52,502

68,859

(Decrease) / Increase in defined benefit obligation

1,409

(1,589)

934

(418)

(Decrease) / Increase in contract liabilities

104

(1,865)

(376)

(166,190)

(2,892)

(105,972)

22,371

Interest charges & related expenses paid

(27,276)

(26,483)

(21,371)

(20,024)

Income tax paid

(3,232)

(5,810)

(355)

(4,956)

Net Cash flows from operating activities

22,295

86,686

19,209

81,214

Cash flows from investing activities

Purchase of tangible assets

(145,519)

(115,572)

(106,794)

(93,258)

Purchase of intangible assets

(798)

(182)

(181)

(155)

Proceeds from sales of fixed assets

2,091

1,635

1,877

1,010

Proceeds from sales of investment properties

148

Dividends received

113

2,822

1,208

Interest received

253

288

446

400

Acquisition of investments and other investments

(1,755)

(4,512)

(4,750)

(11,165)

Acquisition of other investments

(3,500)

(9,100)

(32,706)

(9,100)

Cash acquired from business combinations

(20,223)

1,676

Net Cash flows from investing activities

(169,337)

(127,296)

(137,610)

(110,912)

Cash flows from financing activities

Dividends paid

(9,381)

(11,257)

(9,381)

(11,257)

Loans received

537,131

127,020

477,978

102,696

Loans settlement

(320,289)

(85,917)

(303,383)

(62,030)

Payment of lease liabilities

(4,340)

(4,086)

(3,417)

(3,327)

1,227

1,219

Net cash flows from financing activities

204,348

25,760

163,016

26,082

Net (decrease)/ increase in cash and cash equivalents

57,306

(14,850)

44,615

(3,616)

Cash and cash equivalents at the beginning of period

33,838

48,688

12,627

16,243

Effect of Foreign exchange in the cash and cash equivalents

Cash and cash equivalents at the end of period

91,144

33,838

57,242

12,627

The notes on pages 74 to 153 constitute an integral part of these Financial Statements. 2020 is restated pursuant to the implementation of IAS

19. (Please see note 37)

Annual Financial Report of 31 December 2021

Page | 74

1. Incorporation and Group Activities:

ELVALHALCOR HELLENIC COPPER AND ALUMINIUM INDUSTRY S.A was created by the merger by absorption of

“ELVAL HELLENIC ALUMINIUM INDUSTRY S.A.” (hereinafter “ELVAL”) by the listed “HALCOR METAL WORKS S.A.”

(hereinafter “HALCOR”) with the 131569/30-11-2017 of the Ministry of Economy and Development.

The duration of the company has been set until 31.12.2200. It is listed on Athens Stock Exchange and is a

subsidiary of VIOHALCO S.A.. The Company is registered at the Companies registry (Μ.Α.Ε.) with number

2836/06/B/86/48 and at the General Commercial Registry (GEMI) with registration number 303401000, and LEI:

213800EYWS2GY56AWP42.

These Financial Statements (the "Financial Statements") of the Company for the year ended on 31 December

2021 include the individual financial statements of ELVALHALCOR and the consolidated financial statements of

the Company (together the "Group"). The names of subsidiaries and affiliated companies are presented in Note

30 of the Financial Statements.

The Financial Statements of ELVALHALCOR are included in the consolidated Financial Statements of VIOHALCO

S.A/NV that is traded on the EURONEXT stock exchange in Belgium as well as in the Athens Exchange.

The principal activities of the Group lie in the processing of metals, and more specifically in the production,

manufacturing and trade and agency of products made of copper, copper alloys, aluminium, aluminium alloys

and zinc as well as from other metals or alloys, and any type of their products. The Group is operating in Greece,

Bulgaria and Turkey.

The Company is seated in Greece, 2-4 Mesogeion Ave., Athens Tower, Building B, 11525, Athens. The central

offices of the Company and its contact address are located at the 61 - 62

km of "Athens-Lamia" National

Highway, Inofyta (Pref. of Viotia), GR-32011. The company's website is www.elvalhalcor.com.

2. Basis of preparation of the Financial Statements

(a) Compliance note

The Financial Statements have been prepared in accordance with the International Financial Reporting Standards

(IFRS), as adopted by the European Union. The International Financial Reporting Standards issued by the IASB

may differ from those adopted by the European Union.

The financial statements ended 31 December 2021 were approved for publication by the Company’s Board of

Directors on 15th of March, 2022 and remain under the approval of the General Assembly of Shareholders.

(b) Measurement basis

The Financial Statements have been prepared in accordance with the historical cost principle except derivatives

and investments measured at fair value.

The Financial Statements are presented in Euro, which is the Company’s functional currency. The amounts

indicated in the Financial Statements are denominated in thousands of Euro and are rounded up/down to the

nearest thousand (any differences in sums are due to rounding up/down).

(d) Application of estimates and judgments

Preparing financial statements in line with the IFRS requires that Management take decisions, make assessments

and assumptions which affect the implementation of accounting policies, and the book amounts of assets,

liabilities, income and expenses. The actual results may finally differ from such estimates.

Annual Financial Report of 31 December 2021

Page | 75

Estimates and related assumptions are continuously revised. These revisions are recognized in the period they

were made and any subsequent ones.

Specific information about the areas for which estimates are uncertain and vital decisions must be made with

respect to the application of accounting policies having a considerable effect on the amounts posted in financial

statements is given in the notes below:

Significant Estimates

• Valuation of assets that are not measured at fair values: The Group and the company make estimates

regarding any impairment of the fixed assets which are not measured in fair values (Investments in

subsidiaries and associates, Intangible assets, Property, Plant and Equipment and Investment

property). In regards, to the investments in subsidiaries and other related companies, the Company

examines at each reporting period if there are any indications of impairment of the investment in

participations. Where there are indications of impairment, the Company proceeds to relative test

according to the accounting policy which if follows. The significant estimates of the Management

during the calculation of the recoverable value concern the estimation of the future cash flows, which

depends on the a number of factors, including forecasts regarding the sales in future periods,

forecasts of costs, as well as the use of proper discount rate. In regards to the PPE and investment

property, the impairment of land-plots and buildings (including investment property) requires the

formulation of estimates mainly linked to the cause, the time and the amount of impairment. The

Group examines at each reporting period if there are any indication for impairment of the PPE and

Investment property according to the accounting policy. The Management makes significant

estimates in regards to the determination of the recoverable value. The determination of the

indication for impairment, as well as the estimate of future cash flows and the determination of the

fair values of the assets (or group of assets) require the Management to make significant estimates

regarding the determination and the valuation of indication of impairments, the expected cash-flows,

the discount rates which are applied, the useful lives and the residual values of the assets. In regards

to the investment property, the impairment test may be conducted by the Management in

cooperation with independent valuator.

• Assessment of goodwill and intangible assets impairment: The group assessed the impairment in

goodwill and intangible assets. (Refer to note 11).

3. New principles

New standards, amendments to standards and interpretations: Certain new standards, amendments to standards

and interpretations have been issued that are mandatory for periods beginning on or after 1

January 2021 and

afterwards. The Group’s evaluation of the effect of these new standards, amendments to standards and

interpretations is as follows:

Standards and Interpretations effective for the current financial year

IFRS 16 (Amendment) ‘Covid-19-Related Rent Concessions’

The amendment provides lessees (but not lessors) with relief in the form of an optional exemption from assessing

whether a rent concession related to COVID-19 is a lease modification. Lessees can elect to account for rent

concessions in the same way as they would for changes which are not considered lease modifications.

IFRS 4 (Amendment) ‘Extension of the Temporary Exemption from Applying IFRS 9’

The amendment changes the fixed expiry date for the temporary exemption in IFRS 4 ‘Insurance Contracts’ from

applying IFRS 9 ‘Financial Instruments’, so that entities would be required to apply IFRS 9 for annual periods

beginning on or after 1 January 2023.

Annual Financial Report of 31 December 2021

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IFRS 9, IAS 39, IFRS 7, IFRS 4 and IFRS 16 (Amendments) ‘Interest rate benchmark reform – Phase 2’

The amendments complement those issued in 2019 and focus on the effects on financial statements when a

company replaces the old interest rate benchmark with an alternative benchmark rate as a result of the reform.

More specifically, the amendments relate to how a company will account for changes in the contractual cash

flows of financial instruments, how it will account for the change in its hedging relationships and the information

it should disclose.

Standards and Interpretations effective for subsequent periods

IFRS 16 (Amendment) ‘Covid-19-Related Rent Concessions’ (effective for annual periods beginning on or after

1 April 2021)

The amendment extends the application period of the practical expedient in relation to rent concessions by one

year to cover rental concessions that reduce leases due only on or before 30 June 2022.

IFRS 17 ‘Insurance contracts’ and Amendments to IFRS 17 (effective for annual periods beginning on or after 1

January 2023)

IFRS 17 has been issued in May 2017 and, along with the Amendments to IFRS 17 issued in June 2020, supersedes

IFRS 4. IFRS 17 establishes principles for the recognition, measurement, presentation and disclosure of insurance

contracts within the scope of the Standard and its objective is to ensure that an entity provides relevant

information that faithfully represents those contracts. The new standard solves the comparison problems

created by IFRS 4 by requiring all insurance contracts to be accounted for in a consistent manner. Insurance

obligations will be accounted for using current values instead of historical cost.

IAS 16 (Amendment) ‘Property, Plant and Equipment – Proceeds before Intended Use’ (effective for annual

periods beginning on or after 1 January 2022)

The amendment prohibits an entity from deducting from the cost of an item of PP&E any proceeds received from

selling items produced while the entity is preparing the asset for its intended use. It also requires entities to

separately disclose the amounts of proceeds and costs relating to such items produced that are not an output of

the entity’s ordinary activities.

IAS 37 (Amendment) ‘Onerous Contracts – Cost of Fulfilling a Contract’ (effective for annual periods beginning

on or after 1 January 2022)

The amendment clarifies that ‘costs to fulfil a contract’ comprise the incremental costs of fulfilling that contract

and an allocation of other costs that relate directly to fulfilling contracts. The amendment also clarifies that,

before a separate provision for an onerous contract is established, an entity recognises any impairment loss that

has occurred on assets used in fulfilling the contract, rather than on assets dedicated to that contract.

IFRS 3 (Amendment) ‘Reference to the Conceptual Framework’ (effective for annual periods beginning on or

after 1 January 2022)

The amendment updated the standard to refer to the 2018 Conceptual Framework for Financial Reporting, in

order to determine what constitutes an asset or a liability in a business combination. In addition, an exception

was added for some types of liabilities and contingent liabilities acquired in a business combination. Finally, it is

clarified that the acquirer should not recognise contingent assets, as defined in IAS 37, at the acquisition date.

IAS 1 (Amendment) ‘Classification of liabilities as current or non-current’ (effective for annual periods beginning

on or after 1 January 2023)

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The amendment clarifies that liabilities are classified as either current or non-current depending on the rights

that exist at the end of the reporting period. Classification is unaffected by the expectations of the entity or

events after the reporting date. The amendment also clarifies what IAS 1 means when it refers to the ‘settlement’

of a liability. The amendment has not yet been endorsed by the EU.

IAS 1 (Amendments) ‘Presentation of Financial Statements’ and IFRS Practice Statement 2 ‘Disclosure of

Accounting policies’ (effective for annual periods beginning on or after 1 January 2023)

The amendments require companies to disclose their material accounting policy information and provide

guidance on how to apply the concept of materiality to accounting policy disclosures. The amendments have not

yet been endorsed by the EU.

IAS 8 (Amendments) ‘Accounting policies, Changes in Accounting Estimates and Errors: Definition of

Accounting Estimates’ (effective for annual periods beginning on or after 1 January 2023)

The amendments clarify how companies should distinguish changes in accounting policies from changes in

accounting estimates. The amendments have not yet been endorsed by the EU.

IΑS 12 (Amendments) ‘Deferred tax related to Assets and Liabilities arising from a Single Transaction’ (effective

for annual periods beginning on or after 1 January 2023)

The amendments require companies to recognise deferred tax on transactions that, on initial recognition, give

rise to equal amounts of taxable and deductible temporary differences. This will typically apply to transactions

such as leases for the lessee and decommissioning obligations. The amendments have not yet been endorsed by

the EU.

IFRS 17 (Amendment) ‘Initial Application of IFRS 17 and IFRS 9 – Comparative Information’ (effective for annual

periods beginning on or after 1 January 2023)

The amendment is a transition option relating to comparative information about financial assets presented on

initial application of IFRS 17. The amendment is aimed at helping entities to avoid temporary accounting

mismatches between financial assets and insurance contract liabilities, and therefore improve the usefulness of

comparative information for users of financial statements. The amendment has not yet been endorsed by the

EU.

Annual Improvements to IFRS Standards 2018–2020 (effective for annual periods beginning on or after 1

January 2022)

IFRS 9 ‘Financial instruments’

The amendment addresses which fees should be included in the 10% test for derecognition of financial

liabilities. Costs or fees could be paid to either third parties or the lender. Under the amendment, costs or

fees paid to third parties will not be included in the 10% test.

IFRS 16 ‘Leases’

The amendment removed the illustration of payments from the lessor relating to leasehold improvements in

Illustrative Example 13 of the standard in order to remove any potential confusion about the treatment of

lease incentives.

IAS 41 ‘Agriculture’

The amendment has removed the requirement for entities to exclude cash flows for taxation when measuring

fair value under IAS 41.

Annual Financial Report of 31 December 2021

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4. Significant accounting principles

The accounting principles cited below have been consistently applied to all periods presented in these Financial

Statements and have also been consistently applied by all Group companies.

4.1. Basis of consolidation

a) Business combinations

The acquisitions of subsidiaries accounted under the purchase method on the date of acquisition, the date on

which control is transferred to the Group. Control power is the power of operating and financial policies of an

enterprise so as to benefit from the activity. In assessing control, the Group takes account of potential voting

rights that presently may be exercisable.

The goodwill arises from the acquisition of subsidiaries and constitutes the exceeding amount between the sum

of purchase price and the amount of the non-controlling participation to the acquired entity at the date of

acquisition and the fair value of the net assets acquired. If the sum of the total price paid, the non-controlling

participation recognized and the prior participation in the company is less than the fair value of the net assets

then the difference of a bargain purchase is recognized in the profit and loss.

Any expenses related to the acquisition are posted directly on the profit and loss. Any consideration transferred

is recognized at fair value at the acquisition date.

b) Accounting for acquisitions of minority interests

Acquisitions of minority interests are accounted as transactions of shareholders and percentages and therefore

no goodwill is recognized in such transactions. If the sum of the total price paid, the non-controlling participation

recognized and the prior participation in the company is less than the fair value of the net assets of the subsidiary

acquired, then the difference of a bargain purchase is recognized in the profit and loss. Gains or losses that result

from the sale of the participation to non-controlling interest recorded to equity.

c) Subsidiaries

Subsidiaries are entities that the Group, directly or indirectly, controls their financial and operating policies.

Subsidiary companies are fully consolidated from the day control over them is acquired and cease to be

consolidated from the day this control is no longer exist.

In its financial statements, the Company measures holdings in subsidiaries at their acquisition cost less any

impairment of their value.

d) Loss of control

Upon the loss of control, the Group derecognises the assets and liabilities of the subsidiary, any non-controlling

interests and the other components of equity related to the subsidiary. Any surplus or deficit arising on the loss

of control is recognised in profit or loss. If the Group retains any interest in the previous subsidiary, then such

interest is measured at fair value at the date that control is lost. Subsequently it is accounted for as an investment

in an associate or as an available-for-sale financial asset depending on the level of influence retained.

e) Investments in associates and joint ventures

Associated companies are companies over which the Group exercises significant influence, but not control,

which, in general, applies when the holding percentage in the voting rights ranges between 20% and 50%. A joint

venture is an arrangement in which ELVALHALCOR has joint control, whereby ELVALHALCOR has rights to the net

assets of the arrangement, rather than rights to its assets and obligations for its liabilities. Investments in

associates and joint ventures are accounted for using the equity method and recognised initially at their

acquisition cost. The Group’s investments in associates include goodwill identified on acquisition, net of any

accumulated impairment losses. In the consolidated financial statements, the Group represents the ratio of the

results and the total income after any changes in accounting principles to be comparable to those of the Group

Annual Financial Report of 31 December 2021

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from the date of obtaining significant influence until the date we lose it. When the Group’s share of losses

exceeds its interest in an investment in associate or joint venture the carrying amount of that interest is reduced

to zero and no recognition of further losses are recognized except to the extent that the Group has an obligation

or has made payments on behalf of the associate.

In the Company’s financial statements, investments in associates and joint ventures are recorded at cost minus

any impairment that may occur.

f) Transactions eliminated in consolidation

Inter-company transactions, balances and unrealised profits from transactions between Group companies are

eliminated in preparing the consolidated financial statements. Unrealised gains on transactions between

associates or joint ventures are eliminated against the Group's stake in the affiliated company. The same applies

to non-realised losses, unless there are indications that the value of the assets that was transferred have been

impaired.

g) Business combinations under common control

IFRS 3 “Business Combinations” does not apply to mergers of companies under common control and no guidance

from IFRS applies for such transactions. According to paragraphs 10 to 12 of IAS 8 “Accounting Policies, Changes in

Accounting Estimates and Errors” the Group selects to apply the method of acquisition as described in IFRS 3 for

such transactions, as stated above.

4.2. Foreign currency

a) Transactions and balances

Transactions that are carried out in a foreign currency are converted to the Company’s functional currency based

on the exchange rate that is applicable on the day the transaction is carried out. Gains and losses from foreign

exchange differences that arise from the settlement of such transactions are recorded in the profit and loss

statement. These gains or losses follows the respective income/ expense of such transaction.

b) Transactions with Group companies in different currency

The financial statements of Group companies (none of which has the currency of a hyperinflationary economy)

that have a functional currency different from the Group’s presentation currency are translated as follows:

• Assets and liabilities of foreign activities including goodwill and fair value adjustments arising during

consolidation are converted into Euro based on the official exchange rate for the foreign currency that is in

effect on the balance sheet date.

• Income and expenses are converted into Euro on the basis of the average rate of the foreign currency during

the year which approaches the exchange rate in effect on the date of transactions.

• Any foreign exchange difference that may arise is recorded in an equity reserve named “Foreign exchange

differences due to consolidation” through OCI and transferred to profit and loss when these companies are

sold.

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4.3. Financial instruments

a) Classification

The Group classifies its financial assets to the below categories according for measurement purposes.

• Financial assets measured to fair value (either at FVOCI or FVPL)

• Financial assets measured to amortized cost

The classification depends on the business model of managing the financial assets of the Group and the

objective of the contractual cash flows of the financial asset.

Investments that are not held for trading measured at fair value through profit and loss except the investments

for which the Group, upon initial recognition, designs irrecoverably to measure them at fair value through OCI.

The Group reclassifies these investments only when the business model change.

b) Initial recognition and measurement

Common purchases and sales of financial instruments are recognized at the inception date of the transaction

which is the date at which the Group is obliged to purchase or sale the financial asset.

At initial recognition the Group measures a financial asset to fair value plus, in case of a financial asset that

cannot be measured to FVPL, the transaction costs that are attributable directly to the acquisition of the

financial asset. Transaction costs of the financial asset that measured to FVTPL are recorded in the statement

of profit and loss.

Investments cease to be recognized when the contractual cash flows for the financial assets cease or

transferred and the Group has transferred all the risks and rewards.

c) Subsequent measurement

Investments to financial instruments

The subsequent measurements of the debt investments depends on the business model of the Group for

managing the debt investments and the specific characteristics of the contractual cash flows. The Group

classifies the debt instruments to the following categories:

• Amortized cost: Financial instruments that held to collect the contractual cash flows at given dates

that consist by sole payment of principal and interest, measured at amortised cost. Interest income

is calculated based on the nominal interest rate and are recognized as financial income. Gains/losses

occurred by the recognition-write off of the financial asset recorded in income statement with any

foreign exchange gains/losses. Any impairment losses are recognized in the caption “Impairment loss

on receivables and contract assets” in the statement of profit and loss.

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• Fair value through other comprehensive income (FVOCI): Financial instruments that held either for

collect of their contractual cash flows or sale and give rise to cash flows of solely principal and interest

at specific dates, are measured at fair value through other comprehensive income. Changes in fair

value are recognized in other comprehensive income except for the recognition of impairment losses,

interest income and foreign exchange gains / losses recognized in the income statement. When the

asset is derecognised, the accumulated gain / loss recognized in other comprehensive income is

reclassified to the statement of profit and loss under "Other income / expense". Interest income is

calculated using the effective interest method and recognized as interest income. Impairment losses

are recognized in the line "Impairment of receivables and contract assets" in the statement of profit

and loss.

• Fair value through profit or loss (FVTPL): Assets that do not meet the criteria for classification in the

category "Amortized cost" and "Fair value through other comprehensive income" are measured at

fair value through profit or loss. The gain / loss is recognized in the statement of profit and loss in the

period in which it arises.

For Investments in equity instruments, refer to note "Other investments".

d) Trade and other receivables

Receivables from customers are initially booked at their fair value and are subsequently measured at their

amortized cost less impairment losses. Impairment losses are recognised when there are objective indications

that the Group is not in a position to collect all or part of the amounts due based on contractual terms. The

amount of impairment loss is the difference between the book value of receivables and the present value of

the estimated future cash flows. The amount of provision is recognised in the income statement as an expense.

In regards to the provision for expected credit losses, the Group applies the IFRS 9 simplified approach to

measure expected credit losses which uses a lifetime expected loss allowance for all trade receivables and

contract assets. To measure the expected credit losses, trade receivables and contract assets have been

grouped based on shared credit risk characteristics and the days past due. The Group has identified the ratings

by ratings agencies for a customer who is rated individually, and the country rating in the case of a non-rated

customer, as identifiers of the expected credit loss and accordingly adjusts the provision after those factors.

e) Cash and cash equivalents

Cash and cash equivalents include cash balances, sight deposits, time deposits up to 3-months, high-liquid and

low-risk investments.

f) Other investments

In this category are included equity investments.

4.4. Loans

Loans are initially booked at fair value, less any direct expenses for the execution of the transaction. Subsequently

loans are valued at non-depreciated cost based on the effective interest rate method. Any difference between

the amount that has been collected (net of relative expenses) and the settlement value is recorded in the results

during the term of the loan based on the effective interest rate method.

Loans are classified as “Short-term Liabilities” unless the Group has the right to defer the settlement thereof for

at least 12 months from the balance sheet date. Loan interest charges are directly posted to the income

statement of the period they concern. The recognition stops when the contractual obligations cancelled,

terminated or sold.

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4.5. Trade liabilities

Trade liabilities are initially booked in fair value and are subsequently valued at their amortized cost based on the

effective interest rate method.

4.6. Derivatives and hedge accounting

The Group established a ‘risk management strategy’ as holds derivative instruments to offset the risk of foreign

currency change. Derivatives are initially and subsequently recognized at fair value. The method of recognizing

gains and losses depends on whether derivatives designated as hedging instruments or as held for trading.

The Group documents at the inception of the transaction the relationship between instruments of hedging and

hedged items as well as the strategic management of risk. At the conclusion of the contract and on an ongoing

basis later recorded assessment of the high efficiency of hedging for both fair value hedges and for cash flow

hedges. To offset future transaction demonstrates the possibility of completing the transaction.

a) Fair value hedging

Changes in the fair value of derivatives which are defined as fair value hedges are posted to the results as are the

changes in the fair value of the hedged assets which are attributed to the risk offset.

b) Cash flow hedging

The effective proportion of change in the fair value of derivatives defined as cash flow hedge are posted to an

equity reserve. The gain or loss on the non-effective proportion is posted to the results. The amounts posted as

an equity reserve are carried forward to the results of the periods where the hedged assets affect profits or

losses. In cases of hedging forecast future transactions which result in recognition of a non-monetary asset (e.g.

inventory) or liability, profits or losses which had been posted to equity are carried forward to acquisition cost

of the non-financial asset generated.

When a hedge matures or is sold or when the hedging proportion no longer meets the hedge accounting criteria,

the profits and losses accrued to ‘Equity’ remain as a reserve and are carried forward to the results when the

hedged asset affects profits or losses. In the case of a hedge on a forecast future transaction which is no longer

expected to be realised, the profits or losses accrued to ‘Equity’ are carried forward to the income statement.

4.7. Share capital

The share capital consists of common shares. Direct expenses for the issuance of shares appear after deducting

the relevant income tax, reducing the amount of growth.

4.8. Property, plant and equipment

a) Recognition and measurement

Non-current assets include Land, Buildings, Machinery, Transportation equipment, Furniture and other

equipment are shown at acquisition cost, less subsequent depreciation. Items of Property Plant and equipment

should be recognised as assets as costs incurred. These costs include costs incurred initially to acquire or

construct an item of property, plant and equipment and costs incurred subsequently to add to, replace part of,

or service it. Cost may also include transfers from equity of any gains/losses on qualifying cash flow hedges of

foreign currency purchases of property, plant and equipment.

Subsequent expenses are recorded as an increase to the book value of the fixed assets or as a separate asset

only where it is probable that the future financial benefits will accrue to the Group or the Company and their

cost can be reliably measured. The net book value of an assets that is replaced, ceased to be recognised in balance

sheet.

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The cost of repairs and maintenance is posted to the results when incurred.

The book value of a tangible asset is recorded down to its net realisable value when its book value exceeds its

recoverable amount.

Upon sale of tangible assets, the differences between the proceeds and the carrying value is recorded as gains

or losses on the results and the item 'Other operating income' or 'Other operating expenses "as appropriate.

b) Depreciation

Plots – lots (Land) and assets under construction are not depreciated. Depreciation of other tangible assets is

calculated using the straight-line method during the estimated useful life of fixed assets and their segments if

they have a different useful life. The estimated useful life of these categories is as follows:

- Buildings

20-50

years

- Machinery & equipment

1-40

years

- Transportation equipment

4-15

years

- Furniture and fixtures

1-8

years

Residual value and the useful life of tangible assets are subject to re-examination on each balance sheet date, if

deemed necessary.

4.9. Intangible assets

Intangible assets acquired separately are recognized at acquisition cost while any intangible assets acquired

through the purchase of entities are recognized at their fair value on acquisition date. After acquisition they are

valued at that amount less accumulated depreciation and any accumulated impairment losses. The useful life of

intangible assets may be finite or indefinite. The cost of intangible assets with a definite useful life is depreciated

over the estimated useful life using the straight-line method. Intangible assets are depreciated from the date

they become available for use.

Intangible assets with indefinite useful life are not depreciated but are subject periodically (at least annually) to

an estimate of any impairment based on the provisions of IAS 36 "Impairment of Assets". Residual values are not

recognized. The useful life of intangible assets is evaluated on an annual basis. Intangible assets are tested for

impairment at least annually individually or at cash-generating unit level.

Goodwill do not amortized although measured to its carrying amount less any impairment losses.

Software licences are valued at acquisition cost less accumulated depreciation and any accumulated impairment.

Depreciation is recorded using the straight-line method over the useful life of the assets which ranges from 3 to

5 years.

Expenses required to develop and maintain software are posted as expenses in the income statement during the

year they incur.

In respect of trademarks and licences initially recognised at the inception date and then amortized during their

useful life. Licences have a useful life of 10 years.

Finally, the client relationships are recognised initially at their acquisition date are amortized during their useful

life. The client relationships with indefinite useful life do not amortize although are tested at least annually for

impairment according to the provisions of IAS 36 “Impairment of assets”.

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4.10. Investment property

Investment property includes properties held by the Group to earn long term rentals and cannot be own used.

Investment property is initially measured at cost less any accumulated despeciation. If the net book value of the

investment property exceeds its recoverable amount, the difference is posted as an impairment in the Statement

of Profit and Loss.

The land-plots included in the investment property are not depreciated. The depreciation of the buildings are

calculated on a straight-line method based on their useful life varies from 20 to 50 years.

Any gain or loss on disposal of investment property (calculated as the difference between the net proceeds from

disposal and the carrying amount of the item) is recognized in the profit or loss as incurs.

4.11. Assets Held for sale

Assets, or disposal groups comprising assets and liabilities, are classified as held-for-sale if it is highly probable

that they will be recovered primarily through sale rather than through continuing use. Such assets, or disposal

groups, are generally measured at the lower of carrying amount and fair value minus costs to sell. Impairment

losses on initial classification as held-for-sale and subsequent gains and losses on remeasurement are recognised

in profit or loss. Once classified as held-for-sale, intangible assets and property, plant and equipment are no

longer amortised or depreciated, and any equity-accounted investee is no longer equity accounted.

4.12. Inventories

Inventories are valued at acquisition cost or net realisable value, whichever is lower. Acquisition cost is

determined by applying the annual average weighted cost method and includes the cost to buy, produce or

manufacture and other expenses so as to acquire its current condition and location and the ratio of production

expenses. The cost may include any transfer from the cash flow hedging reserve. Net realisable value is assessed

based on current sale prices of inventories in the course of ordinary activities, less any termination and sales

expenses that apply to the case.

4.13. Impairment

(a) Non-derivative financial assets

Financial assets

The Group recognize expected credit losses related to:

• Financial assets that measured at amortized cost

• Contract assets

• Receivables from leases

The impairment losses recognized are always equal to the lifetime expected credit losses, except the cash and

cash equivalents (12 months expected credit losses). The Group considers that a financial asset is credit-impaired

when the borrower is unlikely to repay its obligations in full, without the Group companies taking measures, such

as the liquidation of collateral (if any).

Lifetime expected credit losses are the expected credit losses arising from all events of possible default

throughout the life of a financial instrument. 12 month expected credit losses are the percentage of the expected

credit losses that arise from events of possible default during the next twelve months of the reporting date (or

earlier). The maximum period considered when estimating expected credit losses is the maximum contractual

period during which the Group companies are exposed to credit risk.

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Measurement of expected credit losses

Measurement of expected credit losses is the weighted average of the expected credit losses of probability,

based on the respective probabilities. The credit-impaired losses are the present value of expected credit losses

(the difference between the cash flows of the contract and the cash flows that are expected to recover). The

expected credit losses are discounted using the original effective interest rate of the financial instrument.

Presentation of expected credit losses in the statement of financial position

Expected credit losses for financial instruments that are measured at amortized cost are deducted from the gross

carrying amount of these assets. The credit losses that are related to trade and other receivables and contract

assets are presented separately in the statement of profit and loss.

Investments accounted for by the equity method

Impairment loss on investments accounted for by the equity method is measured by comparing the recoverable

amount of the investment with its carrying value. Impairment is recognized in profit and loss and is reversed if

there is a favourable reversal in the estimates used to determine the recoverable amount of the investment.

(b) Non-financial assets

Excluding goodwill and fixed assets with unlimited lives tested for impairment at least annually, the carrying

amounts of other non-financial assets of non-current term assets are tested for impairment when events or

changes in circumstances indicate that the carrying amount may not be recoverable.

When the carrying amount of an asset exceeds its recoverable amount, the respective credit loss recorded in the

statement of profit and loss. The recoverable amount of the asset or cash-generating unit is the higher of value

in use and fair value less any costs to sell. For impairment purposes, financial assets classified to the lowest level

for which the cash flows can be directly associated with the asset (cash-generating units). Impairment losses

have been recognised at previous years in respect of non-financial assets (excluding goodwill) are tested at each

reporting date for reversal.

4.14. Employee benefits

(a) Short-term benefits

Short-term benefits to staff in cash and kind are posted as expenses when accrued. A liability is recognized for

the amount expected to be paid as a benefit to the staff and its executives if there is a legal or contractual

obligation to pay this amount as a result of employee services and insofar as such liability can be reliably

measured.

(b) Defined-contribution Plans

Defined-contribution plans are plans for the period after the employee has ceased to work during which the

Company pays a defined amount to a third legal entity without any other obligation. Obligations for contributions

to defined-contribution plans are recognized as an expense in profit or loss at the time they are due.

Defined-benefit plans are any other retirement plans excluding defined-contribution plans. The obligation posted

to the balance sheet for defined-benefit plans is the current value of the future benefit of the employee for these

services for the defined benefit less the fair value of the plan assets and changes arising from the non-posted

actuarial gains and losses and the past service cost. The discount rate corresponds to the rate of return on high-

quality fixed-income investments of the appropriate maturity. Independent actuaries using the projected unit

credit method calculate the defined benefit obligation.

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The past service cost is recorded directly in the income statement, with the exception of the case where changes

in the plan depend on the remaining service lives of employees. In this case, the past service cost is recorded in

the income statement using the straight-line method within the maturity period.

(d) Benefits for employment termination

The benefits due to termination of the employment relationship are paid when employees depart before their

retirement date. The Group books these benefits when it is committed, either a) when it terminates the

employment of existing employees according to a detailed programme for which there is no departure

possibility, or b) when the company recognises expenses for restructuring according to the provisions IAS 37 for

which are included the benefits paid. In the case of termination, where it is impossible to determine the number

of employees that will make use of such benefits, these will not be accounted for but will be disclosed as a

contingent liability. Employment termination benefits that are due in 12 months after the balance sheet date are

discounted.

4.15. Provisions

Provisions are recognized when the Group has a present legal or constructive obligation which will probably

demand an outflow of resources for its settlement. In addition, the amount of this obligation should be reliably

measurable. Provisions are re-examined on each balance sheet date and, if it is likely that there will no longer be

an outflow of resources to settle the obligations, the provisions are reversed. Provisions are used only for the

purpose for which they were originally created. No provisions are recognized for future losses. Contingent assets

and contingent liabilities are not recognized in the financial statements.

When time value of money is significant, provisions are measured at their present value of the costs expected to

be incurred in order to settle the liability, using a pre-tax interest rate as a discount rate, reflecting current market

estimates for time value of money and other associated risks. The increase of provision-liability over time is

recognized as a financial expense.

4.16. Income

(a) Sales of copper goods

Income from sales of goods is recognised when the control is transferred to the buyer. Indicatively, income from

sales of goods is recognized when the significant risks and rewards of ownership have been transferred to the

buyer, no performance obligations which could affect the acceptance of the goods by the buyer have been left

unfulfilled, the collection of the price is reasonably secured, the relevant expenses and eventual returns of goods

can be reliably measured, and no continuous involvement in goods management applies. Any returns or

turnover-related discounts are deducted from the income from sales of goods. The time at which the risk and

rewards are transferred varies per product.

(b) Sales of aluminium goods

Income from sales of goods is recognised when the control is transferred to the buyer. Indicatively, income from

sales of goods is recognized when the significant risks and rewards of ownership have been transferred to the

buyer, no performance obligations which could affect the acceptance of the goods by the buyer have been left

unfulfilled, the collection of the price is reasonably secured, the relevant expenses and eventual returns of goods

can be reliably measured, and no continuous involvement in goods management applies. Any returns or

turnover-related discounts are deducted from the income from sales of goods. The time at which the risk and

rewards are transferred varies per product.

Rendering of services is recognised in the period in which the services are rendered, on the basis of the stage in

the completion of the actual service to the services as a whole.

Annual Financial Report of 31 December 2021

Page | 87

4.17. Government grants

Government grants for investments in assets are recognised as accrued income where there is a reasonable

assurance that the grant will be received and the Group will comply with all relevant conditions. Government

grants relating to the purchase of fixed assets are credited to the income statement on a straight-line basis over

the expected useful lives of the related assets.

Government grants compensating the Group for expenses are recognized in the results so that these will match

the expenses that they will cover.

4.18. Leases

The Group as a lessor

From 1 January 2019, leases are recognized in the statement of financial position as a right of use of assets and

the respective lease liability on the date the leased asset is available for use.

Lease liabilities include the present value of fixed future payments, variable leases, which depends on an index

or interest rate, which are initially measured with the use of an index or interest rate at the date of

commencement of the lease term, the amounts expected to be paid under guaranteed residuals value, the

exercise price of the purchase option, if it is certain that the Company will exercise that right, and the payment

of a penalty for termination of the lease if the duration of the lease reflects the exercise of its right Company for

termination of the lease.

The above lease payments are discounted at the interest rate implicit in the lease or if this rate cannot be reliably

determined by the incremental borrowing rate of the lessee. The incremental borrowing rate is the rate at which

the lessee would be charged to borrow the necessary capital to acquire an asset of similar value to the leased

asset for a similar period of time period, with similar collateral and in a similar economic environment.

For these lease categories where payments include fixed payments on non-leases, the Group has chosen not to

separate them from the leases and to include them in the lease obligation.

After initial recognition, lease liabilities increase with the financial cost and decrease with the payment of rents.

Lease liabilities are remeasured to reflect any revaluations or modifications to the lease.

Rights of use are initially measured at cost and subsequently reduced by the amount of accumulated depreciation

and impairment.

The initial recognition cost of a right to use of the asset includes the amount of the initial measurement of the

lease liability, any lease payments on the date of the lease commencement period or before, less any lease

incentives received, any initial direct costs, and estimating any costs of disassembling or removing the underlying

asset.

Depreciation is carried out using the straight-line method over the shorter period between the entity's useful life

of the asset and the duration of the lease. When the lease obligations include an exercise price for the right to

purchase the underlying asset, the rights to use are amortized over the period useful life of these elements.

The Group has chosen to use recognition exemptions determined by the standard for all lease categories in short-

term leases, i.e. leases of less than 12 months duration and leases in which the underlying asset has a low value.

For the above leases, the Company recognizes the leases at the statement of profit or loss as an expense with

the straight-line method over the term of the lease.

Annual Financial Report of 31 December 2021

Page | 88

The Group as lessee

Leasing contracts in which the Group is a lessor are classified as financial or operating. The lease contracts of the

Group as at 31 December 2018 and 31 December 2019 related exclusively to operating leases.

Income from operating leases is recognized in the statement of profit and loss on a straight line during the lease

agreement.

4.19. Income tax and deferred tax

The income tax of the year includes both current and deferred tax. Income tax is posted in profit or loss save any

cases concerning items directly posted to Equity, in which case it is recognized in Equity.

Current income tax is the tax expected to be paid on the taxable income for the year, based on enacted tax rates

on the balance sheet date and any adjustment to prior-period payable tax.

Deferred income tax is calculated using the liability method, which arises from temporary differences between

the book value and taxation basis of the assets and liabilities. Deferred income tax is not calculated (a) if it is clear

from the initial recognition of an asset or liability in a transaction apart from business combinations in which the

transaction occurred that it did not affect either the book or tax profits or losses, (b) for investments in

subsidiaries to the extent that the temporary difference will not be reversed, (c) the initial recognition of

goodwill. Deferred tax is determined using the tax rates that are expected to apply to the period in which the

asset will be liquidated, or the liability will be settled. The determination of future tax rates is based on laws

passed on the date the financial statements are prepared.

Deferred tax assets are recognised only to the extent that there will be a future taxable profit for use of the

temporary difference generating the deferred tax assets. Deferred tax assets are reduced when the relevant tax

benefit is realized.

Additional income taxes arising from the allocation of dividends are posted in the same year with the obligation

to pay the relevant dividend.

4.20. Segment reporting

An operating segment is a component of the Group that engages in business activities from which it may earn

revenues and incur expenses, including revenues and expenses that relate to transactions with any of the Group’s

other components. All operating segments’ operating results are reviewed regularly by the chief operating

decision maker which is considered to be the Board of Directors that is responsible for measuring the business

performance of the segments.

4.21. Earnings per share

The Group presents both basic and diluted earnings per share for its common shares. The basic earnings per

share are calculated by dividing the profits or loss attributable to holders of common shares by the weighted

average number of outstanding common shares during the period. Diluted earnings per share are determined

by adjusting the profit or loss attributable to holders of common shares and the weighted average number of

outstanding common shares by the effect of all diluted eventual common shares consisting of convertible notes

and shares with options granted to the staff.

Annual Financial Report of 31 December 2021

Page | 89

4.22. Borrowing Cost

The borrowing cost that is directly linked with the purchase, construction or production of fixed assets for which

a considerable amount of time is required so they can be completed for use or sale is added to the cost of those

assets until the time when these assets will be available for use or sale. The proceeds from the interests from

amounts collected as to be used for the purpose of the construction of the asset as well as the amount of grants

reduces the borrowing cost that is capitalized. In all other cases the cost of borrowing is affecting the Income

statement of the fiscal year. To the extent that general borrowing is used for the construction of an asset, the

cost of borrowing for capitalization can be estimated using a capitalization rate.

4.23. Rounding

Any differences arising between the amounts on the financial statements and the relative amounts in the notes

are related to rounding.

5. Operating segments

An operating segment is based on the structure of the information to the Group's management and internal

reporting system. The Group is organized into business centres and business units based on the production of copper

and aluminium products. In particular, it has two reportable operating segments. The operating segments of the

Group are as follows:

• Copper products: this segment produces and sells copper and copper alloys rolled and extruded products

• Aluminium products: the aluminium segment produces and sell a wide range of aluminium products and their

alloys

The segment analysis for the fiscal year 2021 considered as follows:

12 months until 31 December 2021

€ '000

Aluminium

Copper

Total

Total revenue per segment

1,340,639

1,543,153

2,883,793

Inter-segment revenue

(333)

(418)

(751)

Revenue from 3rd Parties

1,340,307

1,542,735

2,883,042

Cost of sales

(1,207,717)

(1,440,499)

(2,648,216)

Gross profit

132,590

102,236

234,826

Other Income

6,989

8,647

15,636

Selling and Distribution expenses

(18,754)

(9,701)

(28,455)

Administrative expenses

(37,114)

(24,648)

(61,761)

Impairment loss on receivables and contract assets

(321)

(168)

(489)

Other Expenses

(4,600)

(8,246)

(12,846)

Operating profit / (loss)

78,790

68,120

146,909

Finance Income

(164)

443

279

Finance Costs

(17,601)

(13,664)

(31,266)

Dividends

113

Net Finance income / (cost)

(17,765)

(13,108)

(30,873)

Share of profit/ (loss) of equity-accounted investees, net of tax

694

738

(648)

Impairment in participations

(5,524)

(341)

Profit / (Loss) from distribution in kind

22,157

Profit/(Loss) before income tax

56,238

76,179

132,417

Income tax expense

(10,119)

(8,384)

(18,502)

Profit/(Loss) for the year

46,119

67,795

113,915

12 months until 31 December 2021

Aluminium

Copper

Total

Annual Financial Report of 31 December 2021

Page | 90

Total assets

1,365,790

864,951

2,230,742

Total liabilities

870,564

551,862

1,422,425

Total

€ '000

Capital expenditure for 12 months until 31 December 2021

Aluminium

Copper

Total

Fixed Assets

152,375

14,798

167,174

Intangible Assets

329

344

Total

152,704

14,813

167,517

€ '000

Aluminium

Copper

Total

Depreciation of fixed assets

(44,225)

(21,441)

(65,667)

Depreciation of right of use assets

(2,311)

(692)

(3,003)

Amortization of intangible assets

(385)

(841)

(1,226)

Depreciation of investments in real estate

(100)

Total depreciation and amortization

(46,921)

(23,075)

(69,996)

Annual Financial Report of 31 December 2021

Page | 91

12 months until 31 December 2020

€ '000

Aluminium

Copper*

Total*

Total revenue per segment

975,944

1,052,886

2,028,831

Inter-segment revenue

(139)

(104)

(243)

Revenue from 3rd Parties

975,805

1,052,783

2,028,588

Cost of sales

(894,142)

(999,683)

(1,893,826)

Gross profit

81,663

53,099

134,762

Other Income

6,711

4,074

10,785

Selling and Distribution expenses

(11,851)

(9,579)

(21,430)

Administrative expenses

(33,531)

(20,775)

(54,306)

Impairment loss on receivables and contract assets

(12)

(473)

(485)

Other Expenses

(5,005)

(4,899)

(9,904)

Operating profit / (loss)

37,975

21,447

59,421

Finance Income

238

288

Finance Costs

(12,139)

(13,368)

(25,506)

Net Finance income / (cost)

(12,088)

(13,130)

(25,218)

Share of profit/ (loss) of equity-accounted investees

694

3,886

4,580

Profit/(Loss) before income tax

26,580

12,203

38,783

Income tax expense

(7,824)

(1,593)

(9,417)

Profit/(Loss) for the year

18,756

10,610

29,366

12 months until 31 December 2020

Aluminium

Copper

Total

Total assets

1,040,941

817,380

1,858,321

Total liabilities

605,306

474,728

1,080,034

€ '000

Capital expenditure for 12 months until 31 December 2020

Aluminium

Copper

Total

Fixed Assets

92,487

19,445

111,931

Intangible Assets

119

189

Total

92.557

19.564

112.120

€ '000

Aluminium

Copper

Total

Depreciation of fixed assets

(39,937)

(20,120)

(60,057)

Depreciation of right of use assets

(1,831)

(627)

(2,458)

Amortization of intangible assets

(425)

(599)

(1,024)

Depreciation of investments in real estate

(140)

(67)

(207)

Total depreciation and amortization

(42,332)

(21,413)

(63,745)

2020 is restated pursuant to the implementation of IAS 19. (Please see note 37).

Annual Financial Report of 31 December 2021

Page | 92

The operating segments are mostly managed centrally, but the greater part of sales are overseas. Sales and

non-current assets of the Group based on the geographical standing are presented as follows:

GROUP

COMPANY

31.12.2021

31.12.2020

31.12.2021

31.12.2020

€ '000

Greece

239,267

190,274

392,427

296,479

Other European Union

1,763,571

1,224,302

1,075,852

793,609

166,801

125,506

111,692

77,452

Other European countries

272,940

181,234

165,638

98,035

Asia

164,384

131,628

67,626

48,444

America

206,435

120,645

125,939

72,468

Africa

56,646

48,410

21,720

15,537

Oceania

12,999

6,590

8,927

3,635

Total

2,883,042

2,028,588

1,969,822

1,405,660

GROUP

COMPANY

31.12.2021

31.12.2020

31.12.2021

31.12.2020

€ '000

Property Plant Equipment

Greece

823,420

709,713

685,581

582,956

International

144,264

142,228

Total

967,684

851,942

685,581

582,956

Right of use assets

Greece

21,032

19,099

16,989

17,838

International

990

635

Total

22,021

19,734

16,989

17,838

Intangible assets and goodwill

Greece

87,403

79,326

70,329

70,627

International

2,526

148

Total

89,929

79,474

70,329

70,627

Investment property

Greece

3,244

6,267

17,499

18,714

Total

3,244

6,267

17,499

18,714

Capital expenditure

Greece

163,058

105,961

130,523

93,505

International

6,535

9,240

Total

169,593

115,201

130,523

93,505

Annual Financial Report of 31 December 2021

Page | 93

6. Income

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Sale of goods

652,111

561,943

579,841

479,669

Metal Turnover in the sales of goods

2,225,743

1,460,594

1,385,188

921,455

Rendering of services

5,187

6,051

4,793

4,537

Total

2,883,042

2,028,588

1,969,822

1,405,660

7. Other operating income and expenses

GROUP

COMMPANY

2021

2020

2021

2020

€ '000

Other Income

Grants of the Fiscal Year

Amortization of Grants

1,593

1,757

1,202

1,221

Rental income

350

352

277

314

Foreign Exchange Gains

4,866

1,139

1,959

1,026

Income from fees

749

231

Income from costs recharged

1,557

1,578

3,808

4,166

Damage Compensation

329

298

232

235

Gain from sale of Fixed assets

344

1,065

297

313

Income from consulting services

561

151

Other Income

5,813

3,744

5,043

3,191

Total

15,636

10,785

12,869

10,689

Other Expense

Impairment of Fixed assets

2,057

1,887

2,057

1,846

Loss from fixed assets write off

884

740

Loss from sale of Fixed assets

902

496

159

Foreign Exchange Losses

5,503

1,838

1,247

1,502

Other taxes

Penalties

Depreciation and amortisation

1,938

2,042

1,344

1,277

Expenses recharged

522

2,404

1,881

2,108

Other Expenses

1,018

1,135

1,122

504

Total

12,846

9,904

8,554

7,248

Net other income-expenses

2,789

881

4,315

3,441

Annual Financial Report of 31 December 2021

Page | 94

8. Expenses by nature

The breakdown of expenses by nature was as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Cost of inventories recognized as an expense

49,983

86,837

155,136

141,968

Metal Cost

2,176,246

1,463,182

1,361,423

916,602

Employee benefits

145,101

120,527

86,556

71,515

Energy

67,066

36,076

41,109

22,377

Depreciation and amortisation

67,996

61,703

46,292

41,931

Taxes - duties

11,293

8,108

7,707

6,136

Credit insurance expenses

2,143

2,070

1,451

1,074

Other insurance expenses

6,617

5,243

3,932

3,429

Rental fees

3,735

2,457

1,862

1,714

Transportation costs for goods and materials

64,946

47,498

42,290

30,406

Promotion & advertising

2,654

2,132

1,378

1,277

Third party fees and benefits

71,280

61,903

95,176

85,214

(Gains)/losses from derivatives

(6,532)

6,182

(12,691)

6,919

Storage and packing

5,242

4,400

1,477

1,079

Production tools

10,013

6,347

4,064

1,896

Commissions

16,027

14,017

9,877

8,956

Foreign exchange differences

(552)

1,561

432

288

Maintenance expenses

26,079

21,845

18,327

15,580

Travel and personnel transport expenses

5,592

5,607

3,539

4,593

Royalties

598

133

587

133

BOD Fees

1,808

1,452

585

Shared utility expenses

397

342

Other expenses

10,701

9,939

4,943

5,612

Total

2,738,433

1,969,377

1,875,452

1,368,592

The analysis of the above expenses as presented in the statement of profit and loss is as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Cost of sales

2,648,216

1,893,640

1,820,663

1,319,072

Selling and Distribution expenses

28,455

21,430

11,370

11,772

Administrative expenses

61,761

54,306

43,420

37,954

Total

2,738,433

1,969,377

1,875,452

1,368,799

2020 is restated pursuant to the implementation of IAS 19. (Please see note 37).

Annual Financial Report of 31 December 2021

Page | 95

For R&D expenses disbursed the amounts below:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Aluminium

3,939

3,021

3,505

2,474

Copper

2,756

2,755

2,756

2,549

Total

6,695

5,776

6,260

5,023

The cost of employees benefits can be broken down as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Employee remuneration & expenses

106,649

87,229

61,798

50,687

Social security expenses

22,791

21,242

13,207

12,637

Defined benefit plan expenses

2,960

1,794

2,072

942

Other employee benefits

12,956

10,076

9,478

7,249

Total

145,356

120,341

86,556

71,515

The number of staff employed by the Company at the end of the current year was: 1,672 (2020: 1,478)

and as for the Group: 3,494 (2020: 2,992).

9. Finance income and cost

The breakdown of financial income and expenses is as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Interest Income

279

288

446

400

Total

279

288

446

400

Interest expenses

26,410

22,995

20,594

17,467

Other Finance Expense

4,856

2,512

3,839

1,974

Total

31,266

25,506

24,434

19,414

*2020 is restated pursuant to the implementation of IAS 19. (Please see note 37).

Annual Financial Report of 31 December 2021

VI. NOTES TO THE FINANCIAL STATEMENTS AS AT 31 DECEMBER 2021

Page | 96

10. Property, plant and equipment

GROUP

€ '000

Fields - Plots

Buildings

Machinery

Transportation

equipment

Furniture &

other equipment

Fixed assets under

construction

Total

Cost

Balance as at 1 January 2020

103,194

205,641

921,678

19,808

24,364

170,816

1,445,503

Effect of movement in exchange rates

(1)

(12)

(14)

Additions

619

1,148

4,911

1,464

1,265

102,524

111,931

Disposals

(3,935)

(159)

(58)

(9,700)

(13,852)

Mergers and absorptions

Write offs

(3,495)

(120)

(3)

(868)

(4,487)

Other reclassifications

34,459

155,519

146

287

(190,765)

(323)

Balance as at 31 December 2020

103,845

241,247

1,074,678

21,140

25,883

71,995

1,538,789

Accumulated depreciation

Balance as at 1 January 2020

(95,286)

(499,729)

(15,427)

(20,990)

(806)

(632,238)

Effect of movement in exchange rates

(3)

Depreciation of the period

(11,660)

(46,098)

(941)

(1,358)

(60,057)

Disposals

2,559

153

2,752

Mergers and absorptions

(29)

Write offs

2,072

120

404

2,599

Reversal of impairment loss

127

Balance as at 31 December 2020

(106,949)

(541,196)

(16,096)

(22,332)

(274)

(686,847)

Carrying amount as at 31 December 2020

103,845

134,299

533,482

5,045

3,551

71,720

851,942

Annual Financial Report of 31 December 2021

Page | 97

GROUP

€ '000

Fields - Plots

Buildings

Machinery

Transportation

equipment

Furniture &

other equipment

Fixed assets under

construction

Total

Cost

Balance as at 1 January 2021

103,845

241,247

1,074,678

21,140

25,883

71,995

1,538,789

Effect of movement in exchange rates

(1)

(0)

(10)

(12)

Additions

14,539

14,168

7,689

971

1,686

128,120

167,174

Disposals

(208)

(1,649)

(1,904)

(341)

(71)

(452)

(4,625)

Mergers and absorptions

208

8,573

12,358

253

1,440

4,153

26,986

Reclassification from Investment Property

3,518

Write offs

(923)

(34)

(41)

(87)

(1,086)

Impairment loss

(1,645)

(411)

(2,057)

Other reclassifications

5,946

44,230

249

499

(51,656)

(732)

Balance as at 31 December 2021

116.739

271,391

1,136,129

22,238

29,396

152,062

1,727,955

Accumulated depreciation

Balance as at 1 January 2021

(106,949)

(541,196)

(16,096)

(22,332)

(274)

(686,847)

Effect of movement in exchange rates

(0)

Depreciation of the period

(12,812)

(49,865)

(1,056)

(1,933)

(65,667)

Disposals

821

969

131

1,976

Mergers and absorptions

(3,691)

(4,474)

(171)

(1,005)

(9,340)

Reclassification from Investment Property

(596)

Write offs

159

202

Other reclassifications

(4)

Balance as at 31 December 2021

(123,224)

(594,405)

(17,160)

(25,207)

(274)

(760,271)

Carrying amount as at 31 December 2021

116,739

148,166

541,725

5,078

4,189

151,787

967,684

Annual Financial Report of 31 December 2021

Page | 98

COMPANY

€ '000

Fields - Plots

Buildings

Machinery

Transportation

equipment

Furniture & other

equipment

Fixed assets under

construction

Total

Cost

Balance as at 1 January 2020

56,105

138,296

652,250

16,038

15,094

152,305

1,030,088

Additions

111

881

3,058

1,447

644

84,885

91,026

Disposals

(1,533)

(148)

(55)

(9,595)

(11,331)

Write offs

(1,529)

(120)

(464)

(2,113)

Other reclassifications

32,798

146,049

(179,141)

(105)

Balance as at 31 December 2020

56,246

171,975

798,294

17,279

15,780

47,990

1,107,565

Accumulated depreciation

Balance as at 1 January 2020

(64,955)

(395,072)

(12,927)

(13,395)

(127)

(486,477)

Depreciation of the period

(7,209)

(30,824)

(774)

(826)

(39,632)

Disposals

920

148

1,105

Write offs

147

120

394

Balance as at 31 December 2020

(72,164)

(424,830)

(13,433)

(14,183)

(524,609)

Carrying amount as at 31 December 2020

56,246

99,811

373,465

3,847

1,597

47,990

582,955

Annual Financial Report of 31 December 2021

Page | 99

COMPANY

€ '000

Fields - Plots

Buildings

Machinery

Transportation

equipment

Furniture & other

equipment

Fixed assets under

construction

Total

Cost

Balance as at 1 January 2021

56,246

171,975

798,294

17,279

15,780

47,990

1,107,565

Additions

8,210

12,998

5,396

335

1,273

101,275

129,486

Disposals

(2,989)

(250)

(39)

(452)

(3,729)

Mergers and absorptions

2,493

7,185

14,688

245

910

1,012

26,533

Write offs

(671)

(0)

(32)

(37)

(741)

Impairment loss

(1,645)

(411)

(2,057)

Other reclassifications

2,112

13,251

221

282

(15,946)

(80)

Balance as at 31 December 2021

65,303

193,859

827,969

17,831

18,173

133,842

1,256,976

Accumulated depreciation

Balance as at 1 January 2020

(72,164)

(424,830)

(13,433)

(14,183)

(524,609)

Depreciation of the period

(8,235)

(33,758)

(833)

(1,260)

(44,086)

Disposals

2,156

2,218

Mergers and absorptions

(3,163)

(638)

(235)

(882)

(4,918)

Write offs

Balance as at 31 December 2021

(1,645)

(83,562)

(457,069)

(14,461)

(16,304)

(571,395)

Carrying amount as at 31 December 2021

65,303

110,297

370,900

3,370

1,869

133,842

685,581

Annual Financial Report of 31 December 2021

VI. NOTES TO THE FINANCIAL STATEMENTS AS AT 31 DECEMBER 2021

Page | 100

(a) Pledges on Fixed Assets

There are pledges related to payment of loans for the fixed assets of the Group and the Company (see note 22).

(b) Assets under Construction

The account “Assets under construction” includes machinery the installation of which has not been completed as at

December 31, 2021.

For the fixed asset of the Group as well as the company Euro € 180 thousands was capitalized in 2021, which stands for

the cost of loans which were drawn for the funding of those assets.

(d) Change in useful life of assets

During 2021, the Group and the Company conducted a review regarding the operating efficiency of its fix assets,

resulted to reassess the useful life of specific buildings and machinery which are contributing in the production

process of the Aluminium segment of the Company.

In the context of development and implementation of the investment program of the Company and the Group by

the management, the continued maintenance and development operations are considered as significant factors for

the efficient operation of the assets, which in turn affect positive the future economic benefits that will be occurred

from the cash inflows of the current equipment.

As a result of the above, the useful life of buildings increased by 5years and the useful life of machinery increased

by 3 years on average. According to all described above, the useful life remained in the range determined by the

respective accounting policy.

This assessment increased the useful life which had as a consequence the depreciation expense to be reduced by

€1.1 mil. approximately for the year 2021. The application of the new useful life was done prospectively according

to the provisions of IAS 8, par. 36 within the fiscal year.

Annual Financial Report of 31 December 2021

Page | 101

11. Intangible assets

GROUP

€ '000

Goodwill

Cost of

development

Trademarks

and licenses

Software

Other

Total

Cost

Balance as at 1 January 2020

27,158

50,475

20,164

117

97,957

Effect of movement in exchange rates

(1)

Additions

189

Disposals

(2)

Other reclassifications

330

Balance as at 31 December 2020

27,158

50,475

20,681

117

98,473

Accumulated amortization and impairment

Balance as at 1 January 2020

(42)

(196)

(17,658)

(77)

(17,973)

Effect of movement in exchange rates

(1)

Amortization for the period

(75)

(945)

(4)

(1,024)

Disposals

Other reclassifications

(4)

Balance as at 31 December 2020

(42)

(271)

(18,606)

(81)

(19,000)

Carrying amount as at 31 December 2020

27,158

50,205

2,074

79,474

GROUP

€ '000

Goodwill

Cost of

development

Trademarks

and licenses

Software

Other

Total

Cost

Balance as at 1 January 2021

27,158

50,475

20,681

117

98,473

Effect of movement in exchange rates

(1)

(0)

(1)

Additions

250

344

Mergers and absorptions

14,652

398

1,305

612

16,967

Write-offs

(5)

Other reclassifications

421

279

732

Balance as at 31 December 2021

41,811

860

51,812

21,818

211

116,512

Accumulated amortization and impairment

Balance as at 1 January 2021

(42)

(271)

(18,606)

(81)

(19,000)

Effect of movement in exchange rates

(0)

Amortization for the period

(46)

(93)

(1,083)

(4)

(1,226)

Mergers and absorptions

(82)

(257)

(499)

(838)

Write-offs

(5,524)

Balance as at 31 December 2021

(5,524)

(169)

(621)

(20,183)

(86)

(26,583)

Carrying amount as at 31 December 2021

36,286

691

51,192

1,635

125

89,929

In respect of the goodwill of €27.2 million as well as the trade name and client relationships of Euro 46.7 million, an

impairment test was performed to test for any indication of impairment of the CGU of the copper segment using the

value in use method based on a five-year business plan, the results of which indicated no need for impairment. The

basic assumptions of the test were as follows:

Annual Financial Report of 31 December 2021

Page | 102

• Risk-free rate: (-)%

• Market risk premium: 5.1%

• Expected income tax rate: 22%

• Unlevered beta: 0.89

• WACC 6.9%

• Growth rate (g) : 1.6%

The expected fair value will be increased (decreased) by €40 million, if the expected growth of the market increases

(decreases) by 0.5%. In addition, should be noted that the expected fair value will be increased (decreased) by €11

million if the expected cash flows increase (decrease) by 1%. Finally, if the discount rate decreases (increases) by 1%,

the expected fair value will be increased (decreased) by €133 million

An increase in WACC caused by the aforementioned factors by one hundred basis units does change the discounted cash

flows and as a consequence the fair value significantly enough to cause an impairment.

Intangible assets, as trade name and client relationships of Euro 46.7 million, do not have a legal or similar maturity as to

the creation of cash flows. As a result, the useful life is indefinite.

The acquirer Elvalhalcor, upon the completion of the allocation of the purchase price for ETEM Group recognized

intangible assets of €1.030 thousands for royalties owned by ΕΤΕΜ COMMERCIAL S.A.. The valuation method is the

Discounted Cash Flow valuation method (DCF). The valuation model calculates the present value of the net cash inflows

from the royalties’ contracts. The aforementioned intangible asset fulfils both the separability criterion and contractual-

legal criterion. The aforementioned criteria are recognised by IAS 38. The useful life considered to five (5) years equal to

the minimum term of the contract. Finally, should be noted that for the above asset have been recognised deferred tax

of €227 thousands.

COMPANY

€ '000

Goodwill

Trademarks

and licenses

Software

Total

Cost

Balance as at 1 January 2020

22,118

47,370

15,620

85,108

Additions

155

Other reclassifications

105

Balance as at 31 December 2020

22,118

47,370

15,880

85,368

Accumulated amortization and impairment

Balance as at 1 January 2020

(134)

(13,905)

(14,039)

Amortization for the period

(67)

(634)

(701)

Balance as at 31 December 2020

(201)

(14,540)

(14,741)

Carrying amount as at 31 December 2020

22,118

47,169

1,340

70,627

Annual Financial Report of 31 December 2021

Page | 103

COMPANY

€ '000

Goodwill

Trademarks and

licenses

Software

Total

Cost

Balance as at 1 January 2021

22,118

47,370

15,620

85,108

Additions

182

Mergers and absorptions

359

Other reclassifications

Balance as at 31 December 2021

22,118

47,370

16,501

85,989

Accumulated depreciation

Balance as at 1 January 2021

(201)

(14,540)

(14,741)

Amortization for the period

(67)

(634)

(649)

Mergers and absorptions

(270)

Balance as at 31 December 2021

(268)

(15,392)

(15,660)

Carrying amount as at 31 December 2021

22,118

47,102

1,109

70,329

ElvalHalcor tested Goodwill for impairment. As a result of the impairment loss recognized in the investment of ETEM BG by the

subsidiary ETEM COMMERCIAL S.A., ElvalHalcor remeasured the Group of ETEM, included the new data, whereupon there was a

need for impairment loss at Group level by €5.5 million. According to paragraph 104 of IAS, the Group impaired the recorded

Goodwill of the CGU of ETEM Group by €5.5 million. Refer to note 13 for more information.

12. Investment property

GROUP

€ '000

2021

2020

Cost

Balance as at 1 January

6,997

7,144

Disposals

(147)

Reclassifications to PPE

(3,518)

Balance as at 31 December

3,478

6,997

Accumulated depreciation

Balance as at 1 January 2018

(729)

(555)

Disposals

Reclassifications to PPE

596

Depreciation

(100)

(207)

Balance as at 31 December

(234)

(729)

Carrying amount as at 31 December

3,244

6,267

Annual Financial Report of 31 December 2021

Page | 104

COMPANY

€ '000

2021

2020

Balance as at 1 January

33,939

34,086

Disposals

(147)

Balance as at 31 December

33,939

Balance as at 1 January

(15,225)

(14,042)

Depreciation

(1,215)

(1,216)

Disposals

Balance as at 31 December

(16,440)

(15,225)

Carrying amount as at 31 December

17,499

18,714

Investment property includes buildings and land that the Group and the Company intend to lease or sell to third parties

in the near future, provided circumstances allow it. The investment property of the company is rented to Group

Companies and at the consolidated financial statements are presented at Fixed Assets as PPE.

The fair values of the investment property which are included in the reporting line “Investment Property” was as follows:

Property category

Fair Value in € ‘000

Industrial Buildings

2,739

Land and Land Plots

1,142

Other property

333

Total

4,214

The valuation of the investment property of the Group for the year ending 31

December 2021 was carried out by external,

independent property valuators. The independent valuators are members of qualified associations and recent experience and

appropriate knowledge in the location and category of the property of the Group being valued. The valuation method was used for the

measurement of the fair value of the investment properties of the Group reflect the efficient and best use of these properties, as

determined by the management of the Group. For the measurement of the fair value of the property used the Comparative Method

of property valuations. These observable data adjusted to affect the relevant characteristics of each property. Investment property

considered as level 3. The Group and the Company are not obligated to carry out a valuation of the fair value of the investment property

on a regular basis.

During 2021, and as a result of the acquisition of ETEM, property of carrying amount of Euro 2.4 million (fair value Euro 5.3 million) was

reclassified to PPE due to full consolidation of the ETEM Group.

On Company’s level are presented, additionally to the above properties, investment properties that are leased to consolidated entities,

which are reclassified to Fixed Assets on consolidated level. The Company measured the fair value of these on January 2021, which

amounted to EUR Euro 23 million. The Group and the Company are not obligated to carry out a valuation annually.

Annual Financial Report of 31 December 2021

Page | 105

13. Investments

Investments in Subsidiaries:

COMPANY

2021

2020

€ '000

Balance as at 1 January

271,359

264,672

Additions

28,406

6,687

Division/ segment spin off

Mergers

(25,792)

Impairment

(4,619)

Balance as at 31 December

269,353

271,359

Following the decision of the Extraordinary General Meeting of the subsidiary “ELVIOK S.A.” dated 25.01.2021, share

capital of the subsidiary was raised by Euro 500 thousand, paid in cash with issuance 50,000 shares, with nominal

value of Euro 10.00 each. Furthermore, following the decision of the Annual General Meeting on 30.09.2021 of

“ELVIOK S.A.”, share capital of the subsidiary was increased by 1.7 million euro paid in cash with issuance of 170,000

thousand shares, with nominal value of Euro 10.00 each.

On 01.07.2021 the decision with Registration Code Number 2574251 and protocol Nr.73823/01.07.2021 (ΑΔΑ:

6ΞΟ046ΜΤΛΡ-ΞΤΥ) of the Ministry of Development and Investments, General Secretariat of Commerce and

Consumer Protection, was registered in the General Commercial Registry (“G.E.MI.”), by operation of the aforesaid

decision the merger by absorption of “FITCO” by “ELVALHALCOR” was approved, pursuant to the aforementioned

Laws, the draft merger terms of the merging companies dated 19.05.2021, the decisions of the Board of Directors

dated 14.05.2021 of the merging companies, and the no. 7163/29.06.2021 notarial deed of the Notary Public Marina

G. Karageorgi.

Following the decision of the Extraordinary General Meeting of the subsidiary Epirus Metalworks dated 22.02.2021,

the capital of the subsidiary was raised by Euro 1,889.1 thousand, paid in cash with issuance of 44,450 shares with

premium, of nominal value Euro 10.00 each and issue price of Euro 42.50 each.

ELVALHALCOR tested for impairment its subsidiaries, considering the new market conditions. Tests concluded that

the book value was less than the valuation by Euro 125 thousand for the participation of TECHOR SA and Euro 216

thousand for the participation in HC ISITMA A.S. The negative effect from the revaluation affected the Statement of

Profit and Loss of the parent company ELVALHALCOR and is posted in the reporting line “Impairment of

participations” in the Statement of Profit and Loss.

On 30.03.2021, ELVALHALCOR paid in full the capital increase of “ETEM S.A.” of total EUR 24,316,420.00, more

specifically, by contribution of EUR 22,800,000.00 in cash and amount of EUR 1,516,420.00 in contribution in kind

(machinery). As a result, of the completion of the capital increase of “ETEM S.A.”, “ELVALHALCOR S.A.” is shareholder

of 70,000 registered common voting shares issued by “ETEM S.A.” with nominal value of EUR 4.00 each, which

represent an 80% of the share capital of “ETEM S.A.”. The financial results of “ETEM S.A.” are included in the financial

results of ElvalHalcor from 01.04.2021. The valuation process of the assets and liabilities of the acquired ETEM to

the fair value under the provisions of paragraph 18 of IFRS was completed within the deadlines set forth by

paragraph 45 of IFRS 3. The goodwill from the transaction was calculated at the amount of Euro 6.9 million for the

Cash Generating Unit (CGU) of ETEM BG and Euro 7.8 million for the Cash Generating Unit (CGU) of ETEM S.A..

The acquirer Elvalhalcor, upon the completion of the allocation of the purchase price for ETEM Group recognized

intangible assets of €1.030 thousands for royalties owned by ΕΤΕΜ COMMERCIAL S.A.. The valuation method is the

Discounted Cash Flow valuation method (DCF). The valuation model calculates the present value of the net cash

inflows from the royalties’ contracts. The aforementioned intangible asset fulfils both the separability criterion and

contractual-legal criterion. The aforementioned criteria are recognised by IAS 38. The useful life considered to five

(5) years equal to the minimum term of the contract. Finally, should be noted that for the above asset have been

recognised deferred tax of €227 thousands.

Annual Financial Report of 31 December 2021

Page | 106

€ '000

31.03.2021

ASSETS

Non-current assets

Property, plant and equipment

19,163

Right of use assets

3,352

Intangible assets and goodwill

1,477

Deferred income tax assets

625

Trade and other receivables

24,694

Current assets

Inventory

18,257

Trade and other receivables

12,314

Income tax receivables

783

Cash and cash equivalents

2,577

33,930

Total assets

58,625

LIABILITIES

Non-current liabilities

Lease liabilities

2,817

Deferred tax liabilities

227

Employee benefits

337

Grants

427

3,808

Current liabilities

Trade and other payables

38,543

Contract Iiabilities

156

Loans & Borrowings

3,358

Obligations under financial lease

636

Provisions

42,737

Total liabilities

46,544

Fair Value of Net Assets Acquired

12,080

Non-controlling interest

2,416

Net Assets Acquired Attributable to Shareholders of ElvalHalcor

9,664

Consideration for the Business Combination

24,316

Goodwill attributed to the CGU of ETEM BG

6,891

Goodwill attributed to the CGU of ETEM S.A.

Goodwill

7,760

14,652

Annual Financial Report of 31 December 2021

Page | 107

In the table that follows are included:

1. In the first column are presented the statements of profit and loss of ΕΤΕΜ Group from 01.01.2021 until

the acquisition date, i.e. 31.03.2021.

2. In the second column are presented the statement of profit and loss of ETEM Group since acquisition date,

i.e. 31.03.2021.

3. The third column represents the consolidated results of of ElvalHalcor Group, excluded the financial result

of ETEM Group.

4. In the fourth column are presented the statement of profit and loss of ElvalHalcor Group as the transaction

was materialised on 01.01.2021.

EUR

Financial results

of ETEM Group

prior to the

transaction date

Financial results

of ETEM Group

since the

acquisition date

Financial Results of

the Consolidated

ElvalHalcor Group

after the

transaction date

Total

Revenue

11,615

65,137

2,817,904

2,894,657

Cost of sales

(9,814)

(56,313)

(2,591,903)

(2,658,030)

Gross profit

1,801

8,824

226,001

236,627

Other Income

119

631

15,004

15,755

Selling and Distribution expenses

(2,026)

(6,470)

(21,985)

(30,481)

Administrative expenses

(1,013)

(2,485)

(59,276)

(62,774)

Impairment loss on receivables and contract assets

(9)

(286)

(204)

(498)

Other Expenses

(106)

(489)

(12,357)

(12,952)

Operating profit / (loss)

(1,234)

(275)

147,184

145,675

Finance Income

264

287

Finance Costs

(101)

(324)

(30,942)

(31,367)

Dividends

113

Net Finance income / (cost)

(92)

(310)

(30,564)

(30,966)

Share of profit/ (loss) of equity-accounted investees, net of tax

Impairment in participations

(4,524)

(1,341)

(5,865)

Profit/ (loss) for distribution in kind

22,157

Profit/(Loss) before income tax

(1,327)

(5,108)

137,526

131,090

Income tax expense

1,024

(19,527)

(18,466)

Profit/(Loss) for the year

(1,291)

(4,084)

117,999

112,624

On 31.12.2021, the Group and the Company tested for impairment its subsidiaries, based on the updated business

plans, as they reflect the expected net cash flows based on management estimates. The valuation model calculates

the present value of the net cash flows generated by each CGU. According to the impairment test conducted, the

estimates for the commercial subsidiaries of ETEM GR revised for the worse, taking into account the inability of

growth in Balkan countries and the extended negative impact of the pandemic to countries with low vaccination

coverage and prolonged persistence of negative impacts in the financial climate. As a consequence of the revisions,

the investments of ETEM GR had to be impaired by Euro 4.5 million at the level of ETEM GR. Consequently,

ELVALHALCOR at company level and following the updated forecasts impaired its investement in ETEM GR by Euro

4.5 million. As a result of the aforementioned impairments, ELVALHALCOR remeasured ETEM GR Group taking into

account the new assumptions, which resulted to a new impairment loss at group level by euro 5.5 million. Taking

into account the new data as follows: Risk-free rate: 0,2%, Market risk premium: 6,9%, Expected income tax rate:

10,0%, Levered beta: 1,28, WACC 7,4%, Growth rate (g): 1,6%. Pursuant to par. 104 of IAS 36, the Group recorded

an impairment loss for the booked goodwill of the CGU of ETEM Group by Euro 5.5 million.

Annual Financial Report of 31 December 2021

Page | 108

Information of subsidiaries with significant non-controlling interest presented in the next page:

2021

€ '000

VΙΟΜΑL S.A.

SOFIA MED

S.A.

ΕΤΕΜ.

Other

Total

Percentage of Non-Controlling Interest

25.00%

10.44%

20.00%

Non-Current Assets

2,812

138,817

26,508

Current Assets

7,483

209,899

45,704

Non-current Liabilities

447

54,483

2,691

Current Liabilities

4,495

138,814

55,357

Net Assets

5,352

155,419

14,164

Attributable to NCI

1,338

16,226

2,833

(1,299)

19,097

Revenue

18,577

712,681

65,137

Profit / (Loss)

900

27,106

(4,060)

Other Comprehensive Income

(10)

1,052

(15)

Total Comprehensive Income

890

28,158

(4,075)

Total OCI of NCI

223

2,940

(815)

(17)

2,330

Cash-Flows from Operating Activities

(78)

(21,049)

8,985

Cash-Flows from Investing Activities

(451)

(6,374)

(1,376)

Cash-Flows from Financing Activities

(16)

25,106

425

Effect on Cash and Cash equivalents

(545)

(2,317)

8,034

2020

€ '000

VΙΟΜΑL S.A.

SOFIA MED S.A.

Other

Total

Percentage of Non-Controlling Interest

25.00%

10.44%

Non-Current Assets

2,654

142,357

Current Assets

6,323

134,013

Non-current Liabilities

755

62,838

Current Liabilities

3,933

86,272

Net Assets

4,288

127,260

Attributable to NCI

1,072

13,286

(6)

14,352

Revenue

14,652

472,111

Profit / (Loss)

470

8,997

Other Comprehensive Income

(23)

1,753

Total Comprehensive Income

447

10,750

Total OCI of NCI

112

1,122

1,234

Cash-Flows from Operating Activities

2,018

(9,146)

Cash-Flows from Investing Activities

(149)

(11,091)

Cash-Flows from Financing Activities

(538)

6,143

Effect on Cash and Cash equivalents

1,330

(14,094)

Annual Financial Report of 31 December 2021

Page | 109

The movement in the account of the companies consolidated using the equity method is as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Balance as at January 1

91,745

85,801

84,965

80,965

Effects from Foreign Exchange

(34)

(1,115)

Share in profit / (loss) after taxes

4,580

Additions

3,000

4,000

3,000

4,000

Dividends received

(1,208)

(4,916)

Share capital reduction (-)

(967)

Reclassifications

(3)

Other changes

(791)

(314)

Dividend in kind

(63,074)

(52,628)

Balance as at December 31

29,964

91,745

30,417

84,965

On 09.04.2021, ELVALHALCOR’s Extraordinary Shareholder’s General Meeting decided the distribution of shares owned

by ELVALHALCOR, and issued by the Belgian company “Cenergy Holdings S.A.” (“Cenergy Holdings”) which is listed on

Euronext Brussels and Athens Stock Exchange, to its shareholders as distribution of dividend of prior year profits in kind,

under the L.4548/2018. As a result of the aforementioned distribution, ELVALHALCOR now holds 3,034 shares (0.002%)

out of 190,162,681 shares, which the share capital of “Cenergy Holdings” is divided into, versus 47,847,092 shares

(25.16%), which ELVALHALCOR held before the conclusion of aforementioned distribution. Following the reduction of

percentage of participation of ElvalHalcor in Cenergy Holdings, any “significant influence” of ElvalHalcor to Cenergy

Holdings ceased, on the aforementioned date. The financial results of Cenergy Holdings have been consolidated using

the equity method until 31.03.2021, date closer to the date of the distribution. The effect of the said distribution is

presented in the reporting line “Profit / (Loss) from distribution in kind” of the interim statement of profit and loss. (see

also note 36).

During 2021, a share capital increase was performed in Nedzink B.V. in which ELVALHALCOR participated by paying Euro

3 million and thus maintaining its share to 50%. However, delays in the full operation of the equipment, in line with

increased problems due to COVID-19 at the end of the year resulted in losses of production and sales, impacting 2021

results more than initially expected. ELVALHALCOR, at its annual impairment testing of its assets and following the

principle of conservatism, incorporated negative estimates for the future results of NedZink B.V. at its business plan

level. As a result of the negative assessments, ELVALHALCOR impaired its investment in NedZink B.V. by 4.7 million

euros, since the recoverable amount was less than the book value of the investment at company level. The assumptions

used were as follows: Risk-free rate: 0,2%, Market risk premium: 6,9%, Expected income tax rate: 10,0%, Levered beta:

1,28, WACC 7,4%, Growth rate (g): 1,6%.

Annual Financial Report of 31 December 2021

Page | 110

The main financial assets of these associated companies can be broken down as follows:

Company

Country

Business

Consolidation

method

% Investment

2021

2020

UACJ ELVAL HEAT EXCHANGER

MATERIALS GmbH

Germany

Commercial

Equity method

49.00%

International Trade S.A.

Belgium

Commercial

Equity method

27.97%

STEELMET S.A.

Greece

Services

Equity method

29.50%

ELKEME S.A

Greece

Metallurgical Research

Equity method

92.50%

VIENER S.A

Greece

Eenenrgy

Equity method

41.32%

VIEXAL S.A

Greece

Services

Equity method

26.67%

HC ISITMA A.S.

Turkey

Industrial

Equity method

50.00%

NEDZINK B.V.

Netherlands

Industrial

Equity method

50.00%

Company

Current Assets

Non-current

assets

Current Liabilities

Long term Liabilities

2021

2020

2021

2020

2021

2020

2021

2020

UACJ ELVAL HEAT EXCHANGER MATERIALS GmbH

9,317

9,219

7,834

7,843

International Trade S.A.

187,131

141,997

7,681

8,559

145,803

105,841

6,461

7,082

STEELMET S.A.

7,847

6,786

3,561

3,049

7,937

6,515

1,710

1,652

ELKEME S.A

1,460

1,649

1,047

700

289

349

123

VIENER S.A

10,294

3,214

1,698

721

6,934

1,971

2,550

307

VIEXAL S.A

2,000

1,768

1,259

1,239

HC ISITMA A.S.

146

244

146

244

NEDZINK B.V.

31,325

25,959

49,598

49,083

28,940

32,561

43,186

29,255

Revenue

Share of profit

/(loss) after tax

Profit / (Loss)

Other

comprehensive

after tax

Dividend

2021

2020

2021

2020

2021

2020

2021

2020

UACJ ELVAL HEAT EXCHANGER MATERIALS GmbH

53,775

37,974

1,074

923

964

1,058

International Trade S.A.

1,438,330

731,871

5,816

479

(196)

(670)

704

1,021

ΣΤΗΛΜΕΤ Α.Ε.

39,478

32,052

825

786

(112)

(31)

620

557

ΕΛΚΕΜΕ Α.Ε.

2,786

2,777

127

121

(1)

ΒΙΕΝΕΡ Α.Ε.

33,428

9,677

724

541

179

106

ΒΙΕΞΑΛ ΑΕ

9,705

7,952

668

444

(1)

(4)

457

473

HC ISITMA A.S.

518

592

(1)

(2)

NEDZINK B.V.

86,636

79,602

(8,930)

(5,778)

The Group does not control Elkeme S.A. as the management is being appointed directly by Viohalco. Elkeme is

consolidated in full by Viohalco S.A.

Annual Financial Report of 31 December 2021

Page | 111

14. Other investments

Other investments include the following:

GROUP

COMPANY

EUR

2021

2020

2021

2020

Unlisted Securities

€ '000

-Greek Equity instruments

3,333

3,406

3,290

1,291

-International Equity instruments

898

895

898

895

Total

4,231

4,301

4,188

2,185

Other investments related to domestic or foreign equity instruments for which neither the Group nor the Company

has the power or significant influence.

The movement in other investments was as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Balance as at January 1

4,302

3,611

2,185

1,682

Additions

539

532

Change in Fair Value

179

Mergers and absorptions

1,995

Sales

(79)

Reclassifications

(29)

Balance as at December 31

4,231

4,302

4,189

2,185

The participations for which the fair value cannot be estimated were valued at cost. For the calculation of the fair value

please see note 28. The fair value recorded through OCI statement (FVTOCI).

Annual Financial Report of 31 December 2021

Page | 112

15. Income tax

Amounts recognised in profit or loss

EUR

2021

2020

2021

2020

Current tax expense

(20,201)

(12,165)

(16,203)

(8,685)

Deferred tax (expense)/income

1,699

2,747

3,992

3,253

Tax expense

(18,502)

(9,417)

(12,211)

(5,432)

Reconciliation of effective tax rate

Accounting Profit/loss (-) before income tax

132.417

38.783

100.456

22.592

Tax rate in Greece

22%

24%

22%

24%

At statutory income tax rate

(29,132)

(9,308)

(22,100

)

(5,373)

Non-deductible expenses for tax purposes

(3,564)

(2,178)

(1,098)

(1,152)

Tax-exempt income

138

1,788

621

851

Effect of tax rates in foreign jurisdictions

3,592

1,401

Current-year losses for which no deferred tax asset is

recognised

(72)

(329)

Change in tax rate or composition of new tax

4,524

3,712

Other taxes

(10)

242

Permanent Differences

6,394

(798)

7,173

Derecognition of previously recognised deferred tax assets

(2)

Changes in tax related to prior years

(372)

(6)

(518)

(14%)

(18,503)

(14%)

(9,417)

(14%)

(12,211)

(14%)

(5,432)

Income tax expense reported in the statement of profit or

loss

(18,503)

(9,417)

(12,211)

(5,432)

The deferred tax assets that arise from the losses carried forward are recognized only if it is possible that they will be

recovered with future profits according to the Groups business plan. There were no losses carried forward for the Group

and the Company, therefore on deferred tax asset has been recognized for the fiscal year 2021.

Pursuant to Law.4799/2021 tax rate reduced to 22% for income of legal entities for the tax year 2021 and onwards. The

effect of the change in tax rate amounted to Euro 4.5 million and 3.7 million for the Group and the Company respectively.

The provisions of article 49 and paragraph 9 of article 72 of Law 4172/2013, as amended with the L.4607/2019, regarding

thin capitalization, were applicable according to which the limit of the additional interest expense is set to 30% of the

EBITDA. These interest expense that are not deducted can be settled with future tax profits with no time limitations.

For the fiscal year 2021, the Company and its subsidiaries are under the audit of the Certified Public Accountants,

according to the provisions of article 65A of L. 4174/2013. This audit is on-going, and the relative report of tax compliance

is expected to be issued after the publication of the financial statements for the year ended on 31st December 2021. The

result of the audit is not expected to significantly affect the financial statements.

The unaudited years of the Group can be found in Note 30.

Annual Financial Report of 31 December 2021

VI. NOTES TO THE FINANCIAL STATEMENTS AS AT 31 DECEMBER 2021

Page | 113

The movement in deferred tax assets and liabilities can be presented as follows:

GROUP

€ '000

Net balance at 1

January 2020

Recognised in

profit or loss

Recognised

in OCI

Change in

tax rate

Other

Net Balance at

31 December

2020

Deferred tax

assets

Deferred tax

liabilities

Property, plant and equipment

(53,110)

2,097

(51,013)

(51,045)

Right of use asset

(512)

980

469

670

(201)

Intangible assets

(11,361)

(51)

(11,412)

(11,434)

Investment property

(370)

(2)

(372)

202

(573)

Other investments

202

(202)

(43)

Derivatives

(270)

(655)

(893)

(104)

(788)

Inventories

(476)

(892)

(1,368)

(1,381)

Loans and borrowings

222

(126)

138

(42)

Employee benefits

3,960

1,815

2,271

4,243

Provision/ accruals

1,912

1,950

1,956

(6)

Deferred income

(164)

(152)

(162)

Other items

2,173

1,001

3,215

3,253

(38)

Carry-forward tax loss

Tax assets/liabilities (-) before set-off

(57,616)

2,747

(607)

1,815

(57,248)

8,465

(65,714)

Set-off tax

(8,294)

8,294

Net tax assets/liabilities (-)

(57,250)

172

57,421

Annual Financial Report of 31 December 2021

Page | 114

GROUP

€ '000

Net balance at 1

January 2021

Recognised in

profit or loss

Recognised

in OCI

Mergers

and

absorbtions

Change

in tax

rate in

profit

and loss

Change in

tax rate in

OCI

Other

Net Balance at 31

December 2021

Deferred

tax assets

Deferred tax

liabilities

Property, plant and equipment

(51,013)

(4,590)

327

4,022

(51,254)

Right of use asset

469

(9)

(61)

432

Intangible assets

(11,412)

912

(10,419)

Investment property

(372)

(312)

Other investments

(43)

995

956

Derivatives

(893)

(30)

(473)

(6)

(3)

(1,404)

Inventories

(1,368)

(676)

126

122

(1,796)

Loans and borrowings

(85)

(9)

Employee benefits

2,271

558

101

(562)

2,406

Provision/ accruals

1,950

256

(170)

2,070

Deferred income

(152)

(59)

Other items

3,215

569

187

4,048

Carry-forward tax loss

Tax assets/liabilities (-) before set-off

(57,250)

(2,826)

(372)

595

4,524

(2)

(55,327)

9,917

(65,245)

Set-off tax

(8,238)

8,238

Net tax assets/liabilities (-)

(55,327)

1,679

(57,006)

Annual Financial Report of 31 December 2021

Page | 115

COMPANY

€ '000

Net balance at 1

January 2020

Recognised in

profit or loss

Recognised

in OCI

Change in

accounting

policy

Net Balance at 31

December 2020

Deferred

tax assets

Deferred tax

liabilities

Property, plant and equipment

(42,171)

2,421

(39,750)

Right of use asset

(308)

968

660

Intangible assets

(10,982)

(52)

(11,034)

Investment property

(572)

(2)

(573)

Other investments

202

(202)

Derivatives

(246)

318

(578)

(506)

Inventories

(579)

(761)

(1,340)

Loans and borrowings

205

(67)

138

Employee benefits

2,750

(1,303)

1,540

Provision/ accruals

1,516

(115)

1,401

Deferred income

(161)

(128)

Other items

1,201

869

2,070

Tax assets/liabilities (-) before set-off

(48,950)

3,253

(521)

(1,303)

(47,521)

5,810

(53,330)

Set-off tax

(5,810)

5,810

Net tax assets/liabilities (-)

(47,521)

Annual Financial Report of 31 December 2021

Page | 116

€ '000

Net balance at

1 January 2021

Recognised

in profit or

loss

Recognised

in OCI

Mergers

and

absorptions

Change in

tax rate

recognised in

profit or loss

Change in

tax rate

recognised

in OCI

Other

Net Balance

at 31

December

2021

Deferred

tax assets

Deferred

tax

liabilities

Property, plant and equipment

(39,750)

(2,371)

(3,856)

3,152

(42,825)

Right of use asset

660

(55)

617

Intangible assets

(11,034)

(319)

913

(10,430)

Investment property

(573)

(514)

Other investments

400

(39)

Derivatives

(506)

(319)

(422)

114

(6)

(1,138)

Inventories

(1,340)

(599)

(7)

111

(1,835)

Loans and borrowings

138

(107)

(30)

(12)

(10)

Employee benefits

1,540

492

(538)

1,655

Provision/ accruals

1,401

412

390

(118)

2,085

Deferred income

(128)

(35)

(162)

Other items

2,070

2,666

280

217

5,633

Tax assets/liabilities (-) before set-off

(47,521)

280

(351)

(3,085)

3,712

(46,963)

9,990

(56,953)

Set-off tax

(9,990)

9,990

Net tax assets/liabilities (-)

(46,963)

Annual Financial Report of 31 December 2021

VI. NOTES TO THE FINANCIAL STATEMENTS AS AT 31 DECEMBER 2021

117

The movement of deferred tax in Other Comprehensive Income was as follows:

GROUP

2021

2020

€ '000

Before

Tax

(expense) /

Benefit

Net of

Tax

Before

Tax

(expense)

/ Benefit

Net of Tax

Amounts recognized in the OCI

Remeasurements of defined benefit liability

(343)

102

(241)

(424)

(333)

Equity investments in FVOCI - net change in fair value

178

(43)

135

Foreign currency translation differences

(132)

(1,145)

Gain / (Loss) of changes in fair value of cash flow hedging -

effective portion

3,300

(725)

2,445

3,899

(656)

3,243

Gain / (Loss) of changes in fair value of cash flow hedging -

reclassified to profit or loss

(432)

249

Other movements that are or may be reclassified to profit or loss

(314)

Total

2,442

(374)

2,069

2,203

(606)

1,597

COMPANY

2021

2020

€ '000

Before

Tax

(expense) /

Benefit

Net of

Tax

Before

Tax

(expense)

/ Benefit

Net of Tax

Amounts recognized in the OCI

Remeasurements of defined benefit liability

(335)

(262)

(237)

(180)

Gain / (Loss) of changes in fair value of cash flow hedging -

effective portion

4,144

(912)

3,232

2,642

(634)

2,008

Gain / (Loss) of changes in fair value of cash flow hedging -

reclassified to profit or loss

(2,033)

489

(1,544)

(235)

(178)

Total

1,776

(349)

1,427

2,170

(521)

1,649

16. Inventories

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Merchandise

11,161

1,887

1,835

1,049

Finished goods

176,994

116,840

113,208

73,083

Semi-finished goods

184,890

135,258

135,609

89,800

By-products & scrap

59,498

36,053

35,530

19,448

Work in progress

14,527

9,660

3,480

2,160

Raw and auxiliary materials

155,858

116,251

73,197

56,032

Consumables

10,720

9,379

5,929

5,660

Packaging materials

2,453

1,960

825

637

Spare parts

81,504

76,487

67,126

60,946

Total

697,605

503,773

436,739

308,816

Inventories are recognized in the net realizable value which reflects the estimated value of sale less costs to sale.

Annual Financial Report of 31 December 2021

Page | 118

17. Trade and other receivables

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Trade receivables

141,509

85,044

66,475

32,322

Less: Impairment losses

(8,520)

(8,431)

(6,175)

(5,315)

Receivables from related entities

117,724

139,164

162,543

179,772

Trade receivables from contracts with customers

250,712

215,777

222,843

206,779

Down payments

3,521

1,597

551

710

Tax assets

29,289

27,957

21,977

20,915

Other debtors

11,535

3,477

4,475

1,657

Other receivables

3,397

6,008

2,123

2,704

Less: Impairment losses

(211)

Total

298,243

254,606

251,758

232,555

Non-current assets

Non-current receivables from related parties

2,700

877

1,091

811

Νon-current receivables

2,347

1,871

1,799

1,592

Total

5,048

2,748

2,890

2,403

Total receivables

303,290

257,354

254,647

234,958

The provision for doubtful customers is created for the outstanding balances for which the Management of the

Group considers as impaired less the expected remuneration from the insurance.

18. Derivatives

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Non-current assets

Future contracts

Total

Current assets

Forward foreign exchange contracts

214

1,305

139

1,219

Future contracts

6,065

4,171

3,050

2,126

Commodity Forward Start Swaps

7,847

Total

14,125

5,477

11,037

3,346

Non-current liabilities

Forward foreign exchange contracts

270

Commodity Forward Start Swaps

3,205

Total

3,205

270

3,205

270

Current liabilities

Forward foreign exchange contracts

1,055

275

386

Future contracts

2,053

1,637

2,053

1,036

Total

3,108

1,912

2,439

1,097

Annual Financial Report of 31 December 2021

Page | 119

For the Group and the Company results from settled financial risk management operations recorded in the Income

Statement during years 2021 and 2020 are included in Cost of Goods Sold for results from metal and exchange

rate derivatives.

The amount of Gains / (Losses) from the valuation of derivatives as cash flow hedge reclassified to statement of

profit and loss of the Group for the fiscal year 2021 was gains of Euro 432 thousands (2020: Loss 8 thousands) and

at Company level was Euro 2,033 thousand (2020: gains 235 thousand). Total impact of the derivatives reclassified

to profit and loss during the fiscal year as well as the prior year was as follows:

ΟΜΙΛΟΣ

ΕΤΑΙΡΕΙΑ

2021

2020

2021

2020

€ '000

(Gains) / Losses from derivatives

(6,532)

6,182

(12,691)

6,919

The movement of derivatives in equity was as follows:

ΟΜΙΛΟΣ

ΕΤΑΙΡΕΙΑ

2021

2020

2021

2020

€ '000

Gain / (Loss) of changes in fair value of cash flow

hedging - effective portion

3,300

3,899

4,144

2,642

Gain / (Loss) of changes in fair value of cash flow

hedging - reclassified to profit or loss

(432)

(2,033)

(235)

Related Tax

(476)

(655)

(422)

(578)

Σύνολο

2,392

3,252

1,689

1,829

19. Cash and cash equivalents

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Cash in hand

306

Short-term bank deposits

91,127

33,532

57,237

12,611

91,144

33,838

57,242

12,627

Bank deposits are set at variable interest rates according to the applicable rates of interbank market. Short term

bank deposits are assigned to bank institutions with varied credit ratings, from A2 to Caa2.

In Note 27.c that is referred to currency risk of the Group, an analysis of cash per foreign currency is presented.

Annual Financial Report of 31 December 2021

Page | 120

20. Share capital and reserves

a) Share capital and premium

Following the completion of the Merger by absorption of “ELVAL HELLENIC ALUMINIUM INDUSTRY S.A.” by “HALCOR

METAL WORKS S.A.”, the share capital of the Company amounts to Euro 146,344,218 (2020: Euro 146,344,218)

divided to 375,241,586 (2020: 375,241,586) common anonymous shares of a nominal value of € 0.39 (2020: Euro

0.39) each traded at the Athens Stock Exchange.

The share premium of Euro 65,030,285 is considered a part of the share capital that rose from the issuance of shares

for cash in a value greater than the nominal.

ElvaHalcor’s capital was created as follows:

The share capital of Halcor amounted to Euro 38,486,258.26 divided to 101,279,627 common shares with voting

rights, of a nominal value of € 0.38 each. The share capital of Elval amounted to € 105,750,180.62 divided to

27,046,082 anonymous shares of nominal value € 3.91 each.

The Merger had, as a result, the increase of Halcor’s capital by:

• Amount of € 105,750,180.62, which corresponds to Elval share capital,

• Amount of € 2,107,779.66 which corresponds to the capitalization of share premium for rounding of the share

price of the merged company.

As a result, the present share capital of “ELVALHALCOR HELLENIC COPPER AND ALUMINIUM INDUSTRY S.A.”

increased from € 38,486,258.26 to €146,344,218.54 with the issuance of 273,961,959 new shares in favour of Elval’s

shareholders, and the total number of shares amounted to 375,241,586 shares with a nominal value of € 0.39.

b) Reserves

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Statutory Reserves

12,138

10,326

7,987

7,363

Hedging reserves

6,012

3,619

2,640

1,355

Special Reserves

44,899

43,376

Tax exempt reserves

176,463

176,759

176,463

Extraordinary Reserves

6,713

6,739

6,713

Other reserves

622

Merger reserves

46,144

69,588

49,303

83,153

Foreign exchange difference

(1,572)

(1,440)

291,419

310,791

287,425

319,045

Annual Financial Report of 31 December 2021

Page | 121

Statutory Reserve

According to article 158 of L.4548/2018, the companies are obligated, from the profit of the year, to create a

statutory reserve for an amount at least equal to 1/20 of the net earnings. The creation of statutory reserve seizes

to be compulsory when this reaches 1/3 of the capital. The statutory reserve is used exclusively for the offsetting of

losses. Pursuant to the decisions of the General Assemblies, the Group and the Company created reserves amounted

to EUR 1.8m and EUR 0.6m, respectively. For the fiscal year 2021 the Board of Directors will propose to General

Assembly a dividend of Euro 0.03 per share.

Untaxed and special reserves

Untaxed and special reserves concern non-distributed profits that are exempt from taxation pursuant to special

provisions of incentive laws (under the condition that companies have sufficient profits to form these reserves).

Reserves from income exempt from taxation and reserves taxed pursuant to special laws concern income from

interest for which a tax has been withheld at the source. In addition to any prepaid taxes, these reserves are subject

to taxation in case they are distributed. No deferred taxes have been accounted for as regards the above untaxed

reserves in case they are distributed.

Exchange rate differences on consolidation

Exchange rate differences on consolidation arise from translating the financial statements of subsidiaries which

are denominated in foreign currency, to the currency of the Parent Company which is in Euro.

Hedging reserves

Hedging reserves contain the effective portion of the changes in the fair value of the derivatives that had been

considered under the hedge accounting. These reserves are transferred to the statement of profit and loss, when

the hedging item will affect the statement of profit and loss.

Reserve of merger/absorption

The reserve of the absorption includes the difference between the acquisition price and the nominal value of the

shares issued.

21. Earnings per share

GROUP

COMPANY

2021

2020

2021

2020

Profits that correspond to the shareholders of the parent

company (in thousands of EURO)

111,689

28,309

88,245

16,954

Weighted average number of shares

375,241,586

Basic profits per share (EUR per share)

0,2976

0,0754

0,2352

0,0452

Basic earnings per share are calculated by dividing the net profits (losses) attributable to the parent company’s

shareholders by the weighted average number of common shares, save the average number of common shares

acquired by the Group and held as own shares.

Annual Financial Report of 31 December 2021

Page | 122

22. Loans and obligations from financial leasing

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Non-current

Borrowings

111,534

164,907

62,489

104,853

Bond Loans

550,577

287,798

536,702

277,485

Lease liabilities

10,392

10,480

6,543

9,222

Total

672,504

463,186

605,734

391,561

Current

Borrowings

92,264

118,078

10,328

67,497

Current portion of Long-term borrowings

55,501

28,855

45,012

19,383

Bond Loans

53,144

42,738

49,461

40,116

Lease liabilities (ex. Finance)

4,785

3,992

3,412

3,278

Total

205,694

193,663

108,212

130,273

Total loans and borrowings

878,198

656,849

713,946

521,834

Between 1 and 2 years

103,512

240,809

84,610

226,739

Between 2 and 5 years

257,398

176,576

211,261

119,172

Over 5 years

311,594

45,800

309,862

45,649

Total

672,504

463,186

605,734

391,561

In H1’21 ElvalHalcor issued a common bond loan amounting to Euro forty million (EUR 40,000,000) with “PIRAEUS

BANK S.A.” with the aim to finance current and general business needs. The loan has a five-year tenure and is

issued according to L.4548/2018.

On 17.11.2021 the trading of a bond loan of Euro 250 million commenced in the Athens Stock Exchange (ISIN

code: GRC281121BD8 and ticker: ΕLHAB1) divided into 250,000 common dematerialized bearer Bonds worth

Euro 1,000 each. The interest rate was set to 2.45% annually with coupon payments semi-annually. The maturity

is seven (7) years and the capital payment is at the maturity date.

On 31.12.2021 the Company signed two loans. One bond amounted to Euro 140 million with “NATIONAL BANK

OF GREECE S.A.”, “ALPHA BANK S.A.”, “PIRAEUS BANK S.A.” and “EUROBANK S.A.”, which also acts a

representative of the bondholders. Out the said amount, amount of EUR 88 million will be used for refinancing

of existing bond loan and amount of EUR 52 million for general business purposes of the Company. The loan has

seven and a half (7.5) years maturity and is issued according to L. 4548/2018 and in conjunction with article 14

of L. 3156/2003, as in force. And one bond of EUR 130,000,000 with “ALPHA BANK S.A.”, “PIRAEUS BANK S.A.”,

“EUROBANK S.A.” and “NATIONAL BANK OF GREECE S.A.”, which also acts a representative of the bondholders.

Out of the said amount, amount of EUR 102 million will be used for refinancing of existing bond loan and amount

of EUR 28 million for general business purposes of the Company. The loan has seven and a half (7.5) years

maturity and is issued according to L. 4548/2018 and in conjunction with article 14 of L. 3156/2003, as in force.

On 31.12.2021 the Group and the Company reclassified amount of loan from ΕIB of Euro 25 million to current

loans and borrowing pursuant to paragraph 74 of IAS 1, after receiving waiver from the lender in regards to loans

towards related parties, but the letter from the credit institution was dated after the 31.12.2021, which was the

reporting date.

Annual Financial Report of 31 December 2021

Page | 123

No events of default exist at the year end.

The Group and the Company have pledged assets of a total amount of Euro 605 million and Euro 344 million,

respectively.

The fair value of the loans is approximating the book value due to the fact that the interest rates of the loan are

approximating their market value.

The actual weighted average interest rates (both short and long term) at the balance sheet date were:

GROUP

COMPANY

2021

2020

2021

2020

Bond loans

2,62%

3,19%

2,61%

3,27%

Bank loans in EUR

2,30%

2,66%

1,61%

2,38%

Bank loans in USD

3,75%

Bank loans in GBP

3,57%

3,50%

3,57%

3,50%

For the bank loans of the Group and the Company that have been assumed from banks, there are clauses of change

of control that provide the lenders with an early redemption clause. The Group secures the consent of the lenders

in case of non-compliance with the said clauses when it is necessary.

23. Liabilities for employee’s retirement benefits

The Group has fulfilled its obligations for pension plans set out by law. According to the Greek labour law,

employees are entitled to compensation in case of dismissal or retirement, the amount of which varies depending

on salary, years of service and the manner of termination (dismissal or retirement). Employees who resign are not

entitled to compensation. The compensation payable in case of retirement equals 40 % of the compensation,

which would be payable in case of unjustified dismissal. The Group believes this is a defined benefit, and it charges

the accrued benefits in each period with a corresponding increase in the pension liability. Any payments made to

retirees each year are charged against this liability. The displayed personal benefit obligation of the Company and

the Group as at 31 December 2021 and 2020 is as follows:

Annual Financial Report of 31 December 2021

Page | 124

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Balance at 1 January

11,176

17,929

7,902

12,776

Amounts recognized in profit or loss

Current service cost

936

616

574

543

Past service credit

383

224

Settlement/curtailment/termination loss

1,612

956

1,254

338

Interest cost/income (-)

133

Total P&L Charge

2,960

1,794

2,072

942

Amounts recognized in OCI

Remeasurement loss/gain (-):

-Actuarial loss/gain (-) arising from:

Demographic assumptions

(64)

Financial assumptions

342

377

340

161

Experience adjustments

143

(4)

Total amount recognized in OCI

343

424

335

237

Other

Division/ segment spin off

194

199

Mergers and absorptions

(2,088)

(1,589)

(1,672)

(625)

Benefits paid

(7,569)

(5,429)

(1,894)

(9,157)

(1,473)

(6,054)

Balance at 31 December

12,585

11,176

8,836

7,902

The assumptions on which the actuarial study was based for the calculation of provision are the following:

GROUP

COMPANY

2021

2020

2021

2020

Discount rate

0.24%

0.29%

0.24%

0.30%

Price Inflation

2.10%

1.25%

2.10%

1.25%

Rate of compensation increase

2.61%

1.73%

2.61%

1.59%

The aforementioned results depend on assumptions (financial and demographic) of the actuarial study. Therefore,

if a discount rate less by 50 basis points had been used then the liability would be higher by 2.04% for the Company

and 2.41% for the Group approximately, although with a discount rate increased by 50 basis points, the liability

would have been dropped by 2,13% for the Company and by 2,92% for the Group. If an assumption of a future salary

increase by 50 basis points annually had been used, then the liability would be higher by 1.86% for the Company and

2.29% for the Group, and if a future salary decreased by 50 basis points, then the liability would have been less by

1.80% for the Company and by 2.50% for the Group. The weighted-average duration of the defined benefit obligation

is 4.12 years and 4.93 years for the Group and the Company, respectively.

Annual Financial Report of 31 December 2021

Page | 125

24. Grants

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Opening balance

15,607

17,365

8,590

9,811

Collection of grants

1,227

1,219

Transfer of grants to results

(8)

Transfer to receivables

(427)

Amortisation of grants

(1,593)

(1,757)

(1,202)

(1,221)

Mergers and absorptions

427

437

Closing balance

15,233

15,607

9,044

8,590

Depreciation of grants corresponding to fixed assets depreciation is posted in the account “Other income” of the

income statement.

Grants have been provided for the purchase of tangible assets.

25. Provisions

No movement has occurred for the Provisions during the fiscal year. Amount of EUR 1.4 mil. for the Group and EUR

1.2 mil. for the Company related to provisions for tax unaudited fiscal years.

26. Trade payables and other liabilities

Trade payables and other liabilities balance according to their current or non-current classification is

as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Suppliers

341,108

252,824

259,140

212,994

Social Security funds

6,137

4,661

3,715

2,867

Amounts due to related parties

20,215

19,608

20,548

30,070

Dividends payable

Sundry creditors

6,819

6,058

3,493

3,420

Accrued expenses

43,806

18,119

40,542

15,390

Other Taxes

5,861

8,625

3,689

6,858

Total

423,961

309,906

331,142

269,597

Annual Financial Report of 31 December 2021

Page | 126

27. Financial assets

The Board of Directors of the Group in conjunction with the parent Group has set rules and procedures for

measuring the following risks:

▪ Credit risk

▪ Liquidity risk

▪ Exchange rate risk

▪ Interest rate risk

Credit Risk

The Group and the Company exposure to credit risk is primarily affected by the features of each customer. The

demographic data of the Group’s clientele, including payment default risk characterizing the specific market and

the country in which customers are active, affect credit risk to a lesser extent since no geographical concentration

of credit risk is noticed. No client exceeds 10% of total sales (for the Group or Company), and, consequently, the

commercial risk is spread over a large number of clients. More specific, should be noted that INTERNATIONAL

TRADE S.A trades products of the Group to various foreign countries, with the delivery provided directly from the

production facilities of the Group to customers, the majority of them does not represent 10% of total sales.

ElvalHalcor’s transactions with INTERNATIONAL TRADE are approved by the Board of Directors and are published

to G.E.MI. (ΓΕΜΗ), pursuant to art. 99-101 of the Law L4548/2018.

Based on the credit policy adopted by the Board of Directors, each new customer is tested separately for

creditworthiness before normal payment terms are proposed. The creditworthiness test made by the Group

includes the examination of bank sources. Credit limits are set for each customer, which are reviewed in

accordance with current circumstances, and the terms of sales and collections are readjusted, if necessary. In

principle, the credit limits of customers are set on the basis of the insurance limits received for them from

insurance companies and, subsequently, receivables are insured according to such limits.

When monitoring the credit risk of customers, the latter are grouped according to their credit characteristics, the

maturity characteristics of their receivables and any past problems of recoverability they have shown. Trade and

other receivables include mainly wholesale customers of the Group. Any customers characterized as being of “high

risk” are included in a special list of customers, and future sales must receive in advance and approved by the

Board of Directors. Depending on the background of the customer and its status, the Group demands real or other

security (e.g. letters of guarantee) in order to secure its receivables, if possible.

The Group makes impairment allowances that reflect its assessment of losses from customers, other receivables

and investments in securities. This provision mainly consists of impairment losses of specific receivables that are

estimated based on given circumstances that they will be materialized though they have not been finalized yet.

Liquidity risk

Liquidity risk is the inability of the Group to discharge its financial obligations when they mature. The approach

adopted by the Group to manage liquidity is to ensure, by holding necessary cash and adequate credit limits from

cooperating banks, that it will always have adequate liquidity to cover its obligations when they mature, under

normal or more difficult conditions, without there being unacceptable losses or its reputation being jeopardized.

Note that on 31 December 2021, the Group had an amount of Euro 91.1 million and the Company amount of Euro

57.2 million as cash and the necessary credit lines that are approved but are not used so as to meet its short-term

and medium-term obligations easily. For serving the investments, the Group and the Company make sure for

securing the necessary funding when needed. Moreover, the Group is in talks with the banks for the on-time

refinancing of the maturing loans.

Annual Financial Report of 31 December 2021

Page | 127

To avoid liquidity risk, the Group makes a cash flow provision for one year when preparing the annual budget as

well as a monthly rolling provision for three months to ensure that it has adequate cash to cover its operating

needs, including fulfilment of its financial obligations. This policy does not take into account the impact of extreme

conditions which cannot be foreseen.

Exchange rate risk

The Group is exposed to foreign exchange risk in relation to the sales and purchases carried out and the loans

issued in a currency other than the functional currency of Group companies, which is mainly the Euro. The

currencies in which these transactions are held are mainly the Euro, the USD, the GBP and other currencies of S/E

Europe.

Over time, the Group hedges the greatest part of its estimated exposure to foreign currencies in relation to the

anticipated sales and purchases as well as receivables and liabilities in foreign currency. The Group enters mainly

into currency forward contracts with external counterparties so as to deal with the risk of the exchange rates

varying, which mainly expire within less than a year from the balance sheet date. When deemed necessary, these

contracts are renewed upon expiry. As the case may be, the foreign exchange risk may be hedged by taking out

loans in the respective currencies.

Loan interest is denominated in the same currency with that of cash flows, which arises from the Group’s operating

activities and is mostly Euro.

The investments of the Group in other subsidiaries are not hedged because these exchange positions are

considered to be long-term.

Interest rate risk

The Group finances its investments and its needs for working capital from bank and bond loans with the result

that interest charges reduce its results. Rising interest rates have a negative impact on results since borrowing

costs for the Group rise.

Prices fluctuation

The Group and the Company rely their purchases and sales to listed prices/ indexes regarding copper, aluminium

and other metals that use and incorporate in their products. Also, the Group and the Company, in respect of its

operations, are exposed to the fluctuations of the prices of natural gas as included in production cost. The risk of

the fluctuation of the metal prices and natural gas is hedged with future contracts.

Cash Flow Hedging

The Group and the Company base both their purchases and sales on stock prices for the price of copper,

aluminum and other metals used and contained in their products and are able to distinctly price customers, but

also to proceed with markets with suppliers, regarding the quantities of metal required for their operation.

Consequently, for each sale of a product or other stock that contains metals, at the time the LME price is agreed

with their customers, they take a long position on the LME for the corresponding quantity contained using

derivatives, and for each order raw material stock with suppliers, at the time the LME price is agreed with the

suppliers, take a short position on the LME for the corresponding quantity using derivatives, where and if these

daily purchases and sales cannot be offset by each other (back-to-back). Thus, the Group and the Company cover

purchases and sales with cash-flow hedging operations, ensuring that the fluctuation of the price of metals in

the international markets will not affect the operating cash flows and consequently the regular, sustainable and

optimal operation of the Group and the Company.

Annual Financial Report of 31 December 2021

Page | 128

In particular, to hedge cash flows related to the Natural Gas market, the Group and the Company conduct

Commodity Forward Start Swaps to hedge the risk of fluctuations in natural gas prices, including natural gas. ,

from market conditions. Also, the Company, from its operations, is exposed to fluctuations in gas prices as a

component of production costs. The risk of fluctuations in metal prices is covered by hedging operations (futures

- on the London Metal Exchange - LME), as well as natural gas. The risk of gas price fluctuations is covered by

cash flow hedging using Commodity Forward Start Swaps derivative contracts traded on the Title Transfer Facility

(TTF). More specific, the Company assumes a long position for predetermined quantities of natural gas that will

be consumed in its future production. Upon the commencement of the hedging transaction, the Group and the

Company shall document the hedging relationship between the hedged item and the hedging instrument in

relation to risk management and the strategy for future gas transactions. The Group and the Company document

the assessment of the effectiveness of the hedge in terms of offsetting changes in the fair value or cash flows of

the hedged items, both at the inception of the hedging relationship and on an ongoing basis.

Macroeconomic environment

Covid 19

The evolvement of the Covid-19 pandemic has had an adverse impact on global economic conditions. ElvalHalcor

and its subsidiaries responded swiftly to the pandemic, prioritising the health and safety of its employees,

suppliers and customers, and social distancing measures were successfully implemented without disrupting

production activity, according to the recommendations of health authorities and international health protocols.

For the additional measures and means of personal protection, according to the recommendation of health

committees, the Group and the Company undertook expenses of Euro 4.2 million (2020: Euro 4.0 million) and

Euro 2.8 million (Euro 2.9 million) respectively, which affected negatively the profitability.

In addition, the slowdown of the world economic outlook is expected to affect negatively a number of companies

operating in different segments. The Group and the Company increased the posting of the “impairment loss on

receivables and contract assets” for the expected credit losses (IFRS 9) following the increase of the risk factors,

hence impacting the financial results negatively, in order to include the new short-term conditions of the global

market. It is noteworthy that the sales of ElvalHalcor are made to companies with long term commercial ties and

presence in the local market, and they do not face any risks deriving from the macroeconomic environment. In

spite of that, the Management constantly evaluates the situation and its possible ramifications in order to secure

that all necessary measures and actions have been taken for the mitigation of any impact to the Group’s and the

Company’s activities.

In spite of the lockdowns in the global economy, the materialization of the investment programmes was

completed with minor delays, and the unhindered operation of the production facilities throughout the

pandemic provided an advantage over many European producers. The availability and the prices of the basic raw

materials follow the international market and are not affected by the domestic situation in any country. The

extensive measures of the lockdowns in many economies reduced temporarily the availability of scrap of copper,

while the traffic of raw materials was disrupted for a short period in certain major shipping ports. ElvalHalcor has

access to multiple sources for raw materials, and acted proactively by increasing the safety stock in critical

materials handling any supply chain disruptions, if any observed.

US anti-dumping investigation

ElvalHalcor participated in the investigation of the US Department of Commerce as a Greek producer of

aluminium sheets and cooperated with the authorities, with continuous transmission of information for the

development of investigations. On 02.03.2021, the US Department of Commerce calculated a final dumping

margin of 0%, for imports from ElvalHalcor.

Following issuance of the final determination by the DoC, the investigation concerning ElvalHalcor’s imports is

terminated without imposition of an antidumping duty and the US International Trade Commission (ITC) will not

make an injury determination with respect to imports from Greece.

Considering the above and the fact that for most of the other participants in the investigations, a dumping margin

has been calculated, and in some cases, a high margin, the Company and the Group reasonably believe that the

decision accommodates the continuation and expansion of the activity in the US market.

Annual Financial Report of 31 December 2021

Page | 129

Disclosures for conflicts in the region of Ukraine

Regarding the developments in Ukraine region, the Group’s sales for 2021 corresponding to 0.9% of its total

turnover to the Russian market and 0.6% to the Ukrainian market, while at company level sales reached to 1%

to the Russian market and 0.6% in the Ukrainian market. Both markets are not significant, and quantities are

easily absorbed by other markets where there is demand for Group’s and Company’s products. It is worth to be

noted that the Group and the Company procure raw materials from the Russian market, mainly primary

aluminum, but this supplier represents 5% -7% of the value of the total purchases and can be replaced by others

without significant impact in the smooth and uninterrupted operation of the Company and the Group. Finally, it

is noted that the consolidated ETEM SYSTEMS LLC, based in Ukraine is a trading company with total assets of 274

thousand euros, turnover of 1,054 thousand euros and net profit after taxes of 30 thousand euros for the closing

year 2021. Therefore and taking into account the size of the consolidated entity, it is reasonably estimated that

they may not affect the size of the Group or the Company.

Capital management

The Groups’ policy is to maintain a strong capital base to ensure investors’, creditors’ and the market’s trust in

the Group and to allow Group activities to expand in the future. The Board of Directors monitors the return on

capital which is defined by the Group as net results divided by total equity save non-convertible preferential

shares and minority interests. The Board of Directors also monitors the level of dividends distributed to holders

of common shares.

The Board of Directors tries to maintain equilibrium between higher returns that would be feasible through

higher borrowing levels and the advantages and security offered by a strong and robust capital structure.

The Group does not have a specific plan for own shares purchase.

There were no changes in the approach adopted by the Group in how capital was managed during the financial

year.

a) Credit risk

The Financial assets subject to credit risk are as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Trade & Other receivables

303,290

257,354

254,647

234,958

Total

303,290

257,354

254,647

234,958

Less:

Downpayments

(3,521)

(1,597)

(551)

(710)

Tax assets

(29,289)

(27,597)

(21,977)

(20,915)

Other receivables

(3,397)

(4,201)

(2,123)

(2,336)

Total

(36,207)

(33,755)

(24,651)

(23,962)

Financial assets entailing credit risk

267,084

223,599

229,996

210,996

Annual Financial Report of 31 December 2021

Page | 130

The balances included in Receivables according to maturity can be classified as follows:

GROUP

2021

Trade and other

receivables

(Gross)

Impairment loss

Trade and other

receivables

(Net)

ECL

€ '000

Neither past due nor impaired

251.441

(1.433)

250.008

0,6%

Overdue

- Up to 6 months

17.250

(631)

16.619

3,7%

- Over 6 months

7.124

(6.667)

457

93,6%

Total

275.815

(8.731)

267.084

GROUP

2020

Trade and other

receivables

(Gross)

Impairment loss

Trade and other

receivables

(Net)

ECL

€ '000

Neither past due nor impaired

208,882

(1,218)

207,664

0,6%

Overdue

- Up to 6 months

15,002

(367)

14,635

2,4%

- Over 6 months

8,358

(7,057)

1,301

84,4%

Total

232,242

(8,642)

223,599

COMPANY

2021

Trade and other

receivables

(Gross)

Impairment loss

Trade and other

receivables

(Net)

ECL

€ '000

Neither past due nor impaired

225,469

(1,043)

224,426

0,5%

Overdue

- Up to 6 months

6,098

(9,541)

5,557

2,0%

- Over 6 months

4,815

(4,802)

98,0%

Total

236,382

(6,386)

229,996

Annual Financial Report of 31 December 2021

Page | 131

COMPANY

2020

Trade and other

receivables

(Gross)

Impairment loss

Trade and other

receivables

(Net)

ECL

€ '000

Neither past due nor impaired

208,644

(832)

207,812

0,4%

Overdue

- Up to 6 months

2,625

(239)

2,386

9,1%

- Over 6 months

5,253

(4,455)

798

84,8%

Total

216,522

(5,526)

210,996

The movement in the account of provision for impairment was as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Balance as at 1 January

8,642

8,243

5,526

5,414

Impairment loss recognized

598

513

131

112

Amounts written off

(1,692)

(86)

(1,096)

Impairment loss reversed

(109)

(28)

Mergers and absorptions

1,294

1,824

Effect of movement in exchange rates

(2)

Balance as at 31 December

8,731

8,642

6,386

5,526

The maximum exposure to credit risk for trade and other receivables by geographic region was as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Greece

19,148

76,689

73,016

84,718

Other EU Member States

165,604

105,407

109,092

105,717

Other European countries

39,572

15,527

26,967

8,691

Asia

14,406

10,561

2,551

2,759

America (North & South)

23,376

10,698

15,536

5,595

Africa

4,510

4,584

2,441

3,412

Oceania

466

133

394

103

Total

267,084

223,599

229,996

210,996

The Group insures the greater part of its receivables in order to be secured in case of failure to collect.

Annual Financial Report of 31 December 2021

Page | 132

b) Liquidity risk

GROUP

€ '000

2021

Liabilities

Carrying

Amount

Up to 1yr

1 to 2 yrs

2 to 5 yrs

Over 5 yrs

Total

Bank loans

259,300

125,452

37,623

82,050

21,597

266,721

Lease liabilities

15,177

5,132

6,939

3,109

983

16,162

Bond issues

603,722

64,921

89,492

217,815

331,522

703,749

Derivatives

6,313

3,108

3,205

6,313

Contract Iiabilities

9,267

Trade and other payables

423,961

409,693

3,174

7,920

423,961

1,317,739

617,572

140,432

306,147

362,021

1,426,173

GROUP

€ '000

2020

Liabilities

Carrying

Amount

Up to 1yr

1 to 2 yrs

2 to 5 yrs

Over 5 yrs

Total

Bank loans

311,840

147,378

34,212

108,232

29,314

319,137

Lease liabilities

14,472

4,050

3,981

5,542

1,069

14,642

Bond issues

330,537

50,959

212,500

71,401

16,226

351,086

Derivatives

2,182

1,912

270

2,182

Contract Iiabilities

8,826

Trade and other payables

309,906

977,762

523,031

250,963

185,175

46,610

1,005,779

COMPANY

€ '000

2021

Liabilities

Carrying

Amount

Up to 1yr

1 to 2 yrs

2 to 5 yrs

Over 5 yrs

Total

Bank loans

117,828

32,324

24,611

46,017

21,597

124,548

Lease liabilities

9,954

3,496

3,990

1,986

841

10,313

Bond issues

586,163

49,692

73,926

193,093

329,881

646,592

Derivatives

5,644

2,439

3,205

5,644

Contract Iiabilities

4,562

Trade and other payables

331,142

316,874

3,174

7,920

331,142

1,055,294

409,387

108,906

244,270

360,238

1,122,801

COMPANY

€ '000

2020

Liabilities

Carrying

Amount

Up to 1yr

1 to 2 yrs

2 to 5 yrs

Over 5 yrs

Total

Bank loans

191,733

89,232

23,203

59,187

29,314

200,937

Lease liabilities

12,500

3,312

3,492

4,878

897

12,579

Bond issues

317,601

48,019

208,897

63,999

16,226

337,140

Derivatives

1,367

1,097

270

1,367

Contract Iiabilities

6,427

Trade and other payables

269,597

799,224

417,683

235,862

128,064

46,438

828,046

c) Exchange rate risk

Annual Financial Report of 31 December 2021

Page | 133

GROUP

2021

€ '000

EUR

USD

GBP

BGN

RON

Other

Trade and other receivables

242,584

39,809

11,864

6,190

1,568

1,276

Cash & cash equivalents

73,952

14,840

481

1,478

336

Total assets

316,536

54,649

12,344

7,668

1,624

1,612

Loans and Borrowings

877,432

605

160

Trade and other payables

356,191

57,737

300

9,208

327

198

Contract Iiabilities

7,896

466

758

110

Total liabilities

1,241,519

58,202

905

10,127

437

236

Net (Assets-Liabilities)

(924,984)

(3,553)

11,439

(2,458)

1,188

1,375

Derivatives for risk hedging (Nominal Value)

(22,242)

(4,977)

Total risk

(924,984)

(3,553)

(10,803)

(7,436)

1,188

1,375

GROUP

2020

€ '000

EUR

USD

GBP

BGN

RON

Other

Trade and other receivables

214,604

27,355

12,431

2,959

Cash & cash equivalents

26,143

6,778

259

382

276

Total assets

240,746

34,133

12,690

3,341

276

Loans and Borrowings

652,931

1,296

2,622

Trade and other payables

263,128

33,079

286

13,202

200

Contract Iiabilities

7,686

1,125

Total liabilities

923,744

34,203

1,582

15,825

215

Net (Assets-Liabilities)

(682,998)

(71)

11,108

(12,483)

264

(209)

Derivatives for risk hedging (Nominal Value)

(5,707)

(6,018)

Total risk

(682,998)

(5,777)

5,090

(12,483)

264

(209)

Annual Financial Report of 31 December 2021

Page | 134

ΕΤΑΙΡΕΙΑ

2021

€ '000

EUR

USD

GBP

BGN

RON

Other

Trade and other receivables

226,121

21,270

7,157

101

Cash & cash equivalents

48,270

8,899

Total assets

230,567

10,854

6,164

101

Loans and Borrowings

520,538

1,296

Trade and other payables

241,028

28,291

206

Contract Iiabilities

6,162

264

Total liabilities

767,728

28,556

1,502

Net (Assets-Liabilities)

(537,162)

(17,702)

4,661

(8)

Derivatives for risk hedging (Nominal Value)

Total risk

(537,162)

(17,702)

4,661

(8)

ΕΤΑΙΡΕΙΑ

2020

€ '000

EUR

USD

GBP

BGN

RON

Other

Trade and other receivables

218,928

9,922

6,107

Cash & cash equivalents

11,639

931

Total assets

230,567

10,854

6,164

Loans and Borrowings

520,538

1,296

Trade and other payables

241,028

28,291

206

Contract Iiabilities

6,162

264

Total liabilities

767,728

28,556

1,502

Net (Assets-Liabilities)

(537,162)

(17,702)

4,661

(70)

Derivatives for risk hedging (Nominal Value)

Total risk

(537,162)

(17,702)

4,661

(70)

The rates that were applied for the foreign exchange translation were:

Annual Financial Report of 31 December 2021

Page | 135

AVERAGE

AT YEAR END

2021

2020

2021

2020

USD

1,1827

1,1422

1.1326

1,1271

GBP

0,8596

0,8897

0.8403

0,8990

RON

4,9215

4,8383

4.9490

4,8683

TRY

10,5124

8,0547

15.2335

9,1131

BGN is locked with the Euro which is the reporting and operating currency of the Group and the Company with rate

1.9558 and as a result there is no foreign exchange risk.

Sensitivity analysis

A change in the price of Euro against other currencies that the Group trades would have corresponding impact on

the income statement and in equity as follows:

2021

GROUP

Profit or loss

Equity, net of tax

€ '000

EUR Strengthening

EUR Weakening

EUR Strengthening

EUR Weakening

USD (10% movement)

648

(792)

2,345

(2,866)

GBP (10% movement)

(61)

(587)

718

RON (10% movement)

(108)

132

(108)

132

2020

GROUP

Profit or loss

Equity, net of tax

€ '000

EUR Strengthening

EUR Weakening

EUR Strengthening

EUR Weakening

USD (10% movement)

642

(525)

488

(399)

GBP (10% movement)

(566)

463

(430)

352

RON (10% movement)

(29)

(22)

COMPANY

2021

€ '000

Profit or loss

Equity, net of tax

EUR Strengthening

EUR Weakening

EUR Strengthening

EUR Weakening

USD (10% movement)

1,777

(2,171)

1,777

(2,171)

GBP (10% movement)

(580)

709

(580)

709

COMPANY

2020

€ '000

Profit or loss

Equity, net of tax

EUR Strengthening

EUR Weakening

EUR Strengthening

EUR Weakening

USD (10% movement)

1,609

(1,967)

1,223

(1,495)

GBP (10% movement)

(424)

518

(322)

394

d) Interest rate risk

Annual Financial Report of 31 December 2021

Page | 136

The following financial liabilities related to loans and borrowings and finance leases:

GROUP

COMPANY

2021

2020

2021

2020

Fixed-rate instruments

€ '000

Financial assets

5,746

3,975

5,746

3,975

Financial liabilities

(262,186)

(18,582)

(253,014)

(16,610)

Variable-rate instruments

Financial assets

3,000

Financial liabilities

(616,013)

(638,266)

(460,932)

(640,239)

Sensitivity analysis

The effects of an increase in the interest rates of 25 basis points both in the Income statement and the Equity can

be depicted as follows:

GROUP

COMPANY

2021

2020

2021

2020

0.25% increase

(1,540)

(1,654)

(1,152)

(1,323)

0.25% decrease

1,540

1,654

1,152

1,323

e) Change of Metal prices

The production of aluminium, copper and alloys require significant quantities of raw materials, as a result, the Group and the

Company purchase raw materials of copper, aluminium and zinc for further fabrication. In order to secure the unhindered

operation of the Group and the Company, considering the usual production cycle as well as the availability of raw materials

from parameters that cannot be controlled either by the Group or the Company (indicatively and not exhaustively, the global

balance of supply and demand, implementation of new laws or regulations related to the production and movement of raw

materials etc.), the Group and the Company maintain a safety stock, the amount of which is set by the Management

considering the production process and the overall market conditions, a practice which is followed by almost all the

competitors and market participants and is embedded in the core characteristics of the operation of the production facilities.

For the usual procurement of raw materials and sales the Group and the Company employ cash flow hedge accounting to

fortify their cash flows from the changes in the prices of metals. According to the set hedging policy, the Group and the

Company close positions in the LME (London Metal Exchange) for each purchase or sale of physical inventory conducted with

suppliers and customers respectively. At the closing of the market position the result is charged to the statement of profit or

loss as well as the completion of the sale or purchase of the physical inventories of the products or raw materials, while the

open positions are being measured in the statement of other comprehensive income as each reporting period.

In addition, it is noted that the Group and the Company determine the cost of inventory by applying the annual average

weighted cost method and measure the inventory at each reporting period at the lower between acquisition cost or net

realisable value, including the safety stock. The changes from the valuation of safety stock cause fluctuations in the variable

cost, which however are not source of cash flow risk, considering the steady retention of the said stock. As a result of the

above, a sensitivity analysis of the change of metal prices on the safety stock is not presented.

Annual Financial Report of 31 December 2021

Page | 137

28. Fair value of financial assets

The different levels have been defined as follows:

− Level 1: consists of exchange traded derivatives and shares which are based on market prices.

− Level 2: consists of OTC derivatives that are based on prices from brokers.

− Level 3: Includes unlisted shares. They come from estimates of the Company as there are no observable

market data.

The financial information concerning Level 3 refers to holdings in domestic and foreign companies with a stake of

less than 20%. These holdings which are not quoted and the fair value cannot be reliably measured, they are valued

at cost and are subject to impairment testing (see Note 14).

GROUP

2021

€ '000

Level 1

Level 2

Level 3

Total

Other Investments

9.978

9,978

Derivative financial assets

6.065

8.060

14,125

Derivative financial liabilities

(2.053)

(4.259)

(6,313)

2020

Other Investments

4,301

Derivative financial assets

4,236

1,305

5,541

Derivative financial liabilities

(1,907)

(275)

(2,182)

GROUP

2021

€ '000

Level 1

Level 2

Level 3

Total

Other Investments

12,935

Derivative financial assets

3,050

7,986

11,037

Derivative financial liabilities

(2,053)

(3,591)

(5,644)

2020

Other Investments

2,185

Derivative financial assets

2,191

1,219

3,410

Derivative financial liabilities

(1,306)

(61)

(1,367)

The derivatives of level 1 comprise of futures traded in ‘London Metal Exchange – LME’ for which there is an

observable market price for all prompt dates on which the contract is settled. The mark-to-market valuations of the

futures are based on evening evaluations of LME, as well as the counterparties valuations in contracts, which are

LME brokers. The derivatives of level 2 comprise of forward FX contracts. The valuation stems from the counterparty

banks based on a valuation model.

Annual Financial Report of 31 December 2021

VI. NOTES TO THE FINANCIAL STATEMENTS AS AT 31 DECEMBER 2021

138

(b) Fair Value in Level 3

The movement of investments classified as Level 3 was as follows:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Balance as at 1 January

4,300

3,611

2,185

1,682

Additions

539

532

Disposals

(77)

Fair value adjustment through OCI

179

1,995

Reclassifications

(29)

Balance as at 31 December

4,231

4,300

4,189

2,185

During the fiscal year, there were no reclassifications of financial assets between levels.

The financial assets classified in Level 3 are valuated with the discounted cash flow method. The valuation model

calculates the present value of the net cash flows that the Cash Generating Unit is creating (CGU) based on

assumptions for future profitability, taking into account the expected growth rate of its operatios as well as the

discount rate.

The expected cash flows have been discounted using rates as follows:

• Risk-free rate: (-)%

• Market risk premium: 5.71%

• Expected income tax rate: 22%

• Unlevered beta: 0.89

• WACC 6,9%

• Growth rate (g): 1,6%.

29. Commitments

The contractual obligations are:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Tangible assets

10,128

3,732

9,477

3,134

Annual Financial Report of 31 December 2021

Page | 139

30. Contingent liabilities / assets

The tax liabilities of the Company and its subsidiaries for certain financial years have not been audited by taxation

authorities and thus are not finalized yet for such years.

The table below presents unaudited tax years of the companies consolidated by ELVALHALCOR SA by applying either

full consolidation or equity method.

On 01.07.2021 the decision with Registration Code Number 2574251 and protocol Nr.73823/01.07.2021 (ΑΔΑ:

6ΞΟ046ΜΤΛΡ-ΞΤΥ) of the Ministry of Development and Investments, General Secretariat of Commerce and

Consumer Protection, was registered in the General Commercial Registry (“G.E.MI.”), by operation of the

aforesaid decision the merger by absorption of “FITCO” by “ELVALHALCOR” was approved, pursuant to the

aforementioned Laws, the draft merger terms of the merging companies dated 19.05.2021, the decisions of the

Board of Directors dated 14.05.2021 of the merging companies, nd the no. 7163/29.06.2021 notarial deed of the

Notary Public Marina G. Karageorgi. The merger by absorption of “FITCO” by “ELVALHALCOR performed

according to the provisions of L. 4601/2019, of L. 4548/2018 and 4172/2013.

Company Country Business

Direct

Participation

Indirect

Participation

Consolidation Method

Unaudited

Fiscal Years

ELVALHALCOR S.A. GREECE Industrial - - - 2016 - 2021

SOFIA MED S.A. (1) BULGARIA Industrial 89,56% 0,00% Consolidation in Full 2015-2021

EPIRUS METALWORKS (1) GREECE Industrial 100,00% 0,00% Consolidation in Full 2019-2021

TECHOR Α.Ε. (1) GREECE Industrial 100,00% 0,00% Consolidation in Full 2016-2021

ELKEME S.A (2) GREECE Metallourgical Research 92,50% 0,00% Equity Method 2010-2021

VIEXAL S.A (2) GREECE Services 26,67% 0,00% Equity Method 2016-2020

VIENER S.A (2) GREECE Energy 41,32% 0,00% Equity Method 2012-2021

ΙΝΤΕRΝΑΤΙΟΝΑL TRADE S.A. (2) ROMANIA Commercial 29,97% 0,00% Equity Method -

TECHOR PIPE SYSTEMS (3) TURKEY Industrial 0,00% 100,00% Consolidation in Full -

HC ISITMA A.S. GREECE Services 50,00% 0,00% Equity Method -

STEELMET S.A (2) GREECE Industrial 29,50% 0,00% Equity Method 2016-2020

SYMETAL S.A (1) GREECE Industrial 100,00% 0,00% Consolidation in Full 2016 - 2021

VEPAL S.A (1) GREECE Industrial 100,00% 0,00% Consolidation in Full 2017-2021

ANOXAL S.A (1) GREECE Industrial 100,00% 0,00% Consolidation in Full 2017-2021

VIOMAL (1) GREECE Industrial 100,00% 0,00% Consolidation in Full 2016-2021

ΒΙΟΜΑΛ Α.Ε (1) GREECE Industrial 75,00% 0,00% Consolidation in Full 2015-2020

ROULOC A.E. (4) SPAIN Commercial 0,00% 100,00% Consolidation in Full 2016-2021

ELVAL COLOUR IBERICA S.A. (4) GERMANY Commercial 0,00% 100,00% Consolidation in Full -

UACJ ELVAL HEAT EXCHANGER MATERIALS GmbH NETHERLANDS Industrial 50,00% 0,00% Equity Method -

NEDZINK B.V. GREECE Industrial 50,00% 0,00% Equity Method -

CABLEL WIRES Α.Ε (1) GREECE Industrial 100,00% 0,00% Consolidation in Full 2019-2021

ΕΤΕΜ COMMERCIAL S.A (1) GREECE Industrial 80,00% 0,00% Consolidation in Full 2017-2021

ETEM BG S.A. (5) BULGARIA Commercial 0,00% 73,60% Consolidation in Full 2019-2021

ETEM ALBANIA S.A. (6) ALBANIA Commercial 0,00% 73,60% Consolidation in Full 2011-2021

ETEM SCG DOO (6) SERBIA Commercial 0,00% 73,60% Consolidation in Full 2012-2021

ETEM SYSTEMS LLC (6) UKRAINE Commercial 0,00% 73,60% Consolidation in Full 2005-2021

ETEM SYSTEMS SRL (6) ROMANIA Commercial 0,00% 73,60% Consolidation in Full 2016-2021

ELVIOK S.A (1) GREECE Services 100,00% 0,00% Consolidation in Full 2019-2020

(1) Susbidiary of ELVALHALCOR

(2) Subsidiary of Viohalco SA

(3) Subsidiary of Techor S.A.

(4) Subsidiary of Elval Colour S.A.

Annual Financial Report of 31 December 2021

VI. NOTES TO THE FINANCIAL STATEMENTS AS AT 31 DECEMBER 2021

140

31. Related parties

Affiliated parties shall mean all companies and natural persons with whom direct (subsidiaries, associated

companies, joint ventures, collaborating companies, shareholders or management with executive tasks) or indirect

relation (entities controlled by shareholders, employees performing administrative tasks or close relatives of the

latter) is established.

GROUP

COMPANY

€' 000

31.12.2021

31.12.2020

31.12.2021

31.12.2020

Sale of goods

Subsidiaries

261.634

197.211

Equity accounted investees

452,087

798,705

700.891

566.291

Joint Ventures

Parent

Other

730,437

90,615

159.682

88.788

1,182,602

889,388

1.122.207

852.357

Sale of services

Subsidiaries

5,727

6,832

Equity accounted investees

759

1,584

810

1,092

Joint Ventures

121

Other

2,516

1642

897

1,442

3,396

3,227

7,433

9,366

Sale of fixed assets

Subsidiaries

943

Equity accounted investees

9,837

Joint Ventures

172

Other

169

217

163

341

10,054

1,211

10,034

Purchase of goods

Subsidiaries

43,809

21,871

Equity accounted investees

16,374

36,298

522

10,082

Joint ventures

Other

81,037

16,518

41,011

15,555

97,447

52,896

85,377

47,588

Purchase of services

Subsidiaries

44,639

37,075

Equity accounted investees

45,830

32,228

26,251

23,470

Parent

169

150

Other

8,217

5,544

6,593

3,789

54,216

37,772

77,633

64,334

Purchase of fixed assets

Subsidiaries

356

5,823

Equity accounted investees

4,659

3,142

3,378

2,036

Other

23,060

14,130

19,912

12,467

27,719

17,272

23,646

20,325

The services, sales and purchases of good from continuing activities with related parties are carried out with the established price

list as with third parties. More specifically:

Annual Financial Report of 31 December 2021

Page | 141

End-of-year balances from sale / purchase of goods, services, fixed assets, etc.

GROUP

COMPANY

€' 000

31.12.2021

31.12.2020

31.12.2021

31.12.2020

Receivables from related parties:

Subsidiaries

76,568

60,231

Equity accounted investees

32,771

68,903

53,786

49,547

Joint Ventures

5,857

5,778

Parent

87,541

250

36,248

249

Other

70,887

70,557

126,171

140,041

172,380

180,583

EUR

Liabilities to related parties:

Subsidiaries

10,151

15,323

Equity accounted investees

9,066

11,757

4,864

8,123

Joint Ventures

269

249

Parent

10,622

5,887

Other

259

7,826

6,598

20,215

19,608

21,207

30,070

Services towards and from affiliated parties, as well as sales and purchases of goods, are realized in accordance

with the fee schedules, which apply for non-affiliates. The Group and the Company have not recorded any

impairment loss in respect of intercompany balances as there are only minor delays in payment for which interest

is invoiced. For 2021 the amount of interest has been invoiced to related parties by the parent company

ELVALHALCOR amounted to Euro 204 thousand compared to 143 thousand in 2020, while at Group level there

were no corresponding charges for 2021 compared to Euro 55 thousand in 2020. Concerning loan commitments

to related parties, these are presented in specific line in Statement of Financial Position (refer to note 34 for more

information)

Sofia Med SA buys from ELVALHALCOR raw materials and semi-finished products of copper and copper alloys,

depending on its needs, as well as finished products which distributes to the Bulgarian market. In addition,

ELVALHALCOR provides technical, administrative and commercial support services to Sofia Med. Respectively,

ELVALHALCOR buys from Sofia Med raw materials, semi-finished products according to its needs, as well as

finished products which distributes to the Greek market.

ELVALHALCOR purchases aluminium scrap from the production process of Symetal, which is re-used as raw

material (re-casting). ELVALHALCOR, occasionally, sells spare parts and other materials to Symetal and provides

other supportive services. Finally, ElvalHalcor sells final spare parts and other materials to SYMETAL and provide

various services.

ELVALHALCOR S.A. sells final aluminium products to Viomal, which constitute raw material for the latter and

Viomal sells back to ELVALHALCOR the returns from its production process.

Elval Colour S.A. buys final products from ELVALHALCOR, which are used as raw material by the latter and

ELVALHALCOR processes Elval Colour’s materials.

Vepal S.A. processes ELVALHALCOR’s products and delivers semi-finished products. ELVALHALCOR sells raw

materials to Vepal and also provides supporting administrative services to the latter.

Anoxal S.A., also, processes ELVALHALCOR’s raw materials and ELVALHALCOR provides administrative support to

Anoxal. Furthermore, Anoxal purchases from ELVALHALCOR other materials (spare parts and other consumables)

for its production process.

Annual Financial Report of 31 December 2021

Page | 142

Epirus Metalworks purchases raw materials from ELVALHALCOR, proceed with the process and then sales

finished products to ELVALHALCOR. ELVALHALCOR provides administrative services to Epirus Metalworks.

Cenergy Group purchases raw materials from ELVALHALCOR according to their needs. In its turn, it sells copper

scrap to ELVALHALCOR from the products returned during its production process.

Steelmet Group provides ELVALHALCOR with administration and organization services.

International Trade exports ELVALHALCOR’s Group products to various foreign countries with the delivery

provided directly from the production facilities of the Group to many customers, the majority of them does not

represent 10% of total sales according to the credit policy of the Group. ElvalHalcor’s transactions with

INTERNATIONAL TRADE are approved by the Board of Directors and are published to G.E.MI. (ΓΕΜΗ), pursuant

to art. 99-101 of the Law L4548/2018.

Metal Agencies LTD acts as a merchant - central distributor of ELVALHALCOR Group in Great Britain.

TEPROMKC Gmbh trades ELVALHALCOR’s products in the German market.

Steelmet Romania trades ELVALHALCOR’s products in the Romanian market.

Teka Systems S.A. undertakes to carry out certain industrial constructions for ELVALHALCOR and provides

consulting services in IT issues and SAP support and upgrade.

Anamet S.A. provides ELVALHALCOR with considerable quantities of copper and brass scrap.

Viexal SA provides ELVALHALCOR with travelling services.

Viohalco S.A. rents buildings and industrial premises to ELVALHALCOR.

Tepro Metall AG trades (through its subsidiary MKC) ELVALHALCOR products and represents the latter in the

German market.

Genecos, as well as its subsidiary Reynolds Cuivre sell ELVALHALCOR’s products and represent ELVALHALCOR in

the French market.

ETEM Gestamp Aluminium Extrusions purchases from ELVALHALCOR aluminium billets and sells in its turn

aluminium scrap from its production process to ELVALHALCOR.

GESTAMP Etem Automotive Bulgaria sells aluminium scrap from its production process to ELVALHALCOR.

ETEM COMMERCIAL SA rents industrial facilities from ELVALHALCOR, purchases aluminium billets and sells in its

turn aluminium scrap from its production process to ELVALHALCOR.

UACJ ELVAL HEAT EXCHANGER MATERIALS purchases from ELVALHALCOR finished aluminium products and

distributes them to international markets.

Benefits to Key Management Personnel

GROUP

COMPANY

31.12.2021

31.12.2020

31.12.2021

31.12.2020

Fees - benefits to the members of the Board of

Directors and executives

12,442

11,762

5,216

4,975

12,442

11,762

5,216

4,975

32. Auditor’s fees

Regarding year 2021, the fees of our auditor’s PriceWaterhouseCoopers S.A. for the Group and for the Company in

respect of audit of the financial statements of the Company amounted to Euro 213 thousand (2020: Euro 202

thousand), for tax audit amounted to Euro 45 thousand (2020: Euro 42 thousand) and fees for other services reached

Euro 101 thousand (2020: Euro 4 thousand). In Group’s level they amounted to Euro 342 thousand (2020: Euro 312

thousand), for tax audit Euro 68 thousand (2020: Euro 69 thousand) and fees for other services Euro 101 thousand

(2020: Euro 4 thousand).

Annual Financial Report of 31 December 2021

Page | 143

33. ROU

The movement in the right of use of assets for the fiscal year and the respective previous presented below:

GROUP

€ '000

Land

Buildings /

Warehouses

Machinery

Transportation

equipment

Total

Cost

Balance as at 1 January 2020

274

158

17,470

5,119

23,021

Additions

1,367

1,714

3,081

Terminations

(416)

Write offs

(6)

Balance as at 31 December 2020

274

1,525

17,470

6,412

25,681

Accumulated depreciation

Balance as at 1 January 2020

(6)

(51)

(2,374)

(1,317)

(3,747)

Depreciation of the period

(23)

(100)

(828)

(1,507)

(2,548)

Terminations

253

Write offs

Balance as at 31 December 2020

(29)

(151)

(3,202)

(2,565)

(5,947)

Carrying amount as at 31 December 2020

246

1,374

14,268

3,846

19,734

GROUP

€ '000

Land

Buildings /

Warehouses

Machinery

Transportation

equipment

Total

Cost

Balance as at 1 January 2021

274

1,525

17,470

6,412

25,681

Additions

2,019

2,075

Terminations

(47)

(764)

(811)

Mergers and absorptions

3,824

614

4,438

Modifications

Balance as at 31 December 2021

274

5,383

17,470

8,281

31,408

Accumulated depreciation

Balance as at 1 January 2021

(29)

(151)

(3,202)

(2,565)

(5,947)

Depreciation of the period

(23)

(539)

(828)

(1,613)

(3,002)

Terminations

602

650

Mergers and absorptions

(736)

(351)

(1,086)

Balance as at 31 December 2021

(51)

(1,378)

(4,030)

(3,927)

(9,386)

Carrying amount as at 31 December 2021

223

3,742

13,440

4,354

22,021

Annual Financial Report of 31 December 2021

Page | 144

COMPANY

€ '000

Land

Buildings /

Warehouses

Machinery

Transportation

equipment

Total

Cost

Balance as at 1 January 2020

17,470

2,882

20,352

Additions

1,367

958

2,325

Terminations

(234)

Balance as at 31 December 2020

1,367

17,470

3,606

22,442

Accumulated depreciation

Balance as at 1 January 2020

(2,374)

(686)

(3,060)

Depreciation of the period

(42)

(828)

(789)

(1,659)

Terminations

115

Balance as at 31 December 2020

(42)

(3,202)

(1,360)

(4,604)

Carrying amount as at 31 December 2020

1,325

14,268

2,246

17,838

COMPANY

€ '000

Land

Buildings /

Warehouses

Machinery

Transportation

equipment

Total

Cost

Balance as at 1 January 2021

1.367

17.470

3.606

22.442

Additions

855

Terminations

(354)

Mergers and absorptions

150

Balance as at 31 December 2021

1.367

17.470

4.257

23.093

Accumulated depreciation

Balance as at 1 January 2021

(42)

(3.202)

(1.360)

(4.604)

Depreciation of the period

(52)

(828)

(806)

(1.686)

Terminations

115

Mergers and absorptions

(83)

Balance as at 31 December 2021

(94)

(4.030)

(1.981)

(6.105)

Carrying amount as at 31 December 2021

1.273

13.440

2.276

16.989

Annual Financial Report of 31 December 2021

Page | 145

Rental fees was recognized in the income statement for fiscal year and the respective prior year presented below:

GROUP

COMPANY

2021

2020

2021

2020

€ '000

Variable rental fees

Low value rental fees

Short term rental fees

3,474

2,278

1,006

1,613

Gain/loss due to difference between asset/liability on early termination

(7)

(61)

Other expenses related to leasing contracts

114

3,735

2,457

1,714

Interest expense related to financial leases amounted for the Group Euro 683 thousand (2020: Euro 707

thousand) and for the Company Euro 517 thousand (2020: Euro 632 thousand).

34. Non-current and current loan receivables

The Company after obtaining the necessary approvals pursuant to articles 99-101 of Law 4548/2018 for the fair

and reasonable of the transaction, provided a loan jointly with Koramic Holding N.V, by 50% corresponding to

their percentage in the participation in affiliated Nedzink B.V., with a nominal value of Euro 11.5 million partially

convertible into equity capital. The loan will be recovered in 2022 and as a result reclassified in current assets.

The loan was recorded at amortized cost. The annual interest rate is 3.6%.

Aon 21.12.2021 the Company signed a credit agreement with the 100% subsidiary Epirus Metalworks, under

which ELVALHALCOR provides credit to EPIRUS METALWORKS, exclusively in cash up to the amount of € 3.0

million. The credit agreement provided for a suration of five (5) years and Epirus Metalworks obtain the right to

partial or full repayment. Annual interest rate is based on 6-month EURIBOR plus margin of 3.6%. As a result the

loan has been classified to current assets.

GROUP

COMPANY

2021

2020

2021

2020

Balance as at 1 January 2021

3.975

3,975

Additions

1.750

3.973

4,750

3,973

Interest income

173

Interest received

(153)

(45)

(153)

(45)

Balance as at 31 January 2021

5.746

3.975

8,746

3,975

35. EBITDA and a-EBITDA

EBITDA: It is the measure of profitability of the entity before taxes, financial, depreciation and amortization. It is

calculated by adjusting the depreciation and amortization to the operating profit as this is reported in the

statement of profit and loss.

Annual Financial Report of 31 December 2021

Page | 146

€ '000

GROUP

COMPANY

2021

2020

2021

2020

Operating profit / (loss)

146,909

59,421

98,554

40,398

Adjustments for:

+ Depreciation of tangible assets

65,667

60,057

44,086

39,632

+ Depreciation of right of use assets

3,003

2,458

1,686

1,659

+ Amortization

1,226

1,024

649

701

+ Depreciation of investment property

100

207

1,215

1,216

- Amortization of Grants

(1,593)

(1,757)

(1,202)

(1,221)

EBITDA

215,312

121,409

144,988

82,179

€ '000

GROUP

COMPANY

2021

2020

2021

2020

EBITDA

215,312

121,409

144,988

82,719

Adjustments for:

+ Loss / - Profit from Metal Lag

(56,135)

9,016

(36,819)

2,672

+ Losses from Fixed assets write-offs or impairments

2,941

1,887

2,797

1,846

- Profit / + Loss from sale of Assets

558

(569)

(138)

(313)

+ Expenses for Covid-19 pandemic

4,159

4,037

2,774

2,941

a - EBITDA

166,385

135,782

113,602

89,325

GROUP

COMPANY

31.12.2021

31.12.2020

31.12.2021

31.12.2020

€ '000

(Α) Value of Metal in Sales

2,225,743

1,460,594

1,385,188

921,455

(B) Value of Metal in Cost of Sales

(2,176,246)

(1,463,182)

(1,361,423)

(916,602)

6,638

(6,428)

13,054

(7,525)

(A+B+C) Metal Result in Gross Profit

56,135

(9,016)

36,819

(2,672)

Regarding the expenses for the treatment of the Covid-19 pandemic, the Group and the Company adjusted

expenses of EUR 4.2 million (2020: EUR 4,0 million) and EUR 2.8 million (2020: EUR 2,9 million) respectively for the

calculation of a-EBITDA. These expenses are directly linked to the pandemic and due to the special circumstances

caused and are not expected to reoccur after it subsides.

a – EBITDA: adjusted EBITDA is a measure of the profitability of the entity after adjustments for:

• Metal result

• Restructuring Costs

• Special Idle costs

• Impairment of fixed assets

• Impairment of Investments

• Profit / (Loss) of sales of fixed assets and investments if included in the operational results

Annual Financial Report of 31 December 2021

Page | 147

• Other impairments

For the current and the respective previous period the figures were as follows:

ALUMINIUM

31.12.2021

31.12.2020

€ '000

Operating profit / (loss)

78,790

37,975

Adjustments for:

+ Depreciation

46,921

42,332

- Amortization of Grants

(1,411)

(1,561)

EBITDA

124,300

78,746

EBITDA

124,300

78,746

Adjustments for:

+ Loss / - Profit from Metal Lag

(20,942)

4,765

+ Losses from Fixed assets write-offs or impairments

2,900

- Profit / + Loss from sale of Assets

(114)

425

+ Expenses for Covid-19 pandemic

2,191

2,586

a - EBITDA

108,336

86,552

ALUMINIUM

31.12.2021

31.12.2020

€ '000

(Α) Value of Metal in Sales

809,726

532,453

(B) Value of Metal in Cost of Sales

(808,669)

(534,070)

19,885

(3,148)

(A+B+C) Metal Result in Gross Profit

20,942

(4,765)

COPPER

31.12.2021

31.12.2020

€ '000

Operating profit / (loss)

68,120

21,447

Adjustments for:

Annual Financial Report of 31 December 2021

Page | 148

+ Depreciation

23,075

21,413

- Amortization of Grants

(183)

(196)

EBITDA

91,012

42,664

EBITDA

42,681

Adjustments for:

+ Loss / - Profit from Metal Lag

(35,193)

4,251

+ Losses from Fixed assets write-offs or impairments

1,858

- Profit / + Loss from sale of Assets

672

(994)

+ Expenses for Covid-19 pandemic

1,968

1,452

a - EBITDA

58,499

49,231

COPPER

31.12.2021

31.12.2020

€ '000

(Α) Value of Metal in Sales

1,416,018

928,141

(B) Value of Metal in Cost of Sales

(1,367,578)

(929,112)

(13,247)

(3,280)

(A+B+C) Metal Result in Gross Profit

35,193

(4,251)

36. Effect in the Profit and Loss from distribution in kind

On 09.04.2021, ELVALHALCOR’s Extraordinary General Meeting decided the distribution of shares of the

listed in the Brussels and the Athens Stock Exchanges, Cenery Holdings S.A., to its shareholders as distribution

of dividend in kind of prior year profits. Pursuant to article 18 par. 1 of L.4548/2018, Cenergy Holdings’s shares

were valuated with the weighted average of the traded price in the markets for the six months ending on the

last before the General Meeting dated 09.04.2021, i.e. 08.04.2021, when was formed to Euro 1.7814836029

per share. At the distribution the book value of the participation in Cenergy Holdings, was Euro 52.6 million

at Company level and Euro 63.1 million at Consolidated level. The difference between the book value and the

valuation of the shares which stood at Euro 85.2 million as a result of the product of the weighted average

price and the shares distributed, was included in the results of the period in a separate reporting line “Profit

/ (Loss) from distribution in kind”.

The aforementioned treatment is done according to the provisions set forth in IAS 8, where it is provided that

in the absence of an IFRS that specifically applies to a transaction, other event or condition, management can

use its judgement in developing and applying an accounting policy that results in information that is: (a)

relevant to the economic decision-making needs of users; and (b) reliable, in that the financial statements:

(i) represent faithfully the financial position, financial performance and cash flows of the entity; (ii) reflect the

economic substance of transactions, other events and conditions, and not merely the legal form; (iii) are

neutral, i.e. free from bias; (iv) are prudent; and (v) are complete in all material respects. In making the

judgement described in IAS 8:10, management can refer to, and consider the applicability of, the following

sources in descending order: (a) the requirements in IFRSs dealing with similar and related issues; and (b) the

definitions, recognition criteria and measurement concepts for assets, liabilities, income and expenses in the

Conceptual Framework for Financial Reporting. In making the judgement described in IAS 8:10, management

also considered the most recent pronouncements of other standard-setting bodies that use a similar

conceptual framework to develop accounting standards, such as the “IFRIC 17 Distribution of Non-Cash Assets

to Owners”, and the “ASC 845 US GAAP” - “Non-monetary transactions”.

Annual Financial Report of 31 December 2021

Page | 149

According to the accounting treatment, which was followed, the account “Results carried forward” is debited

with the amount(s) as decided by the Shareholders’ General Meeting and in application of l.4548/2018, to a

respective credit of a distribution liability. On the date of the distribution, the Company credits the respective

asset which is distributed with the value of “book value”, which is in accordance with its set policies as at that

reporting date, to a credit of a P&L account “Profit/(Loss) from distribution in kind”. Upon completion of the

distribution, debits the liability to a respective credit of the P&L account “Profit/(Loss) from distribution in

kind”. The aforementioned accounting treatment, presents the transaction fairly and accurately.

37. Effect from implementation of IAS 19

The International Financial Reporting Interpretations Committee (IFRIC) decision on Attributing Benefit to

Periods of Service under a defined benefit plan, in accordance with International Accounting Standard (IAS)

19 "Employee Benefits". The International Financial Reporting Interpretations Committee issued the final

agenda decision in May 2021, under the title "Attributing Benefits to Periods of Service" (IAS 19), which

includes explanatory material regarding the way of distribution of benefits in periods of service following a

specific defined benefit plan proportionate to that defined in Article 8 of Law 3198/1955 regarding provision

of compensation due to retirement (the "Labor Law Defined Benefit Plan").

The aforementioned decision differentiates the way in which the basic principles and regulations of IAS 19

have been applied in Greece in the previous years, and therefore, according to what is defined in the “IASB

Due Process Handbook (par 8.6)”, entities that prepare their financial statements in accordance with IFRS are

required to amend their Accounting Policy accordingly.

The Group and the Company applied the IAS 19 provisions as defined under Article 8, Law 3198/1955, Law

2112/1920, and as amended by Law 4093/2012 in the period from initial hiring until the employee retires.

The application of said final Decision has been accounted as a change in accounting policy by applying the

amendment retrospectively form the beginning of the comparative period pursuant to paragraphs 19-22 of

IAS 8.

Below are set forth the restated financial statements. The figures which were not affected by the provisions

of the IAS 19 implementation are not included. As a result, the totals and subtotals as presented cannot be

recalculated based on what is presented below.

GROUP

COMPANY

Statement of Financial Position

2020

IAS 19

Effect

2020

Restated

2020

IAS 19

Effect

2020

Restated

ASSETS

€ '000

Total Assets

1,858,322

1,612,430

1,612,429

Annual Financial Report of 31 December 2021

Page | 150

EQUITY

Equity attributable to shareholders’

Profit / (loss) carried forward

241,771

6,246

248,017

204,078

4,400

208,478

Total Equity attributable to shareholders’

763,935

6,246

770,182

734,497

738,898

Non-Controlling Interest

14,352

Total Equity

778,287

6,246

784,534

734,497

738,898

LIABILITIES

Non-current liabilities

Deferred Tax Liabilities

55,448

1,973

57,421

46,131

1,390

47,521

Employee benefits

19,395

(8,219)

11,176

13,691

(5,789)

7,902

555,703

(6,246)

549,456

461,502

(4,400)

457,102

Total Liabilities

1,080,034

(6,246)

1,073,787

877,933

(4,400)

873,532

Total Equity and Liabilities

1,858,322

1,858,321

1,612,430

Annual Financial Report of 31 December 2021

Page | 151

GROUP

COMPANY

Statement of Other

Comprehensive income

2020

IAS 19

Effect

2020

Restated

2020

IAS 19

Effect

2020

Restated

€ '000

Κέρδος / (ζημία) περιόδου από

συνεχιζόμενες δραστηριότητες

29,507

(141)

29,366

17,110

(156)

16,954

Items that will never be reclassified to

profit or loss

Remeasurements of defined benefit

liability

(1,261)

837

(424)

(805)

568

(237)

Equity investments in FVOCI - net change

in fair value

178

Related tax

249

(200)

193

(136)

Total

(834)

637

(197)

(612)

432

(180)

Items that are or may be reclassified to

profit or loss

Total

1,793

1,829

Other Comprehensive income / (expense)

after tax

959

638

1,597

1,217

432

1,649

Total Comprehensive income / (expense)

after tax

30,466

496

30,962

18,327

275

18,602

GROUP

COMPANY

Income Statement

2020

IAS 19

Effect

2020

Restated

2020

IAS 19

Effect

2020

Restated

€ '000

Revenue

2,028,588

1,405,660

Cost of Sales

(1,893,640)

(186)

(1,893,826)

(1,318,866)

(206)

(1,319,072)

Gross profit

134,948

(186)

134,762

86,794

(206)

86,588

Other income

10,785

10,690

Selling and Distribution expenses

(21,430)

(11,772)

Administrative expenses

(54,306)

(37,954)

Impairment loss on receivables and

contract assets

(485)

(112)

Other expenses

(9,905)

(9,904)

(7,248)

Operating Profit / (Loss) (ΕΒΙΤ)

59,607

(186)

59,421

40,398

(206)

40,192

Finance income

288

400

Finance Costs

(25,506)

(19,414)

Dividends

1,208

Net Finance income / (cost)

(25,218)

(0)

(25,218)

(17,806)

(0)

(17,806)

Share of profit / (loss) of equity-

accounted investees, net of tax

4,580

Profit / (Loss) before income tax

38,969

(186)

38,783

22,592

(206)

22,386

Income tax expense

(9,462)

(9,417)

(5,482)

(5,432)

Profit / (Loss) for the year

29,507

(141)

29,366

17,110

(156)

16,954

Annual Financial Report of 31 December 2021

Page | 152

GROUP

COMPANY

Cost of Employee

benefits

2020

IAS 19

Effect

2020

Restated

2020

IAS 19

Effect

2020

Restated

€ '000

Employee remuneration &

expenses

87,229

50,687

Social security expenses

21,242

12,637

Defined benefit plan expenses

1,794

185

1,979

736

206

942

Other employee benefits

10,076

7,249

Total

120,341

185

120,526

71,308

206

71,515

GROUP

COMPANY

Expense by Nature

2020

IAS 19

Effect

2020

Restated

2020

IAS 19

Effect

2020

Restated

€ '000

Employee benefits

120,341

185

120,526

71,308

206

71,515

Total

1,969,377

185

1,969,561

1,368,592

206

1,368,799

In conclusion, the movement in the Defined Employee Benefits Provision due to Retirement as published and

as restated is as follows:

GROUP COMPANY

2020

IAS 19

Effect

2020

Restated

2020

IAS 19

Effect

2020

Restated

€ '000 € '000 € '000 € '000

Balance as at 1st of January 17,929 (7,568) 10,361 12,776 (5,429) 7,347

Amounts recognized in profit or loss

Current service cost

616 198 814 324 219 543

Pas t service credit

89 (66) 23 23 (10) 13

Settlement/curtailment/termination loss

956 118 1,074 293 45 338

Interest cost/income (-)

133 (65) 68 95 (47) 48

Total P&L Charge

1,794 185 1,979 735 207 942

Amounts recognized in OCI

Remeasurement loss/gain (-):

-Actuarial loss/gain (-) arising from:

Demographic assumptions

130 (226) (96) - -

Financial assumptions

992 (615) 377 629 (468) 161

Experience adjustments

139 4 143 175 (99) 76

Total amount recognized in OCI

1,261 (837) 424 804 (567) 237

Other

Benefits paid

(1,589) (1,589) (625) (625)

Balance as at 31st December 19,395 (8,219) 11,176 13,690 (5,788) 7,902

Annual Financial Report of 31 December 2021

Page | 153

38. Subsequent events

1. On 13.01.2022 ELVALHALCOR participated in the share capital increase of the joint venture Nedzink BV,

with Euro 1.5 million, maintaining its share to 50%. On 28.02.2022, the amount of Euro 1.25 million from

the loan provided to Nedzink BV, was converted to capital.

2. In regards to the developing events in Ukraine, the Group during 2021 had a 0.9% of the Turnover directed

to Russia and 0,6% directed to Ukraine, while at company level the sales stood at 1% for the market of

Russia and 0.6% for the Ukrainian market. Both markets are not significant in size and the respective

quantities can be easily be replaced by other markets where there is demand for the products of the

Group and the Company. It is worth noting that he Group and the Company purchase raw materials from

the Russian market, mostly primary aluminium, but the specific vendor accounts for the 5%-7% of the

required materials and can be easily be replaced by others without any repercussions to the orderly and

unhindered operation of the Company and the Group. Finally, it is noted that the entity ΕΤΕΜ SYSTEMS

LLC, based in Ukraine, is as commercial company with total assets amounting to Euro 274 thousand,

turnover of Euro 1,054 thousand and net profit after tax of Euro 30 thousand for the year 2021. As a

consequence, and considering the financial figures of the said entity, it is reasonably estimated that the

aforementioned financial figures cannot affect the consolidated figures of the Group or the Company,

while the said entity can restart operations swiftly after the turbulence ends.

Annual Financial Report of 31 December 2021

Page | 154

Information under article 10 of Law 3401/2005

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Annual Financial Report of 31 December 2021

VI. NOTES TO THE FINANCIAL STATEMENTS AS AT 31 DECEMBER 2021

155

Report on the Disposal of Funds Raised from the issuance of a Common Bond Loan amounting to

Euro 250,000,000 for the period from 17.11.2021 until 31.12.2021

Pursuant to the provisions of paragraph 4.1.2 of the Athens Stock Exchange Regulation, the decision

number 25/17.07.2008 & 6.12.2017 of the Board of Directors of the Athens Stock Exchange and the

decision number 8/754/14.04.2016 of Board of Directors of the Hellenic Capital Market Commission,

it is announced that, from the issuance of a Common Bond Loan amounting to €250,000,000, of a term

of seven (7) years, divided into 250,000 dematerialised, common, bearer bonds with a nominal value

of €1,000 each and an annual interest rate of 2.45%, carried out in accordance with the decision of

5.11.2021 of the Extraordinary General Meeting of the shareholders of “ELVALHALCOR HELLENIC

COPPER AND ALUMINUM INDUSTRY SOCIETE ANONYME” (“Company”), the decision of the Board of

Directors of the Company (“Common Bond Loan”) and the decision No. 3/935/8.11.2021 of the Board

of Directors of the Hellenic Capital Market Commission for the “Approval of the content of the

prospectus of the company "ELVALHALCOR Hellenic Copper and Aluminum Industry Societe Anonyme"

regarding the public offer and the introduction for negotiation of its dematerialised, common, bearer

bonds with the issuance of a common bond loan” (“Prospectus”), a total capital of €250,000,000 was

raised. The expenses of issuance of the Common Bond Loan, initially estimated according to the

Prospectus (p. 18, under Section D, D2) in the amount of up to approximately €6 million, eventually

amounted to €3,233.7 thousand and reduced respectively the total funds raised.

The issuance of the Common Bond Loan was fully covered and the certification of the payment of the

raised funds was made by the Board of Directors of the Company on 16.11.2021. It is noted that the

issued 250,000 common bearer bonds were listed for trading in the Fixed Income Securities Category

of the Regulated Market of the Athens Stock Exchange on 17.11.2021.

According to what is stated in the relevant Prospectus, it is announced that part of the raised funds

was allocated from 17.11.2021 until 31.12.2021 as follows:

Nr.

Use of Raised Funds

Raised Funds

(Amounts in

€Mill.)

Allocated Funds

until 31.12.2021

inclusive

(Amounts in

€Mill.)

Unallocated

funds on

31.12.2021

(Amounts in

€Mill.)

New investments in real estate for

expansion of activities

30,0

Covering working capital needs

60,0

59,8

0,2

Reduction of Short-Term Borrowing

154,0

Total

244,0

213,8

30,2

Plus: Issuance expenses

3,2

Plus: Difference between budgeted

and incurred Expenditure Expenses

2,8

Grand Total

250,0

217,0

33,0

1) Regarding the use Nr. 1 of the above table, no part of the amount of €30 million was allocated

until 31.12.2021. According to the Prospectus (p. 18, under Section D, D2) an amount of €30 will be

allocated until 30.06.2022 for the payment of a consideration (including the relevant expenses and

taxes) for the purchase of land lot and storage space in Inofyta. The properties will be used, in the long

term, for storage and distribution of the Group’s products. If the above transaction is not completed,

the Company will seek real estate, adjacent to the industrial properties of the Company or its

subsidiaries in the area of Inofyta that serve the business needs of the Group and in case it is not

possible to find the above properties until 31.10.2022 or the amount allocated is less than €30 million,

the Company will allocate until 31.12.2022 any unallocated amount to cover working capital needs.

Annual Financial Report of 31 December 2021

Page | 156

2) Regarding the use Nr. 2 of the above table, from the amount of €60 million, an amount of €59.8

million was allocated until 31.12.2021 in payments of suppliers for the supply of raw materials of the

Company.

3) Regarding the use Nr. 3 of the above table, the amount of €154 million was allocated until

31.12.2021 as follows:

i) an amount of €43 million to “EUROBANK Bank SA” for the repayment of nr. 036/13/28.8.1991,

1712/1/14.12.2010, 37/12/28.8.1991, 570-23.1.1997 framework contracts, open (mutual)

accounts (for more information see section 3.12.1 “Loan Agreements” of the Prospectus),

ii) an amount of €56 million to “ALPHA Bank S.A.” for the repayment of nr. 13183/7.2.1997 and

25573101/28.7.2011 framework contracts, open (mutual) accounts (for more information see

section 3.12.1 “Loan Agreements” of the Prospectus) and

iii) an amount of €55 million to the “National Bank of Greece S.A.” for the repayment of nr.

0400107000/1003/11.3.1988, 9747084420/1.6.2011 and 0400071250/8.11.1977 framework

contracts, open (mutual) accounts (for more information see section 3.12.1 “Loan Agreements”

of the Prospectus).

4) Regarding the unallocated issuance expenses Nr. 4b of the above table, amounting to €2.8

million, their allocation, in terms of use, will be determined by a decision of the Board of Directors of

the Company.

The allocation of funds during the above period from 17.11.2021 until 31.12.2021, per investment/use

category Nr. 1 to 4 of the above table refers to the cash disbursement and not the accounting of the

expense, according to the provisions of nr. 25/17.07.2008 & 6.12.2017 decision of the Board of

Directors of the Athens Stock Exchange.

It is clarified that the temporarily unallocated funds are deposited in the Company’s interest-bearing

bank account.

Athens, March 15

, 2022

The Vice-President of the

BoD

The General Manager of

the Aluminum Segment

and BoD member

The General Manager of

the Copper Segment and

BoD member

The Director appointed by

the BoD

DIMITRIOS

KYRIAKOPOULOS

LAMPROS VAROUCHAS

PANAGIOTIS LOLOS

SPYRIDON KOKΚOLIS

ID Card No. AK 695653

ID Card No. AB 535203

ID Card No. ΑΗ 131173

ID Card No. ΑΝ 659640

Reg.Nr. A’ Class 20872