Climate, Environment, and Social

Our Commitment to the Decarbonization Journey: Net Zero Carbon by 2040

Enerjisa Üretim’s climate transition framework has been updated in line with current scientific data and policy expectations. As part of this update, the reference scenario in its long-term decarbonization roadmap has been revised, moving the target year from 2045 to 2040. This new target aligns closely with several key benchmarks, including the 1.5°C-aligned C2 scenarios outlined in the IPCC’s Sixth Assessment Report (AR6)1, the International Energy Agency’s Net Zero by 2050 roadmap, and the European Union’s 2040 goal of a 90% reduction in greenhouse gas emissions. Additionally, it is structurally consistent with Türkiye’s 2053 net-zero vision and the 2035 renewable energy capacity projections set out in the Türkiye National Energy Plan (TUEP).

The net-zero carbon scenario for 2040 is framed as a probabilistic pathway, shaped by current technological, economic, and regulatory conditions. Its feasibility will depend on a range of dynamic factors, including policy developments, access to finance, system flexibility, technology maturity, and operational transformation capacity. Within this context, the analyses and roadmap presented in the Climate Transition Plan offer a probability-based transformation model built on defined assumptions.

Updating the scenario marks a strategic milestone, particularly in areas such as low- carbon transformation of the generation portfolio, acceleration of renewable energy investments, development of flexible thermal infrastructure, and expansion of energy storage solutions. The emissions reduction targets extend beyond operational activities, encompassing all corporate decision-making mechanisms—from governance to investment planning.

Built on this strategic direction, the Climate Transition Plan outlines the 2030 emissions intensity target in alignment with the IPCC C2 – 1.5°C scenario with high overshoot, along with the corresponding short-, medium-, and long-term strategic actions. The plan adopts an analysis-based approach to assess both resilience to climate-related risks and preparedness for emerging opportunities.

The table below presents our updated emission intensity projections.

Our Strategic Pillars

Enerjisa Üretim’s climate strategy is shaped by a holistic assessment of scientific data, policy developments, technology trends, and societal expectations. Six core principles form the corporate foundation of this strategic direction:

Six fundamental principles form the institutional basis of this strategic orientation:

• Decarbonization as a Strategic Differentiator
• Carbon Pricing and Regulation as Enablers of Strategic Coherence
• System Thinking in Power Sector Innovation
• Energy Security Through Renewable Sovereignty
• Engagement with the Globally Sustainability Architecture
• Just and Regenerative Transition

These principles not only enhance corporate resilience against climate risks but also enable us to approach the energy transition as a sustainable value creation process.

For detailed explanations and implementation steps of these principles, please refer to our Climate Transition Plan.

Our climate strategy is built on innovative solutions and sustainable energy technologies that support low- carbon growth. We manage climate risks, seize opportunities, and lead the transformation to create a better future and a resilient business strategy.

Climate-Related Risks and Opportunities

Enerjisa Üretim has reviewed all climate scenarios outlined by these authorities and integrated them with its own forecasts and projections to establish two scenarios: the “ambitious climate transition” scenario, which anticipates global warming remaining well below 2ºC by the end of the century, and the “slow climate transition” scenario, which projects global warming between 3.5 and 4ºC.

Climate Related Opportunities for Enerjisa Üretim

Thanks to lts position in the energy market and diverstied portfolio, Enerjisa Oretim has idensified a range of promising dimate related opportunities within Turklye’s transition to cleaner energy, especially under the Ambitious Climate Transition scenario ( < 2°C).

Environmental Management

All our operational and new investment processes are designed in full compliance with both national and international environmental regulations, fulfilling our environmental responsibilities and reflecting our commitment to future generations. In this context, prioritizing the implementation of necessary measures to minimize environmental impacts, meeting the expectations of national and international stakeholders, and continuously monitoring compliance with relevant obligations are fundamental to our approach. We continuously enhance our environmental management practices by working closely with local and international regulatory authorities, aiming to develop innovative strategies that reduce negative environmental effects. All necessary permits and approvals have been secured to ensure rigorous monitoring and regular reporting of the environmental impacts of our operations.

Environmentally conscious and sustainable practices are prioritized throughout our all processes. Environmental impacts are consistently monitored at every stage of production, with improvement measures implemented as needed. Under our environmental management system and in accordance with the ISO 14001:2015 standard, we conduct environmental audits and internal inspections across all activities. Comprehensive external audits conducted in 2024 identified no non-compliances, confirming full adherence to legal requirements and corporate standards. Throughout the year, no environmental incidents occurred across any field operations; emergency response plans, regular site inspections, and training programs have supported a proactive approach to potential risks.

At Enerjisa Üretim, we conduct comprehensive efforts across all project sites where our new investments are underway to minimize environmental impacts and ensure effective waste and emissions management. We systematically monitor the activities of our subcontractors in compliance with the International Finance Corporation (IFC) standards, maintaining regular records on water, wastewater, noise, air quality, soil, noise, waste, and chemical management. Through emission measurements at generators, dust control via irrigation and monitoring, use of energy-efficient equipment, waste and wastewater management, and environmental awareness training, we not only ensure environmental compliance but also continuously improve our operational processes.

To effectively manage environmental impacts in our projects and power plants, we implement extensive environmental management procedures aligned with the environmental performance standards of international finance institutions such as IFC and EBRD. Within this framework, water and wastewater management incorporate recovery and reuse methods, while air quality is safeguarded through dust suppression and emission control measures. Chemicals used on site are managed under secure storage and handling protocols; soil excavated during construction is stored separately for rehabilitation purposes, and erosion risks are actively mitigated. Hazardous and non-hazardous waste is segregated and managed through recycling, recovery, or appropriate disposal methods. Groundwater and surface water are regularly monitored, and drainage systems are implemented to protect water resources. All these activities are carried out in full compliance with IFC PS6, EBRD PR6, GRI 304, and EU environmental legislation, aiming to conserve and enhance biodiversity.

Throughout the year, all our plants have undergone extensive audits conducted by various public authorities and financial institutions. Each of these audits was successfully completed without any non- compliance issues or findings. During the inspections, our environmental management systems and operational processes were thoroughly reviewed, confirming full compliance with applicable all environmental regulations, sustainability principles, and corporate standards. This positive outcome reflects our environmental management policies that proactively identify and effectively mitigate environmental risks, supported by our ongoing commitment to continuous improvement. We have enhanced operational efficiency and maintained all our activities in accordance with international environmental standards.

Our efforts in environmental management are made possible by our employees’ strong environmental awareness and dedication to corporate compliance. In line with our philosophy of continuous improvement, we will continue to implement innovative practices and steadfastly pursue sustainability-driven strategies to further advance our environmental performance.

Water and Waste Management

Water Management

At Enerjisa Üretim, we conduct risk assessments and detailed water analyses to ensure the sustainable use of water resources and to minimize water stress risks. Given Türkiye’s status as a water- stressed country, we develop water conservation strategies across all our operations. At our thermoelectric power plants, which have a high dependence on water, we continuously improve processes to reduce water withdrawal and increase water recovery. For every facility where water is withdrawn, the characteristics of the receiving water body are carefully considered, with specific standards applied for different sources such as seas, rivers, and lakes. While complying with local regulatory requirements for water withdrawal, we continually enhance our water management practices in line with international standards.

Wastewater Management

Wastewater management is executed in compliance with national and international standards, aimed at mitigating environmental impacts and enhancing our sustainability performance. Priority substances and control parameters for wastewater treatment are defined based on legal requirements, international standards, and internal company criteria.

Our wastewater discharge management adheres to the Water Pollution Control Regulation (SKKY) and relevant international standards, implementing a comprehensive discharge management system. Local and international requirements are strictly followed to protect water resources, with additional criteria applied in line with IFC Performance Standards and EBRD Performance Requirements. Internal standards aligned with financial institutions’ sustainability criteria and our own environmental commitments have also been established. Regular analyses are conducted at sites with wastewater treatment facilities, ensuring monitored parameters remain within designated limits.

Because receiving environments (seas, rivers, lakes, etc.) differ in characteristics, discharge limits are established considering regional environmental conditions. Water quality parameters and discharge limits are continually monitored and analyzed, with ongoing process reviews to mitigate environmental impacts.

Key parameters prioritized in wastewater treatment include temperature, chemical oxygen demand (COD),suspended solids (SS),biochemical oxygen demand (BOD),pH, total nitrogen, total phosphorus, total coliform, oil, and grease. To date, no non-compliance has been identified.

Domestic wastewater generated at subcontractors’ mobilization areas is securely stored in sealed septic tanks to prevent environmental contamination. Waste accumulated in these tanks is regularly removed and transported to municipal wastewater treatment plants.

Waste Management

In line with this hierarchy, a policy is implemented that prioritizes preventing waste generation at its source, promoting recycling, and enhancing opportunities for energy recovery.

In 2024, there was a significant improvement in waste management performance, with a 37% reduction in total waste generated. This decline is largely attributed to the effective management of ash waste and process optimizations. Non-hazardous waste (excluding ash) decreased by 80%, while hazardous waste was reduced by 84%, marking a substantial advancement in mitigating environmental risks. Industry-wide research is ongoing to develop sustainable management strategies for high-volume waste types such as ash; these efforts include exploring alternative uses, recycling methods, and industrial symbiosis opportunities, which are key focus areas for 2025.

As of 2024, 22 power generation facilities along with our Ataşehir headquarters have been awarded the “Zero Waste Certificate.” Additionally, we plan to submit zero waste certification applications in 2025 to the Ministry of Environment, Urbanization, and Climate Change for seven newly commissioned or acquired plants that have completed the project process. This initiative goes beyond regulatory compliance and reflects our commitment to embedding sustainability as a corporate priority across the company.

Circular Economy

Adopting circular practices across the supply chain strengthens operational resilience against geopolitical risks, raw material price volatility, and energy crises— while also improving supply security by reducing external dependencies. In this direction, our circular transition strategy has been structured using the Circular Transition Indicators (CTI) methodology and is tied to the following targets:

• Short-term goals (by 2025): Increasing the rate of circular material use and reducing the volume of operational waste,
• Medium-term goals (by 2030): Enhancing recovery and regeneration capacity while minimizing waste disposal rates,
• Long-term goals (by 2050): Improving circular performance in full integration with the supply chain and achieving the Net Zero Waste goal.

As part of this approach, the transition from a linear economy to a circular economy is being accelerated, shifting from the traditional “Buy-Use-Throw Away” model to a more sustainable “Buy-Reuse-Recycle” model. The goal is to utilize resources more efficiently and with lower environmental impact in every production cycle.

General Overview of Key Performance Indicators (KPIs) Identified for Each Business Unit Based on Three Circular Principles

Energy Efficiency

Energy efficiency is a cornerstone of our sustainable generation strategy. We aim to maximize resource utilization while minimizing the environmental footprint of our operations. To this end, we prioritize energy- saving measures and carbon emission reductions across both our existing infrastructure and new investments. By combining our expertise in renewable energy generation with operational efficiency, we are implementing digitalization, electrification, and low- emission technologies in energy-intensive processes. Our pioneering projects, carried out at various scales and locations, not only contribute to environmental sustainability but also set industry benchmarks as innovative solutions. The key initiatives underway at our power plants are outlined below.

Integrated Flue Gas Treatment and Carbon Capture (CCUS) Project at Tufanbeyli Energy Hub

As part of our strategic transformation program aimed at increasing energy efficiency while lowering emissions, we are launching a leading project at the Tufanbeyli Energy Hub focused on integrated flue gas treatment and carbon capture technologies. This project targets reducing CO₂ emissions as well as other pollutants in flue gas, including sulfur dioxide (SO₂) and nitrogen oxides (NOₓ),through a multi-pollutant sensitive system approach.

The system, featuring innovative wet scrubbing technology, captures CO2 and NOₓ compounds simultaneously from flue gas and chemically converts them into organomineral liquid fertilizer. This process turns harmful emissions into a valuable input for agricultural production. This approach offers an innovative solution model fully aligned with the principles of the circular economy and decarbonization, integrating environmental responsibility with economic benefit.

Site preparations and the Environmental Impact Assessment (EIA) process are complete, with pilot-scale implementation planned for 2026. During this phase, the system’s modularity, chemical conversion efficiency, energy input impact, and compliance with national regulations will be thoroughly evaluated. Lessons learned from the pilot will provide the foundation for replication strategies at other thermal power plants with similar flue gas compositions near agricultural areas.

This technology moves beyond traditional sulfur treatment systems, positioning the Tufanbeyli Energy Hub, a critical part of energy supply security, as a leading example of transformation aligned with Türkiye’s climate goals.

Bandırma-1 Administrative Building: Carbon Neutral and Green Building Transformation

As part of our efforts to support energy efficiency through structural transformation projects, an integrated energy management system based on carbon-neutral and green building principles has been implemented at the Bandırma-1 Administrative Building. The project targets powering all administrative building operations entirely with renewable energy sources and achieving net-zero emissions at the building level.

Solar panels and wind turbines have been installed on the building’s roof area, complemented by two Pomega hybrid containers deployed for energy storage. The system, with a total installed capacity of 90 kW, meets the building’s lighting, ventilation, and HVAC needs, ensuring energy demand is decoupled from fossil fuels.

A soilless vertical garden system on the building’s façades enhances natural insulation, while irrigation for the green façades is supplied with rainwater harvested from the roof.

All systems are centrally monitored through the Building Management System (BMS),with real-time tracking of energy generation, consumption, and water use via digital platforms. Launched in June 2024, this innovative application directly contributes to local carbon reduction and resource efficiency goals, serving as a benchmark for scaling sustainable building practices across the corporation.

Yamanlı Hydroelectric Plant: Oil Mist Filtration System for Emission Reduction

As part of our preventive measures to reduce operational emission sources, an advanced Oil Mist Filter system has been implemented at the Yamanlı Hydroelectric Plant to control oil vapor released from machinery. This system plays a crucial role in preventing oil-based aerosols, especially those originating from rotating equipment, from dispersing into the air, thereby significantly improving both occupational health and environmental quality.

The filtration system effectively separates oil particles from the air, creating a clean and breathable environment within the work area. This application is strategically important not only for worker health but also for extending equipment lifespan and enhancing operational safety.

The collected oil is periodically drained and disposed of in compliance with hazardous waste management protocols.

The project offers a cost-effective yet highly efficient solution to minimize environmental emissions at hydroelectric production facilities. It is also considered part of a broader transformation vision aimed at integrating sustainable production standards across all our plants.

MadenNEXT: Transforming Mining through Electrification and Smart Operations

The MadenNEXT initiative at the Tufanbeyli Energy Hub was launched to reduce the carbon footprint and enhance operational efficiency by electrifying mining operations. The project aims to eliminate upstream Scope 3 emissions generated by diesel-powered vehicles, thereby restructuring carbon-intensive activities in line with the EU Taxonomy’s sustainable transition framework.

The first phase of this transformation was successfully completed with the deployment of five electric trucks, each equipped with a 564 kW battery capacity, and two electric excavators. These vehicles are actively operating on site, contributing not only to emission reductions but also to lower fuel consumption, decreased noise levels, and reduced risk of vibration-related workplace accidents.

The electrification effort extends beyond vehicles, with a

comprehensive redesign of the entire energy infrastructure to be supported by renewable and smart systems. The mine site will become an integrated, renewable-powered operation through the installation of a solar power plant, battery energy storage systems, and autonomous operation technologies. Notably, Türkiye’s first remotely controlled Stacker/Reclaimer equipment has been successfully commissioned, alongside the launch of digitization-driven automation processes.

Scheduled for completion by the end of 2025, the MadenNEXT project represents a transformative model that goes beyond cutting carbon emissions. It aims to deliver safer working conditions, lower maintenance costs, and long-term energy independence. Feasibility studies conducted within the project provide valuable insights into the efficiency and scalability of electric infrastructure, laying the groundwork for similar site transformations in the future.

Afforestation Activities

Between 2019 and 2024, we planted a total of 1.3 million saplings across the impact zones of our Renewable Energy Resource Areas (YEKA) projects and operational sites. This effort transformed approximately 856 hectares, equivalent to 1,200 football fields, into forested land, making a significant contribution to the ecosystem.

To help preserve the natural ecosystem, we planted 280,000 saplings as a breath of fresh air for the future. Each year, we planted saplings equivalent to 10,000 times our age. Through our afforestation projects, we not only increase green spaces but also maintain ecological balance in the regions, creating long-term carbon sink areas.

Our sapling planting initiatives extend beyond just physically increasing forested areas; they also focus on spreading environmental awareness. Through training and awareness campaigns, we aim to raise local community consciousness—especially among young generations—to adopt sustainable lifestyles. These educational programs cover topics such as nature conservation, biodiversity support, and the importance of combating climate change, reinforcing a sense of environmental responsibility.

When selecting saplings, we prioritized species compatible with the local natural ecosystem that can contribute positively in the long term. The chosen saplings are resistant to frost and minimally affected by potential wildfire due to their thick bark. Additionally, species with economic value and industrial use were selected to support the local economy. This approach ensures a sustainable balance between regional development and ecological preservation.

The growth of the saplings is carefully monitored. Once mature, these trees will create new carbon sink areas, helping reduce atmospheric carbon dioxide levels. Enerjisa Üretim aims to increase its sapling planting target to 2 million by the end of 2026, advancing our goals for ecological restoration and carbon reduction. We remain steadfast in our commitment to nature-aligned sustainable growth.

Within the scope of Sabancı Holding’s Youth Mobilization initiative, we organized, 1,3 a large-scale tree planting event at İzmir Institute of Technology with participation from our employees, university students, and academic staff.

This event was designed to raise environmental awareness among youth and employees while contributing positively to nature. Participants gathered on the university campus to reinforce the importance of contributing to a sustainable future.

The saplings planted during the event were selected from species suited to the region’s climate and soil conditions and aimed to support ecosystem balance. These species were chosen to integrate with the local flora and create carbon sink areas over time, reducing carbon emissions. As the saplings mature, they will also support local biodiversity and establish a natural habitat within the campus grounds. Enerjisa Üretim will continue to support projects that enhance environmental awareness among younger generations and uphold our responsibility to nature through events like this. Moving forward, we plan to expand similar initiatives, further strengthening our positive impact on both nature and society.

Biodiversity and Ecosystem Management

We address the environmental impacts of our energy generation activities not only in terms of legal compliance but as a core element of our corporate strategy. Biyoçeşitlilik yönetimini; IFC Performans Standardı 6 (PS6),Avrupa İmar ve Kalkınma Bankası (EBRD) Performans Gerekliliği 6 (PR6),GRI 304 göstergeleri, Avrupa Yeşil Mutabakatı ve AB Habitat/Kuş Direktifleri gibi uluslararası standartlarla uyumlu şekilde yürütüyoruz.

The year 2024 marked a pivotal milestone for integrating biodiversity management into our corporate framework. As part of this, we appointed a dedicated corporate biodiversity specialist reporting directly to leadership team within our ESG structure. This step both strengthens our institutional capacity and establishes a solid foundation for embedding biodiversity management throughout our operations and investments. We completed the “Biodiversity Governance Document” in 2024 and plan to implement it company-wide starting in 2025. This document clearly defines our biodiversity management responsibilities, from investment decisions and site planning to construction activities and post-operation monitoring.

Management of Dependencies on Nature and Our Environmental Impacts

Our energy generation activities depend on ecosystem services at varying levels. In particular, our hydroelectric plants are directly reliant on the continuity of the water cycle and the healthy functioning of river ecosystems. The efficiency and operational safety of our thermal power plants are sensitive to environmental factors such as climate conditions, air quality, and water resources.

For all our plants, we analyze essential ecosystem services, including water supply, regulation of air and water quality, and soil erosion prevention.By assessing how changes in these services affect our operations, we develop business continuity plans that take these dependencies into account. The key dependencies we identify, in accordance with Science Based Targets Network (SBTN) criteria, comprise the environmental assets and services necessary for the safe and sustainable operation of our plants.

We also monitor and manage our impacts on nature based on the specific ecosystem conditions of the regions where we operate. Especially for large-scale renewable energy projects, we carefully manage site selection processes to reduce habitat loss and fragmentation risks, supported by environmental and social impact assessments.

Direct impacts such as the effects of wind turbines on birds and bats, alterations caused by hydroelectric plants to river ecosystems, and land use pressures from solar plants are evaluated through on-site biological monitoring. For example, migratory bird routes and bat activity are regularly tracked, with turbine-related risks analysed based on collected data. Additionally, we conduct field inspections to manage the risk of invasive species spread and raise awareness among our employees on this issue.

We also consider the indirect effects of climate change on ecosystems. Anticipating that changing climate conditions may alter migration and breeding cycles for certain species, we develop adaptation and mitigation strategies accordingly.

All these efforts are supported by analyses conducted with the ENCORE tool, aligned with TNFD and SBTN frameworks. The table below summarizes the priority impact and dependency areas according to the energy generation technologies we employ.

Ecological Sensitivity studies have been conducted under three main categories, yielding the following results across all Enerjisa Üretim power plants:

Based on the analysis results, a significant portion of Enerjisa Üretim’s sites, 38%, are located in areas facing very high water-related threats, while 57% are situated in regions with high water risk. The water risk indicator used in the analysis was calculated using the World Resource Institute (WRI) Aqueduct Water Risk Atlas Tool, which integrates selected indicators from categories such as physical quantity, quality, regulatory, and reputational risks to measure all water-related risks comprehensively.

WRI Map

Taking into account international biodiversity and natural capital frameworks such as the SBTN and TNFD recommendations, Enerjisa Üretim has identified the biodiversity impact zones and risks of its power plants by utilizing tools and databases like ENCORE, IUCN, and WRI. In light of these detailed analyses, Enerjisa Üretim is working on a roadmap to neutralize biodiversity risks in its operational areas with a responsibility toward tomorrow. As a result of these analyses, nine priority sites4 have been identified where particular sensitivity exists regarding biodiversity and water usage. These sites have undergone detailed assessments to further examine related biodiversity risks and opportunities.

Assessment of Nature-Related Risks

Our impact areas point to various nature-related risks for Enerjisa Üretim. In alignment with the TNFD approach, our company conducts risk assessments based on scientific methods and data. The main nature-related risks are as follows:

By the end of 2024, with expert consultancy support, we completed a Nature Risk and Opportunity Inventory study for key investment sites. This study involved detailed ecosystem and biological component analyses, prioritizing ecosystem services, habitat integrity, and species-based risks. The analysis follows TNFD recommended criteria and provides a solid foundation for more systematic corporate-level risk management. From 2025 onwards, we aim to deepen these inventory results and develop risk reduction action plans for each high-priority site. This will ensure consistent identification, monitoring, and management of nature-related risks throughout the company.

Assessment of Nature-Related Opportunities

Site-Based Practices and Biodiversity Programs

Enerjisa Üretim’s biodiversity strategy is reinforced through concrete, site-based practices, with tailored approaches developed for each type of project. For our hydroelectric, wind, solar, and thermal power plants, located across diverse geographical regions, specific ecological risks and opportunities have been identified, and comprehensive programs have been implemented accordingly. Below is a summary of the key site-based biodiversity management programs applied across our entire portfolio:

Biodiversity in Our Wind Power Plants

Our wind power plants inherently pose potential interaction risks with flying wildlife, particularly birds and bats, which is why ornithological and bat monitoring programs are standard practice at these facilities. Expert biologists conduct bird observations during breeding and migration seasons using fixed- point and transect count methods, while passive ultrasonic detectors record bat activity within the same areas. Utilizing this data, collision risk models for bird and bat species are developed for each site. If elevated risks are identified for specific species, mitigation measures such as Shutdown on Demand or operational curtailment during critical periods are implemented. These proactive steps aim to minimize collision risk by halting or reducing turbine speeds during peak wildlife activity. Additionally, in 2024 we expanded our Post-Construction Fatality Monitoring (PCFM) programs to cover not only turbine areas but also the energy transmission lines and other supporting infrastructure. During the planning phase of our wind projects, critical habitat surveys are conducted, and when endemic or endangered species are detected, project designs are adjusted accordingly. For instance, biodiversity studies at the Kestanederesi Wind Power Plant identified rare invertebrates such as Chorthippus bozdaghensis, a grasshopper unique to the region, and the Apollo butterfly (Parnassius apollo). Tailored monitoring programs have been developed for these species. This approach helps ensure our wind investments provide relatively safe habitats nationwide, striving to harmonize energy generation with wildlife conservation.

Biodiversity in Our Solar Power Plants

Given the extensive surface areas covered by our solar power plants, we place special emphasis on assessing their impact on local habitats. Flora and terrestrial fauna studies are prioritized both before and after installation at our solar sites. Each solar plant’s regional species composition, presence of endemic and sensitive species, and the effects of land-use changes on ecosystems are carefully analyzed. To prevent complete removal of vegetation and enhance existing habitats, we design panel layouts that allow native plants to grow in the spaces between arrays.

Protection of Aquatic Ecosystems in Our Hydroelectric Plants

Dedicated monitoring programs are in place to safeguard freshwater ecosystems impacted by our hydroelectric plants. Environmental flow regimes have been established at dammed hydroelectric projects to preserve aquatic life cycles. For plants without fish passages, fish ladders have been constructed, and a ‘Fish Capture and Transport System’ is utilized to facilitate migration. Other facilities with existing fish passages undergo continuous functionality monitoring. Water quality and sediment accumulation are regularly assessed, alongside seasonal fish monitoring studies. In 2024, our protocols were updated to align aquatic ecosystem monitoring with the EU Taxonomy Regulation, and biological indicators have been introduced, ranging from phytoplankton to macroinvertebrates. At Kandil, Yamanlı, and Arkun hydroelectric plants, collaborations have been established with universities and research institutions to study the long-term effects of hydrological changes and sedimentation. Our objective is to maintain ecological integrity while ensuring sustained energy generation, with the ability to implement protective measures swiftly when necessary.

Biodiversity in Our Thermal Power Plants

Within the scope of the extensive environmental modeling work initiated in 2024 for the Tufanbeyli Power Plant, air emissions, ash management, and waste impacts have been analyzed to identify potential risks to ecosystem health and air quality. Based on these analyses, additional filtration systems, improvements to ash storage areas, and environmental afforestation projects have been planned. Moreover, we aim to support species diversity through site-specific habitat restoration and micro-ecosystem enhancement efforts.

For the Bandırma Energy Base, a comprehensive marine ecology monitoring program has been conducted to assess the impacts of our deep-sea discharge activities on the Marmara Sea. As part of the extensive marine ecology study carried out in 2024, physical, chemical, and biological parameters were thoroughly analyzed in the water intake and discharge zones. The findings revealed that the artificial reef structures in these areas have supported the establishment of stable populations of species such as seabass, sand steenbras, and white grouper. Turbidity observed at the discharge points diminishes between 250 and 500 meters, indicating that ecosystem health is being maintained.

Thanks to our continuous monitoring systems, water temperature and quality are kept within habitable limits for marine life, with operational adjustments made as necessary.

Habitat Restoration and Ex-situ Conservation Projects

Across all our power plants, efforts to repair habitat damage caused during construction and operation are of critical importance. Enerjisa Üretim invests in projects focused on improving local ecosystems and protecting species in every region where it operates. At all sites where we conduct flora studies, seeds from significant and rare plant species are collected and delivered to the national gene bank in Ankara. Starting in 2025, we aim to implement on-site species conservation practices and, where necessary, species translocation (relocation to suitable habitats) in all new projects currently in the construction phase.

Arkun Wildlife Project

In collaboration with the General Directorate of Nature Conservation and National Parks, we are implementing technical measures in the Arkun Dam area to monitor biodiversity and advance wildlife conservation efforts. This ecologically important region is closely monitored for its ecosystems, plant and animal species, and biodiversity—including flora and fauna listed under national and international agreements. We continuously gather new, real-time data to build a comprehensive information database, which is analyzed and reported.

Among the key mammals in the area, we track the chamois population using satellite collars, recording their activity patterns. In 2024, we fitted female chamois, Yıldız and Sıla, with satellite transmitters and released them back into the wild. Regular signals from Yıldız and Sıla provide invaluable insights into their biological and physiological changes, habitat use, and movement routes. This information helps fill knowledge gaps and supports the development of effective biodiversity conservation policies. As the first in Türkiye to monitor chamois with satellite collars, Enerjisa Üretim proudly demonstrates its commitment to respecting wildlife and continues to pioneer innovative conservation initiatives.

To raise awareness about biodiversity and foster a wildlife culture, Enerjisa Üretim annually organizes an award- winning wildlife photography contest within the company through the Enerjisa Üretim Arts Club. In addition, we publish an online magazine titled “Yaban Hayatından İnciler”(Pearls from the Wild),which focuses on wildlife, flora, and fauna.

Nature-Based Risk and Opportunity Analysis in the Supply Chain

We do not limit our assessment of nature-related risks and opportunities to our operations alone; we evaluate them across our entire supply chain. As part of this approach, in 2024 we conducted a detailed analysis based on the TNFD’s LEAP methodology to examine our supply chain’s dependencies on nature and its impacts on the environment.

During the analysis, nine supplier companies were assessed, representing approximately 92% of our total procurement volume and carrying a high potential for nature-related risks. These suppliers were categorized by sectors with significant environmental impact, including construction, machinery and equipment manufacturing, mining, and energy equipment. Sector-specific evaluations identified key factors such as water usage, land conversion, reliance on biotic resources, and greenhouse gas emissions as critical drivers. Using the ENCORE tool, this dual analysis assessed both dependencies on nature and impacts on biodiversity.

Furthermore, by applying WWF’s Biodiversity and WRI’s Water Risk Filters, we developed risk profiles for the ecosystems, water stress, flood risk, and habitat integrity of the regions where these suppliers operate. The findings revealed that some supplier locations face moderate to high nature- related risks. This analysis served not only as an identification tool but also laid the groundwork for transparent and collaborative action planning. We shared the results with the relevant suppliers and have begun developing risk mitigation roadmaps together with each priority supplier. Through a process centered on mutual learning and continuous improvement, we strive to reduce nature-based risks and promote sustainable practices throughout our supply chain.

Social Responsibility and Community Contribution

As Enerjisa Üretim, we operate with a value creation mindset that goes beyond energy generation, placing social and environmental development at the heart of every region where we operate. Aware of our responsibility to society, we implement long-term social initiatives across numerous fields including equal access to education, local development, economic empowerment of women, access to healthcare, environmental protection, and biodiversity conservation. As of 2024, we have systematized our social contribution projects, particularly in the Tufanbeyli, Western Power Plants, and Erciyes regions, through a field-focused approach within our Corporate Social Affairs structure. These efforts, spanning from education and healthcare to regional agricultural development and sports activities, have directly benefited thousands of individuals. Designed in alignment with sustainable development principles, these projects prioritize enhancing social value and fostering growth alongside the communities where we live and operate.

Enerjisa Üretim’s social responsibility approach is fully aligned with the company’s sustainability vision, grounded in an impact-driven and holistic approach. This approach encompasses social support mechanisms that address local development, inclusive economic growth, environmental balance, and social equity together, aiming to achieve long-term transformative change. Our social support mechanisms are designed with sensitivity to local realities, focused on social impact, and developed through a stakeholder-inclusive planning approach, implemented in an integrated manner across defined thematic areas. Our activities not only respond to immediate needs but also seek to reduce risks, expand opportunities, and strengthen social resilience. Within this framework, we categorize our projects according to strategic priorities and manage them under a comprehensive impact management philosophy.

Shared Value Creation and Responsibility Projects

Our approach to social responsibility extends beyond simply meeting current needs; it is integrated into our corporate strategy as a structure that delivers long- term societal benefits. Accordingly, we manage our social investments through an integrated framework that includes impact management, grievance and demand handling, as well as project development and implementation, ensuring that these initiatives are planned and measurable. Our projects also serve as tangible and lasting tools on the ground, shaped by priority social themes.

In 2024, our budget allocated for community investment activities was planned and utilized in line with our thematic priorities. The annual distribution of resources based on these thematic areas is presented below.

In energy generation, managing the social impacts of transformation is just as much a priority as the transformation itself. In the regions where we invest in renewable energy, we diversify our social projects across themes such as climate-resilient livelihoods, water efficiency, biodiversity, and agricultural resilience. Accordingly, we approach social sustainability in conjunction with environmental sustainability and operational efficiency, aiming to align our energy generation processes with the local ecosystem. In doing so, we foster a model of local development that is not only economically sound but also climate-resilient and socially just.

With the establishment of the Corporate Social Relations Department as of 2024, we have shaped our social investments according to strategic priorities. By expanding our corporate capacity, we have systematized our processes. Within the new organizational structure we are developing and aligned with our social impact capacity, we have broadened the thematic areas that we previously focused on as social responsibility priorities, Women, Children, Trees, and Stray Animals, into Regional Development, Economic Empowerment and Employment, Gender Equality, Culture and Environment, Health and Social Welfare, and Education. Projects implemented under these themes are assessed both for the direct benefits they provide and for the systematic level of impact they achieve; these are reported in an integrated manner within the corporate performance indicators.

Based on our social responsibility and impact areas, we manage social impact through four core procedures: Social Impact and Relations Management, Social Investments, Demand and Complaint Management, and the Development and Implementation Procedure for Social Impact Projects. Within this framework, we have launched numerous community-focused projects across multiple locations through dedicated working groups within our sustainability structure.

Throughout 2024, the projects we implemented directly benefited more than 7,000 individuals. In our social investment planning, we actively use impact measurement tools such as SROI to highlight not only outputs but also outcomes and the broader social value created. This approach clearly demonstrates that our social strategy serves as a foundational pillar guiding decision-making across the organization and contributing to sustainable value creation.

Community Projects and Social Impact Analysis

In line with the policies and procedures we implement, we regularly conduct social and environmental impact assessments in our power plant operations and project areas. By placing stakeholder engagement at the center of all these processes, we ensure ongoing communication with local communities through our Power Plant Administrative and Social Affairs Teams and Community Liaison Officers. Community Liaison Officers are employed in roles specifically structured for our YEKA wind power plant projects and operate in fields unique to these projects. We systematically record and evaluate requests, feedback, and complaints from our stakeholders, and develop sustainable solutions tailored to identified needs. We design our communication processes to cover our entire value chain and regularly review field-level practices to ensure continuous improvement.

We classify each social responsibility and community investment project based on clearly defined thematic priorities and implement them by prioritizing their potential for social contribution within these categories. For example, the Yahyalı Women’s Beekeeping Program, launched to support sustainable livelihoods, is categorized under the “Gender Equality” theme, while the Greenhouse Heating Project is directly linked to the goals of “Regional Development” and “Environmental Sustainability.” Our projects are designed not only to address current needs within the thematic framework, but also to deliver long-term value by mitigating risks, enhancing opportunities, and strengthening community resilience.

We structure our social responsibility approach to be responsive to regional needs, sustainability-focused, and impact-driven. Our aim is to make tangible and lasting contributions across key social sectors such as education, health, economic development, environment, cultural preservation, and sports.

Thematic Areas	Relevant Sustainable Development Goal
Education, Children

In the education sector, initiatives, focused on upgrading school facilities, supplying technical equipment, and enhancing student engagement. As part of these efforts, renovations and repairs at Soysallı Enerjisa Primary and Middle Schools have established healthier learning environments for students. The provision of camera traps to Bayramiç Vocational School has supported hands-on training opportunities. Furthermore, various equipment upgrades and event sponsorships at Enerjisa Science High School have contributed to the students’ academic success and social growth.

Thematic Areas	Relevant Sustainable Development Goal
Healthcare and Social Welfare

In the healthcare sector, efforts to improve access to medical services and strengthen infrastructure included donations of various medical devices, support for mobile health services, and volunteer- driven blood donation campaigns. Surgical equipment provided to Göksun State Hospital enhanced treatment capabilities, while technical equipment supplied to Tufanbeyli and Saimbeyli hospitals increased the efficiency of emergency healthcare services. Transportation support for home care and dialysis patients helped facilitate access to services in rural areas.

Thematic Areas	Relevant Sustainable Development Goal
Economic Empowerment and Livelihoods

Under the themes of economic development and employment, agricultural infrastructure support has been provided to local producers, programs encouraging women’s entrepreneurship have been implemented, and initiatives aiding post-disaster recovery have been launched. The greenhouse heating project in Tufanbeyli promoted production through the use of renewable resources, while beekeeping support for women in Yahyalı contributed to rural development. Irrigation projects bolstered agricultural output, and infrastructure assistance was also extended to livestock farmers recovering from disasters.

Thematic Areas	Relevant Sustainable Development Goal
Culture and Environment

Within the scope of environmental sustainability and cultural preservation, monitoring technologies have been employed to protect wildlife, and preventative infrastructure against forest fires has been established. Drone support was provided in Adana Yamanlı to aid efforts against illegal hunting, while a fire watchtower constructed at the Çanakkale Harmancık WPP site has enhanced early response capabilities.

Thematic Areas	Relevant Sustainable Development Goal
Sports, Children

In the field of sports, camps and club support programs have been implemented to promote the physical development of children and youth, while leveraging the unifying power of sports to encourage healthy lifestyle habits. Within this framework, a basketball camps organized in partnership with Enerjisa and its stakeholders, as well as cash grants to a sports club in Yahyalı, have been successfully carried out.

Since 2019, in collaboration with our stakeholders, we have reached more than 2,200 children under the motto “Our Energy is Basketball.” Through 14 different camps held across Türkiye, from Çanakkale to Kahramanmaraş, we provided children with basic basketball training, monitored their physical development, and organized activities that foster team spirit. While combining the unifying power of basketball with social responsibility at our camps, we also raised awareness on renewable energy and sustainability. To date, our camps have reached the cities of Çanakkale, Balıkesir, Aydın, Muğla, Adana, and Kahramanmaraş, providing thousands of children with basketballs, jerseys, and fundamental basketball training support. The key projects are highlighted above; comprehensive details of each initiative can be found in the appendicies.

Social Return on Investment (SROI)

To evaluate not only the quantitative but also the qualitative and economic impacts of our community contribution investments, we have adopted the SROI analysis method. This approach allows us to calculate the economic value of the benefits our social projects provide to society. Through the SROI approach, we aim to guide our investment decisions in a data-driven and strategic manner.

In this context, we applied the SROI (Social Return on Investment) methodology in 2024 to assess the impact of our Womentum program, which was launched to support women’s career development and participation in the workforce. As a result of this analysis, it was calculated that every TL 1 investment returns to society as a social benefit worth TL 17.37. This ratio indicates that the program not only provides individual gains but also aligns closely with gender equality, economic participation, and sustainable development goals.

Within the program, women participants were supported through mentorship, workshops, and online training, achieving significant gains in areas such as confidence development, professional skills, sustainability knowledge, and gender awareness. Additionally, the program contributed to increasing women representation in sectors like engineering and energy, where women’s presence is typically low, and established a network that strengthens solidarity among women.

We will continue to integrate the SROI approach into our other social investment projects in the coming period, systematically measuring and managing social impact. Through this, we aim to make our community contributions more transparent, sustainable, and measurable.

Social Impact Analysis and Future Commitments

At Enerjisa Üretim, to contribute to sustainable development goals, we have implemented social projects in various areas such as education, regional development, gender equality, economic empowerment and livelihoods, health and social welfare, culture, and environment. In our social impact analysis conducted to measure the effects of these projects, we analyzed measurable data on the number of people affected, budget, sustainability level, and the economic, social, and environmental contributions provided. We evaluated the projects based on criteria such as alignment with SDGs, long-term impact, and replicability, clearly demonstrating their contributions to societal transformation.

In the upcoming period, we will continue to develop programs supporting women entrepreneurs, increase green energy and carbon-neutral projects, and expand initiatives focused on ensuring equal opportunities in education.

Detailed information on the projects implemented as part of Enerjisa Üretim’s social responsibility activities in renewable energy investment regions throughout 2024, within our sustainability structure and special working groups, is provided in the Appendices section.

Human Rights and Social Responsibility Principles

We place respect for human rights, ethical business practices, and social responsibility at the core of all our activities. As a signatory of the United Nations Global Compact, we maintain our commitment to full compliance with global standards in human rights, labor standards, environment, and anti-corruption. In this context, we manage our business processes fairly, inclusively, and responsibly, adopting an approach based on the principle of equality.

In line with our human rights commitment, we prioritize protecting the fundamental rights of all stakeholders in our value chain, from our employees to our business partners, integrating this approach into our policies and management systems. We systematically apply situational review processes throughout the value chain, develop a Human Rights Risk Inventory, nd regularly report current situation analyses to the Sustainability Management Committee and Ethics Board.

Our policy approach encompasses a wide range of rights-related commitments, including the promotion of freedom of expression, protection of personal data and privacy, and combating human rights violations such as child labor and forced labor. The human rights governance processes we have implemented at the corporate level are structured based on a risk-based approach and are designed to be integrated with our Risk Management, Occupational Health and Safety , Sustainability, and Social Responsibility processes. These processes are established to serve as a fundamental component of our overall management system.

In 2024, we updated our policies and procedures within the scope of gender equality and the fight against sexual violence and discrimination, enhancing human rights awareness among our stakeholders. Operating across a broad geography with varying human rights risks makes it critical that all our stakeholders uphold these rights. In 2024 we did not encounter any legal or criminal proceedings related to human rights cases.

We are fully committed to respecting human rights in our interactions with employees, suppliers, business partners, and all stakeholders. This approach is shaped by the United Nations Guiding Principles on Business and Human Rights. In line with this commitment, and while pledging full compliance with the highest ethical standards and legal frameworks, we actively uphold the following key commitments:

• To uphold freedom of expression,
• To ensure the protection of personal data and privacy,
• To safeguard the right to access information,
• To stand against discrimination and violence,
• To combat sexual and commercial exploitation of children as well as child labor,
• To implement age verification systems as a fundamental control mechanism in recruitment and supplier selection processes, and to establish effective systems to prevent child labor,
• To establish grievance and reporting mechanisms that are open, accessible, and, when necessary, allow for anonymity; to increase awareness of these mechanisms among all employees and business partners; and to ensure prompt and fair responses to reported violations, and
• To conduct regional and sector-based risk mapping to assess the risks of child labor and forced labor across all our operations and supply chain, and to increase audit frequency in priority areas.

In fulfilling all these commitments, we act in accordance with the following international standards and principles:

• ILO Declaration on Fundamental Principles and Rights at Work (1998),
• Worst Forms of Child Labor Convention (No. 182),(1999),
• UN Guiding Principles on Business and Human Rights (2011),
• UN Global Compact (2000),
• OECD Guidelines for Multinational Enterprises (2011),
• Women’s Empowerment Principles (2011)