2.2.ESRS E2. Pollution

2.2.1. Impact, risk and opportunity management
2.2.2. Metrics and targets

Viscofan recognises the importance of pollution prevention, actively measuring and managing the environmental impact of its operations. It promotes and invests to adopt strict measures with the aim of minimising emissions, effluents, pollution and waste generation. The implementation of advanced technologies ensures that pollution prevention is integrated into every step of the production process.

Current and potential impacts, risks and opportunities

Positive

Impact: investment in available technologies for the filtering and washing of emissions and the treatment and discharge of water that mitigate the risk of water pollution

Negative

Impact: air or water pollution. Generation of microplastics in the production process.
Risk: imposition of fines and penalties and implementation of corrective actions as a result of litigation arising from non-compliance in matters of pollution.

Policies and commitments

Pollution Control and Reduction Policy.
ISO 14001 certifications.

Actions and resources

Investments amounting to €9.9 million for projects related to pollution prevention. Namely, the installation of a sulphates crystalliser and a gas scrubber at the Cáseda plant in Spain, and investments for wastewater treatment at the Zacapu plant in Mexico and Pando in Uruguay.
Viscofan promotes certification under the ISO 14001 environmental management system of the Group's plants, which includes risk analysis and internal audits to ensure the measures implemented.

Sustainability objectives

Compliance with applicable pollution legislation.

Governance

Board of Directors. Appointments, Remuneration and Sustainability Committee, Audit Committee.
Executive Sustainability Committee.
CEO.
Operations and Operational Sustainability Management.
Local General Managers.

2.2.1 Impact, risk and opportunity management

Description of the processes for determining and assessing material IROs

ESRS 2 IRO-1

In Viscofan Group's materiality analysis described in section 1.1.4 of this Sustainability Report, pollution has been identified as a relevant aspect, in particular due to emissions into the atmosphere and discharges into water.

In addition, for these material aspects, the Viscofan Group's process for determining impacts, risks and opportunities (IROs), described in the ESRS 2 – General Disclosures section under IRO Management, identifies several specific IROs based on the analysis of the Group's operations, the downstream and upstream phases of the value chain. The description of each IRO includes its particular characteristics and the elements used in its examination and analysis.

Material impacts, risks and opportunities and their interaction with strategy and business model

ESRS 2 SBM-3, ESRS E2-6 (phased in)

Below are the main IROs, their classification by category and their description, as well as their interaction with Viscofan's business, strategy and financial planning in accordance with disclosure requirement SBM-3 of ESRS 2.

Viscofan's objective is to avoid or mitigate risks by actively deciding on how to respond, while also seeking to take advantage of opportunities by incorporating them into our strategy.

It should be noted that, for material impacts and risks of pollution, Viscofan has specific response plans in place to anticipate or mitigate possible future financial impacts. From this and the tolerance analysis of possible expected financial effects, no impairment was identified on the current assets and no significant investments were envisaged to comply with the commitments established in our 2022-2025 Sustainability Action Plan.

Impacts

Air or water pollution in a production plant

Casing is an industrial process that requires the physical and chemical transformation of different raw materials to form them into a seamless tube, known as the casing. Disposal of these raw materials without proper control can have polluting effects on the air or water. Depending on the process phases, this impact may occur:

On the air: this transformation requires auxiliary raw materials, the use of which can cause emissions into the air in the form of gases. In particular, from the list of pollutants listed in Annex II to Regulation (EC) No 166/2006 of the European Parliament and of the Council, Viscofan emits ammonia and carbon disulphide. Although all plants with these types of emissions comply with the limits set by local authorities, these emissions at very high levels could have an impact on local air quality.
On the water: during the production process and especially after extrusion, Viscofan carries out cleaning phases set forth in the food safety system, a process that is carried out with water. From the list of pollutants listed in Annex II to Regulation (EC) No 166/2006 of the European Parliament and of the Council, organic carbon in the form of cellulose or collagen fibres is released from the casings during cleaning, which by themselves and in non-relevant quantities are not harmful to the environment. However, in high quantities, they can reduce the level of oxygen in the water and affect marine ecosystems.

Microplastic Leak

Viscofan's products include plastic casings, films and bags for which microplastics are used, i.e. smaller than 5 millimetres. This raw material is used in the Group's facilities where these final products are manufactured. They are Hasselt in Belgium, Cáseda in Spain, Itu in Brazil and San Luis Potosí in Mexico. Without adequate control, these microplastics used in the process could cause the leakage of waste into water surfaces.

Both negative impacts are not predefined by their time horizon, beyond the need to carry out adequate maintenance of the assets, to implement the production safety protocols and to incorporate of the best available technologies to avoid significant leaks or spills. The more Viscofan works to minimise the impact of the production process on the environment, the lower the future probability of occurrence. This is the basis of Viscofan's Pollution Control and Reduction Policy and the environmental management strategy and system implemented and described below. There were no spills or leaks at Viscofan Group facilities in 2024 that had to be reported to the competent authorities, understood as those that cause damage to the external environment of the facility

Investment in available technologies for the filtering and scrubbing of emissions and the treatment and discharge of water

By investing in advanced technologies for filtering and scrubbing emissions, as well as for water treatment and discharge, Viscofan seeks to improve air and water quality near production plants.

Collaboration with specialised equipment suppliers is a key pillar in this initiative. Working closely with these suppliers not only ensures the acquisition of cutting-edge technologies, but also encourages the continuous development of innovations.

With regard to air emissions, Viscofan's investments in filtering and scrubbing enable, in some cases, the reduction of pollutant emissions. For its part, the adoption of state-of-the-art technologies in water treatment allows Viscofan to effectively manage effluents and minimise environmental impact. These technologies include systems capable of efficiently removing pollutants and toxic substances.

This is an impact that Viscofan continuously promotes to the best of its ability. The subsection on actions and resources related to pollution of this ESRS details investments with a positive impact. However, it could possibly materialise with greater frequency and positive impact in the medium and long term as better technologies are developed. That is why continuous collaboration with suppliers of this type of equipment is key.

This is the basis of Viscofan's Pollution Control and Reduction Policy and the environmental management strategy and system implemented and described below in the section "Environmental management system oriented towards pollution prevention".

Risks

Fines and penalties and implementation of corrective actions as a result of litigation arising from non-compliance in matters of pollution.

As a result of this productive activity, there is the possibility of fines and penalties being imposed because of litigation for non-compliance with pollution regulations. The effect could be a monetary penalty, which is difficult to quantify because it would depend on the type of incident and the competent authority at the affected location. Additionally, corrective measures could be imposed, requiring additional investment.

In 2024, there have been no significant fines or penalties arising from litigation for non-compliance in matters of pollution. See Note 13.3 of the Viscofan Group's Consolidated Financial Statement on Contingent Liabilities.

This is a risk that can occur at any time horizon, and the possibility depends on governments establishing different legislation, requirements, and pollution standards. For this reason, Viscofan works with the commitment to updating and complying with environmental regulations in the countries in which it is present and with the aim of continuous improvement in the prevention and reduction of pollutants, while minimising a risk of these characteristics and a possible impact on Viscofan's financial situation. This is the basis of Viscofan's Pollution Control and Reduction Policy and the environmental management strategy and system implemented and described below in the section "Environmental management system oriented towards pollution prevention".

Viscofan's actions to mitigate this risk and the main investments financed by the business's cash generation have been detailed in the subsection on actions and resources related to pollution.

Environmental management system oriented towards pollution prevention

Viscofan has a strategy and a business model specially designed to address material impacts and risks in terms of pollution, which includes elements to be able to face and overcome the challenges related to pollution.

Firstly, pollution prevention is integrated and managed locally in production plants that have an environmental management system (in most cases, ISO 14001 certified), which makes it easier to minimise and control the environmental impact of the production process.

At the same time, the corporate Operational Sustainability team and local managers play a crucial role in ensuring that all production plants operate in accordance with established environmental standards, not only in compliance with local and national laws, but also based on an internal standards framework that places a strong emphasis on pollution prevention.

Overall, pollution prevention is a dynamic process that has the following components:

Risk assessment and analysis: the production plants have an assessment to identify possible sources of air, water and soil pollution. This includes analysis of production processes, raw material handling and waste management. Risk analysis tools are used to determine the critical points that could generate polluting emissions.
Implementation of continuous monitoring: the plants promote the installation of monitoring systems in areas identified as high risk. These systems collect data on air quality and emissions, as well as water data at sites with water treatment plants. The information collected is used to detect patterns and possible incidents of contamination at an early stage.
In addition, within this component, operational procedures are reviewed and updated to comply with environmental regulations.
Investments in equipment: Viscofan promotes investment in the plants by seeking as far as possible the best available technologies to prevent pollution.
This includes, for example, the installation of filtering systems to efficiently capture and remove particles and compounds from emissions from production processes. These systems seek to ensure that the air quality in our facilities and in nearby communities is maintained at optimal levels. Likewise, the plants have gas scrubbing technologies for the elimination of gaseous pollutants through absorption and chemical reaction processes, significantly reducing the emissions of substances into the environment.
With regard to water, Viscofan works with the aim of further improving the quality of discharge into freshwater, endeavouring to achieve the correct purification of its wastewater and the minimisation of the environmental impact of its activities. As a result, Viscofan has water treatment plants at its manufacturing facilities, where the treatment of water makes it possible to improve the quality of discharges. Factories that treat 100% of the water are: Cáseda (Spain), Zacapu (Mexico), Koteks (Serbia), Itu (Brazil), Pando (Uruguay) and Suzhou (China).
Development of response and mitigation protocols: rapid response protocols are developed and formalised to mitigate any pollution incidents that may occur. These protocols include emergency procedures, communication with local authorities and corrective measures to minimise environmental and public health impact.
Audits: internal and external audits are carried out to assess the effectiveness of the measures implemented. Viscofan works with the aim of certifying all plants under the ISO 14001, which, among other environmental aspects, emphasises the minimisation and prevention of pollution events.
Also, the corporate Operational Sustainability team carries out exhaustive audits to assess and verify compliance with environmental regulations in each facility, and with ISO standards.
During audits, the team examines all aspects of the plant's operations, including waste management, air emissions, water discharges and resource use. They also identify areas for improvement and suggest more sustainable and efficient practices. A crucial part of their work is the assessment of environmental management systems, ensuring that plants have adequate procedures in place to minimise environmental impact.

On this basis, Viscofan considers that it has a strategy in place to address material impacts and risks with the aim of preventing a pollution event, seeking, as far as possible, the promotion of a management system and investments in the best available technologies that go beyond regulatory compliance. This qualitative analysis is based on the premise that it strives to improve the current status, both in the medium and long term. No quantitative resilience analysis has been performed.

Pollution-related policies

ESRS E2-1, ESRS 2 MDR-P

Pollution Control and Reduction Policy

Key content and principles

Within the framework of the General Sustainability Policy and in line with the Sustainable Development Goals (SDGs), Viscofan has a Pollution Control and Reduction Policy approved by the Board of Directors.

This policy is the framework for the establishment of an environmental management system in the Viscofan Group, under the principles of precaution, prevention and continuous improvement for air, water and soil pollution, a material issue according to the double materiality analysis. These are its basic principles of action:

Recurrent assessment of the impacts and risks of air, water and soil pollution including analysis of production processes, raw material handling and waste management.
Implementation and continuous monitoring of identified high-risk areas to detect patterns and possible incidents of contamination at an early stage.
Promotion of investments in equipment with the best available technologies in the prevention of pollution.
The development of rapid response protocols to mitigate any pollution incidents that may occur, with emergency procedures, communication with local authorities and corrective measures to minimise environmental and public health impact.
Internal and external audits to assess the effectiveness of the measures implemented under ISO standards.
The implementation of a structure of operational sustainability experts with skills in pollution prevention.
Minimisation of substances of concern.

The Policy's basic principles and commitments will be developed and implemented based on the management of risks and impacts, establishing objectives, programmes and plans that promote the continuous improvement of processes and practices within the Group for pollution prevention, and particularly through:

The supervision of compliance with and respect for the applicable regulations, as well as other obligations voluntarily assumed, including the implementation of certified environmental management systems and the performance of internal and external audits under ISO standards that, among other aspects, emphasise the minimisation and prevention of pollution events and promote their implementation in suppliers.
The establishment and periodic review of objectives and plans for the reduction of polluting gases in the air, undertaking the necessary investments for the implementation of advanced filtering and emission scrubbing technologies, in order to improve air quality in accordance with applicable regulations.
The establishment and periodic review of objectives of plans to reduce the consumption of water resources, and investment in the most advanced technologies that guarantee the purification of water used before its return to nature.
Drafting of action plans to improve waste control and management, including circular economy projects for its disposal.
Development of training programmes for professionals in the Group's companies that include pollution prevention skills.
Promotion of Research and Development and Innovation and, to this end, establish partnerships with suppliers of specialised equipment to ensure the availability of advanced technologies for pollution prevention.
Development of response and mitigation protocols for all production centres that include emergency procedures, communication with local authorities and corrective measures to minimise environmental and public health impact.

Esta política se encuentra disponible en la página web de Viscofan, en el apartado de Gobierno Corporativo – Reglamentos y Políticas.

Scope of the Policy

This Policy applies to the entire Viscofan Group and binds all its staff, regardless of the position and function they perform. It does not provide for exclusions in terms of activities or geographical areas.

It also sets forth that the Company will promote the application of the principles and bases of the Policy to any natural and/or legal person linked to the Group companies, when this is possible and advisable, in such a way that they follow principles and guidelines consistent with the Policy and the other sustainability policies.

Monitoring and supervision:

Monitoring of the Policy is the responsibility of the Board of Directors, which will exercise it through the oversight of the Appointments, Remuneration and Sustainability Committee regarding the development and implementation of sustainability policies and strategies, and of the Audit Committee in terms of the integrity of the non-financial information included in the management report, as well as in the supervision of non-financial risks arising from the Group's actions in relation to the Policy.

Additionally, the Group has an Executive Sustainability Committee whose tasks include promoting sustainability plans and programmes in the implementation of policies. and an Ethics and Compliance Committee reporting to the Audit Committee which, in addition to ensuring compliance with the Code of Conduct, manages the channel for reporting any offences by employees and other people related to the company.

Pollution-related actions and resources

ESRS E2-2, ESRS 2 MDR-A

The focus of Viscofan's actions for pollution prevention and minimisation is based on two aspects:

Environmental Management System. ISO 14001:

We are working to attain this environmental management certification at all our production plants. The breakdown of the Group's plants with the ISO 14,001 certificate at 31 December 2024 is as follows:

Country	Plant	ISO 14.001
Spain	Cáseda	Yes
Spain	Urdiain	Yes
Germany	Weinheim	Yes
Germany	Alfhausen	No
Serbia	Novi Sad	Yes
Czech Republic	Ceske Budejovice	Yes
Belgium	Hasselt	Yes
US	Danville	No
	Montgomery	Yes
	New Jersey	Yes
Mexico	Zacapu	Yes
Mexico	San Luis Potosí	Yes
Brazil	Itu	Yes
Brazil	Matarazzo	Yes
Uruguay	Pando	Yes
China	Suzhou (2 plantas)	Yes
Australia	Sidney	Yes

Investments in equipment

CapEx allocated in the year to projects to protect water and air quality amounts to €9.9 million. The investments have been identified in the list of additions to property, plant and equipment and intangible assets of the Viscofan Group (see notes 5 and 6 to the consolidated financial statements).

Viscofan's commitment to protecting the environment and preventing air pollution is reflected in its investment in advanced technologies that allow us to reduce polluting gas emissions, namely the installation of a sulphates crystalliser and a gas scrubber at the Cáseda plant in Spain, and an emissions control system at the Zacapu plant in Mexico.

At the same time, Viscofan is working to promote investment in improving water purification and treatment capacity. In this regard, in 2024, we made investments to improve the water treatment and sanitation systems at the Zacapu plant in Mexico, Pando in Uruguay and Urdiain in Spain. In addition, Viscofan has treatment plants in factories that treat 100% of the water discharged.

These investments have been financed with the cash generation from the business, although Viscofan has financing with sustainable criteria that, although not particularly assigned to the aforementioned projects, contributes to the sustainable performance of Viscofan, framed in the Sustainability Action Plan. See note 15 of the consolidated financial statements.planta de Zacapu en México.

2.2.2 Metrics and targets

Pollution-related targets

ESRS E2-3, ESRS 2 MDR-T

Within the framework of the sustainability action plan, Viscofan has not established Group-wide specific pollution reduction targets aside from compliance with the limits established by the competent authorities.

The effectiveness of the actions and the environmental management system for the prevention of pollution described in this ESRS with respect to material IROs is monitored locally, with indicators based on the limits of emissions to air and water included in the environmental permits issued for all operations by the competent authorities. In addition, work is being done in view of improving the levels established by the applicable regulations as far as possible, although without establishing specific quantifiable targets within the framework of the Sustainability Action Plan.

This strategy has allowed us to respond to the specific needs of each location and ensure compliance with local environmental regulations, which identify priority substances and provide a guide to reduce emissions with which Viscofan works at a local level.

The Pollution Control and Reduction Policy, approved in December 2024, sets forth that, for the development and implementation of its basic principles and commitments, it will seek to establish objectives and plans for the reduction of polluting gases in the air.

On this basis and in accordance with the reporting regulations of this sustainability report, the relevant emission levels have been consolidated, creating a broader and more detailed view of our environmental impact across all our operations. It is expected that this information will serve as the basis for a thorough analysis in the coming years to identify patterns and key areas for improvement, and that it can serve as a solid basis for studying the feasibility of implementing a coherent global strategy that maximises our capacities and resources and can be articulated in the setting of targets as catalysts for improvement.

Air, water and soil pollution and substances

ESRS E2-4, ESRS E2-5

Pollutants

Below are the pollutants, in consolidated quantities of installations exceeding the thresholds detailed in Annex II to Regulation (EC) No 166/2006 of the European Parliament and of the Council (European Pollutant Release and Transfer Register, "European PRTR Regulation"), emitted into air, water and soil, with the exception of GHG emissions that have been reported in accordance with ESRS E1. Climate change.

267 tonnes of ammonia (NH3) emitted into the atmosphere as a result of casing production.
361 tonnes of nitrogen oxides (NOx/NO2) emitted into the atmosphere that are generated in the combustion of natural gas in boilers to obtain steam.
96 tonnes of total organic carbon (TOC) (as total C or COD/3) into the water, mainly cellulose or collagen fibres, which on their own and in non-relevant quantities, are not harmful to the environment, but in high quantities can reduce the level of water oxygen and could affect marine ecosystems.

Viscofan has not used a direct measurement method for the quantification of polluting substances due to the complexity and variability of industrial processes. As a result, it is difficult to make precise direct measurements at all times in a continuous process such as the casings'.

Importantly, as they rely on estimates, there is an inherent degree of uncertainty in the calculations. This uncertainty can arise from multiple sources, such as variability in operating conditions, model accuracy and the precision of historical data.

In the case of ammonia (NH3), it has been estimated based on consumption data of this raw material and with measurements of concentrations carried out by the R&D department in specific locations. A variability of +/-5 percentage points in the emission factor can lead to an increase or decrease of 16 tonnes in the quantity.

For nitrogen oxides (NOx/NO2) emitted, it is estimated based on a periodic annual measurement for the State Register of Emissions and Pollutant Sources and an official factor from the public entity in Navarre. This factor has been applied to the consumption of natural gas from boilers. A variation of +/- 5% in this factor can mean an increase or decrease of 19 tonnes in the quantity.

The total organic carbon discharged into the water is estimated through the average concentration from the weekly measurements made by an accredited external laboratory, applied to the average daily flow of the period. A variation of +/-5% in this factor can mean an increase or decrease of 5 tonnes in the quantity.

Microplastics:

In 2024, the Viscofan Group has used 6,287 tonnes of microplastics in the manufacturing process of casings, films and plastic bags that mostly leave the facilities as products. This information has been obtained from consumption data in the SAP raw materials management computer system implemented in the Group's locations that have this type of production process.

Other substances

In accordance with Regulation (EC) No 1272/2008 of the European Parliament and of the Council, the Group has used substances of concern which, if mismanaged, could pose a chronic danger to organs and the marine environment through prolonged exposure in significant quantities.

In the production process of cellulose and fibrous casings, Viscofan has used 8,429 tonnes of sulphur gaseous compounds and has emitted 6,457 tonnes thereof. The washing process prevents this compound from being incorporated into the final product, while air emissions are minimised by the installation of gas scrubbers.
In the water purification and treatment facilities, Viscofan has used 2,918 tonnes of sodium hypochlorite in order to oxidise the organic matter before it is discharged into the water. However, in these facilities. this substance is transformed into other compounds not considered to be of concern such as chlorides, which have not been discharged into the water.
Viscofan uses ammonia (NH3) in the production process of casings (936 tonnes) which is then scrubbed and, in reduced concentrations, is emitted into the atmosphere (267 tonnes).

Viscofan has carried out an analysis on all implementations and no substances of very high concern have been identified as produced, used or placed on the market based on the criteria set out in Article 57 of Regulation (EU) No 1907/2006 (REACH) and have been identified in accordance with Article 59(1) of that Regulation.

Expected financial effects of pollution-related risks and opportunities

ESRS E2-6. Phased-in disclosure requirement

Viscofan does not report this information in this sustainability report because it is a phased-in disclosure requirement and therefore exempt from reporting in the first year of the sustainability report as per Appendix C of ESRS 1.