The Navigator Company, S.A.

2024 ANNUAL REPORT • MANAGEMENT REPORT 2

003

MANAGEMENT REPORT

350

CONSOLIDATED FINANCIAL

STATEMENTS

495

SEPARATE FINANCIAL

STATEMENTS

574

CORPORATE GOVERNANCE

Content

ANNUAL REPORT 2024 • MANAGEMENT REPORT 4

Management report

1. Overview 9

1.1. Message from the Chairman 9

1.2. Message from the Chief Executive Officer 11

1.3. 2024 in numbers 14

1.4. Awards 19

1.5. Paternships for impact 20

2. Our identity 23

2.1. Purpose and values 23

2.2. Company Profile 24

2.3. Creating sustainable value 30

3. Strategy and Governance 38

3.1. Business Strategy 38

3.2. Governance model 40

3.3. Risk management 45

3.4. 2030 Agenda and Roadmap 51

3.4.1. Global trends and challenges for Navigator 51

3.4.2. Our Agenda 53

3.4.3. Contribution to SDGs 75

3.4.4. 2030 Roadmap 80

3.4.5. Stakeholder engagement 101

4. Performance in businesses 105

4.1 Bleached eucalyptus pulp (BEKP) 105

4.2 Paper 107

4.3 Packaging 108

4.4 Tissue 109

4.5 Energy 111

4.6 Financial performance 111

4.7 Sustainable financial management 112

4.8 Share performance 113

4.9 Contribution to State tax revenues 115

4.10 The Navigator Group's tax policy 119

5. Non-Financial Statement 120

5.1. General disclosures – ESRS 2 121

5.1.1. Basis of preparation 121

5.1.1.1. General basis of preparation of the Non-Financial Statement (BP-1) 121

5.1.1.2. Disclosures in relation to specific circumstances (BP-2) 122

5.1.2. Governance 123

5.1.2.1. The role of the administrative, management and supervisory bodies (GOV-1) 123

5.1.2.2. Information provided on sustainability matters addressed by the undertaking’s

administrative, management and supervisory bodies (GOV-2) 127

5.1.2.3. Integration of sustainability-related performance in incentive schemes (GOV-3) 128

5.1.2.4. Risk management and internal controls over sustainability reporting (GOV-5) 128

5.1.3. Strategy 130

5.1.3.1. Strategy, business model and value chain (SBM-1) 130

5.1.3.2. Interests and views of Stakeholders (SBM-2) 131

5.1.3.3. Material impacts, risks and opportunities and their interaction with strategy and business

model (SBM-3) 132

5.1.4. Impact, risk and opportunity management 134

5.1.4.1. Description of the process to identify and assess material impacts, risks and opportunities

(IRO-1) 134

5.1.4.2. Disclosure requirements in ESRS covered by the Non-Financial Statement (IRO-2) 139

5.2 Environmental information 140

5.2.1. European Taxonomy 140

5.2.1.1. Background to the European Environmental Taxonomy 140

5.2.1.2. Eligibility analysis 140

5.2.1.3. Alignment analysis 141

5.2.1.4. Disclosure of KPIs 145

5.2.1.4.1. Proportion of turnover from products or services associated with taxonomy-aligned

economic activities 147

5.2.1.4.2. Proportion of CapEx on products or services associated with taxonomy-aligned economic

activities 148

5.2.1.4.3. Proportion of OpEx on products or services associated with taxonomy-aligned economic

activities 150

5.2.1.4.4. Templates personalised in accordance with Regulation 2022/1214 152

5.2.1.5. Next steps in applying the taxonomy 165

5.2.2. ESRS E1: Climate change 166

5.2.2.1. Strategy 166

5.2.2.1.1. Material impacts, risks and opportunities and their interaction with strategy and business

model (SBM-3) 166

5.2.2.1.2. Transition plan for mitigating climate change (E1-1) 171

5.2.2.2. Management of impacts, risks and opportunities 174

5.2.2.2.1. Policies related to climate change mitigation and adaptation (E1-2, MDR-P) 174

5.2.2.2.2. Actions and resources in relation to climate change policies (E1-3, MDR-A) 176

5.2.2.3. Targets and metrics 177

5.2.2.3.1. Targets related to climate change mitigation and adaptation (E1-4, MDR-T, MDR-M) 177

5.2.2.3.2. Energy consumption and mix (E1-5) 179

5.2.2.3.3. Gross Scopes 1, 2, 3 and total GHG emissions (E1-6) 180

5.2.2.3.4. Anticipated financial effects from material physical and transition risks and potential

climate-related opportunities (E1-9) 182

5.2.3. ESRS E3: Water and marine resources 183

5.2.3.1. Strategy 183

5.2.3.1.1. Material impacts, risks and opportunities and their interaction with strategy and business

model (SBM-3) 183

5.2.3.2. Management of impacts, risks and opportunities 183

5.2.3.2.1. Policies related to water and marine resources (E3-1, MDR-P) 183

5.2.3.2.2. Actions and resources related to water and marine resources (E3-2, MDR-A) 184

5.2.3.3. Targets and metrics 186

5.2.3.3.1. Targets related to water and marine resources (E3-3, MDR-T) 186

5.2.3.3.2. Total water consumption (E3-4) 188

5.2.3.3.3. Anticipated financial effects from water and marine resources-related impacts, risks and

opportunities (E3-5) 188

5.2.4. ESRS E4: Biodiversity and ecosystems 189

5.2.4.1. Strategy 189

5.2.4.1.1. Material impacts, risks and opportunities and their interaction with strategy and business

model (ESRS 2 SBM-3) 189

5.2.4.1.2. Transition plan for biodiversity and ecosystem conservation (E4-1) 191

5.2.4.2. Management of impacts, risks and opportunities 191

5.2.4.2.1. Policies related to biodiversity and ecosystem conservation (E4-2, MDR-P) 191

5.2.4.2.2. Actions and resources related to biodiversity and ecosystems (E4-3, MDR-A) 193

5.2.4.3. Targets and metrics 197

5.2.4.3.1. Targets related to biodiversity and ecosystem conservation (E4-4, MDR-T) 197

5.2.4.3.2. Impact metrics related to biodiversity and ecosystem conservation (E4-5, MDR-M) 200

5.2.4.3.3. Anticipated financial effects from important biodiversity and ecosystems-related risks and

opportunities (E4-6) 201

5.2.5. ESRS E5: Use of resources and circular economy 201

5.2.5.1. Strategy 201

5.2.5.1.1. Material impacts, risks and opportunities and their interaction with strategy and business

model (SBM-3) 201

5.2.5.2. Management of impacts, risks and opportunities 202

5.2.5.2.1. Policies related to resource use and circular economy (E5-1, MDR-P) 202

5.2.5.2.2. Actions and resources related to resource use and circular economy (E5-2, MDR-A) 204

5.2.5.3. Targets and metrics 206

5.2.5.3.1. Targets related to resource use and circular economy (E5-3, MDR-T, MDR-M) 206

5.2.5.3.2. Resource inflows (E5-4) 207

5.2.5.3.3. Resource outflows (E5-5) 209

5.2.5.3.4. Anticipated financial effects from important risks and opportunities related to resource

use and the circular economy (E5-6) 210

5.2.6. Entity-specific disclosures - Sustainable Forest Management 211

5.2.6.1. Strategy 211

5.2.6.1.1. Material impacts, risks and opportunities and their interaction with strategy and business

model (SBM-3) 211

5.2.6.2. Management of impacts, risks and opportunities 212

5.2.6.2.1. Policies related to Sustainable Forest Management (MDR-P) 212

5.2.6.2.2. Actions and resources related to Sustainable Forest Management (MDR-A) 214

5.2.6.3. Targets and metrics 217

5.2.6.3.1. Metrics related to Sustainable Forest Management (MDR-T) 217

5.2.6.3.2. Impact metrics related to Sustainable Forest Management (MDR-M) 224

5.3. Social Information 226

5.3.1. ESRS S1 – Own workforce 226

5.3.1.1. Strategy 226

5.3.1.1.1. Material impacts, risks and opportunities and their interaction with the strategy and

business model (ESRS 2 SBM-3) 226

5.3.1.2. Impacts, risks and opportunities management 229

5.3.1.2.1. Policies related to own workforce (S1-1, MDR-P) 229

5.3.1.2.2. Processes for engaging both workers and workers' representatives about impacts (S1-2)

233

5.3.1.2.3. Processes to remediate negative impacts and channels for own workforce to raise

concerns (S1-3) 234

5.3.1.2.4. Taking action on material impacts on own workforce, and approaches to managing

material risks and pursuing material opportunities related to own workforce, and

effectiveness of those actions (S1-4, MDR-A) 235

5.3.1.3. Targets and Metrics 242

5.3.1.3.1. Targets related to managing material negative impacts, advancing positive impacts, and

managing material risks and opportunities (S1-5, MDR-T) 242

5.3.1.3.2. Characteristics of the undertaking’s employees (S1-6) 249

5.3.1.3.3. Characteristics of non-employees in the undertaking’s own workforce (S1-7) 252

5.3.1.3.4. Collective bargaining coverage and social dialogue (S1-8) 253

5.3.1.3.5. Diversity indicators (S1-9) 255

5.3.1.3.6. Adequate wage (S1-10) 255

5.3.1.3.7. Training and skills development indicators (S1-13) 255

5.3.1.3.8. Health and safety indicators (S1-14) 256

5.3.1.3.9. Work-life balance metrics (S1-15) 259

5.3.1.3.10. Remuneration metrics (pay gap and total remuneration) (S1-16) 259

5.3.1.3.11. Incidents, complaints and severe human rights impacts (S1-17) 260

5.3.1.3.12. Entity specific metrics – MDR-M 260

5.3.2. ESRS S2 – Workers in the value chain 263

5.3.2.1. Strategy 263

5.3.2.1.1. Material impacts, risks and opportunities and their interaction with the strategy and the

business model (ESRS 2 SBM-3) 263

5.3.2.2. Impacts, risks and opportunities management 265

5.3.2.2.1. Policies related to value chain workers (S2-1) 265

5.3.2.2.2. Processes for engaging with value chain workers about impacts (S2-1) 266

5.3.2.2.3. Processes to remediate negative impacts and channels for value chain workers to express

concerns (S2-3) 266

5.3.2.2.4. Taking action on material impacts on value chain workers, and approaches to managing

material risks and pursuing material opportunities related to value chain workers, and

effectiveness of those actions (S2-4) 267

5.3.2.3. Targets and Metrics 269

5.3.2.3.1. Targets related to managing material negative impacts, advancing positive impacts, and

managing material risks and opportunities (S2-5, MDR-T) 269

5.3.2.3.2 Entity-specific metrics- MDR-M 271

5.3.3. ESRS S3: Affected communities 272

5.3.3.1. Strategy 272

5.3.3.1.1. Material impacts, risks and opportunities and their interaction with the strategy and

business model (ESRS 2 SBM-3) 272

5.3.3.2. Impacts, risks and opportunities management 274

5.3.3.2.1. Policies related to Affected Communities (S3-1, MDR-P) 274

5.3.3.2.2. Processes for engaging with affected communities about impacts (S3-2) 277

5.3.3.2.3. Processes to remediate negative impacts and channels for affected communities to raise

concerns (S3-3) 279

5.3.3.2.4. Taking action on material impacts on affected communities, and approaches to managing

material risks and pursuing material opportunities related to affected communities, and

effectiveness of those actions (S3-4) 280

5.3.3.3. Targets and Metrics 283

5.3.3.3.1. Targets related to managing material negative impacts, advancing positive impacts, and

managing material risks and opportunities (S3-5, MDR-T) 283

5.3.3.3.2 Entity-specific metrics- MDR-M 284

5.4. Governance Information 286

5.4.1. ESRS G1: Bussiness Conduct 286

5.4.1.1. Strategy 286

5.4.1.1.1. Material impacts, risks and opportunities and their interaction with the strategy and

business model (ESRS 2 SBM-3) 286

5.4.1.2. Impacts, risks and opportunities management 287

5.4.1.2.1. Business conduct policies and corporate culture (G1-1, MDR-P) 287

5.4.1.2.2. Management of the relationship with Suppliers (G1-2, MDR-P) 292

5.4.1.2.3. Procedures to address corruption and bribery (G1-3, MDR-P) 294

5.4.1.2.4. Actions and resources related to material sustainability themes (MDR-A) 295

5.4.1.3. Targets and Metrics 296

5.4.1.3.1. Monitoring the effectiveness of policies and actions through targets (MDR-T) 296

5.4.1.3.2. Incidents of corruption or bribery (G1-4) 299

5.4.1.3.3. Expenditure with local Suppliers (Entity-Specific Disclosure, MDR-M) 299

6. Proposed allocation of profits 300

7. Declaration required under Article 29-G,1 c) of Securities

Code 301

8. Our performance 303

8.1 Economic indicators 303

8.2 Environmental indicators 304

8.3 Social indicators 307

9. Annexes 309

9.1 Correspondence Tables [ESRS, Non-Financial Information, WEF] 309

9.1.1. ESRS 309

9.1.2. DNFI Table (Disclosure of Non-Financial Information) 324

9.1.3. Table summarising World Economic Forum’s Stakeholder Capitalism core metrics 330

9.2 GRI Table 332

9.3 Progress Report on Meeting Act4nature Portugal Commitments 338

9.4 Independent Auditor’s Limited Assurance Report on Sustainability Statement 343

ANNUAL REPORT 2024 • MANAGEMENT REPORT 9

1. Overview

1.1. Message from the Chairman

Companies prove their value and their potential when they succeed in being agents of change, and that change is recognised

as necessary, generating value and contributing to a positive impact for society as a whole.

Just such change has been the guiding principle adopted by The Navigator Company, an organisation whose financial and non-

financial performance reflects not only the goals set out for each financial year, but above all an ongoing commitment to

creating long-term sustainable value, aligned with the purpose of the Semapa Group - Making it Better, which means creating

a positive impact on people, the community, the environment and, consequently, on our shared future.

This is a future which, at The Navigator Company, we are building on the basis of active management of eucalyptus forests,

and anchored in our sound industrial and financial structure, in innovation, in the launch of new products, and in the knowledge

that we generate and share, as well as in the sustainable practices that we live by.

It is also a future that inspires us with enthusiasm, because it is built on the talent of the people who work in this company.

Their capacity to respond to the challenges we face gives us increased confidence to press ahead with the capital projects

needed for our transformative agenda, with innovative operations and products, rooted in a model geared to circular

development, neutral in fossil carbon.

The investment drive we have pursued at The Navigator Company points to what we want for the future, centred on scientific

research in the field of forestry, but also on continued international expansion, with our move into the UK market through the

acquisition of Accrol, as well as sustainable investment in our operations.

This research-centred strategy has consistently borne fruit, notably in the essential work of all the researchers at RAIZ, our

forest and paper research institute and one of the top centres of its kind, offering an example of the ever closer links between

industry and a range of academic institutions.

It is this expertise that has enabled us to follow a path where innovation is more the rule and less the exception, across all the

company’s activities, from forest, through to industrial operations and the products that leave our mills in Portugal, Spain and

the United Kingdom and are distributed to more than 130 countries around the world.

We should recall that, in the mid-twentieth century, The Navigator Company was a pioneer and the first company in the world

to produce cellulose pulp from Eucalyptus globulus using the kraft process, and then printing and writing paper entirely made

from the fibre of this species. As a consequence, seven decades on, Portugal is the top European manufacturer of this type of

pulp and of UWF paper. And, above all, a benchmark for quality around the world.

In another transformative venture, The Navigator Company started up production of moulded cellulose packaging in late 2024.

This is the first time anywhere in the world that these products have been made from eucalyptus fibre, and the articles

produced are aimed at the food retail, hotel, restaurant and catering sectors, replacing the fossil-based materials currently

used. A pioneering move that we hope will bear fruit in the future.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 10

The knowledge we achieve from the research we promote is too important to be kept confined in the companies and

institutions where it is generated. That is why we also invest in schemes that ensure that this expertise reaches everyone

involved in the eucalyptus forest value chain.

Because this expertise relates not just to production, but also to all the dynamics in the forest ecosystems that benefit us all, it

needs to be shared widely with many sectors of society, showing how the sustainable practices and active management we

implement in eucalyptus forests are a way of creating wealth for Portugal and protecting the benefits of woodlands in general,

including protection of conservation forests.

Just as important as the pace at which we are able to innovate, learn and share our knowledge, is what this all means and

where it will take us.

With around 109 thousand hectares of certified planted forests in Portugal, spread over more than half the country’s municipal

districts, The Navigator Company is the Portuguese exporter that contributes most to domestic value added, while also

generating direct, indirect and induced employment for some 30 thousand people, and providing business for approximately 8

thousand suppliers, 70% of which are Portuguese. All this adds up to a positive impact on a vast number of people and reflects

our ongoing commitment to generating environmental, social and economic wealth.

The company’s sustainable practices are significant precisely because they are aligned with the future we want for every

society and for the planet, which is calling for urgent, robust and effective responses to its current challenges.

These responses make the forest sector a key player in the modern circular bioeconomy, a model which offers a transition from

a linear economy based on fossil resources, which generates waste, to a circular economy, based on renewable resources,

minimizing effects on the climate, and making full use of by-products and waste by converting them into bioproducts that avoid

the need for fossil-based products.

This is a road familiar to us, which we shall continue to follow and which, at The Navigator Company, we are committed to

sharing with everyone in a broad coalition that includes our employees, suppliers, customers, our business, technical and

scientific partners, the different communities in which we operate, and our investors.

To all of these, I am grateful for their dedication, commitment and support in our endeavours, in setting the course for the

future, and in securing the sustainable future growth of The Navigator Company.

Ricardo Pires

Chairman of the Board of Directors

ANNUAL REPORT 2024 • MANAGEMENT REPORT 11

1.2. Message from the Chief Executive Officer

In a year when our strategic vision and in-house talent were put to the test, The Navigator Company once again displayed one

of its most distinctive features as a bioindustry: its ability, time and again, to rediscover its potential - and then to fulfil it.

We have grown through diversification, we have expanded our international presence and built up our portfolio, as the same

time as well have invested in new uses for cellulose pulp, moving beyond the traditional applications in the pulp and paper

sector.

On this transformative journey, on which we are defined not just by what we produce, but also by the impact we create, we

have embraced our role in the circular economy and speeded up our contribution to decarbonisation.

The success we have achieved from this strategy approach reflects our sound business model, anchored in efficient

management of the business mix, a sales strategy focused on customers, strict cost control and ongoing efforts in innovation

and sustainability, two foundational values that have shaped our identity for more than seven decades.

Milestones in growth

The tissue and sustainable packaging segments, where we launched our diversification drive, clearly bear witness to our

capacity to deliver. These segments already account for a very significant proportion - 26% - of the company’s total sales.

The scaling up of our tissue operations, our innovative portfolio and production capabilities have been the three key features of

our move into the sector. We then took things to a new level in 2024 with the acquisition, in May, of what is now Navigator

Tissue UK, expanding our customer base and generating important synergies with our teams in Portugal and Spain.

This has been reflected in a 55% increase in the volume and value of sales, an achievement that is all the more significant

when we consider how it has been done. International sales already account for 79% of total sales, and the retail segment (At

Home or Consumer) represents 83%, demonstrating our success in appealing to end users. This has been recognised by the

multiple consumer-led awards that have gone to Navigator, reflecting our consistent focus on developing innovative products

and on branding.

Navigator is establishing itself in tissue as a house of brands, an approach that cultivates affinities with consumers and

differentiated products. This is a strategy that is familiar to us from UWF paper, where our mill brands account for 77% of

sales, in sharp contrast to the industry as a whole, where the average rate is between 20 and 25%. Not forgetting the focus on

premium products, which grew again to 58% of total sales.

In the packaging segment, the market has responded eagerly to our distinctive offering, in which packaging based on

Eucalyptus globulus fibre offers a much-needed substitute for single use plastics obtained from fossil resources. The gKRAFT

range, which already boasts a portfolio of 300 clients, has doubled its sales, thanks to a fast-growing array of products, and in

particular the move into lightweight (low grammage) flexible packaging.

Once again, we are redefining the potential of this sector, as seen in the start-up, in late 2024, of a production line for moulded

cellulose components made from eucalyptus pulp. This is another world first, achieved in collaboration with RAIZ, our R&D

laboratory. This plant in Aveiro, the largest in the world to be vertically integrated with production of cellulose from Eucalyptus

globulus, is already turning out seven different articles for the food sector, the first in a new generation of sustainable solutions

with barrier properties that we are developing in partnership with clients in Portugal and further afield.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 12

Growing responsibly

To look back at 2024 is to revisit a year of initiatives and achievements that have bolstered our commitment to growing and

diversifying our business. But the most striking feature of all is the alignment with Navigator’s Responsible Business Strategy,

laid down in our 2030 Agenda, which expresses our purpose, focused on people and the future of the planet.

We create value responsibly in our stewardship of some 110 000 hectares of forests, (108 807 in Portugal and 1,111 in Spain),

in keeping with best practices in sustainable forest management, underlining the crucial role of well-managed planted forests in

the transition from a linear, fossil-based model, for which there is no future, to a circular bioeconomy model, which is carbon

neutral and nature-friendly.

We also grow responsibly when we are careful about our own impacts and in improving our operations, increasing our

investment in projects geared to sustainability. Out of total capital expenditure in 2024 of 241 million euros, 50% was in

projects classified as ESG. This continuous investment has been recognised by independent industry watchers. An example is

the classification of Navigator as a 2025 ESG Industry Top Rated Company in the ESG Risk Ratings of Sustainalytics, one of the

world’s leading ESG rating agencies.

On this matter, I would like to draw attention to our Decarbonisation Roadmap, which is mobilising more than 350 million

euros. This impetus has enabled us to bring forward our interim targets: for direct EETS emissions by three years. Next year,

we will achieve the targets initially set for 2029, with emissions down 55% on 2018, the baseline year.

We are also investing in water efficiency, with more than 25 million euros allocated to efficient and circular use of this resource.

Since 2019, we have reduced specific water use by 13%, which represents good progress towards our target of a reduction of

33% by 2030.

Growing with people

For Navigator, sustainable growth means engaging with stakeholders, and here too we made important strides in 2024.

This was the year in which we organised the Eucalyptus Forum, designed to stimulate open technical and scientific debate on

planted eucalyptus forests. We assembled more than 120 specialists from different areas, including representatives of

academic, researchers, local authorities, NGOs, forestry producers and professionals in the sector, creating an arena for

informed and illuminating dialogue.

Whilst preconceived ideas have a polarising effect, science brings people together. For this reason, our aim was to correct

misconceived ideas about eucalyptus, shining a scientific light on the myths and communicating more clearly the role of

planted forests in Portugal’s sustainable development. As a result of this initiative, we will this year launch two books compiling

all the knowledge produced at the Forum; one will be a technical and scientific publication, the and the other aimed at the

general reader.

Internally, we reasserted our unshakeable commitment to occupational health and safety, through continuous efforts from day

to day. We remained focused on our “Mission Zero” strategy, and especially on training and skills development, adoption of

best practices and continuous improvement of our management systems. Sustained investment in this area - totalling close to

27 million euros in the past five years - has had a real impact on the ground: in 2024, we recorded our lowest ever figure for

accidents leading to sick leave, clearly reflecting our achievements and our success in strengthening a culture of safety.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 13

From forest to future

Our business activities are anchored in a balanced approach that integrates the three pillars of sustainability. We recognise that

they are all equally important and that none should be neglected, without losing sight of the reality that they can only be

achieved if this is built on firm economic foundations.

The strong results we were able to record in 2024, in particular EBITDA margins, and the way these compare with the wider

industry, provide us with a firm basis for our future plans. It is this profitability that ensures that our environmental and social

commitments are feasible, securing the continuity of our operations and boosting our long-term resilience.

Accordingly, in conjunction with RAIZ, our R&D laboratory, we are stepping up our pipeline of innovation based on Eucalyptus

globulus, by studying new bioproducts derived from the species, as sustainable alternatives - natural, recyclable and

biodegradable - to products derived today from fossil raw materials, in particular, biofuels and e-fuels, helping to decarbonise

harder-to-abate sectors, such as shipping and aviation.

The Navigator Company has a firm belief in the merits of talent, innovation and the capacity to find industrial applications for

knowledge. This was how, more than seventy years ago, we started to redefine the boundaries of the entire pulp and paper

sector. We also know that it is not enough to rest on our laurels, and prefer instead to work at the intersection between science

and sustainability - where we feel ourselves to be in our element - striving to go further, taking as our starting point the fibre

from Eucalyptus globulus, an outstanding raw material for which new potential is continually being discovered.

The agenda which, in 2022, gave rise to our new range of sustainable packaging was called “From Fossil to Forest”. The time

has come to expand the horizons of everything we can create and achieve in the era of the new bioeconomy. In the era of

“From Forest to Future”.

António Redondo

Chief Executive Officer

ANNUAL REPORT 2024 • MANAGEMENT REPORT 14

1.3. 2024 in numbers

FINANCIAL DATA

€2088m

€547m

€287m

Total sales

EBITDA

Net income

€241m

26%

20.1%

Capital expenditure

EBITDA Margin

ROCE

21.5%

1.13 x

€150m

ROE

Interest bearing net debt/EBITDA

Dividends

ANNUAL REPORT 2024 • MANAGEMENT REPORT 15

GHG emissions intensity in accordance with ESRS E1.53. Includes total scopes 1, 2 (location-based) and 3 emissions

Total scopes 1 and 2 (location-based) emissions, in accordance with ESRS E1-644a and E1 6.44b

ETS- European Emissions Trading Scheme.

Total energy consumed in accordance with GRI 302-1

Energy intensity in accordance with GRI 302-3. Considering primary energy consumption and the total quantity of pulp, paper and tissue produced, in Portugal. Excluding

primary energy from Biomass Power Plants, consumed for dedicated power generation

FOR THE CLIMATE AND NATURE: ACTING

Climate Change

599 397

tCO

(down 36% on 2020)

down

41%

976

tCO

e/m€

Scopes 1 and 2 emissions

Reduction in direct ETS CO

emissions

in relation to 2018

(baseline)

GHG emissions intensity

(scopes 1+2+3)

6.4 m tCO

Accumulated stock in our forests

11.5

TWh

(up 4% on 2023)

3.56

MWh/t

(down 1% on 2023)

Energy consumed

Primary energy consumed from

renewable sources in Portugal

Energy intensity

in Portugal

1.2

TWh

(down 19% on 2023)

Electricity sold

ANNUAL REPORT 2024 • MANAGEMENT REPORT 16

Takes into consideration volume of water withdrawal by total manufacturing output.

Sustainable Forest Management

136 850 ha

73%

92%

Assets under Navigator group management

Wood used from woodlands

with certified forest management

Wood suppliers with

chain-of-custody certification

€

8.88

108 654

Investment in fire prevention

and

support for fighting forest fires

in Portugal

100% certified assets under management,

corresponding to 1.2% of the area

of mainland Portugal

Biodiversity Conservation

11.8

of the area under management

classified as Conservation Interest Areas

(managed for conservation purposes,

and not for production)

4 474

Classified as protected habitats

by the Natura 2000 Network

123

Areas that have undergone

ecological restoration

or rehabilitation

Water Management

down 8.5

Specific water use in industrial operations

in Portugal vs. 2019

(baseline for 2030 target)

20.5

Specific water use

in industrial operations

in Portugal

(down 3,3% on 2023)

Use of Resources and Circular Economy

5 241 400

Raw materials consumed

Renewable raw materials

99.8

Non-hazardous waste

446 601

(up 1,0% on 2023)

42 571

Waste generated

Sands (by-product) recovered for

construction sector

Rate of waste disposal in

industrial landfill

ANNUAL REPORT 2024 • MANAGEMENT REPORT 17

FOR SOCIETY: GROWING

People, Talent and Human Capital Development

3 965

€203.7m

93.8%

Direct jobs

Employee pay and benefits

Employees on permanent contracts

294

approximately

50%

Average training hours per

Employee

Young people in the Talent Attraction

Programme

Integration rate for vocational

internships

21 292

Training hours for Interns

Health, Safety and Well-being

93%

2 671

4.1

Internal employees included under

Occupational Health and Safety

Management System

Employees included under Occupational Health

programme

Frequency rate for accidents

at work

Does not include trainees/bursary holders or board members.

Includes vocational internships, trainees and summer internships in 2023.

There are various activities in the organisation, in particular Forest Management, Wood Supply and RAIZ, which do not fall under ISO 45001. However, activities in these

sectors are subject to the same principles and procedures.

Includes figures for internal Employees and external Employees.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 18

Community Relations

€1.6m

41.9 t

13 318

Investment in the community

(in Portugal and Mozambique)

Paper donations,

in Portugal

Participants in Floresta do Saber

(Forest of Wisdom) project in 2024

(31 187 since 2020)

7 000

Families impacted, Mozambique

Responsible Business Conduct

2 800

Employees with training in Code of Ethics

and Conduct, Whistleblowing, Internal Policies

and Prevention of Corruption and Related

Offences

Confirmed cases

of corruption

Women on Governance Bodies

(35.7%)

Innovation, Technology and R&D

€10.9m

Investment in RDI

Families of patents

(accumulated)

Supply Chain Management

7 718

70%

Suppliers

Volume of purchasing

from Portuguese

suppliers

Navigator’s total RDI expenditure on basis of amount eligible for SIFIDE.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 19

1.4. Awards

RATINGS

Score: 11,6

place out of 85

Paper & Forestry companies

with lowest risk

for investors

Score: A

Climate Change

(“Leadership” level)

Score: A-

CDP Forests

(nível de “Leadership”)

Score: A

In 2024, The Navigator Company

received a score of A in the MSCI

ESG Rating

Score: 73/100

Top 5%

of companies

OTHER PUBLIC RECOGNITION

SDGs Observatory

Incorporation of the Sustainable Development Goals (SDGs) into Navigator’s corporate policies, once again highlighted by the

SDGs Observatory as an example of good practice.

The way in which Navigator has incorporated SDGs into its business strategy was once again highlighted by the Center for

Responsible Business and Leadership, at CATÓLICA-LISBON, in the third SDGs Observatory report on Portuguese companies

published in 2024 - “2024 Annual Report: Observatory of SDGs in Portuguese companies”.

The implementation of SDGs in the business strategy, grading the level of the company’s contribution (Core, Supportive and

Local SDGs) and the detailed way in which SDGs are linked to the specific targets and programmes it pursues to meet the

commitments in its 2030 Agenda and Roadmap, have been recognised by the Observatory as an example of good practice and

concrete evidence of the company’s contribution to the United Nations 2030 Agenda.

RAIZ

TOP 10 Portuguese organisations with the largest number of international patent applications.

Reporting Matters

In the “Reporting Matters 2024” league table, organised by WBCSD and Radley Yeldar (RY), Navigator improved its score and

was positioned in the top 5 in the Basic Resources group.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 20

The strong points reported include robust discussion of the operating context and its impacts on corporate strategy, visual

representation of KPIs for performance analysis, and the clear incorporation of sustainability into the business strategy,

supported by the 2030 Roadmap.

Navigator voted best place to work in the industrial sector

In the first edition of “Merco Talento Universitário” (University Talent research by Merco, corporate reputation business

monitor) in Portugal, Navigator came out top in the ranking of companies where university students are most eager to work.

This result further consolidates the Company’s position as a top organisation in the industrial sector and the Portuguese job

market.

5 Stars Award

Pelo terceiro ano consecutivo, a marca Amoos conquistou o prestigiado Prémio Cinco Estrelas. O inovador rolo de cozinha

Amoos Calorie Control™, com microalvéolos criados para aumentar a eficácia na absorção das gorduras de alimentos acabados

de fritar, foi considerado pelos consumidores como o melhor produto em competição na categoria Rolos de Cozinha.

Kantar Award

The Amoos brand was named by Kantar Spain as the fastest growing brand in terms of penetration in Spanish homes 2023, in

the household goods category.

Business Culture Award

A Navigator Tissue Ejea foi distinguida pelo Instituto Aragonês de Fomento pelas boas práticas empresariais, responsáveis e

sustentáveis, e pelo seu elevado nível de empenho na excelência. Este prémio destaca a Empresa enquanto geradora de um

impacto positivo nas comunidades onde atua.

Business Culture Award

Navigator Tissue UK won the award for best company in the Well-being category thanks to its POP programme, developed and

implemented to the benefit of people.

APCE Grand Prix - Internal Publication

The Leading with Purpose handbook was singled out for its importance in promoting a culture of strong, motivating, conscious

and responsible leadership.

1.5. Paternships for impact

In 2024, Navigator stepped up implementation of collaborative models in many of the Company’s

initiatives and projects.

Partnerships and participation in cooperation schemes with organisations that share our values helps the Company to achieve

its aims and boosts the positive impact it seeks to have on Society, the Climate and Nature. In this report we highlight just a

few of Navigator’s partnerships, which can serve as examples of how the Company attaches value to the organisations with

which it cooperates.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 21

FOR THE CLIMATE AND NATURE

• Collaboration with academic, educational and research institutions, forest sector and fire-fighting associations and

companies, with the aim of helping to maintain and continuously improve the economic, ecological and social functions of

woodlands.

• Partnerships with various organisations for developing innovative products and solutions, able to contribute to a low-

carbon economy, in line with current climate science, and a sustainable circular bioeconomy, which is Nature-positive and

Climate-neutral.

• Active participation, as members, of associations of strategic importance for promoting cooperation centred on

sustainability, in close engagement with the Community.

OMYA

in Setúbal, for the supply of combustion gases from Navigator's boilers and lime kilns, so that CO

can be captured and

incorporated in the products manufactured at this industrial complex.

Specialty Minerals Inc.

at Figueira da Foz, for the supply of combustion gases from the boilers, so that CO

can be captured and incorporated, and

for reusing the carbonate sludges produced at this industrial complex.

Saint-Gobain

for promoting the circular economy and decarbonisation of the mortar industry.

BCSD Portugal

through the act4Nature Portugal initiative, which Navigator was one of the first companies to join, now sitting on the

Advisory Board.

Faculty of Science, University of Lisbon

in logistical support for the ForCe project (Forest Certification in Eucalyptus Plantations).

Serras do Porto Park

in connection with the Life Serras do Porto project.

AFOCELCA

in the area of fire response resources and procedures.

OFA (Organização Florestal Atlantis)

in supporting management of forest smallholdings (Cantanhede and Figueira da Foz region).

National Institute for Agrarian and Veterinary Research (INIAV), among other partners, in connection with the RRP

transForm project “P1.1 Genetic improvement, production and conservation of forest reproduction materials”, particularly for

the recovery of the Monchique oak

Wildlife Conservation Society, Fundação Biofund and Government of Mozambique

for promoting biodiversity protection in Mozambique, through needs assessments, sharing experience, field trips and

Stakeholder engagement (COMBO+ Programme). Large scale geographical study in progress, to identify priority areas for

forest protection and restoration.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 22

FOR SOCIETY

• Collaboration with academe, Navigator’s peer companies and organisations in the science and technology system,

involving national and international partners, with the aim of contributing to solutions that respond to the current

challenges facing society.

• Partnerships with entities that help us promote topics ranging from environmental and forest literacy to the importance

of sport and social inclusion, associating ourselves with social causes and working on projects for the wider

community.

• Collaboration with Portugal’s public employment service, helping to develop skills and add value to human capital.

Girl MOVE Academy

as part of Portucel Moçambique’s corporate social responsibility policy, with the aim of empowering young women and educating

them for leadership.

Vocational colleges and universities

such as ATEC - Academia de Formação, a Escola Secundária Dr. Bernardino Machado (Figueira da Foz), ISCTE (Lisbon University

Institute), University of Coimbra, Instituto Superior Técnico and Nova University Lisbon, for participation in job fairs, award of

study bursaries, promotion of workshops and seminars, and hosting students for curricular internships.

Express (leading Portuguese weekly newspaper)

in connection with the Eucalyptus Forum (May 2024), an event designed to promote in-depth reflection on forest issues, and in

particular on planted eucalyptus forests.

Utopia – Literature Festival

in promoting events under the Dá a Mão à Floresta (Give the Forest a Hand) project.

Cenjor - Journalism Training Centre

in organising training in Portuguese forests for journalists and journalism students, so as to equip them with the facts about this

vital ecosystem and sustainable use of its resources.

Drupa

presence on the HP stand, to promote the Navigator Premium Books brand.

iMM-Laço Hub and ABC Global Alliance

in the Pioneer Inspire Hope project to support the fight against breast cancer, since 2005.

UN Global Compact

in connection with the commitment to ethical conduct, integrity and environmental conservation, as well as protection and

respect for Human Rights, an integral part of Navigator’s approach to sustainable development, instituted in its internal codes

and policies and reflected throughout the Company’s operations and strategy.

Crédito Agrícola

to provide exclusive financing terms for members of the Navigator Forestry Producers Club.

Galp

to provide discounts for members of Navigator’s Forestry Producers Club when refuelling at the network of filling stations.

Interprev

offering members of Navigator’s Forestry Producers Club with customised services, at more competitive prices.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 23

2. Our identity

2.1. Purpose and values

Purpose

It's people, their quality of life and the future of the planet that inspire and motivate us.

We want society to share not just in the wealth we create, but also in our knowledge, our experience and our resources, all in the

name of a better future.

That is why we are committed to creating sustainable value for our shareholders, and for society as a whole, leaving a better

planet for future generations, through natural products that are sustainable, recyclable and biodegradable, that help to sequester

carbon and produce oxygen, that protect biodiversity, improve the soil and combat climate change.

Values

Trust

We believe in people, we welcome everyone's contribution, we respect their identity, promoting development, cooperation and

communication.

Integrity

We are guided by principles of transparency, ethics and respect in our dealings amongst ourselves and with others.

Enterprise

We are passionate about what we do, we like to get out of our comfort zone, we have the courage to take decisions and to accept

risks in a responsible way.

Excellence

In our work we focus on quality, efficiency, safety and getting it right.

Innovation

We seek to bring out everyone's skills and creative potential to do the impossible.

Sustainability

The balance between the economic, environmental and social pillars of sustainability underpins our business model.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 24

2.2. Company Profile

From Fossil to Future

With seven decades of continuous innovation and a recognised commitment to the quality of its products and solutions, The

Navigator Company is an integrated producer of forest materials, pulp, paper, tissue, sustainable packaging solutions and

bioenergy.

A sound financial and industrial structure is the foundation on which Navigator has developed its core business, whilst

simultaneously investing in sustainability and growth through diversification, as exemplified by it latest business areas: Tissue

and Packaging.

In alignment with its Purpose, focused on people and the planet, Navigator is today moving beyond its traditional business in

the pulp and paper sector, aware of everything it can do as a driving force for a new forest-based circular bioeconomy.

With RAIZ, our R&D laboratory, and taking Eucalyptus globulus, an unrivalled raw material, as our starting point, we are

developing new bioproducts and biomaterials, exploring business opportunities in the bioeconomy, in particular in eucalyptus

essential oils, biocomposites, biofuels and synthetic fuels.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 25

Pulp

The pulps produced by The Navigator Company set global standards for the industry, reflecting almost seven decades of

experience in development and innovation on the basis of a raw material with an unmatched reputation. In 1957, Companhia

Portuguesa de Celulose, the predecessor to what is today Navigator, was the first company in the world to produce Eucalyptus

globulus pulp on an industrial scale, using the kraft method, setting a new standard for the industry all round the world.

Versatile enough to be ideal not just for producing premium paper products, but also for use in the automobile industry, the

food and medical sectors, to mention only a few, Eucalyptus globulus pulp is today proving highly suitable for developing a new

generation of bioproducts able to successfully replace those which are today obtained from fossil sources, including plastics and

liquid fuels.

Worldwide, eucalyptus fibre already accounts for almost half the total fibre on the market and 80% of hardwood fibre, and

demand continues to boom.

The Navigator Company is Europe’s top producer, and the 7

largest in the world of bleached eucalyptus pulp (BEKP), with

annual capacity of 1.6 million tons, at its industrial units in Aveiro, Figueira da Foz and Setúbal.

In 2024, due to increased incorporation into paper produced by the company, The Navigator Company’s pulp sales fell by 16%,

to a total of 389 thousand tons. However, a 13% improvement in average prices in relation to the previous year meant that, in

relation to the value of sales, the drop was smaller, at just 5%.

The excellent quality of a home-grown raw material

Eucalyptus globulus, which is naturalised in Portugal, is regarded around the world as the best species for manufacturing

paper pulps. Several countries have tried to plant it, without success, further highlighting the unique conditions that Portugal

offers this species.

UWF Paper

As Europe’s leading producer and the 6

largest in the world of UWF (uncoated woodfree) paper, The Navigator Company can

also boast strong brands which serve to differentiate its products. The year of 2024 was no exception: mill brands accounted

for close to 77% of sales for the period (vs. an average of 73% over the period 2018-2024), as compared with an average of

between 20 and 25% for the paper sector as a whole.

The Company is the world leader in the premium segment, a factor of differentiation which was again boosted in 2024, with

premium products accounting for 58% (as compared to an average of 55%, in the period 2018-2024). Industry-wide, premium

products have an average share of between 10 and 15%.

The shares achieved for mill brands and premium products in 2024 were the second best ever recorded, which is all the more

relevant if we recall that, when market conditions are more difficult, mill brands and segments with greater value added offer

an additional safeguard for Navigator’s results.

In 2024, Navigator's printing and packaging paper sales totalled 1225 thousand tons, up by 8% on 2023. The sales volume, in

euros, grew by 3%.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 26

Manufactured at the mills in Figueira da Foz and Setúbal, which together have rated capacity of 1.6 million tons, The Navigator

Company's UWF papers are exported to 132 countries.

World leader in the premium segment

Two out of every three reams of office paper exported from Europe are produced by The Navigator Company. Launched in

1992, in a branding initiative then unprecedented in the industry, the Navigator brand leads the world in sales in the

premium office paper segment.

Tissue

Navigator took its Tissue business to a new level in 2024 with the acquisition of Navigator Tissue UK, just one year after it

completed a similar operation in Spain, with what is now Navigator Tissue Ejea.

The synergies and the combined expertise of the teams in Portugal, Spain and the United Kingdom have expanded the portfolio

(now one of the most comprehensive in Europe) as well as the customer base, strengthening Navigator’s strategic position in

the tissue market. Production is now divided between eight plants: two in Portugal, one in Spain and five in the United

Kingdom.

The Company first moved into this segment in 2015, in line with its plan for diversification and growth, and tissue is now its

second largest business area. The volume of tissue sales (finished products and reels) totalled 220 thousand tons in 2024,

representing an increase in the volume and value of sales of 55%.

This growth was significant not just for its scale, but also for the way it has happened: international sales now account for 79%

of total sales, at the same time as, in terms of segments, the At Home or Consumer (retail) segment has accounted for a

growing share, currently representing 83% of sales, pointing to the popularity of products manufactured by Navigator with end

consumers.

The diversity of the portfolio has been a factor in this process, along with the company’s disruptive approach to the segment,

with a strong element of innovation and investment in launching distinctive products. Navigator has registered 7 trademarks,

each for a specific proprietary technology, developed through close collaboration between RAIZ, its research laboratory, and

the Company’s commercial and industrial teams.

The consumer’s choice

Navigator’s Amoos brand won the Five Star Award in 2022, 2023, 2024 and 2025, with its Amoos Aquactive

Kitchen/Multipurpose Roll, Airsense Toilet Paper, Calorie Control Kitchen Roll and Naturally Soft Napkins. In early 2025, the

brand also won the Consumer’s Choice award in the Toilet Paper category and Product of the Year in the Household Papers

category (Naturally Soft napkins, 40x40). Also in the first few months of 2025, one of Navigator UK’s products, the Flash roll,

was voted product of the Year, and recognised as one of the most innovative in its category.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 27

Sustainable packaging

After only three full years of operation, the sustainable packaging sector already has more than 300 customers, in a commercial

operation based entirely on its own brand - gKRAFT. With this new segment, Navigator is helping to speed up the transition from

single use fossil plastics to the use of natural fibres, which are sustainable, recyclable and biodegradable, thereby stepping up its

commitment to sustainability.

In 2024, the sales volume in the segment doubled in relation to the previous year, with 70% of sales in Europe, most importantly

in Italy, the Iberian Peninsula, France and Germany, and the remainder in overseas regions, with Latin America, Turkey and North

Africa as the largest markets. Since its launch in late 2021, the gKRAFT range has been exported to 47 countries.

This performance was achieved by moving into new segments, launched in 2023 and the early months of 2024, above all in the

area of flexible packaging, confirming the effectiveness of the strategy of diversifying into these new packaging paper applications

using eucalyptus fibre.

The year of 2024 saw Navigator once again pioneering change in the global industry, with the start-up of production at a new

industrial unit, in Aveiro, for moulded cellulose components, offering a response to the ever more pressing need to substitute the

single-use, fossil based plastics which dominate the food sector.

This is the first time anywhere in the world that moulded cellulose articles have been produced from eucalyptus fibre. The new

unit has annual production capacity for approximately 100 million units and is the largest in the world to be vertically integrated

with production of Eucalyptus globulus cellulose.

Production started up with seven 100% recyclable and/or compostable products for single use applications in the food sector, and

the unit offers the flexibility and scalability needed to seize the various opportunities that are opening up for replacing single use

plastics and aluminium.

Alongside this, work has proceeded on developing new products, in partnership with national and international clients, and on

researching and developing new sustainable barrier property solutions, as well as trials of commercial products.

Moulded cellulose certified for food contact

In early 2025, Navigator’s gKRAFT Bioshield moulded cellulose products achieved certification for food contact under

European Regulation (EC) 1935/2004 (food contact) and, for the first time for products of this kind, under the German

recommendation BfR XXXVI, in a certificate issued by ISEGA, the prestigious German laboratory. Certification enables us to

market products for the food segment, for contact with fatty, moist and dry foods, applying to our entire tableware and take-

away line.

Energy

The Navigator Company has extensive experience of generating energy from renewable sources, and 2024 was another landmark

year in this field.

This was the year we completed work on new solar arrays for internal power consumption at the industrial units in Figueira da

Foz, Aveiro and Vila Velha de Ródão. With photovoltaic solar power facilities featuring total rated capacity of approximately 38

MW, Navigator is now Portugal’s largest generator of solar power for internal consumption in an industrial setting.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 28

In 2024, 78% of the electricity generated by Navigator was from renewable sources. The Company accounts for 3% of all

electricity produced in Portugal, including 34% of power generated in the country from biomass.

Support for the national grid

Navigator’s industrial units took part in 2024 in the manual Frequency Restoration Reserve Band Market (mFRR Band). This

system service, provided to the operator of the power grid by qualified consumers, helps to safeguard the security of supply

in the National Electrical System, which has already proved to be decisive for protecting domestic consumers and critical

users. Over the course of this year, Navigator’s units were mobilised on 32 occasions as part of this service.

Forest

The Navigator Group manages a total of approximately 137 000 hectares of woodlands, including production forests, and areas

given over to wildlife conservation. In mainland Portugal, Navigator manages approximately 109 000 hectares, 100% certified

under the FSC

and PEFC systems (since 2007 and 2009, respectively).

Through its Forest Management Plan (FMP), Navigator promotes active management of its forest holdings (both its own estates,

and rented land), with an efficient and responsible approach. Scientific support is provided by RAIZ, the group’s own forest and

paper research centre, enabling it to implement innovative silvicutural practices, adapted to the specific soil and climate conditions

in each region.

In 2024, Navigator celebrated the first anniversary of the Forestry Producers Club, a pioneering scheme which sets out to unite

and support the community of forestry Producers, Suppliers and Service Providers in adopting sustainable forest management By

the end of 2024, the club had attracted 385 members, together representing turnover in the sector of around 600 thousand euros

and a workforce of more than 3100. Membership benefits include financial solutions, support for modernising equipment and

exclusive discounts which help to cut costs.

Active management and profitability are factors that can revitalise the rural economy, combating desertification and the

abandonment of forests, by creating jobs and anchoring businesses and residents in these regions. It accordingly contributes to

environmental and social gains thanks to the adoption of good practices that minimise environmental impacts, reduce the fire risk,

increase sequestration of CO

and promote biodiversity.

Biodiversity conservation

Biodiversity conservation represents a priority in Navigator’s forest management model. In 2024, Conservation Interest

Zones (CIZs) accounted for approximately 12% of the areas under management, surpassing the certification requirements.

These areas contain habitats which are essential for a number of species, including endemic and protected species with

varying conservation and protection status, which are regularly monitored. Within the CiZs, there are 4,474 hectares

included in the Natura 2000 Network. By 2024, a total of 1195 species and sub-species of flora and more than 260 species of

fauna had been identified on Navigator’s estates.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 29

R&D and Innovation

Research and Development (R&D), combined with the ability to put the resulting knowledge to industrial use, are among the

fundamental pillars of The Navigator Company's identity, securing its success as a global pioneer.

The RAIZ Institute is currently the visible face of this ongoing scientific work applied to forestry and industry. The largest private

institute in Europe, and one of the largest in the world, dedicated to R&D for eucalyptus forests and their products, it was set up in

1996 and its shareholders, in addition to Navigator, are the University of Coimbra, the University of Aveiro and the Higher

Institute of Agronomy (University of Lisbon).

RAIZ is a private non-profit organisation, recognised as belonging to the Portuguese Science and Technology System. It works in

three major R&D areas: forestry, industry/technology and specialist supporting services for the Company’s operations.

At a key moment for development of the forest-based bioeconomy, in which Navigator is deeply involved, RAIZ’ work in this field

has gained a significant impetus.

New biomaterials, biochemicals and biofuels obtained from E. globulus are at an advanced stage of development, with the

potential to generate new business opportunities, including new applications for cellulose fibres in fibre/thermoplastic composites,

bioactive compounds from eucalyptus foliage and bark, and advanced biofuels.

A benchmark for innovation

“Barómetro Inventa 2024 – Patentes Made in Portugal”, a specialist industrial property survey, singled out

RAIZ as a leader in sustainable innovation, highlighting that it doubled its number of patent applications in

2022. The institute has registered 23 families of patents, making it the top ranking (non-university) entity.

RAIZ’ patent count was surpassed only by the Universities of the Minho, Aveiro, Lisbon and Coimbra.

Portucel Moçambique

Portucel Moçambique is an affiliate of The Navigator Company and is developing a forestry venture in Mozambique, to be

integrated in the first place with the woodchip industry and, at a later stage, with the paper pulp sector. The venture represents

long term investment estimated at 2.5 billion dollars, and has already reached the export phase, having dispatched 9 shiploads

from the port of Beira.

The project is designed so as to share value and promote sustainable socio-economic development in its operational areas, by

creating jobs, training, vocational skills and knowledge transfer. This means it contributes to economic progress and stronger

value chains, increased exports and fiscal revenues, the development of forest and industry, inclusive development of

Communities and their farmlands, to a balanced environment and the preservation of biodiversity.

The venture generates positive economic impacts. Locally, around 16.5 million dollars has been paid out in wages, for casual work

by members of local communities. In 2024, the Company generated permanent employment for around 300 people and additional

full-time work, equivalent to more than 700 jobs.

Investment to date in the Social Development Programme, part of the Investment Agreement with the authorities, totalled close

to 8.2 million dollars at year-end 2024. This programme reaches out on a regular basis to some 7000 families and is focused on

three objectives: improved food security, support for livelihoods and improved welfare. The programme has been implemented on

the basis of regular and inclusive dialogue with the communities which benefit.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 30

The Company attaches value to stakeholder inclusion in the main decisions taken at local, provincial and national level;

consultations are conducted on a regular basis and various arrangements are in place for technical and scientific cooperation.

Regular and frequent communication is assured between Communities, Portucel technical staff and the Liaison Officers, so as to

achieve a smooth and collaborative relationship between the parties involved.

Portucel has already planted more than 35 million trees in Mozambique, which have accumulated a carbon stock of 3.4 million

tons.

2.3. Creating sustainable value

Our responsible business strategy is based on creating long-term value and sharing it with our various Stakeholders, in line with

our intentions set out in the Corporate Purpose.

We are a top player in wealth generation in Portugal and leading contributor to the country's economy. We have a direct impact

on the lives of thousands of people all along the value chain - including Shareholders, Employees, Customers, Suppliers, Local

Communities, Suppliers and society in general.

Our impacts

€2,189m

Direct economic value generated

€2,088m

Turnover

7,711

Suppliers — 70% Portuguese

2.5%

of Portuguese exports of goods

€1,825m

Direct economic value distributed

€365m

Accumulated economic value

€120m

ESG CAPEX (51% of total NVG

CAPEX in 2024)

66%

ESG finance

€241m

in projects aimed at the Climate Transition and

the Digital Transition, under the RRP up to 2026

30,000

Direct, indirect and induced

employment

The percentage refers to the value of finance contracted.

Source: KPMG study - 2016.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 31

Our industrial plant sets international standards due to its scale and sophisticated technology, which is the foundation on which

we have grown. In addition to four modern and large-scale industrial complexes located in Portugal, we have expanded our

geographical base for industrial production and sales by means of two recent acquisitions in the tissue sector, first in Spain

(Navigator Tissue Ejea), in 2023, and then in the United Kingdom (Navigator Tissue UK), in 2024. This strategy is designed to

increase our industrial and commercial capacity, to optimise our portfolio of Iberian customers and to strengthen our position in

the tissue market in Western Europe. In terms of forestry, our operations are located in mainland Portugal, Galicia (Spain) and

Mozambique.

Our business strategy and results position us as one of Portugal’s largest industrial concerns – ranking as the third largest

exporter of goods in Portugal. Approximately 91% of our output is sold outside Portugal, with products shipped to 134

countries.

Because our value chain incorporates home-grown natural resources from planted forests and because we create livelihoods and

jobs in Portugal, where we source most of our raw materials and services, we are the top exporting company in terms of

contribution to Domestic Value Added

Through our business operations we generate jobs for 30,000 people, in direct, indirect and induced employment

, and we work

with more than 7,700 Suppliers, 70% of which are Portuguese.

In 2024, Navigator recorded turnover of €2 088 276 553, the second highest figure in the Group’s history, whilst direct economic

value (revenue) increased by 7.1% in relation to 2023.

Despite the troubled economic and geopolitical context, which shaped expectations on international markets (finance, energy,

logistics and commodities) in the first half of the year, the international economy bounced back. Benchmark prices for UWF paper

proved resilient and order books improved for UWF, packaging and, at the end of the year, tissue, enabling the Company to stick

to its capex and innovation commitments in all segments and to explore opportunities for growth in tissue, packaging and energy.

Efficient management of its business mix, the sales strategy, cost controls and the focus on innovation and business sustainability

are all key factors in ensuring that the Navigator Group is competitive.

Navigator’s forest business strategy has strong roots in Portugal, due to the location of its industrial complexes and the quality of

its management of planted eucalyptus forests. In 2024, the Company transferred approximately 228 million euros to the various

districts of Portugal.

Source: Figures published by INE for 2021.

Source: KPMG study - 2016

ANNUAL REPORT 2024 • MANAGEMENT REPORT 32

Value Generated and Distributed

Creating long-term value

Creating long-term value and sharing it with our various Stakeholders is built into our identity (Chapter 3.4.5) and we are mindful

of how our business impacts society and that our economic and financial performance cannot be dissociated from how we manage

our Community relations, from judicious management of the resources we use, from our ability to mitigate our business risks or

from transparent, open-access communication.

As set out in our Purpose, we want to share with society not only our results, but also the expertise at our disposal, our

experience and our resources, with a commitment to leaving a better planet for future generations - through natural products that

are sustainable, recyclable and biodegradable, that help to sequester carbon, protect biodiversity and combat climate change.

Pursuit of a responsible business, promoting sustainable development and in alignment with the United Nations Sustainable

Development Goals (SDGs) is therefore set out in our 2030 Agenda – Creating Value Responsibly (Chapters 3.4.2 and 3.4.3).

Customers are a strategic Stakeholder for The Navigator Company's success, and we therefore invest in building a close

commercial relationship and meeting their needs. Strong brands and sustainable products (Chapter 2.2) remain essential factors,

which are combined with a firm commitment to innovation.

We have invested in creating innovative and distinctive products, in promoting a new generation of bioproducts, offering an

alternative to fossil-based materials, and in developing potential new businesses, aligned with sustainable development (Chapter

3.4.2).

ANNUAL REPORT 2024 • MANAGEMENT REPORT 33

We keep up with market trends and sustainability challenges (Chapter 3.4.1), with our strategy of product diversification, where

we have made significant strides. An example of this is our move into the packaging business, with a new line of packaging paper

(gKRAFT), which helps reduce the use of plastics, by providing substitute materials from renewable sources.

We also contribute to the rural economy, through development of the regions where we operate and improving the woodlands we

manage, with an impact on Local Communities (Chapters 5.3.3). In particular, we add value to the entire forest value chain,

highlighting the potential of Portuguese forests for producing a diversified range of products.

We set out to contribute to generating opportunities for professional growth in an array of different sectors, from forestry to

manufacturing, and from research to end products. This benefits and empowers our eucalyptus Growers, Suppliers and Local

Communities. We have a positive impact on the employability and skill levels of young people (Chapter 3.4.2) and forestry

producers, by working to share our knowledge through educational initiatives promoting sustainable forest management and

certification, with the aim of contributing to improved and better protected forests.

As the foundation of all our operations, we invest in our human capital - in skills, recognition, motivation, health and welfare

(Chapters 3.4.2). We support our Employees’ families and, as part of our efforts to recognise the dedication and commitment of

our people to achieving positive results for the Company, we have responded to this success by awarding and increasing

performance and productivity bonuses.

Portucel Moçambique

In the operations of Portucel Moçambique, the process of harvesting and exporting eucalyptus wood from the country is

geared to creating sustainable value, supporting the Company’s operations in the country in the long term. Over the length of the

value chain, the returns from the project include:

ANNUAL REPORT 2024 • MANAGEMENT REPORT 34

• Skilled employment and professional advancement. The company employs a permanent workforce of 313 (96%

Mozambican, and 23% women), as well as providing a further 1,100 full time equivalent (FTE) jobs on a casual and

seasonal basis, mostly for Local Communities.

• Wealth generation and added value in the country, as well as environmental protection and investment in Communities.

A forest-based industrial cluster is being created, with a focus on exports, thanks to the favourable soil, climate and geographical

conditions, positioning Mozambique and the Company in the international market for exporters of sustainable wood.

Between 2021 to 2024, a total of 9 shiploads were dispatched from the port of Beira, corresponding to 285 thousand m

of wood,

of which 241 thousand m

was harvested from Portucel Moçambique's plantations.

In addition, Portucel Moçambique contributes to the development of Local Communities in the areas where it operates through the

different elements of its Social Development Programme (Chapter 5.3.3), representing investment of 7.6 million dollars.

Finance and investment for sustainable development

Navigator has committed itself to ensuring that its sustainable financing and investment

policies incorporate ESG criteria, setting specific targets for this in its 2030 Roadmap (Chapter

3.4.4).

We have made significant strides in recent years towards sustainable finance, through financing

operations where pricing is pegged to compliance with Sustainable Development Goals or ESG

performance indicators, included in our 2030 Roadmap. In 2024, the implementation of this policy

was clearly visible in the loans contracted: 355 million euros in ESG finance, enabling Navigator to

achieve a ratio (ESG/total) of 66%.

ESG finance

contracted

ANNUAL REPORT 2024 • MANAGEMENT REPORT 35

These financing arrangements enable us to make a judicious selection of maturities and risk conditions, and the pricing

mechanisms are a clear demonstration of our commitment to sustainability goals.

We have also been willing to work in partnerships, submitting funding applications to leverage the transition to a low-carbon

economy and to the bioeconomy, thereby boosting our contribution in this area (see following section).

It is important to note that we have adopted a Responsible Investment Policy for Navigator’s Pension Fund

. The entities

contracted to manage our pension funds pursue a responsible investment policy, seeking to contribute to sustainability of the

market as a whole in the long term, with the goal that all our assets should be linked to environmental, social and governance

(ESG) criteria.

The selection process for managers included assessing how far they incorporate ESG factors into investment decision-making, and

evidence that they play an active role in promoting sustainable investment. The Fund will have the goal of achieving neutrality in

greenhouse gas emissions by 2050 throughout its portfolio and will now use climate change metrics in its reporting.

ESG Investment allocation

In 2024, capital expenditure totalled €241 million (compared to €187 million in 2023). Capital expenditure consisted mostly of

projects aimed at structural and safety projects, modernising equipment and improving efficiency, as well as maintaining

production capacity.

Of these investments, approximately 50% (totalling more than €120 million) related to projects and initiatives with ESG aims,

including structural, environmental and decarbonisation projects. Some of the main capex projects classified as ESG include, for

example, the new recovery boiler in Setúbal (Chapter 5.2.1), the new biomass lime kilns in Figueira da Foz and Aveiro, the

ANNUAL REPORT 2024 • MANAGEMENT REPORT 36

conversion of the fuel oil burners to hydrogen in the recovery boilers in Figueira da Foz and Aveiro and the Biomass boiler in

Setúbal, the solar power facilities in Figueira da Foz and Vila Velha de Ródão, and the new tower and washing presses in Aveiro,

which will contribute to accelerating the Group's decarbonisation plan, as well as investment in waste water treatment plant

(WWTP in Setúbal) and the treatment of fly ash from the recovery boiler in Aveiro.

The Group is currently involved in four of the components (C5, C11, C12 and C16) of the RRP - Recovery and Resilience Plan,

with eligible investments of approximately €269 million, up to 2026.

Navigator continues to press ahead as planned with the projects under the Recovery and Resilience Plan (RRP). For eligible

investments under the RRP, an incentive rate of around 40% is anticipated, corresponding to close to €100 million, of which the

company received approximately €21 million in 2023 and €25 million in 2024.

The following RRP projects are already in progress, under the different Agendas:

• From Fossil to Forest Agenda (Sustainable Packaging Products to substitute Fossil Plastics | Investment in R&D and

industrial innovation, in projects for development of i) high yield chemical pulp and brown papers; ii) moulded cellulose

for hard packaging; iii) biocomposites; iv) papers with barrier properties; and v) smart packaging.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 37

• Decarbonisation Agenda | Includes, among others, the projects for: i) new cogeneration turbine in Figueira da Foz, ii)

new lime and biomass kiln in Figueira da Foz, iii) new recovery boiler in Setúbal, iv) incineration of non-condensable

gases (NCG) in the new recovery boiler in Setúbal, v) new cogeneration plant at Tissue Aveiro, vi) new solar facility at

Tissue Aveiro, vii) new bleaching tower and pulp washing presses in Aveiro, viii) new cogeneration plant in Vila Velha de

Ródão, ix) new solar power facility at Tisssue VVR, conversion of Lime Kiln 3 in Aveiro from natural gas (NG) to Biomass,

and xi) conversion of fuel burners at recovery boilers (RC4) in Aveiro, RC2 in Figueira and biomass boilers (BB) in Setúbal

to burning NG/H

• TransForm Agenda | Projects relating to: i) genetic improvement and seed orchards at Viveiros Aliança and RAIZ, ii)

remote data detection for sustainable and resilient forest management, iii) boosting adoption of electrical engines in

Portugal's forest sector, and iv) recovery of industrial waste for fertiliser production.

• Be@t – Textile Bioeconomy Agenda | Featuring: i) development of biocomposites for application in the textile industry

and ii) innovative non-woven fabrics, incorporating paper cellulose fibre.

• Produtech R3 Agenda | Projects for i) robotised boxing machine for napkins in Aveiro, ii) artificial vision for Wood

reception and iii) automatic truck loading.

Another important project, for conversion of Lime Kiln 1 in Setúbal, from oil/NG to biomass, is not included under the RRP, but

instead under a European Innovation Fund programme.

External recognition of our commitment to sustainability

Our dedication to creating value responsibly, as we take care of people and the planet, is reflected in our positive external

assessment from a range of independent organisations, serving to encourage our own assessment process and continuous

improvement in ESG performance.

Our performance as a low ESG risk company for investors has earned Navigator recognition from Sustainalytics, as an ESG

Industry Top Rated company, and a place in its prestigious global list of 2025 ESG Top-Rated Companies. We also obtained a

score of “A” from the MSCI ESG Ratings, which set out to measure the resilience of companies to long term ESG risks, and we

achieved Gold status in our Ecovadis rating. We were also honoured once again internationally for our commitment to combating

climate change and managing deforestation risks, achieving last year's top rating of ‘A’ in the CDP Climate Change, guaranteeing

a place on the prestigious A-List for Climate, and the ‘A-’ rating in the CDP Forests, both of which positioned the company at the

leadership level.

These ratings, together with the awards listed in Chapter 1 of this report, clearly reflect Navigator's commitment to leading the

transition to a more sustainable business model. More than just external recognition, this achievement celebrates the collective

efforts of the entire organisation and, in particular, the hard work and dedication of each and every employee.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 38

3. Strategy and Governance

3.1. Business Strategy

Because Sustainability is what guides and underpins our business, we constantly assess our performance in this area by using an

ESG framework, designed to monitor our performance in managing environmental, social and governance issues in our business.

This is the stance we take: we integrate sustainability into our strategic business vision, as a concept that promotes a long-term

balance between three essential pillars - economic, environmental and social. It is an essential feature of any development model

able to meet the needs of today without compromising the future of mankind and the planet.

The Company's Responsible Management Strategy is based on Ethics, Responsibility and Transparency. We are responsible for

forest-based products that contribute to sustainable development and to the well-being of Society, in alignment with the United

Nations 2030 Agenda.

Our sound financial position enables us not only to consider opportunities for investing in efficiency and innovation in our core

businesses, but also to look for new opportunities for growth and move towards diversification:

Energy

The Navigator Group is one of Portugal's largest producers of renewable and sustainable energy. In 2024, 78% of all the energy

we produced was from renewable sources. In addition to generating energy from forest biomass, the Group has been expanding

the capacity of the solar power facilities at its industrial complexes. Work was concluded in 2024 on the building of new solar

power facilities for the group's own consumption at our sites in Figueira da Foz, Aveiro and Vila Velha de Ródão, increasing the

rated capacity to approximately 38 MW. This has made Navigator Portugal's top producer of solar power for internal consumption

in an industrial setting.

In connection with this, the Navigator Group is also investing in batteries (electrical storage), above all for providing regulation

reserve system services.

Taking a medium-long term view, Navigator is still looking into the attractiveness of investing in green fuels, both biofuels

(medium term) and e-fuels or synthetic fuels (medium-long term).

In biofuels, possible capex projects are being assessed in the production of second generation bioethanol (using eucalyptus bark

as raw material) and in producing kraft biomethanol (through the recovery and purification of by-product biomethanol produced at

pulp mills) for use as fuel or in the chemicals industry.

In e-fuels, capex projects are still being assessed for production of e-methanol and e-jetfuel. These are two distinct projects, with

different technologies and potential partners. In both cases, an essential component is biogenic CO2, a by-product in our pulp

production processes. In brief, these are processes for synthesising (biogenic) CO2 and green H2 (obtained from water

electrolysis) with a view to producing sustainable hydrocarbons (e-methanol, e-kerosene), neutral in carbon emissions, for the

shipping and/or aviation sectors, where electrical engines are not an option.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 39

Tissue

In line with its business diversification strategy, the Navigator Group decided in 2014 to move into the tissue sector, and has

pursued this goal consistently since then. It started in 2015 with acquisition of AMS Star Paper, with the capacity to produce 60

000 tons of tissue each year.

In 2018, the Group invested in a greenfield tissue production unit at our industrial site in Aveiro, integrated with our pulp mill,

with rated capacity of 70 000 tons of tissue paper/year and production capacity for finished products of 55 000 tons.

In 2023, the Navigator Group acquired the tissue business of the Spanish Gomà-Camps Group and the industrial site in the

Zaragoza region, which has capacity to produce 35 000 tons of tissue paper a year, along with converting capacity of 55 000 tons.

More recently, in 2024, the Navigator Group acquired the Accrol Group, in the United Kingdom, incorporating 5 plants producing

tissue and wet wipes (a new category of hygiene and cleaning products, to complement our existing range), with total rated

production capacity for 130 000 tons of finished products.

With the incorporation into the group of Accrol, now called Navigator Tissue UK, the Navigator Group is now one of the top 4

players in the tissue paper converting market in the United Kingdom and is vying for leadership of the private label segment.

With this dynamic of expansion, the tissue business area has proved both growth and the creation of sustainable value, whilst

proving resilient and profitable, even in challenging market conditions, permitting us to look forward to continued growth (organic

and/or non-organic) in this market segment.

Packaging

The development of our packaging business continues to show considerable promise, with a growing Customer base and

recognition of the quality of our sustainable products, based on eucalyptus globulus fibre, for varied uses in sectors ranging from

fashion to food retail, e-commerce, manufacturing and farming. At present, 70% of sales are to European countries, in particular

Italy, the Iberian Peninsula, France and Germany. Outside Europe, the main markets are Latin America, Turkey and Northern

Africa.

As part of the process of business diversification, and in keeping with the sustainability and ESG goals established, the Navigator

Group has moved into new segments, launched in 2023 and the early months of 2024, especially in the area of flexible packaging.

The results have confirmed the effectiveness of the strategy of diversifying into these new packaging paper applications using

eucalyptus fibre.

In 2024, Navigator started up integrated production of moulded eucalyptus cellulose parts, intended to substitute single-use

plastic packaging in the food service and food packaging market. The seven initial products offer production flexibility and

scalability for exploiting the various opportunities opening up for substituting single use plastics and aluminium.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 40

Mozambique

Since the Memorandum of Understanding signed in 2018 with the Mozambican Government, work has continued to centre on

Phase 1 (export of woodchip). Portucel Moçambique started in 2020 to harvest the first plantations established in Manica province,

yielding wood which was exported between 2021 and 2024 from the port of Beira. These shipments totalled 285 thousand cubic

metres, with an export value of more than 21 million dollars.

In this regard, construction of the new port in Macuse is a major step forwards and one of the pre-conditions for developing the

project, both for the first phase (woodchip) and for future exports of the paper pulp to be produced in the second phase of the

project, which involves building the pulp mill.

Portucel Moçambique contributes with significant economic and social impacts, starting with jobs and vocational training, above all

in the countryside (2000 jobs in phase one and 8000 in phase two), but also through economic growth and a stronger value chain

(3.3 billion meticais, of 75 million dollars, in contracts for Mozambican companies). The venture also boosts exports, by 100

million dollars/year in the first phase and a billion dollars/year in the second. There are also contributions to developing transport

and logistical infrastructure.

Biomaterials

With RAIZ, Navigator’ R&D laboratory, the Group has been researching and stepping up development of new bioproducts derived

from Eucalyptus globulus, exploring business opportunities in the bioeconomy for a vast range of applications, in particular in the

areas of hygiene and personal care, cosmetics, nutraceuticals, food additives and the health sector, as well in biofuels and

synthetic fuels.

3.2. Governance model

The Navigator Company has a unitary management model, with a Board of Directors (BD) comprising executive and non-

executive directors, as well as an Audit Board and a Statutory Auditor. The General Meeting consists of all the shareholders who

wish to attend: there are no limits on exercise of voting rights by its shareholders.

The following internal committees exist in the Company:

Attached to the board of directors:

i. Executive Committee (EB)

ii. Corporate Governance Committee

iii. Talent Committee

iv. Risk Management Committee

v. Environmental Board

vi. Sustainability Forum

Not attached to the board of directors:

ANNUAL REPORT 2024 • MANAGEMENT REPORT 41

vii. Remuneration Committee

viii. Ethics and Integrity Committee

Decisions relating to definition of Company strategy, and to its general policies and the corporate structure of the Navigator

Group, are the province of the Board of Directors, and the Executive Committee has no delegated powers to this effect. The non-

executive directors accordingly take part in designing strategy, central policies and the business structure and in reaching

decisions that are to be considered strategic by virtue of the sums or risks involved, and also in assessing execution of these

decisions. Currently, there is no representation of employees or other workers on administrative, management or supervisory

bodies.

The management of the Company is centred on the relationship between the Board of Directors and the Executive Committee.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 42

ÓRGÃOS SOCIAIS

BOARD OF DIRECTORS

EXECUTIVE COMMITTEE

AUDIT BOARD

Chairman

Ricardo Miguel dos Santos Pacheco

Pires

Members

Ana Teresa Cunha de Pinho Tavares

Lehmann

António José Pereira Redondo

António Quirino Soares

Dorival Martins de Almeida

Hugo Alexandre Lopes Pinto

João Paulo Cabete Gonçalves Lé

José Fernando Morais Carreira de

Araújo

Maria Isabel da Silva Marques

Abranches Viegas

Maria Teresa Aliu Presas

Mariana Rita Antunes Marques dos

Santos

Nuno Miguel Moreira de Araújo Santos

Sandra Maria Soares Santos

Vítor Paulo Paranhos Pereira

Chairman

António José Pereira Redondo

Members

António Quirino Soares

Dorival Martins de Almeida

João Paulo Cabete Gonçalves Lé

José Fernando Morais Carreira de

Araújo

Nuno Miguel Moreira de Araújo Santos

Chairman

José Manuel Oliveira Vitorino

Full members

Gonçalo Nuno Palha Gaio Picão Caldeira

Maria da Luz Gonçalves de Andrade

Campos

Alternate member

Marta Isabel Guardalino da Silva

REMUNERATION COMMITTEE

Chairman

Maria Eduarda Faria e Maia de Oliveira

Luna Pais

Members

Carlota Infante da Câmara Albergaria

Caldeira

João do Passo Vicente Ribeiro

OFFICERS OF THE GENERAL

MEETING

COMPANY SECRETARY

STATUTORY AUDITOR AND

EXTERNAL AUDITOR

Chairman

Rui Manuel Pinto Duarte

Secretary

Luís Nuno Pessoa Ferreira Gaspar

Full

António Pedro Gomes Paula Neto Alves

Alternate

António Alexandre de Almeida e

Noronha da Cunha Reis

KPMG & Associados - Sociedade de

Revisores Oficiais de Contas, S.A.

Represented by

Rui Filipe Dias Lopes, Statutory Auditor,

registered with the Association

of Statutory Auditors under no. 1715

Alternate

Vítor Manuel da Cunha Ribeirinho,

inscrito na Ordem dos Revisores Oficiais

de Contas sob o n.º 1081

ANNUAL REPORT 2024 • MANAGEMENT REPORT 43

DETAILS OF BOARD OF DIRECTORS

Members

Independence

6 Executive Directors

71.4 % non-independent

8 Non-executive Directors

28.6 % Independent

Gender

Average time on board

0.55 Average ratio of women to men (5:9)

5.7 years overall average, simple mean with extremes of 0

to 16 years

35.7 % Women

0 less than 1 year

64.3 % Men

10 between 1 and 5 years

2 between 5 and 10 years

Nationality

2 more than 10 years

93% Portuguese

7% Other

Average age

57.5 years

Age range

46 to 72 years

For more detailed information we refer to the Report on Corporate Governance Practices. Issues of sustainability governance are

addressed in Chapter 5.1.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 44

SKILLS MATRIX

Gender

Year of birth

Position Engineering

Economy

Management

Other

areas of

study

Business

Management

and

Administration

Governance

Mergers &

Acquisitions

International

Expansion Academic

Talent

Management

Research

and

Development

Information

Technologies

Sustainability*

Pulp

and

Paper

Energy

Industry

Ricardo

Pires

M 1976 Chairman

X X X X X X X X

X X X X

António

Redondo

M 1964 CEO X X X X X X X X X X X X X

Fernando

Araújo

M 1964 CFO

X X X X X X X

X X X

Nuno

Santos

M 1970 X X X X X X X X X X X

João Lé

M 1963

X X X

X X X X

Dorival

Almeida

M 1966

X X X X

X X X X X X X

António

Quirino

Soares

M 1974

X X

Ana

Lehmann

F 1972

X X

X X X

X X

Hugo

Pinto

M 1978 X X X X X X X X X

Isabel

Viegas

F 1958 X X X X X

Mariana

Marques

dos

Santos

F 1966 X X X X X X X

Sandra

Santos

F 1971 X X X X X X X X X X

Teresa

Presas

F 1952

X X X X X

X X

Vítor

Paulo

Paranhos

Pereira

M 1957

X X X X

X X

* Includes powers for overseeing strategy, management of impacts, risks and opportunities, good practices and certification on topics related to (i) Sustainable Forest Management and Biodiversity Conservation;

(ii) Climate Action and Energy; (iii) Water Management; (iv) Circular Economy; (v) People Management; (vi) Innovation, Development and Bioproducts; and (vii) Value Chain.

Table in context in section 16, Corporate Governance Report | Part I – Information on Capital Structure, Organisation and Corporate Governance

ANNUAL REPORT 2024 • MANAGEMENT REPORT 45

3.3. Risk management

Risk management is a crucial process in our business as it provides a structured approach for identifying, assessing and analysing

potential risk events that might influence the Group's objectives, as well as for identifying mitigation measures, so as to reduce

the likelihood of the occurrence of such events and the scale of their impact.

In 2023, in order to strengthen the company's risk management process, the Risk Management Department (DGR) reviewed

and implemented a new Enterprise Risk Management (ERM) framework in accordance with the COSO guidelines (Committee

of Sponsoring Organisations, Treadway Commission) and ISO 31000. The implementation of this framework involved the

participation of the - various Group departments, and it was initially rolled out for the UWF Paper and Pulp business lines. ERM

was extended in 2024 to the new business areas, in particular Tissue Paper and Packaging. This has brought improved alignment

with the Group's strategy and goals, as well as targeted and continuous monitoring of risks, with clear segregation of

responsibilities between those involved in the process.

The Risk Management Governance Model has also been improved, entailing a new Risk Management Committee which is

geared primarily to: (1) permanent monitoring of Group risks; (2) the need to empower the risk management process; (3) the

specific expertise needed in risk management; (4) coordination between the different risk management areas and subsystems.

Subcommittees (Commercial, Production, Capacity Building, Resilience and Reputational) have also been set up with the following

objectives: (1) to integrate and coordinate relations between risks; (2) to calibrate risk assessments and appetite levels; (3) to

monitor and push for risk mitigation; (4) to help think through the response to risk (expertise); (5) to support and implement

mitigation measures; (6) to report risk issues. A Risk Oversight Committee has also been set up to exercise oversight.

This risk management Governance Model is aligned with the IIA (Institute of Internal Auditors) Three Lines Model, which

involves: (1) in the first line, all business units responsible for conducting everyday risk management activities; (2) the second

line consists of the CEO, the Risk Management Department, the Compliance Unit, Empremédia (insurance brokers) and the

Sustainability Department, who are responsible for providing support in the implementation and monitoring of risk management

and the Risk Management Committee, in order to ensure that risks are identified and correctly managed on an ongoing basis; (3)

the supervisory line consists of the Internal Audit Office, the Audit Board and the Risk Oversight Committee, who ensure that the

first and second lines comply with the policies and standards adopted.

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Risk management process

Risk management in the Navigator Group is based on the Risk Management Policy, approved by the Board of Directors, which (i)

lays down the principles, guidelines and responsibilities for appropriate identification, analysis, assessment, treatment and

response to risks and (ii) ensures that risk management is consistent with the Group’s strategic goals, helping to promote a risk

management culture in the organisation.

The Group's risk management process is in line with internationally accepted best practices, models and frameworks for risk

management, including COSO II - Integrated Framework for Enterprise Risk Management and ISO 31000. This process comprises

a series of seven inter-related phases, which together comprise a process of ongoing improvement, embodied by a communication

and consultation process and a monitoring and review process. The following diagram illustrates the workflow for the risk

management process:

For more information on the risk management process, we refer to the Corporate Governance Report - Section C.III - Internal

Control and Risk Management.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 48

Main risks

The process of determining the main risks entails various stages, including: (1) analysis of internal and external context and

structuring of Group strategy and goals; (2) interviews with first line managers in order to identify risks; (3) analysis of

connections between risks; (4) sub-committee risk surveys; (5) attribution of risk owners; (6) definition of risk appetite levels; (7)

assessment of inherent risk; (8) definition of existing mitigation measures; (9) residual risk assessment; (10) risk matrix. The

main risks reflected in the risk matrix are updated each year.

At Navigator, risk management is a key strategic element for ensuring the organisation’s resilience and sustainability in the long

term. In 2024, the Company strengthened its commitment to incorporating ESG (Environmental, Social, Governance) concerns in

risk management, as established in our 2030 Roadmap. This serves to underline the strategic importance of ensuring that

environmental, social and governance risks are addressed pro-actively across the whole organisation.

Mindful of the growing significance of climate and natural risks for the future of business and the planet, and with the adoption of

new sustainability standards, incorporating the recommendations of the TCFD (Task Force on Climate-related Financial

Disclosures) and the TNFD (Taskforce on Nature-related Financial Disclosures), we have strengthened the integrated risk

management approach to material sustainability topics, enabling us not only to consolidate the integration of ESG dimensions, but

also to identify new areas requiring strategic attention. These resulted in the inclusion of a new risk in our Enterprise Risk

Management (ERM) framework: that of biodiversity conservation. This reflects the growing importance of preserving

ecosystems and the need to mitigate the impacts linked to environmental degradation, ensuring that our operations are

sustainable and that natural resources are protected.

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The Corporate Governance Report contains a brief description of the various risks included in the ERM tool, as well as the main

mitigation measures envisaged.

For more detailed information on the alignment between the Navigator Group's main risks and the material sustainability topics

identified, we refer to Chapter 5, Non-financial Statement.

3.4. 2030 Agenda and Roadmap

The Navigator Company's Responsible Management Strategy incorporates and highlights the Company's commitment to

Sustainability. As vigilant observers of the world around us, we periodically analyse major global trends and the principles

challenges posed to our business.

The Navigator Company has embraced an active role in developing a low-carbon and circular economy, both through sustainable

management of its forests, investment in renewable energy, and through its commitment to a forest-based bioeconomy, by

offering bioproducts able to substitute other fossil-based goods.

In its 2030 Responsible Management Agenda, Navigator has comprehensively and ambitiously embraced a commitment to

Sustainability, supporting and monitoring its performance through an ESG framework known as the 2030 Roadmap.

3.4.1. Global trends and challenges for Navigator

At The Navigator Company we remain committed to monitoring global developments and their implications, thereby refining our

strategy for operating successfully and sustainably in a scenario of uncertainty. We understand the importance of contributing to a

sustainable future, as a reference company in the national economic fabric and in the forest-based bioindustry. With a worldwide

value chain, we work continuously to keep up with and respond to the challenges of our sector.

Nowadays we face an increasingly complex and unstable reality, conditioned by strong geopolitical and financial tensions that

constantly test our Purpose. Whilst the uncertainties so characteristic of the current situation present challenges for companies,

they can also open doors to new opportunities. These challenging scenarios act as catalysts for innovation, where ambition,

dedication and resilience are essential for achieving concrete results with a lasting impact, directly influencing our capacity to

generate sustainable value over time.

The Global Risks Report 2025 published by the World Economic Forum (WEF) offers a comprehensive analysis of the challenges

which will shape the global outlook, highlighting the growing interconnection between geopolitical, environmental, social and

technological risks. It also stresses the need for international cooperation and innovative strategies for ensuring stability and

resilience.

This meant that our Responsible Business Agenda, or 2030 Agenda, was designed around an analysis of the main macrotrends

and challenges which could directly or indirectly impact the Company’s business, and an analysis of the relevance of the main

sustainability topics. In order to ensure that our 2030 Agenda remains up to date and responds to a constantly changing scenario,

we have been reviewing these premises - in 2024 we conducted a review of the double materiality analysis (Chapter 5.1) which

resulted in adjustment to the material topics, and in early 2025 we reviewed the main macrotrends and challenges, in the light of

global sustainability trends. The following figure illustrates the process of designing Navigator's 2030 Agenda.

It concludes that, in general, the macrotrends and challenges identified in previous years remain relevant, even if it might make

sense to update the respective descriptors so as to reflect the current context.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 52

Below we present the most relevant macrotrends shaping the scenario in which we operate.

Macrotrends identified as relevant

PLANET AT THE LIMIT DEMOGRAPHIC CHANGE

TECHNOLOGICAL

INNOVATION

DISRUPTION OF SOCIAL

COHESION

GEOPOLITICAL

AND ECONOMIC

INSTABILITY

Existential threats to the

Earth and human life,

biodiversity loss and climate

change all point to the

planet's limits, both in the

short and long term.

The scarcity of resources,

deforestation and pollution

accelerate degradation of

the environment and the

emergence of zoonotic

diseases (epidemics and

pandemics), of which Covid-

19 is the most recent

example.

Increasing temperatures and

the imbalance in the

terrestrial system leading to

more frequent and more

severe climate phenomena

will bring suffering and

migration, resulting in costs

and economic losses.

Increasingly severe water

stress may affect two thirds

of the world population by

2025, and generate

geopolitical conflicts over

access to water.

Soil and land degradation

will have a material impact

on farming in many regions.

Air quality will remain a

concern in many cities, with

severe consequences for

public health.

Critical changes in terrestrial

systems have been

identified by the WEF as the

third most severe global risk

within a horizon of 10 years.

The world's population is

growing, ageing and

increasingly urbanised.

Demographic changes

increased involuntary

migratory flows and the

growth of megacities puts

additional pressure on

natural resources.

Demographic factors are

impacting economic

development, due to both

the ageing of the

population, and

intergenerational

differences.

The inversion of

demographic pyramids in

some parts of the world

may lead to the failure of

social security systems

and the need for older

generations to stay in

work.

As power shifts from baby

boomers to millennials and

Generation Z, reflecting

different experiences and

perspectives, companies

will be challenged to stay

relevant in their purpose,

and to invest more and

take greater care of their

human capital, on which

their ability to compete

depends.

New technologies, such as

digitalisation, automation,

Artificial Intelligence (AI),

Blockchain and BigData

will allow companies to

accelerate and expand

their positive impact on

sustainable development

of the economy and

society.

Key technologies in

different areas - from

biotech to renewable

energy - will undergo

exponential development.

New technology has

implications for the future

of work. New jobs will be

gained, but old jobs will be

lost, which entails learning

new skills, and refreshing

the old.

The risk of growing digital

inequality in access to

networks and critical

technologies.

Greater dependence on

cybernetics and data

systems.

Added vulnerability to

cyber attacks. The risk of

new levels of data

snooping and manipulation

in the service of profits

and power.

According to the WEF, the

risk of disinformation and

misinformation is the most

severe global risk in a time

horizon of 2 years.

Within a timeframe of 10

years, the adverse effects

of AI is one of the most

severe global risks.

Increasing social divisions,

uncertainty and anxiety.

Increased inequality within

and between countries,

together with the erosion of

trust in institutions, is fuelling

a wide range of protest

movements, and could

potentially lead to polarisation

of domestic politics, populist

and nationalist sentiment and

authoritarian regimes.

Feelings of anxiety, depress,

loneliness and stress, in

response to the pandemic and

an uncertain future, can

undermine social cohesion.

Rising inflation, loss of

purchasing power and

structural deterioration of job

prospects and/or living

standards for people of

working age could lead to

crises in employment or

livelihoods, and to the erosion

of employment rights.

Differences in access to

technology and digital skills

increases the risk of the gap

between "rich" and "poor",

challenging social cohesion.

Geopolitical instability,

economic downturn, shifts

in power and consequent

move away from

multilateralism.

Trade tensions will

probably remain a feature

of the geopolitical scene

for the rest of the decade.

The centre of gravity in

the global economy is

shifting to Asia, but also to

Africa and Latin America.

Nationalisation of

resources and competition

between states for control

of vital raw materials will

potentially become an

increasingly important

factor in international

relations, with a

consequent impact on

supply chains, which will

tend to shorten.

Higher interest rates,

together with a drop in

earnings in real terms, are

leading to economic

recession.

Economic recession,

inflation, erosion of social

cohesion, manpower

shortages and public debt

are the main risks

identified by Portuguese

business leaders in WEF’s

2024 Executive Opinion

Survey.

Armed conflict has risen

up the list and is identified

by the WEF as the third

most severe global risk

within a horizon of 2

years.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 53

This context is reflected in a series of challenges that are posed to Navigator's business, identified in a process that involve

participation by external and internal Stakeholders, as detailed below: (i) Protect and value biodiversity; (ii) Climate mitigation

and low carbon economy; (iii) Sustainable consumption; (iv) Circular economy; (v) Tech for Good; (vi) the Future of Work; (vii)

Investment in human capital; (viii) Protection of fundamental rights; (ix) Resilient and sustainable value chains; (x) Participation

in the adaptation of the regulatory framework; and (xi) Stakeholders Capitalism.

The design process for Navigator's Agenda 2030 is represented in the following figure:

The structure of our 2030 Agenda, how it responds to the global challenges identified and how it contributes to the SDGs is

presented in detail further on (Chapter 3.4.5).

3.4.2. Our Agenda

The Navigator Company's 2030 Responsible Management Agenda is based on the principle of “Creating Value Responsibly”

and was developed to boost the company’s positive impact in the long term, contributing to sustainable growth, aligned with the

demands of a constantly changing world. In order to manage it, we established a strategy anchored in a governance structure

that promotes economic success in a fair and balanced way, taking account of our Stakeholders’ interests and encouraging them

to cooperate (Chapter 3.4.5).

Our management is anchored in the principles of Ethics, Responsibility and Transparency. Faithful to our Purpose - centred on

people, their quality of life and the future of the planet - we accept our responsibility for forest-based products that promote

sustainable development and the well-being of society, in full alignment with the United Nations 2030 Agenda (Chapter 3.4.3).

ANNUAL REPORT 2024 • MANAGEMENT REPORT 54

We have adopted a stance focused on long term value creation, by strengthening performance, business resilience and our

corporate reputation, while making sustainability a strategic competitive advantage (Chapter 2.3).

In order to ensure that our efforts are focused on the areas with the greatest impact, we conducted a review of our double

materiality analysis (Chapter 5.1), identifying Impacts, Risks and Opportunities. This process led to the definition of 11 material

topics and consequently to updating the 2030 Agenda, which remains structured around two strategic action areas- for the

Climate and Nature, and for Society-, each one with a specific purpose and aligned with the two dimensions of our purpose,

People and the Planet.

Strategic Axes of the 2030 Agenda

For Climate and Nature - Acting: Preserving and enhancing natural capital, thus generating economic, environmental and

social value by minimising the ecological footprint and optimising efficiency in the use of resources; Contributing to a circular and

low-carbon economy based on innovation, technology and R&D.

For Society - Grow: Apply ethical principles, demonstrate integrity and transparency in everything we do, manage risk, promote

respect for human rights and make commitments to our Stakeholders; Develop our people, involve communities and share value

with society in a fair and inclusive way.

The Navigator Company’s 2030 Agenda Material Topics

The material topics of the 2030 Agenda have only undergone minor adjustments in name and scope as a result of the double

materiality review conducted at the end of 2024 and to more clearly reflect their link to the ESRS standards, while remaining

stable in their essence and thematic focus. The table below illustrates this interconnection between the standards and our 11

material topics:

ESRS THEMATIC STANDARDS MATERIALS Material Topics - 2030 AGENDA

Environmental Issues

E1 – Climate change

E3 – Water and marine resources

E4 – Biodiversity and ecossistems

E5 – Resource use and circular economy

Social Issues

S1 – Own workforce

S2 – Workers in the value chain

S3 – Affected communities

Governance Issue

G1 – Bussiness conduct

Climate and Nature strategic area (5 material

topics)

• Climate Change

• Water Management

• Use of Resources and Circular Economy

Biodiversity Conservation

• Sustainable Forest Management (*)

Society strategic area (6 material topics)

• Inovation, Tecnology e R&D

• People, Talent, and Human Capital Development

• Health, Safety and Well-being

• Community Relations

• Supply Chain Management

• Responsible Business Conduct

(*) Entity-specific disclosures

ANNUAL REPORT 2024 • MANAGEMENT REPORT 55

The material topics for Navigator, according to the strategic areas of the 2030 Agenda, are presented below.

For Climate and Nature: Acting

Climate Change

As an industrial undertaking, we are aware that our activity, through our own operations and those along our value chain, have an

impact on consumption of natural resources, with consequent atmospheric emissions, generation of odours, liquid effluents, waste

and other issues. These include greenhouse gas (GHG) emissions with potential negative impacts on the environment and on the

worsening of the effects of climate change. The consumption and production of energy is a highly important topic in the context of

operational performance and management of Navigator’s resources, representing simultaneously significant costs and income,

and an important share of the total GHG emissions generated.

On the other hand, our forest operations make a positive contribution to sequestering carbon. It should be stressed that, of all

Portuguese forest species, eucalyptus is that which sequesters the most CO

per hectare, in each year of growth. The figure for

ANNUAL REPORT 2024 • MANAGEMENT REPORT 56

eucalyptus stands is 11.3 tons of CO

/hectare per year, almost three times more than woodlands of maritime pine (3.9 tons of

/hectare per year) and seven times more than cork oak woodlands (montado) (1.6 tons of CO

/hectare per year)

In the field of climate risks, a project has been in progress since 2022 to implement the recommendations of the Task Force on

Climate-related Financial Disclosures (TCFD). The aim is to be able to integrate the TCFD recommendations into corporate

strategy and risk management processes, seizing the opportunity to assess the potential financial and strategic implications of

climate change and to develop appropriate responses.

Our commitments on climate change and energy topics are set out in our 2030 Roadmap (Chapter 3.4.4), and envisage:

• Promoting efficient use of resources, minimising our ecological footprint, with the aim of optimising energy intensity, year

after year;

• Investment in low carbon solutions leading to carbon neutrality, with the aim of cutting GHG emissions from operations in

Portugal (by 2035) and increasing renewable energy as a proportion of total consumption of primary energy in 2030;

• Promote sustainable use of soil and forest resources, including biodiversity, with the aim of ensuring that the CO

stock

sequestered in Navigator’s forest holdings in Portugal does not decrease more than 10% from its 2022 level.

We develop and incorporate technologies and practices geared to environmental protection and prevention of atmospheric

pollution, in compliance with the applicable legal requirements and best practices.

Since 2019, we have voluntarily adopted a roadmap to carbon neutrality, reflecting our ambition of decarbonising the

industrial complexes in Portugal by 2035 (ETS – European Emissions Trading Scheme emissions).

We took our commitment to cutting CO

emissions further by signing up to the Science Based Targets initiative (SBTi), and

securing approval of the targets submitted in 2022. This global organisation, respected internationally for its assessments of

initiatives taken by companies towards a low-carbon economy, has validated our science-based climate targets as a "key element"

in Navigator's decarbonisation journey towards net zero. The new reduction targets (detailed in the next section) now include

scopes 2 and 3 in the Company’s inventory of carbon emissions in Portugal, as well as extending the other scope 1 emissions, and

were set taking 2020 as the baseline (date of our first full emissions inventory).

As well as helping to mitigate climate change, our decarbonisation plan has a positive impact thanks to the use of waste forest

biomass to produce energy, reclaiming this resource and protecting forests against fires. Another positive impact comes from

the generation of power from renewable sources. We are phasing out consumption of fossil-based energy and replacing it

with less carbon-intensive energy sources, and investing in photovoltaic solar power, which generates power for internal

use, cutting our energy costs.

As a bioindustry on the right side of the future, based on the eucalyptus sector and the pulp and paper industry, we promote a

forest-based bioeconomy with potential positive impacts.

It is important to note that CO

sequestered by trees during the photosynthesis process is transformed into biogenic carbon,

which is stored in wood fibres and consequently in forest-based products, such as pulp and paper. Sustainable management

of our forests accordingly boosts this positive impact.

In Mozambique we can also point to our contribution to storing carbon, above all on two fronts, in planted forests and through

preservation of conservation interest forests. Steps have also been taken to reduce emissions, such as through conservation

Calculations made on the basis of “Inventário Florestal Nacional 6”, published by Instituto de Conservação da Natureza e das Florestas (2015), considering all types of

stand (pure, dominant and irregular) and for all biomass components.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 57

farming techniques that mitigate the effects of nomadic farming, raising awareness of the need to reduce use of broadcast burns,

among other activities under the Social Development Programme (Chapter 5.3.3).

In addition, we seek to develop processes that enable us to capture carbon in the production process and we invest in the

search for bioproducts and innovative solutions (Chapter 3.4.4), developed in partnership with different entities, in line with

current climate science, taking an active role in developing a circular and sustainable bioeconomy which is Nature-positive and

Climate-neutral.

Our efforts in this were rewarded in 2024 with our classification as a climate action leader and an “A” rating from CDP Climate

Change.

Water Management

At The Navigator Company, we use water resources throughout our operations, from forestry through to manufacturing. We

recognise that rainfall patterns in the Iberian Peninsula have changed in recent years and so the water scarcity index in the

various Hydrographic Regions where the Company operates has worsened, especially south of the Tagus. We are closely

monitoring the impact of climate change on water resources, assessing the effect it may have on business continuity. It is

important to note that we are involved in the design of the Hydrographic Region Management Plans (HRMPs) in the areas where

our plants are located in Portugal, with representation on the Hydrographic Region Boards. In addition, we follow the findings of

studies assessing water availability, both at present and in the future, determining the scarcity index per basin and sub-basin.

We have identified several water-related risks to industrial and forestry operations, such as physical risks (acute and chronic),

such as droughts, water shortages, water stress, floods, saltwater intrusion and rising sea level, as well as transition, regulatory

and technological risks. The main risks occur both in our supply chain and in our own use of the resource.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 58

We also analyse the financial impact of climate risks on water management in connection with the project to implement the

recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) (Chapters 5.2.2 and 5.2.3).

We believe it is imperative that our activities should not, in themselves, constitute an additional risk factor for the environment

and local Communities, and water management is one of the key issues discussed on the Community Monitoring Committees,

whose contributions we incorporate in the design of water plans and measures, in particular the development of our Water Use

Reduction Programme.

We have several mitigation and adaptation measures implemented and in progress, in order to address the risks identified

and to cut use of this vital resource.

Our commitment to responsible management of water resources considers the quantity withdrawn, but also the quality of the

water discharged. Our 2030 Roadmap (Chapter 3.4.4) therefore contains the following objectives in relation to industrial

operations in Portugal:

• Promotion of efficient use of resources, minimising our ecological footprint, with the aims of studying the potential

for reducing water consumption at the Espirra nurseries, monitoring the impact of production forests on water

management, reducing specific use of water and reducing the organic load in effluents.

In relation to Mozambique, the aims of monitoring the impact of production forests on water management are part of the plan for

the next three years.

It should be noted that the water used in industrial production processes is drawn not just from intakes, but also from the raw and

subsidiary materials, including wood and chemicals. The water used is returned to nature in the form of water vapour and treated

effluent, but wastes, products and by-products also contain significant volumes of water.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 59

Use of Resources and Circular Economy

Planted forests play a crucial role in the transition from a linear economy, dependent on fossil fuels, to a circular bioeconomy low

in fossil carbon. This transition is supported by renewable, recyclable and biodegradable forest products, bringing benefits for

nature and contributing to carbon neutrality.

4. The wood we use at The Navigator Company is sourced from sustainably managed forests (Chapter 5.2.6). This is

processed into various types of paper products which, after serving their purpose, are collected and recycled, becoming a

raw material once more Fibre from the Eucalyptus globulus we plant in Portugal is recognised as suitable for recycling

over a larger number of cycles than its competitors. A comparative analysis conducted by RAIZ, our forest and paper

research institute, has proven that this species can be recycled over ten cycles - six more than for other paper fibres

5. We are therefore positioning ourselves as a strategic player, investing in Research, Development and Innovation (RDI)

projects for implementing the best available techniques for the sector and looking for bioproducts and innovative

solutions, developed in partnerships with a variety of organisations (Chapter 3.4.2).

6. Our 2030 Roadmap (Chapter 3.4.4) reflects the importance of using these resources and promoting the circular economy,

through a range of commitments and goals. In relation to raw materials and waste, our main focus has been on:

• Promoting efficient use of resources, minimising our ecological footprint, proposing solutions that make for greater

efficiency in the use of wood in the industrial process;

• Promoting the circular bioeconomy, prioritising R&D solutions. The aim here is to develop sustainable applications

that add value to industrial by-products (sludges, fly-ash and other inorganic waste) and to achieve, by 2030, a rate

of waste disposal in industrial landfill of less than 10%.

7. We invest in solutions that promote efficient and responsible use of raw materials, energy (Chapters 5.2.2 and 5.2.2)

and water (Chapter 5.2.3), as well as reduction and recovery of the waste generated. Our ultimate aim is therefore to

reduce the environmental impact of our operations, fostering continuous improvement of our performance and

contributing to a low fossil carbon circular economy.

8. The production process used by the Company since its founding, the kraft process, is based on the fundamental

principles of the circular economy, in which the secondary flows of materials generated in producing pulp and cyclically

reused, minimising the use of virgin raw materials:

• The sodium-based chemical compounds used in cooking wood for producing cellulose are recovered on-site in what is

called the sodium cycle;

• After cooking, these compounds continue in a flow called black liquor, rich in lignin, which is used in turn to produce

sufficient thermal energy for the pulp production process and electricity, which is sold to the national grid;

• In order to recover the sodium based compounds, other calcium based compounds are used, and these are likewise

recovered after use on site, in another parallel cycle, known as the calcium cycle.

9. Taking advantage of the potential for circularity inherent in the process, we invest continuously in closing circuits and

optimising the use of resources, prioritising reduction of waste production, as well as recycling and reclamation.

18 Info Tecnicelpa nº 54, pages 30 and 31 - https://www.tecnicelpa.com/files/Info54_marco2018.pdf

The target set is not a legal requirement; it was set voluntarily, like the other targets in our 2030 Roadmap.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 60

10. We have adopted technological solutions that enable us to reincorporate waste in production processes, or to

reclaim waste internally, in particular in energy production. Solutions of this type make it possible to minimise the use

of virgin raw materials, and also to minimise wastage and effluent loads (Chapter 5.2.5). Because the vast majority of

waste is generated in pulp production operations, we have invested in improvements in the efficiency of treatment

processes and systems, cutting production of this waste to minimum levels.

11. Our efforts to promote the circular economy have been leveraged by the Corporate Upcycling Project, and by

investment in RDI projects and in establishing partnerships and synergies, which has enabled us to implement

technological solutions such as:

• Use of flue gases for capturing CO

, which is used in producing precipitated calcium carbonate (Chapter 5.2.2);

• Reinforcing on-site circularity of carbonate sludges produced at the Figueira da Foz Industrial Complex, which are

used in producing calcium carbonate;

• Optimisation of chemical recovery cycles at paper pulp production units;

• Minimising production of biological sludges, through incorporation in black liquor evaporation, obtaining energy from

its organic content in the Recovery Boiler at the Figueira da Foz Industrial Complex;

• Use of sands from Biomass Boilers (by-product) as substitute for sands from natural sources used in construction

materials (e.g. mortars, aggregates, pre-cast concrete). In addition, the recovery and reuse of water is also part

of the circularity of our production process, and most of the water used is returned to the environment in the form of

treated effluent (Chapter 5.2.5).

ANNUAL REPORT 2024 • MANAGEMENT REPORT 61

Biodiversity Conservation

Within the assets under our management in mainland Portugal we manage woodlands classified as Conservation Interest Zones

(CiZ), which serve as an important habitat for a diverse range of flora and fauna, including species with varying conservation and

protection status. These areas are accordingly managed for conservation purposes only. These zones also include Areas of High

Conservation Value (AHCV), an exclusive concept of the FSC

certification scheme, which enjoy special safeguards in view of

the presence of environmental, social and cultural heritage of exceptional value.

It should be noted that our pro-biodiversity approach is not applied only in CIZs. This work is carried out across all our holdings,

and the plans for each forestation/reforestation project define from the outset the conservation areas to be protected.

In this way, we have pursued a planned strategy of biodiversity conservation and promotion since 2008, with the aim of

conciliating production aims with conservation, whilst also responding to forest certification indicators. We have developed a no

net loss strategy, meaning that there will at least be no biodiversity loss as a result of our activities, or, whenever possible, we

will create a net positive gain in the biodiversity present on our holdings and in its state of conservation.

The Company's activities apply the best management practices based on the Habitats and Birds Directives and the guidelines of

the National Network of Protected Areas, which aim to protect or improve the conservation status of habitats and species with

relevant conservation status.

We invest continuously in monitoring and assessment, active protection and conservation (such as rehabilitation or

restoration or natural habitats and ecosystems), benefiting species that use them for their ecological functions of feeding,

shelter or breeding. These also serve as ecological corridors, enabling species to disperse naturally and permitting genetic

interchange between populations.

To support this strategy for conserving biodiversity, we have Biodiversity Assessment Techniques Manuals (BATM) and field

reports on monitoring and conservation, as well as Conservation Action Plans (CAP), with contributions from experts. The

approach we use means we enjoy access to a significant set of data on relevant wildlife to be preserved in the territory, also

enabling us to identify, avoid, mitigate and minimise negative impacts (direct or indirect) on biodiversity, as well as to boost the

positive impacts.

We were one of the original signatories of the act4nature Portugal initiative organised by BCSD Portugal, for which we sit on

the Advisory Board. Set up in 2020, this initiative sets out to mobilise and encourage companies to protect, promote and restore

biodiversity and ecosystem services, helping to halt and reverse their loss by 2030, leading to better integration of natural capital

into companies' business models and value chains.

Another development was the visit by the Wildlife Conservation Society (WCS) to forest holdings managed by the Company, in

order to show how we conserve biodiversity in mainland Portugal, continuing the exercise in sharing experiences that started in

Mozambique. This was an opportunity to discuss the lessons learned and approaches that could improve our current processes,

under the COMBO+ Programme (Chapter 5.2.4).

Sustainable Forest Management

We are aware of the environmental and socio-economic impacts of our operations. Despite the impacts that forest

plantations in which one species predominates can have on the environment, like any other human activity, there is growing

recognition that responsible and balanced management of planted forests, such as that practised by Navigator, can play an

ANNUAL REPORT 2024 • MANAGEMENT REPORT 62

important role in the planet’s sustainability - by protecting soils and water, improving air quality and mitigating climate change

(Chapter 5.2.6), among others.

There may be negative impacts for Local Communities, as a result of operations in the field, such as damage to public

infrastructure, caused by the use of machinery and vehicles. However, we should also stress the positive impacts generated by

our operations, as forests and forest-based products make a positive contribution to the economy and to society, by generating

income for landowners, encouraging the management of other woodlands and areas, for farming and pasturage use, as well as

local economic activities associated with forests, such as grazing and bee-keeping.

In view of the importance of forest management and biodiversity conservation to our operations and business model, our 2030

Roadmap (Chapter 3.4.4) lays down three commitments:

• Ensure sustainable use of soil and forest resources, including biodiversity. Our goals include: contributing to a

reduction of rural fires, aiming to keep the burned area under Navigator's management at below 1% each year, and

creating a positive impact on biodiversity (or net gain), through conservation work in line with the Company’s

strategy and the commitments made through act4nature Portugal.

• Ensure that all wood is obtained from credible sources (FSC

or PEFC certification schemes, or controlled origin). Our

goals involve: promoting certification of the chain of custody of all our wood Suppliers by 2030, and ensuring that the

wood consumed by the Company comprises 80% certified wood by 2030.

• Provide a safe and healthy environment for workers, guaranteeing their welfare, including the aim of providing OHS

(Occupational Health and Safety) training on a continuous basis in forest operations, for service providers, Suppliers

and operators in the sector, seeking to provide more than 600 hours of training each year.

Our business model is therefore based essentially on sustainable forest management, with a strong commitment to

certification, prioritising renewal and improvement of forests and protection of natural, social and cultural heritage. Also

fundamental is respect for the rights of workers and Local Communities, along the value chain. In order to mitigate the negative

effects of our activities, we systematically identify and assess the environmental and social impacts of forest activities, resulting in

the matrices used during the planning and execution of operations, enabling us to avoid negative impacts or to adopt the

appropriate measure when these impacts occur. In the course of this assessment we also consult local Stakeholders, such as the

Local Community and/or specialists in the different natural, social and cultural factors under assessment. The communication

channels that affected Stakeholders can use, for remediation of the negative impacts of these operations, include The Navigator

Company's official website and the whistleblowing channel.

They can also make representations in person to the Company’s staff, or else send an email or telephone. In Mozambique, an

important role is also played by the Community Liaison Officers (Chapter 5.3.3). We anchor our work in creating and sharing

knowledge and in establishing partnerships along the value chain - with Forest Landowners and Forestry Associations, Business

Associations, Suppliers, Local Authorities and other Community bodies.

We invest in support programmes which promote sustainable and certified forest management, supporting forest landowners

outside the areas under our direct management. These programmes incentivise good practices, conservation of natural and socio-

cultural heritage, and reinforce forest fire prevention and defences, mitigating their significant impacts on ecosystems, the

Group and our Stakeholders.

Sources:

“Substitution Effects of Wood-based Products in Climate Change Mitigation”, Leskinen et. al, 2018, TIG Analysis:

https://efi.int/sites/default/files/files/publication-bank/2019/efi_fstp_7_2018.pdf

– FAO 2016.Forestry for a Low-Carbon Future: Integrating Forests and Wood Products into Climate Change Strategies, FAO Forestry Paper 177, Rome, Italy.

https://researchrepository.murdoch.edu.au/id/eprint/66391/1/I5857E.pdf

ANNUAL REPORT 2024 • MANAGEMENT REPORT 63

The responsible forest management that we promote includes investment in conservation of biodiversity and of ecosystem

services. Healthy ecosystems are fundamental for well-being, health, job creation and community livelihoods, ensuring that their

needs are met. The important supporting role played by biodiversity in the balance of Nature means that conserving biodiversity is

an important contribution to mitigating and adapting to the effects of climate change.

We also attach great importance to the more visible aspects of Navigator's active policy in wildlife conservation, consisting of

public information and awareness raising initiatives, through which we share our experience and case studies in our own

publications, editorial projects and events for the media and different Stakeholder groups. Our work with forest operators

encompasses technical issues relating to know-how transfer on topics related to eucalyptus husbandry, planning of forest

operations, information management (geographical information systems (GIS), document systems and data bases) and decision

making, as well as dissemination of information on occupational safety and biodiversity conservation.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 64

For Society: Grow

Responsible Business Conduct

Our business and the standards of good conduct we have adopted respond to the ever more exacting criteria set by our

Stakeholders - both internally and in interactions with external stakeholders. The key values that guide our operations are Trust,

Integrity, Enterprise, Innovation, Sustainability and Excellence, and these underpin the various policies, codes and regulations

established to assure the good practices associated with our operations and business.

In order to foster ethical business conduct on the part of the Group and its Stakeholders, Navigator has a Compliance System

which is designed to ensure that the applicable legal requirements are met, especially as regards anti-corruption rules,

prevention of money laundering and terrorist financing, compliance with international sanctions, conflict of interests, protection

of Human Rights and protection of personal data.

Navigator has a policy of zero tolerance in relation to any breach of the legal or regulatory rules in force on these matters. To

this end, it undertook several projects in 2023 in order to consolidate ethical, transparent and socially fair conduct, based on

the ethical principles adopted.

In order to prevent and mitigate the risks inherent in our dealings with third parties, Navigator has implemented a series of

Compliance Policies, consisting of a Third Party Vetting Policy, a Compliance with International Sanctions Policy and an

Anti-

Money Laundering and Counter Terrorist Financing (AMLCTF).

These Compliance Policies lay down general principles for Navigator’s actions in its dealings with Investors, Employees,

Suppliers, Customers and Partners, and the forms of conduct which are expressly prohibited in the relations it establishes in

the course of its business. They also define measures for preventing these risks through appropriate due diligence procedures,

in order to assess the risk of criminal activity and the integrity of Navigator's counterparties.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 65

Attention is also drawn to the review of our Code of Ethics and Good Conduct, the Code of Conduct for Suppliers and the Code

of Good Conduct for Preventing and Combating Workplace Harassment, so as to harmonise them with the new documents

adopted.

Navigator regards Employee training as essential in order for these policy documents to be correctly implemented, with a view

to promoting a Compliance culture based on ethics and integrity. For this purpose it offers training courses in Compliance

issues, in particular concerning the Code of Ethics and Conduct, Internal Policies, Whistleblowing, Prevention of Corruption

and Related Offences and Protection of Personal Data.

Innovation, Technology and R&D

We believe that scientific knowledge, people with talent and expert skills, combined with innovation and technology, offer a

promising foundation for a sustainable future. These are the prerequisites for developing biobusinesses and a new array of

Portuguese industries that aspire to making a difference, by creating economic value in harmony with the Climate and Nature.

Innovation and technology, firmly anchored in Research and Development (R&D) activities, are the foundation of Navigator's

business, ensuring that its products and processes are sustainable.

Creating Value Responsibly, the central concept in our 2030 Agenda (Chapter 3.4.2), presupposes designing and putting in

practice solutions that create sustainable value and competitiveness in the long term. In our 2030 Roadmap we have therefore

accepted the following commitments:

• Develop adaptive forest practices, from a climate change perspective;

• Develop innovative, competitive and sustainable products;

• Develop sustainable bioproducts, reducing dependence on fossil resources and working towards a decarbonised

economy;

• Promote scientific and technological co-creation in the field of the bioeconomy and bioproducts.

Mindful of the importance to its operations of scientific and technological expertise, Navigator took a pioneering step in Portugal in

1996 of setting up its own R&D centre in partnership with three Portuguese universities. This was RAIZ, our Forest and Paper

Research Institute.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 66

The science generated at Portuguese universities, in the field of biotechnology and the bioeconomy, has underpinned lasting

partnerships that we are eager to carry forward. Our commitment to working collaboratively involves not only Stakeholders in

the Portuguese science and technology system, but also international partners and leading players in our industry.

In order to advance our RDI activities, we therefore take part in networks and consortia, submitted applications to funds and

external financing programmes (in Portugal and abroad), in addition to our own investment in this field. The knowledge resulting

from these activities has a real economic impact, that can be seen in the creation of innovative and distinctive products, in

addition to new technology and services. By supporting the work of a wide team of researchers, technicians and bursary holders,

we are able to contribute to postgraduate training in Portugal and to generating jobs in science. We encourage the creation of

intellectual property and scientific publications in the fields of forestry, pulp, paper and forest-based biorefineries. We also

place this expertise at the service of society, through forest literacy programmes, as exemplified by RAIZ’ “Forest of Knowledge”

(“Floresta do Saber”) Project.

In structural terms, our financing policy provides us with sound and consistent foundations for gradual implementation of projects,

enabling us to act systematically in advance of programmed events. We have also been willing to work in partnerships, submitting

funding applications to leverage the transition to a low-carbon economy and to the bioeconomy, thereby boosting our contribution

in this area.

We have pressed ahead with the digital transition and adoption of Artificial Intelligence (AI) in order to boost efficiency, innovation

and sustainability, working on more than 30 projects that integrate AI, machine learning and robotics, with an impact on cost

reduction, process optimisation and improved productivity.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 67

In the industrial sector, machine learning models have been used to make progress in managing consumption of wood and

chemicals, reducing waste and complying with quality parameters. These strategic projects have included optimisation of logistical

management and implementation of Advanced Process Control (APC) solutions in the pulp sector, improving quality, process

stability and consumption of chemicals.

In the UWF segment, we have developed Advanced Analytics models to control excess grammage and variability in whiteness,

cutting consumption and waste. In the Tissue segment, we have created a tool for optimising paper grammage, minimising

variability and fibre consumption. In forestry, we are moving ahead with projects to facilitate access to raw material.

With a focus on employees, we have also invested in automation using GenAI, promoting automation of tasks, risk mitigation and

improvements in productivity and team motivation. Examples include the Generative AI model with interactive chatbot for

responding round the clock to employee queries, automated processing of environmental data and adoption of centralised

platforms for client and supplier interactions.

People, Talent and Human Capital Development

O capital humano representa uma prioridade para a Navigator, e nele temos investido de forma sistemática, com vista a promover

o seu desenvolvimento, evolução e o sentimento de realização dos nossos Colaboradores. Exemplo de que a Gestão do Talento é

uma das nossas prioridades, é o facto do pelouro se encontrar sob a responsabilidade direta do CEO da The Navigator Company e

por sua vez, o pelouro de Recursos Humanos estar sob a alçada de um membro da Comissão Executiva.

A importância estratégica do tema prende-se com o papel decisivo que os nossos Colaboradores têm na Empresa – para o futuro

e sustentabilidade do negócio –, assim como pelo número de empregos que asseguramos, como parte do nosso impacto social e

económico junto das Comunidades locais onde operamos. A gestão dos nossos Colaboradores assenta na estabilidade dos vínculos

laborais, no reconhecimento e valorização do mérito, no crescimento interno e no desenvolvimento de competências, ao longo da

carreira, para além do investimento na promoção da sua segurança, saúde e bem-estar (Cap. 5.3.1).

In our 2030 Roadmap (Chapter 3.4.4), we establish the following

commitments in relation to talent management and developing human

capital:

• Promote development and upskilling of human capital in

line with the Company's present and future needs;

• Contribute to the skills and employability of young people

in the regions where we operate;

• Promote an inclusive organisational culture able to

integrate internal and external challenges.

It should be noted that, in the field of talent management, we seek

whenever possible to adjust and align practices in the different

geographical regions where we operate; this has been finalised in

relation to Mozambique. In the case of Ejea (Spain) and the United

Kingdom, the subsidiaries are in the process of transition and alignment

of policies and practices, as a result of the acquisitions made in 2023

and 2024 respectively.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 68

Health, Safety and Well-being

Aware that the risks involved in our operations include the possibility of accidents at work and occupational diseases, we have

made a firm commitment to the quality of life of our Employees, investing continuously in a safe and healthy environment, to

ensure their well-being. Such incidents can be potentially life-changing for our Employees and their families, and also damage

the Company’s reputation and competitiveness, potentially compromising our strategic goals.

It is our responsibility to create an Occupational Health and Safety (OHS) culture which enables us to make a sustained

reduction in the probability of these events occurring and thereby eliminate both accidents at work and occupational diseases. By

conducting our business in a responsible way, we can not only cut the Company’s costs, but also minimise risks to people,

Workers in the value chain, Communities and the environment (especially those resulting from the Company’s industrial units and

forest operations) as well as contribute to the continued good state of our facilities and plant.

Our 2030 Roadmap (Chapter 3.4.4) reflects the importance of this topic, through the commitment to providing workers with a

safe and healthy environment in order to ensure their well-being, which takes material form in a series of goals established for

Portugal:

• Achieve the Target of “Zero Accidents” through continuous improvement to safety, attaining a frequency Index of ≤2 in

2030 (internal and external Employees);

• Develop the Occupational Health programme up to 2030;

• Reduce the number of uncharacterised accidents due to non-compliance with rules and procedures;

• Organise ongoing training courses in Occupational Health and Safety in forest operations for service providers,

suppliers and operators in the sector.

In Mozambique, the plan for the years ahead features the aim of reducing the frequency index for accidents at work.

Community relations

The Navigator Group has a significant presence in several regions, through our industrial operations, as well as our forest

operation in Portugal, Galicia (Spain) and Mozambique.

In line with our purpose (Chapter 2.1) we have accepted a responsibility to find ways to share value with our Stakeholders

(Chapter 3.4.5), and especially with Local Communities. These have a crucial role to play in relations with companies, as they are

the first link in the chain to feel the impacts, positive and negative, of our forest and industrial operations.

We accept our social responsibility, contributing to progress and the welfare of the communities where we operate, in alignment

with the Code of Ethics and Good Conduct. We have likewise formally adopted and implemented a Human Rights Policy, which

sets out our commitment to acting in such a way as to respect Human Rights in Local Communities, including, where applicable,

indigenous peoples, adopting measures to minimise negative impacts, and to protect their values, culture and traditions. This

Policy also establishes a commitment to promoting Community engagement in order to obtain feedback on Human Rights and

labour rights issues, recognising the importance of listening and ongoing dialogue in order to incorporate local concerns in our

internal decision-making processes (Chapter 5.4.1).

An important tool in this is the Whistleblowing Channel (Chapter 5.4.1), available on the website for any member of the

community affected, leading to investigation of cases of Human Rights violations in Local Communities. It is important to stress

that no cases of human rights violations were identified during the reporting period.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 69

Because forests are the principal source of our resources, one of our priorities involves educating the public about the benefits of

woodlands and the importance to society of sustainable use of forest-based products. In our 2030 Agenda and Roadmap we set

out our commitment to developing our relationship with Communities, working to transfer our knowledge and to raise public

awareness of the economic, social and environmental importance of forests (Chapter 5.2.6).

We therefore remain committed to launching projects that help to generate and share knowledge in the field of forest literacy,

especially online, as well as initiatives to empower Stakeholders, such as forestry producers (Chapter 5.2.6). Another important

target group is our local school communities, where it is extremely important to raise awareness of forest protection at an early

age.

Supply Chain Management

Aware of the impact of our purchasing policies on the creation and distribution of value, among the thousands of companies and

workers belonging to our Suppliers chain, we are committed to establishing partnerships and encouraging positive change.

The Company’s operations require supplies of wood, biomass, chemicals and other products, used in the industrial process -

for processing into finished products and by-products we market - and energy, which we produce and consume. The impacts

associated with our supply chain have to do not only with the extraction and production of these resources, but also with their

transportation.

Wood and biomass logistics are responsible for directly handling a large volume of wood, from our forest holdings (own and

rented properties), logistical parks and ports to the mills, using a variety of means of transport (road, rail and sea).

We also ship our products to more than 130 countries and approximately 3,800 delivery points, using various means of

transport (maritime, rail and road), prioritising sustainability of the transport chain and based on partnerships with our Suppliers

in developing efficient solutions.

These activities have an environmental and also social impact, to which we may add the importance of ensuring a resilient supply

chain able to respond to our needs, so that we can guarantee business continuity. Accordingly, in 2023, we established a series of

commitments in our 2030 Roadmap (Chapter 3.4.4), most notably:

• An increase in certified wood and promotion of chain-of-custody certification of all our wood Suppliers;

• Expand the range of Suppliers with assessments on financial and ESG criteria;

• Promote sustainability practices along the Suppliers Chain.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 70

Sustainability also entails ensuring that the delivery modes of transport complement each other, and so whenever operationally

and financial viable we use rail and maritime transport, although road haulage continues to represent a significant proportion of

our logistical flows. Rules were established in 2023 for implementing the Emissions Trading System (ETS), the EU policy in

maritime transport for combating climate changes and effectively reducing greenhouse gas emissions. Operators will now have to

purchase licenses permitting CO

emissions, which may lead the industry to develop more efficient solutions both through

alternative fuels and by redesigning ships, among other measures (e.g. reducing the speed of ships, choice of more efficient

routes). This is a topic we will follow with interest.

It is with the 2030 Agenda and the way we address our material topics that we respond to the main sustainability challenges

identified for Navigator (Chapter 3.4.2).

ANNUAL REPORT 2024 • MANAGEMENT REPORT 71

Challenges for Navigator

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Protect and value

biodiversity

Biodiversity loss is one of the pressing global

crises of our age, and is regarded by the

World Economic Forum (WEF) as one of the

most severe global risks for the next ten

years.

Wildlife and ecosystem protection,

conservation and restoration have a crucial

role to play in securing benefits in terms of

climate regulation, availability of resources

and other environmental and social services.

Alongside this growing recognition of the

importance of Nature to business, of its

dependence and impacts, new solutions and

partnerships have emerged to halt

biodiversity loss (looking at the value chain),

to integrate financial valuation of ecosystem

services and to promote nature-based

solutions.

• Supply Chain Management

• Responsible Business Conduct

• Innovation, Technology and R&D

• Climate Change

• Biodiversity Conservation

• Use of Resources and Circular Economy

• Sustainable Forest Management

• Sustainable management of Navigator's

forests through certification under FSC

and PEFC schemes

• Programmes supporting forestry

producers and improvement of eucalyptus

forests

• Dissemination of good forestry practices

through our own channels and sector

events

• Action and resources for fire prevention

and to support fire-fighting

• RDI activities and investment in

bioproducts

• Forest renewal activities

• Projects for forest literacy and biodiversity

conservation

• Establishing partnerships

• Conservation and monitoring activities to

which we are committed in connection

with Act4nature Portugal

• Eucalyptus Forum

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Climate mitigation

and low carbon economy

Failure to take climate action (mitigation

and adaptation) points again to the need

for greater commitment and action in this

area.

Climate events will become more frequent

and more severe (a “new normal”),

affecting where and how people live and

work, which requires a greater focus on

adaptation strategies.

Political action is starting to be taken on

climate issues around the world, along

with a stricter regulatory framework in the

European Union.

The low-carbon economy is at the heart of

post-pandemic recovery plans. The

development of new technologies (e.g.

carbon capture solutions) will be

accelerated, new jobs will be created and

new energy sources (e.g. hydrogen) and

new opportunities will be explored

The COP29 agreement establishes a

consensus on carbon markets, creating

mechanisms to trading carbon credits and

encouraging substantial investment in

projects to cut emissions. Technological

innovation is needed, so as to avoid

additional costs and ensure competitiveness.

• Supply Chain Management

• Responsible Business Conduct

• Innovation, Technology and R&D

• Climate Change

• Biodiversity Conservation

• Use of Resources and Circular Economy

• Water Management

• Sustainable Forest Management

• Company's Roadmap for Carbon Neutrality

and decarbonisation targets approved by

SBTi (Science Based Targets Initiative)

• Sustainable forest management

• Investment in systems and technologies

that minimise environmental impacts and

promote improved energy efficiency

• Gradual elimination of consumption of

fossil-based energy and investment in

alternative and renewable energy sources

(e.g. photovoltaic solar, biomass, green

hydrogen)

• Production of renewable energy

• RDI Activities

and investment in bioproducts

• Analysis of positive contribution of our

agroforestry assets as a carbon sink

• Alignment with TCFD initiative

and the European Taxonomy

ANNUAL REPORT 2024 • MANAGEMENT REPORT 72

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Circular economy

Regulatory developments and consumer

pressure relating to sustainable production

and consumption, scarcity of resources,

supplier chain volatility and the imminent

threat of climate change are leading

companies to develop more circular business

models that generate business value as well

as environmental benefits.

There is also a growing need to measure

circularity, using new tools, standards and

frameworks.

• Supply Chain Management

• Responsible Business Conduct

• Innovation, Technology and R&D

• Climate Change

• Biodiversity Conservation

• Use of Resources and Circular Economy

• Water Management

• Sustainable Forest Management

• Community relations

• Optimisation and improvement of

industrial processes - efficiency in use of

resources, processes and treatment

systems

• Reclamation of waste and reincorporation

of by-products in Navigator processes

• Promoting industrial symbiosis

• RDI activities and investment in

bioproducts

• Establishing partnerships

• Participation in Circular Bioeconomy

Alliance platform

• Improving scientific and technological

expertise in forest-based circular and

digital bioeconomy

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Sustainable consumption

Growing consumer awareness, activism and

demands, especially among younger

generations. Demand for healthier and more

sustainable products, openness to new

consumption models - digital, shift from

ownership to sharing.

Consumers who are more aware and

demand information that is clearer, more

transparent and traceable.

Increased production of packaging as

alternative to plastics (in particular, single

use plastics).

Emphasis on the role of companies in raising

consumer awareness and designing solutions

which are more sustainable and competitive

in terms of costs.

• Supply Chain Management

• Responsible Business Conduct

• Innovation, Technology and R&D

•

• Climate Change

• Biodiversity Conservation

• Use of Resources and Circular

Economy

• Water Management

• Sustainable Forest Management

• Community relations

• Products with forest certification label

and/or EU Ecolabel

• RDI activities and investment in

bioproducts

• gKRAFT range packaging products

furthering the transition to more

sustainable solutions

• Innovative tissue products:

 Amoos Naturally Soft™ (unbleached

eucalyptus kraft pulp)

 Amoos Aquactive™ (produces soap

bubbles when wetted)

 Amoos Air Sense™ (with floral

fragrance capsules)

 Amoos Calorie Control™ (improved

capacity to absorb food oils and

grease)

• Forest literacy projects

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Tech for Good

Covid-19 has once again highlighted the

importance of technology and of accelerating

digitisation, bringing about new ways of

working, socialising and selling. This

development raises issues relating to digital

fairness and access and other problems

associated with technological advances.

Faster digital transformation in order to

improve business resilience and

sustainability performance, creating

solutions for a number of social and

environmental problems.

Financing opportunities for companies to

leverage the technological revolution,

• Supply Chain Management

• Responsible Business Conduct

• Innovation, Technology and R&D

• Climate Change

• Biodiversity Conservation

• Use of Resources and Circular Economy

• Water Management

• Sustainable Forest Management

• New Digital Technology Department

taking a broad approach to topics related

to Industry 4.0 and digital

transformation in all operational areas

• Investment in systems and technologies

that minimise environmental impacts

and promote improved resource

efficiency

• RDI activities and investment in

bioproducts

• gKRAFT range packaging products

• Innovative tissue products

ANNUAL REPORT 2024 • MANAGEMENT REPORT 73

enabling them to invest in decarbonisation,

in the bioeconomy, in mobility and in

digitising their processes and ways of

working.

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Future of work

Ongoing advances in robotics, artificial

intelligence and machine learning are

launching a new era of automation, as

machines start to rival or surpass human

performance in various working activities.

Debate about adapting people and jobs to

this new era, and the skills of the future

The pandemic speeded up the shift to digital,

and this has created a need to upskill and

prepare human capital for new functions and

work processes.

Sustainability is increasingly valued, both by

applicants and by companies, meaning that

investment in developing “green skills” will be

essential.

• Responsible Business Conduct

• People, Talent and Human Capital

Development

• Health, Safety and Well-being

• Internal succession mapping to ensure

sustainability at different functional levels

in future

• Employee development plans

• More flexible remote working (part-time)

• Investment in training and the options

offered by the Learning Center

• Commitment to creating digital skills

• Mobilising Employees around Company's

Purpose

• Promoting employability and attracting

young talent

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Investment in human capital

People as one of industry's most valuable

assets. The pandemic underlined the S in ESG,

with a particular emphasis on Employee well-

being, health and safety. It also accelerated

new ways of working and of handling the

relationship between businesses and their

Employees (e.g. more flexible, remote,

integration with working, personal and family

life).

In order to retain and engage with Employees,

companies will have to promote a better

connection between work and their purpose,

promote opportunities for growth and

development and create more diverse and

inclusive working models and environments, in

particular to motivate younger generations.

Sustainability is increasingly more important for

Employees and applicants, and for this reason it

is important to communicate ESG strategy and

impact

Greater attention paid by companies, but also

by investors and financial institutions, to

detailed information on human capital.

• Responsible Business Conduct

• People, Talent and Human Capital

Development

• Health, Safety and Well-being

• Providing opportunities for Employees to

develop their professional lives and

careers

• Creation of customised development

plans

• Investment in training and the options

offered by the Learning Centre

• Promotion and empowerment of new

leaders

• Nurturing the spirit of enterprise

• Improved conditions in terms of pay and

bonuses

• Benefits plans and pension fund

• Mobilising Employees around Company's

Purpose

• Promoting employability and attracting

young talent

• Resources for providing safe working

conditions

• Occupational health and preventive

medicine programmes

• Mission 0

• Future Leaders Forum

• GROW Project (CRESCER)

• Industrial Forum

ANNUAL REPORT 2024 • MANAGEMENT REPORT 74

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Resilient and sustainable value chains

The Covid-19 pandemic and the imperative

need for economic recovery have put the

resilience of value chains to the test and

added to the urgency of examining their

sustainability. Difficulties have been

experienced in importing raw materials and

exporting products, as a result of successive

disruptions to supply chains (including

strikes, shortages, protectionist policies and

other factors).

Stakeholders continue to put pressure on

companies to improve management of their

supply chains, paying special attention to

respect for human rights and the

environment. Expectations of greater

maturity in programmes and initiatives

implemented by companies, and of greater

transparency and improved assessment of

supply chain performance in terms of

sustainability.

Transition from soft law to hard law, with

increasingly strict regulatory frameworks

holding companies liable for their impacts on

the value chain.

• Supply Chain Management

• Responsible Business Conduct

• Community relations

• Health, Safety and Well-being

• Climate Change

• Biodiversity Conservation

• Use of Resources and Circular

Economy

• Water Management

• Sustainable Forest Management

• Code of Conduct for Suppliers

• Strategy of partnership with Suppliers

(e.g. increasing energy, resource and

transport efficiency, looking for

alternatives to fossil-based energy and

contributing to decarbonisation goals)

• Sustainable management of forests

through certification under FSC® and

PEFC schemes

• Promoting chain-of-custody certification

of all our wood suppliers

• Programmes supporting Forestry

Producers and improvement of

eucalyptus forests (e.g. Forestry

Producers Club)

• Dissemination of good forestry practices

through our own channels and sector

events

• Eligibility criteria for supply of raw

materials

• Optimisation of inbound wood flows

• Partnership with raw material Suppliers

to encourage production of energy from

biomass

• Commitment to alternatives to road

transport (e.g. rail and maritime)

• Payment of Suppliers by confirming

(applicable only to certain categories of

Suppliers)

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Protection of fundamental rights

The response of businesses to movements

such as #InclusionMatters,

#MentalHealthMatters and

#RepresentationMatters, has increased the

attention paid to human capital. Companies

have come under scrutiny, from a wide range

of Stakeholders, in relation to topics such as

unfairness, racism, harassment or other

types of discriminatory practices.

Expectations concerning respect for human

and employment rights are broadened to

include value chains, on the light of recent

regulatory developments (transition from soft

law to hard law).

More than just securing a social license to

operate, companies will have to work actively

to build relationships of trust and create

social value with Employees and

Communities, and also speak out and take

action against injustice.

Diversity as a competitive factor - diversity,

fairness and inclusion programmes and

practices are being reassessed and expanded.

Funds take greater interest in social and

governance issues for ESG investments.

• Supply Chain Management

• Responsible Business Conduct

• People, Talent and Human Capital

Development

• Health, Safety and Well-being

• Community relations

• Responsible business conduct, based on

ethics, responsibility and transparency

• Codes of Ethics and Conduct for

Employees and for Suppliers

• Human Rights Policy

• Gender Equality Plan

• Whistleblowing channel

• Working conditions which are fair, safe

and promote Employees' health, well-

being and development

• Collective bargaining instruments

• Investment in training

• Industrial Forum

• Signing up to UN Global Compact

ANNUAL REPORT 2024 • MANAGEMENT REPORT 75

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Participation in adaptation

of regulatory framework

Regulation creates the stable, predictable and

fair conditions on which business depends in

order to invest, compete and prosper.

Companies must support the design of

policies that provide incentives for

sustainable transformation.

Business must adjust to new European

regulations and new ways of dealing with

global changes. Challenges such as climate

action, diversity, fairness and inclusion,

humans rights, the fight against

greenwashing, among other things, will be

subject to more consistent rules, and

companies, by working in partnership, will be

key to this process.

In view of evolving and increasingly strict

regulatory frameworks, companies must be

more transparent, using their advantage to

shape policies, regulations and standards in

order to address the challenges of

sustainability in the long term.

• Supply Chain Management

• Responsible Business Conduct

• Climate Change

• Biodiversity Conservation

• Use of Resources and Circular

Economy

• Sustainable Forest Management

• Monitoring of the most pressing topics on

the political agenda in Europe, Portugal

and Mozambique

• Advocacy initiatives by the Public Affairs

Department in relation to regulatory,

environmental and social matters

• Collaboration on research and issuing

technical reports

• Participation in sector associations and

events, in Portugal and internationally

• Organisation of events, visits and

debates around topics of structural

interest to the Company and the sector

• Business Round Table

CHALLENGE ASSOCIATED MATERIAL TOPICS OUR RESPONSE

Stakeholder Capitalism

Importance of responding to the needs of

Companies' different Stakeholders. In

contrast to the prevailing model of

maximising short-term profits for

Shareholders, Stakeholder Capitalism is

based on creating long term shared value,

considering not only Shareholders, but also

Customers, Employees, Communities and

Suppliers, among others.

Business model will be redesigned to respond

to pressure from society and markets and

there will be a growing need to apply new

metrics to assess impacts.

Companies must lead the way in reinventing

capitalism to ensure that the power of private

enterprise and competitive markets can be

harnessed to support social, environmental

and business prosperity in the long term.

• Supply Chain Management

• Responsible Business Conduct

• People, Talent and Human Capital

Development

• Health, Safety and Well-being

• Community relations

• Navigator's Purpose

• 2030 Responsible Business Agenda

• Sustainability governance structure with

involvement of external Stakeholders

(Sustainability Forum,

Environmental Council and Community

Monitoring Committees)

• Stakeholder communication and

engagement mechanisms

• Finance for sustainable development

• Sharing value with Stakeholders

• Responsible business conduct, based on

ethics, responsibility and transparency

• Reporting of information and internal

reflection on WEF Stakeholder Capitalism

metrics

• Signing up to UN Global Compact

• Eucalyptus Forum

3.4.3. Contribution to SDGs

We are committed to taking an active part in the United Nations 2030 Agenda, making the Sustainable Development Goals

(SDGs) a tangible reality. The 2030 Agenda and Roadmap have been updated to reflect the findings of the double materiality

analysis (Chapter 5.1) and the reassessment of our contribution to the SDGs and the respective targets, ensuring that all our

ANNUAL REPORT 2024 • MANAGEMENT REPORT 76

commitments are aligned with these global priorities (Chapter 3.4.4). In this way, we ensure that each initiative and measure

taken by the Company is geared to maximising our positive impact and making a real contribution to the 2030 Agenda.

Mindful of The Navigator Company's impact and the extent of its influence on attainment of SDGs, we have structured our

contribution into three categories:

a. Core: strategically relevant for the Group - they demonstrate the strong connection between its business activities and

the areas where it can generate a positive impact.

b. Supportive: direct or indirect contributions resulting from the Group’s sustainability approach, in particular

actions/programmes under way internally and/or arising from programmes to support the Group’s core activities.

c. Local: direct or indirect contributions resulting from the sustainability approach taken by individual Group companies,

which are aligned with the local context of the geographical regions where they operate, and which add to the

contributions mapped out for the core and supportive SDGs. In connection with this, attention is drawn to the

contributions of the Social Development Programme being pursued by Portucel Moçambique.

The following table identifies the SDGs and their respective targets to which Navigator is contributing, as well as the material

issues most directly associated with them. The 2030 Roadmap (Chap. 3.4.4) also highlights the correspondence between the

company's commitments and the SDGs which, through the objectives and targets set, are addressed.

CORE SDGs

Promote inclusive and

sustainable economic

growth, full and

productive employment

and decent work for all.

Build resilient

infrastructure, promote

inclusive and

sustainable

industrialization and

foster innovation.

Ensure sustainable

consumption and

production patterns.

Take urgent steps to

combat climate change

and its impacts.

Protect, restore and

promote sustainable use

of terrestrial

ecosystems, sustainably

manage forests, combat

desertification, halt and

reverse land degradation

and halt biodiversity

loss.

Target s

8.1, 8.2, 8.3, 8.4, 8.5, 8.6, 8.7,

8.8

Target s

9.1, 9.2, 9.4 and 9.5

Target s

12.2, 12.4, 12.5,

12.6 and 12.8

Target s

13.1, 13.2 and 13.3

Target s

15.1, 15.2, 15.3,

15.5 and 15.8

OUR CONTRIBUTION

Contribution to Portugal’s

per capita economic growth

(approximately 0.75% of

Portugal's GDP).

Creation of a fairer, healthier

and safer workplace for all

Employees.

Close relationship with local

Suppliers and producers,

making for a stronger local

economy and more resilient

Communities. Technological

modernisation and innovation.

More scientific research

and improved technological

capabilities.

Investment in innovative forest-

based solutions and products,

and in improving forestry

practices, helping to promote a

circular and low fossil carbon

bioeconomy

Promotion of collaborative work

with partners. Development of

sustainable bioproducts,

reducing dependence on fossil

resources and working towards

a decarbonised economy.

Investment in improved

technologies and solutions for

minimising environmental

impacts, such as renewable

energy, efficient and circular use

of resources, reduction of water

use and waste recovery.

Promoting the circular economy

through efficient use of

resources, optimised processes,

management of treatment

systems (water and waste) and

boosting industrial synergies.

Waste is selectively collected,

correctly stowed and sent for

appropriate final disposal,

Assessment of the real and

potential impacts of climate-

related risks and opportunities

on our businesses, strategy, and

financial planning. Promotion of

forest resilience and their

important function in

sequestering carbon.

Commitment to a 63% reduction

in scopes 1 and 2 GHG

emissions by 2035, in relation to

2020, and a 37.5% cut in our

scope 3 GHG 3 emissions

(targets approved by SBTi).

Management of a vast forest

holdings in mainland Portugal

(1.2% of the area of mainland

Portugal), 100% certified under

the FSC® and PEFC schemes.

Practices that promote yields

and resilience in the long term.

Ecological restoration and

conservation of soils and

protected agro-forestry habitats,

and conversion of inappropriate

production forests and

reforestation with native

species.

Eradication of invasive species.

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Investment in efficient use of

resources, innovation and

technology.

Related material topics

Responsible Business Conduct;

Supply Chain Management;

Innovation, Technology and

R&D;

Use of Resources and Circular

Economy;

People, Talent and Human

Capital Development;

Health, Safety and Well-being.

Promotion of improved

infrastructures, including health

and school infrastructures in

Mozambique, as part of the

Social Development

Programme.

Related material topics

Climate Change;

Innovation, Technology and

R&D;

Community Relations;

Use of Resources and Circular

Economy.

prioritising reclamation

operations whenever possible.

Sustainable production,

products of distinctive quality,

made from renewable raw

materials, responding to

consumers’ expectations.

Related material topics

Innovation, Technology and

R&D;

Use of Resources and Circular

Economy.

Investment in renewable

sources, such as biomass and

solar.

Contribution to the debate on

policies, strategies, plans and

measures for combating climate

change, at home and

internationally.

Developing educational and

awareness raising programmes

dealing with climate action.

Related material topics

Climate Change;

Responsible Business Conduct;

Innovation, Technology and

R&D;

Use of Resources and Circular

Economy;

Sustainable Forest

Management;

Biodiversity Conservation.

Combating desertification and

reducing erosion, by

disseminating good practices in

conservation farming, and by

raising community awareness of

environmental issues.

Annual monitoring of

biodiversity and ecosystem

services, assessment and

mitigation of the impacts of

forest operations.

Technical support programmes

for forestry producers (e.g. E-

globulus platform and Forestry

Producers Club).

Collaboration with academe on

project to assess impact of

Forest Certification in

Eucalyptus Plantations.

Related material topics

Responsible Business Conduct;

Biodiversity Conservation;

Sustainable Forest

Management;

Use of Resources and Circular

Economy.

SUPPORTIVE SDGs

Ensure healthy lives and

promote well-being for all, at

all ages.

Ensure inclusive and equitable

quality education and promote

lifelong learning opportunities

for all.

Achieve gender equality and

empower all women and girls.

Ensure availability and

sustainable management of

drinking water and sanitation

for all.

Target s

3.3, 3.4, 3.8 and 3.9

Target s

4.3, 4.4, 4.6 and 4.7

Target s

5.1, 5.4, 5.5

Target s

6.1, 6.3, 6.4, 6.5, 6.6 and 6.8

OUR CONTRIBUTION

Preventive measures and monitoring of

Employee health, as part of the

Occupational Health Programme in

Portugal and the Preventive Medicine

Programme in Mozambique.

Contribution to physical, mental and

social welfare through Occupational

Health Programme, which includes

mental health counselling, welfare and

other professional consultations.

Early identification of health issues,

advice on treatment and

recommendations for improved health,

through the Preventive Medicine

Programme.

Improved health and welfare of

Communities in Mozambique through the

Social Development Programme,

Improving skills and employability, in

particular of young people, in the regions

where we operate. Attracting and

developing young people through

vocational internships.

Family welfare support for employees,

through award of study grants.

Development of specific educational

programmes, such as:

• Forest of Wisdom

• Give the Forest a Hand

• My Planet

• Florestas.pt

• Biodiversidade.pt

• Producers’ Club

Implementation of the Equality Plan and

the Governance Model for Diversity,

Equity and Inclusion.

Internal measures to boost the proportion

of women in leadership positions.

Support for the GirlMove Academy, a

project seeking to empower young women

and train them for leadership.

Gender study in the Mozambique’s wood

processing sector, involving ILO, in order

to identify opportunities for employment

and decent work for women in companies

in the sector.

Related material topics

Responsible Business Conduct;

People, Talent and Human Capital

Development;

Implementation of Water Use Reduction

Programme (WURP).

Investment in technologies to reduce

water consumption, such as systems for

reusing water and treating eluents.

R&D activities relating to forestry

practices, aiming to conserve water in the

soil, and searching for solutions (genetic

materials and practices) that can bring

greater resilience to water scarcity.

Monitoring of water quality using a

protocol developed by Portucel

Moçambique, in partnership with RAIZ

(with an operational approach).

Execution of a plan for drilling and

repairing bore holes, providing access to

drinking water for several Communities

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promoting the quality of water for human

consumption and investment in health

infrastructures, including operating

theatre at Ile hospital.

Risk assessment and monitoring of

physical, biological and chemical agents

and ionising radiation at industrial units.

Related material topics

Community Relations;

Health, Safety and Well-being.

Promoting equal access by Employees

and skills development through the

training oered by the Learning Center.

Related material topics

People, Talent and Human Capital

Development;

Community Relations.

Supply Chain Management;

Community Relations;

Health, Safety and Well-being.

where we operate, as part of the Social

Development Programme.

Tests of the quality of water for human

consumption, ensuring access to drinking

water for a large number of families.

Related material topics

Water Management;

Innovation, Technology and R&D.

Ensure access to affordable,

reliable, sustainable and

modern energy sources for all.

Making cities and communities

inclusive, safe, resilient and

sustainable.

Promote peaceful and inclusive

societies for sustainable

development, provide access to

justice for all and build

effective, accountable and

inclusive institutions at all

levels.

Strengthen the means of

implementation and revitalize

the global partnership for

sustainable development.

Target s

7.2 e 7.3

Target s

11.2, 11,3, 11.4, 11.A, 11.B, 11.6

Target s

16.5, 16.6 e 16.7

Target s

17.16 e 17.17

OUR CONTRIBUTION

Generation of renewable electricity from

biomass, accounting for approximately

34% of all power produced in Portugal

from this source.

Investment in producing renewable

energy, in particular using photovoltaic

solar technology and installing panels in

our industrial complexes.

Approximately 80% of the primary energy

used in our production processes is from

renewable sources.

Corporate Programme for Energy

Eiciency at Navigator's industrial units.

Related material topics

Climate Change;

Innovation, Technology and R&D.

Contribution to job creation in the rural

areas where we operate and to a stronger

local economy.

Working with communities in order to

respond to their needs and concerns

relating to management of the

environmental and social impacts of the

Company’s operations and projects to

improve their welfare and quality of life.

Specific programmes to promote lasting

commercial relationships in rural areas

(e.g. Forestry Producers Project and the

Forestry Producers Club).

Working to improve infrastructures,

including construction and rehabilitation

of access roads and bridges in

Mozambique, as part of the Social

Development Programme. Contribution to

protecting and preserving cultural

heritage in areas under our management,

as part of sustainable and holistic forest

management.

Related material topics

People, Talent and Human Capital

Development;

Community Relations.

The compliance system features policies

and instruments designed to prevent

corruption.

Involvement of internal and external

Stakeholders in the sustainability

governance structure, promoting

eective, responsible and transparent

management, through the Sustainability

Forum, the Environmental Board and the

Community Monitoring Committees, and

through the Community Liaison Oicers

in Mozambique.

Related material topics

Responsible Business Conduct;

Community Relations.

Partnerships with several entities to

further knowledge, training, innovation

and value generation, through initiatives

such as the Sustainability Forum and the

Forestry Producers Club.

Related material topics

All material topics.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 79

LOCAL SDGs

End poverty in all its forms, everywhere.

End hunger, achieve food security,

improve nutrition and promote

sustainable agriculture.

Reduce inequalities within and between

countries.

Target s

1.5

Target s

2.3, 2.4 e 2.5

Target s

10.1, 10.2, 10.3 e 10.4

Contribution to improved incomes for vulnerable

communities in Mozambique and provision of technical

training so as to raise professional standards in the

labour market.

Combating poverty in local communities through local

hiring and incentives for bee-keeping as a livelihood,

through the Social Development Programme.

Related material topics

Community Relations.

Improved food security and diversity, as well as

sustainable farming and practices, through agricultural

extension (improved seeds, conservation farming

techniques), barns (minimising post-harvest losses),

school vegetable gardens and community

environmental awareness raising campaign, as part of

the Social Development Programme in Mozambique.

Related material topics

Community Relations.

Portucel Moçambique contributes to growth in income and

improved welfare for the more disadvantaged, through its

Social Development Programme, and also through the

employment generated by its operations. These jobs are

available in rural areas, where the population is more

vulnerable and has poorer access to basic infrastructures.

Contribution to improved incomes and welfare for the

disadvantaged population, through the Social Development

Programme, and employment generated by the operations

of Portucel Moçambique.

Promoting pay equity, ensuring that women and men

receive fair pay for equal work or work of equal value.

Implementation of Tax Policy with significant impact on the

business fabric, aecting all of the Group's value chain.

Related material topics

Supply Chain Management;

People, Talent and Human Capital Development;

Community Relations.

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3.4.4. 2030 Roadmap

In the 2030 Roadmap, we indicate the current state of progress made by Navigator towards each goal – Status – and link this

to the contents of this report. In addition, attention is drawn to the new goals and interim targets for the next annual cycle.

The roadmap contains a review of the contribution made by commitments in the 2030 Responsible Management Agenda to

attainment of the targets of the SDGs in the United Nations 2030 Agenda.

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3.4.5. Stakeholder engagement

The Navigator Company's responsible management strategy is designed to generate economic, social and environmental

impact along the value chain, listening to and aligning the expectations of our Stakeholders with Navigator's strategy and

needs.

Our aim is to create long term value for the 10 relevant Stakeholder groups with which we have dealings. The Stakeholder

groups were identified at an internal workshop, with members of the Executive Committee, as part of the materiality analysis

process in 2015. This mapping has been undergoing review, to keep it up to date and to ensure integration of the expectations

identified in relation to the issues considered most relevant to the Company's future, and there was no significant change to

the Stakeholder groups identified in relation to the previous report.

We use various forms of communication and engagement, and the channels and frequency vary depending on the

Stakeholder group and the needs identified. In this way we seek to consolidate trusting relationships and our social license to

operate, increasing transparency and identifying possible risks and opportunities.

Communication channels used for all groups include email and the Company's website and social media, as well as the

whistleblowing channel (Chap. 5.4.1).

The formal mechanisms for direct interaction with different Stakeholder groups include the bilateral communication channels

established, such as the Industrial Forum, and interactions with workers’ representatives (Chapter 5.3.1); the Community

Monitoring Committees (Chapter 5.3.3) and the Community Liaison Officers who help to build a close relationship

between the Company and local Communities in Mozambique (Chapter 5.3.3) - initiatives which are crucial for understanding

the concerns of Communities, seeking to respond to their needs and incorporating practices into our action plans.

Navigator's Sustainability Forum (Chapter 5.1), an internal sustainability governance body, also provides an important arena

for dialogue. Significantly, its members took part in the double materiality process (Chapter 5.1) and annual sessions are

organised with the participation of national and international experts, to discuss subjects of relevance to the Company's

business and to our Stakeholders.

Navigator also has an Environmental Board, with members drawn from academe, which is responsible for monitoring the

Company’s environmental performance (Chapter 5.1) and holds regular meetings over the year.

Mindful of the need for continuous improvement and of our purpose of sharing our knowledge and resources with society, we

have made several information channels available to local Communities (Chapter 5.3.3) and forestry producers (Chapters

5.2.6).

Our Public Affairs Department also does important work in promoting a close relationship with institutional stakeholders and in

advocacy initiatives on regulatory, environmental and social issues.

The Navigator Company sets out to generate economic, social and environmental impact along the value

chain, listening to and aligning the expectations of our Stakeholders.

Relationship with our Stakeholders

Our aim is to create long term value for the 10 relevant Stakeholder groups with which we have

dealings.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 102

STAKEHOLDER GROUPS HOW WE ENGAGE HOW WE CREATE VALUE

• General Meetings

• Dedicated events

• Roadshows

• Conferences for presentation of results

• Annual and quarterly reports

• Environmental Board

• Sustainability Forum

• ESG performance information

• ESG ratings

• Investor relations

• Regular reporting of financial and non-

financial information

• Sustainability Forum

•

Risk reduction

• Optimisation of operations

• Optimisation of assets

• Increased revenues and distribution of

dividends

• Submission of intellectual property patents

• Pension Fund Supervisory Board

• Industrial Forum

• Managers' Forum

• Intranet

• My Planet

• Navigator Forests Conference

• Navigator Commercial Conference

• Straight to the Top Programme

• Periodic meetings between Executive

Committee and Workers’ Committee

• Collective bargaining instruments

• Navigator Tour - Visits to our mills and

nurseries

• Family Day

• Future Leaders Forum

• Growing Project

• Digital Forum

• Eucalyptus Forum

• Fórum Digital

•

Fórum Eucalipto

• Stable employment

• Payment of wages, performance and

productivity bonuses

• Benefits and support for families

• Vocational training and development

• Provision of safe working conditions that

promote well-being

• Raising awareness of healthcare and

preventive medicine

• Management of pension fund

• Promoting a sense of purpose

•

Sustainability Forum

• Participation in events and management

bodies of industry associations in areas

such as energy, forestry and sustainable

development

• Meetings and visits to our facilities

• Eucalyptus Forum

• Contribution to the design of shared

solutions for economic, environmental and

social challenges in the sector, regions and

the country.

• Active participation in development

projects and support for forestry producers

through Biond – Forest Fibers from

Portugal

ANNUAL REPORT 2024 • MANAGEMENT REPORT 103

STAKEHOLDER GROUPS HOW WE ENGAGE HOW WE CREATE VALUE

• Sustainability Forum

• Technical support and training

• Forestry Producers Club

• Annual Forestry Producers Meeting

• Trade Fairs

• e-globulus platform

• Florestas.pt platform

• Collaboration agreements

• Forestry Producers Magazine

• Navigator Tour - Visits to our mills and

nurseries

• Eucalyptus Forum

•

Technical training

• Tools for promoting responsible and

sustainable forest management

• Large scale production of clones, making

for healthier and more productive forests

• Genetic improvement of plantations

• Support for fire prevention and fire-

fighting

• Solutions for controlling pests and other

biotic risks to plantations

• Adding value to ecosystem services,

through sustainable forest management

and biodiversity conservation

• Increased efficiency in forest production

• Business activities

• Periodic listening exercises

• Advertising campaigns

• Satisfaction surveys

• ESG Questionnaires

• Complaints

• Meetings and visits to our mills and

nurseries

•

Webinars and specialist events

• Quality products, mostly bearing

certification seals

• Response to market needs

• New products and services

• Close relationships and trust, generating

value for Consumers

• Advocacy activities– Public Affairs sector

• Community Liaison Committees

• Sustainability Forum

• Formal response to legal requirements

• Meetings and response to various

enquiries

• Navigator Tour - visits to our mills and

nurseries

• Responsible fiscal policy

• Helping to power Portugal’s business fabric

and promoting exports

• Contributing to better rural development

policies and to attainment of Portugal's

carbon neutrality targets, with concrete

proposals/action plans

• Participation in Taxpayers’ Forum

• Environmental Board

• Sustainability Forum

• Study grants and Master's degrees

• Research partnerships (RAIZ)

• Cooperation agreements with universities

• Forest of Wisdom

• Navigator Tour - Visits to our mills and

nurseries

•

Eucalyptus Forum

• Investment in R&D

• Generating and disseminating knowledge

• Partnerships with universities and

institutes to produce knowledge on a co-

creation basis

• Creating employment in science

• Development of bioproducts

• Sustainability Forum

• Community Liaison Committees

• Collaboration agreements

• Navigator Tour - Visits to our mills and

nurseries

• Participation in leading NGOs in the field of

sustainable forests and biodiversity

conservation

For example: the World Wide Fund for

Nature's Forests Forward programme

• Dialogue with NGOs in Navigator’s

Sustainability Forum

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STAKEHOLDER GROUPS HOW WE ENGAGE HOW WE CREATE VALUE

• Sustainability Forum

• Declarations of conformity

• Technical visits to facilities of chemical

raw materials suppliers

• Annual Forestry Producers Meeting

• Forestry Producers Magazine

• Navigator Tour - Visits to our mills and

nurseries

• Navigator Hub

• Suppliers’ Day

• Forestry Producers Club

• Eucalyptus Forum

•

Supplies and provision of services

• Generating employment and powering

development of Portugal's business fabric

• Sharing values and good practice

• Support for reducing carbon footprint

• Community Monitoring Committees

• Community liaison officers (Mozambique)

• Give the Forest a Hand

• Forest of Wisdom

• Biodiversidade.com.pt

• Florestas.pt platform

• Sustainability Forum

• My Planet

• Navigator Tour - Visits to our mills and

nurseries

• Forestry Producers Club

• Eucalyptus Forum

• Promotion of the rural economy

and bioeconomy

• Generating employment

• Training up young talent

• Investment in the Community

• Promotion of forest literacy

• Adding value to ecosystem services,

through sustainable forest management

and biodiversity conservation

• Helping to mitigate climate change risks,

through carbon sequestration and

investment in renewable energy sources

• Reducing the impacts from atmospheric

emissions, noise and odours, and from

waste generation

• Reducing the impacts of liquid emissions

on water availability

ANNUAL REPORT 2024 • MANAGEMENT REPORT 105

4. Performance in businesses

4.1 Bleached eucalyptus pulp (BEKP)

After a 1

half of 2024 marked by the strength of the benchmark index for hardwood pulp in Europe (PIX BHKP in dollars), which

rose to record levels in early July (1440 USD/ t), the 2

half brought a severe correction in prices in China, ending the year at 545

USD/t. This slump in prices confirmed the 2024 downward cycle as the fastest and sharpest in recent years. As a consequence,

prices also adjusted downwards in Europe in the second half, most markedly in 4

quarter, ending the year at 1000 USD/t.

In China, prices stabilised at the end of the 4

quarter, supported by an increase in business - an improvement in downstream

sectors, with the market feeling the effect of a major player in the domestic market discontinuing production (due to persistently

poor returns on operations), and an upsurge in the volume of trading at the end of the year.

European demand for hardwood pulp (HW) performed well in 2024, culminating in growth of 13%; demand for short eucalyptus

fibre (EUCA) was up 12% over the year. The pulp market was sustained by stable demand in certain segments, such as printing

and writing paper (especially UWF), tissue and packaging paper (UWF up 8%, CWF up 5% and tissue up 7%).

This improvement stands in contrast to the decline in demand for short fibre in China, with a downward correction of 9% in HW

and 8% in EUCA, penalised by a domestic paper market that remained depressed through to the end of the 4

quarter, making it

hard for paper manufacturers to increase prices and relieve the pressure on their margins.

New ventures starting up in 2023 in Chile and Uruguay and the start-up of new production capacity in 2024 in Brazil and China

both led to a gradual increase in supply, especially over this period, putting downwards pressure on prices.

It should be stressed that, worldwide, eucalyptus fibres represent almost half of all fibre in the market and almost 80% of

hardwood fibre.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 106

Source: PPPC, December (2024 vs. 2023)

Pulp sales stood at 389 thousand tons, due to increased incorporation into paper products, representing a reduction of 16% in

relation to 2023. The improvement in average sales prices in relation to the previous year (up 13%) meant that the value of sales

dropped by just 5% (vs. 2023).

ANNUAL REPORT 2024 • MANAGEMENT REPORT 107

4.2 Paper

In Europe, apparent demand for uncoated woodfree printing and writing paper (UWF) grew by 8% in relation to 2023, with the

strongest growth in paper for the printing industry (10%), followed by office paper (8%) and reels for the paper processing

industry (5%).

In the United States, demand dipped by just 0.2% in relation to 2023, whilst China recorded growth of 2% (January to

November).

Apparent global demand for printing and writing paper grew by 0.5% in all segments, with demand for UWF paper up 0.3%.

Coated or couché papers (CWF) recorded growth of 0.5%, whilst papers using mechanical fibre (coated and uncoated) presented

an increase of 1.2%.

Significantly, UWF has remained the most resilient segment over the years, due to its versatile uses Unlike other grades, where

demand has slumped since 2020, UWF has been practically stagnant (declining 0.58% a year, as compared to a drop of 4.1% in

CWF and 6.9% in papers made from mechanical pulp - CAGR 2020-24).

Source: PPPC, December (2024 vs. 2023)

Capacity utilisation rates in the European industry (output/capacity) were up on 2023. Navigator operated in 2024 with an

average capacity utilisation rate of 86%, as compared to an average of 82% in the European industry for the same period.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 108

At the end of the year, the benchmark index for office paper in Europe (PIX A4 B-copy) stood at 1096 €/t, up slightly from its level

at the start of the year (1092 €/t), pointing to the resilience of the paper price. The index closed the year of 2024 at an average

price of 1107 €/t, representing an increase of 31% over pre-pandemic levels (845 €/t between 2015 and 2021).

Navigator's printing and packaging paper sales totalled 1225 thousand tons, up by 8% on 2023. The sales volume, in euros, grew

by 3% (in relation to 2023). Attention is drawn to the strength of our business model, based on differentiation, premium products

and strong mill brands in the various markets where we operate.

Mill brands represented 77% of the year's sales (vs. an average of 73% over the period 2018-2024). Premium products continue

to represent a large share, at 58% (compared to an average of 55% over the period 2018-2024). These two ratios stand at their

2nd highest levels of all time. When market conditions are more difficult, mill brands and segments with greater value added offer

an additional safeguard for Navigator’s results.

In addition to the quality, innovation and sustainability credits associated with our products, we offer an additional guarantee

to our Customers and Consumers through the guarantee to our customers and consumers through the forest certification and/or

EU Ecolabel labelling on our products.

With regard to product information and labelling, we comply with Regulation (EU) 453/2010 of 20 May, by publishing a

technical safety data sheet for all our products, describing their main characteristics, applications and advice on use and recycling.

We therefore apply the Ecolabel and/or FSC® and PEFC certification logos, among others.

4.3 Packaging

Expectations of a return to normality in 2024 were confirmed and market behaviour was more typical, with demand stabilising and

growing stronger. European deliveries of Kraft MF (machine finished) papers (white and brown) reported by CEPI (January-

December) were up by 23.1% on the same period in 2023.

Navigator’s packaging segment performed consistently over the year, with a gradual increase in sales. The sales volume in the

segment doubled in relation to 2023. At present, 70% of our sales are in Europe, mainly in Iberia, Italy, France and Germany,

with the remaining 30% in overseas markets (where Latin America, Turkey and North Africa are our leading markets).

This performance has been based on the move into new segments, launched in 2023 and the early months of 2024, above all in

the area of flexible packaging. The strong results in these segments have confirmed the effectiveness of the strategy of

diversifying into these new packaging paper applications using eucalyptus fibre. In fact, sales in the flexible packaging and boxes

(rigid packaging) segments accounted for a significantly larger proportion of turnover, thereby reducing the dependency on the

bag segment, a more competitive market where growth has recently shown less momentum.

Navigator has continued to broaden its customer base, which already numbers close to 300 clients in a sales operation 100%

based on its own brand - gKRAFT™. The packaging paper offering is based around the three gKRAFT™ macrosegments - BAG,

FLEX and BOX –, which then divide into 12 subsegments for different applications. The innovative introduction of the properties of

eucalyptus fibre has been crucial in securing the growing acceptance and recognition that these products already enjoy in the

market.

The year 2024 also saw the start-up of production at the new industrial unit in Aveiro for moulded cellulose components.

Production started up with 7 products for single-use applications in the food sector, fully recyclable and/or compostable: a 22cm

plate, a 17cm plate (dessert), a 500ml bowl, 1 litre take-away packaging, a tray (laminated for raw protein - beef, pork and

poultry), a fruit basket and an espresso coffee cup.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 109

These 7 products offer production flexibility and scalability for exploiting the various opportunities opening up for substituting

single use plastics and aluminium. Alongside this, work has proceeded on developing new products, in partnership with national

and international clients, and on researching and developing new sustainable barrier property solutions, as well as trials of

commercial products.

In an important breakthrough, early in the new year (2025), our moulded cellulose products, under the gKRAFT™ Bioshield brand,

secured conformity certification for food contact under European Regulation (EC) 1935/2004 (food contact) and under the German

recommendation BfR XXXVI. This means that our gKRAFT™ Bioshield products are the first moulded cellulose products in the

world to achieve conformity with recommendation BfR XXXVIA. This certification was issued by ISEGA, the prestigious German

laboratory. Certification enables us to market products for the food segment, for contact with fatty, moist and dry foods, applying

to our entire tableware and take-away line.

4.4 Tissue

Demand for tissue was lively throughout the year, with growth of 5.4% estimated in Western Europe. This strong growth is due

essentially to recovery in consumption in the Away-from-Home segment and growing household spending power.

Navigator’s tissue business took a front seat in 2024, marked by the acquisition of what is now called Navigator Tissue UK, which

took effect during the 2

quarter. The integration of this new unit is part of Navigator’s ambitious plan for growth and

diversification, and strengthens its strategic position in the tissue market.

Tissue sales displayed significant resilience, with sustained growth in demand for Navigator's finished products.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 110

The volume of tissue sales (finished products and reels) totalled 220 thousand tons in 2024, representing an increase in volume of

55% in relation to 2023, with sales in euros likewise growing by 55%. This growth was powered by the additional capacity of

Navigator Tissue Ejea, acquired in Spain in the 2

quarter of 2023, and by the capacity of Navigator Tissue UK as from 1 May

2024, which, in addition to boosting growth of sales, broadened the customer base and yielded significant gains in acquisition

synergies.

International sales in tissue business continue to grow, and now represent 79% of the total sales volume in this segment, with the

English and Spanish markets accounting for close to two thirds of total sales, at 31% each, and the French market claiming 15%

of sales. Sales broke down into 97% finished products and 3% reels, representing an improvement in the mix of 3pp when

compared with 2023.

In terms of client segments, At Home or Consumer (retail) business has grown in importance, currently accounting for 83% of

sales, whilst Away-from-home and wholesalers account for the remaining 17%.

Tons

Q2, Q3 and Q4 2023 and 2024 include Tissue Ejea l May to December 2024 includes Tissue UK

Finished product and reels

Twenty twenty-five started with good news, as the Amoos brand won two major accolades: the Five Star Prize and the 2025

Consumer’s Choice Award. These awards are also the result of continuous work on branding, which has been gradually rolled out

in this business area. Public recognition boosts contact and the visibility of our products and brands with the general public; no

less importantly, it improves the brand profile with our Customers and prospective Major Clients.

Five Star Award: 4 years of excellence. For the fourth year running, Amoos has won the Five Star Award, coming out top in the

napkins category with its 40x40 product in the Naturally Soft range. This award shows that Portuguese consumers are interested

in a more sustainable, high quality solution - featuring softness, in the case of napkins - provided by the Natural Soft Fibre™

technology. The Naturally Soft range is made up of dermatologically tested products, made from 100% virgin fibre, free of

chemical bleaching agents, making more efficient use of certain resources, such as wood, energy and water.

Consumer’s Choice 2025: No. 1 in Toilet Paper: For the first time, the Amoos brand also won the title of No. 1 Brand in the

2025 Consumer’s Choice, in the Toilet Paper category. This award, which enjoys healthy awareness ratings in the world of

ANNUAL REPORT 2024 • MANAGEMENT REPORT 111

Portuguese consumer goods, highlights the potential of the value placed by Portuguese households on the quality of the Amoos

toilet paper range.

Product of the Year Awards: In June 2024, we launched a multi-purpose kitchen roll range in the United Kingdom under the

iconic Flash cleaning brand. Made from paper which is 100% FSC certified, Flash Kitchen Roll combines strength and absorption,

providing consistent and reliable cleaning power. In 2025, Flash Kitchen Roll was voted Product of the Year in the Household Paper

category of the Product of the Year Awards, the largest consumer survey in the United Kingdom on product innovation.

4.5 Energy

Energy sales in 2024 stood at approximately 123 million euros, down 27% on the previous year.

This reduction was due essentially to the transfer of the Setúbal combined-cycle natural gas power station to operation for internal

consumption; in the previous year, the plant had operated exclusively for sale to the market.

By way of compensation, the reduction in power sales resulting from operation of the Setúbal plant for internal consumption

enabled Navigator to to make a corresponding reduction in power purchases for operation of the group’s largest paper machine.

Another important development during the year was the participation by the Group’s industrial units in the manual Frequency

Restoration Reserve Band Market (mFRR Band). This system service, provided to the operator of the power grid by qualified

consumers, helps to safeguard the security of supply in the National Electrical System, which has already proved to be decisive for

protecting domestic consumers and critical users. Over the course of the year, Navigator's units were mobilised on 32 occasions to

reduce their power consumption, under the mFRR Band service.

Another important development in 2024 was completion of work on new solar arrays for internal power consumption at the

industrial sites in Figueira da Foz, Aveiro and Vila Velha de Ródão. With photovoltaic solar power facilities featuring total rated

capacity of approximately 38 MW, Navigator is now Portugal’s largest generator of solar power for internal consumption in an

industrial setting.

4.6 Financial performance

Cost management and growing sales volumes of UWF, packaging and tissue enabled us to achieve EBITDA of 547

million euros.

Variable costs were brought down significantly over the year which, in conjunction with management of paper prices, especially in

segments with greater value added, afforded additional protection for results. These factors, combined with a sales strategy of

prioritising mill brands and product and market diversification, made it possible to achieve EBITDA of 547 million euros.

Cash costs came down by between 2% and 10% in all pulp and paper segments (printing and writing, tissue and packaging).

Continued efforts to control costs have made it possible to cut cash costs by between 10 and 14% in comparison with 2022,

although they remain above pre-pandemic levels.

It should be stressed that 2024 was marked by the crisis in the Red Sea, requiring changes to shipping routes and prompting an

upward tendency in freights worldwide. Despite these difficulties, Navigator succeeded in keeping its logistical costs on a

downwards course, with a 6% reduction in relation to 2023.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 112

Navigator remains focused not just on managing its variable costs, boosting efficiency in consumption of raw and subsidiary

materials, by reducing specific consumption levels, in particular in pulp, paper and Tissue production, but also on making efforts to

contain fixed costs.

Total fixed costs ended the period at a higher level than in 2023, due to the incorporation of the Navigator Tissue Ejea unit in the

quarter of 2023 and Navigator Tissue UK in May 2024, the increase in the value of the bonus awarded by way of employee

profit sharing, increased severance payments under the rejuvenation scheme and non-recurrent costs related to the acquisition of

Accrol. However, when the new acquisitions are excluded, fixed costs, not including Personnel costs, rose by well under the rate of

inflation for the year.

In this context, Navigator achieved EBITDA of 547 million euros in 2024 and an EBITDA / Sales margin of 26.2% (up 0.5 p.p. on

2023).

4.7 Sustainable financial management

Net debt in 2024 grew by 128 million euros in relation to 2023: in a period marked by large disbursements associated with the

acquisition of Accrol (€153 million), dividends (€150 million) and capex (€241 million), this reflects robust capacity for cash flow

generation. The Interest Bearing Net Debt/EBITDA ratio stood at 1.13 (vs. 0.98 in 2023), consolidating the Group’s financial

strength profile.

Debt totalling 95 million euros was repaid over the year, whilst six new long term facilities were contracted, for a total of 355

million euros, of which 330 million euros was drawn during the year (230 million euros maturing in 7 years – bullet - and the

remaining 100 million euros in 6 and 5 years). Of that borrowing, 250 million euros is on a flat rate basis, either by hedging the

interest rate with derivatives (interest rate swaps) or else directly contracted on that basis.

Navigator continues to enjoy ample liquidity, with 218 million euros in long term facilities available, an appropriate level of

average debt maturity, with rationally staggered repayments, and approximately 65% of total debt tied to sustainability (vs. 46%

in 2023) and 89% of total debt issued on a flat rate basis, directly or via hedging instruments, enabling us to maintain low

financing costs in a scenario of sharply rising interest rates.

Despite the new facilities contracted, incorporating higher market interest rates, the average cost of debt issued at 31 December

remained below 2.4%.

Navigator is committed to carrying on its business in full compliance with environmental, social and governance (ESG) principles

and best practices and has established this Sustainability-Linked Finance Framework to support the financing and/or refinancing of

its activities in general, through bond issues or loans indexed to sustainability indicators.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 113

4.8 Share performance

The international economy proved fairly resilient in 2024, with growth in global GDP of more than 3%. Business was driven by a

consistent employment market and a recovery in spending power. With inflation coming down, close to the target levels of the

monetary authorities, the central banks reacted to this adjustment and set about cutting their reference rates.

However, growth was not evenly spread: in the US, the economy remains robust with GDP growth surpassing expectations,

whilst in the Euro Zone, GDP continues to be sluggish. In China, the difficulties in the real estate sector and slack domestic

demand continue to weigh on the economy, although the strong foreign trade results helped to keep growth at close to 5%.

This scenario meant that, in general 2024 was a positive year for the main stock markets. The global index MSCI ACWI was up

15% on the year (after a gain of 20% in 2023) and Euro Stoxx 600 rose by 6% (up 13% in 2023). However, after the presidential

elections in the United States, this dynamic abated somewhat, especially after the Fed, at its December meeting, poured cold

water on expectations of interest rate cuts.

The year ended with a strong dollar, and great uncertainty as to the potential disruptive effects of the economic policies of the

incoming US president and the evolution of monetary policy. The escalation of war in the Middle East and Ukraine posed the

largest challenge to economic and financial forecasting.

The share prices of Pulp and Paper sector companies were hit, especially in the second half of the year, by volatility in the pulp

prices, when benchmark indexes suffered a sharp downwards adjustment, after reaching all-time highs in July 2024. Most

European shares in the sector ended the year with a loss.

Total shareholder returns (TSR) for Navigator in 2024 stood at 7%, again reflecting steady performance by the shares and

distribution of dividends.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 114

Navigator shares grew in value by 1.18% over 2024, closing the year at €3.59 per share. The listed prices fell to its lowest level of

€3.402 in early December, having peaked at €4.436 on 15 May, following the acquisition of Navigator Tissue UK. Average daily

trading stood at 567 101 shares, with an average daily turnover of 2.1 million euros.

Navigator Share Price 2024

Fonte: Bloomberg

The annual general meeting was held on 24 May 2024, and approved distribution of dividends of €150 million, equivalent to a

gross dividend of €0.21091/share, paid on 11 June. An interim dividend for 2024 was announced in December, of €100 million,

equivalent to €0.14061/share, which was paid on 14 January 2025.

Navigator stock is currently included in more than 240 investment funds, 90 of which feature an ESG approach, up by

approximately 15% from 2023. These funds recognise the Company’s impact on environmental, social and governance issues.

Navigator is also featured in around 40 share indexes.

Navigator's sustainable performance and business have been recognised in ESG questionnaires and ratings.

In February 2025, Navigator was again named by CDP – Disclosure Insight Action as a leader in climate change mitigation, with

an “A” rating in the CDP Climate Change questionnaire, placing us in the A-List for Climate, with continued leadership status.

On 12 July 2024, Navigator renewed its rating as a low risk company for investors when it was named a “2025 ESG Industry Top

Rated Company” in the ESG Risk Rating by Sustainalytics, one of the world’s best respected ESG rating agencies.

Navigator also achieved an A-rating from the MSCI ESG Ratings assessment (2024).

Navigator's rating and excellent ranking are important facts that reflect its ongoing efforts to integrate sustainability as a priority

in its business model its capacity to anticipate and manage ESG risks in the conduct of its operations.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 115

The average target price assigned by the 8 analysts following the share, at the end of the year, was 5 euros, approximately 39%

above the closing price (3.59 euros), and 23% higher than the 2023 average target price, with six Buy recommendations and two

Keep recommendations.

Analysts’ Recommendations in 2024

For information about Navigator's capital structure, please see the Corporate Governance Report in this Annual Report.

4.9 Contribution to State tax revenues

In the course of the Navigator Group’s business, its component companies are subject to a large number of taxes, charges and

contributions, making the Group a major contributor to State revenues in Portugal, helping the country to achieve its welfare

and development objectives. The tax policy therefore has a significant impact on the business fabric, affecting all of the Group's

value chain.

For this reason, the Navigator Group has a tax policy aligned with the Group’s business development strategy, defined in

accordance with the economic substance of its business and designed to ensure full compliance, by Group entities, with their

tax obligations, in all the jurisdictions in which they carry on their business, seeking to comply fully with the spirit and letter of

the applicable legislation.

Aware of its role in Portugal's industrial and business fabric, and because of the vital importance of transparency in dealings

with shareholders, the Navigator Group has sought in recent years to calculate its Tax Footprint, identifying the volume of tax

revenues obtained from its business operations and the taxes it collects and administers on behalf of the State and other

parties, thereby contributing on this dual basis to the State’s tax revenues.

As illustrated in the “Taxes paid” graph, the Group footed a total tax bill in 2024 (including more than 20 different taxes,

contributions and charges) of €124 million (2023: €109 million), equivalent to an effective tax burden of 35.22% in 2024

(2023: 31.42%) on pre-tax profits. This tax burden consisted primarily of Corporation Tax (IRC), including surcharges

(Municipal and State), Autonomous (flat-rate) Taxation (TA) and Social Security contributions, the last two of which totalled

€93 million (2023: €79 million) and €23 million (2023: €22 million), respectively.

Buy

Hold

Sell

ANNUAL REPORT 2024 • MANAGEMENT REPORT 116

Taxes paid include fairly substantial environmental taxes, totalling 5 million euros. These include the Petroleum Products Tax,

Water Resources Charge, Public Maritime Domain Charge, Waste Management Charge, Special Consumption Tax (IEC) on

electricity, Extraordinary Contribution on the Energy Sector (CESE), Single Road Tax (IUC) and CO2 licenses, on which the

outlay was higher than in the previous year (2023: 4 million), due to more licenses being needed. This increase also

demonstrates the fiscal contribution to the pursuit of sustainability goals, in line with the Group’s policy. Accordingly, the size

of the Group’s tax bill again shows that its contribution is already high, meaning that the creation of new charges or financial

contributions in future will clearly result in double taxation and a heavy tax burden for the Group, the consequence of which

will be to limit Navigator’s capacity to invest in more sustainable projects, as we have been doing.

In taxes levied by the State, Navigator as a whole paid out, in 2024, a sum of 1158 million euros (2023: €1119 million), with

VAT once again the single largest contributor to this total (2024: €1064 million vs. 2023: 1017 million), pointing to the Group's

collaboration in collecting tax revenues for the Portuguese State. It should be noted that Navigator is not remunerated by the

State for collecting this tax, in contrast to what happens in other jurisdictions, and even to the situation in Portugal for other

economic operators, which are remunerated by the tax authority (e.g. attachments made on the tax authority’s request),

meaning that Navigator bears in full the costs of levying these taxes on the State's behalf.

CIT

60%

Social

Security

contributions

supported by

Company

20%

Municipal and

State surcharge

19%

CIT

75%

Social

Security

supported

by Company

18%

Enviromental

taxes

Main taxes paid

Total tax paid

ANNUAL REPORT 2024 • MANAGEMENT REPORT 117

Mention should also be made of the VAT assessed and self-assessed by Navigator in other jurisdictions where it is registered for

VAT purposes outside Portugal, where it collected an additional total of €59 million in VAT (2023: €57 million) for the respective

state authorities.

VAT collected for other states

Country

2024

2023

Figures in Euros

Germany

17 181 032

15 144 100

Poland

17 223 814

14 299 873

Netherlands

16 948 429

11 947 886

United Kingdom

2 325 176

8 250 287

France

1 798 043

3 602 915

Spain

2 526 286

2 417 292

Switzerland

€-75

694 581

Italy

815 334

329 550

Total

58 818 038

56 686 485

The Group also collects €10.9 million in Social Security contributions payable by its Employees (2023: €10.4 million) and €24

million in income tax (IRS) deducted at source (2023: €34 million), essentially on salaries paid to its Employees. The labour tax

rate for 2024 stood at 16.16% (2023: 18.90%), and the increase was essentially due to the reduction in the Group's

consolidated profits (acquisition of Accrol). This indicator is calculated as the ratio between taxes levied on labour (Social

Security contributions payable by the company and the worker, and IRS deducted from employees’ pay) and pre-tax profits.

Taxes collected

VAT assessed and

self-assessed

92%

Personal /corporate

income tax

withholdings

Social Security under the

responsibility of the employee

ANNUAL REPORT 2024 • MANAGEMENT REPORT 118

In terms of the geographical distribution within Portugal of taxes charged on a territorial basis (municipal surcharge,

Municipal Property Tax, Municipal Conveyance Tax and municipal charges), the Group has the largest tax bill in the regions of

Setúbal, Figueira da Foz, Aveiro and Vila Velha de Ródão, where it pays local taxes of €2.2 million, €1.6 million, €0.8 million

and €0.5 million, respectively.

Worldwide, the Group paid out a total of €57 M in Corporate Income Tax (CIT) in 2023, determined on a cash flow basis. The

following table provides a geographical breakdown of corporate income tax paid by jurisdiction/country:

Jurisdiction

Accounting

result in 2022

Corporation

Tax paid

in 2023

Share of

Corporation

Tax paid

in 2023

Accounting

result in 2021

Corporation

Tax paid

in 2022

Share of

Corporation

Tax paid

in 2022

Figures in Euros

Spain

3 397 530

4 283 482

2.62%

946 641

311 989

0.47%

Netherlands

77 631

14 239

0.01%

58 620

8 182

0.01%

Portugal

499 827 076

157 819 034

96.57%

496 215 202

64 445 158

97.00%

France

109 464

54 649

0.03%

94 340

26 322

0.04%

Germany

189 360

65 200

0.04%

204 280

237 331

0.36%

Austria

40 593

4 268

0.00%

338 780

4 268

0.01%

United Arab Emirates

3 940

0.00%

9 213

0.00%

United States

67 239 990

479 402

0.29%

3 242 467

1 137 557

1.71%

Italy

88 319

36 424

0.02%

64 145

17 087

0.03%

Morocco

18 933

2 596

0.00%

13 152

1 621

0.00%

Mexico

18 747

12 472

0.01%

11 379

8 737

0.01%

Poland

14 926

4 667

0.00%

-3 651 881

1 964

0.00%

United Kingdom

308 163

137 493

0.08%

273 674

0.00%

Russia

0.00%

30 832

0.00%

Turkey

17 236

1 857

0.00%

5 654

12 310

0.02%

Egypt

8 951

887

0.00%

14 775

2 000

0.00%

Ireland

6 228

498 941

0.31%

566 730

220 107

0.33%

South Africa

0.00%

Nigeria

0.00%

Mozambique

13 713 375

1 447

0.00%

1 984 682

1 488

0.00%

Total

557 653 711

163 417 057

100.00%

500 422 683

66 436 122

100.00%

In the context of compliance with its country by country tax reporting obligations, it may be seen that, in 2023, the Group paid

97% of its global corporate income tax burden in Portugal (2022: 97.00%; 2021: 78.87%; 2020: 80.92%; 2019: 95.95%;

2018: 92.93%; 2017: 93.78%), in the 19 jurisdictions (2022: 17; 2021:18; 2020 to 2019: 16; 2018: 18; 2017:17) where the

Group is established, its tax payments represented the following percentages of global corporation tax: 3.12% in Europe,

0.00% in Africa & Middle East and 0.30% in America.

Lastly, the Tax footprint report is of special importance to the Group in its efforts to computerise its tax function, with a view to

the reliability of fiscal information for compliance with tax reporting obligations, and insofar as it brings together and analyses

ANNUAL REPORT 2024 • MANAGEMENT REPORT 119

the main indicators for the many different taxes paid and collected on behalf of the State, and the Group's decisive contribution

to public revenues in Portugal.

4.10 The Navigator Group's tax policy

The Navigator Group fulfils the duties of corporate citizenship by complying with its obligation to create value and finance the

general functions of the States where its carries on its business, by paying taxes, contributions, charges and other levies

payable under the law, helping to promote the sustainable economic and social development development of these countries.

The Navigator Group's tax policy is intended to ensure full compliance, by the entities making up the Group, of their tax

obligations in all the jurisdictions in which they carry on their business, seeking to comply in full with the spirit and letter of the

applicable legislation.

To this end, the Navigator Group relies on its internal specialists and external consultants (where necessary) to ensure that the

taxation law applicable to its business and transactions is interpreted appropriately and prudently, and it also seeks binding

information from the tax authorities, where admissible and opportune, in order to ensure compliance with its tax obligations, in

a spirit of collaboration and in its pro-active endeavours to minimise risks and possible tax contingencies.

The Navigator Group's tax policy is aligned with the group's business development strategy, meaning that the policy reflects

the economic substance of its activities. For this reason, the Group's transactions are treated for tax purposes in keeping with

its business activities, and the fiscal implications of those transactions are just one of many economic factors to be considered

in management decisions at the Navigator Group.

Obviously, like any other business cost, the Navigator Group is obliged to manage its tax expenditure in a financially

responsible manner for the Company and for its Shareholders. For this reason, under its tax policy, the Navigator Group makes

use of the tax benefits and incentives for which it is eligible on the tax legislation of the countries where it carries on its

business and which are appropriate to that business, in view of its economic substance.

In addition, in transactions with related entities, the rules, OECD guidelines and international best practices in relation to

transfer pricing are considered when deciding on the terms and conditions of these intra-group transactions.

The Navigator Group also takes active steps to establish a relationship based on cooperation with the tax authorities of the

countries where it carries on its business, in order to ensure it complies with tax legislation. This also entails providing the

information and mandatory documents required by these tax authorities, in order to ensure that it complies with its own

obligations and also that the economic operators interacting with the Navigator Group likewise comply with their respective tax

obligations. Importance is also attached to appropriate and effective disclosure of the Navigator Group's tax policy, as well as

of its tax footprint, providing an annual breakdown of its tax bill and of the taxes that it collects and administers on behalf of

the State or other parties, thereby contributing on two fronts to the State’s fiscal revenues and the payments made to public

authorities. Lastly, the Navigator Group develops and complies with internal procedures for appropriate and regular oversight

of its tax practices and review of its tax policy, with the involvement of its corporate boards, in order to minimise the potential

financial and reputational risks involved in decision-making on taxation matters.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 120

5. Non-Financial Statement

Preliminary note

The Corporate Sustainability Reporting Directive (CSRD)

requires the disclosure of information on sustainability, in accordance

with European reporting standards, with reference to the period starting 1 January 2024.

The CSRD laid down that Member States should transpose its provisions by 6 July 2024, and it is applicable to companies included

within the terms resulting from its transposition into the respective national legal systems.

The process of transposing this Directive into Portuguese law was not concluded by that date, nor by the end of 2024 and, to the

best of our knowledge, it remains under consideration by the competent authorities; as a result, by 1 January 2025 it has still not

taken effect.

Companies subject to the CSRD, such as Navigator, are already included under the Non Financial Reporting Directive (NFRD), and

the CSRD represents a very significant change in sustainability reporting, requiring compliance with the more exacting criteria of

the European Sustainability Reporting Standards (ESRS)

In view of the failure to transpose the CSRD, the Portuguese Securities Market Commission (CMVM) issued a recommendation on

9 December 2024 to the effect that companies subject to its supervision and which the new duty would apply as from 1 January

2025 should make every effort to comply with the requirements of the Directive in question, so as to bring greater continuity,

adaptability, transparency and comparability to the sustainability information disclosed, aligning themselves with its objectives..

In its annual circular in 2025, the CMVM subsequently announced that, in view of the legal context described, it will take a gradual

approach, seeking above all to promote gradual adaptation by Issuers to the requirements which will follow from transposition of

the CSRD.

Accordingly, when drawing up this report in line with the recommendations, The Navigator Company has complied, voluntarily,

with the rules established in the CSRD, where and to the extent to which it was able to ensure full compliance with the respective

provisions, considering the failure to transpose the directive, as described, within the deadlines and period indicated.

Directive (EU) 2022/2464 of the European Parliament and the Council, of 14 December 2022, amending Regulation (EU) 537/2014, Directive 2004/109/EC, Directive

2006/43/EC and Directive 2013/34/EU as regards corporate sustainability reporting.

Delegated Regulation (EU) 2023/2772.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 121

5.1. General disclosures – ESRS 2

5.1.1. Basis of preparation

5.1.1.1. General basis of preparation of the Non-Financial Statement (BP-1)

Scope of consolidation

The Non-Financial Statement has been drawn up on a consolidated basis, and the scope of consolidation is the same as for the

Financial Statements. There are affiliates included in the scope of consolidation which are exempt from the obligation to submit

individual or consolidated sustainability reports

. Encompasses information and data aligned with the calendar year of 2024,

covering the period from 1 January to 31 December. For disclosures on E1-6 Gross scopes 1, 2, 3 GHG emissions and total

greenhouse gas emissions (GHG) operating control was considered in determining the scope of consolidation. [ESRS 2.5a |

ESRS 2.5b1| ESRS 2.5b2]

The company has not invoked the exemption established in Articles 19-A.3 and 29-A.3, of Directive 2013/34/UE, on the

disclosure of imminent facts or matters under negotiation for companies established in a Member State of the EU [ESRS 2.5e]

Value chain

In keeping with the double materiality principle, relevant information on the value chain is included, both upstream and

downstream, whenever necessary for an understanding of Navigator’s material impacts, risks and opportunities and to point to

compliance with the qualitative characteristics defined in the Corporate Sustainability Reporting Directive (CSRD). In keeping

with this, commitments and specific actions have been incorporated to ensure sustainable practices at all stages of our

operations. These commitments can be consulted in the 2030 Roadmap (Chapter

3.4.4). [ESRS 2.5c]

Intellectual property, know-how or results of innovation

Navigator has not used the option of omitting information about intellectual property, know-how or results of innovation [ESRS

2.5d].

External verification

The information contained in the Non-Financial Statement has been verified by KPMG & Associados - Sociedade de Revisores

Oficiais de Contas, S.A. This firm has prepared an independent limited reliability assurance report (Chap. 9.4).

Navigator Brands, S.A.; Navigator Parques Industriais, S.A.; Navigator Paper Figueira, S.A.; Empremédia - Corretores de Seguros, S.A.; Empremedia, DAC; Empremedia

RE, DAC; RAIZ - Instituto de Investigação da Floresta e Papel; Enerpulp – Cogeração Energética de Pasta, S.A.; Navigator Pulp Figueira, S.A.; Ema Cacia - Engenharia e

Manutenção Industrial, ACE; Ema Setúbal - Engenharia e Manutenção Industrial, ACE; Ema Figueira da Foz - Engenharia e Manutenção Industrial, ACE; Navigator Pulp

Setúbal, S.A.; Navigator Pulp Aveiro, S.A.; Navigator Fiber Solutions, S.A.; Navigator Tissue Aveiro, S.A.; Navigator Tissue Ródão, S.A.; Navigator Tissue Ibérica, S.A.;

Navigator Tissue Ejea, SL; Navigator Tissue France, EURL; Portucel Moçambique - Sociedade de Desenvolvimento Florestal e Industrial, Lda; Navigator Forest Portugal,

S.A.; EucaliptusLand, S.A.; Gavião - Sociedade de Caça e Turismo, S.A.; Afocelca - Agrupamento Complementar de Empresas para Proteção Contra Incêndios, ACE;

Viveiros Aliança - Empresa Produtora de Plantas, S.A.; Bosques do Atlântico, SL; Navigator Africa, SRL; Navigator Paper Setúbal, S.A.; Navigator North America Inc.;

Navigator Afrique du Nord; Navigator España, S.A.; Navigator Netherlands, BV; Navigator France, EURL; Navigator Paper Company UK, Ltd; Navigator Holding Tissue UK,

Ltd; Navigator Corporate UK, Ltd; Accrol Holdings, Ltd; Navigator Tissue UK, Ltd; LTC Parent Ltd; Leicester Tissue Company Ltd; Art Tissue Ltd; John Dale (Holdings) Ltd;

John Dale, Ltd; Severn Delta, Ltd; Navigator Italia, SRL; Navigator Deutschland, GmbH; Navigator Paper Austria, GmbH; Navigator Paper Poland SP Z.O.O; Navigator

Eurasia; Navigator Paper Mexico; Navigator Middle East Trading DMCC; Navigator Egypt, ELLC; Navigator Paper Southern Africa; Portucel Nigeria Limited; Navigator Green

Fuels Setúbal, S.A.; Navigator Green Fuels Figueira da Foz, S.A.; Navigator Abastecimento de Madeira, ACE;

Pulpchem Logistics, ACE.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 122

5.1.1.2. Disclosures in relation to specific circumstances (BP-2)

Time horizons

Navigator has selected time horizons consistent with the ESRS definitions for impacts, risks and opportunities, except for

climate risks. The time horizons are: short term (<1 year), medium term (1 to 5 years) and long term (>5 years). In the case

of climate risks, the time horizons are aligned with the TCFD recommendations: medium term (up to 2035) and long term (up

to 2050). [ESRS 2.9a]

Value chain, sources of estimation and outcome uncertainty

The metrics/indicators/KPIs which include estimated upstream and/or downstream value chain data, using indirect sources, are

scope 3 emissions (E1-6). Calculation of this indicator uses estimates based on the best available information, albeit subject to

uncertainty, in particular emissions associated with the transformation of intermediate products (Category 10) and the end of

life of products (Category 12) Scope 3 emissions are also calculated on the basis of emission factors from credible data bases

which, even so, may not best represent the reality of Navigator’s value chain. [ESRS 2.10]

Additionally, estimates are used in the case of disclosures on: estimated financial impact of climate change (E1.SBM-3); water

withdrawal (E3-4); hours worked for unwaged workers (S1-14); and monetary value of donations in kind (specific disclosure by

entity). Unless otherwise indicated, the metrics disclosed in the sustainability statement have not been validated by an external

entity other than the auditor of the report. For further information, please see sub-chapter 9.4 [ESRS 2.11]

Comparative information

Navigator has made use of the transitional provision related to section “7.1 Presenting comparative information” of ESRS 1

and, in the case of metrics, does not present the comparative information required by this section in this reporting year.

Comparative data is presented only for the targets established, where available/applicable.

Changes in preparation or presentation of sustainability information

Changes in the preparation and presentation of sustainability information in comparison with the previous reference period,

where applicable, are identified jointly with the respective information. It should be noted that, in environmental indicators, as

in previous year, scope 1 emissions have been revised, incorporating the changes in EETS (European Emissions Trading

Scheme) verification and information not available at the time of publication of the 2023 Annual Report. These changes have a

materiality of less than 0.2%. It is noted that, in the case of social indicators, the 2023 own workforce data (indicator S1-6)

has been updated to include workers at the Tissue Ejea unit (Spain) [ESRS 2.13].

Reporting errors in prior periods

Navigator has not identified material errors in relation to information reported in prior periods. [ESRS 2.14]

Ecoinvent, CEPI and Eurostat

ANNUAL REPORT 2024 • MANAGEMENT REPORT 123

Disclosures stemming from local legislation or generally accepted sustainability reporting pronouncements

The Non-Financial Statement seeks to consolidate and reflect or approach and commitment to sustainability matters. It has been

drawn up in accordance with (see “Preliminary note” at the start of this chapter): (1) the European Sustainability Reporting

Standards (ESRS); and (2) the Non-Financial Reporting Directive, transposed into Portuguese law by Decree-Law 89/2017, of 28

July. Navigator also reports with reference to the GRI (Global Reporting Initiative) Standards, presenting the respective index in

Chapter 9.2. [ESRS 2.15]

Incorporation by reference

Navigator has adopted the “Incorporation by reference” approach to improve the narrative structure of the report and has

included certain disclosure requirements over the course of the annual report and in the Non-Financial Statement itself. The list of

disclosure requirements incorporated by reference and their location in this report is contained in Chapter 9.1.1. [ESRS 2.16]

5.1.2. Governance

The information on the Statement on due diligence (GOV-4) is contained in chapter 9.1.1.

5.1.2.1. The role of the administrative, management and supervisory bodies (GOV-1)

Description of bodies

The following information is incorporated by reference to other parts of the management report and documents:

• Disclosure of the composition and diversity of the administrative, management and supervisory bodies (ESRS

2.21a/c/d/e): Chap. 3.2 Governance Model in this report and in sections 11, 17, 21, 31 and 39 of the Corporate

Governance Report | Part I – Information on capital structure, organisation and corporate governance;

• Representation of employees and other workers on the company’s administrative, management and supervisory bodies

(ESRS 2.21b): Chap. 3.2 Governance Model in this report and in sections 11, 17, 21, 31 and 39 of the Corporate

Governance Report | Part I – Information on capital structure, organisation and corporate governance;

• Disclosure of the identity of the members of administrative, management and supervisory bodies (ESRS 2.22a):

sections 11, 17, 21, 31 and 39 of the Corporate Governance Report | Part I – Information on capital structure,

organisation and corporate governance;

Sustainability governance

Sustainability governance is supported by a number of different bodies and corporate committees, each with clearly defined

functions with regard to sustainability management. Powers to decide on Navigator's mission, strategy, policies and targets

(including as regards sustainable development) lie with the Board of Directors. The design of our 2030 Responsible

Management Agenda (Chap. 3.4.2), published for the first time in 2021, was subject to strategic reflection in 2024, in order to

conciliate it with the review of the double materiality analysis, in accordance with the ESRS standards. This reflection was

presented and approved by the Executive Committee and the commitments and priority plans established in the 2030 Agenda

and Roadmap were adjusted to as to align them with international trends and the social and environmental challenges facing

Navigator's business (Chap. 3.4.1). [ESRS 2.22b/d]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 124

The Executive Committee has delegated management of the 2030 Roadmap to the heads of the different Company

departments and there is a team of sustainability key users, in various departments, who track the action plan established

for the areas where intervention is required under the Roadmap. [ESRS 2.22c]

This team works with management staff, and with support from the Sustainability Department, to assess Navigator's

performance in relation to the objectives set. Any changes to the original plans are reported to the Executive Committee for

approval, and then made public in the Annual Report. [ESRS 2.22c/d] The Sustainability Department is overseen by the

executive director responsible for sustainability issues, enabling coordination across all other Navigator departments and with

the Sustainability Forum in order to address specific issues. [ESRS 2.22c]

The Sustainability Forum is one of the main committees providing support to the Board of Directors. Headed by the Chief

Executive Officer, this structure is supported by a consolidated model with internal and external members, including leading

figures linked to major Stakeholder groups, such as members of academe, NGOs, industrial associations and forestry

producers' organizations. [ESRS 2.22c]

The Sustainability Forum is an arena for dialogue and meets twice a year. One of the annual sessions is internal, attended by

the Forums Permanent Members (internal and external) and the second session adopts an open model, with participation by a

wide-ranging group of Stakeholders (Chapter 3.4.5). These sessions have often taken on a regional flavour, seeking to reach

out to Local Communities, and to benefit from the cooperation between Navigator and the various municipalities where we

have operations, as well as to foster collaboration with leading figures in our sphere of activity. [ESRS 2.22c]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 125

Participation by external Stakeholders is also a feature of the Environmental Board, which consists of four members, all of them

leading academics and independent figures, of respected technical and scientific expertise, especially in the environmental areas

relevant to Navigator's business. [ESRS 2.22c]

The Ethics and Integrity Committee comprises three prestigious independent figures, appointed by the Board of Directors, who

select their own chairman and are charged with monitoring the rules established in the Code of Ethics and Good Conduct. [ESRS

2.22c/ G1.5a]

In addition, attention is drawn to the role of the risk management structures in implementing the respective policies and in

managing ESG risks. [ESRS 2.22c]

There are also the Community Monitoring Committees (Chapter 5.3.3) – in Aveiro, Figueira da Foz, Setúbal and Vila Velha de

Ródão – which include representatives of municipal authorities, local bodies, NGOs and universities, among others. These

committees reflect a policy of openness and sharing information about the activities of the various industrial complexes, as well as

seeking to learn about our Partners' expectations and needs. [ESRS 2.22c]

This governance model enables engagement across various Group structures on sustainability matters, and to incorporate

external perspectives from significant Stakeholders into efforts to honour our commitment to create value sustainably (understood

as a simultaneous quest for economic prosperity, environmental responsibility and a fair society) and to actively encourage our

Partners and Stakeholders to join us in pursuing these goals. [ESRS 2.22c]

The following information is incorporated by reference to other parts of the management report and documents:

• Functions and responsibilities of administrative, management and supervisory bodies in overseeing risks (ESRS

2.22a/b/c): Chap. 3.3 Risk management in this report and in sections 50 to 51 of the Corporate Governance Report | Part

I – Information on capital structure, organisation and corporate governance.

• Role of administrative, management and supervisory bodies with regard to business conduct (ESRS G1.5a): chap. 3.2

Governance Model and sections 11-38, Corporate Governance Report | Part I - Information on Shareholder Structure,

Organisation and Corporate Governance | B. Statutory Bodies and Committees | II. Management and supervision | III.

Audit

Expertise and skills

The members of the Board of Directors and the Executive Committee have powers and are responsible for decision-making

processes relating to all sustainability issues. Internal departments report all matters relating to sustainability to the EB. Likewise,

sustainability matters are discussed by the Environmental Board and the Sustainability Forum, which report to the Executive

Committee and the Board of Directors. It may also be noted that, in connection with ESG (Environmental, Social and Governance)

requirements, a training programme was designed and implemented in 2022 and 2023, by a specialist external firm, aimed at the

executive directors and a number of other senior managers, in order to strengthen internal expertise in the organisation of these

fields. The topics addressed included the dynamics of the international agenda and the response of institutions to climate and

social challenges (2030 Agenda, the Paris Agreement and the European Union Green Deal), sustainable finance, Environmental

Taxonomy, the Sustainable Finance Disclosure Regulation (SFDR), the Corporate Sustainability Reporting Directive (CSRD),

double materiality, TCFD and the Sustainability Due Diligence Directive, which are directly or indirectly related to the IROs which

have been formally identified. [ESRS 2.23a/b]

The following information is incorporated by reference to other parts of the management report and documents:

• Disclosures concerning the expertise of members of administrative, management and supervisory bodies in sustainability

and business conduct matters (ESRS 2.23/ G1.5b): Chap. 3.2 Governance Model in this report and in sections 16 to 19 of

the Corporate Governance Report | Part I – Information on capital structure, organisation and corporate governance.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 126

Board of Directors (administration and management bodies)

ESRS 2.21a and ESRS 2.21e

Number of Members

Percentage

Executive

42.9%

Non-executive

57.1%

Independent

28.6%

ESRS 2.21d

Number of Members

Percentage

Male

64.3%

Female

35.7%

Others

Not disclosed

Total

100%

Gender diversity on Board of Directors

(Index)

0.56

Supervision

The figures below refer only to the Audit Board.

ESRS 2.21a and ESRS 2.21e

Number of Members

Percentage

Non-Independent

25%

Independent

75%

ESRS 2.21d

Number of Members

Percentage

Male

50%

Female

50%

Others

Not disclosed

Total

100%

Gender diversity on Audit Board (Index)

ANNUAL REPORT 2024 • MANAGEMENT REPORT 127

5.1.2.2. Information provided on sustainability matters addressed by the undertaking’s

administrative, management and supervisory bodies (GOV-2)

The following information is incorporated by reference to other documents:

• Information provided to bodies on IROs (ESRS 2.26a/b/AR6): sections 21, 24 and 25 of the Corporate Governance

Report | Part I – Information on capital structure, organisation and corporate governance.

The sustainability issues/IROs assessed by administrative, management and supervisory bodies, or by the relevant

committees, during the reporting period, included:

• Regulatory issues and decarbonisation projects, including analysis of the EETS review, project to install a new biomass

boiler at the Vila Velha de Ródão plant and solar power facilities.

• Review of double materiality analysis of sustainability matters in line with the ESRS standards developed in connection

with the European Corporate Sustainability Reporting Directive (CSRD); calibration of material topics, adjustment of

Navigator’s 2030 Agenda and alignment of sustainability reporting with the CSRD and the ESRS standards.

• Nomination of new external members for the Sustainability Forum and planning of two annual sessions, given over to

the topics of “Sustainability reporting in the context of the CSRD. The case of Supplier Chain Management” (internal

session) and “The Navigator Company’s new 2030 Agenda” (external session).

• Project and 2025-2030 action plan for monitoring suppliers in quantification (and reduction) of emissions and the

regulatory requirements concerning ESG (environmental, social and governance) practices.

• Approval of review of Risk Management Policy in the Risk Management Regulations.

• Approval of the Environmental Policy, addressing the main environmental issues considered in relation to Navigator's

business and referring, where applicable, to other Company policies dealing with similar matters.

• Presentation of issues related to programmes for certification groups and Forestry producers’ organisations, including

presentation on Forestry Development Programme, focussing on strategies, performance indicators (KPIs),

sustainability, technical training, certification and future challenges.

• Presentation of proposals for reformulating Navigator's biodiversity strategy and integration of Navigator in SPEA’s

initiative for a National Network of Bird Sanctuaries.

• Presentation of a proposed pilot project for voluntary carbon sequestration to be implemented in an area managed by

the Company.

• Planning for start-up of moulded cellulose project.

• Cooperation Agreement between União das Misericórdias Portuguesas (UMP) and Navigator Forest Portugal, with a view

to improving sustainability and forest management in woodlands of eucalyptus and other species on properties owned

by these UMP member organisations.

• Proposals relating to Community Monitoring Committees (CMCs), as prime forums for discussion.

• Discussion of Corporate Programme for Reducing Water Use.

• Discussion of 2025 Equality Plan and associated initiatives, such as the “DEI Diagnosis”.

• Monitoring of the GROWING Project and respective initiatives.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 128

5.1.2.3. Integration of sustainability-related performance in incentive schemes (GOV-3)

The following information is incorporated by reference to other documents:

• Incentive schemes and remuneration policies linked to sustainability matters (ESRS 2.29a/b/c/e): sections 24-25 and 70

of the Corporate Governance Report | Part I – Information on capital structure, organisation and corporate governance.

Assessment of the performance of each Executive director follows a structured internal process defined in the Remuneration

Policy. The basic criteria for assessing the performance of Executive directors (in force 2023-2025) are defined in that policy,

setting the variable remuneration component.

The annual variable remuneration is based on a target amount applicable to each Director and which is payable when his

performance and that of the Company corresponds to expectations and pre-established goals. This target value is set after

considering the general principles set out above - market, specific duties, the Company's situation -, with special attention

being paid to comparable market situations in positions of equivalent importance.

Actual performance is assessed against expectations and goals, thereby defining the variation in relation to the target, on the

basis of a series of quantitative and qualitative KPIs related to the performance of the Company (corresponding to the general

business indicators, with a weighting of 65%) and that of the Executive director in question. These consist of Specific Goals –

corresponding to the proportion of the variable remuneration dependent on sustainability-related goals and/or

impacts (20%), which include ESG KPIs such as, for instance, the findings of the annual Organisational climate study,

reduction of CO

emissions, certified wood and consumption of water, energy and wood –, and Behavioural Indicators (15%).

On the other hand, Non-executive directors and Members of the Audit Board only receive fixed remuneration, with no variable

component, meaning there are no incentives linked to any factor. [ESRS 2.29a/b/c/e] [E1.GOV-3.13]

5.1.2.4. Risk management and internal controls over sustainability reporting (GOV-5)

The Navigator Group's internal control system is based on the COSO (Committee of Sponsoring Organizations of the Treadway

Commission) guidelines, ensuring the integrity and transparency of the internal processes. In order to strengthen the reliability

of sustainability reporting, the Group has adopted the COSO – ICSR (Internal Control over Sustainability Reporting) guidelines.

This retains the five fundamental components of the traditional internal control model, adjusted to the sustainability context,

ensuring a structured and effective approach to risk management and the quality of the information disclosed [ESRS 2.36a/b]:

Control environment:

• Navigator promotes an organisational culture that attaches value to ethics and socio-environmental responsibility. The

Group's Codes of Ethics and Good Conduct establish values, principles and rules of conduct to be observed within the

organisation and in dealings with Shareholders, Suppliers, Clients and other Stakeholders, in their different aspects

and forms.

• The Board of Directors is responsible for creating and maintaining an effective system of internal control and risk

management. Responsibility for maintaining the internal control and risk management system in relation to

sustainability reporting is delegated to the Executive Committee. The control environment is supported by its own

governance structure, aligned with the 3-line model of the IIA (Institute of Internal Auditors), as described in sections

50-55, Corporate Governance Report | Part III. Internal control and risk management.

Risk assessment:

ANNUAL REPORT 2024 • MANAGEMENT REPORT 129

• The Navigator Group's risk management process is in line with internationally accepted best practices, models and

frameworks for risk management, including COSO II - Integrated Framework for Enterprise Risk Management and ISO

31000, and is supported by the Risk Management Policy.

• The Group pro-actively identifies and analyses the risks that may affect the reliability and accuracy of its sustainability

reporting This includes monitoring of factors such as changes to legislation and regulations, Stakeholder expectations

and environmental impacts from its industrial activities.

• The Group has adopted an approach that integrates risk management with ESG topics, ensuring a connection between

the double materiality exercise and the risk management model, so as to identify, assess and mitigate impacts and

opportunities strategically.

Control activities:

• The Navigator Group's controls include policies, guidelines, procedures and organisational structures that ensure

compliance with the Executive Committee’s instructions and mitigation of the risks associated with sustainability

reporting.

• The minimum requirements for internal control are designed to prevent, detect and correct errors and irregularities in

the collection, processing and disclosure of ESG information, and also to ensure data is traceable.

• These activities are implemented at all levels of the organisation and include approvals, authorisations, checks,

reconciliations and segregation of duties.

Reporting and communication:

• The Group’s reporting and communication channels support the collection, processing and disclosure of sustainability

reporting information, and there is continuous communication between the different levels of the organisation and

external Stakeholders.

Monitoring and continuous improvement:

• Sustainability reporting is monitored by the Executive Committee and the Board of Directors, ensuring alignment with

the Group's strategic objectives. Periodic assessments are conducted of the effectiveness of the internal control system

in the context of sustainability reporting. On the basis of these assessments, corrective action is implemented with a

view to continuous improvement of the quality and accuracy of the information disclosed.

In prioritising the risks related to sustainability reporting and in analysing their importance in relation to the organisation’s

other risks, the assessment is carried out in the broader context of the Group’s main risks (see Chap. 3.3 Risk management),

given that they may add to or attenuate some of the main risks. This integrated approach ensures that material risks and

opportunities are incorporated in Enterprise Risk Management, the Group’s risk management tool. [ESRS 2.36c/d]

Navigator arranges for periodic reporting of the findings of its risk assessment and the respective internal controls to the

administrative, management and supervisory bodies, through its governance model. The findings of the risk assessment are

discussed, whenever justified, at meetings of the Risk Management Committee, held quarterly, and then presented at sessions

of the Risk Oversight Committee (six-monthly meetings) and the Executive Committee (weekly meetings). The Sustainability

Forum (bi-annual meetings) and the Environmental Board also discuss significant issues related to sustainability (see Chap. 5.1).

[ESRS 2.36e]

The following information is incorporated by reference to other parts of the management report and documents:

• Risk control and management (ESRS 2.36a/b): sections 50-55 of the Corporate Governance Report | Part I –

Information on capital structure, organisation and corporate governance.

• Main risks identified, together with respective mitigation strategies (ESRS 2.36c): Chap. 3.3 Risk management in this

report and in section 53 of the Corporate Governance Report | Part I – Information on capital structure, organisation

and corporate governance and section in this chapter on review of the double materiality analysis.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 130

5.1.3. Strategy

5.1.3.1. Strategy, business model and value chain (SBM-1)

The following information is incorporated by reference to other parts of the management report and other documents:

• Describe the significant groups of products offered and/or services provided by the company (ESRS 2.40a-i/ii): Chap. 2.2

Company Profile, Chap. 3.1 Business Strategy, Chap. 4 Performance in businesses.

• Headcount of employees by geographical area/country (ESRS 2.40a-iii): Chap. 5.3.1.3.2 Characteristics of salaried

Employees of the Company (S1-6).

• Company’s sustainability goals in terms of groups of products and services, customer groups, geographical areas and

Stakeholder relations (ESRS 2.40e): Chap. 2.2 Company Profile; Chap. 2.3 Creating sustainable value; Chap. 3.1

Business Strategy; Chap. 3.4.4 2030 Roadmap; Chap. 3.4.5 Stakeholder engagement.

• Assessment of current significant products and/or services and significant markets and groups of customers, in relation to

its sustainability goals (ESRS 2.40f): Chap. 4 Performance in businesses.

• Elements of company strategy that relate to sustainability matters (ESRS 2.40g): Chap. 3.1 Business strategy and Chap.

3.4 2030 Agenda and Roadmap, including sub-chapters 3.4.1 Global trends and challenges for Navigator, 3.4.2 Our

Agenda and 3.4.3 Contribution to SDGs.

• Exemption from disclosure of the information referred to in Article 18.1 a) of Directive 2013/34/EU (ESRS 2.41): note 2.1

on business segments in Financial Statements.

• Business model (ESRS 2.42 a/b): Chap. 2.2 Company Profile and chap. 3.1 Business strategy.

Value chain

The figure below illustrates The Navigator Company's value chain, dividing activities into upstream, own operations and

downstream, as well as the connection to leading Suppliers, distribution channels and Customers. [ESRS 2.42c]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 131

Revenues

In 2024, Navigator generated total revenues of 2088 million euros. The revenues from the different sectors in which Navigator

operates are detailed in 2.1 of the Notes to the Financial Statements, in relation to business segments:

Navigator has two Combined Cycle Natural Gas Power Stations which are currently operating for in-house consumption, with

the sale of any power surpluses to the national grid. These assets fall within activity 4.30 (High-efficiency co-generation of

heat/cool and power from fossil gaseous fuels) of European Regulation 2020/852 on the European Taxonomy. In 2024,

earnings from this activity totalled 5.1 million euros – see Chap. 5.2.1. [ESRS 2.40d-1]

The Company is not active in producing chemicals. [ESRS 2.40d-2]

Navigator does not generate revenues associated with coal and oil activities [ESRS 2.40d i], controversial weapons [ESRS

2.40d iii] or the cultivation and production of tobacco. [ESRS 2.40d iv]

5.1.3.2. Interests and views of Stakeholders (SBM-2)

The following information is incorporated by reference to other parts of the management report:

• The company’s engagement with Stakeholders (ESRS 2.45a/b): Chap. 3.4.5 Stakeholder engagement

ANNUAL REPORT 2024 • MANAGEMENT REPORT 132

Navigator’s own workforce has a central role in our business and is one of our priorities (Chap. 5.3.1). Our concern with their

fundamental rights is expressed in our Human Rights Policy, which is reflected in our actions. We seek to be an exemplary employer

and to maintain open and transparent dialogue with the workforce. The initiatives we pursue in order to listen to/engage with our

Employees include the Industrial Relations Forum, regular meetings with Workers’ Representative Organisations, the GROWING

project, Employee consultation and organisational climate surveys (Chap. 5.3.1), which enable us to make continuous improvements

to our strategic approach and to respond to Employees’ expectations and needs.

Through community meetings, Workers in the value chain also play an important role in our business (Chap.

5.3.2). They make

their contributions in team meetings and training sessions (in the field and in the classroom). These contributions are analysed by

the Executive Committee, which establishes action plans to implement them, and can potentially influence the Company's strategy

and business model. [S2.9] On the other hand, there may be positive or negative impacts from Navigator on their interests, views

and rights, including respect for their human rights, and these are managed through implementation of specific measures, enabling

us to mitigate negative impacts and boost positive impacts (Chap.

5.3.2). [S2.9]

In terms of affected Communities, the meetings of the Community Monitoring Committees and the Community Liaison Officers

(in Mozambique), as well as other engagement procedures, are designed to bring Navigator closer to Local Communities,

promoting joint reflection and strengthening our social license to operate (Chap. 5.3.3). These initiatives are very important for

understanding the concerns of Communities, seeking to learn about their expectations and to respond to their needs. [S3.7]

Another aspect that is given consideration is prospecting and developing business opportunities in using woodlands for

multiple purposes, through agroforestry initiatives, such as promoting businesses to sell non-wood products or providing areas

for specific activities on properties under Navigator's management, taking into account the local, regional or national economy

and listening to operators or other representatives of Local Communities, when relevant and opportune. [S3.7]

We should stress that our governance model (Chap. 3.2) - which involves the participation of internal and external Stakeholders

- enables engagement with various structures across Navigator on sustainability issues, to incorporate an external perspective

from significant Stakeholders into efforts to honour our commitment to create value sustainably and to actively encourage all

our Partners and Stakeholders to join us in pursuing these goals. We believe that only with strong governance will we be able to

address the main environmental, social and economic risks and opportunities which have an impact on The Navigator Company,

and the impacts we generate for our various Stakeholders. In this way, all relevant contributions from our different Stakeholders

are shared with the Executive Committee. [ESRS 2.45d]

No changes occurred in the reporting period to the Company’s strategy or business model as a result of Stakeholder

interactions. Stakeholder views are aligned with the Company’s current strategy and are often complementary. [ESRS 2.45c c1

c2]

5.1.3.3. Material impacts, risks and opportunities and their interaction with strategy and

business model (SBM-3)

Impacts, risks and opportunities

The following information is incorporated by reference to other parts of the Non-Financial Statement, more specifically to the

chapters on thematic standards, for detailed information on:

• Description of material impacts resulting from materiality assessment (ESRS 2.48a)

• Description of material risks and opportunities resulting from materiality assessment (ESRS 2.48a)

• Description of time horizons (ESRS 2.48ciii)

• Specification of the impacts, risks and opportunities covered by the disclosure requirements in the ESRS (ESRS 2.48h)

ANNUAL REPORT 2024 • MANAGEMENT REPORT 133

The Company’s negative or positive material impacts on people or the environment are identified at the start of each thematic

standard [ESRS 2.48c-1]. In addition, the chapters on thematic standards detail the source of these impacts and their

relationship with the Company’s strategy and business model; most material impacts result from its activities or its commercial

dealings, such as purchases of wood, its main raw material [ESRS 2.48c-2] [ESRS 2.48c-4]. The current and anticipated effects

of its material impacts, risks and opportunities on its business model, value chain, strategy and decision-making are addressed

in theme SBM-3 of the thematic ESRS. [ESRS 2.48b]

Financial effects

In the next few years, Navigator plans to conduct a quantitative analysis of sustainability-related risks and assessment of the

financial position of our assets and liabilities. [ESRS 2.48d] [ESRS 2.48e]

In accordance with Appendix C of ESRS 1, Navigator has opted not to report information on the anticipated financial effects of

impacts, risks and opportunities. [ESRS 2.48e]

Resilience of strategy and business model

At Navigator we believe it is essential to have a long-term plan of action that points us towards honouring the commitments

set out in our 2030 Agenda. This is supported by the 2030 Roadmap, a tool based on an ESG framework, enabling the

Company to achieve its ambitions, guiding and tracking its progress over time. At present, the commitments and goals in the

2030 Agenda and Roadmap relate mostly to the Group’s activities in Portugal, but they are planned to evolve so as to include

the other geographical regions in the next few years.

We have accordingly mapped out a position that seeks to boost value creation - maximising our performance, contributing to

the resilience of our business and our corporate reputation and image, and paving the way for sustainability to feature as a

strategic competitive advantage. [ESRS 2.48f]

The following information is incorporated by reference to other parts of the Non-Financial Statement, for detailed information

on:

• Creating sustainable value - Chapter 2.3

• Business Strategy - Chapter 3.1

• 2030 Agenda and Roadmap - Chapter 3.4

• Analysis of climate resilience (ESRS 2.48f) – Chap. 5.2.2.1.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 134

Changes in material IROs in relation to previous reporting period

Not applicable. This is the first year that Navigator has implemented the Double Materiality Assessment under the CSRD. [ESRS

2.48g]

5.1.4. Impact, risk and opportunity management

5.1.4.1. Description of the process to identify and assess material impacts, risks and

opportunities (IRO-1)

The following information is incorporated by reference to other parts of the Corporate Governance Report:

• Corporate Governance Report Part I - Information on Shareholder Structure, Organisation and Corporate Governance

| C. Internal Organisation |III. Internal control and risk management

The publication in the Official Journal of the European Union of the Corporate Sustainability Reporting Directive (CSRD) - Directive

(EU) 2022/2464 established the requirements for reporting sustainability information for a broader group of companies, through

application of the European Sustainability Reporting Standards (ESRS). Because the Navigator Group is already subject to the

Non-Financial Reporting Directive (NFRD), it is included in the first group of companied to implement the new directive -

information relating to FY24, published in 2025. This requirement presents the various stages of implementation of the double

materiality process, as well as the methodologies used, and the findings obtained.

The double materiality assessment was conducted on the basis of a wide-ranging process - carried out in conjunction with the

Semapa Group - which set out to identify, assess, prioritise and monitor the potential and real impacts, positive and negative, on

people and the environment, in the short, medium and long term (materiality impact, inside-out perspective), as well as the

risks and opportunities that might in turn have a financial effect on the Company (materiality impact, outside-in perspective).

The assessment made from these two perspectives, referred to below as “double materiality”, was carried out in the context of

each of the ESRS, dealing with environmental, social and governance issues.

The double materiality reassessment followed a four-stage methodological approach. This design of the process will be

reviewed at least annually (or as necessary), in order to ensure alignment with the most recent practices.

1. Understand

2. Identify

3. Assess

4. Determine

Understand the business,

the value chain and related

activities

Identify impacts, risks and

opportunities (IROs)

Assess the IROs

Determine the material

topics

• Analyse internal

operations, business

model and the available

data.

• Map out the value

chain.

• Identify relevant topics.

• Engage with

Stakeholders.

• Conduct research and

analyses to identify

relevant IROs, using

sector benchmarks,

internal documents and

listening to

Stakeholders.

• Validate and prioritise

the IROs identified for

assessment.

• Define the threshold

applicable to

materiality of impact

and financial

materiality.

• Assess materiality of

impact and financial

materiality.

• Identify the IROs above

the established

threshold.

• Validate the final list of

IROs, and calibrate, if

necessary.

Output

Mapping of value chain; list of

relevant topics resulting from

listening to Stakeholders.

Output

Preliminary list of IROs.

Output

Preliminary findings of IRO

assessment.

Output

Final list of material topics.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 135

The initial stage took into consideration the organisation’s business and operating processes, including the geographical regions

where the Group operates, and commercial relations upstream and downstream (mapping of value chain).

Past experience was taken into account, in view of the history of significant interaction with external experts and

Stakeholders. An external listening exercise was not conducted, as it is not required by the CSRD. Even so, the findings

obtained in this materiality review turned out to be largely aligned with previous periods.

In any case, the Sustainability Forum and the Environmental Board will nonetheless reflect on the exercise, during the course

of 2025.

Contextual information and identification of IROs

The identification stage for the preliminary list of IROs involved 15 information sources, ranging from general resources,

sustainability reports and the internal resources of the Navigator and Semapa Groups, as well as external resources. On the basis

of the research, a list was drawn up with a total of 320 IROs, at the ESRS sub-sub-topic level and considering in the mapping the

business models across the various subsidiaries of the Semapa Group (which includes The Navigator Company), the geographical

regions where they operate and their location along the value chain.

General resources

Sustainability reporting

Internal resources

External resources

In a stage prior to identifying the

impacts, risks and opportunities,

regulatory instruments and guides

were consulted, with a view to

application of the double

materiality analysis.

• Delegated Regulation

(EU) 2023/2772;

• EFRAG IG1 Materiality

Assessment;

• EFRAG IG2 Value Chain;

• EFRAG IG3 List of ESRS

Datapoints (explanatory

note + excel).

A basic set of IROs was

developed, by reviewing the

reports existing in the Semapa

Group.

• Navigator -

Sustainability Report

2023.

Review of Semapa Group internal

resources, with relevance to

identification of IROs and design

of the assessment methodology.

• Materiality analysis for

Semapa Group

subsidiaries 2022

and

2023;

• Semapa Group – list of

risks and opportunities

identified.

• Risk assessment

methodology (ERM).

• Navigator TCFD Report.

Consultation of external

information sources relevant to

Navigator Group's business

segments, in particular:

• TNFD. Draft Sector

Guidance – Forestry and

Paper;

• TNFD. Additional Sector

Guidance – Forestry and

Paper;

• IRO Repository, PwC

International.

In addition to the resources listed above, the four stages of the double materiality analysis also involved considering the inputs

from a number of internal specialists who took part in the various working sessions to validate and assess the list.

Description of the processes for identifying and assessing the environmental IROs

As stated above, the Double Materiality Analysis addressed all the ESRS Standards, using the same methodology and criteria to

determine and assess the IROs identified in each thematic standard. No materially relevant IROs were identified for thematic

standards E2 and S4.

In addition, specific aspects were considered in the context of some of the thematic standards, as presented below.

In the case of climate, as recommended by the TCFD, in 2002 we identified and assessed the main physical risks, acute or

chronic, and the transition risks, which consist of regulatory, technological, market and reputational risks. In the course of this,

and in keeping with the good practices in the TCFD Guidance on Scenario Analysis, we used exploratory analyses that

Navigator Group’s first double materiality exercise

ANNUAL REPORT 2024 • MANAGEMENT REPORT 136

describe a diverse range of plausible future states, which are used to assess potential climate-related risks and uncertainties,

and also to test the resilience of Navigator's strategy for the different future conditions adjacent to these same scenarios

(Chap. 5.2.2). We also identified climate-related opportunities, with potential positive impacts for business: As a member of

the “Climate and Energy” and “Sustainable Reporting and Finance” working parties of BCSD Portugal, we took part in a task-

force (TF) on the subject to climate risks and opportunities, resulting in a new “Business guide to climate risks and

opportunities”. The expertise acquired in this process and from the WBCSD's “Climate-related Financial Impact Guide” has been

applied in the “impact pathways” approach. This is a way of calculating the financial impact of the risks and opportunities

identified, on the basis of different risk implications or opportunities for the Group. In our assessment of transition risks and

opportunities, we identified short, medium and long term events and analysed the exposure of our assets and business

activities to these, by assessing the variation in CO

prices in the short, medium and long term. The information resulting from

these processes contributed to identifying the IROs within the scope of the respective analysis.

In the case of water resources, it is stressed that the IROs identified were screened using several tools and criteria, including

the WRI Aqueduct Water Risk Atlas, which makes it possible to map areas of water stress, Hydrographic Region Management

Plans (HRMPs), Cycle 3, the Water Footprint Indicators, which measure the water impact of products, and the Certification

under ISO 14001, which guarantees sustainable practices in water management.

With regard to biodiversity and ecosystems, identification and assessment of IROs was informed by Navigator’s prior

knowledge of its impacts on biodiversity, on the basis of its practices for assessing impacts from the Group’s forestry activities

and its participation in a pilot project, under the Natural Capital Protocol, undertaken in 2018. In connection with this, it is

important to stress that biodiversity conservation is built into our forest management model, applying a hierarchy of impact

mitigation and assessment of the wildlife both in the areas under management and the surrounding areas. Starting with this

underlying body of information, the compilation of additional information and the mapping of conservation interest zones

contribute to an overall assessment of the risks and opportunities and design of appropriate conservation measures. For all

activities with potential impact, pre-operational assessments are carried out in order to plan the execution of operations at a

local scale, considering the wildlife, cultural heritage and social factors and consulting Stakeholders.

The pilot project mentions were designed to align Navigator’s existing procedures with an internationally agreed standardised

structure, published in the “Forest Products Sector Guide to the Natural Capital Protocol”. This exercise was carried out on the

basis of data gathered over the preceding ten years and involved identifying dependencies on the basis of the ESR (Ecosystem

Services Review).

Lastly, through participation in the WBCSD Forest Solutions Group, Navigator has collaborated in drawing up guidelines on

sustainable forest management developed and disseminated in the document entitled “Forest Sector Nature-Positive

Roadmap”, which has served as an additional benchmark for identifying IROs related to Sustainable Forest Management. In

addition, this document has served as an important starting point for defining other environmental IROs related to the forest,

in relation to other topics in the standards, strengthening Navigator's integrated approach to IROs and to its value chain.

Material IRO assessment process

The process of assessing IROs was carried out through a total of 24 meetings, involving the participation of 73 internal

experts, representing 25 sectors in 19 Departments. During the sessions for each ESRS standard, each expert gave their opinion

on each of the IROs, and the final assessment was the result of a consensus between the various participants involved.

Materiality of impact

In assessing the materiality of impact, we addressed the negative and positive impacts, actual and potential, on the basis of

their severity (a combination of scale, scope, and irremediable character, in the case of negative impacts only) and probability

(not considered for the purposes of calculating the materiality of negative impacts on human rights, in which case severity was

scored in the light of the respective probability). Using quantitative limits for each parameter, the material impacts were identified.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 137

Factors for assessing the materiality of impact

Assessment methodology applied

Scale

Scope

Irremediable character

Probability

5= Very great damage or

benefits for people or the

environment

5= National or international

impact and/or impact on a large

number of people

5= Difficult to remediate or

irremediable/irreversible

1= Certain (<6 months|

Happening)

4= Great damage or

benefits for people or the

environment

3= Regional impact and/or

impact on a moderate number of

people

3= Temporary or easily remediable in

the medium term

0.80= Very probable (6

months to 1 year)

3= Moderate damage or

benefits for people or the

environment

1= Local impact and/or impact

on a small number of people

1= Temporary or easily remediable in

the short term

0.60= Probable (1 to 2

years)

2= Minor damage or

benefits for people or the

environment

0= Not applicable 0= Not applicable

0.40= Unlikely (2 to 5

years)

1= Very minor damage or

benefits for people or the

environment

0.20= Rare (> 5 years)

0= Not applicable

Time Horizon

Short term: Reporting year

Medium term: From reporting year and up to 5

years

Long term: More than 5 years

Financial materiality

In assessing financial materiality, using quantitative limits, we assessed the probability and magnitude of the financial effects of

the risks and opportunities and consequently identified the material risks and opportunities for Navigator.

It should be noted that, with regard to the magnitude criterion, the scoring scales established were based on intervals

corresponding to the percentage of EBITDA, each of the subsidiaries having their respective benchmark values.

Factors for assessing financial materiality

Assessment methodology applied

Magnitude

Probability

5= Critical - Over 20% of EBITDA

1= Certain (<6 months| Happening)

5= High - Between 10% and 20% of EBITDA

0.80= Very probable (6 months to 1 year)

4= Medium - Between 5% and 10% of EBITDA

0.60= Probable (1 to 2 years)

3= Low - Between 1% and 5% of EBITDA

0.40= Unlikely (2 to 5 years)

The likelihood of the

risk/opportunity happening

Magnitude of the potential financial

effect

Probability

Magnitude

ANNUAL REPORT 2024 • MANAGEMENT REPORT 138

1= Very low - Up to 1% of EBITDA

0.20= Rare (> 5 years)

0= Not applicable

Time Horizon

Short term: Reporting year

Medium term: From reporting year

and up to 5 years

Long term: More than 5 years

Conclusion of double materiality process

When the assessment sessions were concluded, a limit of 3 was set, applied to the materiality of impact and financial materiality.

This limit was selected so as to use the same materiality threshold as established in internal risk analyses.

Once the limit was established, a calibration exercise was carried out. After this review, the final list of material IROs for

Navigator presents 60 impacts (40 positive and 20 negative), 26 risks and opportunities (16 risks and 10 opportunities), making

a total of 86 material IROs, breaking down as follows:

• 5 environmental topics, four corresponding to ESRS E1, E3, E4 and E5 and one for Entity-specific disclosure;

• 3 social topics, corresponding to ESRS S1, S2 and S3;

• 1 governance topic, corresponding to ESRS G1.

These findings were subsequently validation by the Executive Committee.

Sustainability topic Value Chain IRO

ESG Dimension Topic Sub-topic Location Type

Environment

E1 Climate change

Climate change

adaptation

Upstream, Own

operation and

Downstream

Positive impact, Risk

and Opportunity

Mitigation of

climate change

Upstream and Own

operations

Positive impact,

Negative Impact, Risk

and Opportunity

Energy

Upstream and Own

operations

Positive impact,

Negative Impact, Risk

and Opportunity

E3 Water and marine

resources

Water - Water

withdrawal

Own operations

Negative impact and

Risk

E4 Biodiversity and

ecosystems

Impacts on status

of species

Upstream and Own

operations

Positive impact and

Negative impact

Impacts and

dependencies on

ecosystem

services

Upstream and Own

operations

Positve impact and

Negative impact

Factors with

direct impact on

biodiversity loss

Upstream and Own

operations

Positive impact, Risk

and Opportunity

E5 Resource use and

Circular economy

Inflows of

resources,

including use of

resources

Upstream and Own

operations

Positive impact and Risk

Waste

Own operations and

Downstream

Positive impact and

Opportunity

Outflows of

resources related

to products and

services

Downstream

Positive impact and

Opportunity

ANNUAL REPORT 2024 • MANAGEMENT REPORT 139

Sustainability topic Value Chain IRO

ESG Dimension Topic Sub-topic Location Type

Sustainable Forest

Management (Entity

Specific)

Upstream and Own

operations

Positive impact

Social

S1 Own workforce

Working

conditions

Own operations

Positive impact,

Negative impact and

Opportunity

Equal treatment

and opportunities

for all

Own operations

Positive impact,

Negative impact and

Opportunity

S2 Workers in the

value chain

Working

conditions

Upstream and Own

operations

Negative impact

Equal treatment

and opportunities

for all

Upstream, Own

operations and

Downstream

Positive impact

Other direct

work-related

impacts

Own operations Positive impact

S3 Affected

communities

Economic, social

and cultural rights

of communities

Own operations Positive impact

Governance G1 Business conduct

Corporate culture Own operations Positive impact and Risk

Management of

supplier relations,

including

payment

practices

Own operations Positive impact

Corruption and

bribery

Own operations Positive impact

5.1.4.2. Disclosure requirements in ESRS covered by the Non-Financial Statement (IRO-2)

The materiality of information was determined on the basis of the material IROs resulting from Navigator's double materiality

assessment. After identifying the material thematic standards, materiality was assessed with regard to disclosure requirements

and datapoints. The materiality assessment process and the use of thresholds are described in the preceding section (IRO-1).

The disclosure requirements to which Navigator responds, by means of this Non-Financial Statement, together with the list of

datapoints resulting from other EU legislation, are identified in Chap. 9.1.1 ESRS Correspondence Tables.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 140

5.2 Environmental information

5.2.1. European Taxonomy

5.2.1.1. Background to the European Environmental Taxonomy

In 2019, the European Commission announced the European Green Deal, a new strategy for development with the aim of

achieving climate neutrality by 2050 and to support economic growth through more efficient means and sustainable use of natural

resources. To facilitate this, a practical framework for sustainable investment has been provided by Regulation (EU) 2020/852

of the European Parliament and the Council of 18 June 2020, on the taxonomy. The taxonomy functions as a standardised and

mandatory classification system, i.e. a common language, to be used to determine which economic activities are considered

"environmentally sustainable" in the European Union. The idea is for companies to direct their investment flow to activities

regarded as sustainable, whilst at the same time maintaining transparency in reporting and reducing the possibility of

greenwashing.

According to the Taxonomy Regulation, for an economic activity to be environmentally sustainable it must:

1. Contribute to at least one of the six environmental objectives identified in the Regulation /climate change mitigation;

climate change adaptation; sustainable use and protection of water and marine resources; transition to a circular

economy; pollution prevention and control; protection and restoration of biodiversity and ecosystems);

2. Not significantly harm any of the other five objectives; and

3. Comply with the minimum social safeguards relating to Human Rights, Corruption, Taxation and Fair Competition.

In view of the European Taxonomy and the publication by the European Commission of the Climate, Environmental and

Complementary Delegated Acts, the Navigator Group discloses in its 2004 reporting the results of the eligibility analysis and

alignment of its economic activities.

5.2.1.2. Eligibility analysis

In 2024, the activities identified as eligible under the Climate Delegated Act, the Complementary Delegated Act and the

Environmental Delegated Act are:

Activities

Code*

Forest Management CCM 1.3

Electricity generation using solar photovoltaic technology CCM 4.1

Electricity generation from bioenergy CCM 4.8

Cogeneration of heat/cool and power from bioenergy CCM 4.20

High-efficiency co-generation of heat/cool and power from fossil

gaseous fuels

CCM 4.30

Construction, extension and operation of water collection, treatment

and supply systems

CCM 5.1

Construction, extension and operation of waste water collection and

treatment systems

CCM 5.3

Close to market research, development and innovation CCA 9.2

ANNUAL REPORT 2024 • MANAGEMENT REPORT 141

Conservation, including restoration, of habitats, ecosystems and

species

BIO 1.1

* CCM - Climate change mitigation; CCA – Climate change adaptation; BIO – Biodiversity and Ecosystem Restoration

Navigator’s main economic activities, which are production of pulp and paper, continue not to be eligible under the European

Taxonomy.

All the activities described above which are eligible for the climate change mitigation objective (CCM) are also eligible for the

climate change adaptation objective (CCA). The Group considers that the climate change mitigation objective is the most relevant

in these cases.

At present, the taxonomy delegated acts lay greatest stress on industries that are more carbon intensive / green energy

intensive. This means that the Group’s main activities - pulp and paper production - are not contemplated and cannot therefore

be included in the Navigator Group's eligible activities.

5.2.1.3. Alignment analysis

The eligibility and alignment of activities with the technical criteria established in the taxonomy regulation are analysed

annually by the Company. For each economic activity, the Group assessed the criteria of “Substantial contribution” (SC) and

“Do no significant harm” (DNSH). The conclusions stated were based on the best knowledge existing at the date of analysis of

these criteria.

1.3 - Forest

Management

Navigator manages approximately 109 thousand hectares of woodlands in mainland Portugal,

including production and conservation forests. The entire area managed is certified under the FSC®

and PEFC standards, and subject to audits by independent external entities. However, one of the

criteria for alignment of this activity is the existence of a specific audit for verification of SC and

DNSH criteria. In order to respond to this criterion, Navigator is actively seeking a partner able to

conduct an audit that responds to the requirements of the European taxonomy, and until then the

activity is considered as unaligned. In connection with this activity, the Group considered in its

CapEx KPI the acquisition of forest land, as well as other investment supporting forest management.

4.1 - Electricity

generation using

solar photovoltaic

technology

Navigator has seven Solar Power Facilities for in-house consumption, which contribute to reducing

scope 2 greenhouse gas emissions and also its dependence on the electricity market. Navigator

considers that this activity is carried on in alignment with the criteria for CS and DNSF.

4.8 – Electricity

generation from

bioenergy

Navigator has two Biomass Power Plants, which used waste forestry biomass certified under the

SBP standard for power generation. The Group considers that the forestry biomass used meets

the criteria established in Article 29, paras. 6 and 7 of EU Directive 2018/2001. All the waste

forestry biomass used is acquired on the domestic market, in compliance with Portuguese

legislation, thereby complying with the sustainability criteria and in alignment with the taxonomy.

4.20 Cogeneration of

heat/cool and power

from bioenergy

Navigator has three High Efficiency Renewable Cogeneration Plants, which use biomass by-

products resulting from pulp production, in particular black liquor and eucalyptus bark. In

addition, waste forestry biomass is acquired, which is certified under the SBP standard The Group

considers that the waste forestry biomass used meets the criteria established in Article 29, paras.

6 and 7 of Directive EU 2018/2001. All the waste forestry biomass is purchased on the Portuguese

market and in accordance with Portuguese legislation, thereby complying with the sustainability

criteria.

This activity is taxonomy-aligned.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 142

4.30 High-efficiency

co-generation of

heat/cool and power

from fossil gaseous

fuels

The Group operates two combined-cycle natural gas cogeneration plants. Although Navigator

considers that most of the technical requirements for alignment are met, it has not yet been

possible to identify and external verifier to assess the activity under the Taxonomy Regulation and

report its findings to the European Commission.

The activity was accordingly considered non-

aligned.

5.1 Construction,

extension and

operation of water

collection, treatment

and supply systems

The water used in production processes is withdrawn and treated by Navigator's own systems at

the industrial complexes in Aveiro, Figueira da Foz and Setúbal. Power consumption by withdrawal

and treatment systems is less than 0.5kWh per m

of water supplied at the industrial complexes

in Aveiro and Figueira da Foz, but higher in Setúbal. For that reason, this activity is considered

taxonomy-aligned in Aveiro and Figueira da Foz and non-aligned at the Setúbal industrial

complex.

5.3 Construction,

extension and

operation of

wastewater

collection and

treatment systems

The Group has wastewater collection and treatment systems (WWTP) at all its production units in

Portugal. Power consumption by these facilities is below the level set in the criterion for CS for

this activity. As a result of the technical assessment of the criteria for SC and DNSH set in the

Delegated Act, this activity is considered to be taxonomy-aligned.

9.2 Close to market

research,

development and

innovation

Through Instituto Raiz, the Group carries on research activities, including applied research, and

experimental development of solutions, processes, technologies and other products geared to

climate change adaptation. Attention is drawn to the programme for genetic improvement of

eucalyptus in 2024, with a significant contribution to climate change adaptation. The Group

considers the criteria for SC and DNSH to be met, and so the activity is considered to be

taxonomy-aligned.

1.1 Conservation,

including restoration,

of habitats,

ecosystems and

species

This activity contributes to re-establishing or restoring ecosystems, habitats or species habitats in

good conditions. The activity meets the criteria for SC and DNSH, and so is considered to be

taxonomy-aligned. The eligibility and alignment analysis took into account CapEx and OpEx

relating to the Zambujo Recover Project.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 143

Additional detail on application of criteria relating to the Appendices of the Climate Delegated Act

Application of the criteria relating to Appendix A of

the Climate Delegated Act

Navigator has implemented an enterprise risk management

system (ERM) which enables it to identify, assess, monitor and

mitigate risks which may impact its operations, reputation and

regulatory compliance (Chap. 3.3). In order to assess climate,

physical and transition risks, Navigator follows the

recommendations of the Task Force on Climate-related

Financial Disclosures (TCFD). Assessment of the financial

impact resulting from the risks identified considers two-time

horizons (2035 and 2050) and three climate scenarios aligned

with rising levels of temperature increase as established by the

IPCC – RCP 2.6, RCP 4.5 and RCP 8.5 (Chap. 5.2.2.2.1).

Navigator establishes information on the level of exposure of

its assets to the physical risks of drought, heat waves, cold,

fires and pests, for each region of the country. The findings of

the analysis make it possible to classify production areas in

accordance with their level of climate vulnerability to the risks

identified, considering the respective factors of exposure,

sensitivity and ability to adapt. In reforestation and

biodiversity conservation practices, the findings of the analysis

described are taken into account. Navigator plans to go further

in assessing its physical risks, by broadening this study to

include more climate risks and scenarios and a more robust

analysis of the potential impact on its activities, resulting from

both its own operations and from its value chain.

Application of Appendix B criteria (Sustainable use

and protection of water and marine resources)

Navigator carries on its activities in accordance with the

Portuguese legislation in force, in particular Law 58/2005

which transposed Directive 2000/60/EC, and with

management plan for use and protection of water resources.

The Environment Impact Studies to which its facilities are

subject are carried out under Directive 2014/52/UE (updating

Directive 2011/92/UE) and involve an assessment of impact on

water resources.

Application of Appendix D criteria (Protection and

restoration of biodiversity and ecosystems)

Biodiversity conservation is built into Navigator's forestry

management model, with action to protect and restore

biodiversity and ecosystems. The Navigator Group has annual

plans for monitoring biodiversity in its forestry holdings.

Around 12% of its woodland holdings comprise areas of

conservation interest, and 4474 hectares are classified by

Rede Natura 2000 as protected habitats. Navigator sets out to

protect biodiversity, creating a positive impact by taking action

in keeping with its commitments in connection with the

act4nature Portugal initiative.

Application of criteria for DNSH for pollution

prevention and control

The Group’s policy is to adopt the best available techniques

(BATs) for the sector, particularly those that can mitigate the

environmental impacts associated pollution from its production

processes. Through its Management Systems Policy and

Environmental Policy, the Company has made commitments

to ensuring compliance with the requirements applicable to its

activities and products, and to manage and mitigate

environmental risks, in particular by controlling and preventing

pollution and responding to potential environmental

emergencies, safeguarding the precautionary principle.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 144

Minimum safeguards

In order for eligible activities to be classified as aligned, it is essential that they comply with minimum social safeguards. The

taxonomy defines these safeguards as “alignment with the OECD Guidelines for Multinational Enterprises, the UN Guiding

Principles on Business and Human Rights, including the principles and rights set out in the eight fundamental conventions

identified in the Declaration of the International Labour Organisation on Fundamental Principles and Rights at Work and the

International Bill of Human Rights”. In order to help companies comply with these requirements, the European Commission's

Platform on Sustainable Finance published, in 2022, the Final Report on Minimum Safeguards, where it identifies four essential

areas that must be addressed to ensure conformity: Human Rights, Corruption, Tax and Fair Competition.

Human Rights

The Navigator Group recognises the fundamental importance of respect for Human Rights and for employment rights; this is built

into its business activities. To this end, it has adopted and implemented a number of internal instruments, including the

Human

Rights Policy, the Code of Ethics and Good Conduct, the Equality Plan and the Code of Good Conduct for Preventing and

Combating Workplace Harassment.

Mindful of the important role its suppliers play in advancing Human Rights, Navigator has implemented a Code of Conduct for

Suppliers, which complements the Code of Ethics and Good Conduct and sets out to align its partners’ practices with the principles

followed by the Group. Navigator has also implemented a Third-Party Vetting System, based on due diligence procedures for

identifying and mitigating risks related to corruption and related offences, money laundering, international sanctions and Human

Rights violations.

In 2024, Navigator signed up to the UN Global Compact, took part in the Business & Human Rights Accelerator Program and

conducted a first level assessment of the actual and potential impacts of its operations throughout the value chain, identifying

priorities for action. The programme enabled it to develop internal skills, establishing a firm foundation for future analyses and

mitigation and remediation strategies. Also in 2024, the Company reviewed its double materiality analysis, resulting in

identification of material impacts, risks and opportunities in its own operations and along the value chain. Navigator also has

FSC

certification for forest management and the chain of custody, ensuring that environmental and human rights risks

associated with the source of the wood it acquires are monitored.

Corruption, Fair Competition and Tax

In view of the international context in which it operates, the growing involvement of the private sector in combating corruption

and related offences, and the legal obligations incumbent on it, Navigator has adopted a

Policy for Prevention of Corruption and

Related Offences, through which it seeks to establish a series of professional values and standards of integrity which must be

shared by all its Employees.

Complementing this, Navigator has implemented a Plan for Prevention of Corruption and Related Offences Risks (PPR)

, in which it

identifies the risks of corruption and related offences to which it is exposed, establishes criteria for assessing these risks and lays

down preventive and corrective measures designed to mitigate the likelihood of their materialising. Under the PPR, Assessment

Reports are drawn up, quantifying the degree of execution of the preventive and corrective measures defined, as well as the

projection for full implementation.

With regard to competition, Navigator is committed to acting in compliance with competition law, to abiding by market rules

and standards and to promoting fair competition. These commitments are reflected in internal documents, such as the Code of

Ethics and Good Conduct and the Code of Conduct for Suppliers, which expressly lay down that Navigator’s business, together

with that of its Suppliers, must be conducted in accordance with the standards governing fair competition and all the relevant

legislation.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 145

In tax matters, the Company has implemented a Tax Policy, which is designed to ensure that the entities making up the Group

comply with their tax obligations, in all the jurisdictions in which they do business, seeking to maintain full compliance with the

legislation applicable. Aware of its role in Portugal's industrial and business fabric, and because of the vital importance of

transparency in dealings with Stakeholders, Navigator has sought in recent years to calculate its tax footprint, so as to identify

and disclose the volume of tax revenues obtained from its business operations and the taxes it collects and administers on behalf

of the State and other parties.

The Group regularly provides training on Ethics and Integrity for all its Employees, designed to stress the importance of the rules

established in the Code of Ethics and Good Conduct and other internal policies. Specific training was provided in 2024 on Personal

Data Protection and Employment Law. Navigator also provides a Whistleblowing Channel

, on its website, for reporting any

irregularity detected by its Stakeholders, in connection with the topics addressed above. This channel is governed by the

Whistleblowing Regulations

which the Company has implemented.

In the course of its taxonomy-eligible activities in 2024, the Navigator Group did not identify any relevant conviction on matters

of Human Rights, Corruption, Tax or Fair Competition. Without prejudice to the above, attention is drawn to the anti-dumping

proceedings brought by the Department of Commerce in the United States, in connection with investigation of alleged dumping

practices in paper imports in several formats from five countries (Australia, Brazil, China, Indonesia and Portugal). As a result of

these proceedings, anti-dumping duties are applied on Portugal's exports to the United States of certain types of paper marketed

by Navigator. These exports are related to a taxonomy non-eligible activity.

5.2.1.4. Disclosure of KPIs

The Taxonomy Delegated Act (Article 8) establishes a number of key performance indicators (KPIs) associated with

environmentally sustainable activities that non-financial undertakings must disclose: the proportion of their turnover (Turnover

KPI), the proportion of their capital expenditure (CapEx KPI) and the proportion of their operating expenditure (OpEx KPI). Below

we present the summary of findings:

KPI eligibility and

alignment

Total (EUR)

Proportion eligible

and aligned (%)

Proportion eligible

and non-aligned

(%)

Proportion non-

eligible (%)

Turnover 2 088 276 553 € 5.6% 0.2% 94.1%

CapEx 461 294 721 € 18.3% 2.8% 78.9%

OpEx 75 352 805 € 14.2% 4.8% 81.0%

Accounting policies

As established in the taxonomy, the figures reported were calculated in accordance with Navigator's Consolidated Financial

Statements for the financial year ended 31 December 2024, which were prepared in conformity with the International Financial

Reporting Standards (IFRS), in force on 1 January 2024 and as adopted by the European Union.

The European Taxonomy requires companies to disclose how they avoided duplication in considering economic activities eligible

(numerator), in other words, in determining turnover, capital expenditure and operational expenditure. The Navigator Group

determined eligible expenses on the basis of its financial and cost accounting and ensured that cost items were considered only

once in calculating indicators.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 146

In FY2023, the Navigator Group considered activity 1.3 as eligible and aligned. However, as explained in the section “Alignment

analysis”, Navigator has not been able to respond in full to the technical criterion for “Audit”, as it is still not audited by an

independent third party in accordance with the taxonomy criteria. In this year’s reporting, Navigator has accordingly corrected

activity 1.3 Forest Management to non-aligned, rectifying the figures in column n-1 to non-aligned.

Turnover

Turnover was determined based on International Financial Reporting Standard IFRS 15, i.e. considering sales and services

provided in the course of the Navigator Group's normal business. Total turnover (denominator in calculating the ratio eligible

activities) therefore corresponds to the revenue reported in the Consolidated Financial Statements (2.1 of the Notes to the

Financial Statements).

The turnover from eligible and aligned activities corresponds to the sale of electricity from renewable biomass cogeneration

facilities and biomass power plants. The turnover from eligible and non-aligned activities corresponds to the sale of electricity

from natural gas cogeneration facilities. The other eligible activities are used mostly in internal Group operations and, as such,

are not considered for the purposes of this indicator.

CapEx

The figure stated as total CapEx in the denominator calculation of the eligible activities ratio corresponds to the sum of acquisitions

in 2024 of tangible assets, intangible assets (excluding CO

licenses) and right-of-use assets, as disclosed in nos. 3.2, 3.3 and

3.6 of the Notes to Navigator's Consolidated Financial Statements. In addition, this also takes into consideration acquisitions of

intangible assets, tangible fixed assets and right-of-use assets associated with acquisition of Accrol, disclosed in no. 1.2 of the

Notes to Navigator's Consolidated Financial Statements.

For the purposes of determining this ratio, additions of intangible assets related to acquisitions of CO

licenses were excluded,

insofar as these does not correspond effectively to acquisition of licenses, but rather to licenses awarded to the Group, and their

classification as intangible assets results from the accounting policy adopted by the Group. No additions were recorded in 2024

to the Group’s investment properties.

The CapEx values classified as eligible, including those considered both taxonomy-aligned and taxonomy non-aligned, correspond

to investment in assets or processes associated with the Group’s activities, in particular:

→ Investment to support forest management activities, in particular acquisition of forest land;

→ Investment in biomass power plants;

→ Investment in biomass cogeneration plants, which includes investment in new recovery boiler in Setúbal;

→ Investment in effluent treatment at industrial complexes, which includes investment in WWTP 2 in Setúbal;

→ Investment in Research & Development projects in connection with the genetic improvement programme; and

→ Investment in conservation, including restoration, of habitats, ecosystems and species, in connection with Zambujo

reCover Project.

OpEx

The total OpEx stated in the denominator for calculation of the eligible activities ratio corresponds to the following expenditure

determined on the basis of the Consolidated Financial Statements at 31 December 2024:

→ Uncapitalised research and development costs;

→ Expense of industrial cleaning;

→ Maintenance and repair expense included in no. 2.3 of the Notes to the Consolidated Financial Statements.

→ Expense of specialist work directly related to maintenance and repair. These costs have been analysed item by item.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 147

→ Personnel expenditure in connection with maintenance and repair.

→ Uncapitalised short term lease expense; and

→ Other expense directly relating to maintenance of tangible fixed assets.

The OpEx values associated with the Group’s eligible activities (taxonomy-aligned or non-aligned) correspond essentially to

expenditure on research and development relating to forestry, expenditure related to habitats and ecosystem conservation and

restoration, uncapitalised expenditure needed to operate renewable biomass co-generation plants, biomass power plants, natural

gas co-generation plants, withdrawal and treatment of water and collection and treatment of effluents.

5.2.1.4.1. Proportion of turnover from products or services associated with taxonomy-aligned economic

activities

Financial

year 2024

2024 Substantial contribution criteria

Criteria for DNSH (“do no

significant harm”) (h)

Economic

activities

(1)

Code (a) (2)

Turnover (3)

Proportion of turnover,

year N (4)

Climate change mitigation

(5)

Climate change adaptation

(6)

Water (7)

Pollution (8)

Circular economy (9)

Biodiversity (10)

Climate change mitigation

(11)

Climate change adaptation

(12)

Water (13)

Pollution (14)

Circular economy (15)

Biodiversity (16)

Minimum safeguards (17)

Proportion of turnover

taxonomy

aligned (A.1) or

taxonomy

-eligible (A.2),

2023 (18)

Category

—

enabling activity (19)

Category

—

transitional activity (20)

Text Euro %

(b)

(c)

(b)

(c)

Y; N;

N/EL

(b)

and

(c)

(b)

(c)

(b)

(c)

N/E

(b)

and

(c)

Y/N Y/N Y/N

% C T

A. TAXONOMY-ELIGIBLE ACTIVITIES

A.1. Environmentally-sustainable activities (taxonomy-aligned)

Electricity

generation

from

bioenergy

CCM

4.8

24 726 984 € 1% Y

N/EL

N/E

Y Y Y Y Y Y Y 1%

Cogeneratio

n of heat

and power

from

bioenergy

CCM

4.2

92 812 610 € 4% Y

N/EL

N/E

Y Y Y Y Y Y Y 5%

Turnover of

environmentally

sustainable

activities

(taxonomy-aligned)

(A.1)

117 539 594 € 6% 6% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 6%

Of which, enabling

activities

0 € 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 0% C

Of which, transitional

activities

0 € 0% 0% Y Y Y Y Y Y Y 0% T

A.2. Taxonomy-eligible but environmentally unsustainable activities (taxonomy non-aligned activities) (g)

High-

efficiency

co-

generation

of heat and

power from

fossil

gaseous

fuels

CCM

4.3

5 118 236 € 0% EL

N/EL

N/E

ANNUAL REPORT 2024 • MANAGEMENT REPORT 148

Turnover from

taxonomy-eligible

but

environmentally

unsustainable

activities

(taxonomy non-

aligned activities)

(A.2)

5 118 236 € 0% 0% 0% 0% 0% 0% 0% 2%

A. Turnover from

taxonomy-eligible

activities (A.1+A.2)

122 657 830 € 6% 6% 0% 0% 0% 0% 0% 8%

B. TAXONOMY NON-ELIGIBLE ACTIVITIES

Turnover from

taxonomy non-eligible

activities (B)

1 965 618 723 €

94%

Total (A + B) 2 088 276 533 €

100

5.2.1.4.2. Proportion of CapEx on products or services associated with taxonomy-aligned economic

activities

Financial

year 2024

2024 Substantial contribution criteria

Criteria for DNSH (“do no

significant harm”) (h)

Economic

activities (1)

Code (a) (2)

CapEx (3)

Proportion of CapEx, year N

(4)

Climate change

mitigation (5)

Climate change adaptation (6)

Water (7)

Pollution (8)

Circular economy (9)

Biodiversity (10)

Climate change mitigation

(11)

Climate change adaptation

(12)

Water (13)

Pollution (14)

Circular economy (15)

Biodiversity (16)

Minimum safeguards (17)

Proportion of CapEx

taxonomy

aligned (A.1) or

taxonomy-eligible (A 2) year

Category

—

enabling activity (19)

Category

—

transitional activity (20)

Text Euro %

N/E

(b)

and

(c)

N/EL

(b)

and

(c)

N/EL

(b)

and

(c)

N/EL

(b)

and

(c)

N/EL

(b)

and

(c)

N/EL

(b)

and

(c)

Y/N Y/N Y/N Y/N Y/N Y/N Y/N % C T

A. TAXONOMY-ELIGIBLE ACTIVITIEY

A.1. Environmentally sustainable activities (taxonomy-aligned)

Electricity

generation

using solar

photovoltaic

technology

CCM

4.1

2 505 217 € 1% Y N/EL N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 0%

Electricity

generation

from

bioenergy

CCM

4.8

3 202 254 € 1% Y N/EL N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 2%

Cogeneratio

n of heat and

power from

bioenergy

CCM

4.2

75 769 408 €

Y N/EL N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 37%

Construction

, extension

and

operation of

water

collection,

treatment

and supply

systems

CCM

5.1

177 831 € 0% Y N/EL N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 149

Construction

, extension

and

operation of

waste water

collection

and

treatment

systems

CCM

5.3

3 010 995 €

1% Y N/EL N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 3%

Close to

market

research,

development

and

innovation

CCA

9.2

23 020 € 0%

N/E

Y N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 0% C

CapEx for

environmentally

sustainable

activities

(taxonomy-aligned)

(A.1)

84 688 724 €

0% 0% 0% 0% 0% Y Y Y Y Y Y Y 43%

Of which, enabling

activities

23 020 € 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 0% C

Of which, transitional

activities

0 € 0% 0% Y Y Y Y Y Y Y 0% T

A.2. Taxonomy-eligible but environmentally unsustainable activities (taxonomy non-aligned activities) (g)

Forest Management

Dep.

CCM 1.3 7 995 895 € 2% EL N/EL N/EL N/EL N/EL N/EL 7%

High-efficiency co-

generation of heat and

power from fossil

gaseous fuels

CCM 4.30 3 545 059 € 1% EL N/EL N/EL N/EL N/EL N/EL 1%

Construction, extension

and operation of water

collection, treatment

and supply systems

CCM 5.1 1 324 717 € 0% EL N/EL N/EL N/EL N/EL N/EL 0%

CapEx for taxonomy-eligible but

environmentally unsustainable

activities (taxonomy non-aligned

activities) (A.2)

12 865 671 € 3% 5% 0% 0% 0% 0% 0% 8%

A. Capex for taxonomy-eligible

activities (A.1+A.2)

97 554 395 € 21% 41% 0% 0% 0% 0% 0% 51%

B. TAXONOMY NON-ELIGIBLE ACTIVITIES

CapEx for taxonomy non-eligible

activities (B)

363 740 326 € 79%

Total (A + B)

461 294 721 €

100%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 150

5.2.1.4.3. Proportion of OpEx on products or services associated with taxonomy-aligned economic

activities

Financial

year 2024

2024

Substantial contribution criteria

Criteria for DNSH (“do no significant

harm”) (h)

Economic

activities (1)

Code (a) (2)

OpEx (3)

Proportion of

OpEx, year N (4)

Climate change mitigation (5)

Climate change adaptation (6)

Water (7)

Pollution (8)

Circular economy (9)

Biodiversity (10)

Climate change mitigation

(11)

Climate change adaptation

(12)

Water (13)

Pollution (14)

Circular economy (15)

Biodiversity (16)

Minimum safeguards (17)

Proportion of OpEx taxonomy

aligned (A.1) or taxonomy

eligible (A.2), 2023 (18)

Category

—

enabling activity (19)

Category

—

transitional activity (20)

Text

Euro

Y; N;

N/EL

(b)

and

(c)

Y; N;

N/EL

(b)

and

(c)

Y; N;

N/EL

(b)

and

(c)

Y; N;

N/EL

(b)

and

(c)

Y; N;

N/EL

(b)

and

(c)

Y; N;

N/EL

(b)

and

(c)

Y/N

A. TAXONOMY-ELIGIBLE ACTIVITIEY

A.1. Environmentally-sustainable activities (taxonomy-aligned)

Electricity

generation

from

bioenergy

CCM

4.8

1 969 444 €

N/EL

Cogeneration

of heat and

power from

bioenergy

CCM

4.20

2 515 784 €

N/EL

Construction,

extension and

operation of

water

collection,

treatment and

supply

systems

CCM

5.1

820 587 €

N/EL

Construction,

extension and

operation of

waste water

collection and

treatment

systems

CCM

5.3

2 036 398 €

N/EL

Close to

market

research,

development

and innovation

CCA

9.2

3 384 703 €

N/EL

Conservation,

including

restoration, of

habitats,

ecosystems

and species

BIO

1.1

7 597 €

N/EL

CapEx for

environmentally

sustainable activities

(taxonomy-aligned)

(A.1)

10 734 512 €

14%

10%

Of which, enabling

activities

3 384 703 €

Of which, transitional

activities

0 €

A.2. Taxonomy-eligible but environmentally unsustainable activities (taxonomy non-aligned activities) (g)

ANNUAL REPORT 2024 • MANAGEMENT REPORT 151

Forest

Management

Dep.

CCM

1.3

3 017 074 €

N/EL

High-efficiency

co-generation

of heat and

power from

fossil gaseous

fuels

CCM

4.30

289 239 €

N/EL

Construction,

extension and

operation of

water

collection,

treatment and

supply

systems

CCM

5.1

297 932 €

N/EL

OpEx for taxonomy-

eligible but

environmentally

unsustainable

activities (taxonomy

non-

aligned activities)

(A.2)

3 604 245 €

A. OpEx in taxonomy-

eligible activities

(A.1+A.2)

14 338 758 €

19%

15%

11%

B. TAXONOMY NON-ELIGIBLE ACTIVITIES

OpEx in taxonomy non-

eligible activities (B)

61 014 048 €

81%

Total (A + B)

73 352 805 €

100%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 152

5.2.1.4.4. Templates personalised in accordance with Regulation 2022/1214

Under the Taxonomy Regulation, Article 8 of the Delegated Act, standardised templates must be disclosed with regard to activities

connected to nuclear energy and fossil gas

Template 1: Nuclear and fossil gas related activities

Row Nuclear energy related activities

The undertaking carries out, funds or has exposures to research, development, demonstration

and deployment of innovative electricity generation facilities that produce energy from nuclear

processes with minimal waste from the fuel cycle.

The undertaking carries out, funds or has exposures to construction and safe operation of new

nuclear installations to produce electricity or process heat, including for the purposes of district

heating or industrial processes such as hydrogen production, as well as their safety upgrades,

using best available technologies.

The undertaking carries out, funds or has exposures to safe operation of existing nuclear

installations that produce electricity or process heat, including for the purposes of district heating

or industrial processes such as hydrogen production from nuclear energy, as well as their safety

upgrades.

Row Fossil gas related activities

The undertaking carries out, funds or has exposures to construction or operation of electricity

generation facilities that produce electricity using fossil gaseous fuels.

The undertaking carries out, funds or has exposures to construction, refurbishment, and

operation of combined heat/cool and power generation facilities using fossil gaseous fuels.

YES

The undertaking carries out, funds or has exposures to construction, refurbishment and

operation of heat generation facilities that produce heat/cool using fossil gaseous fuels.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 153

Template 2: Taxonomy-aligned economic activities (denominator) - Turnover

Row Economic Activities

Amount and proportion of Turnover

CCM + CCA

Climate change mitigation

(CMM)

Climate change

adaptation (CCA)

Amount % Amount % Amount %

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.26

of Annexes I and II to Delegated Regulation

2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.27

of Annexes I and II to Delegated Regulation

2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.28

of Annexes I and II to Delegated Regulation

2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.29

of Annexes I and II to Delegated Regulation

2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.30

of Annexes I and II to Delegated Regulation

2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.31

of Annexes I and II to Delegated Regulation

2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of other

taxonomy-aligned economic activities not

referred to in rows 1 to 6 above in the

Turnover denominator

117 539 594 € 6% 117 539 594 € 6% 0 € 0%

8. Total Turnover 117 539 594 € 6% 117 539 594 € 6% 0 € 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 154

Template 2: Taxonomy-aligned economic activities (denominator) - CapEx

Row Economic Activities

Amount and proportion of CapEx

CCM + CCA

Climate change mitigation

(CMM)

Climate change

adaptation (CCA)

Amount % Amount % Amount %

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.26 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.27 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.28 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.29 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.30 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.31 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of other taxonomy-

aligned economic activities not referred to

in rows 1 to 6 above in the CapEx

denominator

84 688 724 € 18% 84 665 704 € 18% 23 020 € 0%

8. Total CapEx 84 688 724 € 18% 84 665 704 € 18% 23 020 € 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 155

Template 2: Taxonomy-aligned economic activities (denominator) - OpEx

Row Economic Activities

Amount and proportion of OpEx

CCM + CCA

Climate change

mitigation (CMM)

Climate change adaptation

(CCA)

Amount % Amount % Amount %

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.26 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.27 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.28 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.29 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.30 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.31 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of other taxonomy-

aligned economic activities not referred to in

rows 1 to 6 above in the OpEx denominator

10 726 916 € 14% 7 342 213 € 10% 3 384 703 € 4%

8. Total OpEx 10 726 916 € 14% 7 342 213 € 10% 3 384 703 € 4%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 156

Template 3: Taxonomy-aligned economic activities (numerator) - Turnover

Row Economic Activities

Amount and proportion of Turnover

CCM + CCA

Climate change mitigation

(CMM)

Climate change

adaptation (CCA)

Amount % Amount % Amount %

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.26 of

Annexes I and II to Delegated Regulation

2021/2139 in the Turnover numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.27 of

Annexes I and II to Delegated Regulation

2021/2139 in the Turnover numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.28 of

Annexes I and II to Delegated Regulation

2021/2139 in the Turnover numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.29 of

Annexes I and II to Delegated Regulation

2021/2139 in the Turnover numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.30 of

Annexes I and II to Delegated Regulation

2021/2139 in the Turnover numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.31 of

Annexes I and II to Delegated Regulation

2021/2139 in the Turnover numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of other taxonomy-

aligned economic activities not referred to

in rows 1 to 6 above in the Turnover

numerator

117 539 594 € 100% 117 539 594 € 100% 0 € 0%

Amount and proportion of taxonomy-

aligned economic activities in the Turnover

numerator

117 539 594 € 100% 117 539 594 € 100% 0 € 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 157

Template 3: Taxonomy-aligned economic activities (numerator) - CapEx

Row Economic Activities

Amount and proportion of CapEx

CCM + CCA

Climate change mitigation

(CMM)

Climate change

adaptation (CCA)

Amount % Amount % Amount %

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.26 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.27 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.28 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.29 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.30 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.31 of

Annexes I and II to Delegated Regulation

2021/2139 in the CapEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of other taxonomy-

aligned economic activities not referred to in

rows 1 to 6 above in the CapEx numerator

84 688 724 € 100% 84 665 704 € 100% 23 020 € 0%

Amount and proportion of taxonomy-aligned

economic activities in the CapEx numerator

84 688 724 € 100% 84 665 704 € 100% 23 020 € 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 158

Template 3: Taxonomy-aligned economic activities (numerator) - OpEx

Row Economic Activities

Amount and proportion of OpEx

CCM + CCA

Climate change

mitigation (CMM)

Climate change

adaptation (CCA)

Amount % Amount % Amount %

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.26 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.27 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.28 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.29 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.30 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-aligned

economic activity referred to in Section 4.31 of

Annexes I and II to Delegated Regulation

2021/2139 in the OpEx numerator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of other taxonomy-

aligned economic activities not referred to in

rows 1 to 6 above in the OpEx numerator

10 726 916 € 100% 7 342 213 € 68% 3 384 703 € 32%

Amount and proportion of taxonomy-aligned

economic activities in the OpEx numerator

10 726 916 € 100% 7 342 213 € 68% 3 384 703 € 32%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 159

Template 4: Taxonomy-eligible but not taxonomy-aligned economic activities - Turnover

Row Economic activities

Amount and proportion of Turnover

(CCM + CCA)

Climate change mitigation

(CMM)

Climate change

adaptation (CCA)

Amount % Amount % Amount %

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred to

in Section 4.26 of Annexes I and II to Delegated

Regulation 2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred to

in Section 4.27 of Annexes I and II to Delegated

Regulation 2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred to

in Section 4.28 of Annexes I and II to Delegated

Regulation 2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred to

in Section 4.29 of Annexes I and II to Delegated

Regulation 2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred to

in Section 4.30 of Annexes I and II to Delegated

Regulation 2021/2139 in the Turnover denominator

5 118 236 € 100% 5 118 236 € 100% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred to

in Section 4.31 of Annexes I and II to Delegated

Regulation 2021/2139 in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of other taxonomy-

eligible but not taxonomy-aligned economic

activities not referred to in rows 1 to 6 above

in the Turnover denominator

0 € 0% 0 € 0% 0 € 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 160

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic activities

in the Turnover denominator

5 118 236 € 100% 5 118 236 € 100% 0 € 0%

Template 4 Taxonomy-eligible but not taxonomy-aligned economic activities - CapEx

Row Economic activities

Amount and proportion of CapEx

(CCM + CCA)

Climate change mitigation

(CMM)

Climate change

adaptation (CCA)

Amount % Amount % Amount %

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.26 of Annexes I and II to

Delegated Regulation 2021/2139 in the CapEx

denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.27 of Annexes I and II to

Delegated Regulation 2021/2139 in the CapEx

denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.28 of Annexes I and II to

Delegated Regulation 2021/2139 in the CapEx

denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.29 of Annexes I and II to

Delegated Regulation 2021/2139 in the CapEx

denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.30 of Annexes I and II to

Delegated Regulation 2021/2139 in the CapEx

denominator

3 545 059 € 28% 3 545 059 € 28% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.31 of Annexes I and II to

Delegated Regulation 2021/2139 in the CapEx

denominator

0 € 0% 0 € 0% 0 € 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 161

Amount and proportion of other taxonomy-

eligible but not taxonomy-aligned economic

activities not referred to in rows 1 to 6

above in the CapEx denominator

9 320 612 € 72% 9 320 612 € 72% 0 € 0%

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic

activities in the CapEx denominator

12 865 671 € 100% 12 865 671 € 100% 0 € 0%

Template 4: Taxonomy-eligible but not taxonomy-aligned economic activities - OpEx

Row Economic activities

Amount and proportion of OpEx

(CCM + CCA)

Climate change mitigation

(CMM)

Climate change

adaptation (CCA)

Amount % Amount % Amount %

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.26 of Annexes I and II to

Delegated Regulation 2021/2139 in the OpEx

denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.27 of Annexes I and II to

Delegated Regulation 2021/2139 in the OpEx

denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.28 of Annexes I and II to

Delegated Regulation 2021/2139 in the OpEx

denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.29 of Annexes I and II to

Delegated Regulation 2021/2139 in the OpEx

denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.30 of Annexes I and II to

Delegated Regulation 2021/2139 in the OpEx

denominator

289 239 € 8% 289 239 € 8% 0 € 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 162

Amount and proportion of taxonomy-eligible but

not taxonomy-aligned economic activity referred

to in Section 4.31 of Annexes I and II to

Delegated Regulation 2021/2139 in the OpEx

denominator

0 € 0% 0 € 0% 0 € 0%

Amount and proportion of other taxonomy-

eligible but not taxonomy-aligned economic

activities not referred to in rows 1 to 6

above in the OpEx denominator

3 315 006 € 92% 3 315 006 € 92% 0 € 0%

Amount and proportion of taxonomy-eligible

but not taxonomy-aligned economic

activities in the OpEx denominator

3 604 245 € 100% 3 604 245 € 100% 0 € 0%

Template 5: Taxonomy non-eligible economic activities - Turnover

Row Economic activities Amount Percentage

Amount and proportion of economic activity referred to in row 1 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes

I and II to Delegated Regulation 2021/2139 in the Turnover denominator

0 € 0%

Amount and proportion of economic activity referred to in row 2 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.27 of Annexes

I and II to Delegated Regulation 2021/2139 in the Turnover denominator

0 € 0%

Amount and proportion of economic activity referred to in row 3 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.28 of Annexes

I and II to Delegated Regulation 2021/2139 in the Turnover denominator

0 € 0%

Amount and proportion of economic activity referred to in row 4 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.29 of Annexes

I and II to Delegated Regulation 2021/2139 in the Turnover denominator

0 € 0%

Amount and proportion of economic activity referred to in row 5 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.30 of Annexes

I and II to Delegated Regulation 2021/2139 in the Turnover denominator

0 € 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 163

Amount and proportion of economic activity referred to in row 6 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.31 of Annexes

I and II to Delegated Regulation 2021/2139 in the Turnover denominator

0 € 0%

Amount and proportion of other taxonomy-non-eligible economic

activities not referred to in rows 1 to 6 above in the Turnover

denominator

1 965 618 723 € 94%

Total amount and proportion of other taxonomy-non-eligible

economic activities in the Turnover denominator

1 965 618 723 € 94%

Template 5: Taxonomy non-eligible economic activities - CapEx

Row Economic activities Amount Percentage

Amount and proportion of economic activity referred to in row 1 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes

I and II to Delegated Regulation 2021/2139 in the CapEx denominator

0 € 0%

Amount and proportion of economic activity referred to in row 2 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.27 of Annexes

I and II to Delegated Regulation 2021/2139 in the CapEx denominator

0 € 0%

Amount and proportion of economic activity referred to in row 3 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.28 of Annexes

I and II to Delegated Regulation 2021/2139 in the CapEx denominator

0 € 0%

Amount and proportion of economic activity referred to in row 4 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.29 of Annexes

I and II to Delegated Regulation 2021/2139 in the CapEx denominator

0 € 0%

Amount and proportion of economic activity referred to in row 5 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.30 of Annexes

I and II to Delegated Regulation 2021/2139 in the CapEx denominator

0 € 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 164

Amount and proportion of economic activity referred to in row 6 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.31 of Annexes

I and II to Delegated Regulation 2021/2139 in the CapEx denominator

0 € 0%

Amount and proportion of other taxonomy-non-eligible economic

activities not referred to in rows 1 to 6 above in the CapEx

denominator

363 740 326 € 79%

Total amount and proportion of other taxonomy-non-eligible

economic activities in the CapEx denominator

363 740 326 € 79%

Template 5: Taxonomy non-eligible economic activities - OpEx

Row Economic activities Amount Percentage

Amount and proportion of economic activity referred to in row 1 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.26 of Annexes

I and II to Delegated Regulation 2021/2139 in the OpEx denominator

0 € 0%

Amount and proportion of economic activity referred to in row 2 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.27 of Annexes

I and II to Delegated Regulation 2021/2139 in the OpEx denominator

0 € 0%

Amount and proportion of economic activity referred to in row 3 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.28 of Annexes

I and II to Delegated Regulation 2021/2139 in the OpEx denominator

0 € 0%

Amount and proportion of economic activity referred to in row 4 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.29 of Annexes

I and II to Delegated Regulation 2021/2139 in the OpEx denominator

0 € 0%

Amount and proportion of economic activity referred to in row 5 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.30 of Annexes

I and II to Delegated Regulation 2021/2139 in the OpEx denominator

0 € 0%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 165

Amount and proportion of economic activity referred to in row 6 of Template

1 that is taxonomy-non-eligible in accordance with Section 4.31 of Annexes

I and II to Delegated Regulation 2021/2139 in the OpEx denominator

0 € 0%

Amount and proportion of other taxonomy-non-eligible economic

activities not referred to in rows 1 to 6 above in the OpEx

denominator

61 014 048 € 81%

Total amount and proportion of other taxonomy-non-eligible

economic activities in the OpEx denominator

61 014 048 € 81%

5.2.1.5. Next steps in applying the taxonomy

In line with the Group’s strategy and its sustainability goals, Navigator will press ahead in 2025 with developing procedures and

action to respond appropriately to the Taxonomy alignment criteria. These activities include:

→ More robust implementation of climate risk analysis (Appendix A to the Climate Delegated Act – Annex I) aligned

with the work of responding to the recommendations of the Task Force on Climate-related Financial Disclosures

(TCFD);

→ Continued development of a Human Rights due diligence procedure, designed to strengthen practices and

commitments relating to operations;

→ Analysis of potential extensions of the Taxonomy Regulation to other activities and implementation of guidelines

that may have a significant impact on classification of the Group's eligibility and alignment in future;

→ Monitoring of possible updates by European Commission to the Taxonomy Regulation, as a result of the Omnibus

legislative package.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 166

5.2.2. ESRS E1: Climate change

5.2.2.1. Strategy

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

(SBM-3)

Description

Impacts, Risk

or Opportunity

Time horizon Location in value chain

Related sub-topic

or sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

Emission of greenhouse

gases (Scope 1).

Negative impact -- Own operations Mitigation of climate change

Emission of greenhouse

gases (Scope 2).

Negative impact -- Amount Mitigation of climate change

Emission of greenhouse

gases (Scope 3).

Negative impact -- Upstream/downstream Mitigation of climate change

Energy consumed from

non-renewable sources in

own operations contributes

to climate change.

Negative impact -- Upstream/Own operations Energy

Undertake initiatives with

our Stakeholders for

climate change adaptation.

Positive impact

Upstream/downstream Climate change adaptation

Capture and sequestration

of CO

Positive impact -- Own operations Mitigation of climate change

Production of renewable

electricity contributes to the

country’s renewable energy

mix.

Positive impact -- Own operations Energy

Development of

bioproducts, as an

alternative to other

products that cause more

pollution, contributes to the

non-worsening of GHG

emissions during the life

cycle of use of these

products (post-sales).

Positive impact -- Downstream Mitigation of climate change

Physical impacts of climate

change, through extreme

weather events (e.g.

hurricanes, heavy rainfall).

Acute physical risk

Medium term - From

reporting year and

up to 5 years

Own operations Climate change adaptation

Change in rainfall patterns

and other climate factors

leading to loss of yields in

production forests.

Chronic physical risk

Long term - Over 5

years

Own operations, Upstream Climate change adaptation

Climate change can lead to

potential disruption of the

supply chain and the

consequent impact on the

availability and quality of

raw materials may

compromise the Group’s

business.

Transition risk

Long term - Over 5

years

Amount Climate change adaptation

Increase in severity and

frequency of forest fires.

Chronic physical risk

Short term -

Reporting year

Amount Climate change adaptation

ANNUAL REPORT 2024 • MANAGEMENT REPORT 167

Description

Impacts, Risk

or Opportunity

Time horizon Location in value chain

Related sub-topic

or sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

- Rise in average sea level

may lead to reduction of

production capacity and

revenue obtained and/or

damage to operations.

Chronic physical risk

Long term - Over 5

years

Own operations Climate change adaptation

Higher carbon price and

reduction in availability of

licenses under EU-ETS.

Risk

Medium term - From

reporting year and

up to 5 years

Own operations Mitigation of climate change

Increased energy costs

associated with non-

renewable sources.

Risk

Medium term - From

reporting year and

up to 5 years

Own operations Energy

Adaptation of portfolio to

impacts of climate change

which respond to consumer

preferences, reinforcing

competitive advantage in

the market and positively

impacting revenues (e.g.

NVG - Investment in R&D

to develop new forest-

based products able to

substitute forest-based

products, helping to

mitigate climate change).

Opportunity

Medium term - From

reporting year and

up to 5 years

Own operations Climate change adaptation

The transition to more

sustainable technologies

may lead in the long term

to significant improvements

in operational efficiency and

cut overall operating costs,

improving profitability

and/or capturing an

additional market share.

Opportunity

Long term - Over 5

years

Own operations Mitigation of climate change

Substitution of fossil fuels

by renewable fuels (e.g.

biomass, solar and

hydrogen).

Opportunity

Medium term - From

reporting year and

up to 5 years

Own operations Mitigation of climate change

Investment in energy

efficiency and renewable

energy sources can lead to

improved profitability.

Opportunity

Medium term - From

reporting year and

up to 5 years

Own operations Energy

Note: the material impacts identified are actual, and so there is no associated time horizon. [E1.SBM-3.18]

For the financial year of 2023, the resilience of the Group’s strategy was analysed by quantifying the financial impact of one

transition risk, three physical risks and one opportunity, considered as material for the business and considering two-time

horizons - 2035 and 2050.

We developed a structured approach to assess and improve the resilience of our strategy and business model in relation to climate

change, in line with TCFD recommendations. We present below: the scope of the resilience analysis; the methodology and the

period for which the analysis was conducted; and the main findings, highlighting the conclusions from the analysis of scenarios

[E1.SBM-3.19a].

Scope of the resilience analysis

The resilience analysis focused on the physical and transition risks, as well as opportunities, assessing financial and operational

impacts in two-time horizons (2035 and 2050). The study encompasses physical risks, in particular forest fires, water scarcity,

extreme weather events and impacts on forestry yields; transition risks, such as climate regulations, increased carbon cost (EU-

ANNUAL REPORT 2024 • MANAGEMENT REPORT 168

ETS) and changing consumer preferences; and the opportunities included investment in new forest-based products and adoption

of technologies to mitigate climate impacts.

How the resilience analysis was conducted

The resilience analysis was conducted by defining climate scenarios and was based on the IPCC RCP 2.6, RCP 4.5 and RCP 8.5

models. In addition, a financial assessment was made of the impact of four climate risks and one opportunity, considering the

three climate scenarios and two-time horizons.

In keeping with the TCFD recommendations for scenario analysis, the company used exploratory analyses that describe a

diverse range of plausible future states, which are used to assess potential climate-related risks and uncertainties, and also to test

the resilience of our strategy for the different future conditions adjacent to these same scenarios.

To this end, three climate scenarios were defined, considering two distinct time horizons: medium term (2035) and long term

(2050). These climate scenarios were constructed on the basis of the IPCC scenarios, or Representative Concentration Pathways

(RCP) – RCP 2.6, RCP 4.5 and RCP 8.5. These were complemented by narratives of plausible futures, from the “Sustainable

Development Scenario” developed by the International Energy Agency and the “Climate Scenario Tool” for the food, forestry and

farming products sector, developed by the WBCSD, respectively called the green, yellow and red scenario. In addition, a financial

assessment was made of the impact of four climate risks and one opportunity, considering the three climate scenarios and two-

time horizons.

Physical risks tend to be more severe in the 4ºC climate scenario (red scenario), given that in this scenario the likelihood of the

occurrence and severity of extreme climate events is greater. However, in the 1.5°C and 2°C scenarios it is still possible that

some physical risks will be moderately severe. The transition risks are general more severe in the scenarios which comply with the

aims of the Paris Agreement, i.e. the 1.5ºC scenario (green scenario) and the < 2ºC scenario (yellow scenario).

The following table sets out the scenarios considered in the resilience analysis.

Scenarios Description of narrative Time horizon Base Model

Green

Rapid and orderly climate action

• Economy grows sustainably, with heavy investment in

renewable energy and low carbon technologies.

• Political and regulatory transition makes for a balanced

transition, with positive impacts for N.

• Industry is gradually decarbonised, enabling business models

to adapt, based on electrification of processes and use of

renewable fuels based on green hydrogen.

• Adoption of circular economy models, reducing dependence

on fossil fuels.

• Consumer preference for sustainable and certified products

• Growing use of biomass certified as renewable fuel.

• Heavy investment in R&D in new forest-based products,

replacing forest-based products.

2035-2050

• IPCC SSP 1- 2.6 (RCP 2.6)

• WBCSD – 1.5ºC scenario

based on innovation

Yellow

Sudden and uncoordinated climate action

• Potential recession due to sudden measures to cut emissions.

• Increased industrial costs due to increased carbon taxes and

rigid regulation.

• Negative impact on economic growth, with increased market

volatility.

• Renewable energies adopted abruptly. increasing transition

cost.

• Dependence on fossil fuels decreases, but without stable

replacement solutions in the short term.

• Increased investment in carbon capture and storage (CCS)

tec.

2035-2050

• IPCC SSP 2- 4.5 (RCP 4.5)

• WBCSD – <2°C scenario

based on planned policies

ANNUAL REPORT 2024 • MANAGEMENT REPORT 169

• High adaptation costs due to regulatory pressure and need

for high-speed innovation.

Red

Slow and uncoordinated climate action (no mitigation)

• Continuation of traditional operational model, without

effective decarbonisation policies.

• Uneven economic growth, with rising operating costs due to

extreme weather events.

• Breakdowns in supply chains and increased uncertainty in

financial markets.

• Energy pattern remains dominated by fossil fuels, with only

low-level implementation of renewables.

• Significant increase in energy prices, undermining industrial

competitiveness.

• Lack of incentives for sustainable innovation, reducing

adoption of clean technologies.

• Poor adoption of decarbonisation technologies due to absence

of government incentives.

• Retention of traditional processes, but with rising energy and

environmental costs.

2035-2050

• IPCC SSP 5-8.5 (RCP 8.5)

• WBCSD – >3ºC scenario

based on historical

tendencies

When the resilience analysis was conducted

Our resilience analysis has been continuously perfected in order to ensure that climate risks and opportunities are integrated into

our business strategy. In 2022, we published our first report aligned with the TCFD recommendations. In 2023, we updated our

analysis of climate risks and opportunities, including a detailed financial assessment of four risks and one opportunity. In addition,

a strategy review was conducted, ensuring that these elements and the respective TCFD alignment are incorporated in Navigator's

Enterprise Risk Management (ERM) system.

Findings of resilience analysis and impact of climate scenarios

The results from our analysis of climate scenarios suggest that our current strategy is resilient with regard to its ability to address

climate risks and take advantage of related opportunities. Nonetheless, these results have enabled us to identify critical areas to

be monitored, in order to implement mitigation and adaptation measures and also targets to strengthen Navigator's resilience to

climate change [E1.SBM-3.19].

In the future, we intend to continue to develop a more robust analysis of climate-related risks and opportunities, and also to make

progress in the analysis of financial impacts from climate change on our business in line with our sustainable business strategy

[E1.SBM-3.AR7c].

Climate Scenario

Risks

Mitigation

measures

implemented /

planned

Time

horizon

Estimated

impact

(M€/year)

Green Yellow Red

Physical

risks

Change in

precipitation

patterns and

other climate

factors leading

to loss of

yields in

forests

managed by

• Geographical

diversification of wood

supply

• Use of plants from

genetic improvement

programme

• Sharing of technical

know-how concern best

silviculture practices

with Forestry producers

2035

2050

2 – 5 ●● ●●● ●●●●●

ANNUAL REPORT 2024 • MANAGEMENT REPORT 170

Navigator

• Explore other sources of

raw material in order to

ensure business continuity.

Physical

risks

Water scarcity

at the

locations of

the Group’s

industrial

complexes

• Implementation of Water

Use Reduction Programme

(WURP)

• Assessment of reuse of

industrial effluents in

industrial processes

• Assessment of new

sources of fresh water

2035

2050

8 – 40 ●● ●●● ●●●●●

Physical

risks

Increase in

severity and

frequency of

forest fires

• Geographical

diversification of wood

supply

• Implement of best

silviculture practices for

reducing the fire risk

• Use best available

technologies for fire fighting

2035

2050

2.5 - 4 ● ●●● ●●●●

Transition

risks

Increased cost

of emission

licenses in EU-

ETS system

• Setting of specific targets

for industrial operations

based on climate science

• Implementation of

Navigator’s Decarbonisation

Roadmap

2035

2050

3 – 12 ●●●● ●●● ●

Potential financial impact of climate-related risks 15.5 - 61

Caption:

●●●●● Most severe ● Least severe

Climate Scenario

Opportunities

Mitigation

measures

implemented

/ planned

Time

horizon

Estimated

impact

(M€/year)

Green Yellow Red

Investment in R&D to develop new

forest-based products

2035

2050

30 - 40 ●●●●● ●●● ●

Potential financial impact of climate-related opportunities 30-40

Caption:

●●●●● Most severe ● Least severe

Reduction in forest yields due to climate change (e.g. change in resulting pattern), based on analysis conducted internally by Raiz for scenarios RCP 4.5 and 8.5. Annual

impact calculated on the basis of opportunity costs associated with import of wood from outside Iberia, also considering lower pulp yields.

Reduction in water withdrawal licenses as a result of less water being available in the drainage basins and aquifers from which Navigator supplies itself. Analysis based on

hydrological modelling conducted by APA for RCP scenarios 4.5 and 8.5. Annual impact calculated on the basis of lost production resulting from lower volume of water

authorised for withdrawal.

Loss of wood in areas managed by Navigator as a result of forest fires. Annual impact calculated on the basis of opportunity costs associated with import of wood from

outside Iberia, and historical data for burned area in past 10 years.

Impact calculated on the basis of estimated estimated in Navigator's Decarbonisation Roadmap, award of free licenses up to 2035 and CO

prices between 4 €/tCO

(red

scenario) and 188 €/tCO2 (green scenario).

Development of new forest-based products and solutions to replace fossil-based plastic is an opportunity that may represent new business areas for Navigator, in the

short and medium term. In connection with the From Fossil 2 Forest Mobilising Agenda, Navigator has estimated potential Gross Value Added to be achieved in 2027 in

relation to 2020 as a result of these new products.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 171

We have demonstrated the capacity to adapt to climate change in the short, medium and long term, adjusting our strategy,

business model and investment decisions to mitigate risks and take advantage of emerging opportunities. We have increased our

access to financing by integrating ESG criteria into our financial decisions. In June 2022, Navigator issued bonds with a value of

€150 million, maturing in 2028, under the Sustainability-Linked Bonds Framework, and at the same time repaid a loan of the

same amount, valid until 2023. This further extended the average maturity of the Group's debt and contributed to a reduction in

the Company's financing costs, as well as featuring terms tied to fulfilment of its sustainability commitments. The terms of the

loan are indexed to three ESG indicators envisaged in the Company's Sustainability Agenda, and also aligned with the United

Nations Sustainable Development Goals [E1.SBM-3.AR8b].

In addition, climate risk management is built into the Company's financial assessments, ensuring greater stability in the valuation

of assets and projection of cash flows. Alongside this, the Company is implementing a robust capex programme geared to

decarbonisation, technological modernisation and energy efficiency [E1.SBM-3.AR8b].

5.2.2.1.2. Transition plan for mitigating climate change (E1-1)

The transition plan for mitigating climate change plays a fundamental role in the way companies adapt their business models,

making them compatible with target of limiting global warming to 1.5º, in line with the Paris Agreement. Our transition plan

enables us to align our strategy and business model with the target of 1.5º set in the Paris Agreement, through a number of key

initiatives [ESRSE1-1.14]:

• Climate scenario analysis and risk management: the analysis of climate-related risks and opportunities was

conducted using three climate scenarios, including the 1.5°C scenario (RCP 2.6, comparable with SSP1-2), assessing the

resilience of the strategy in the face of possible regulatory and market changes. The assessment was conducted in

accordance with the recommendations of the Task-Force on Climate-related Financial Disclosures (TCFD). [ESRS E1-1.14]

• Design of a decarbonisation roadmap: sets three specific targets for cutting the GHG emissions from our activities:

86% cut in EU-ETS emissions by 2035, in relation to 2018; 63% cut in absolute scope 1+2 emissions by 2035, in relation

to 2020 and 37.5% cut in absolute scope 3 emissions by 2035, in relation to 2020, the last two targets having been

approved by SBTi in 2022. The target for scopes 1 and 2 is aligned with the 1.5ºC target set by the Paris Agreement.

[ESRSE1-1.14]

• Investment in renewable energy: we have a significant plan under way for investment in renewable energy, in

particular projects to replace fossil fuels with sustainably sourced biomass, increasing the capacity of renewable biomass

cogeneration facilities and building new solar power facilities. In addition, two new steam turbines are being built, for the

renewable cogeneration plants in Aveiro and Figueira da Foz, which will make it possible to increase the efficiency of

these facilities and bring down scope 2 emissions. [ESRS E1-1.14]

• Shutdown of natural gas cogeneration plants: In line with the Decarbonisation Roadmap, we anticipate shutting

down the two Natural Gas Cogeneration Plants operated by the Group, by 2035. The cogeneration plant in Figueira da Foz

has been operating on a backup basis since 2021, since the start-up of the new Biomass Boiler that year. The Setúbal

cogeneration plant has been operating with just one of the two generator sets since 2023, and a full shutdown of the

facility is anticipated by 2035, with the installation of a new Recovery Boiler, due to start up in the second quarter of

2025. [ESRS E1-1.14]

• Carbon capture and sustainable forest management: in a context of industrial symbiosis, we supply CO

form

operations to our suppliers of precipitated calcium carbonate (PCC), which we then use as a raw material in producing

UWF in Figueira da Foz and Setúbal. In 2024, this made it possible to incorporate approximately 123,000 tons of CO

, of

which 12,700 form fossil origin, avoid emission into the atmosphere. In addition, sustainable management of more than

135 thousand hectares of forests, in mainland Portugal and Mozambique, enables us to point to a carbon stock of

approximately 9.1 Mt CO

e. [ESRS E1-1.14]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 172

Our transition plan has been approved by the administrative, management and supervisory bodies. [ESRS E1-1.16i]

Compatibility of goals with limiting warming to 1.5ºC [ESRS E1-1.16a] [E1-4.34f]

Embracing an active role in the search for solutions for the climate challenge, we set two new climate science-based targets in

2022 for reduction of greenhouse gas (GHG) emissions. We set near-term targets of a 63% reduction in scopes 1 and 2 GHG

emissions and a 37.5% reduction in scope 3 emissions by 2035, in relation to 2020 levels. The targets, approved by SBTi, are

consistent with the ambition to reduce GHG emissions to the levels needed to limit global warming to 1.5ºC, in the case of scopes

1 and 2 emissions, and well below 2°C, in scope 3 emissions. The targets were set on the basis of decarbonisation trajectories in

the sector and the wider economy, ensuring conformity with scientific climate principles. [ESRS E1-1.16a]

Climate scenarios were analysed on the basis of the IPCC’s 15°C scenario (RCP 2.6) and the Sustainable Development Scenario of

the International Energy Agency (IEA). This approach ensures a balanced transition, guaranteeing that climate action is

compatible with sustainable development principles. [ESRS E1-1.16a]

The approach to analysis of climate scenarios, risk and opportunities assessment and target setting has been aligned with the

Forest Sector Net-Zero Roadmap of World Business Council for Sustainable Development (WBCSD), a benchmark mapping a

credible decarbonisation trajectory for the sector. We continue to monitor developments in terms of climate science, especially the

GHG Protocol and SBTi benchmarks for the sector. [ESRS E1-1.16a]

It should be noted that the Company is not excluded from EU benchmark indicators aligned with the Paris Agreement. [ESRS E1-

1.16g]

Decarbonisation levers

Our climate transition plan is based on several levers and actions for cutting GHG emissions, aligned with the targets and strategy

for climate change mitigation. The main measures adopted include operational optimisation, implementation of new technologies

and changes to the product portfolio, advancing the transition to a low-carbon economy. The main decarbonisation levers and

actions include: [ESRS E1-1.16b] [ESRS E1-1.16h]

Energy transition and adoption of renewable energy

Navigator is focussed on advancing the energy transition at its industrial complexes, investing in the use of renewable fuels, in

particular sustainable biomass (biomass that meets the sustainability criteria set in REDII), rather than fossil fuels. We invest in

highly efficient technologies that make it possible to maximise the energy content of biomass, such as the construction of a new

recovery boiler at the Setúbal Industrial Complex, due to start up in 2025.

We are also committed to producing renewable electricity, by upgrading our current high efficiency cogeneration facilities and

installing new solar power facilities for in-house consumption, helping to bring down scope 2 emissions. In 2024 Navigator started

up the solar power facility at Tissue Aveiro, with power capacity of 1.9 MWp, and the second solar power facility at Paper Figueira,

with capacity of 2.7 MWp. Alongside this, a new solar power facility was built on the ground in Figueira da Foz, with capacity of

17.4 MWp, in a partnership with EDP, ensuring a supply of renewable electricity for 25 years. [ESRS E1-1.16b]

Operational Efficiency

In addition to the energy transition, Navigator has been working to implement operational efficiency projects at its industrial

complexes in order to optimise energy intensity on an ongoing basis. In 2024, energy efficiency projects completed presented a

potential annual energy reduction of 4.6 GWh, helping to optimise resources. [ESRS E1-1.16b]

Adaptation of product and service portfolio

ANNUAL REPORT 2024 • MANAGEMENT REPORT 173

Development of the gKRAFT sustainable packaging segments, which offers alternatives to fossil-based plastics, supporting the

transition to renewable, low carbon products. Production of moulded cellulose articles to substitute disposable plastics in the food

packaging sector, in alignment with sustainability goals. [ESRS E1-1.16b]

Sustainable forest management and carbon sequestration

Sustainable management of 136 850 hectares of forest plays a fundamental role in mitigating climate change. Among other

advantages, this makes it possible to sequester 9.1 Mt of CO

. In addition, the cellulose and paper products marketed by

Navigator make it possible to store approximately 2.6 Mt CO

equivalent. [ESRS E1-1.16b]

Initiatives along the value chain

Navigator is also aiming to reduce the emissions along its value chain (scope 3). To that end, the Company is drawing up a

decarbonisation plan that will involve working closely with its logistical suppliers, in promoting low carbon solutions, efficient

processes and optimised routes. [ESRS E1-1.16b]

Investment and financing supporting execution of transition plan

Our decarbonisation roadmap is ambitious and requires action throughout the value chain. In the context of scopes 1 and 2

emissions, the roadmap includes a set of 23 initiatives, of which 17 are supported by the RRP and one by the Innovation Fund -

the European Union fund for climate policy, focusing especially on energy and industry. It may be noted that we have so far

concluded eight of the proposed initiatives. Of the others, fourteen have been approved and are in progress. Execution of the 23

initiatives is estimated to represent investment in excess of 350 million euros in the period 2019-2028. In the field of energy

efficiency, more than 8 million euros has been invested in projects that bring energy savings of approximately 100 GWh/year,

avoiding the emission of 23,000 tons of CO₂. These measures have included improvements to the production of compressed air,

optimisation of cooling systems, installation of LED lighting and improved thermal efficiency, bringing annual savings of 6 million

euros in our energy costs. These initiatives have also made it possible to optimise consumption of energy from primary sources

per ton of manufactured output. [ESRSE1-1.16c]

Main CapEx projects in decarbonisation in 2024

In 2024, work started on the Tissue Aveiro Solar Power Facility and the 2

Rooftop Facility at Paper Figueira, two projects

supported by the RRP and representing investment of approximately 2.5 M€, aligned with the technical criteria of the European

taxonomy. [ESRSE1-1.16e]

Another solar facility with a capacity of 17.4 MWp at the Figueira da Foz Industrial Complex also went into operation, in a

partnership with EDP. This will supply approximately 26.3 GWh/year of 100% renewable power, over 25 years.

Significant progress was made in building the new high efficiency recovery boiler in Setúbal, and this is planned to start up in the

second quarter of 2025. This facility, fundamental for optimising generation of thermal energy from sustainable biomass, will

enable us to scale down operation of the Natural Gas Cogeneration Plant. In relation to the baseline in the decarbonisation

roadmap, the new recovery boiler will bring a potential reduction in excess of 100 thousand tons of CO

. Partial funding has been

provided by the European Investment Bank (EIB), under the REPowerEU programme. This project, along with other improvements

made to Renewable Cogeneration Plants using Bioenergy have contributed to eligible CapEx, aligned with the technical criteria of

the European taxonomy, for activity 4.20. [ESRSE1-1.16c] [ESRSE1-1.16e] [ESRSE1-1.16f]

Accumulated stock in forests in Portugal and Mozambique.

The inventory of the accumulated stock in forests in Mozambique uses the figure recorded in 2021 as the baseline.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 174

ESG initiatives undertaken in 2024, including investment in decarbonisation projects, represented approximately 51% of total

CapEx, corresponding to around 120 million euros. [ESRSE1-1.16c]

Future CapEx plans

We remain committed to identifying and analysing new technological solutions which can be translated into initiatives for inclusion

in the Decarbonisation Roadmap, so as to eliminate future emissions associated with industrial assets and processes. We are

actively seeking to achieve the commitments made in the 2030 Agenda in relation to climate change, in particular by cutting

scopes 1, 2 and 3 emissions.

Progress in implementation of the transition plan

The progress made in implementing our transition plan is witnessed by the reduction in emissions, growth in the use of renewable

energy and the channelling of investment to sustainable initiatives. In relation to the reduction of GHG emissions, by 2024 we

achieved a 41% reduction in direct EETS (European Emissions Trading Scheme) emissions, in comparison with 2018 levels. In the

context of the SBTi targets, we achieved a reduction in scopes 1 and 2 emissions of approximately 36%, in relation to the baseline

year, and 14%, in relation to 2023 [E1-4.2.80j].

The reduction in direct emissions, in relation to the reference years, has been driven by implementation of eight decarbonisation

projects, as well as by the slower pace of paper production, which enabled us to scale down operation of Natural Gas

Cogeneration. In addition, there was a substantial reduction in 2024 in the emissions factor for electricity in Portugal,

demonstrating the increased incorporation of renewables in the national energy mix [E1-4.2.80j].

With regard to scope 3 emissions, which encompass emissions associated with the supply chain, transport and product life cycle,

there was an increase of 10% in relation to the baseline year and a reduction of 8% in relation to 2023. In this area we have

made significant improvements in the collection, analysis and quantification of emissions, and in particular identified more

appropriate emissions factors, more precise estimates of kilometres travelled and more complete calculation methodologies, in

relation to emissions for processing and end-of-life treatment of sold products (C10 and C12, respectively) [E1-4.2.80j]

This progress means the Company remains on the right track to achieve the target of a 63% reduction in scopes 1 and 2 GHG

emissions by 2035. [ESRSE1-1.16j] [E1-4.2.80j]

In relation to the transition to renewable energy, 80% of the primary energy consumed in 2024 was from renewable sources, in

particular biomass and solar energy, equalling the target set for 2030. [ESRSE1-1.16j] [E1-4.2.80j]

Energy consumption per ton of output in industrial activities in Portugal was brought down by approximately 1% in relation to

2023, in line with Navigator’s ambition, set out in its 2030 agenda, of optimising energy intensity, year after year. [E1-4.2.80j]

The Company’s climate action was recognised in 2024 by Carbon Disclosure Project (CDP), earning it a score of "A", which

confirms it as a leader in climate performance. In addition, the Company remains aligned with international frameworks, such as

the Science Based Targets (SBTi) initiative and the Task Force on Climate-related Financial Disclosures (TCFD). [ESRSE1-1.16j]

5.2.2.2. Management of impacts, risks and opportunities

5.2.2.2.1. Policies related to climate change mitigation and adaptation (E1-2, MDR-P)

Navigator’s policies and strategies reflect a wide-ranging commitment to sustainability and response to climate change, most

notable its Environmental Policy and the Management Systems Policy.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 175

The Environmental Policy and the Decarbonisation Roadmap are framed by the Company’s Purpose, establishing commitments

for the Climate and Nature, in keeping with the materially relevant topics in Navigator’s 2030 Agenda and contributing to the

successful implementation of the UN Sustainable Development Goals (SDGs). They focus on mitigating climate change, promoting

reduction of greenhouse gas emissions and encouraging investment in renewable energy and efficient processes.

In particular,

they lay down the following commitments [E1-2.25]:

• To take an active role in the low-carbon economy, in line with current scientific knowledge, through sustainable

management of its forests, investment in renewable energy sources and improving the efficiency of its processes,

products and services.

• To reduce greenhouse gas emissions (GHG) with a view to achieving carbon neutrality, in line with the aims of

climate action as set out in the Paris Agreement.

• To incorporate climate risk assessments in the decision-making process, in line with European recommendations

and the main international frameworks.

• To achieve, systematically, improved energy performance and optimisation of processes.

The Management Systems Policy

sets out Navigator’s general commitments in relation to its quality environmental, energy and

safety management systems. This stresses the adoption of best available techniques for improving environmental performance -

which includes energy performance and adoption of efficient and sustainable practices - and encourages suppliers to develop

products and services which are aligned with the Company's requirements and aims. [ESRS 2.65a | E1-2.25]

Complementing this, it may be noted that the Forestry Policies (Chap. 5.2.6) and PG 80 – Management of Environmental

Issues address climate change adaptation, ensuring the resilience of ecosystems and effective management of the environmental

impacts associated with the company’s operations. [E1-2.25]

Document

Environmental Policy

Description of key

contents and general

objectives

[ESRS 2.65a]

In line with the principles of prevention, mitigation and remediation of the actual and potential

impacts of operations, with the requirements to which the Company has signed up voluntarily

and with all the applicable obligations to comply with the law, this lays down Navigator's

general commitments on environmental matters. It also includes specific content on: climate

change and CO

sequestration; water management; circular economy; energy and raw

material management; sustainable forestry management and biodiversity conservation.

Scope

[ESRS 2.65b]

It applies to Navigator’s own operations and has impacts upstream and downstream in the

value chain, on Suppliers and local

Communities. It covers all geographical regions and

Navigator's business areas.

Most senior level

position accountable for

its implementation

[ESRS 2.65c]

Executive Committee

Standards or third party

initiatives

which the Company

undertakes to comply

with

[ESRS 2.65d]

UN Fundamental Right of access to a clean environment

Availability

[ESRS 2.65f]

Available on the Intranet and online.

References throughout

of the non-financial

Statement

• E3 – Water and marine resources (Chap. 5.2.3)

• E4 – Biodiversity and ecosystems (Chap. 5.2.4)

• E5 – Resource use and circular economy (Chap. 5.2.5)

• Sustainable forest management (Chap. 5.2.6)

ANNUAL REPORT 2024 • MANAGEMENT REPORT 176

Document

Decarbonisation Roadmap

Description of key

contents and general

objectives

[ESRS 2.65a]

Roadmap setting targets and goals for mitigating climate change in Navigator's industrial

activities

Scope

[ESRS 2.65b]

Applies to own operations, including internal Stakeholders, and covers Portugal.

Most senior level

position accountable for

its implementation

[ESRS 2.65c]

Executive Director responsible for Energy

Standards or third party

initiatives

which the Company

undertakes to comply

with

[ESRS 2.65d]

SBTi

Availability

[ESRS 2.65f]

Available on the Navigator’s Annual Report

5.2.2.2.2. Actions and resources in relation to climate change policies (E1-3, MDR-A)

Navigator plans to implement action and allocate resources under its policies related to climate change, both to initiatives already

under way and to those planned for implementation. Execution of seven actions already undertaken, comprising the Tissue Aveiro

Solar Power Facility (SPF), Figueira Rooftop SPF 2, Adaptation of Burners to H₂, Installation of variable-frequency drives (VFD) in

Aveiro, Installation of LED lighting in Figueira da Foz and Installation of a Reboiler for Steam Production in Vila Velha de Ródão,

entailed capital expenditure (CapEx) of 1.0 M€, 1.5 M€, 4.5 M€, 0.1 M€, 0.2 M€ and 0.4 M€, respectively. [ESRS 2.69b]

Initiatives planned and due for completion in 2025, which include Tissue SPF in Vila Velha de Ródão, New Steam Turbine at Tissue

Aveiro, New Steam Turbine at Paper Figueira and New Recovery Boiler in Setúbal, represent multiannual CapEx of 2.2 M€,

18.7 M€, 7.6 M€ and 135.8 M€, respectively. [ESRS 2.69b]

The following table presents a detailed description of the actions carried out and planned, including their scope (own operations),

time horizon and the results already achieved or expected.

Main actions

Status

Scope of action

Time horizon

Results

[ESRS 2.68a]

[ESRS 2.68b]

[ESRS 2.68c]

[ESRS 2.68 a

ESRS 2.68e]

Actions aimed at reducing scope 1 emissions

Adaptation of burners

to H

Executed

Own operations (Figueira da Foz)

(Reduction of scope 1 emissions)

2024 7500 tCO

/year

Installation of 1

Reboiler for steam

production in Ródão

Executed

Own operations (Vila Velha de Ródão)

(Reduction of scope 1 emissions)

2024

3.8 GWh/year

793 tCO

/year

New Recovery Boiler in

Setúbal

Planned

Own operations (Setúbal)

(Reduction of scope 1 emissions)

2025 101,000 tCO

/year

Actions aimed at reducing scope 2 emissions

Tissue Aveiro SPF Executed

Own operations (Aveiro)

(Reduction of scope 2 emissions)

2024

2.5 GWh/ano

260 tCO

/year

Figueira Rooftop SPF 2 Executed

Own operations (Figueira da Foz)

(Reduction of scope 2 emissions)

2024

3.7 GWh/year

384 tCO

/year

CFV Figueira Solo Executed

Own operations (Figueira da Foz)

(Reduction of scope 2 emissions)

2024

26.3 GWh/year

2701 tCO

/year

Installation of Aveiro

SPF

Executed

Own operations (Aveiro)

(Reduction of scope 2 emissions)

2024

0.5 GWh/year

53 tCO

/year

ANNUAL REPORT 2024 • MANAGEMENT REPORT 177

Main actions Status Scope of action Time horizon Results

[ESRS 2.68a]

[ESRS 2.68b]

[ESRS 2.68c]

[ESRS 2.68 a

ESRS 2.68e]

Installation

of LED Lighting

Figueira da Foz

Executed

Own operations (Figueira da Foz)

(Reduction of scope 2 emissions)

2024

1.1 GWh/year

109 tCO

/year

CFV Tissue Ródão Planned

Own operations (Vila Velha de Ródão)

(Reduction of scope 2 emissions)

2025

5.9 GWh/year

606 tCO

/year

New Steam Turbine

Tissue Aveiro

Planned

Own operations (Aveiro)

(Reduction of scope 2 emissions)

2025

11,200 tCO

/year

New Steam Turbine

Paper Figueira

Planned

Own operations (Figueira da Foz)

(Reduction of scope 2 emissions)

2025

2800 tCO

/year

Note: For further information on CapEx - Nos. 3.2, 3.3 of 3.6 of the Notes to Navigator's Consolidated Financial Statements.

5.2.2.3. Targets and metrics

5.2.2.3.1. Targets related to climate change mitigation and adaptation

(E1-4, MDR-T, MDR-M)

In our 2030 Roadmap (Chapter 3.4.4) we have set six targets relating to climate change mitigation and adaptation, in line

with the IROs identified [E1-4.33]. By 2035, we aim to achieve a reduction of 86% in direct EETS emissions of CO₂ at our

industrial complexes, and also to reduce scopes 1 and 2 GHG emissions by 63% and scope 3 GHG emissions by 37.5%. Another

of our targets is to optimise energy intensity, with efforts to improve efficiency on an ongoing basis and ensure that 80% of the

primary energy consumed is from renewable sources. Attention is drawn to the objective of developing cloned plants and

improved seeds, able to boost yields by between 30% and 50% and of offering greater resilience to climate change.

The targets set for reducing CO

emissions are directly related to our Decarbonisation Roadmap and Environmental Policy,

reflecting our commitment to sustainability and reducing GHG emissions. These have been established in line with the Company’s

own operations in Portugal and Spain, involving participation by internal Stakeholders, the Environmental Board, the Community

Monitoring Committees, the Faculty of Science and Technology at Nova University Lisbon and the SBTi. [E1-4.2.80 | E1-

4.2.80c/g/h]

The following table shows the different targets set and the progress achieved. [E1-4.2.80j]

Goal

and

target

covered,

scope

Baseline

Associated

metric

2022

Performance

2023

Performance

2024

Performance

Results

achieve

[E1-4.34a and

34b]

[E1-4.34b]

[E1-4.34c]

[E1-4.34a and 34b and

ESRS 2.80j]

[E1-4.34a and 34b and

ESRS 2.80j]

[E1-4.34a and 34b and

ESRS 2.80j]

[E1-4.34d

and ESRS

2.80b]

Cut direct

EETS CO

emissions by

86%

89%

Scope 1

774,464

tCO

Baseline:

2018

Scope 1 EETS

-28.6%

552,587 tCO

-41.0%

457,990 tCO

-41%

454,234 tCO

-86%

Year: 2035

Cut scopes 1

and 2 GHG

emissions by

63%

91%

scope 1

96%

scope 2

Location

Based

937,710

tCO

Baseline:

2020

Scope 1+2

Goal defined in 2022

-26%

698,715 tCO

-36%

599,397 tCO

-63%

Year: 2035

Figure corrected through EETS verification (previous figure 456,689 tCO

)

ANNUAL REPORT 2024 • MANAGEMENT REPORT 178

Cut scope

3 GHG

emissions

37.5%

76%

scope 3

958,266

tCO

Baseline:

2020

Scope 3

Goal defined in 2022

+6.8% 1,142,275

tCO

+9.6%

1,050,577 tCO

-37.5%

Year: 2035

Optimise

eneregy

intensity,

year after

year

Baseline:

2020

Energy

intensity

12.0 GJ/t 12.9 GJ/t 12.7 GJ/t Year: 2030

Increase

use of

renewable

energy as

proportion of

total primary

energy

consumption

70%

Baseline:

2020

76% 80% 80%

80%

Year: 2030

Develop

genetically

improved

clones and

seeds, with

gains in

yields and

resilient to

climate

change.

- -

Gain

in volume

and pulp (%),

Genetic

diversity (no. of

hybridisations,

no. of clones

delivered or

other diversity

indicator)

New clone varieties

delivered for

production.

Clone selection has

had impacts on the

resistance of

eucalyptus to

disease, in nurseries

and in the field.

Incorporation of new

genetic materials in

the programme

(release of more

than 100

individuals). Poor

year for seed

production.

Incorporation of 29

lots of seeds for 24

species through

importation and

collection at

Portuguese

“Escaroupim”

arboretum, to

increase diversity in

Genetic

Improvement

Programme in the

long term through

hybridisation with E.

globulus.

3 new clones

delivered in the

Viveiros Aliança

portfolio, with a

genetic gain of 41%

(volume and pulp),

all resistant to

Neopestalotiopsis,

and two with known

resistance to

Ophelimus.

Maintain

gains in

volume and

pulp (30-

50%)

and/or

enrich

genetic

diversity

(for biotic

and abiotic

factors).

* Target for activities in Portugal. The following emissions sources are excluded from scope 1: i) emissions associated with fluorinated gases; ii) own fleet; iii) CH

and N

associated with fertiliser use, representing approximately 4% of inventory.

**The following categories were included: Category 1, excluding emissions associated with purchases of PCC, pulp, services, wood and waste forestry biomass; and

categories 3, 4, 9, 10 (emissions related to processing pulp into UWF and tissue) and 12 (50% of emissions associated with landfill disposal).

As part of the goal of an 86% reduction in EETS emissions by 2035, an interim target was set of 31.5% by 2027. This target was

exceeded two years running, and so we now regard it as attained. [E1-4.2.80e].

In relation to the target calculation methodology, the reduction in direct EETS emissions of CO₂ from industrial complexes has

been defined in accordance with the European Emissions Trading Scheme Directive. In addition, the two targets relating to scopes

1, 2 and 3 emissions have been set on the basis of the principles of the GHG Protocol and aligned with the SBTi initiative [E1-

4.2.80f]. The targets set and validated by SBTi encompass all of Navigator’s activities. [E1-4.34b]

No changes were made to the value of the targets, the year set for attainment, the calculation or data collection methodology or

to the assumptions, sources or limitations, in relation to the previous reporting period. [E1-4.2.80j]

The baseline years for the targets, 2018 and 2020, were selected as being periods which are representative of the Company’s

operations, with production levels in line with the average for the previous five years. [E1-4.AR25a]

The reference target values aligned limiting global warming to 1.5ºC for scopes 1 and 2 were calculated on the basis of the

methodology and tool provided by SBTi. [E1-4.AR26]

The progress made in the past in order to achieve the goals established prior to the current reference year is document in the

2030 Roadmap (Chap. 3.4.4). [E1-4.34c]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 179

We set out decarbonisation targets in the light of various future factors, including changes in consumer preferences, the

evolution of regulations and new technologies. The business diversification plan and product portfolio that the company has

implemented in its sustainable business strategy ensures that the strategy for transition to a low carbon model is robust and

adaptable to different future scenarios. [E1-4.34e]

5.2.2.3.2. Energy consumption and mix (E1-5)

[E1-5.37/38] Energy mix

Total 2024

(MWh)

[E1-5.38a]

Fuel consumption from coal and coal products

[E1-5.38b]

Fuel consumption from crude oil and petroleum products

240 757

[E1-5.38c]

Fuel consumption from natural gas

2 050 398

[E1-5.38d]

Fuel consumption from other fossil sources

39 973

[E1-5.38e]

Consumption of purchased or acquired electricity, heat, steam, or

cooling from fossil sources

346 079

[E1-5.37a]

Total energy consumed from fossil sources

2 677 206

[E1-5.37b]

Total energy consumed from nuclear sources

123 061

[E1-5.37ci]

Fuel consumption for renewable sources including biomass

8 943 195

[E1-5.37cii]

Consumption of purchased or acquired electricity, heat, steam, and

cooling from renewable sources

898 251

[E1-5.37ciii]

Consumption of self-generated non-fuel renewable energy

10 938

[E1-5.37c]

Total energy consumed from renewable sources

9 852 383

[E1-5.37]

Total energy consumption

12 652 651

[E1-5.AR34]

Fossil sources as a % of total energy consumption

21%

[E1-5.AR34]

Nuclear sources as a % of total energy consumption

[E1-5.AR34]

Renewable sources as a % of total energy consumption

78%

Note: Methodology - The energy consumption reported includes primary energy and electricity consumed in all geographical regions, including Navigator Tissue UK, merged

into the group in May 2024. It excludes consumption of electricity at international offices, due to the low materiality. Energy consumption at industrial facilities represents

99.9% of Navigator’s total consumption, and the rest is divided between forestry operations, offices in Portugal and employee mobility. Electricity and natural gas

consumption are measured using our own meters managed by the network operator. Fuel oil and biomass consumed are measured using the weighbridges at the industrial

complexes. Black liquor is quantified using flow meters at the entrance to the recovery boiler. Considering the net calorific value (NCV) of fuels consumed in accordance

with the EETS Regulation. Energy consumption related to employee mobility estimated on basis of kilometers recorded on the respective platforms or estimated on the

basis of invoiced costs. The most significant changes in 2024 include energy associated with a full year of operation of Navigator Tissue Ejea, as well as the energy

consumed at Navigator Tissue UK, merged into the group as from May 2024.

At the 3 pulp mills, Navigator produces renewable electricity from biomass in high efficiency cogeneration facilities. In addition, it

has two biomass power plants dedicated to the sale of electricity, located in Aveiro and Setúbal, respectively. It also produced

renewable power at 7 solar power facilities for in-house consumption, located at the industrial complexes in Aveiro, Figueira and

Setúbal, as well as at Instituto RAIZ and at the Espirra Estate. In addition, in Setúbal and Figueira da Foz, power is generated in

two combined-cycle natural gas plants, although the plant in Figueira da Foz is currently operating only on a back-up basis.

Power generation

Total 2024

(MWh)

[E1-5.39]

Total power generation

1 373 621

[E1-5.39]

Electricity produced from renewable sources

1 070 207

[E1-5.39]

Electricity produced from fossil sources

303 414

Electricity sold

1 159 115

ANNUAL REPORT 2024 • MANAGEMENT REPORT 180

Note: Power generation is quantified using dedicated meters

[E1-5.38/40/41] Energy intensity

2024

Consumption of energy in HCIS [MWh]

12 652 651

Net revenues from HCIS [€]

2 088 276 553

Energy intensity (MWh / M€)

6 059

Note: Energy intensity is calculated on the basis of total energy consumption and total revenues, as Navigator's economic activities are classified as being high climate

impact sectors (HCIS) [E1-5.42]

5.2.2.3.3. Gross Scopes 1, 2, 3 and total GHG emissions (E1-6)

[E1-6.44a] Scope 1 GHG emissions

2024 (tCO

eq)

Scope 1 GHG emissions from fossil sources 509 037

Scope 1 GHG emissions from biogenic sources 3 551 724

Note 1: The GHG Protocol guidelines have been followed. [E1-6.AR39b]

Note 2: Scope 1 emissions from fossil sources include emissions under the European Emissions Trading Scheme (EETS), which in 2024 represented 454,234 tCO

, in other

words, 89% of total scope 1 emissions. This figure is provisions, as it has not yet been EETS verified. [E1-6.44a/48b/50b]

Note 3: CO

emissions from biogenic sources result from combustion of black liquor and other biomass fuels for energy production. They are calculated in accordance with

MRR Guidance Document no. 3, of the European Commission, in line with the sustainability criteria of the REDII Directive.

The calculation of scope 1 emissions includes direct emissions associated with activities carried out by the Company. This scope

includes the activities of Portucel Moçambique, Navigator Tissue Ejea, Navigator Tissue UK (from May to December 2024), and

excludes the international offices, due to their low materiality. This calculation counts the CO

emissions included in the European

Emissions Trading Scheme (EETS), which in 2024 represented approximately 89% of the scope 1 total. The other emissions of

, CH

, N

O and fluorinated gases are also counted, in accordance with the requirements of the GHG Protocol. We include

emissions relating to industrial, forestry and R&D activities, as well as emissions related to employee travel in our own fleet. CO

emissions from biogenic sources result from combustion of black liquor and other biomass fuels for energy production, in line with

the sustainability criteria of the REDII Directive. Biogenic CO

emissions are part of the natural carbon cycle and are treated as

carbon neutral. [E1-6.AR39b]

The most relevant changes in 2024 include emissions associated with a full year of operation of Navigator Tissue Ejea, as well as

the emissions associated with Navigator Tissue UK, merged into the group as from May 2024. [E1-6.47]

The Corporate Inventory of GHG emissions is described in the following table [E1-6.44d/52/AR47]

[E1-6.44d/52/AR47] Total GHG emissions (tCO

eq) 2024 2023 % Δ

[E1-6.44a] Scope 1 GHG emissions 509 037 508 833 0%

EETS emissions 454 234 457 990 -1%

Other scope 1 emissions 54 803 50 843 8%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 181

GHG emissions from regulated emission trading schemes (%) [E1-

6.44a/48b/50b]

89% 90%

[E1-6.44b/49/52] Gross location-based Scope 2 GHG emissions 140 633 230 642 -39%

[E1-6.44b/49/52] Gross market-based Scope 2 GHG emissions 126 020 312 942 -60%

[E1-6.44c/51] Total Gross indirect (Scope 3) GHG emissions 1 388 985 1 397 752 -1%

Category 1: Purchased goods and services 856 601 792 005 8%

Category 3: Fuel and energy-related activities (not included in Scope 1 or

Scope 2)

90 324 100 052 -10%

Category 4: Upstream transportation and distribution 95 383 90 208 6%

Category 9: Downstream transport and distribution 96 808 116 597 -17%

Category 10: Processing of sold products 102 467 154 224 -34%

Category 12: End-of-life treatment of sold products 147 402 144 667 2%

Total location-based GHG Emissions 2 038 655 2 137 228 -5%

Total market-based GHG Emissions 2 024 042 2 219 528 -9%

Note 1: The GHG Protocol guidelines have been followed. [E1-6.AR39b/AR46d]

Note 2: Scopes 1, 2 and 3 emissions include emissions associated with all Navigator’s activities in all geographical regions, except for emissions associated with the

international offices due to their low materiality (<0.02%). The emissions of Navigator Tissue UK, merged into Navigator in May 2024, were included in scopes 1 and 2 and

there are plans for extending this to scope 4 next year.

Note 3: Othere scope 1 emissions represent emissions associated with industrial assets outside the scope of EETS, emissions associated with fluorinated gases, methane

and nitrous oxide and emissions associated with travel in our own fleet.

Note 4: The 2023 figures, including EETS emissions, fluorinated gases, methane and nitrous oxide, have been updated, incorporating the EETS verification prior to

publication of the 2023 Sustainability Report, information nor previously available. The materiality of the adjustment is less than 0.2%

Note 5: Location-based scope 2 emissions were calculated with the latest emissions factors from the International Energy Agency (IEA). Market-based emissions consider

the emission factors of the vendors as well as the supply of 100% renewable energy under Power Purchase Agreements (PPA). The 2024 figures are provisional, as the final

emission factor values are not yet available.

Note 6: In scope 3, categories 2, 5, 6 and 7 are excluded, due to their low materiality. Navigator conducted a materiality analysis in 2022, and identified these categories

as not material. Categories 8, 11, 13, 14 and 15 are excluded because they do not apply to Navigator's business. [E1-6.AR46i]

There was a reduction of approximately 5% in 2024 in the corporate emissions inventory in relation to 2023. Scope 1 emissions

remained at the same level as 2023, including, however, emissions associated with a full year of operation of Navigator Tissue

Ejea and seven months of Navigator Tissue UK. In relation to the baseline year of 2018, EETS emissions have come down by

41%, achieving practically half of the target established for 2035. In industrial activities in Portugal, direct emissions per ton of

output came down by approximately 5% in relation to 2023, as a result of improved operational efficiency at mills and less

consumption of fuel oil. In relation to scope 2 emissions, there was a significant reduction of 39% in relation to 2023 (location-

based) and 60% (market-based), due above all to the reduction in emissions factors. In the case of location-based emissions, the

emissions factor in Portugal was kgCO

/MWh, impacted by the high level of incorporation of renewable energy in the national mix.

In the case of market-based emissions, the result was impacted by the supply mixes of vendors. This indicator considers the

contractual instruments established for supply of renewably sourced electricity, in particular a Power Purchase Agreement (PPA)

ANNUAL REPORT 2024 • MANAGEMENT REPORT 182

for 115 GWh with Endesa which includes guarantees of renewable origin, as well as supply of power under physical PPAs with the

solar power facilities at Figueira da Foz and Ejea [E1-6.45d]. Attention should also be drawn to Navigator Tissue UK, where the

electricity purchased is 100% renewable.

In order to calculate scope 3 emissions, the guidelines of the GHG Protocol are considered. This involves following a hybrid

methodology: average data and spent data. The combination of these two methodologies offers the best approach to calculating

scope 3 emissions. [E1-6.AR46h] The emissions factors selected for calculating scope 3 emissions are taken from credible

databases, mostly from Ecoinvent and DEFRA. We do not use emissions factors provided by suppliers [E1-6.AR39] and [E1-

6.AR46g]. Scope 3 emissions in 2024 remained in line with those recorded in the previous year. Improvements were made during

the year to the calculation methodology for this scope, aligned with Navigator's commitment to progressively incorporation more

comprehensive and better quality data. The scope of raw materials considered was expanded, to include the geographical regions

of Portugal, Spain and Mozambique. However, emissions associated with Navigator Tissue UK have still not been included, due to

the complexity of gathering data. With regard to category 1, packaging materials, chemicals and other raw materials not previous

quantified were added. In relation to category 4, the distances travelled in wood transportation were estimated on the basis of the

municipality of origin of the raw material.

[E1-6.53/54] GHG emissions intensity

GHG emissions

2024 (tCO

eq)

Net Revenues

2024 (€)

GHG emissions

intensity

(tCO

eq/M€)

Location-based 2 038 665 2 088 276 553 976

Market-based 2 024 042 2 088 276 553 969

Note: For more information related to Navigator's net revenues in 2024, please see no. 2.1 to the Financial Statements. [E1-6.55]

stock retained in our products

[MDR-M] Biogenic carbon retained

in our products

2024

Total Mt CO

2.6

5.2.2.3.4. Anticipated financial effects from material physical and transition risks and potential climate-

related opportunities (E1-9)

In 2023, Navigator conducted an analysis of financial impacts, in accordance with the TCFD recommendations, quantifying the

impact of 4 risks and 1 opportunity (see section on SBM-3, at the start of this chapter). Nonetheless, as permitted by Appendix C

to ESRS 1, Navigator opted not to report additional information on this analysis

ANNUAL REPORT 2024 • MANAGEMENT REPORT 183

5.2.3. ESRS E3: Water and marine resources

5.2.3.1. Strategy

5.2.3.1.1. Material impacts, risks and opportunities and their interaction with strategy and business

model (SBM-3)

Description

Impacts, Risk or

Opportunity

Time horizon Location in value chain

Related sub-topic or

sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

Water withdrawal in area of

water scarcity and/or stress

(Intensive use of shared

resource)

Negative impact -- Own operations Water withdrawal

Underground water

withdrawal

Negative impact -- Own operations Water withdrawal

Surface water withdrawal

Negative impact -- Own operations Water withdrawal

Water stress

Risk

Short term –

reporting year

Own operations Water withdrawal

Note: the material impacts identified are actual, and so there is no associated time horizon.

5.2.3.2. Management of impacts, risks and opportunities

5.2.3.2.1. Policies related to water and marine resources (E3-1, MDR-P)

The Navigator Company has developed and formalised a series of policies in which the subject of water is addressed, including the

Environmental Policy and the Management Systems Policy. In addition, and specifically in connection with forestry activities,

the Forestry Policy addresses significant water issues, among other things. These policies are complemented by several other

more specific documents such as the General Procedure for Management of Environmental Issues and Technical Standard 08 -

Management of Water Resources. [E3.9]

The Environmental Board, the Sustainability Forum and the Local Community Monitoring Committees are bodies belonging to the

sustainability governance structure that include external Stakeholders (Chap. 3.4.5) and take part in defining Navigator's policies,

contributing scientific expertise and the concerns most relevant to local Communities. [ESRS 2.65e]

Navigator’s Environmental Policy addresses issues of water use and supply effluent treatment and the design of products and

services, establishing clear commitments to invest in the best available technologies, continuous optimisation of industrial

processes and promotion of water efficiency and ecodesign of products.

As a more general policy supporting the Environmental Management System in accordance with ISO 14001, the Management

Systems Policy sets out a commitment to mitigate and minimise environmental impacts associated with Navigator's activities,

whilst also promoting adoption of the best available techniques for improving environmental performance, which includes water

(and effluent) management. [E3.11] [E3.12c] [ESRS 2.65 a]

The Forestry Policy does not explicitly address water management, but is part of the sustainable forestry management model, in

accordance with the applicable legislation and the PEFC and FSC

standards (FSC

-C010852). In order to ensure that water

resources are preserved and used sustainably, a specific water management strategy has been designed, aligned with

environmental goals and targets incorporated into forestry management practices [E3.11] [ESRS 2.65 a]. This strategy is

ANNUAL REPORT 2024 • MANAGEMENT REPORT 184

designed to prevent impacts on water resources and to boost the positive impacts, ensure that water quality is maintained, and

that water remains available. Its priorities are biodiversity conservation and protection of aquatic ecosystems, ensuring the

integrity of surface and underground water bodies, as well as preservation of river ecosystems and the environmental services

they provide, promoting retention of sediments, hydrological regulation and protection against erosion [E3.AR18a] [E3.AR18b].

Implementation of this approach is ensured by the Forestry Management System, which includes Technical Standard 08 -

Management of Water Resources, defining the good practices applied to water management in forestry activities. This set of good

practices is applied in the areas of protection, rehabilitation and maintenance. Its scope includes own operations in Portugal and

Spain, covering local communities and relevant State authorities.

We recognise that certain regions where we operate face challenges related to water stress. In accordance with the WRI

Aqueduct Tool (August 2024 version) the industrial complexes in Aveiro, Figueira da Foz, Setúbal and Ejea (Spain) are located in

drainage basins with a level of water stress equal to or higher than 40% [E3.13] [E3.AR28]. The Industrial Complex in Vila Velha

de Ródão and the five tissue converting plants in the United Kingdom are located in drainage basins with a level of water stress of

less than 20% Navigator has clearly accepted a commitment to contribute to studying and maintaining the ecological

requirements of the drainage basins in which it operates, especially in those presenting water stress, acting in close cooperation

with the Authorities and local Communities. [E3.11] [ESRS 2.65 a] [E3.AR17] [E3.12c]

The following information is incorporated by reference to other parts of the Non-Financial Statement (MDR-P, ESRS 2, §65

a/b/c/d/f):

• Presentation of Environmental Policy: Chap. 5.2.2

• Presentation of Management Systems Policy: Chap. 5.2.5

• Presentation of Forestry Policy: Chap. 5.2.6

5.2.3.2.2. Actions and resources related to water and marine resources (E3-2, MDR-A)

Water is a resourced used throughout Navigator's value chain, from forestry production through to the end product. At the

different stages of our industrial processes, where the materiality of impact is most significant, water is used in steam production,

transport of materials, cooling systems and other areas The water used is predominantly obtained through surface and

underground intakes, and there are only occasional cases where it is obtained from the municipal water network. As a shared

resource, it is especially important to use water efficiently, in order to minimise the impact on the water environments in which we

operate. Our water intakes are licensed by the National Water Resources Authority, and water is withdrawn in strict compliance

with the upper limits authorised.

In this context, Navigator has since 2017 implemented the PRWU (Programme for Reducing Water Use) in its operations. the aim

of which is a 33% reduction in specific use of water by 2030, in relation to 2019. This programme includes a set of initiatives for

optimising processes, such as recovery of water from industrial processes, recirculation of filtered water and closed washing

circuits, thereby reducing withdrawal of fresh water. In 2024, around 14 strategic initiatives were concluded under the PRWU,

representing a potential annual reduction of approximately 2.4 million m

of water. In Aveiro, among other measures, Navigator

upgraded the vacuum circuit in the production of unbleached pulp, with reuse of hot water in the showers of the pulp drying

machines. At the pulp mills in Figueira da Foz and Setúbal, it was possible to implement measures to reuse secondary

condensates from evaporation. In transferring slurry pulp to paper machine 4 in Setúbal, reuse of clarified water has made it

possible to make significant reductions to water use, with an estimate annual potential of approximately 450 thousand m

water. [E3.18b] [E3.18c]

The installation of an ultrafiltration system with Membrane Bioreactors (MBRs) at WWTP no. 2 in Setúbal, a project funded by

the RRP and concluded in 2023, made it possible in 2024 to achieve a reduction of more than 80% in the organic load of the

processed effluent (measured in mgCQO/l treated effluent), when compared with pre-product levels. This significant improvement

in management of the WWTP has resulted in an opportunity to reuse the effluent generated in industrial processes, in keeping

with a circular approach to the use of resources. In 2023, still at the trial stage, it was possible to use approximately 720 m

/day

ANNUAL REPORT 2024 • MANAGEMENT REPORT 185

of treated effluent in the water circuit of paper machine no. 3, and this is expected to increase in the years ahead, as new

opportunities are identified. Alongside this initiative the multidisciplinary PRWU team will continue to identify and implement

further measures to optimise water use in the years ahead, with a focus on reusing and streamlining the use of this resource at

the stages of pulp bleaching, pulp drying and pulp transfer to the paper machines. [ESRS 2.68] [ESRS 2.69]

In addition to the steps take in an industrial setting, we apply good management practices for water resources in forestry sectors,

through measures for protection, rehabilitation and maintenance, ensuring that ecosystems are preserved, as well as the quality

of the water in our operations [E3.18d]. Up to 2024, 2813 hectares were identified as priority areas for protection and sustainable

management of water resources in Portugal and 27 hectares in Spain. In Mozambique, the action taken focuses on assessing

water quality in drainage basins, and no significant negative impacts have been identified in basins with an occupation rate of

more than 15%.

The most significant CapEx projects have included: the WURP, with CapEx of 3.6 M€ (Aveiro, Figueira da Foz and Setúbal); and

direct reuse of treated effluent from WWTP 2 in Setúbal, with a CapEx of 0.2M€. The relationship between the current financial

resources allocated to these actions or action plans and the most significant figures in the financial statements can be consulted in

the chapter on the financial statements. [ESRS 2.69b]

Main actions Status Scope of action Time horizon Results

[ESRS 2.68a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68 a

ESRS 2.68e]

WURP Aveiro Executed Own operations, Aveiro 2022-2024

Reduction of water use by 85 000

m³/year

WURP Figueira da Foz Executed

Own operations, Figueira

da Foz

2022-2024

Reduction of water use by 950 000

m³/year

WURP Setúbal Executed Own operations, Setúbal 2022-2024

Reduction of water use by 1 400 000

m³/year

Direct reuse of effluent

from WWTP 2 in Setúbal

Planned Own operations, Setúbal 2025 Reuse of 500 000 m

/year

Note 1: WURP - Water Use Reduce Programme. The measures reported were concluded in 2024. CapEx executed during the period 2022-2024. Estimated

outcomes associated with the measures on the basis of 1 full year of operation.

Note 2: For further information on CapEx - Nos. 3.2, 3.3 of 3.6 the Notes to Navigator's Consolidated Financial Statements.

Remediation of impacts

We implement various measures to prevent, mitigating and offset the environmental impacts of our operations. As examples, we

may cite our collaboration with scientific Institutions and local Authorities in order to reduce the environmental effects of our

authorities and to minimise the risks for neighbouring Communities. In Aveiro, management and monitoring of salinity levels in

Rio Novo do Príncipe, by constructing a temporary water covering structure in the summer months, enables us to ensure the

quality of the water needed for industrial operations, and also for farming by local Communities. In Figueira da Foz, Navigator

operates and maintains the water supply canal to the plant, which also supplies irrigation water to farmed in the Lower Mondego

area. In Setúbal, we have implemented a plan for management of water withdrawal from the Mitrena peninsula aquifer, in order

to monitor and mitigate the impacts of salination of the water body. [ESRS 2.68d]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 186

5.2.3.3. Targets and metrics

5.2.3.3.1. Targets related to water and marine resources (E3-3, MDR-T)

Our commitment to responsible management of water resources considers the quantity withdrawn, but also the quality of the

water discharged, as materialised through three targets in our 2030 Roadmap. [ESRS 2.80c] These are aligned with our 2030

Agenda and the Sustainable Development Goals (SDGs), Specifically SDG 6 (Clean Water and Sanitation), SDG 9 (Industry,

Innovation and Infrastructure) and SDG 12 (Sustainable Consumption and Production). [ESRS 2.80f]

Note 1: the method for calculating metrics is unchanged from the previous year [ESRS 2.13], and no prior period errors were identified for the first two targets; in the case

of the 3

target, this is the first reporting year [ESRS 2.14]. These metrics are subject to external verification in connection with this report, and are not verified by other

entities [ESRS 2.77 b]. No interim targets were developed [ESRS 2.80e].

The first two targets are associated with the Management Systems Policy, in mitigating and minimising the environmental impacts

of the Company’s activities, aligned with the requirements of the Environmental Management System under ISO 14001. These are

also associated with the Environmental Policy, in promoting reduction of water use in industrial processes and minimisation of

environmental impacts resulting from industrial effluents in natural water courses, implementing, whenever possible, the best

available techniques (BATs), in particular in reuse processes and closed circuits, as well as removal and treatment of pollutants.

Target 3 is likewise related to the Environmental Policy. [ESRS 2.80a]

The targets for reduction of specific water use and of the organic load in Navigator’s industrial effluents were established

considering the local and global context in which the Company operates, addressing its own industrial operations in Portugal,

Goal and target Baseline

Associated

metric

2022

Performance

2023

Performance

2024

Performance

Results

to achieve

[ESRS 2.80]

[ESRS 2.80d]

[ESRS 2.75

ESRS 2.80b]

[ESRS 2.80J]

[ESRS 2.68J]

[ESRS 2.80J]

[ESRS 2.80e]

Cut specific use of

water by at least 33%

by 2030

(Applies to own

industrial operations

in Portugal)

Benchmark

value:

22.4 m

Baseline:

2019

m³ of water per

ton of output

Reduction

of 14.7%.

(19.1 m

/t)

Reduction of 5.1%.

(21.2 m

/t)

Reduction of 8.5%.

(20.5 m

/t)

15.1 m

Year: 2030

Reduce by 10% the

organic load in

Navigator's industrial

effluents by 2030, in

relation to 2022

(Applies to own

industrial operations

in Portugal)

Benchmark

value:

4.6 kgCQO/t

Baseline:

2022

kgCQO/ton of

output

(4.6 kgCQO/t)

Increase of 2%

(4.6 kgCQO/t)

Increase of 12%

(5.1 kgCQO/t)

4.1 kgCQO/t

Year: 2030

Study the potential for

reducing water

consumption at the

Espirra nurseries with a

reduction of at least

10%/year in water use

up to 2030.

(Applies to own

forestry operations

in Portugal)

Benchmark

value:

363,756

/year

Baseline:

2022

water

Reduction of 15%

(310,100 m3/year in

relation to 2022)

Reduced by 7%

(288,279 m

/year

310,100 m

vs.

288,279 m

relation to 2022)

260,000 m

/year

Year: 2030

ANNUAL REPORT 2024 • MANAGEMENT REPORT 187

where the materiality of impact on water is most significant, and are not science-based [ESRS 2.80c | ESRS 2.80g | ESRS 2.80f].

They are related to management of water resources and reduction of water consumption. Internal Stakeholders were involved in

setting them, through the different forums and procedures for dialogue with external Stakeholders, in particular the

Environmental Board, the Community Monitoring Committees and the Sustainability Forum, seeking to ensure transparency and

alignment with the expectations of the Communities, Authorities and Experts. [ESRS 2.80h]

The target for reduction of specific use of water contributes to reducing water withdrawal, as it seeks to scale down the water

intake by optimising industrial processes, reusing internal flows and implementing more efficient technologies [E3.AR23]. It

considers all the water withdrawn,including process water, cooling water and water for steam production. The methodology

established is based on alignment with a sector benchmark, ensuring the strategy of reducing water consumption uses the best

available practices. Historical analysis of the water volumes used at different stages of the process has enabled us to detect critical

consumption points and possible optimisations. The benchmark year has been set as 2019, which was representative of normal

operation of the mills. [ESRS 2.80f]

The measures that Navigator has implemented with regard to use of water resources are helping the Company achieve the target

of a 33% reduction in specific water use. In 2024, in the industrial operations in Portugal, specific water use stood at 20.5 m

/t,

approximately 8.5% lower than in the baseline year (22.4 m

/t). In absolute terms, total water withdrawal was approximately

11.6% lower than in 2019, down by approximately 8 hm

, equivalent to 1.5 months of mill operations in Portugal. [ESRS 2.80j]

The Company operates in regions with water pressure and has implemented measures to reduce the organic load in its

effluents, such as MBR ultrafiltration at the Setúbal WWTP and oxygen delignification at the pulp mills, ensuring compliance with

the Emission Limit Values (ELVs). Established in 2023, these are based on an integrated strategy, considering European

guidelines, including the Industrial Emissions Directive. They consider the organic load, measured in kg of chemical oxygen

demand in the treated effluents at Navigator’s own WWTPs on its industrial complexes. Continuous monitoring ensured progress is

assessed and measures adjusted, as necessary. In order to reduce water use, the Company has adopted reuse of internal flows,

taking advantage of condensates and optimising industrial processes, so as to minimise withdrawal in areas where water is most

scarce. Identification of strategic investment projects, such as installation of ultrafiltration systems at WWTPs and oxygen

delignification at pulp mills will enable Navigator to achieve its target, helping to significantly reduce the pollutants discharged.

[E3.23 | [ESRS 2.80f]

In relation to the target for reducing the organic load in industrial effluents, there was an increase of 12% in relation to the

baseline year (5.1 kgCQO/t as compared to 4.6 kgCQO/t), impacted by operational problems at the pulp mills and the Figueira

and Setúbal WWTPs. [ESRS 2.80j]

The target of studying the potential for water reduction and consumption at nurseries is being met by a study to assess

the potential for cutting water consumption at the Espirra Nursery, with the aim of promoting responsible management of this

natural resource in an area identified as under water stress, according to the WRI tool [E3.23]. The strategy is based on full

implementation of drip irrigation in the nursery, minimising water losses and cutting consumption, as well on continuous

monitoring and control of the irrigation system [ESRS 2.80f | ESRS 2.80c | ESRS 2.80g]. In 2024, there was a reduction of 21%

in relation to the baseline year and of 7% in comparison with 2023. These results reflect the effectiveness of the actions and

measures implemented to achieve the established objective. [ESRS 2.80j]

We have based water management on a climate risk analysis, aligned with the recommendations of the Task Force on Climate-

related Financial Disclosures (TCFD). The focus is on the availability and quality of water in the drainage basins in which we

operate, considering the physical risks, such as water stress and drought, and transition risks, including regulatory changes and

stricter environmental requirements. Navigator’s Enterprise Risk Management (ERM) system includes assessment of these risks

and implementation of mitigation measures, with a direct impact of business continuity and resilience. [ESRS 2.80f]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 188

Metrics (E3-4, MDR-M)

5.2.3.3.2. Total water consumption (E3-4)

Water withdrawal (million m

)

2024

[E3.28a]

Aveiro (Portugal)

12.5

[E3.28a]

Vila Velha de Ródão (Portugal)

0.7

[E3.28a]

Figueira da Foz (Portugal)

22.5

[E3.28a]

Setúbal (Portugal)

24.9

[E3.28a]

Ejea (Spain)

0.2

[E3.28a]

Forestry Operations - Portugal and Spain

2.1

[E3.28a]

Forestry Operations - Mozambique

0.1

[E3.28a]

Other (Portugal)

0.04

[E3.28a]

Total

63.0

[E3.AR32]

[E3.28b]

Total in areas of water stress 61.9

Note 1: The data on water withdrawal in Aveiro, Ródão, Figueira, Setúbal and Ejea and locations in the forestry sector in Portugal and Spain is obtained

exclusively through direct measurement, which accounts for 100% of the information source. In the case of the forestry sector in Mozambique, 99.8% of the

data is from direct measurement, whilst 0.2% is from extrapolations. Informaiton on data quality is not available for the United Kingdom [E3.AR29].

Note 2: Areas with high water stress are deemed to be regions where the percentage of total water withdrawn is high (40-80%) or extremely high (over

80%) in the Aqueduct Water Risk Atlas tool of the World Resources Institute (WRI).

Note 3: In industrial activities, Navigator uses flow meters calibrated in accordance with validated standard methodologies. Figures are reported to the relevant

Authorities. [E3.28e]

Note 4: In forestry activities, flow meters are used at each borehole and there is an annual analysis for each borehole. [E3.28e]

Note 5: Total water withdrawal is calculated by considering two components: forestry consumption and consumption in infrastructures. Water consumption in

forests includes the water used in producing plants, measured using meters, and an estimate of consumption per plant planted or replanted, assuming 2.1

waterings per plant, with 5 litres of water each time, for a total area of 47.82 hectares. Water consumption in infrastructures corrresponds to the use of offices,

and is measured by meters and aligned with billing data. It is assumed that all the water withdrawn is consumed, consider 0% losses, as there is no

measurement system for assessing waste.

Note 6: The figure for water withdrawal in the United Kingdom was not reported, as the group of industrial complexes was acquired in 2024.

Water intensity (m

/M€)

2024

[E3.29]

Total water withdrawal (hm

)

63.0

[E3.29]

Turnover (million euros)

2 088

[E3.29]

Water intensity (m

/M€)

30 184

Note 1: The calculation of water intensity considers the total volume of water withdrawn and total consolidated turnover.

5.2.3.3.3. Anticipated financial effects from water and marine resources-related impacts, risks and

opportunities (E3-5)

The following information is incorporated by reference to other parts of the Non-Financial Statement: description, quantification,

time horizons and assumptions for anticipated financial effects related to water scarcity risk [E3.33a | E3.33b | E3.33c] – Chap.

5.2.2 Climate Change (E1) (ESRS 2 SBM-3\Results of Analysis of Resilience and Impact of Climate Scenarios). In accordance with

Appendix C of ESRS 1, Navigator has opted not to report the remaining information in the first year of presenting its non-financial

statement.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 189

5.2.4. ESRS E4: Biodiversity and ecosystems

5.2.4.1. Strategy

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

(ESRS 2 SBM-3)

Description

Impact, Risk

Opportunity

Time horizon

Location in

value chain

Related sub-

topic or sub-

sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

Activities of suppliers of materials and

services in the value chain may cause

biodiversity loss.

Negative

impact

- Amount

Size of

species

population

Impact on species with threatened status

due to degradation of ecosystems caused

by upstream activities.

Negative

impact

Own operations

and upstream

Global risk of

species

extinction

Exploitation and/or mismanagement of

natural resources by Suppliers may lead

to an impact on ecosystem services.

Negative

impact

- Amount

Impacts and

dependencies

on ecosystem

services

Advancing habitat preservation and

restoration, in conservation interest

areas, contributing to the protection and

recovery of biodiversity and to resilience

in the face of climate change~.

Positive

impact

- Own operations

Size of

species

population

Implementation of programmes and/or

projects for restoration, conservation or

direct or indirect protection of important

ecosystems or habitats with external

entities.

Positive

impact

- Own operations

Impacts and

dependencies

on ecosystem

services

Exploitation and/or mismanagement of

natural resources by the Company may

lead to a negative impact on ecosystem

services.

Negative

impact

Own operations

Impacts and

dependencies

on ecosystem

services

Development of partnerships with

academe and/or other entities in

conducting scientific studies may

contribute to advancing and conserving

biodiversity and to restoration

methodologies.

Positive

impact

Own operations

Factors with

direct impact on

biodiversity loss

Variations in rainfall patterns, high

temperatures, extreme weather events,

droughts, forest fires, diseases and pests,

and water availability may have a

negative impact on business through

biodiversity loss, species distribution and

abundance and ecosystem resilience, with

consequent reduction of productivity, less

access to raw materials and increased

operating costs

Risk

Medium term - From reporting

year and up to 5 years

Own operations

and upstream

Climate change

Contribution to reduction in no./intensity

of forest fires through programmes

and/or projects, reducing financial losses

and positively impacting the social license

to operate.

Opportunity

Short term - Reporting year

Own operations

Factors with

direct impact on

biodiversity loss

NOTES: The material impacts identified are actual, and so there is no associated time horizon. The double materiality assessment did not point to an material

negative impact with regard to degradation, desertification or impermeabilisation of soils. [E4.16b]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 190

Navigator manages approximately 109 thousand hectares of woodlands in mainland Portugal, including production

forests, and areas given over to conservation of relevant wildlife - Conservation Interest Zones (CIZs). All our woodlands

in mainland Portugal are certified under the FSC

system (license no. FSC

-C010852), since 2007, and the PEFC system

(licenses no. PEFC/13-23-001), since 2009. This is an activity considered eligible by the taxonomy. [E4.16a]

We should stress that 35% of these forest holdings intersect with classified areas, such as the National Network of

Protected Areas (RNAP) and the Natura 2000 Network (RN2000) – Special Conservation Zones and Special Protection Zones –,

RAMSAR sites (Wetlands of International Importance) and the UNESCO Biosphere Reserve. It should also be noted that 64.7% of

the forest holdings that intersect with sensitive areas is given over to eucalyptus production. [E4.16a]

In the holdings under out management, in mainland Portugal, the CIZs are areas that we manage with conservation aims, serving

as an important habitat for a diverse range of flora and fauna, including species with different conservation and protection

statuses, and endemic species. Within these zones, the High Conservation Value Areas (HCVAs), an exclusive FSC

certification

concept, are the most relevant, in view of the presence of environmental, social and cultural heritage elements of exceptional

value, which are thereby safeguarded.

In Galicia (Spain) we manage 1 111 hectares of forest and 28% of these holdings lies within sensitive areas (mostly

in the Biosphere Reserve), and 82.2% of this area is given over to eucalyptus production. [E4.16a]

In Mozambique we manage approximately 26 932

hectares, with no operations in sensitive or classified areas. [E4.16a]

We have a Forest Management Plant (FMP) for our own and rented holdings with regard to out operations in mainland

Portugal; this plan complies with the requirements transposed in the technical standards of the Institute of Nature Conservation

and Forests, established by ministerial order on the basis of Decree-Law 15/2009. This includes the Biodiversity Conservation

Programmes (BCPs), for our forestry holdings that overlaps with areas designated for nature conservation or biodiversity, in

connection with RN2000 and the RNAP. The aim of these programmes is to ensure that the interventions proposed in the FMP are

compatible with and contribute to conservation of protected species and habitats, where their favourable status depends on forest

management. These programmes take into consideration the applicable provisions of the RN2000 Sectorial Plan and other

relevant plans and regulations (e.g. management plans or regulations for protected areas and for territorial planning). [E4.16a]

In Mozambique, we have a specific Forest Management Plan (FMP), still without all the information in the FMP for Portugal

and without the framework of local standards, given that these do not exist. This guidance document is aligned with forest

certification standards, characterising the physical environment, the socio-economic environment and the Company’s actions in

areas under management. As well as structuring the management of forestry assets, it provides an integrated overview of the

Company’s approach, offering an understanding of the overall approach and contributing to improved individual and

organisational performance. [E4.16a]

In Galicia (Spain), checklists of requirements are drawn up, which are given to Service providers, setting out the constraints

needed to prevent or mitigate potential negative impacts from operations, including those which affect biodiversity and

ecosystem services. Whenever necessary and applicable, environmental impact studies are carried out and local Stakeholders

are consulted, along with the relevant authorities. Each area operation plan is subject to a specific assessment process.

[E4.16a]

It is important to note that, although Navigator's operations affect some threatened species, this impact has been mitigated. The

Sustainable Forest Management system (Chap. 5.2.6.2.1) includes detailed matrices for assessing environmental and

social impacts, providing for integrated mitigation measures. [E4.16c]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 191

5.2.4.1.2. Transition plan for biodiversity and ecosystem conservation (E4-1)

Since 2008, our business strategy has been built into out forest management model, and is key to business resilience.

This strategy is based on assessment of wildlife and the impacts of our operations, on collaboration with Experts and local

Communities, on monitoring of biodiversity and ecosystems, and also on gathering information on species and habitats, for

mapping and conservation.

In planning and executing our activities, we seek to balance productivity, resource conservation and the well-being of

Communities. To this end, we identify natural, landscape, heritage and socio-cultural resources, ensuring they are preserved and

improved. Prior assessment of the environmental and social impacts and the risks associated with our operations is an

essential practise, enabling us to adopt more responsible management.

The evolution of this strategy seeks to respond to the challenges imposed by international initiatives, such as the EU 2030

Biodiversity Strategy, COP15 and the Kunming-Montreal Agreement, as well as ESG requirements and the Nature

Restoration Law, and to align the governance strategy for biodiversity, aims and endeavours with the regulatory and social

requirements, especially in reporting and certification.

In order to strengthen biodiversity conservation, we have developed targets for 2030 and 2050 (see section “Targets and

metrics” and Chap. 3.4.4), including the statement of positive biodiversity impacts and creation of biodiversity

credits, in partnership with Academe. Alongside this, we have invested in internal training on biodiversity, ecosystem services

and restoration, ensuring improved Employee expertise.

We take an active part in designing environmental policies through discussion forums.

Assessment of direct and indirect impacts, risks and dependencies on biodiversity and ecosystem services is a priority. We

maintain certification of responsible forest management and regularly review our practises so as to minimise negative

impacts, especially in high conservation value areas.

In Mozambique, we invest in raising environmental awareness, development of technology for monitoring soils and

water resources and in partnerships with organisations such as the Wildlife Conservation Society (WCS) and Biofund.

We also implement an Action Plan for Biodiversity and a Social Development Programme (Chap. 5.3.3), focused on

improving food security, increasing incomes and community welfare, and thereby reducing the pressure on natural resources.

With this integrated approach, we have stepped up our commitment to biodiversity conservation and sustainable development,

contributing to ecological regeneration and improvement of the ecosystems in which we operate. [ESRSE4-1.13]

5.2.4.2. Management of impacts, risks and opportunities

5.2.4.2.1. Policies related to biodiversity and ecosystem conservation (E4-2, MDR-P)

The Company’s policies and strategies reflect a wide-ranging commitment to sustainability and a response to biodiversity and

ecosystem conservation. The Environmental Policy and Forestry Policies focus on promoting responsible management of

our plantations and agro-forestry holdings, with the aim of producing tangible and intangible goods, with respect for

conservation of wildlife and socio-cultural assets. Together, through carbon sequestration and storage, in forests and in the

resulting raw materials and products, the plantations and agro-forestry holdings we manage contribute to a circular

bioeconomy and perform an important role in mitigating the effects of climate change, in alignment with the Sustainable

Development Goals - most notably SDGs 15, 2 and 6 (Chap. 5.2.2). Reflecting our commitments, we were among the initial

signatories to the act4nature Portugal initiative, promoted by BCSD Portugal (see sections on actions and targets). [ESRS

2.65a | E4-2_AR13]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 192

Our various commitments include the Environmental Policy, which deals with promoting sustainable forest management, and

conservation of biodiversity and ecosystem services as an integral part of our forest management model (Chap. 5.2.6). It also

establishes commitments relating to climate change and sequestering CO

– an important driver of biodiversity loss - and energy

management (Chap. 5.2.2), water management (Chap. 5.2.3), raw materials and the circular economy (Chap. 5.2.5). [ESRS

2.65a| E4-23a | E4-2_AR4]

The Forestry Policy stresses our aware of the importance of our assets and adoption of a forest management model that seeks

to contribute to maintaining and continuously improving the economic, ecological and social functions of forested areas, both at

the level of individual woodlands, and at the forest landscape scale, embracing a long-term commitment to: The commitments

established, directly related to biodiversity and ecosystems conservation, include the following [ESRS 2.65a | E4-23a | E4-2_AR4

| E4-24a/b/d]:

• To make an active contribution to countering illegal logging and to controlling the origin of the wood it

purchases.

• To maintain and improve responsible management of woodlands, in a balance with their natural and social surroundings,

developing and promoting actions, including with third parties, that ensure that deforestation or degradation are

avoided and/or that forests are conserved.

• To develop and promote the concept of forest plantations which, thanks to the way they are managed, can make a

positive contribution to preserving the integrity of ecosystems and protecting high conservation values, assuring

effective processes for Stakeholder participation and fostering economic growth and job creation

• To implement a forest management model for which the good practices are documented in a Forest Management

System, and informed by expertise obtained through Research and Development, as well as including measures to

mitigate potential environmental and social impacts.

• To keep conservation of biodiversity and ecosystem services as an integral part of the forest management model,

seeking to ensure that the planning and execution of forestry activities results in, at least, maintaining the biodiversity

values on our holdings (”no net loss”) or implementing initiatives, such as restoration, that lead to a biodiversity

gain (“net positive gain”),

• To promote adoption of best practices by Suppliers and encourage them to operate in keeping with the guiding

principles of responsible forest management, through support, by transferring know-how, monitoring and sharing

experiences.

• To maintain a proactive attitude in relation to other entities in the forestry sector, such as Landowners, Forestry

producers and other Stakeholders, including Suppliers of raw materials, developing strategic partnerships and working

actively to improvement the overall performance and competitiveness of forests and fostering initiatives for forest

certification, as a way of promoting responsible management, and also of countering the factors that lead to

deforestation, forest degradation and/or conversion of natural ecosystems.

The Mozambique Forestry Policy

also addresses our role as an agent of economic and social development, with the aim of

establishing forest plantations and promoting the creation of agro-forestry areas, conciliating the production of goods

with conservation of natural resources and responsible action in relation to the families and communities living in our project

areas(Cap. 5.2.6). [ESRS 2.65a | E4-24b]

The guidelines stemming from our Environmental and Forestry Policies are set out in key documents of the Forest Management

System, in particular the Company’s Technical Standards, the Biodiversity Assessment Techniques Manuals (BATMs) and

the Conservation Action Plans (CAPs).

These policies are directly linked to mitigation of impact factors that contribute to biodiversity loss and to the IROs

identified in the double materiality analysis, covering not only the impacts related to biodiversity and ecosystems, but also

dependency on ecosystem services, physical risks, traceability of the source of wood from the supplier chain, among other things

[E4-23a/b/c/d/e | E4-2_AR4 ], translated into the targets and actions presented in the following sections.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 193

With forest certification and support for producers (Chap. 5.2.,6), we manage our forest holdings in mainland Portugal in

keeping with the legal requirements applicable to the sector and other regulations and standards to which we have signed up

voluntarily, the pan-European criteria for sustainable forest management, in accordance with Portuguese Standard NP 4406

(Sustainable Forest Management) and the Principles and Criteria of the Forest Stewardship Council

, with which our policies are

aligned. Certified forest management allows us to guarantee that the wood used in our products - pulp and paper - is

obtained from forests managed on a responsible basis. [ESRS 2.65d | E4-2_AR12]

Through our Forestry Policy, we guarantee our commitment that the production, supply and consumption of raw materials

is in line with principles of sustainability and biodiversity protection (Chap. 5.2.6). We limit purchases of wood and fibre to

Supplies who present proof of responsible practices, avoiding negative impacts on protected areas; we require conformity with the

European Timber Regulation (EUTR) and give priority to FSC

e PEFC™ certification, ensuring that natural forests are not

converted and traditional rights are not violated. [E4-23d/e]

We invest continuously in monitoring and assessment, active protection and conservation (such as rehabilitation or

restoration or natural habitats and ecosystems), benefiting species that use them for their ecological functions of feeding, shelter

or breeding. These also serve as ecological corridors, enabling species to disperse naturally and permitting genetic interchange

between populations. [E4.23e]

We are committed to maintaining and disseminating our Forest Management System, establishing and updating strategic goals,

promoting continuous improvement of its effectiveness and ensuring transparency and alignment with sustainability challenges.

[E4-23aiii e AR4]

We have ensured that conservation of biodiversity and ecosystem services is built into our corporate strategy,

aligning it with the most up-to-date scientific knowledge and with voluntarily accepted commitments. In order to systematise and

assess impacts and dependencies on biodiversity, we are designing a simplified framework, inspired by key elements of the

Natural Capital Protocol, in an approach to be tested in a pilot project. [E4.23e]

In addition, we are stepping up training and awareness raising for our Employees, both internal and external, through activities

that address biodiversity conservation and implementation of good corporate practices, ensuring more effective engagement,

aligned with sustainability principles. [E4-2_23] [E4-23e]

The following information is incorporated by reference to other parts of the Non-Financial Statement (MDR-P, ESRS 2, §65

a/b/c/d/f):

• Presentation of Environmental Policy: Chap. 5.2.2

• Presentation of Forestry Policy: Chap. 5.2.6

• Presentation of Portucel Moçambique Forestry Policy: Chap.

5.2.6

• Presentation of Mozambique Social Development Plan: Chap. 5.3.3

5.2.4.2.2. Actions and resources related to biodiversity and ecosystems (E4-3, MDR-A)

Our approach is centred on biodiversity monitoring, and on promoting biodiversity and ecological restoration, with the aim of

maintaining or improving the conservation status of natural and semi-natural habitats, and much of our work in this area is on a

long term basis. This action is part of our integrated and sustainable forest management (Chap. 5.2.6).

In connection with the act4nature Portugal initiative, we have submitted a set of commitments relating to biodiversity and

ecosystem services [E4.23e], which we renewed in 2023 (see section “Targets and metrics”), updating and establishing new

targets, with the ultimate objective of generating a positive impact, or a net gain, in biodiversity. These targets are centred on

implementing annual monitoring plans for species and habitats, as well as work to maintain, improved conservation

status and restore biodiversity and ecosystem services (B&ES) in the forest holdings under our management. This

approach encompasses conservation, rehabilitation and ecological restoration. [E4.23e]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 194

Main actions

Status

Scope of action

Time horizon

Results

[ESRS 2.68a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68 a

ESRS 2.68e]

Zambujo reCover

Executed

and planned

Own operations in

Portugal, Idanha-a-Nova

2022-2050

40 hectares of eucalyptus converted to holm

oak + 70 hectares with work to improve

conservation status of holm oak habitat 9340

hectares Forests of Quercus ilex and Quercus

rotundifolia. Collection of 50 kg of Q.

rotundifolia acorns on Zambujo estate for

germination in nurseries and subsequent

planting on property.

Recovery of the

Monchique oak

Executed and

planned

Own operations,

upstream and

downstream in South-

west Portugal

2023-2030

Molecular studies employed whole-genome

sequencing (WGS) of 80 individuals from

nine populations, followed by bioinformatics

analysis of populations structure. The

findings show a geographical pattern of

hybridisation towards the Monchique core

areas, with the outlying populations in the

Mira and Ribeiras de Aljezur populations

presenting high degree of introgression with

Portuguese oak. However, it was clear that

there were pure individuals, in Monchique

and in the Ribeira do Seixe valleys, evem

when compared with the populations in

southern Spain (Algeciras). Collection of

acorns in turn permitted germination of

around 1558 plants of Q. canariensis, Q.

faginea and Q. lusitanica, from 8 distinct

provenances, and with germination rates

that varied between 20.8% and 87.5%.

These will serve for restoration work and

creation of metacollections in various

botanical gardens and arboretums. In

addition, the grafting process was successful

on to pendunculate oak (Q. robur subsp.

broteroana) rootstock.

ForCe Project – Forest

Certification (FC) in

Eucalyptus Plantations

Executed

and planned

Own operations,

upstream and

downstream in central

Portugal and in Brazil

2022-2026

Final results yet to be determined - Session

for presentation of partial and preliminary

results by Faculty of Science, University of

Lisbon.

Sowing plants to attract

pollinators to the

Espirra Estate

Executed

and planned

Own operations

in Portugal

2023 - 2026

In a 2023 study, the areas seeded presented

a higher number of individuals and nearly

twice as many species as the area not

seeded, indicating that the sowing of forest

species considerably increased biodiversity

at this site.

Inclusion in Network

of Bird Sanctuaries

Planned

Own operations,

upstream and

downstream in Portugal

2025 - 2026

Establish a network of areas throughout

Portugal where birds and their habitats are

protected and monitored, in partnership with

the Landowners, engaging with the general

public and considering both threatened

species and common species. The goal is to

reverse the tendency for reduction in various

species of birds regarded as common, which

has been happening in recent decades, and

at the same time to contribute to

biodiversity conservation, as a whole, and to

raising environmental awareness among the

general public. Specifically: Survey

populations of birds occurring on the Espirra

and Alfebrinho Estate, in line with the

different forms of land use on the property,

establish a management plan, designed to

encourage these populations and regularly

monitor bird populations and the effects of

management actions on the respective

demography and on how they use the

different habitats..

ANNUAL REPORT 2024 • MANAGEMENT REPORT 195

Main actions

Status

Scope of action

Time horizon

Results

[ESRS 2.68a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68 a

ESRS 2.68e]

Annual plan

for monitoring and

assessment of impacts

prior to each forestry

operation.

Executed

and planned

Own operations

in Iberian Peninsula

and in Mozambique

Ongoing

Experts are hired to help with the monitoring

and the findings enable us to make

adjustments from time to time in the

conservation measures and strategies to be

adopted in the following year. In 2024,

monitoring (of flora, fauna and vegetation)

was carried out by experts on 19 properties

throughout mainland Portugal and 7 nesting

sites for threatened species were monitored.

Forest restoration pilot

programmes

Executed

and planned

Own operations

in Mozambique

2023 - 2026

Contracting of areas only and exclusively for

conservation. Identification of costs

associated with restoration. Capacity to

engage with the Community on the goal of

preservation. Engagement and meetings

with potential partners (nursery operators,

acquisition of other experiences in the

region, etc.).

LIFE Serras do Porto

Executed and

planned

Upstream, Own

operations, Downstream,

in Portugal

2022-2027

Navigator Forest Portugal, SA is a partner of

the Parque das Serras project in Porto. In

this project, the Company has approximately

55 ha (total area) to carry out ecological

restoration work on some of its areas within

the Regional Protected Landscape.

Up to 2025, there are plans for 6.34 ha of

infilling (substitution of trees which have not

survived planting) of maritime pine and

arbutus and 1.22 ha of chemical

devitalisation of stumps and manual planting

of arbutus, totalling 7.11 ha (12 % of project

area). In an area of 16.42 ha, coppice shoots

will be cut, with devitalisation of stumps and

manual planting of cork oaks and arbutus

(densification). In addition, felled wood

material is being placed to form a stockade,

and localised undergrowth clearance is being

carried out.

Along the Silveirinhos stream there is an

area of 0.98 ha where acacias are being

manually felled/debarked, making a total of

17.40 ha (31% of project area).

Wildlife was monitored in 2023, and in 2024

we conducted water analyses, in order to

gauge the ecological status of the riverside

gallery forests.

Multi-criterion spatial

analysis, in order to

prioritise areas

for biodiversity

protection

Started, not

concluded

Own operations

in Mozambique

2025

Map and prioritisation of

conservation/protection areas under

Portucel’s management

Map of areas with potential for contracting

(exclusively) for conservation purposes

Scale up partnership with WCS

Alignment of

biodiversity strategy

with TNFD LEAP

approach

Planned

Own operations (Iberian

Peninsula)

2025

It is planned to align strategy for all the

Group’s forestry activities with the LEAP

approach by the end of 2025.

Work currently under way includes: the ForCe project will generate new knowledge for science, which will promote conservation

of vertebrates, sustainability of eucalyptus plantations, attainment of certification and SDG 8, 12 and 15 objectives; and Zambujo

ReCover, network of bird sanctuaries and sowing for insects, which contributes to SDG 15 and, in the case of insects, the 2030

European Biodiversity strategy (decline of pollinators is reversed). [ESRS 2.68a]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 196

The Company’s activities take into account the Habitats and Birds directives. We assess, identify and map the species and habitats

existing and potentially existing in the estates managed. We accordingly adopt measures to conserve species (e.g. when

necessary, adjusting the timing of operations to avoid breeding cycles), when present or potentially present on the land. We

protect Natura 2000 Network habitats, maintaining or improving their state of conservation, when possible (e.g. restoration), as

well as protecting or improving the state of conservation of the habitats of species, such as by creating buffer zones around water

courses.

The fundamental principle of water resource management in forestry operations is to prioritise protection over rehabilitation

(because it is more effective to conserve an existing ecosystem than to artificially reinstate one), thereby reducing the use of

more complex and more expensive interventions. Even so, when a given site is in need of rehabilitation, the objective is for it to

return as close as possible to its natural state, so that it can achieve its potential.

In Mozambique, the biodiversity conservation approach is based on two dimensions: the macro dimension, applying across all

project areas and with broader aims, such as raising community awareness of environmental issues and promoting conservation

farming, as part of the Social Development Programme (Chap. 5.3.3), and a more micro approach, specific to each

conservation/protection block identified. All the relevant actions, teams responsible, monitoring frequencies and other details are

included in an internal document called the Action Plan for Biodiversity (APB) This document includes analyses and innovative

strategies suited to a forest management model, the mosaic model, which is less usual around the world. We have the Wildlife

Conservation Society (WCS) as partner, which has worked with us since 2016 on improving and strengthening the effectiveness of

our conservation approach, which has been achieved through an variety of projects. In addition, we have been training our focal

points in the community - Community Liaison Officers (Chap. 5.3.3) – to use a tool enabling them to survey the fauna and flora in

the location/community in which they live or work. This information will be useful for constructing an internal data base which will

enable us to have more information, and so make for better decisions on where to focus conservation efforts. In late 2024 we

concluded a project designed to identify priority areas for forest protection and restoration, within Portucel's operating areas. This

approach, currently in a digital format, involves compiling indicators and making geographical analyses and is based on multiple

criteria (operational and ecological), in order to define priorities, both in current areas and in areas to be contracted future,

exclusively for conservation purposes.

We continue to run pilot projects for forest restoration, serving for analysis of the best adapted species, survival rates,

maintenance costs, spacing, and other factors.

We work to raise awareness of environmental issues, reaching out to the families and the Communities in the areas where

we operate. In this work, we seek to build know-how and encourage vigilance as to the impact that practices used by the

Community have on natural resources, and we also provide brief practical training activities in more sustainable solutions, using

resources available locally. Likewise, as part of the Food Security pillar in the Social Development Programme (Chap. 5.3.3)

Portucel runs an agricultural extension programme aimed at families, which includes training in conservation farming

techniques, provision of improved seeds and hands-on training in demonstration fields for agricultural crops. These initiatives

enable us to improve community skills and awareness of good practices, promoting more efficient use of the land, making it more

productive, and for longer. In addition, we encourage beekeeping as a source of sustainable income, a safeguard for biodiversity

and a way of protecting critical forest areas, reducing the need for broadcast burns. Alongside this, our teams support families and

communities in creating safe conditions for burns - a deeply rooted practice - ensuring this is done in a controlled fashion, taking

due account of factors such as temperature, humidity, wind and slopes.

We apply the mitigation hierarchy in biodiversity and ecosystem conservation. In Portugal, these practices are integrated

into the forest management model, ensuring protection of biodiversity on the basis of impact assessments, use of Geographical

Information Systems (GIS) and implementation of conservation and ecological restoration plans. The operations are monitored by

internal and external audits, ensuring compliance with FSC

and PEFC standards. In Mozambique, prevention, minimisation and

restoration measures are implemented, in order to reduce the environmental impact of forest operations. These include the

mapping of sensitive areas, maintenance of ecological corridors, protection of critical habitats and limitation of interventions

during nesting seasons. In addition, steps are taken to minimise the fragmentation of ecosystems, so as to reduce pressure on

natural resources and restore degraded areas through reintroduction of native species.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 197

We have adopted sustainable planning which balances production and conservation, in keeping with the precautionary principle

and mitigation of impacts, Environmental assessments include identification of priority conservation areas, where specific

measures are applied to maintain and rehabilitate habitats, such as the creation of protection strips around water courses and

implementation of buffer zones for threatened species. Strategic partnerships are also promoted with Experts and local

Communities in order to strengthen environmental monitoring and implementation of good practices. As a signatory to the

act4nature Portugal initiative, Navigator ubdertakes to integrate biodiversity into its business models and contribute to protection

and recovery of ecosystems by 2030. [E4.28a] [AR19]

Before we start any afforestation or forest activities and in operations to apply plant protection products, we conduct a

comprehensive local assessment, which includes identifying water points, bodies of water, water courses and habitats. Protection

strips are established around water courses in order to reduce disruption to the soil, preserve riparian gallery forests, conserve

habitats and improve water quality. To this end, the forest management practices adopted by the Group divide into two types

(protection/rehabilitation/restoration and maintenance), both based on the precautionary principle. [AR20d]

The Company allocates each year an internal budget to biodiversity conservation, with a view to attaining the aims of our annual

programme for monitoring wildlife, and for developing partnerships on biodiversity conservation, consultancy and training

projects. We also have a budget devoted to habitat maintenance and improvement, rehabilitation and restoration. It may be

noted that the recovery of Quercus canariensis falls within the scope of “Genetic improvement and forestry reproduction activities

- RRP TransForm Agenda Project”, for genetic conservation and ecosystem recovery for Quercus canariensis (Monchique oak), and

is co-funded by this programme. The LIFE Serras do Porto project is also co-funded by Project 101074476 — LIFE21 CCA-PT-LIFE

SERRAS DO PORTO. [ESRS 2.69a]

5.2.4.3. Targets and metrics

5.2.4.3.1. Targets related to biodiversity and ecosystem conservation (E4-4, MDR-T)

In our 2030 Roadmap (Chap. 3.4.4), we have several goals/targets related to biodiversity and ecosystem conservation (indicated

in the table). We have also integrated fire prevention and fire fighting into our forest management strategy, recognising the

impacts, dependencies, risks and opportunities for biodiversity and ecosystems (Chap. 5.2.6), for which we have set a specific

target.

The targets are aligned with targets 2, 4, 10 and 11 of the Kunming-Montreal Global Biodiversity Framework, relevant

aspects of the Eu Biodiversity Strategy for 2030 and other national policies and legislation related to biodiversity and

ecosystems. [E4-32b] They also seek to contribute to some of the SDGs, such as 15 and 17 (see Chap. 3.4.3). [ESRS 2.80f]

The following information is incorporated by reference to other parts of the management report:

• Target “Help reduce rural fires, seeking to ensure that the burned area under Navigator's management stays below 1%

each year”, which, in the mitigation hierarchy, falls under prevention: MDR-T, ESRS 2, §80 – Chap. 5.2.6.3.1

• Performance achieved in 2024, in relation to commitments made by Navigator through the act4nature Portugal initiative:

MDR-T, ESRS 2, §80j – Chap. 9.3

ANNUAL REPORT 2024 • MANAGEMENT REPORT 198

Goal and

target

Mitigation

hierarchy

level

Baseline

Associated

metric

2022

Performance

2023

Performance

2024

Performance

Results to

achieve

[ESRS 2.80]

[E4 32f]

[ESRS 2.80d]

[ESRS 2.75]

[ESRS 2.80b]

[ESRS 2.80J] [ESRS 2.80J] [ESRS 2.80J] [ESRS 2.80e]

Create positive

impact on (or net

gain in)

biodiversity by

taking action in

keeping with

commitments

made by

Navigator through

act4nature

Portugal.

Prevention,

minimisation,

recovery and

rehabilitation

Benchmark

value: Not

applicable

Baseline:

2020

See Progress

Report on Meeting

Act4nature

Portugal

Commitments

2022

(see online

)

See Progress

Report on Meeting

Act4nature

Portugal

Commitments

2023

(see online

)

The results are in

the table Actions

and resources

related to

biodiversity and

ecosystems (E4-

3, MDR-A); see

also chapter 9.3.

Progress Report

on Meeting

Act4nature

Portugal

Commitments

By 2024,

complete the

approach to

integrating

B&ES

conservation

into corporate

strategy, in line

with available

scientific

knowledge and

voluntarily

accepted

commitments;

By 2026, to

establish a

simplified

framework, in

line with the

key elements of

global

benchmark

frameworks,

(e.g. Natural

Capital

Protocol), for

systematic

assessment of

B&ES impacts

and

dependencies,

testing the

approach in a

pilot project.

By 2030:

execute annual

species and

habitat

monitoring

plans and work

to maintain,

improve the

state of

conservation

and restore

B&SE in the

forest holdings

managed by the

Company, in

the following

areas: (i)

conservation;

(ii)

rehabilitation;

and (iii)

ecological

restoration.

By 2030: in the

field of

ecological

restoration,

start and/or

continue work

ANNUAL REPORT 2024 • MANAGEMENT REPORT 199

NOTES: For the first two goals, the geographical scope is mainland Portugal; the others, for which information is available online, include action abroad,

although some of the associated initiatives take place in Portugal [ESRS 2.80c | E4.32d]. The calculation method for goals/metrics is unchanged in relation to

the previous year. [ESRS 2.80i]

The targets established for biodiversity and ecosystem conservation are related to the policies identified and described above, in

the case of creating positive impact (or net gain) in biodiversity, through actions under commitments made by Navigator under

the act4nature Portugal initiative, and there is a direct connection to the Forestry Policy and the Environmental Policy, in which

Goal and

target

Mitigation

hierarchy

level

Baseline

Associated

metric

2022

Performance

2023

Performance

2024

Performance

Results to

achieve

[ESRS 2.80]

[E4 32f]

[ESRS 2.80d]

[ESRS 2.75]

[ESRS 2.80b]

[ESRS 2.80J] [ESRS 2.80J] [ESRS 2.80J] [ESRS 2.80e]

on at least 110

hectares.

By 2030:

continue the

other work to

maintain and

improve state

of conservation

(work on at

least 30

ha/year)

By 2030:

execute at least

one project for

recovery of a

threatened

species and

support

another.

By 2030: run

training

programmes

with content

relating to

B&ES

conservation

topics and raise

awareness of

good business

practices, for

internal and

external

employees.

Year:

2030

Consolidate the

Biodiversity By

The Navigator

Company project

Minimisation Benchmark

value: Not

applicable

Baseline:

2022

Approximately 24

700 social media

followers;

14 299 new

followers

More than 96 000

hits on website;

156 000 website

hits since launch

Approximately

210 online

content items.

By 2025:

Execute 4

partnerships

Baseline: 2022

Interim Target

By 2025: Raise

the profile of

Navigator's

biodiversity

conservation

strategy with

urban adults

and Portuguese

NGOs.

Baseline: 2022

ANNUAL REPORT 2024 • MANAGEMENT REPORT 200

these targets are embraced by Navigator [ESRS 2.80a | ESRS 2.80f]. In the case of commitments made to Act4Nature, it should

be stressed that these were analysed by the Advisory Board of BCSD Portugal [ESRS 2.80h]. The target for the Biodiversity By

The Navigator Company project was set with through continuous engagement, over the years, with various Stakeholder groups in

the forest sector and local Communities. [ESRS 2.80h]

5.2.4.3.2. Impact metrics related to biodiversity and ecosystem conservation (E4-5, MDR-M)

Owned, rented or managed sites within or in the

vicinity of protected areas of key biodiversity zones

[E4_35]

Number (sites)

383

Area (hectares)

37 901.00

In Mozambique, there are no areas where work has been done in or in the vicinity of protected areas, of key biodiversity zones

In addition, entity-specific metrics are reported. The following data has been audited in the annual audit of compliance with

responsible forest management standards. [ESRS 2.77b]

Name

Performance 2024

Total hectares, not owned, rented or managed, restored or conserved, in

mainland Portugal

123.54 ha

% of total owned, managed or rented area set aside for restoration or

conservation, in mainland Portugal

11.8%

% of total owned, managed or rented area set aside for restoration and

conservation, in mainland Portugal

1.8%

No. species of fauna and flora, in mainland Portugal

268 species of fauna

1 195 species of flora

No. red list species identified, in mainland Portugal (GRI 304-4)

5 are classified as Critically Endangered, 17 as Endangered, 46

as Vulnerable and 30 as Near-threatened, using the

classification of the International Union for Conservation of

Nature.

Habitats protected or reclaimed (ha)

Protected habitats (ha): 4 474

Reclaimed habitats (ha): 123

Location in or close to protected areas and areas with high biodiversity

index

National Network of Protected Areas (RNAP)

Hectares: 7 608

% of total holdings managed: 7.0

Sites classified in the Natura 2000 Network

Hectares: 26 996

% of total holdings managed: 24.8

ANNUAL REPORT 2024 • MANAGEMENT REPORT 201

Special Protection Zones (ZPE) in the Natura 2000 Network

Hectares: 20 359

% of total holdings managed: 18.7

Methodological notes [ESRS 2.77a]:

• The 1

metric results from the sum of hectares in the plot where ecological rehabilitation and restoration work is carried

out (maintenance and upgrading of habitat conservation status), and the information on execution in the field if

confirmed by the Forestry Production and Operations Department in the Forest Management System (INFLOR).

• In the 2

, 3

, 6

and 7

metrics, the percentages and hectares of classified or protected areas are taken from SIG data

bases, which contain the area effectively managed by the Company, up to 31 December 2024. In particular, the CIZs

are catalogued in the SIG data base, in the table of attributes, making it possible to calculate this area in relation to the

total area. Forest management certification requires a minimum of 10% CIZs.

• In the case of the species identified (4

and 5

metrics), species of fauna are mapped in SIG (Geographical Information

Systems) by property where they have been identified, by experts, and catalogued in accordance with their threatened

status; the same for threatened flora. The calculation is made on the basis of the species existing on the properties

under management, up to 31 December 2024. It refers only to native fauna and flora.

5.2.4.3.3. Anticipated financial effects from important biodiversity and ecosystems-related risks and

opportunities (E4-6)

The Navigator Group is still assessing the anticipated financial effects of the material risks and opportunities related to biodiversity

and ecosystems, and for this reason, and in accordance with Appendix C to ESRS 1, Navigator has opted not to report information

in the first year of preparing its Non-Financial Statement. [E4.45abc]

5.2.5. ESRS E5: Use of resources and circular economy

5.2.5.1. Strategy

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

(SBM-3)

Description

Impacts, risk or

Opportunity

Time horizon Location in value chain

Related sub-topic or

sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

Use of raw materials from

renewable resources.

Positive impact -- Own operations

Inflows of resources,

including use of resources

Reuse of waste/by-

products.

Positive impact -- Own operations Waste

Creation of industrial

symbioses in

materials flow

Positive impact -- Downstream Waste

ANNUAL REPORT 2024 • MANAGEMENT REPORT 202

Description

Impacts, risk or

Opportunity

Time horizon Location in value chain

Related sub-topic or

sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

UWF products sold to

Clients and Users are

designed with a view to a

long life or a circular life

cycle, helping to ensure

that less waste ends up in

landfill.

Positive impact -- Downstream

Outflows of resources

related to products and

services

Products sold to

Customers have high

recyclability rates.

Positive impact -- Downstream

Outflows of resources

related to products and

services

Building stronger

competitive position as a

response to the preferences

of Clients and End

consumers for circular, low

carbon products with a high

recycling rate.

Opportunity

Medium term - From

reporting year and

up to 5 years

Downstream

Outflows of resources

related to products and

services

Implement practices for

reuse of materials, in order

to reduce costs and

dependence on virgin

resources, differentiate the

company in the

marketplace and

strengthen its image as a

leader in sustainability.

Opportunity

Short term -

Reporting year

Own operations Waste

Difficulty in sourcing raw

materials (e.g. chemicals;

sands; alternative raw

materials) due to

disruptions in logistical

chains (e.g. geopolitical

conflict, strikes, etc.).

Risk

Medium term - From

reporting year and

up to 5 years

Amount

Inflows of resources,

including use of resources

Less wood available for

pulp production due to

competition for this raw

material from other uses

(e.g. burning for energy

production).

Risk

Medium term - From

reporting year and

up to 5 years

Amount

Inflows of resources,

including use of resources

Loss of production forest

due to competition for land

use (e.g. installation of

solar panels rather than

production forests).

Risk

Medium term - From

reporting year and

up to 5 years

Amount

Inflows of resources,

including use of resources

NOTES: The material impacts identified are actual, and so there is no associated time horizon.

5.2.5.2. Management of impacts, risks and opportunities

5.2.5.2.1. Policies related to resource use and circular economy (E5-1, MDR-P)

We have several policies which structure our approach to the use of resources and the circular economy, and which ensure a

responsible development model, promoting substitution of virgin raw materials with renewable materials and sustainable sources

of supply [E5-1.15] The most important of these are the Environmental Policy and the Management Systems Policy. These

policies are complemented by procedures for managing environmental issues (PG80) and waste management (PG27) [E5-1.14].

In order to ensure compliance with best environmental practices, the Company has adopted recognised standards, including ISO

14001, and conforms to the legal requirements at national and European level. Attention is also drawn to ISO 9706, which

guarantees that paper does not lose its properties over 100 years (on display) or 200 years (in dark storage). [ESRS 2.65d]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 203

The Company’s Environmental Policy lays down Navigator's general commitments in relation to environmental matters,

establishing guidelines for sustainable operations. In connection with the circular economy, the Company is committed to: (1)

promoting the circular bioeconomy, reusing waste and by-products from processes within a logic of industrial symbiosis and

incorporating them in new applications and products; (2) using ecodesign both in products such as packaging, selecting more

sustainable materials and ensuring they are recyclable and, whenever possible, biodegradable; (3) actively encouraging

Consumers to recycle its products, through dedicated messaging and campaigns. The Environmental Policy also underlines the

need to: demonstrate the sustainable origin of wood, giving priority to certified sources and promoting use of renewable

materials, as well as product recyclability; develop and apply solutions which make for more efficiency in using wood in the

industrial process; whenever technical and economically viable, replace hazardous chemicals with non-hazardous products, in

keeping with best available techniques. [ESRS 2.65a]

In our Management Systems Policy, we commit ourselves to mitigating and minimising the environmental impacts of our

operations, working to reuse waste in closed-loop systems and to adopt best available techniques for improving environmental

performance. We also encourage our Suppliers to develop products aligned with our environmental requirements, highlighting the

incorporation of renewable materials as a strategic indicator. In addition, we promote compliance with FSC

and PEFC standards,

strengthening the commitment to sustainable forest. PG80 - Management of Environmental Issues, a complementary document to

this policy, also guides the Company towards preferential use of renewable resources, rather than non-renewable resources. [E5-

1.15]

The Environmental Policy, the Systems Management Policy and PG80 - Management of Environmental Issues adopt a

comprehensive approach, applying, whenever possible and appropriate, the strictest level in the waste hierarchy, assigning

priority to prevention. The Company works to develop and implement processes and technologies that maximise efficiency,

minimise losses and encourage recirculation of resources, helping to reduce waste production. This policy includes measures for

prevention, recycling and reuse. PG27 - Waste Management Procedure lays down guidelines for the correct sorting and

classification of waste, ensuing that the final disposal is the most appropriate and causes the least possible impact on health and

the environment. The approach adopted follows a hierarchy that assigns top priority to prevention, followed by (preparation for)

reuse, recycling, other types of reclamation and, in the final instance, disposal. It promotes extending the life cycle of materials,

paving the way for synergies between Navigator and its partners, within the logic of the circular economy. Taken together, these

documents prioritise waste prevention and minimisation, rather than processing, including recycling, and the underlying principle

is reduction of waste generation at source, promoting efficiency in the use of raw materials, avoiding waste and optimising

production processes. In addition, they require that significant environmental matters be managed with a focus on reduction at

source, prior to considering other options, such as recycling and reclamation. [E5-1.AR9a/b]

Document

Management Systems Policy

Description of key

contents and general

objectives

[ESRS 2.65a]

This Policy sets out Navigator’s general commitments in relation to its quality environmental,

energy and safety management systems.

Scope

[ESRS 2.65b]

It applies to own operations, and is aimed at internal and external Stakeholders (e.g. Suppliers,

Industrial Synergies), and covers Portugal, Spain and Mozambique.

Most senior level

position accountable for

its implementation

[ESRS 2.65c]

Executive Committee

Standards or third party

initiatives

which the Company

undertakes to comply

with

[ESRS 2.65d]

• Product Safety Standards (BRC and IFS, for food use)

• ISO 9706 (Guarantee that paper does not lose its properties over 100 years (on

display) or 200 years (in dark storage)

• FSC

and PEFC standards, certifying the origin of fibrous materials

Most relevant

complementary

documentation

General procedure: Management of Environmental Issues (PG80)

Availability

[ESRS 2.65f]

This document is communicated to all Employees, Business partners and Stakeholders through

the intranet and is displayed at workplaces, as well as on the company's website.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 204

References throughout

of the non-financial

Statement

• E1 – Climate change (Chap. 5.2.2)

• E3 – Water and marine resources (Chap. 5.2.3)

• S1 – Own workforce (Chap. 5.3.1)

• S2 – Workers in the value chain (Chap. 5.3.2)

The following information is incorporated by reference to other parts of the Non-Financial Statement (MDR-P, ESRS 2, §65

a/b/c/d/f):

• Presentation of Environmental Policy - Chap. 5.2.2

5.2.5.2.2. Actions and resources related to resource use and circular economy

(E5-2, MDR-A)

In alignment with our targets for reducing the disposal of waste at industrial landfill sites and developing sustainable and value

added applications for by-products from the industrial process (see section “Targets and metrics”), we have adopted a set of

strategic actions. [ESRS 2.68]

The measures adopted are designed to boost circularity in the use of resources and to this end we are increasingly investing in

innovative solutions, prioritising reduction of waste generation, maximising recycling and reclamation of by-products.

These initiatives not only improve the Company’s environmental efficiency but also generate solutions for local Communities,

reducing the material impacts of operations. [ESRS 2.68]

The main measures implemented include [ESRS 2.68e]:

• Reduction of waste production – in 2024, only 9% of raw materials used resulted in waste. Including fuels in the raw

materials used, waste generated represented 7%.

• Minimising production of hazardous waste which, in 2024, represented only 0.2% of total waste generated.

• Development of bioproducts from forest raw materials, contributing to a more sustainable and innovative business.

• Building up partnerships with universities and research centres, driving the creation of innovative solutions for

reclaiming industrial by-products.

• Efforts to source Portuguese raw materials, thereby shortening value chains. In 2024, approximately 65% of wood

used was sourced from Portugal, contributing to domestic value added. In addition, 75% of subsidiary raw materials were

acquired from Portuguese suppliers.

• Implementation of best practices in waste management in Navigator’s internal processes, in collaboration with OGR

and other industrial partners. Examples of these practices included minimising dust when unloading ash, by humidifying

them, use of tanker trucks (instead of open trucks, to reduce dust dispersion during transport and raising the awareness

of hauliers to the correct stowage of loads.

• Demonstration projects, in partnership with academic institutions and companies, which promote the use of waste in

developing new products, permitting the partial or total substitution of virgin raw materials and working to have waste

reclassified as by-products.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 205

Main actions Status Scope of action

Time

horizon

Results

[ESRS 2.68a]

[ESRS 2.68b]

[ESRS 2.68c]

[ESRS 2.68a] [ESRS 2.68e]

Reclamation

of carbonate

sludges

Executed

Own operations, External partners, Portugal

Ongoing

51.3 thousand tons reclaimed in

2024

Reclamation

of biological

sludges

Executed Own operations, External partners, Portugal

Ongoing

59.0 thousand tons reclaimed in

2024

Reclamation of

sand

Executed Own operations, External partners, Portugal

Ongoing

40.0 thousand tons reclaimed in

2024

Resource

management in

forestry operations

Executed Own operations, Portugal and Spain

Ongoing

61% reduction in waste generated

and not sent for disposal, in

comparison with 2023.

Reuse of BPP ash Planned Own operations, External partners, Portugal Start-up 2025

Potential reclamation of 15 000 tons

of fly ash over 5 years

Installation of Lime

Kiln Figueira

Planned Own operations, External partners, Portugal

Start-up 2025

90% reduction in production

of carbonate sludge

Alteration

of fly ash discharge

system to dry

method

Planned Own operations, External partners, Portugal Start-up 2025

Dry fly-ash discharge will make it

possible to identity new applications

for reclaiming this waste product

Production

of soil-cement

Planned Own operations, External partners, Portugal

Start-up 2025

Reclamation of fly-ash

from biomass boilers

in production of Low Carbon Clinker

Notes: No negative material impacts and only positive impact have been identified associated with the use of resources and the circular economy, meaning

that no remediation actions are identified [ESRS 2.68d].

In industrial operations, optimisation of production processes is a strategic priority, with a view to minimising fibre losses,

reducing consumption of chemicals and increasing the efficiency of water use. These initiatives are part of a sustainable approach,

seeking to mitigate the material risks associated with reduced availability of wood and difficulties in sourcing raw materials.

Implementation in 2023 of a new wood preparation line (LM3) at the Figueira industrial complex resulted, in 2024, in significant

improvements in fibre losses associated with this stage in the pulp production process. The oxygen delignification process to be

installed at the Setúbal paper mill, planned to start up in 2025, will make it possible to reduce consumption of chemicals at the

pulp bleaching stage.

We take steps with a positive impact in the context of the circular economy, promoting the use of renewable raw materials

and a forest-based bioeconomy. Action is implemented to reuse waste/by-products, based on R&D promoted by RAIZ and

in partnership with other economic operators, in a context of industrial symbiosis. In the context of the circular economy, the

reuse of carbonate sludges, resulting from the causticisation process at pulp mills, is a partnership with Secil and Cimpor, and

these sludges are incorporated in the production of cement products. In addition, some of the carbonate sludges produced at the

Figueira da Foz unit are incorporated in the production of precipitated calcium carbonate (PCC), and essential raw material for

producing paper on the site. Reclamation of biological sludges generated in effluent treatment at the industrial complexes is

achieved through composting, and as a fuel in the production process for expanded clay (Leca). Reclaimed sands generated in

the biomass boilers are also used to produce construction materials, thanks to their classification as a by-product. In 2024, at the

Setúbal Industrial Complex, Navigator introduced the sieving of sands in order to separate them into grain sizes, optimising and

boosting the potential for using them in civil construction [E5-1.19].

We also have plans, for example, for reuse of ash from the Biomass Power Plant (BPP) in Aveiro, by Saint Gobain, in

producing mortars, for installation of a lime kiln at the Figueira da Foz unit, for changing the system for unloading ash to a dry

process, for production of soil-cement and sieving of sands, as indicated in the following table [ESRS 2.68]. Implementation of the

ANNUAL REPORT 2024 • MANAGEMENT REPORT 206

reclamation of BPP ash, installation of a lime kiln in Figueira and changing the ash unloading system to a dry process required

capital expenditure (CapEx) in 2024 of 0.8 M€, 30 M€ and 0.1 M€, respectively [ESRS 2.69b]

The process of reclassifying waste as by-products, as happened with sands in 2019 and as is planned for fly-ash in 2025, plays a

fundamental role in achieving our goals. In the same way, implementation of measures to reclaim carbonate sludges, biological

sludges, biomass boiler sands and fly ash contributes directly to attaining those goals, by avoiding the disposal of these materials

at landfill sites. [ESRS 2.68a]

Management of waste produced in forestry activities, including in plant production, ensures selective collection, correct stowage

and routing to an appropriate final destination, prioritising reuse operations whenever possible. We also discourage unlawful

disposal of waste in woodlands, alerting the relevant authorities, so they can investigate and pursue the matter. Waste

management in forestry operations is aligned with high standards of resource efficiency, application of circular business practices,

measures taken to avoid waste production and optimised waste management in keeping with the waste hierarchy [E5-3.20].

Implementation of this action has required significant capital expenditure (CapEx) or operating expenditure (OpEx) (current and

future), through the budgets of the departments responsible for managing waste.

The action plan has specific financial resources allocated, including an annual budget for waste management, ensuring it is routed

to OGR. In addition, there are annual budgets for environmental improvements, which may include optimisation projects in waste

management and the circular economy. [ESRS 2.69a]

CapEx - Nos. 3.2, 3.3 of 3.6 the Notes to Navigator's Consolidated Financial Statements. [ESRSE 2.69b]

5.2.5.3. Targets and metrics

5.2.5.3.1. Targets related to resource use and circular economy (E5-3, MDR-T, MDR-M)

Our 2030 Roadmap (Chapter 3.4.4) has established two targets focussing on waste. The target for reducing disposal of waste

in industrial landfill is aligned with national and European goals for sustainable waste management. It contributes to SDG 12

(Sustainable Consumption and Production), promoting reuse of materials, and is in keeping with the national targets established

for waste management and with European Directive 2018(850, which imposes tougher restrictions and encourages recycling and

reused for energy purposes. In addition, it is compliant with the waste hierarchy principle, prioritising reduction and reuse over

final disposal and supports the General Waste Management Rules (GWMR) by fostering the circular economy, reducing the

environmental footprint of industry and incentivising technologies for reusing waste [ESRS 2.80f]. The target relating to

development of sustainable, value-added applications, for by-products from the industrial process falls under other

types of reclamation, in the waste hierarchy. [E5-3.25]

Goal and

target

Baseline

Associated

metric

2022

Performance

2023

Performance

2024

Performance

Results

to achieve

[ESRS 2.80]

[ESRS 2.80d]

[ESRS 2.75]

[ESRS 2.80B]

[ESRS 2.80j]

[ESRS 2.80e]

Achieve by

2030 a rate of

waste disposal

in industrial

landfill of less

than 10%.

14% in 2021

Waste

deposited

in landfill

(t)/Waste

generated (t)

Goal reformulated

in 2022

12%

<10% in 2030

ANNUAL REPORT 2024 • MANAGEMENT REPORT 207

Develop

sustainable

applications

and added

value for by-

products from

industrial

process

(sludges, ash

and other

inorganic

waste)

N/A N/A

991 t of carbonate

sludges

28 395 t of sand for

incorporation

4 800 t of

carbonate sludges

reclaimed in

production of PCC

35 624 t of sand

(by-product)

reclaimed

for construction

sector

1 355 t of fly-ash

reclaimed

in concrete articles

1 260 t of

carbonate sludges

reclaimed in

production of PCC

39 995 t of sand

(by-product)

reclaimed

for construction

sector

N/A

NOTES: No changes have been made to the value, year, calculation methodology, assumptions, sources or limitations of targets [ESRS 2.80i | ESRS

2.13], and no prior period errors have been identified [ESRS 2.14]. These metrics are subject to external verification in connection with this report, and

are not verified by other entities. [ESRS 2.77b]

Both targets are in relation to Navigator's own operations in Portugal. They are not science-based, nor were ecological threshold

values considered. These targets are not a legal obligation but are adopted voluntarily as a result of engagement with internal

Stakeholders, the Environmental Board and the Community Monitoring Committees. The targets set are aligned with the

Environmental Policy and the Management Systems Policy, and the respective complementary documents. [E5-3.25 | ESRS

2.80a| ESRS 2.80g| E5-3.26 | E5-3.27]

The methodology for setting the first target was based on the following points [ESRS 2.80f]:

• Alignment with the goal of reducing the amount of waste dumped in landfill, indexed to sector benchmarks.

• Historical analysis of waste and by-product flows.

• Identification of waste reclamation opportunities: For the main secondary flows, potential reclamation solutions were

analysed, maximising reincorporation into production processes.

• Reclassification from waste to by-product: This approach permits alternatives to conventional reclamation with OGR,

extending the possibilities for reuse.

• Planning and scheduling: The company has established a multiannual plan for implementing the measures, so that

the target is met gradually.

• Monitoring and readjustment

Seeking to exploit the full potential for circularity in our production processes., Navigator works continuously with RAIZ and

technological and industrial partners to assess sustainable applications for by-products from the industrial process. In relation

to this target, wastes and by-products which are reclaimed in value-added applications are quantified. Quantification uses the

same methodology for all waste generated [ESRS 2.80f]. Performance in 2024 presented a positive trajectory in comparison

with previous years, with an increase of 5% in materials reclaimed in applications of this type, in relation to 2023. [ESRS 2.80j]

5.2.5.3.2. Resource inflows (E5-4)

Operations

Resource inflows

[E5-4.30]

Products (including packaging)

In its industrial processes for eucalyptus kraft pulp, UWF paper, packaging, tissue and energy,

Navigator adopts a sustainable and efficient industrial model in the use of resources. Its production

chain involves incorporating essential raw materials, auxiliary products and

packaging used

throughout the process and in final distribution, as well as a range of technological equipment.

Packaging materials include materials from renewable sources, such as cardboard boxes, wrapping

paper, wooden pallets and labels, but also other materials, such as stretch or cling film, plastic belts

and wire for bundling.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 208

Operations

Resource inflows

[E5-4.30]

Materials

Essential raw materials used in Navigator's industrial processes include Eucalyptus globulus wood

from sustainably managed forests, both from its own plantations and acquired from third parties. Of

the total wood consumed, 73% is from plantations certified by the FSC

and PEFC™. For pulp

production, we should mention chemicals such as sodium hydroxide, sodium chlorate, sulphuric acid,

oxygen and hydrogen peroxide. Production of UWF paper uses precipitated calcium carbonate (PCC),

starch, gluing agents and optical whitening agents. In tissue production, we use wet strength agents.

In addition, Navigator used purchased fibre, complementing the eucalyptus fibre produced internally

with long fibre pulp, recycled fibre and uNotesleached fibre. In terms of fuel, the Company uses black

liquor and eucalyptus bark from wood used in pulp production, as well as residual forest biomass for

energy generation. It also uses some fossil fuels, including natural gas, fuel oil, diesel and propane.

Water and assets

Water is a fundamental resource, and is used for the cooking, bleaching and paper sheet formation

stages. Approximately 80% of the water used is duly treated and returned to the environment,

ensuring the sustainability of the production process.

Resource inflows

2024

(t)

2024

(%)

TOTAL [E5-4.31a]

5 241 400

Renewable

4 569 007

87%

Non-renewable

672 361

13%

Recycled

TOTAL [E5-4.31c]

5 241 400

Wood

4 359 966

83%

Chemicals

702 754

13%

Fibre

81 400

Packaging

96 271

Others

1 010

TOTAL [E5-4.31a]

5 241 400

Total biological materials

4 503 929

86%

Total technical materials

737 472

14%

Biological Materials [E5-4.31a]

4 503 929

Sustainably sourced biological materials [E5-4.31b]

4 441 366

99%

Other biological materials

62 563

Resource inflow data is calculated on the basis of measurements, at the factory gate, of the weight of the most relevant raw

materials. The industrial complexes are equipped with weighbridges duly calibrated for measuring wood, chemicals, fibre, fuel,

packaging materials and other things. In addition, for materials which are quantified by unit, in particular packaging materials, the

respective unit weights are used for conversion into tons. We have quantified the materials consumed in all Navigator activities in

all geographical regions, except for Navigator Tissue UK. [E5-4.32]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 209

5.2.5.3.3. Resource outflows (E5-5)

Products and materials

Navigator develops products which incorporate the principles of the circular economy, ensuring that pulp, paper and tissue are

designed with the focus on durability, recyclability and recirculation in the biological cycle.

BEKP (Bleached Eucalyptus Kraft Pulp) is a renewable and biodegradable material, which can be used in producing new paper

or recycled fibres. Sourced from plantations certified by the FSC

and PEFC, it sustainable origin is guaranteed [E5-5.35].

High yield uNotesleached eucalyptus pulps, in particular UEKP (UNotesleached Eucalyptus Kraft Pulp) and HYKEP (High Yield

Eucalyptus Pulp), have been developed to produce packaging materials, helping to substitute fossil plastic.

UWF (Uncoated Woodfree) Paper is outstandingly durable, maintaining its quality even after multiple recycling’s. As a 100%

recyclable product [E5-5.36c], it can be reincorporated in the production process as a secondary fibre, and can also be reused in

sketch and note pads prior to recycling.

Tissue paper is developed for efficient use, reducing waste per sheet through compaction technology. Some products include

recycled fibre, promoting the recirculation of materials. In addition, they are biodegradable, permitting sustainable intergation into

the biological cycle with low environmental impacts. [E5-5.35]

A production unit for moulded cellulose packaging started up in 2024 at the Aveiro Industrial Complex. With production capacity

for 100 million articles, this unit is able to produce trays, dishes and plates for food or ready meals. These renewably sourced

products are able to substitute packaging made from fossil-based plastic. [E5-5.35]

Packaging products, including moulded cellulose products, are also products from Eucalyptus globulus fibres. These products

include uNotesleached pulps such as UEKP and HYKEP, which use less chemicals.

In addition to products sold, by-products are generated at the industrial units which can be incorporated into other materials. BPP

fly ash, classified as a by-product in January 2025, can be incorporated in specific mortars, partially or totally replacing mineral

binder. Sands for biomass boilers, classified as a by-product in October 2019, can be used in manufacturing cement, cement

mortars and paving, as fine aggregates.

Navigator paper is outstandingly durable and offers optimised use, presenting high opacity and strength, enabling it to be

reused more times before recycling. In addition, all paper products produced by Navigator are 100% recyclable, due to being

uncoated, ensuring they can be recirculated in the production cycle. The production process minimises the use of harmful

chemicals, permitting unrecycled products to be biodegradable. [E5-5.35]

As an intermediate product, the durability of pulp cannot be quantified, as this depends on the manufacturing process. The

durability of tissue, as a single-use product, can also not be quantified. The UWF paper produced by Navigator complies with

ISO 9706:1994, guaranteeing a useful lifespan of more than 200 years in archives (dark storage). [E5-5.36a/5.36b]

All products produced by Navigator are from biological and biodegradable sources. The volumes of products and by-products

produced by Navigator are all calculated on the basis of direct measurement. UWF paper is 100% recyclable and is a product

designed in accordance with circular principles [E5-5.40].

Waste

[E5-5.37a/5.37b/5.37c/5.39]

Total waste generated

Hazardous

Non-hazardous

Total waste

2024

ANNUAL REPORT 2024 • MANAGEMENT REPORT 210

TOTAL

979

445 622

446 601

Reclaimed

620

300 307

300 927

Preparation for reuse

93 0 93

Recycling

137

184 852

184 988

Other forms of reuse

391

115 456

115 847

Disposal

359

145 315

145 674

Incineration, providing energy

88 759

Landfill

113

56 335

56 448

Others

246

221

467

The waste generated in Navigator’s activities is mostly non-hazardous, and in 2024 this accounted for 99.8% of total waste

generated. [E5-5.38]

In industrial activities, the waste flows with the largest volume are WWTP sludges generated in treating effluents, fly-ash from

biomass boilers and carbonate sludges from the causticising process at pulp mills. The waste management hierarchy principle is

used, applying the highest level whenever possible, as laid down in the Company’s policies and procedures. [E5-5.38]

In forestry activities, the most significant waste flows consists of packaging, packaging waste and used tyres, the latter

derived from illegal dumping by third parties on properties managed by the Company. The materials present in waste include

plastics, chemical wastes with hazardous and non-hazardous properties, and wood. [E5-5.38]

Approximately 67% of all waste generated is sent for reclamation. Examples include the reclamation of WWTP sludges, in

agricultural applications, and incorporation of fly-ash and sand from the biomass boilers in cement products and other

construction materials. Carbonate sludges are mostly generated at the Figueira da Foz Industrial Complex, due to the limited

capacity of the chemical lime recovery process. With the start-up of the new lime kiln, planned for 2025, a significant reduction in

production of this waste is anticipated. Of the waste disposed of, 61% is used to produce energy on site, in Navigator's renewable

cogeneration facilities, eliminating the inefficiencies associated with transporting, treating and sending these waste products to

third party facilities, substituting fossil fuels. Only 12% of the waste generated is sent to landfill. [E5-5.38]

The calculation methodology used is based on direct measurements made on the duly calibrated weighbridges existing at the

industrial complexes, and the information is logged on the e-GAR platform. [E5-5.40]

5.2.5.3.4. Anticipated financial effects from important risks and opportunities related to resource use and

the circular economy (E5-6)

In accordance with Appendix C of ESRS 1, Navigator has opted not to report information on the anticipated financial effects of

impacts, risks and opportunities related to resource use and the circular economy in this first reporting year.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 211

5.2.6. Entity-specific disclosures -

Sustainable Forest Management

5.2.6.1. Strategy

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

(SBM-3)

Description

Impact, Risk

or Opportunity

Time horizon

Location in the

value chain

Related sub-theme

or sub-sub-theme

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

Promoting forest management certification

and chain of custody of national partner entities,

through dedicated initiatives and programmes.

Positive impact - Upstream

(Entity-specific

disclosure)

Ensuring that the wood purchased comes from

credible (certified) sources and does not

contribute to deforestation, conversion of natural

forests or damage to relevant ecosystems.

Positive impact - Upstream

(Entity-specific

disclosure)

Disseminate technical information and provide

training on good forest management practices,

including practices for the conservation of

relevant natural and socio-cultural values.

Positive impact -

Own operations and

Upstream

(Entity-specific

disclosure)

Promote research and innovation linked to

production and conservation forest and the

sharing of knowledge in these areas.

Positive impact -

Own operations and

Upstream

(Entity-specific

disclosure)

Protecting and conserving the natural, cultural

and social values existing in the areas under the

company's forest management, whether owned

or leased.

Positive impact - Own operations

(Entity-specific

disclosure)

Contribution to reducing

the number/intensity of forest fires through

programmes and/or projects, reducing financial

losses and positively impacting the social licence

to operate.

Opportunity

Short Term -

Reporting Year

Own operations

Fatores de impacto

direto na perda de

biodiversidade

Note: The material impacts identified are real and therefore do not have a time horizon associated with them.

At Navigator, sustainable forest management is intrinsically linked to the Impacts, Risks and Opportunities (IRO) identified in

themes E1 (Climate change), E3 (Water and marine resources), E4 (Biodiversity and ecosystems) and E5 (Use of resources and

circular economy), and is fully in line with the applicable regulatory requirements.

We promote forest certification, resource traceability and capacity building in the sector, ensuring the protection of

ecosystems and the sustainable use of raw materials. Our approach strengthens environmental resilience and contributes to

creating value throughout the production chain and communities, aligning us with the principles of the circular economy and

biodiversity conservation.

The main paper fibre used by the Company (Eucalyptus globulus) has several advantages over other species, such as the

production of paper with a lower specific grammage and using less forest area, the possibility of a greater number of

subsequent recyclings and higher quality and potential for use in new products.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 212

5.2.6.2. Management of impacts, risks and opportunities

5.2.6.2.1. Policies related to Sustainable Forest Management (MDR-P)

Our commitment to responsible management of forest areas, in full balance with their natural and social surroundings, is also a

commitment to take action against the forces that lead to deforestation and forest degradation, as set out in the Forest Sector

SDG Roadmap (a reference roadmap published by the Forest Solutions Group, WBCSD, to inspire the forest sector's contribution

to the Sustainable Development Goals).

We manage our forest assets in mainland Portugal in accordance with the legal requirements applicable to our activity and

other regulations and policies that we have voluntarily signed up to, such as the pan-European criteria for sustainable forest

management, in accordance with the Portuguese standard NP 4406 for Sustainable Forest Management, and the Principles

and Criteria of the Forest Stewardship Council

. Forest management certification ensures that the wood used in our

products - pulp and paper - comes from responsibly managed forests. We have been FSC® certified since 2007 and PEFC certified

since 2009, with 100 per cent of the forest area under our management in mainland Portugal certified by these two systems.

Forest assets in Mozambique are managed in accordance with the legal framework applicable to our activities and the forest

management principles and criteria of international certification systems. Portucel Moçambique is FSC

Chain of Custody certified

and is in the process of obtaining FSC

Forest Management certification [ESRS 2.65d]. The conservation of biodiversity and

ecosystem services (Chap. 5.2.4) is an essential part of this model, seeking to guarantee the maintenance or improvement of

biodiversity values through restoration initiatives.

We express our commitments to promoting sustainable forest management in our Forestry Policies and Environmental Policy

(Chap. 5.2.2). Through these policies we promote the preservation of natural values and ecosystems, contribute to soil formation

and the fight against erosion, protect the forest against fires and regularise the water cycle, enhancing land use that stimulates

territorial cohesion and wealth creation.

Document

Forestry Policy

Description of key contents

and general objectives [ESRS

2.65 a]

The Navigator Company's Forestry Policy is committed to the sustainable management of its forest

resources, promoting responsible practices that ensure the sustainable production of tangible and

intangible goods. This Policy defines general objectives and principles for forest management activities

that the company uses to make decisions.

Scope

[ESRS 2.65b]

It is aimed at Own operations and has an impact on the Upstream and Downstream of the value chain, on

Suppliers and on local communities in the Iberian Peninsula.

Most senior level position

accountable for its

implementation [ESRS 2.65c]

Executive Committee

Standards or industry

initiatives the policy aims

to commit to [ESRS 2.65d]

• FSC

wood certification standards

•

Portuguese standard NP 4406 for Sustainable Forest Management in accordance with the

principles and criteria of the Forest Stewardship Council

Most relevant

complementary

documentation

• General Environmental Aspects Management Procedure (PG80)

• Forest Management System

• Code of Conduct for Suppliers

Available at

[ESRS 2.65f]

Available on the Intranet and Internet pages

References throughout the

Non-Financial Statement

• E1 - Climate change (Chap. 5.2.2)

• E3 - Water and marine resources (Chap. 5.2.3)

• E4 - Biodiversity and ecosystems (Chap. 5.2.4)

• E5 - Use of resources and circular economy (Chap. 5.2.5)

• S2 - Workers in the value chain (Chap.5.3.2)

ANNUAL REPORT 2024 • MANAGEMENT REPORT 213

Through our Forestry Policy, we are committed to managing our assets in accordance with the FSC® and PEFC forest certification

standards and to implementing and promoting a responsible forest management model, both in our Own operations and with

Suppliers, which involves (i) mitigating potential negative impacts and conserving and restoring biodiversity and ecosystem

services, and (ii) managing biotic and abiotic risks (including those arising from climate change). In particular, we aim to [ESRS

2.65a]:

• Developing and promoting the concept of forest plantations which, through the way they are managed, can make a

positive contribution to maintaining the integrity of ecosystems and protecting high conservation values and

guaranteeing effective stakeholder participation processes, fostering economic growth and employment.

• Implementing a forest management model whose best practices are documented in a Forest Management System, are

informed by the knowledge derived from Research and Development and include measures to mitigate potential

environmental and social impacts.

• Ensuring the health and safety of our Employees, including the employees of third parties that provide forestry

services, guaranteeing them adequate training/information for the risks assessed.

We also ensure that the production, supply and consumption of raw materials follow principles of sustainability and

biodiversity protection. We limit the purchase of wood and fibres to Suppliers who demonstrate responsible practices,

avoiding negative impacts on protected areas. To this end, we require compliance with the European Timber Regulation (EUTR)

and favour FSC

and PEFC

™

certifications, ensuring that there is no conversion of natural forests or violation of traditional rights.

[ESRS 2.65a]

The Policy refers to recognised standards and certifications supervised by third parties, ensuring sustainable practices through

independent audits. [ESRS 2.65d] In addition, we promote the sustainable management of ecosystems, with continuous

monitoring of biodiversity, habitat conservation plans and measures to minimise environmental impacts (Chap.

5.2.4). We invest in research and partnerships to evaluate and improve performance. [ESRS 2.65a]

Through our Policy we have also taken on a leading role in expanding the forest certification process in Portugal (see next

section). [ESRS 2.65a]

Portucel Moçambique's Forestry Policy

should also be mentioned. In order to guarantee the generation of value and the

recognition of its activity by society in general, Shareholders, Employees, Customers, Suppliers and other Stakeholders, the

Company has adopted a forest management model that: (1) aims to contribute to the maintenance and continuous improvement

of its productive, economic, ecological, social and environmental functions, both at the stand level and at the landscape level; (2)

is based on criteria developed in accordance with The Navigator Company's good technical, environmental and social practices.

[ESRS 2.65a]

Document

Portucel Moçambique's Forestry Policy

Description of key contents

and general objectives [MDR-P_01;

§65 a] [ESRS 2.65 a]

It demonstrates Portucel's commitment to the sustainable management of its business, in order to

ensure that its activities are carried out in accordance with the best environmental, social and

economic practices.

Scope

[MDR-P_02; §65 b] [ESRS 2.65b]

It is aimed at Own operations and has an impact on the Upstream of the value chain, on the

Government and on local communities. It covers all the geographies in which Portucel Moçambique

operates in Mozambique (Manica and Zambézia).

Most senior level position

accountable for its

implementation

[MDR-P_03; §65 c]

[ESRS 2.65c]

Board of Directors

Standards or industry

initiatives the policy aims to

commit to

[ESRS 2.65d]

Forest Stewardship Council

Principles and Criteria

United Nations Global Compact

ANNUAL REPORT 2024 • MANAGEMENT REPORT 214

Available at

[MDR-P_06; §65 f] [ESRS 2.65f]

Available through the Internet page

References throughout the

Non-Financial Statement

• E1 – Climate change (Chap. 5.2.2)

• E3 – Water and marine resources (Chap. 5.2.3)

• E4 – Biodiversity and ecosystems (Chap. 5.2.4)

• E5 – Resource use and circular economy (Chap. 5.2.5)

• S2 – Workers in the value chain (Chap. 5.3.2)

The following information is inserted by reference to other parts of the Non-Financial Statement (MDR-P, ESRS 2, §65 a/b/c/d/f):

• Environmental Policy presentation: Chap. 5.2.2

5.2.6.2.2. Actions and resources related to Sustainable Forest Management (MDR-A)

In line with our 2030 Agenda and Roadmap (Chap. 3.4.4), and in accordance with the defined objectives and targets (see next

section), we have invested in programs to support the increase in sustainable, certified forest management and support

for Forest owners, going beyond the areas under our direct management and aiming to cover a greater number of owners -

encouraging them to adopt good practices and invest in the conservation of the territory's natural and socio-cultural values. These

initiatives seek to respond to the individual needs of Forest Partners at national level, including the recently created Forest

Producers Club and the Eucalyptus Forum. The aim of these programs is to stimulate the sharing of knowledge and the

training of forest Stakeholders, as well as to protect forests and Communities from forest fires.

Through various support programs for Forest Management Certification Groups, Chain of Custody/Responsibility Groups, Forest

Producer Organizations, Companies and Forest Producers, we contribute to build a common front in defense of the interests

of the national forest sector.

Principal actions

Status

Action scope

Time horizon

Results

[ESRS 2.68 a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68 a

ESRS 2.68e]

Portugal’s forest activity

Eucalyptus Forum

project

Taken

Own

and downstream

operations of the value

chain, in Portugal

2024

In 2024, the Eucalyptus Forum project was

born, with the aim of promoting in-depth

reflection on forestry issues and, in

particular, planted eucalyptus forests. The

initiative centred on two meetings. At the

first, an ISCTE study of Portuguese society's

perceptions of eucalyptus was presented,

and six workshops were held, attended by

around 70 participants from outside

Navigator. The second meeting, in

partnership with the Expresso newspaper,

brought together national and international

experts from various fields in four round

tables. The work of the two meetings gave

rise to a body of ideas and responses aimed

at promoting forest literacy. In total, the

meetings were attended by around 400

people.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 215

Principal actions

Status

Action scope

Time horizon

Results

[ESRS 2.68 a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68 a

ESRS 2.68e]

Clube Produtores

Florestais (Forestry

Producers Club)

Taken and planned

Upstream operations

with owners, forestry

Associations, Service

Providers and wood and

biomass Suppliers in

Portugal

Continuous

Support for the acquisition of 5 pieces of

forestry equipment, worth €0.3 million; 2.

Protocol with Galp, for discounts on fuel at

the pump, with an estimated impact on

companies of €0.5 million; Protocol with the

Caixa Central de Crédito Agrícola Mútuo to

boost investment, where €0.5M has already

been facilitated; Partnership with

Empremédia to offer members more

advantageous insurance conditions. 5

policies closed, totaling €0.6 million.

Support programs for

forest producers

Taken and planned

Upstream

and downstream

operations in Portugal

Continuous

Continuation of the incentive associated with

the supply of certified wood (absolute value

of €4/m3).

Support for 18 forest management and/or

chain of custody certification groups and

other forest Producer Organizations.

TecFloresta - 77 sessions were held, with a

total of 470 participants, promoting the

transfer of technical-scientific knowledge and

tools to support forest management.

Premium Program - Free technical support,

open to all Owners with eucalyptus forests,

covering 1842 hectares.

Best Eucalyptus - Project developed within

the scope of Biond (Navigator and Altri), to

improve good practices for Producers and

private forest owners. the most relevant

program being Limpa e Fertil (PLA), with

78,764 hectares intervened, until the end of

2024, and 9,790 forest producers benefited

(cumulative values). Of the area intervened

in 2024 (15,064 ha), 12,181 ha were

fertilized for the 2nd time, since the program

began.

Prior assessment of

forestry operations for

impacts on natural,

cultural and social

values

Taken and planned

Own operations in

Portugal

Continuous

Creation of 406 checklists for operations

considered to have the greatest impact on

the environment.

Promote the

Florestas.pt platform as

the national reference

for forestry data

Taken and planned Baseline value:

2 iniciatives

Baseline year:

2020

Continuous

To collect, systematise and disseminate

comprehensive information and knowledge

on Portuguese forestry and agroforestry,

highlighting their relevance, challenges and

opportunities in a clear, inspiring and

accessible way.

744 articles published since launch

490,000+ visitors to the site in 2024

1 621 412 visitors to the site since launch.

126 digital contents in 2024.

714 newsletter subscribers.

More than 115 personalized replies by email;

7 awareness-raising actions/participation in

initiatives; 4 new Partners in 2024 (27 since

launch).

Mozambique’s forest activity

ANNUAL REPORT 2024 • MANAGEMENT REPORT 216

Principal actions

Status

Action scope

Time horizon

Results

[ESRS 2.68 a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68 a

ESRS 2.68e]

Environmental and

social compliance audit

Taken and planned

Downstream operations

with the Mozambican

Government, in

Mozambique

Continuous

The Mozambican legal framework provides

for an annual external and independent audit

to assess compliance with the Environmental

Management Plan (a plan resulting from the

potential negative and positive impacts that

the forestry project could have).

Water and soil

monitoring

Taken and planned

Downstream operations

with Employees

and service providers in

the forestry business,

in Mozambique

Continuous

On an annual basis, we monitor the river

basins over which we have an occupation of

at least 15%, in order to assess the water

quality parameters upstream and

downstream, monitoring the impact of the

plantations on water quality. The programme

also covers soil fertility monitoring, allowing

for an assessment of the soil in the same

location throughout the eucalyptus growth

cycle (in Mozambique, 8 years).

Environmental

education program in

the Communities

Taken and planned

Own operations

with the Communities in

Mozambique

Continuous

Carrying out environmental awareness-

raising in communities, with the aim of

promoting sustainable practices in the areas

where we operate.

Awareness-raising activities for 5520 people;

146 sessions.

Increasing knowledge

and areas of restoration

Planned

Own

and downstream

operations with the

Communities in

Mozambique

2025-2030

Collection of areas for conservation only.

Identification of costs associated with

restoration. Ability to involve the community

in the preservation goal. Involvement and

development of meetings with potential

partners (nurserymen, acquisition of other

experiences in the region, etc.).

Note: No negative material impacts were identified, only positive impacts, so no remediation actions have been identified. It should be noted, however, that

we systematically identify and assess the environmental and social impacts of forestry activities, giving rise to matrices used in the planning and execution

phase of operations, thus making it possible to avoid negative impacts or act accordingly when they occur. As part of this assessment, local consultation is also

carried out with Interested Parties, such as the Local Community and/or experts in the different natural, social and cultural aspects being assessed. The

communication channels that affected Stakeholders can use to remedy the negative impacts of these operations include our website, the complaints channel

and the Community Liaison Officers (Chap. 5.3.3). [ESRS 2.68d]

In 2024, the Eucalyptus Forum project was born, an initiative promoted with the aim of gathering and sharing knowledge about

national forests, from their history to their future. It aims to provide a solid base of information, with the broad involvement of

Society, seeking literacy based on scientific research into planted eucalyptus forests and the value they create in their many

dimensions - social, economic and environmental. There were two main moments for sharing knowledge, with around 400

participants. We presented the perceptions of eucalyptus in Portuguese society, based on the results of the study on perceptions

of eucalyptus in Portugal, carried out by ISCTE. The debate centred on eucalyptus plantations and their role in climate adaptation

and the forest-based bioeconomy, and the foundations were laid for the design of initiatives to get to know the reality of

eucalyptus and the pulp and paper sector. With a connection to culture and to those who make paper their raw material, this

Eucalyptus Forum was attended by writers José Eduardo Agualusa, Mia Couto and Miguel Esteves Cardoso and by physicist,

professor and essayist Carlos Fiolhais. [ESRS 2.68 a]

The support programmes for Forestry Producers were continued, with the aim of promoting the productivity, resilience and

sustainability of the national forest, involving the players in the eucalyptus sector, thus contributing to the development of the

rural world and boosting the transfer of knowledge. [ESRS 2.68 a]

Faced with the problem of forest fires and the resulting impacts at various levels - social, economic and environmental - we are

committed to prevention through good forestry practices, in order to make the forest area under our management more resilient.

We regularly carry out actions to: maintain paths and firebreaks; control vegetation; reduce the fuel load and create zones of

discontinuity. We are also committed to supporting firefighting through Afocelca, the Forest Protection Company, and we support

the recovery of burnt areas, in particular through our participation in the Nodeirinho and Derreada projects, promoted by Biond -

Forest Fibers from Portugal. These initiatives aim to reduce the risk of fire, control invasive species and restore the productive

ANNUAL REPORT 2024 • MANAGEMENT REPORT 217

potential of the affected forests. Despite continued efforts, in 2024 there was an increase in the area burnt, due to fires that

occurred in September in the centre and north of the country, affecting several areas under the company's management (see

‘Targets and metrics’ section).

Mozambique is also actively working on this dimension, through a strategy based on the generalised implementation of a series of

actions, duly accompanied and monitored, including: the use of controlled fire (or cold burning); harrowing/manual digging;

clearing paths and firebreaks; the training of forest rangers and rapid intervention teams based in various locations and which

minimise potential spread; the placement of beehives at the edge of the forest to encourage the protection of a family asset, as

well as raising awareness, both among Employees at their intersection with Communities, and through campaigns on community

radio. [ESRS 2.68 a]

In addition, we are a member of TC 145 - Technical Commission for Sustainable Forest Management. We collaborate in the

most varied working groups that exist in this commission, participating in the preparation of documents and normative opinions in

the field of forest management, reinforcing Navigator's position on these matters. This participation is active and dynamic, making

it possible to update and adapt the regulatory documentation to the reality of Portuguese forestry, with many small and medium-

sized forestry producers. [ESRS 2.68 a]

In Mozambique, we highlight our participation in the Mozambican Government's forestry development programme in

Zambezia province - MOZ-RURAL. This project aims to increase the income of beneficiaries in the selected areas, increase the

added value of micro, small and medium-sized agricultural businesses, increase productivity and market access for the selected

small Producers and improve natural resource management practices in these areas. [ESRS 2.68 a]

5.2.6.3. Targets and metrics

5.2.6.3.1. Metrics related to Sustainable Forest Management (MDR-T)

Within the framework of our 2030 Roadmap (Chap. 3.4.4), we have defined a set of targets/goals related to sustainable forest

management, which cover objectives related to:

• Consumption of certified wood by the Company;

• Certification of the chain of custody of the Company's wood suppliers;

• Training of forestry producers and dissemination of technical information;

• Monitoring the impact of the production forest on water management;

• New genetic materials;

• New tools for biological control of pests and diseases;

• Reducing fires in rural areas;

• Stock of CO

sequestrated in the forest area under Navigator's management.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 218

Goal and

Target

Baseline

Associate

d metric

Performance202

Performance

2023

Performance

2024

Results

to achieve

[ESRS 2.80]

[ESRS 2.80d]

[ESRS 2.75]

[ESRS 2.80b]

[ESRS 2.80j]

[ESRS 2.80e]

Ensure that

the

Company’s

wood

consumption

include no

less than 80%

certified wood

by 2030.

Baseline value:

74%

Baseline year:

2020

Percentage of

certified wood

used in the

total wood

consumed

68%

69%

73%

(72.94% from the

national market

and 73.39%

considering the

total origin of

certified wood

received by

Navigator)

Results to

achieve:

80%

Year:

2030

Promote chain

of custody

certification

for all our

wood

Suppliers by

2030.

Baseline value:

74%

Baseline year:

2020

Percentage of

wood

suppliers with

chain of

custody

certification

87%

92%

Results to

achieve:

80%

Year:

2030

Introduce and

promote the

establishment

of natural

enemies for 2

eucalyptus

pests

(New 2024)

Baseline value:

Anagonia e

Cleruchoides not

established in

Portugal

Baseline year:

2023

The impact

on the

respective

pests

(parasitism

rate) has yet

to be

determined

- - Development and

release of 2

natural enemies:

Anagonia and

Cleruchoides.

Results to

achieve:

Anagonia e

Cleruchoides

established in

Portugal and with

an impact on the

respective pests

(parasitism rate

still to be

determined)

Year:

2030

Identify at

least 1 natural

enemy of

Acacia

dealbata and

introduce it in

Portugal

(New 2024)

Baseline value:

6 species of

defoliator insects

identified

Baseline year:

2024

Number of

natural

enemies of

Acacia

dealbata

introduced in

Portugal

- - Several natural

enemies of Acacia

dealbata were

imported and 6

species of insects

were identified,

which are being

studied in a

confined

environment

Results to

achieve:

1 natural enemy

of Acacia

dealbata

introduced in

Portugal

Year:

2030

Develop

genetically

improved

clones and

seeds, with

gains of 30-

50% in yields

and resilient

to climate

change

Baseline value:

Gain in volume of

35% and in pulp of

38% (6 clones, 2

of them not

resistant to

Pestalotiopsis)

Baseline year:

2020

Gain in

volume and

pulp (%),

Genetic

diversity

(number of

crosses,

number of

clones

delivered or

other

diversity

indicator)

New clone varieties

delivered for

production. Clone

selection has had

impacts on the

resistance of

eucalyptus to disease,

in nurseries and in

the field.

Incorporation of new

genetic materials in

the programme

(release of more than

100 individuals)

Incorporation of

29 lots of seeds

for 24 species

through

importation and

collection at

“Portuguese

“Escaroupim”

arboretum, to

increase

diversity in

Genetic

Improvement

3 new clones were

delivered to the

Viveiros Aliança

portfolio with a

genetic gain of

41% (volume and

pulp), all with

resistance to

Neopestalotiopsis,

and two with

known resistance

to Ophelimus

Results to

achieve:

Maintain volume

and pulp gains

(30-50%) and/or

enrich genetic

diversity (for

biotic and abiotic

factors)

Year:

2030

ANNUAL REPORT 2024 • MANAGEMENT REPORT 219

Goal and

Target

Baseline

Associate

d metric

Performance202

Performance

2023

Performance

2024

Results

to achieve

[ESRS 2.80]

[ESRS 2.80d]

[ESRS 2.75]

[ESRS 2.80b]

[ESRS 2.80j]

[ESRS 2.80e]

Poor year for seed

production

Programme in

the long term

through

hybridisation

with E. globulus

Ensure the e-

globulus

platform

reaches more

Portuguese

forestry

producers and

provides

effective

support.

Baseline value:

- No. of users

(cumulative): 600

- No. of registered

users (cumulative):

<100

Baseline year:

2019

- No. of users

(cumulative)

e/ou

- No. of

registered

users

(cumulative)

14,883 users

accessed the

platform; 687

registered users;

63,394 visualisations.

(cumulative values).

More than

20,000 users

have accessed

the platform;

850 registered

users.

More than 82

thousand views

(cumulative

values).

27,733 users

accessed

the platform

(cumulative).

1,040 registered

users

(cumulative).

Results to

achieve:

- No. of users

(cumulative):

35,000

- No. of

registered users

(cumulative):

1250

Year:

2030

Monitoring the

impact of

production

forestry on

water

management

Baseline value:

Qualitative

Baseline year:

2019

Installation of

two

experimental

forest basins

to quantify

flows and

monitor

hydrological

responses

Frequent

collection of field

information and

integration into

the eco-

hydrological

model, greater

knowledge of

plantation-water

use interaction

Results to

achieve:

Knowledge of

hydrological

dynamics in

forested

experimental

basins and the

relationship with

forest

management,

embodied in

published works

or other forms of

dissemination

Year:

2030

Launch the

Navigator

Forestry

Producers

Club

Baseline year:

2023

Not

applicable

Target reached in

2024.

Interim targets:

– Hold a meeting

of the main

Stakeholders by

2025

– Guarantee 100

new subscriptions

by 2025

– The Club's 1st

anniversary event

was held, with

the participation

of the main

Stakeholders.

No. of registered

members: 367

ANNUAL REPORT 2024 • MANAGEMENT REPORT 220

Goal and

Target

Baseline

Associate

d metric

Performance202

Performance

2023

Performance

2024

Results

to achieve

[ESRS 2.80]

[ESRS 2.80d]

[ESRS 2.75]

[ESRS 2.80b]

[ESRS 2.80j]

[ESRS 2.80e]

Consolidated

Forestry

Producers

project,

promoting and

disseminating

technical

information

about forestry

production,

helping to

share best

practices, by

2030.

Baseline year:

2020

No. of

initiatives/yea

r (digital and

in person):

No. of

forestry

producers

contacted/ye

ar: 10

thousand

5 exhibitions in the

agroforestry sector in

Portugal and Galicia;

2 forestry fundraising

campaigns in the

Galicia region;

3 editions of the

magazine, with an

average print run of

15,000 copies;

300 digital contents;

112 participants in

the 1st Meeting of

Forestry Producers;

Impact on a

community of more

than 12,500 people.

9 exhibitions in

the agroforestry

sector in

Portugal and

Galicia;

2 forestry

fundraising

campaigns in the

Galicia region;

3 editions of the

magazine, with

an average print

run of 15,000

copies;

200 digital

contents;

111 participants

in the 3rd

Meeting of

Forestry

Producers;

Impact on a

community of

more than

15,000 people.

11 initiatives (10

events in the

agroforestry

sector in Portugal

and Galicia; 1

forestry

fundraising

campaign in

Galicia)

4 editions of the

magazine, with an

average print run

of 15,000 copies;

more than 200

digital contents;

130 participants in

the 4th Meeting of

Forestry

Producers;

(Interim target

reached in 2024)

Impact on a

community of

more than 18,000

people.

Interim targets:

- Carry out 40

initiatives to

contact forestry

producers by

2025.

- Hold 4 Forest

Producer

Meetings by 2025

(interim target

reached in 2024)

- Guarantee 100

new subscriptions

by 2025.

Year:

2030

Contribute to

the reduction

of wildfires in

rural areas,

endeavouring

to ensure that

the area burnt

under

Navigator's

management

is less than

1% per year.

Baseline value:

2.1%

Baseline year:

2018

% of burnt

area under

Navigator

management

0.3%

1.8%

2.66%

Results to

achieve:

<1%/ano

Year:

2030

Ensure that

the stock of

CO2

sequestered

in the forest

holdings

under

Navigator's

management

does not fall

by more than

Baseline value:

6.1 Mt CO

eq.

Baseline year:

2022

Cumulative

stock of CO2

sequestered

in the forest

area under

Navigator's

management

(Mt CO

eq.)

6.1 Mt CO

eq.

6.2 Mt CO

eq.

6.4 Mt CO

eq.

(+4,9% face a

2022)

Results to

achieve:

Positive variation

in the stock of

sequestered

in the forest area

under Navigator's

management

compared to 90%

of the 2022 value

(baseline year)

Year:

2030

ANNUAL REPORT 2024 • MANAGEMENT REPORT 221

Goal and

Target

Baseline

Associate

d metric

Performance202

Performance

2023

Performance

2024

Results

to achieve

[ESRS 2.80]

[ESRS 2.80d]

[ESRS 2.75]

[ESRS 2.80b]

[ESRS 2.80j]

[ESRS 2.80e]

10% in

relation to

2022

(baseline

year), by

2030.

Note: The geographical scope of the targets defined is mainland Portugal. [ESRS 2.80c | E4.32d]

Setting targets

The targets set for sustainable forest management are in line with previously identified policies, reflecting Navigator's commitment

to promoting responsible forest management, ensuring the conservation of ecosystems, the enhancement of biodiversity and the

efficient use of natural resources, in accordance with Portuguese standard NP 4406 and the pan-European criteria for sustainable

forest management. The Company adopts practices that are consistent with the FSC

-C010852 Principles and Criteria, helping to

prevent illegal logging and controlling the origin of the wood purchased. It maintains and improves the management of forest

areas, in balance with the natural and social environment, promoting actions that prevent deforestation, degradation or forest

conversion. It develops and incentivises plantations that protect high conservation values and fosters effective Stakeholder

participation processes, boosting economic growth and employment. The forest management model is based on good practices

documented in a Forest Management System, informed by research and development, with measures to mitigate environmental

and social impacts.

We encourage our Suppliers to adopt responsible practices through support, knowledge transfer and monitoring, as well as

maintaining a proactive stance in collaboration with Forestry Producers and other agents in the sector, promoting certifications

and counteracting factors that induce forest degradation. We also ensure the dissemination and continuous improvement of our

Forest Management System, establishing and updating objectives, always in line with the commitments made in our Forestry

Policy. [ESRS 2.80a]

Biological pest control is an effective and sustainable solution in economic and environmental terms. Its implementation makes

it possible to reduce the negative impact of pests, helping to increase the productivity and resilience of the national eucalyptus

forest. [ESRS 2.80a]. Biological control is a control method that involves introducing specific natural enemies of these pests to

reduce their impact. The selection and introduction of natural enemies is a time-consuming process that requires detailed studies

to ensure that the biological control agents are effective and will not have negative impacts. RAIZ (Chap. 3.4.2) has a biofactory

and specialised technicians with the capacity to import, study, produce and release natural enemies of eucalyptus pests. The

biological control solutions applied in Portugal favour not only Navigator directly, but also all other forestry producers, since the

natural enemies act throughout the area where the target pests are established. [ESRS 2.80f]

The development of genetically improved clonal and seminal plants is in line with forestry policy, promoting the renewal of

eucalyptus production forests using improved clonal and seminal plants that provide higher quality performance, better growth

and resilience to climate change. It contributes to: (1) maximising the profitability of productive areas, reducing the pressure on

other non-productive areas (conservation/preservation); (2) mitigating the proliferation of pests and diseases through the use of

plants that are more resistant to these biotic agents, helping to improve the phytosanitary health of the national forest. [ESRS

2.80a]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 222

The methodology used to establish the target is based on conventional breeding techniques, where the selection of parents,

controlled crossing plans, trials to test the offspring obtained and, finally, the selection of new parents and the restart of a new

breeding cycle predominate. Improvement between cycles is monitored using BLUP (Best Linear Unbiased Predictor) type

statistical analysis techniques, ranking all the individuals in the programme according to their gain value. The variables to be

improved are growth (wood volume), survival, wood density, pulp yield and rooting. Adding qualitative information on resistance

to diseases and pests to the programme is done in addition to the genetic gain and can have a restrictive effect on selection.

Periodically, successively better clones are identified in one or more of the criteria mentioned, which are recommended to Aliança

Viveiros (clone portfolio) for large-scale plant production. [ESRS 2.80f]

It should be noted that climatic conditions and resistance to pests and diseases require the development of customised solutions,

with a broader portfolio that allows choices of genetic material better adapted to different local soil and climate conditions (cold,

dryness, biotic risks). The solutions serve not only Navigator, but also the forestry producers who access the plants produced in

our nurseries, thus promoting the environmental and economic sustainability of the industry and contributing to the development

of the forestry sector. [ESRS 2.80f]

Increasing the reach and effectiveness of the e-globulus platform among Portuguese forestry producers is one of Navigator's

targets for sustainable forest management. This platform is a tool that encourages responsible and sustainable forest

management and contributes to technical training. It is aligned with the dissemination of good practices and the transfer of

knowledge to the public (forest owners, forestry technicians and other interested organisations, academia and others) [ESRS

2.80a]. The e-globulus platform aims to encourage the adoption of forest management practices that are adjusted to the local

reality. It is a knowledge transfer tool that can be used by Navigator, forestry producers and other organisations in the sector,

among others. The platform's appeal to users is assessed quantitatively and, as with other online platforms, by monitoring the

evolution of recorded indicators, such as the number of users and visualisations. [ESRS 2.80f]

Water resource management is extremely important for forestry production. The continuous improvement of management

practices is based on the technical and scientific knowledge that is being produced. We don't just study experimental basins; we

also continually invest in understanding the influence of soil and climate on the productive capacity of stands and in studying

silvicultural practices adjusted to local conditions. We consider plant growth and also the conservation and greater retention of

water in the soil. This goal is related to a research project, in partnership with the University of Aveiro, which consists of

monitoring two instrumented experimental basins to assess water availability (quality and quantity), trying to understand the

dynamics of the hydrological response throughout the development cycle of the stands. In addition, this data is used to feed

hydrological modelling (with the SWAT model - Soil and Water Assessment Tool), and scientific papers have already been

published in international journals and disseminated at scientific congresses. [ESRS 2.80f]

The goals involved internal and external Stakeholders through different forums and structured dialogue mechanisms, such as the

Environmental Council and the Sustainability Forum, seeking to ensure transparency and alignment with the expectations of

Communities, Authorities and Experts. [ESRS 2.80h]

During 2024, no changes were made to the target value, target year, calculation or data collection methodology, assumptions,

sources or limitations. However, new goals have been reformulated and defined, with a view to continuous improvement. [ESRS

2.80i]

Target performance

ANNUAL REPORT 2024 • MANAGEMENT REPORT 223

Name

Target performance in 2024

[ESRS 2.80j]

Ensure that the Company’s wood

consumption include no less than

80% certified wood by 2030

Compared to 2023, Navigator increased the use of certified wood in its processes by 4 pp. This goal is

progressing and the target set is expected to be reached before 2030.

Promote certification of the chain

of custody of all our wood

Suppliers by 2030

Compared to 2023, Navigator maintained its performance, continuing to work towards the target set. This

objective is in progress and is expected to be reached before 2030.

Introduce and promote the

establishment of natural enemies

for 2 eucalyptus pests

Two natural enemies of two important eucalyptus pests were produced in a biofactory and released in the

field. The effect of these natural enemies is being monitored in the field.

Identify at least one natural

enemy of Acacia dealbata and

introduce it to Portugal

Regarding new natural enemies, several species of acacia defoliators were imported from Australia, and

their potential is being studied by RAIZ to assess which species could be beneficial as biological control

agents.

Develop genetically improved

clonal and seed plants, with 30-

50% productivity gains and

resilience to climate change

Every year, the target is reviewed in a meeting with internal Stakeholders in order to prioritise criteria for

selecting genetic materials (growth, survival, wood quality, rooting, resistance to pests and diseases),

analysing the trend of genetic gain in the portfolio. The incorporation of three new genetic materials into

the clonal plant portfolio will improve the performance of Aliança Nurseries in terms of phytosanitary

control (in relation to Neopestalotiopsis), greatly strengthening the clonal solutions for reforestation in

areas with a high-water deficit.

Increase the reach and

effectiveness of the e-globulus

platform among national forest

producers

In 2024, headings were strengthened (e.g. ‘is-Science’), functional improvements were developed and

new content was produced. The platform is kept responsive, functional and updated for public

consultation. The trend in use and interest in the platform is monitored by Google Analytics indicators.

Monitor impact of production

forests on water management

In 2024, the study on the impacts of climate change on the two national forested basins with contrasting

soil and climate conditions was deepened, particularly with regard to water and biomass production, and

the assessment of the water scarcity/availability index.

Launch the Navigator “Clube

Produtores Florestais” (Forestry

Producers Club)

Goal achieved in 2024, with the celebratory meeting.

Consolidated Forestry Producers

project, promoting and

disseminating technical

information about forest

production, helping to share best

practices, by 2030

4 editions of the magazine, with an average print run of 15,000 copies; more than 200 pieces of digital

content; 10 exhibitions in the agroforestry sector in Portugal and Galicia; 130 participants in the 4th

Meeting of Forestry Producers; 1 forestry fundraising campaign in the Galicia region.

Impact on a community of more than 18,000 people.

Help reduce rural fires, seeking to

ensure that the burned area

under Navigator's management

stays below 1% each year

In 2024, the focus on fuel management was maintained as a priority, and efforts were made to provide

fire-fighting support within the scope of Afocelca, in order to improve intervention capacity in fires that

jeopardise Navigator's assets. The extreme weather conditions in September 2024, combined with other

factors, boosted the occurrence and spread of rural/forest fires in the Centre and North of the country,

thus affecting a significant area of the Company's assets under management, leading to an increase in the

area burnt in relation to the total under management (≈2.7%).

ANNUAL REPORT 2024 • MANAGEMENT REPORT 224

Name

Target performance in 2024

[ESRS 2.80j]

Ensure that the stock of CO

sequestered in the forest holdings

under Navigator's management

does not fall by more than 10% in

relation to 2022 (baseline year),

by 2030

In 2024, we are looking at a positive evolution of 226 kt in the stock of CO

sequestered in the forest area

under Navigator's management. We have yet to finalise how to account for carbon in the soil, following on

from the work started last year with RAIZ.

5.2.6.3.2. Impact metrics related to Sustainable Forest Management (MDR-M)

Metrics

2024

sequestered in our forests

Portuguese forests, detained by Navigator 6.4 Mt CO

Area of eucalyptus 5.3 Mt CO

Area of cork oak, coniferous and other forest species 1 Mt CO

Agricultural areas, with shrub or bush species 0.16 Mt CO

Portucel Moçambique eucalyptus forest 2.7 Mt CO

Total 9.1 Mt CO

Certified forest area in mainland Portugal

Certified forest area in mainland Portugal, both via FSC

and PEFC 108,654 ha

Segregation by type of area under management in mainland Portugal

Area of eucalyptus 79,791 ha

Area of other forest species

10,023 ha

(9% managed area by Navigator)

Area of other land use

20,104 ha

(18% managed area by Navigator)

Total area managed

Area in Portugal 108,807 ha

Area in Spain 1111 ha

Area in Mozambique 26,932 ha

Total 136,850 ha

Total hectares of owned, leased or managed forests that have been converted

to plantations or non-forest land use since 2020

Area in Portugal 0 ha

Area in Spain 0 ha

Area in Mozambique

0 ha

Number of trees planted

Number of trees planted in Portugal

3.4 M

Number of trees planted in Mozambique

0.3 M

(Eucalyptus grandis urophyla plants)

Total

≈3,7 M

ANNUAL REPORT 2024 • MANAGEMENT REPORT 225

Metrics

2024

Number of plants produced in nurseries

Nurseries in Portugal

7,731,275

(forest and ornamental plants)

Nurseries in Mozambique

1,519,755

(only Eucaliptus spp)

% Burnt area under Navigator's management

Portugal continental

2.66%

(% in ha)

Moçambique

e-globulus

Number of total users

27,733

(cumulative)

Number of views

91,854

cumulative)

Number of registered users

1,040

(cumulative)

Number of news, events and updates

+ of 35

“Clube Produtores Florestais” (Forestry Producers Club)

Number of registered users

367

Turnover

€538 M

Number of Employees and members

2,680

Investment in infrastructure and services for forest fire defense

Investment in forest fire prevention and support in Portugal

€8.80 M

Afocelca's activities in Portugal

€3.02 M

Clearing and vegetation control activities in Portugal

€5.40 M

Maintenance of paths and firebreaks in Portugal

€0.46 M

Provision of specific PPE in Mozambique

€2448

Fire Prevention and Fighting Services - Human and material resources in Mozambique

€101,673

Manual digging vs. harrowing in Mozambique

€147,113

Cold burning (controlled fire) in Mozambique

€161,157

Pre-fire weeding in Mozambique

€107,828

Supply of certified wood

Certified wood in the National market

72.94%

Certified wood in total wood purchased - National and international markets

73.39%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 226

5.3. Social Information

5.3.1. ESRS S1 – Own workforce

5.3.1.1. Strategy

5.3.1.1.1. Material impacts, risks and opportunities and their interaction with the strategy and business

model (ESRS 2 SBM-3)

Description

Impact, Risk

or Opportunity

Time Horizon

Location

in the value chain

Sub-topic or related

sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

Improvement of job

security of Workers with

fixed-term and open-end

contracts.

Positive impact - Own operations Job security

Shift work impacts on

quality of life and physical

and mental health.

Negative Impact - Own operations Work schedule

Paying attractive salaries

(monetary benefits) and

granting non-monetary

benefits promotes

employee satisfaction.

Positive impact - Own operations Adequate wages

Paying attractive salaries

(monetary benefits) and

granting non-monetary

benefits promotes

employee satisfaction.

Opportunity

Short Term -

Reporting year

Own operations Adequate wages

Promoting social dialogue

between the Management

and Workers'

representatives leads to a

greater involvement of

Workers regarding common

interests and may impact

Workers' conditions.

Positive impact - Own operations Social dialogue

Positive impact - Own operations

Freedom of association, the

existence of works councils,

plus information,

consultation and

participation rights of

Workers

Greater bargaining power

of Workers covered by

collective bargaining.

Positive impact - Own operations

Collective bargaining,

including the percentage of

Workers covered by

collective agreements

Work-life balance improves

the health and well-being of

Employees

Positive impact - Own operations Work-life balance

Workforce empowerment

and continuous skill

assessment assist

Employees' professional

and personal growth.

Positive impact - Own operations

Training and skills

development

ANNUAL REPORT 2024 • MANAGEMENT REPORT 227

Description

Impact, Risk

or Opportunity

Time Horizon

Location

in the value chain

Sub-topic or related

sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

We guarantee equal pay for

work of equal value in the

geographies we operate in.

Positive impact - Own operations

Gender equality and equal

pay for work of equal value

At Navigator, there is

currently a rejuvenation

program ongoing, allowing

Employees from the age of

57 to join it, interrupting

their cycle in the

Organisation. This program

has the advantage of

granting better economic

conditions to the Employees

covered, in light of their

current job situation, thus

allowing them to interrupt

their professional activity

before the legal retirement

age.

Positive impact - Own operations Diversity

At Navigator, there is

currently a rejuvenation

program ongoing, allowing

Employees from the age of

57 to join it, interrupting

their cycle in the

Organisation. This program

offers clear benefits for the

Company, allowing it to

"renew" its workforce, with

all the resulting advantages

(e.g. absenteeism).

Opportunity

Medium Term -

Between the

reporting year and

up to 5 years

Own operations Diversity

A lack of gender

representation and age

diversity creates less

inclusive and equitable

environments, reducing

innovation and a sense of

belonging.

Negative Impact - Own operations Diversity

Accidents at work or

occupational diseases lead

to fatalities, injuries or

other pathologies

Negative Impact - Own operations Safety and health

Non-compliance with

occupational safety rules

and procedures adversely

affects the health and

safety of Workers

Negative Impact - Own operations Safety and health

Implementing programs

and policies promoting a

safe working environment,

including training in safety,

ergonomics and well-being,

tends to increase

satisfaction, productivity

and positively influences

the Company's reputation,

reducing the number of

occupational accidents

Opportunity

Short Term -

Reporting year

Own operations Safety and health

ANNUAL REPORT 2024 • MANAGEMENT REPORT 228

Description

Impact, Risk

or Opportunity

Time Horizon

Location

in the value chain

Sub-topic or related

sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

Note: The identified material impacts are real and not time-specific.

Our human capital represents a priority for Navigator and is the focus of continuous and structured investment to promote its

development, evolution and sense of accomplishment. Proof of the importance of Talent Management is the direct supervision

by the CEO of The Navigator Company. The Human Resources department is headed by a member of the Executive Committee.

This structure highlights the strategic role of our Employees in the sustainability and future of our business and the social and

economic impact generated in the local communities we operate in (Chap.

5.3.3).

Our approach to people management is based on the stability of working arrangements, the appreciation of merit, growth

(internal progression and continuous skills development) and the promotion of safe working environments for about 4,000

Employees. Navigator seeks to be a reference employer, betting on the satisfaction of its workforce, which translates into

greater productivity, the ability to attract young talent and the retention of qualified professionals, thereby positively influencing

the Company's reputation. [ESRS S1.14d] [ESRS S1.13b]

Navigator's workforce includes Employees with a contractual relationship with the Group and non-employees (temporary

workers). The latter are subdivided into two groups: workers hired through temporary employment agencies and non-employees

providing services or manpower to Navigator through explicit contractual agreements. Currently, the number of non-employees is

small and so therefore they were not considered in the scope of this profit and loss account. [ESRS S1.14a]

We actively invest in promoting the safety, health and well-being of our Employees and acknowledge the relevance of these

dimensions for both quality of life and productivity. We are aware of the impacts inherent to our operations, including the

possibility of occupational accidents and diseases, and we are firmly committed to creating a safe and healthy environment.

Events like these, aside from impacting our Employees and their families, may also compromise the achievement of our health

and safety objectives. We thus promote a culture of Occupational Safety and Health (OHS) that aims at, in a sustained

manner, minimise risks, reduce accidents at work and eradicate occupational diseases. Conducting business in a responsible

manner also helps us reduce costs and mitigate risks for people and workers in the value chain (Chap.

5.3.2), Communities (Chap.

5.3.3

) and environment (Chap. 5.2) – especially in the context of our industrial units and forestry operations – and ensure the

preservation of facilities and equipment. [ESRS S1.13a] [ESRS S1.14d]

The identified negative material impacts include both systemic impacts and individual incidents. Shift work and a lack of

gender representation and age diversity are examples of systemic impacts that can, respectively, affect the quality of life and

physical and mental health of shift Workers, and create a less inclusive and equitable environment, reducing innovation and a

sense of belonging, thus adversely affecting the organisational culture and productivity. See also occasional incidents, e.g.

accidents at work resulting from non-compliance with safety standards, which may compromise the health and safety of

Employees. [S1.14b]

Navigator adopts several practices that generate significant positive impacts on the well-being and development of its

Employees, and in particular of its employees in the several regions Navigator operates in. [S1.14c] The offer of attractive

salaries and benefits, together with continuous training and work-life balance, contributes to Employee satisfaction,

growth and well-being. Social dialogue and collective bargaining promote the improvement of working conditions and

encourage involvement and active participation of Employees in the organisation. The rejuvenation program, offering economic

advantages for older employees, reflects Navigator's commitment to the well-being of all its Workers. Furthermore, moving from

fixed-term to open-ended agreements provides job security, reinforces Employee stability and satisfaction, aligning with our

mission of providing a stable and secure professional path. Finally, equal pay for work of equal value proves our commitment

to fairness and justice in the workplace, reinforcing Navigator's culture of inclusion.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 229

Our workforce is predominantly male, a gender imbalance historically influenced by the physical demands of forestry and

industrial jobs. We are well aware of this challenge and take on the responsibility of promoting a culture of equity, committing

ourselves to value diversity, gender equity and inclusion, effectively ensuring equal opportunities in the workplace. [ESRS

S1.13a] [ESRS S1.14d]

After an internal assessment carried out by Navigator, no Employees with specific characteristics or in a particular context who,

when carrying out their activities, were exposed to increased risk of damage were identified, according to the impacts and

opportunities identified in the materiality assessment. [S1.15] On the other hand, we highlight the rejuvenation program, a

measure aimed at a specific workforce group, well-being of older Employees and optimisation of Navigator's human resources

management. [S1.16]

We are well aware of our role in building a fairer and more sustainable society by conducting our operations and activities based

on a responsible corporate culture and ethical principles. We thus reaffirm our commitment to respecting Human Rights in all

our operations and the value chain, ensuring that we promote decent work environments free from any form of exploitation, as

expressed in the commitments of our Human Rights Policy. In this context, the Group has not identified, in its operations,

countries or geographical regions with an increased material risk of forced, compulsory or child labour. [ESRS S1.14f] [ESRS

S1.14g]

As a company, we undertake to catalyse change and positively influence society, promoting a positive and lasting impact. The

material impacts, risks and opportunities identified cover all our Employees and may change depending on the location and

country. [ESRS S1.14] It is worth mentioning that the material impacts on our human capital do not result from transition plans to

reduce negative environmental impacts or climate neutrality, but from our continued commitment to valuing people and creating

safe and equitable working conditions. [ESRS S1.14e]

5.3.1.2. Impacts, risks and opportunities management

5.3.1.2.1. Policies related to own workforce (S1-1, MDR-P)

We assume the importance of respect for Human and Labour Rights and our commitment to value diversity, gender equity and

inclusion as an integral part of the global development of our business activity, through the adoption and implementation of

several internal instruments, of which the following stand out: the Code of Ethics and Conduct; the Human Rights Policy; the

Equality Plan. In addition, and concerning the promotion of occupational safety and health, we refer to the Major Accident

Prevention Policy (MAPP), in line with the objectives established in the Management Systems Policy [S1.20 | S1.23 |

S1.24a | S1.24c | S1.24d]. We seek, whenever possible, to adjust and align practices in the different geographies we operate in,

ensuring coherence and alignment with our principles and strategic objectives.

The Code of Ethics and Conduct

reflects the values and commitments that guide our performance, promoting integrity,

transparency and responsibility. This Code ensures decent working conditions for Employees and expressly prohibits child and

forced labour, in line with the ILO Conventions and the Universal Declaration of Human Rights [ESRS 2.65d | S1.20 | S1.21 |

S1.22]. It is complemented by the Code of Conduct for Suppliers (Chap.

5.4.1) and by the Internal Regulations and Good

Practices Guides for Occasional Workers and Service Providers of Portucel Moçambique. [AR13]

Within the scope of non-discrimination, the Code of Ethics and Conduct establishes that Employees must not act in a

discriminatory manner with other Employees or to any persons, namely based on race, religion, sex, sexual orientation, ancestry,

age, language, territory of origin, political or ideological beliefs, economic situation, social context or contractual relationship,

fostering respect for human dignity as one of the basic principles of the culture and policy followed by Navigator [S1.24b |

S1.24c]. In addition, this document is complemented by

the Code of Good Conduct for Preventing and Combating Harassment at

Work. [S1.24a]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 230

For Navigator, respect for human dignity as a fundamental right is an essential ethical issue and one of the basic principles of our

Group's culture and policy. We are convinced of our role in building a better society by conducting operations and activities based

on a responsible corporate culture. Under our Human Rights Policy

we put measures in place to ensure that the Human and

Labour Rights of all those establishing a relationship with the Navigator Group are respected. We also undertake to promote

measures to identify the main impacts and potential risks of Navigator in the field of Human Rights, namely through due diligence

processes, and to implement appropriate measures to prevent, mitigate and remedy possible non-compliance situations. To

ensure the implementation of these commitments, this Policy defines a matrix of responsibilities associated with its governance

model, establishing the specific powers of each area, board and commission involved and ensures a clear and efficient

management of the activities provided for therein. [S1.20 | S1.21 | S1.24d]

We are committed to respecting Human Rights, in our operations and value chain, under the principles established in the

International Charter of Human Rights, the OECD Guidelines for Multinational Enterprises, the Fundamental Conventions of the

International Labour Organization and the United Nations Guiding Principles on Business and Human Rights, and are signatories to

the English and Portuguese versions of the “CEO's Guide on Human Rights”, published by WBCSD and BCSD Portugal,

respectively, with other companies at the international and national levels. [S1.20 | S1.21 | S1.22 | S1.24c]

The documents guiding our responsible conduct and in the commitments made by the Navigator Group contain and acknowledged

a broad list of Human Rights, such as: freedom; equality and dignity; non-discrimination and coercion; freedom of thought,

conscience and religion; prohibition of slavery and child labour; health and safety at work; recognition of freedom of association

and collective bargaining and equal and gender opportunities. [S1.24a | S1.24c]

It's also worth mentioning that, on the operational work fronts in Mozambique, the Community Liaison Agents (Chap. 5.3.3) also

assess aspects related to Human Rights, such as the existence of child labour. Due to the existence of a minority Shareholder –

International Finance Corporation (IFC) –, Mozambique's operations are governed by the Performance Standards (PS) of this

institution, of which we would like to highlight PS2: Work and Working Conditions and PS4: Community Health, Safety and

Security. [S1.20] | S1.21]

Our Human Rights Policy, in line with the principles set out in the Code of Ethics and Conduct, expressly prohibits child labour,

forced labour and other forms of modern slavery (including human trafficking). We therefore undertake not to employ people

under these conditions nor tolerate labour exploitation practices. [S1.22]

In our Policy, we are also committed to valuing diversity, gender equity and inclusion, to effectively ensure equal

opportunities in the workplace. This commitment extends to Migrant Workers and Persons with Disabilities, ensuring the absolute

prohibition of any form of discriminatory conduct, whether in the relationship with Employees (or with local Communities – Chap.

5.3.3). [S1.24a | S1.24b | S1.24c]

To duly implement the structuring instruments mentioned above, the first step would be to prevent and avoid situations of

discrimination is the training and awareness of our Employees. To this end, we offer training on Ethics and Integrity to all

Employees to reinforce the importance of the rules provided for in the internal instruments on Human Rights. [S1.24d]

Within the scope of Diversity, Equity and Inclusion (DEI), it is worth mentioning that we have implemented a governance

model with the identification of a person in charge and a committee, reporting to the Board of Directors, supported by a broad

multidisciplinary working group, which emerged aimed at strengthening the diagnostic model, proposal and implementation of

internal initiatives and projects in this field. In this model, the creation of the Equality working group takes into account

gender, age, nationality and professional experience diversity, and its members represent the boards most directly involved in the

strategy and monitoring of the theme [S1.24a]. To strengthen gender equality in its different dimensions and the Navigator

Group's practices in this field, as well as to continue the development of policies that facilitate the reconciliation of personal, family

and professional life, several measures were implemented as provided for in the Gender Equality Plan 2024 and the

Equality

Plan 2025 was defined. [S1.24a]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 231

Document

Equality Plan

Description of key

contents and general

objectives

[ESRS 2.65 a]

Its main objective is to promote and ensure a level playing field within the Company to eliminate discrimination,

especially concerning gender. In addition, it aims at creating an inclusive environment that recognises and values

diversity, providing equal opportunities for all employees.

Scope

[ESRS 2.65b]

It focuses on the company's operations and impacts Employees in Portugal.

Most senior level

position accountable for

its implementation

[ESRS 2.65c]

Executive Committee

Standards or third party

initiatives

which the Company

undertakes to comply

with

[ESRS 2.65d]

Availability

[ESRS 2.65f]

This document is shared with all Employees through the Intranet and Internet sites.

The Company translates the remuneration

policy of its Employees based on the career model structured around functional

families, aiming at promoting equal pay, competitiveness and retention of talent, aligning professional progression with merit and

organisational growth. It includes mobility guidelines, structured career plans and continuous training programs to develop team

skills. Under the new Career Plan for Operational Technicians, skill training programs have been created, and a new

registration and monitoring system has been implemented that can be monitored directly by the managers. This model allows

teams to continuously acquire skills and develop their professional potential based on a number of factors provided for in the plan.

This approach was defined jointly by the Human Resources Department (career plan) and the Compensation and Benefits

department (rewards program) and approved by the Executive Committee, in line with the OECD Guidelines for Multinational

Enterprises, Fundamental Conventions of the International Labour Organization and the United Nations Guiding Principles on

Business and Human Rights.

Navigator has an Occupational Safety and Health Management System (OSHMS) governed by ISO 45001 and covering

internal and external Employees. We undertake to provide a safe and healthy work environment, preventing occupational injuries

and diseases, in line with the ILO Declaration on Fundamental Principles and Rights at Work and the United Nations Guiding

Principles on Business and Human Rights. This commitment is operationalised through [S1.23]:

• Identification and control of risks associated with work activities and implementation of preventive measures.

• Continuous training of Employees and partners, promoting a safety culture.

• Definition of clear responsibilities and allocation of adequate resources to ensure compliance with safety standards and

objectives.

• The implementation, monitoring and assessment of practices promoting occupational safety and health, thus reinforcing the

protection of direct and indirect workers. This system includes:

1) Continuous risk assessment, considering the dynamics of operations and the introduction of new technologies.

34 Set of practices that, although not formalized in a “policy” document, are in force.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 232

2) Consultation and involvement of Employees, encouraging their active participation in the improvement identification.

3) Incident and accident management, including investigation, reporting and corrective measures to prevent recurrences.

Through the Management Systems Policy

, we are committed to creating shared value with society, promoting quality,

sustainability, safety and innovation in our operations, and ensuring compliance with legal and ethical obligations, from a

continuous improvement and sustainable development perspective. As commitments made and with an impact on our Employees,

we would like to emphasise:

• Provide safe and healthy working conditions for the prevention of work-related injury and ill-health, following the principles of

continuous improvement;

• Implement social responsibility practices, particularly for the benefit of Employees and local Communities where it develops

its industrial and forestry activities;

• Promote consultation and participation of Workers, as well as their personal and professional development, encouraging

initiative, innovation, productivity and commitment to achieve the goals.

The Major Accident Prevention Policy (MAPP)

addresses the management of risks associated with the handling of hazardous

substances by ensuring [S1.23]:

• The protection of human health and the environment through robust hazard control and management systems;

• Operationality of the Internal Emergency Plan, in articulation with external entities, to ensure an effective response to risk

situations;

• Periodic review of the management system to incorporate learnings and maintain effectiveness.

These instruments are interconnected and are based on our commitment towards continuous improvement, health and safety of

our Employees and the sustainability of our operations [S1.23]. It is also worth mentioning our “Mission Zero” Health and Safety

Strategy, under which several actions were identified and implemented (see Section S1-4). By integrating these policies and

systems, we promote a holistic approach to occupational safety and health, aligned with our sustainability, excellence and

innovation values. Hence, we ensure compliance with legal and voluntary duties, the well-being of our Employees and the

protection of Communities and the environment. [S1.23]

Document

Major Accident Prevention Policy

Description of key

contents and general

objectives

[ESRS 2.65 a]

This policy highlights the commitment to prevent major accidents involving hazardous substances, promoting

continuous improvement, compliance with legal requirements, the safety of operations, training of stakeholders and

protection of human health and the environment.

Scope

[ESRS 2.65b]

Focuses on the company's industrial operations in Portugal and impacts Employees,

Stakeholders (essentially Service Providers and External Employees) and Local Communities.

Most senior level

position accountable for

its implementation

[ESRS 2.65c]

Executive Committee

Standards or third party

initiatives

which the Company

undertakes to comply

with

ANNUAL REPORT 2024 • MANAGEMENT REPORT 233

[ESRS 2.65d]

Availability

[ESRS 2.65f]

This document is communicated to all Employees, Business Partners and Stakeholders

through the Intranet and Internet sites.

It is also posted in the workplace.

References throughout

of the non-financial

Statement

S2 – Workers in the value chain (Chap. 5.3.2)

It is also worth mentioning that we are developing a Health and Wellness Policy [ESRS 2.62] establishing guidelines to

strengthen the well-being of Employees. This policy includes guidelines for the modernisation of Medical Centres and continuous

improvement of Health Services, adoption of inclusive and personalised care, promotion of medical appointments and involvement

of Employees in the definition of health and well-being priorities, and implementation of emergency prevention and response

measures.

The following information is included by reference to other parts of the Non-Financial Statement (MDR-P, ESRS 2, §65 a/b/c/d/f):

• Presentation of the Code of Ethics and Conduct: Chap. 5.4.1

• Presentation of the Human Rights Policy: Chap. 5.4.1

• Presentation of the Management Systems Policy: Chap. 5.2.5

5.3.1.2.2. Processes for engaging both workers and workers' representatives about impacts (S1-2)

Open and transparent social dialogue has always been a major concern for Navigator, reinforced in recent years through the

promotion of regular communication with the different Workers' representative structures, to establish greater proximity and to

meet the objectives advocated by both parties in the labour relation [S1-27a]. Thus, not only did these structures and the

different operational areas and Navigator's Human Resources (HR) Department come closer, but direct dialogue has also been

encouraged with the Executive Committee and the Director in charge of the HR department. [S1-27]

A clear example of this type of initiative is the Labour Forum, relying on the presence of the Executive Committee and the

Workers' Representative Organisations (WRO) of all Navigator sites and business areas, and all Industrial Directors, Human

Resources, Legal Services and Safety Departments. In this forum, a perspective on the evolution of different businesses, current

and future challenges and the evolution of the global context is shared. Labour-related issues of interest to Workers are discussed

here. It is worth mentioning the importance of social dialogue in the labour negotiation processes, which resulted in a multi-

annual agreement covering the period from 2022 to 2023 and its renegotiation to cover the 2024/2025 period [S1-27]. To this

extent, in addition to signing atypical deal agreements, the following collective regulation instruments were also amended

[S1-27a]:

• The Navigator Company's Company Agreement entered into with Fetese;

• The Navigator Company's Company Agreement entered into with Fiequimetal;

• Navigator Tissue Ródão and Navigator Tissue Aveiro Collective agreements, entered into with the Fiequimetal and Fetese trade

union structures.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 234

Regular meetings are held with workers representation organisations (WRO), through monthly or bimonthly meetings, in all

manufacturing units, promoted by the Manufacturing Boards and the Human Resources Boards. In these meetings, topics related

to the evolution of business, safety of facilities and people, human resource issues, such as career plans, working hours, social

benefits, labour negotiations, among others, are addressed. [S1-27b]

In Mozambique, we hold annual meetings with both Workers and Service Providers during which we communicate the project

progress and gather Employees' opinions. In addition to these general meetings, the Company further hosts meetings with the

second lines of management to inclusively discuss topics relevant to the project [S1-27a]. The responsibility for ensuring this

dialogue rests with the Managing Director. [S1-27c]

The effectiveness of the dialogue can be assessed through the voluntary turnover rate, which is quite low (4.7%), a clear proof

of the level of satisfaction of Employees working in the Organisation. [S1-27e]

We also have a Whistleblowing Channel in place, allowing us to report irregularities and/or infractions, and we conduct

consultations with Employees and organisational climate studies (see the following sections). [S1-27]

5.3.1.2.3. Processes to remediate negative impacts and channels for own workforce to raise concerns (S1-

In the conduct of our activities and our interactions with all Stakeholders, we consider it essential to promote a culture based on

transparency and trust to have mechanisms that facilitate the identification, communication and investigation of concerns related

to illegal behaviour or contrary to the Code of Ethics and Conduct or other internal regulations [S1.32 a | S1.32d]. To this end, we

have implemented a Whistleblowing Channel

(Chap. 5.4.1) and the following complementary channels, where Employees can

express their concerns or needs [S1.32b]:

• Organisational Climate Study, carried out every 2 years, covering all employees.

• “CRESCER” (GROWING) project, aimed at improving the "commitment and sense of accomplishment" of our staff, with a

page available on the intranet with the possibility of interactions on the several contents, including a dedicated space for new

suggestions, feedback or comments.

• Communication channels and transversal documents applicable in Portugal, to better address doubts and questions of

Employees, namely:

1) Employee Guide, with a summary of the main HR policies and processes in force, distributed on paper to all Employees

and with an e-book version available on the intranet (published in 2024);

2) HResolve Portal, with customisation of interlocutors for the themes where employees have questions for a more agile and

fast response, capable of monitoring the KPIs for continuous improvement.

3) Implementation of a chat bot to answer Employees questions (prepared in 2024, to be launched in 2025);

There is also a process specifically defined for those not happy with their Performance Assessment. Complaints are submitted

on the RHesolve Portal or by email, within 15 days after receiving the assessment, and the process is analysed by the

Performance and Careers (P&C) department in partnership with the Talent Business Partner, the Management and the relevant

Director. Navigator undertakes to provide a written response to the Employee and, where appropriate, the assessment is

changed. [S1.32c | S1.32e]

In Portugal, we annually carry out two consultations with Navigator workers on occupational health and safety, where,

through a digital and anonymous questionnaire, we identify strengths and development needs in Navigator's OHS area. The first

ANNUAL REPORT 2024 • MANAGEMENT REPORT 235

consultation covers internal and external Workers, while the second is intended exclusively for internal Workers. [S1.32c |

S1.32e]

In Mozambique, complaint boxes were installed at strategic points of the offices, to ensure that Employees can submit their

complaints safely and confidentially. In the case of Occasional Workers in the field, complaints can be forwarded through the

Technical Experts or Community Liaison Agents – through the complaint management mechanism for local Communities, as these

Workers reside in the local Communities -, who, in turn, direct them to the Company, through the Communication Technical

Experts, for analysis and resolution at the Management level. [AR30 | S1.32c]

We would like to stress that for the correct implementation of these structuring instruments and promotion of a culture of

compliance based on ethical and integrated performance, Navigator understands that the training of its Employees is

indispensable. To this end, we provide training on compliance, namely, Communication of Irregularities and Internal Policies.

[S1.33]

The following information is included as reference to other parts of the Non-Financial Statement: further information on following

up and monitoring the issues raised and addressed, and ensuring the effectiveness of the Reporting Channel (Chap.

5.4.1

5.3.1.2.4. Taking action on material impacts on own workforce, and approaches to managing material risks

and pursuing material opportunities related to own workforce, and effectiveness of those

actions (S1-4, MDR-A)

Navigator is strongly committed to the appreciation and well-being of its Employees, acknowledging the fact that the responsible

management of its workforce is essential to ensure a safe, inclusive and productive work environment.

We engage with our workforce, both directly and indirectly, through assorted processes that guide our decisions. In the field of

Occupational Health and Safety, we ensure that all Employees are consulted through an online survey, carried out twice a

year. The results of this survey are shared transparently, allowing everyone access to information and knowledge of the actions

defined based on the responses collected. [S1.39]

In addition, we foster collaboration between the Workers' representation structures, the several operational areas and Navigator's

Human Resources Department. At the same time, direct dialogue has been promoted with the Executive Committee, including the

Director heading the Human Resources department. [S1.39]

We continuously develop initiatives to strengthen organisational culture, train, improve working conditions and promote

safety and work-life balance of our Employees. We thus guarantee the implementation of actions to prevent, mitigate or

correct negative material impacts on the workforce, also further promoting positive impacts and opportunities identified as

material for Navigator. [S1.38a | S1.38c | S1.40b]

The Company ensures that its practices do not cause or contribute to negative material impacts on its workforce, through policies

and practices ensuring a healthy, safe and inclusive work environment. We ensure that working conditions comply with legal

regulations and best practices, promoting the well-being of Employees and preventing any form of exploitation or discrimination.

[S1.41]

On the other hand, definition of targets and analysis of associated metrics (see section “Targets and metrics”) allow the Group to

monitor the evolution of its performance, and the effectiveness of the actions implemented to better adjust the adopted

strategies. [S1.38d]

Among the main initiatives implemented throughout 2024, the actions developed and ongoing under the “CRESCER”

(GROWING) Project, the Health Month and the Zero Mission Strategy stand out. We also highlight the adhesion to the

UN Global Compact and participation, during the first half of 2024, in the Business & Human Rights Accelerator Program,

ANNUAL REPORT 2024 • MANAGEMENT REPORT 236

which helped us carry out a first-level assessment of the actual and potential impacts on our workforce, the value chain and the

Communities affected by its activity, identifying priorities for action. [S1.37 | ESRS 2.68]

Main actions Status

Scope

of the

action

Time Horizon Results

[ESRS 2.68 a]

[ESRS

2.68 a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68a | ESRS 2.68d | ESRS 2.68e]

Talent management and human capital development

Implementation of the “CRESCER”

(GROWING) Project - an organisational

culture evolution program

Execute

d and

planned

Own

operations, in

all units,

except the

new factories

in the United

Kingdom

Ongoing, since 2022

Helped establish relations between

Employees and is considered a success factor

to retain people in the organisation and

strengthen and train our leaders.

Also helps foster a sense of belonging and

fulfilment for Employees.

Consolidation of the results of the

initiatives already implemented under

the “CRESCER” (GROWING) Project

Planned

Own

operations, in

all units,

except the

new factories

in the United

Kingdom

2025

Consolidate project results by creating habits

and practices in the organisation.

Health Month, focused on to the theme

of Diversity and Inclusion

Execute

Own

operations in

Portugal

Ongoing, since 2018

Promote the participation and sharing of

good practices in the field of health and well-

being and publicise the several ongoing

programs. In 2024, it focused on the theme

of Diversity, Equity and Inclusion, where

several workshops and webinars were made

available to Employees, in particular:

• Cooking workshops “A place of

inclusion: Cuisine of the several

countries”

• Creation of an e-book to compile

recipes/ingredients used in the Health

Month cooking workshops

• Webinar "Stereotype with inclusive

dynamics - The (Pre)Concepts"

•

Workshop Obstacles to Inclusion: The

Stereotypes

•

Daily sentences on the intranet:

Multicultural moment

Implementation of the measures

provided for in the Equality Plan 2024

Execute

d and

planned

Own

operations

Started in 2024,

ongoing

Strengthening gender equality in its different

dimensions and the Group's practices in this

field, as well as to continue the development

of policies that facilitate the reconciliation of

personal, family and professional life. The

implementation of the 2024 Equality Plan

included the development and planning of

measures within the framework of the

Company's strategy, mission and values,

equal access to employment, training,

equality in working conditions, protection in

parenting, reconciliation of work with family

and personal life, and prevention of

harassment at work.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 237

DEI Project startup

Execute

d and

planned

Own

operations

Started in the last

quarter of 2024, and

continuing into 2025

At the end of the year, a new project on the

theme of Diversity, Equity and Inclusion

(DEI) called "DEI Diagnosis" began, with the

support of an external expert, aimed at

strengthening the Company's compliance in

terms of legal requirements, thus assisting

the development of a dedicated action plan

and support a consistent and integrated

evolution of the Company's strategy in this

matter.

Health, safety, and wellbeing

Mission Zero - Action 1:

Development of initiatives, focusing on

the areas of psychology, nutrition and

physiotherapy, to provide tools to help

the Employees covered improve their

quality of life and adapt to shift work

schedules

Execute

d and

planned

Own

operations in

Portugal

(Industrial

and Forestry)

Started in 2022,

ongoing

Psychological, nutritional and personalised

physiotherapy support

Results: Improvement of quality of life and

the ability to adapt to labour requirements,

with a particular focus on Employees doing

shift work.

Strengthening skills to adapt to work

challenges

Results: Reduction of complaints of fatigue

and muscle problems, improving productivity

and well-being.

Investigation and immediate response to

accidents

Results: Improvement in safety procedures

and Employees' confidence in Navigator's

response.

Direct worker involvement in problem

identification and problem solving

Results: Implementation of solutions aligned

with the real needs of Employees,

strengthening a sense of belonging and

appreciation.

Planned metric: Implementation rate of

actions proposed by Employees, from 2024.

Recognition and encouragement towards the

adoption of safe practices

Results: Increased motivation and

commitment to safety policies, contributing

to a safer organisational culture.

Number of recognised Employees: 133

Reduction in the number of accidents with

sick leave: 47 (2024) vs. 57/2023

Empowerment to avoid future impacts

Number of participations: 13 405

OVERALL result of all actions

Significant reduction in incidents over the

period, with a direct impact on meeting the

target of the Frequency Index =4.

Avoided sick leaves: 277 | Total recoveries:

321 | Partial recoveries: 137

ANNUAL REPORT 2024 • MANAGEMENT REPORT 238

Mission Zero - Action 2: dissemination of

hobbies and leisure activities

Execute

d and

planned

Own

operations in

Portugal

(Industrial

and Forestry)

Started in 2023,

ongoing

Mission Zero - Action 3: Implementation

of actions aimed at reducing the

occurrence of occupational accidents or

diseases

Execute

d and

planned

Own

operations in

Portugal

(Industrial

and Forestry)

Started in 2022,

ongoing

Mission Zero - Action 4:

Implementation of a penalty and

recognition regime associated with

compliance with occupational safety

rules and procedures

Execute

d and

planned

Own

operations in

Portugal

(Industrial

and Forestry)

Started in 2023,

ongoing

Mission Zero - Action 5: Empowerment

of Workers

Execute

d and

planned

Own

operations in

Portugal

(Industrial

and Forestry)

Started in 2023,

ongoing

Mission Zero - Action 6: Implementation

of programs and policies to promote a

safe working environment

Execute

d and

planned

Own

operations in

Portugal

(Industrial

and Forestry)

Started in 2021,

ongoing

Extension of the implementation of the

Zero Mission Strategy to all industrial

and forestry units in Iberia

Planned

Iberia

(Industrial

and Forestry)

2026

The extension of the Mission Zero strategy

aims at strengthening the physical and

mental health of Employees, promoting their

well-being and safety in the workplace. A

reduction in occupational accidents and

diseases is expected, as well as greater

compliance with safety rules and procedures.

In addition, the initiative contributes to

training and skills development, creating a

safer and more qualified working

environment.

Action Plan 2025

Planned

Iberia

(Industrial

and Forestry)

2025 - 2026

Improving health and safety.

Further actions

Participation in the Business & Human

Rights Accelerator Program - a UN

Global Compact program that

encourages companies from all sectors

to take concrete actions to protect

Human and Labour Rights.

Execute

Transversal

2024

Through participation in the program,

Navigator analysed and identified the main

risks for its workforce, the value chain and

the Communities affected by its activity. An

action plan was then developed and focused

on one of the identified salient issues –

Occupational Safety and Health – to ensure

continuous due diligence on Human Rights,

in line with the main risks identified, at a

later stage. In addition, the plan aims, in the

future, also to strengthen internal skills and

establish a solid basis for future analysis, as

well as for the implementation of risk

mitigation and remediation strategies.

The implementation of the actions under the Mission Zero strategy and the “CRESCER” (GROWING) Project required the allocation

of significant financial and human resources. [ESRS 2.69a | S1.43]

5.56 million euros were allocated to develop Mission Zero actions in 2024, e.g. capital expenditures (CapEx), and 2.14 million

euros pertaining to operating expenses (OpEx). In addition to the financial resources allocated 19 internal employees and 23

external employees (including health teams), helped implementing these actions [ESRS 2.69 to | S1.43]. For 2025, 6.4 million

euros. e.g. CapEx, and 2.5 million euros OpEx should be allocated. [ESRS 2.69 a | S1.43]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 239

400 thousand euros (OpEx) were allocated to the “CRESCER” (GROWING) Project in 2024. The Project implementation also

involved an internal team of 3 people and more than 100 Employees from different levels within the organisation's hierarchy. For

2025, 576 thousand euros (OpEx) should be allocated. [ESRS 2.69 a | S1.43]

The following information is included by reference to other parts of the Annual Report:

More information on the relationship between current financial resources allocated to actions or action plans and the most

relevant amounts are contained in the financial statements: ESRS 2.69b – Notes 2.3, 3.2, 3.3, 3.6 of the Annual Report

Financial Statements.

Talent management and human capital development

Aligned with the purpose, “It's the people, their quality of life and the future of the planet that inspire and move us”, The

Navigator Company created an internal, mobilising and organisational transformation project, transversal to the entire Group –

the “CRESCER” (GROWING) project. [ESRS 2.68a] Under the motto “That all Navigator people lead the future of the

Organisation, committed and accomplished”, the “CRESCER” (GROWING) project has 3 objectives:

1. Stimulate a Sense of Belonging

2. Improving Our Way of Working

3. Prepare Current and Future Leaders

In the diagnostic phase, held in 2023, we held focus group sessions with more than 200 Employees, resulting in a Roadmap of 29

initiatives, whose implementation is ongoing over 3 years. The work teams were given autonomy to implement the solutions,

create a dynamic of mobilising work and also bring employees closer to different areas, functions, generations and geographies

[ESRS 2.68a]. Within the scope of the “CRESCER” (GROWING) Project, the following actions implemented to prevent, mitigate or

remediate negative material impacts on the own workforce stand out [S1.38a]:

• Leadership with Purpose Manual + Lead Program - customised behaviour guide for Navigator leaders, later consolidated in a

training program;

• Recognition Program - to encourage the recognition and appreciation of the behaviours to be fostered in the Organisation;

• Employee Guide - compilation of human resources policies to facilitate the clarification of doubts and the integration of new

Employees;

• Referral Program - so that everyone can contribute to the create teams and the future of the Organisation;

• Development of several support tools: Leader Dashboard, Task Master to support prioritisation, People Plan, Quick Guides on

various topics, among others;

• Digital Forum: Aimed at stimulating digital literacy, disseminating Navigator's digital initiatives and enhancing Digital

communication;

• Navigator Family Tour – relaunch an internal program whereby Employees and families are invited to visit the industrial

complexes, now with differentiated activities for children under 12 years old who, for safety reasons, cannot move around

the industrial operations;

• Straight to the Top - STT2.0 – program to collect ideas for improving operational efficiency and reducing costs to reward

successful ideas from individuals or teams.

Every 2 years, within the scope of the several companies of the Semapa group, an organisational climate study is carried out for

all employees [S1.38b | S1.38c | S1.38d], the results of which allow us to reinforce and update the “CRESCER” (GROWING)

ANNUAL REPORT 2024 • MANAGEMENT REPORT 240

project roadmap. In 2024, and in addition to the Climate Study, a survey – Pulse – was conducted to delve deeper into themes

that required evolution or clarification, where, once again, all the Company's Employees were involved in the national territory and

international offices covered by the Climate Study. [S1.38b | S1.38c | S1.38d]

The Health Month, on the theme of Diversity and Inclusion, helped focus on some of the impacts, risks and opportunities

identified as priorities, namely the negative impact associated with the lack of gender representation and age diversity, correlated

with the creation of less inclusive and equitable environments, resulting in a reduction in innovation and the sense of belonging of

Employees. [ESRS 2.68a | S1.38a]

Health, safety, and wellbeing

Within the scope of the Mission Zero strategy, defined for the 2023-2026 triennium, an ambitious action plan was established -

based on the five pillars of the strategy: Monitoring and Control; Operational Excellence; Leadership; Skills; Behavioural Program

- which responds to the identified material impacts and opportunities, acting not only in the mitigation of negative impacts but,

above all, their prevention and promotion of opportunities. [ESRS 2.68a | S1.38a | S1.38c | S1.40b]

The Occupational Health (OH) team has developed several initiatives, especially in the field of psychology, nutrition and

physiotherapy, to provide tools to help the Employees covered improve their quality of life and adapt to shift work schedules.

Among the initiatives, the following stand out (Action 1):

• Workshops on sleep, with tips to improve sleep quality;

• Nutritional guidelines on what to eat before, during and after shifts;

• Recommendation of exercises to improve muscle structure throughout the day.

To promote work-life balance and the health and well-being of our Employees, the OH team, in partnership with several managers

and Employees, promoted the dissemination of hobbies and leisure activities, inspiring other Employees to join in. These actions

included (Action 2):

• Exhibitions, information leaflets and webinars;

• Promotion of physical exercise, through clarification sessions and explanatory leaflets;

• Face-to-face and Teams sessions during the working hours;

ANNUAL REPORT 2024 • MANAGEMENT REPORT 241

• Ergocoaching that, combined with physical activity at work, encourages not only exercise but also the improvement of

muscle condition. In 2024, these activities were extended to all Employees, including shifts, normal, operational and white

collar workers.

Within the scope of the pillars of the strategy that concern the Behaviour and Leadership, Operational Excellence and Competence

programs, among the actions implemented with the objective of reducing occupational accidents or diseases are the following

(Action 3):

• Gamification – development of a platform with weekly games and challenges on security, procedures, rules and good

practices;

• Safety Walks – more than 16,000 held in 2024, with behaviour correction and improvement of unsafe conditions identified;

• Safety Moments – daily sessions for operational teams to analyse and discuss relevant information related to events that

occurred in the previous week;

• Transversal Procedures – elaboration of standards on critical topics such as Work Permits, Risk Assessment and Lockout

Tagout (LOTO), and it is a very critical procedure related to the consignment of equipment and fluid lines;

• AGIR Accident Investigation – Serious and Irreparable Accidents, such as contact with chemicals, machinery/equipment or

work at height, are investigated within 24 hours, with presentation of conclusions to the Director in charge.

As a way of encouraging compliance with occupational safety rules and procedures, a penalty and recognition regime associated

with compliance was implemented (Action 4). This system:

• Recognises and rewards proactive, exemplary and participatory Employees;

• Penalises, via cardinal rules, productivity awards and disciplinary procedures, those who do not comply with the norms, rules

and procedures.

Recognising that the training of the workforce and the continuous skill assessment assists the professional and personal growth of

Employees, in 2024 more than 37,000 hours of safety training were provided (Action 5). New approaches were adopted in terms

of training, of which the following stand out:

• Role-play and gamification dynamics;

• The Industrial Challenge, which involved all Operational Technicians in discussions based on filming real situations of (in)safe

behaviours;

• Reinforcement of the training of Employees through the possibility of conducting e-learning and face-to-face courses.

It is also worth mentioning the focus on implementing programs and policies promoting a safe working environment, including

training in safety, ergonomics and well-being (Action 6), as a means to increase employee satisfaction and productivity and,

simultaneously, positively impact the reduction in the number of accidents, thus positively influencing Navigator's reputation. The

following initiatives stand out:

• Safety Month included the game "The Expedition", with practical exercises and team dynamics;

• The quarterly “Safety Conversations”, led by the Industrial and Forestry Directors, involving Supervisors and Operational

Technicians;

ANNUAL REPORT 2024 • MANAGEMENT REPORT 242

• The Supervisors Forum, dedicated to safety, identified programs to improve and proposals for new initiatives in 2025.

For 2025, in addition to continuing the 2024 actions, the following initiatives stand out [ESRS 2.68a]:

• Certification of safety leaders;

• Extend the recognition program to collective and service provider initiatives;

• Develop a security management platform;

• Carry out the improvement project of the winders/rewinders;

• Implement Near Miss campaigns, share good practices and incidents with the testimony of Employees.

The actions implemented under Mission Zero were developed to predict, cooperate and support the availability of solutions for

Employees directly impacted by the identified material impacts. These actions were fundamental to mitigate adverse effects and

promote the recovery and well-being of injured Workers. The results are presented in the following worksheet. [ESRS 2.68d |

ESRS 2.68e]

5.3.1.3. Targets and Metrics

5.3.1.3.1. Targets related to managing material negative impacts, advancing positive impacts, and

managing material risks and opportunities (S1-5, MDR-T)

Under our 2030 Roadmap, and aware of the importance of responsibly managing the impacts and opportunities related to our

Employees, we have established a set of strategic commitments to guide and monitor our journey. These commitments translate

into specific goals that reinforce the promotion:

• Of safe and responsible behaviours contributing to a true culture of safety and well-being, improving working

conditions, reducing work-related musculoskeletal diseases (WMSDs) and, consequently, occupational accidents and

diseases, ensuring a safe and healthy environment for our Employees and culminating in our ambition to achieve zero

accidents associated with our operations. [AR49a]

• The development and empowerment of human capital aligned with current and future needs contribute to the

qualification and employability of young people in the regions where we operate.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 243

Goal and Target Scope

Baseline

Associated

metric

Performance

Results to

achieve

2024 2023 2022

[ESRS 2.80c]

[ESRS

2.80d]

[ESRS 2.75 |

ESRS 2.80b]

[ESRS 2.80J]

[ESRS 2.80e]

Health, safety, and

wellbeing

Achieve Zero Accident

Target through

continuous

improvement in

safety, under the new

2021-2025 OHS

Strategy:

- Frequency index ≤2,

in 2030

Own

operations,

Iberia.

It includes

internal

employees and

external

workers

Baseline

value:

7.3

Baseline

year:

2022

Frequency

index

4.1

5.8

7.3

Results to

achieve:

Frequency

index (IF) ≤2.0

(Internal and

external

employees)

Year:

2030

Interim target:

Achieve a

Frequency

Index =2.6, in

2025 (Baseline

year 2022).

Achieve an

Occupational Accident

Frequency Index ≤0.3

in 2025

Own

operations in

Mozambique.

It includes

internal

employees and

external

workers

Baseline

value: 2.5

Baseline

year:

2022

0.36

1.6

2.5

Frequency

Index:

≤0.3

Year:

2025

<10% accidents

mischaracterised for

non-compliance with

rules and procedures

(new)

Own

operations,

Iberia.

It includes

internal

employees and

external

workers

Baseline

value:

49%

Baseline

year:

2022

<10%

accidents

mischaracterise

d for non-

compliance

with rules and

procedures

(new)

19%

(new goal

2024)

- - Results to

achieve:

<10%

Year:

2030

Develop the

Ergonomics Axis: 100

jobs intervened by

2030.

Own

operations,

Iberia.

Baseline

value:

Baseline

year:

2022

Intervened

workstations

(accumulated)

- Ergonomics

Project

202

(accumulate

d value)

(accumulated value)

(accumulated

value)

Results to

achieve:

100 jobs

intervened

Year:

2030

Develop the

Occupational Health

program by 2030:

- Work Capacity

Index (WIC): 45%

in 2030;

Own

operations,

covers all

geographies

except

Navigator

Tissue Ejea

and Navigator

Tissue UK

Baseline

value:

Baseline

year:

2020

Work capacity

index

Assessing

Employee

satisfaction

Since the

monitoring

of this index

is carried out

every 4

years,

the

revaluation

of the Work

Ability

Index (WAI)

will take

place in

2025.

Since the monitoring

of this index is carried

out every 4 years,

the revaluation of

the Work Ability

Index (WAI) will

take place in 2025.

97%

Since the

monitoring of

this index is

carried out

every 4

years,

the

revaluation

of the Work

Ability Index

(WAI) will

take place in

2025.

Results to

achieve:

45%

>95%

Year:

2030

ANNUAL REPORT 2024 • MANAGEMENT REPORT 244

Goal and Target Scope

Baseline

Associated

metric

Performance

Results to

achieve

2024 2023 2022

- Evaluation of

Employee

satisfaction with

the

program: >95%

97%

Talent management

and human capital

development

Establish partnerships

with educational

institutions in all

regions we operate in,

in the national

territory (universities

and technical schools)

and internship

programs, contributing

to the development of

skills and

employability of young

people.

Own

operations in

Portugal

Baseline

value:

Baseline

year:

2020

No. of actions

in universities

and technical

schools

No. of

internship

programs

No. of

actions in

universities

and

technical

schools.

Average of

execution of

the plan

above 90%:

100%, in

2024

(considering

only the

number of

job fairs).

No. of

internship

programs

Execution of

the

internship

plan in

2024:

80.85%

291

Internships1

professional

internships:

• 47

professional

internships

for

graduates

and masters

(27%);

• 125

professional

internships

Operational

Technicians

(73%).

Participation in 26

initiatives at

universities

(trade fairs, pitches

and presentations).

31 curricular

internships/dissertatio

n projects.

3 open sessions for

final year master

students at FCTUC,

Nova FCT and UA.

8 scholarships

awarded.

23 student group

visits to Navigator

factories (636

students).

109 professional

internships, of which:

• 51 professional

internships for

graduates and

masters, with

integration of 27.4%

of these in the staff;

• 58 professional

internships for future

Operators, with

integration of 67.2%

of these as

Operational

Technicians.

About 50%

integration of

professional

internships.

3 long-term trainees

(24-month program);

48 summer

internships.

Participation

in 19 job fairs

(face-to-face

and virtual).

6 pitch

sessions.

presentations

on the

Company and

Junior

Recruitment

Programs.

seminars/wor

kshops on

topics related

to the

Company's

activity.

3 open

sessions for

final year

master

students at

FCTUC, Nova

FCT and ISA.

11 meetings

between

Navigator

representativ

es and

Teachers

from

educational

institutions to

increase

synergies.

2 Merit

Scholarships

awarded at

Nova FCT.

Results to

achieve:

Year:

2030

Interim

targets:

- Integrate

20% of the

professional

internships

directed to

Boards

- Integrate

50% of the

professional

internships of

Operational

Technicians

ANNUAL REPORT 2024 • MANAGEMENT REPORT 245

Goal and Target Scope

Baseline

Associated

metric

Performance

Results to

achieve

2024 2023 2022

Joint protocol

with Altri,

Corticeira

Amorim and

Sonae Arauco

for the full

financing of

scholarships

in the field of

forestry

engineering

at the

universities of

UTAD/FEUP,

ISA and

ESAC.

8 student

group visits

to our

factories (242

students).

104

internships,

of which:

• 49

professional

internships of

Staff (47%);

• 55

professional

internships of

Operational

Technicians

(53%);

• 35 summer

internships.

9 long-term

trainees (24-

month

program)

welcomed

Cover 80% of

Employees with

individual

development plans

(IDPs) customised to

their professional

needs and projects, in

alignment with

Navigator's succession

needs, by 2030

Own

operations,

covers all

geographies

except

Navigator

Tissue Ejea

and Navigator

Tissue UK

Baseline:

Baseline

year:

2020

% of

Employees with

development

plans

customised to

their

professional

needs and

projects

31% of the

total number

Employees

with IDP

53% of

Technicians /

Specialists /

Managers

with IDP

31% of the total

number of Employees

with IDP

38% of

Technicians/Specialist

s/Managers with IDP

37% of the

total number

of Employees

with

IDP

76% of

Technicians/S

pecialists/

Managers

with IDP

Results to

achieve:

80%

Year:

2030

Adjusted

interim targets

in 2024:

ANNUAL REPORT 2024 • MANAGEMENT REPORT 246

Goal and Target Scope

Baseline

Associated

metric

Performance

Results to

achieve

2024 2023 2022

45% of the

total number of

Employees with

IDP in 2025

(Base year

2021);

60% of

Technicians /

Specialists

/Managers with

IDP in 2025

(Base year

2022).

Create awareness in

the teams about good

practices and ESG

sustainability

commitments by 2026

Portugal 2023 N/A The S-

pertise

Program was

created and

the syllabus

of the

Sustainabilit

y and ESG

training,

starting in

2025, was

structured.

The internal

Sustainabilit

y Hub

platform was

launched

with

sustainability

content for

employees.

- -

Until 2026 host

periodical

awareness

actions and

offer training

to 80% of

Employees.

Continuously monitor

the main motivational

stimuli of Employees

to achieve a better

adaptation of the

management

practices, policies and

processes

implemented.

Own

operations in

Portugal,

International

Offices and

Mozambique

2020

N/A

“CRESCER”

(GROWING)

Climate Survey

No. of Open

Days

“CRESCER”

(GROWING)

- 45%

implementati

on of the

roadmap of

initiatives

suggested

Employees.

Climate

Survey -

Average

result of

indicators

related to

satisfaction

and

engagement

: 65.4

(2023);

The Straight To The

Top program

covered 4 industrial

complexes, with the

following results:

35 ideas submitted;

1 award-winning

idea.

Organisational climate

survey witnessed a

73% participation

rate (the highest

value of all surveys

conducted at

Navigator).

Straight to

the Top

program.

Employer

branding

actions:

Onboarding,

Semapa

event.

“CRESCER”

(GROWING):

implementation

of 100% of the

roadmap in

2030.

Climate

Survey:

Average >70%

in the

indicators

related to

satisfaction and

engagement of

the climate

study.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 247

Goal and Target Scope

Baseline

Associated

metric

Performance

Results to

achieve

2024 2023 2022

We held 69

Open Days

in 2024 - 34

in the 1st

semester

and 35 in

the 2nd

semester.

Open days, in

a total of 69

sessions,

aimed at new

Employees

and people

already

integrated

into the

Organisation,

to foster the

transversality

of knowledge

between the

various areas.

The launch of

the

“CRESCER”

(GROWING)

project

included the

hosting of

listening

sessions with

the

involvement

of about 200

people,

whose inputs

should lead to

a roadmap of

initiatives and

actions to be

implemented

gradually and

consistently.

Target-setting process

In general, our targets are set through benchmarking exercises, considering the best practices in the sector and, in specific cases

(such as the percentage of the number of accidents mischaracterised due to non-compliance with rules and procedures and

interventions in jobs, for example), we consider the evolution of the results obtained over the last three years, in light of the

established action plan (bringing together several initiatives and actions) [S1.46 | ESRS 2.80f | S1.47]. The opinions of different

internal and external Stakeholders are also taken into account, through different forums and structured dialogue mechanisms

such as the Sustainability Forum, to ensure transparency and alignment with the expectations of Communities, Authorities and

Experts.

In the development of our goals, we seek on the one hand, to ensure the focus on the continuous development of our Employees,

in alignment with Navigator's strategic objectives and, on the other hand, we take into account the local context of the

geographies we operate in. In this context, it is worth mentioning our contribution to the qualification and employability of young

people, including in the inner regions of Portugal, where some of our factories are located. [S1.46 | ESRS 2.80f]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 248

To ensure effective monitoring of our performance against the established goals, we regularly monitor progress through daily,

monthly or quarterly evaluations, depending on the specific nature of each indicator. [S1.47]

We have also been developing several initiatives and moments of internal sharing, such as Safety Moments, Weekly Meetings,

quarterly industrial meetings, and local industrial meetings, ensuring regular and integrated performance analysis. The results are

submitted and presented and discussed in Steering Committees and in local and corporate OSH Committees, where corrective and

improvement measures are also defined [S1.47]. Furthermore, under our commitment towards continuous improvement, the

lessons learned, and the results obtained are widely disseminated, promoting a culture of safety and reinforcing the application of

prevention and penalisation measures whenever necessary. [S1.47]

In particular, the Zero Accident Goal and workplace interventions (Develop the Ergonomics Axis) were developed in alignment

with the Safety policy integrated into the management systems in order to provide safe and healthy working conditions for the

prevention of work-related injury and ill-health, following the principles of continuous improvement [S1.46 | ESRS 2.80 a]. To set

these targets we relied on the participation of Stakeholders, integrating information on internal and external Employees, who

receive training and information on the rules and procedures, as well as information on the penalty regime applicable in case of

non-compliance. [S1.46 | ESRS 2.80h]

Although we consider it essential to have a long-term action plan directing us towards achieving the commitments outlined under

our 2030 Agenda, we should be mindful of the fact that, as a corporate management tool, the Roadmap is not static. Annually, a

reflection is made that may lead to fine-tuning of some of the objectives set, establishment or adjustment of intermediate goals

and, in some cases, setting of new goals. In this context, we emphasise that, in light of the response to the ESRS Standards,

some adjustments were made, namely definition and/or explanation of the associated metric, base year, result to be achieved,

baseline, etc. [S1.46 and ESRS 2.80i]

Performance against targets

Health, safety, and well-being

Regarding our performance in 2024, we emphasise that, through the implementation of the Mission Zero strategic plan, we were

able to, after five years, achieve the much-coveted Frequency Index (FI) of 4.1 – an intermediate goal established for 2024 –,

showing the effectiveness of an integrated and multidisciplinary approach. This result is proof of everyone's effort, commitment

and dedication in building a safer working environment. It reflects an increasingly strong safety culture, where every action counts

and where the protection of our people always comes first.

Among the several actions carried out (see section S1-4), efforts were made in areas such as continuous training, with more than

37,000 hours of safety training, and the introduction of innovative methodologies such as gamification and role-play. [S1.46 |

ESRS 2.80j | S1.47]

The promotion of healthy practices, such as Ergocoaching and well-being activities, combined with the structuring of transversal

procedures for critical topics, contributed to an increasingly present safety culture. Initiatives such as Safety Walks, the

Supervisors Forum and Safety Talks were instrumental in involving all levels of the organisation in identifying risks and

implementing solutions. [S1.46 | ESRS 2.80j | S1.47]

It is also worth mentioning the fact that were able to meet the target established for 2030 before that date as regards the number

of jobs intervened (100) for ergonomics purposes and reached, in 2024, a cumulative total of 202 jobs intervened. [S1.46 | ESRS

2.80j | S1.47]

Regarding Mozambique, we have been monitoring the Frequency Index (If) since 2020, pointing to a continuous improvement

in safety through a significant investment in raising Communities' awareness as to the need to operate safely, educating Service

Providers traditionally focused rather on operations and less on safety and environmental issues. This work resulted in a reduction

ANNUAL REPORT 2024 • MANAGEMENT REPORT 249

in the Frequency Index from 2.5 in 2022 to 0.36 in 2024. However, to obtain a more comprehensive view, Portucel

Moçambique adopted, in 2024, the measurement of a Combined Safety Indicator, which integrates a Frequency Index (with a

weighting of 60%) and a Severity Index (weighting of 40%), thereby allowing a better assessment of both the number of

accidents with sick leave and their severity. A note on the absence of fatalities in Portucel Moçambique operations.

Talent management and human capital development

In 2024, several measures were implemented to promote and reinforce the construction of Individual Development Plans (IDPs),

consolidating a culture of continuous growth. Among the main initiatives, the prioritisation of Employees to benefit from this plan

stands out, ensuring broader access, and constant communication through multiple channels, such as email, intranet, webinars

and training. In collaboration with the Learning Centre, these plans became the basis for identifying new training needs to be

integrated into the annual training plan. In addition, performance assessments and development programs now include specific

guidance for creating or adjusting plans, while the Talent Review process now provides personalised development guidance for all

Employees involved. Quality was ensured through management reviews, driving continuous improvement. The guideline has been

updated with practical examples, focused on key competencies, and the Performance Improvement Plan process has been

reformulated, with a greater focus on developing and building these growth tools.

Four years after having established this objective and in the face of all the actions implemented in the year under analysis and

past years, the need to review and adjust the intermediate target to [S1.46 | ESRS 2.80i] was identified:

• 45% of the total number of Employees with IDP in 2025 (Baseline year 2021);

• 60% of Technicians / Specialists /Managers with IDP in 2025 (Baseline year 2022).

Our commitment to increasing youth employability is reflected in the establishment of 172 professional internships in the year

2024. Whenever possible, we carry out these internships under the IEFP (Portuguese Employment and Professional Training

Institute) state program, contributing to youth employability policies. In 2024, the integration rate of post-training operational

technicians was 73%, so the intermediate target was exceeded by 23%. In the case of the Staff, the integration rate was 27%, so

we are 7pp above the intermediate target. [S1.46 | ESRS 2.80j]

5.3.1.3.2. Characteristics of the undertaking’s employees (S1-6)

Navigator is present in several countries, with almost 4,000 employees. Responsible management of our human capital is key to

ensuring a fair and inclusive working environment, promoting talent retention.

Below, the main characteristics of Navigator's employees are presented

. This information is essential to understand the impact

of the Navigator Group's work practices and to define informed strategies on human capital management.

Total employees,

broken down by

gender

2024 2023

Δ %

35 It is worth mentioning that trainees/scholarship holders and governing bodies are not considered in these values.

36 Updated data in relation to the 2023 Annual Report, with the inclusion of Navigator Tissue Ejea Employees

ANNUAL REPORT 2024 • MANAGEMENT REPORT 250

Number of employees (staff

numbers)

S1-6-002

Male

3 213

2 821

13.9%

S1-6-003

Female

752

646

16.4%

S1-6-004

Other

S1-6-005

Not disclosed

S1-6-001

Total employees

3 965

3 467

14.4%

Total employees, broken down by country/region

202

Number of employees (staff numbers)

S1-6-006

Portugal

3 180

Mozambique

128

Spain

176

France

Italy

Germany

USA

United Kingdom

437

The Netherlands

Turkey

Poland

Austria

S1-6-007

South Africa

S1-6-008

Morocco

S1-6-009

Mexico

Total employees

3 965

The 2024 data refer to the number of employees as at December 31 and include all Workers with a contractual relationship with

Navigator, including Navigator Tissue Ejea and Navigator Tissue UK Workers. The total number of employees includes the 14

members of the Board of Directors. [S1.50d]

The total number of Workers is also disclosed in notes 7 and 7.1 of the financial statements. [S1.50f]

[S1.50b and S1.52]

Total number of employees, by type of contract,

broken down by gender

2024

S1-6-003, S1-

6-002, S1-6-

004, S1-6-

005, S1-6-001

Number of Workers

Male

3 213

ANNUAL REPORT 2024 • MANAGEMENT REPORT 251

Female

752

Other

Not disclosed

Total

3 965

1-6-014, S1-

6-013, S1-6-

015, S1-6-

016, S1-6-012

Number of permanent employees

Male

3 021

Female

696

Other

Not disclosed

Total

3 717

S1-6-021, S1-

6-020, S1-6-

022, S1-6-

023, S1-6-019

Number of temporary employees

Male

192

Female

Other

Not disclosed

Total

248

S1-6-028, S1-

6-027, S1-6-

029, S1-6-

030, S1-6-026

Number of Workers' non-guaranteed working hours

Male

Female

Other

Not disclosed

Total

[S1.50b, S1.51 and S1.52]

Total number of employees, by type of contract,

broken down by gender

2024

S1-6-010, S1-

6-011, S1-6-

001

Number of Workers

Portugal

3 180

Outside Portugal

785

Total

3 965

S1-6-017, S1-

6-018, S1-6-

012

Number of permanent employees

ANNUAL REPORT 2024 • MANAGEMENT REPORT 252

Portugal

2 950

Outside Portugal

767

Total

3 717

S1-6-024, S1-

6-025, S1-6-

019

Number of temporary employees

Portugal

230

Outside Portugal

Total

248

S1-6-031, S1-

6-032, S1-6-

026

Number of Workers' non-guaranteed working hours

Portugal

Outside Portugal

Total

The 2024 data refer to the number of employees as at December 31 and include all Workers with a contractual relationship with

Navigator, including Ejea and UK tissue Workers. [S1.50d]

The recruitment of temporary employees takes place based on explicit contracts with stipulated time and place. These agreements

are essentially established to address the lack of human capital and/or expert workers required to carry out temporary projects or

events. [S1AR56]

[S1.50c]

Employee turnover rate

2024

S1-6-047

Number of Employees who left the Company

355

Number of Employees in the reporting period

3 784

S1-6-048

Employee turnover rate (%)

9.4%

Note: The outputs and headcount of Navigator Tissue UK were accounted for as of the acquisition date (May).

For 2024, all outputs throughout the year were accounted for, including the tissue units in Ejea and tissue in the United Kingdom

[AR56 | AR60 | S1.50d], considering as the denominator the average number of staff in the 12 months of the year. [AR59 |

S1.50d]

5.3.1.3.3. Characteristics of non-employees in the undertaking’s own workforce (S1-7)

[S1.55a]

Number of non-employees

2024

Non-employees

S1-7-001

Portugal

124

S1-7-002

Mozambique

182

S1-7-003

United Kingdom

S1-7-004

Spain

ANNUAL REPORT 2024 • MANAGEMENT REPORT 253

Other Geographies

Total

323

Mozambique has non-employees, both in the provision of services and hired through employment agencies. These Workers

perform their duties independently, without a direct link with a fixed employer and are remunerated according to the services

provided or the agreements signed.

The number of non-employees is reported in numbers. These correspond to Temporary Workers (TW) working full-time at the end

of 2024 [S1.55b-1 | S1.55b-2] and only Temporary or non-employees were considered [S1.55b-2]. The data presented does not

include information regarding the geographies where the Group has fewer than 50 Employees.

5.3.1.3.4. Collective bargaining coverage and social dialogue (S1-8)

Collective labour conventions

2024

Coverage of collective labour conventions (%)

S1-8-002

Within the EEA

99%

S1-8-003

Portugal

100%

S1-8-004

Spain

89%

France

Italy

Germany

The Netherlands

Poland

S1-8-005

Austria

S1-8-007

Outside the EEA

S1-8-008

Mexico

Mozambique

USA

United Kingdom

South Africa

Morocco

S1-8-009

Turkey

S1-8-001

Total

84%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 254

Social dialogue

2024

Social dialogue

S1-8-010

Within the EEA

99%

Portugal

100%

Spain

89%

France

Italy

Germany

The Netherlands

Poland

Austria

Outside the EEA

Mexico

Mozambique

USA

United Kingdom

South Africa

Morocco

Turkey

Total

84%

[AR70]

Reporting model to cover collective bargaining and social dialogue

Coverage

rate

Collective bargaining coverage

Social dialogue

Employees— EEA

(for countries with >50 employees

representing >10 % of total Workers)

Employees– Outside the EEA

(estimate for regions with >50 employees

representing >10 % of total Workers)

Workplace representation (EEA only)

(for countries with >50 employees

representing >10 % of total Workers)

0-19 %

n/a

UK and Mozambique

n/a

20-39 %

n/a

40-59 %

n/a

60-79

n/a

80-100%

Portugal and Spain:

n/a

Portugal and Spain:

Navigator has no agreement with the Company's Employees for representation by a European Works Council, a European Works

Council or a Societas Cooperativa Europaea (SCE) Workers' committee. [S1.63b]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 255

5.3.1.3.5. Diversity indicators (S1-9)

In the data presented, Employees in qualified positions were considered as senior staff, and all Operational Technicians and

Supervisors working in the factory floor areas [AR71] were excluded.

[S1.66a]

Gender distribution at senior management level

(number)

2024

Employees at senior management level (number)

S1-9-002

Male

870

S1-9-003

Female

535

S1-9-004

Other

S1-9-005

Not disclosed

S1-9-001

Total

1 405

[S1.66a]

Gender distribution at the senior management

level (%)

2024

Employees at senior management level (number)

S1-9-006

Male

61.92%

S1-9-007

Female

38.08%

S1-9-008

Other

S1-9-009

Not disclosed

[S1.66b]

Distribution of Workers by age group

2024

Number of Workers

S1-9-010

< 30 years old

559

S1-9-011

30-50 years old

2 448

S1-9-012

> 50 years old

958

5.3.1.3.6. Adequate wage (S1-10)

In all countries where we operate, we ensure that the wages paid are fair and adequate, ensuring that they are above the

minimum wage established in each country. [S1.69]

5.3.1.3.7. Training and skills development indicators (S1-13)

Percentage of employees who

participated in regular reviews of

2024

ANNUAL REPORT 2024 • MANAGEMENT REPORT 256

performance and career development

(%)

Genus

S1-13-002

Male

92%

S1-13-003

Female

89%

S1-13-004

Other

S1-13-005

Not disclosed

The data presented for 2024, referring to the Performance Assessment, refers to 2023, given that the Performance Management

Cycle of 2024 is not yet completed. All Employees in Portugal, Mozambique and international offices were considered, and the

tissue units in Ejea and in the United Kingdom were not covered.

Employees whose performance was assessed in 2023 were appraised once in the relevant year [AR77a] under the agreed number

of reviews [AR77b].

Number of hours of training per employee

2024

Genus

S1-13-049

Male

100

S1-13-050

Female

S1-13-051

Other

S1-13-052

Not disclosed

Average number of hours training per employee

The data presented represent the total hours of training for 2024, considering the number of staff on the last day of the

corresponding year. For the year 2024, a total of 3519 Employees were considered, 684 female and 2835 male, which

corresponds to all national and international Employees, except for the tissue unit in the United Kingdom. In the case of the tissue

unit in Ejea, only the e-learning registered on the Learning Centre portal was considered, and the training hours offered locally

were excluded.

5.3.1.3.8. Health and safety indicators (S1-14)

Navigator has an Occupational Safety and Health Management System (OSHMS), implemented under ISO 45001, and which is

certified by an external entity.

[S1.88a]

Percentage of Workers covered by a health and

safety management system

2024

S1-14-001

Labour

74.6%

S1-14-002

Employees

78.4%

S1-14-003

Non-employees

27.9%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 257

The data presented refer to the OSH Management System in Portugal and Navigator Tissue Ejea, certified according to ISO

45001. It is worth mentioning that, in the Organisation some activities, namely Forest Management, Wood Supply and ROOT, are

not within the scope of ISO 45001. However, operations in these areas follow the same principles and procedures. This indicator

does not include the Mozambique and United Kingdom geographies.

In the period under review, no fatalities were recorded in Navigator's operations. [S1.88b]

Work-related accidents

2024

Portugal and Spain:

S1-14-017

Labour

159

S1-14-018

Employees

149

S1-14-019

Non-employees

Mozambique

S1-14-017

Labour

S1-14-018

Employees

S1-14-019

Non-employees

ANNUAL REPORT 2024 • MANAGEMENT REPORT 258

[S1.88c]

Accidents at work (per 1,000,000 hours)

2024

Portugal and Spain:

S1-14-020

Labour

28.6

S1-14-021

Employees

27.8

S1-14-022

Non-employees

50.2

Mozambique

S1-14-020

Labour

12.15

S1-14-021

Employees

8.67

S1-14-022

Non-employees

30.56

The data above refer to the operations performed in Portugal, Spain and Mozambique, and as regards other geographies the

Company is still in the process of integrating information.

As for Portugal and Spain, and as regards the number of hours worked by employees, the records in the Company's information

system were considered. The hours worked by non-employees are estimated from the number of Employees crossing the gates

and whose access is recorded in the computer system, assuming that they work an average of 8 hours a day. In the case of forest

areas, there is a record and control dedicated to this collection of information. The Project Directorate has its own information

gathering, which is accounted for by the local teams [AR90].

In Mozambique, the accounting of hours worked was carried out in a disaggregated way for the three groups considered: Number

of employees; Individual service providers (PSI) and Occasional work. For each of these groups, the methodology applied was the

following [AR90]:

• Staff: (Number of working days of each month x 8 h) x number of staff - days of absence of Employees of this category

• Individual service providers: Number of working hours of each month x number of PSI

• Duty sheets (workdays) collected by the operational team, and which give rise to payment.

Number of confirmed occupational

diseases

2024

Work-related illness

S1-14-

023

Employees

S1-14-

024

Non-employees

The data presented refer to the operations in Portugal and Mozambique, and in the latter geography, there was no record of work-

related diseases. 100% of these Employees are entitled to family care leave.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 259

Number of days lost due to work-related

injury and death due to work-related

accidents, work-related ill-health and

deaths due to ill-health in Employees

2024

Portugal and Spain:

S1-14-

025

Employees

2 187

S1-14-

026

Non-employees Workers

Mozambique

S1-14-

025

Employees

S1-14-

026

Non-employees

In Mozambique, the 20 days of sick leave indicated for the year 2024 were a consequence of a (the only) accident with sick leave

that occurred in 2024, which involved an external Worker (of a forestry service provider).

5.3.1.3.9. Work-life balance metrics (S1-15)

Percentage of Workers entitled to and

using family care leave (%)

2024

S1-15-003

Male

6.1%

S1-15-004

Female

7.6%

S1-15-005

Other

S1-15-006

Not disclosed

S1-15-002

Total

6.5%

The information above refers to Employees of companies in Portugal and Mozambique and Ejea. Parental, paternity, maternity and

family care leave were considered for this calculation. 100% of these Employees are entitled to family care leave.

5.3.1.3.10. Remuneration metrics (pay gap and total remuneration) (S1-16)

Gender wage gap (%)

2024

S1-16-001

Total

To calculate the wage gap between men and women, only regular monthly salaries as of 12/31/2024 were considered (which

include basic remuneration,

remuneration for exemption from fixed working hours (EFWH), complementary remuneration, shift

allowance and performance of functions). [S1.97c]

Ratio of annual total remuneration

2024

S1-16-018

Total

32.25

To calculate the annual total remuneration ratio, the total monthly remuneration of the highest-paid individual was considered

compared to the median of the total monthly remuneration of the headcount (excluding the highest-paid individual). Salary data

ANNUAL REPORT 2024 • MANAGEMENT REPORT 260

are based on all regular monthly remuneration (which includes base remuneration, EFWH Allowance, Shift Allowance and other

complementary monthly remuneration of a regular nature). For this purpose, the entire Navigator staff as at 12/31/2024 is

accounted for.

5.3.1.3.11. Incidents, complaints and severe human rights impacts (S1-17)

The total number of work-related discrimination incidents, including harassment and complaints, reported by the Compliance

Area, results from the Whistleblowing Channel (see section S1-3). As mentioned above, this channel is intended for the

communication of irregularities by Employees, Suppliers, Customers, Service Providers, Local Communities or any other interested

parties and can be accessed via the website and Intranet. [S1.103d] Portucel Moçambique has a specific document for the

management of complaints from the Communities: the Complaints Management Mechanism. [S1.103d]

2024

[S1.103a]

S1-17-001

Total number of work-related discrimination incidents, including

harassment in the reporting period

[S1.103b]

S1-17-002

Number of complaints submitted by Employees through the grievance

reporting channels

[S1.103c]

S1-17-003

Fines, penalties and compensation for damages (€)

[S1.104a]

S1-17-04

Number of serious human rights incidents related to the Company's

workforce

[S1.104b]

S1-17-05

Total amount of fines, sanctions and compensation for damages caused

by serious human rights incidents related to the Company's workforce

(€)

[S1.106]

S1-17-06

Number of serious human rights incidents in which the Company played

a role in ensuring redress for those affected

The total number of work-related discrimination incidents, including harassment, corresponds to the substantiated complaints

received by the Compliance Area through the Whistleblowing Channel in 2024. The number of complaints submitted by Employees

through the grievance communication channels reflects the total number of complaints received by the same Channel throughout

2024, which includes other issues, in addition to those related to Human Rights.

No cases of serious human rights incidents were confirmed in 2024.

5.3.1.3.12. Entity specific metrics – MDR-M

In addition to the metrics to be reported under the ESRS, Navigator monitors an additional set of metrics that support the analysis

of the evolution of its performance. [ESRS 2.77c]

Occupational Health Program

Our approach to Occupational Health and Safety (OHS) puts the well-being of Employees at the heart of the operation. To that

end, we have a robust Occupational Health (OS) structure, with a psychologist, a nutritionist, a social worker and four

physiotherapists, as well as a medical team (which includes six occupational physicians, four curative medicine physicians and 20

nurses), ensuring close and accessible monitoring to all Employees in the industrial, forestry and administrative areas.

The Portuguese manufacturing units are equipped with Medical Stations, providing specialised support whenever necessary. The

nursing team ensures continuous assistance 24 hours a day, except Vila Velha de Ródão unit, where the service is available during

daytime hours.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 261

The different capacities of the Occupational Health team work closely together, providing integrated and multidisciplinary

monitoring, and promoting actions aimed at risk prevention, health promotion and improvement of the quality of life at work.

One of the structuring projects of this strategy is the Ergonomics Project, which is there in all industrial units and nurseries, with

more than 200 jobs being the focus of this type of intervention. This initiative, conducted by the physiotherapists of the

Occupational Health team, aims at analysing the jobs identified as critical, through regular field visits and feedback from

Employees. The investment made has been significant, but the results point to a reduction of about 50% in work-related

musculoskeletal injuries since the beginning of the project.

Physical activity at work has been an essential pillar in health promotion, complementing this preventive approach. In 2024, we

started offering daily sessions via Teams, ensuring participation of all Employees, regardless of their location. More than 1000

Employees were registered and joined the sessions on a regular basis both in person and online. This initiative has helped reduce

work-related musculoskeletal diseases (WMSDs), reinforcing the importance of movement and physical well-being in the

prevention of health problems.

In addition to these initiatives, we are reinforcing our commitment to health promotion through structured programs, such as

sleep analysis, food habits during shifts and social support, as well as the Health Month (celebrated annually in October),

promoting several outreach activities with operational teams.

To complement this support, we also provide Health Insurance for our Employees from all geographies, granting access to a wide

network of medical services and specialists.

[ESRS 2.77c – Entity specific metrics]

Occupational Health Program

2024

No. of Physiotherapy appointments

2 116

No. of Nutrition appointments

716

No. of Psychology and Social Work appointments

1 044

No. of casualties avoided

277

No. of Employees covered

2 671

No. of partial/total recoveries

321/137

Ergonomics Project

A Project that includes several actions, namely the direct intervention in the workstations and the awareness of Employees about

the correct posture to carry out certain tasks.

[ESRS 2.77c – Entity specific metrics]

Ergonomics Project

2024

No. of posts intervened

202 (accumulated

numbers since the

beginning of the

project)

No. of Actions Performed

Number of approved actions

214

Number of implemented actions

141

ANNUAL REPORT 2024 • MANAGEMENT REPORT 262

Young Talent

In this metric, the professional, summer and trainee internships that took place during 2024 were counted. In total, on December

31, 2024, 111 trainees were considered present, with 21 292 hours of training. [ESRS 2.77a]

Young Talent

2024

No. of young people in the Talent Attraction Program

298

Integration Fee (%)

50%

No. of hours of training for trainees

21 292

Note: The Talent Attraction Program accounts for all trainees from 2024. For the calculation of the number of hours of training, the trainees who

collaborated with the Company on December 31, 2024 are considered.

Birth Premium

In 2023, a new measure under the protection of parenthood was implemented, in the form of a Birth Premium, applicable to the

children of Employees born from the beginning of the year. This is a parenting support benefit, materialised in the awarding of a

premium equivalent to one month of base remuneration to all Employees with children born as of January 1 of each calendar year.

The Birth Premium is paid in the month following the child's birth month. [ESRS 2.77a]

In 2024, this premium was awarded to 109 Employees, corresponding to an investment of about € 150,653.

[ESRS 2.77c – Entity specific metrics]

Birth Premium

2024

No. of Employees

109

Premium Amount (€)

150,652.54

Note: The Birth Award is awarded to all Employees of the companies of the Group.

Evolution of employee salaries and benefits

[ESRS 2.77c – Entity specific metrics]

Evolution of Employee salaries and benefits

2024

2023

2022

Evolution of Employee salaries and benefits (M€)

202 709

171 127

185 194

Note: The evolution of employee salaries and benefits refers to the Portugal and Mozambique geographies. This metric corresponds to Indicator GRI 201-

01.

Grants and benefits

In 2024, €9,453,335 were allocated in social support benefits and subsidies, within the scope of family support programs and

benefits attributed to Employees in Portugal, such as health insurance, life insurance and pension fund, corresponding to an

average €2,729 investment per Employee.

Nationalities

At the end of 2024, Navigator had Employees of 40 nationalities in its staff.

[ESRS 2.77c – Entity specific metrics]

Nationalities

2024

Number of nationalities

ANNUAL REPORT 2024 • MANAGEMENT REPORT 263

5.3.2. ESRS S2 – Workers in the value chain

5.3.2.1. Strategy

5.3.2.1.1. Material impacts, risks and opportunities and their interaction with the strategy and the

business model (ESRS 2 SBM-3)

Description

Impact, Risk

or Opportunity

Time Horizon

Location

in the value chain

Sub-topic or related

sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48cii]

[ESRS 2.48a]

[ESRS 2.48h]

Non-compliance with

occupational safety rules

and procedures adversely

affects the health and

safety of Workers

Negative Impact - Amount/Own operations Safety and Health

Training and improving the

skills of Workers have a

positive impact on their

income.

Positive impact -

Amount/Own

operations/Downstream

Training and skills

development

Ensuring access of all

Workers to hygiene,

sanitation and drinking

water conditions impacts

the health of Workers in the

value chain.

Positive impact - Own operations Water & Sanitation

Note: The identified material impacts are real and not time-specific.

Navigator's approach to sustainability rests on the development of a business with responsible management, including workers

in the undertaking’s value chain, as part of this responsible action. We take a comprehensive approach to ensure the

occupational safety and health (OSH) of everyone working along our value chain, including direct employees (Chap.

5.3.1)

and employees of our Suppliers, Service Providers and Partners. Workers in the value chain subject to material impacts

include service providers working in forestry activities and those working in industrial operations we focus also on.

[S2.11a]

Acknowledging the fact that non-compliance with occupational safety rules and procedures adversely affects the health and safety

of Workers, we promote a safety culture, in line with our "Mission Zero" strategy aimed at eliminating occupational accidents.

The objective of Mission Zero covers those working and collaborating with us, without excluding Workers from specific groups,

geographies or other classifications. [S2.10a-1] [S2.11]

We establish strict criteria for Suppliers and Partners – through specific policies, our Service Provider Manual, among other

documents -, requiring them to know and comply with the procedures and rules in force in the Company, ensuring the

implementation of preventive practices and promoting audits and risk assessments, ensuring compliance with our

ANNUAL REPORT 2024 • MANAGEMENT REPORT 264

occupational safety and health standards and contributing to the adaptation of the business strategy. We reinforce the importance

of safety culture through our Occupational Safety and Health Management System, certified by ISO 45001, ensuring that

both Direct Employees and External Workers operate under safe conditions (Chap. 5.3.1). [S2.10a-1]

We value continuous training as an essential mechanism for the training of Workers in our value chain. By providing training in

occupational safety, correct use of Personal Protective Equipment (PPE) and operational risk management, we help reducing

accidents and improve the skills of Workers, with direct impact on their performance and achievement. [S2.10a-1]

In the forestry activity, the Operations Quality Control process informs and validates compliance of the Service Providers'

practices with the technical references and with the legal, social and environmental requirements in force, minimising the risk of

failure of the operations carried out. The results obtained support the selection of Service Providers for the performance of future

operations. The Safety and Waste Management Sheet, together with the respective safety procedures, is equivalent to the Service

Provider Manual referred to above, is a specific instrument in forestry activity. In Logistics and Transport, the Road Transport

Environment and Safety Procedure is equivalent to the Service Provider Manual and is a specific instrument for the

transportation activity.

[S2.10a-2| S2.10a-1]

We do not operate in geographies or with products involving significant risks of child, forced or compulsory labour among

workers in the Company's value chain. [S2.11b]

The identified material negative impacts can be classified either as generalised or systemic, or as related to specific incidents or

business relationships [S2.11c]. Widespread or systemic impacts result from structural factors such as gaps in safety culture,

gaps in training, or weaknesses in oversight of OSH practices in the value chain. These impacts may manifest themselves through

recurring trends, such as the increase in the accident rate among contractors due to little knowledge of internal procedures. The

impacts related to individual incidents or specific business relationships may result from specific situations of non-

compliance by Service Providers or Workers, resulting in accidents or risk events. [S2.11c]

Regardless of its origin, non-compliance with rules and procedures can lead to serious occupational accidents, thus increasing the

need for strict supervision, audits and frequent follow-up actions, as well as full compliance with our Service Provider Manual or

similar documents specific to the forestry activity. [S2.11c]

Activities that result in positive material impacts include OSH training, regular audits and inspections, sharing good practices,

and integrating Service Providers into the Company's safety culture [S2.11d]. Key types of value chain Workers who are or may

be positively affected include: [S2.11d]

Contracted workers and Service providers – by complying with the rules and procedures, they reduce risk

exposure and improve their OSH performance.

Supervisors and security management teams – they benefit from a more controlled and predictable

environment, facilitating risks identification and mitigation.

Internal employees interacting with third parties – are impacted by the global improvement of the safety

culture, which reduces accidents and promotes a safer working environment.

It is worth mentioning that Workers of Service Providers and, where applicable, those in the logistics and transportation sector,

have specific rest areas available inside the Company's facilities, as well as access to sanitary facilities, changing rooms and water

points. We thus ensured these Workers have access to adequate conditions of hygiene, sanitation and drinking water,

promoting their well-being, health and better working conditions. [S2.11d]

After an internal assessment carried out by Navigator, no Employees with specific characteristics or in a particular context who,

when carrying out their activities, were exposed to an increased risk of damage were identified, according to the impacts and

opportunities identified in the materiality assessment. [S2.12]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 265

Strict compliance with rules and procedures, combined with structured and continuous training, thus raises the operational safety

levels, resulting in a reduction in incidents and strengthening of the safety culture throughout the value chain. [S2.11d]

5.3.2.2. Impacts, risks and opportunities management

5.3.2.2.1. Policies related to value chain workers (S2-1)

In line with the principles guiding our operations, we are committed to fostering responsible conduct throughout our value chain.

Navigator's main policies covering Workers in the value chain are: Human Rights Policy; Codes of Conduct for Suppliers;

Major Accident Prevention Policy; Management Systems Policy; Forestry Policies. These documents apply to everyone

performing their activity along our value chain. In addition, as a complementary document, the Good Practices Guide for

Service Providers and Occasional Workers, which establishes the principles, rights and duties duly aligned with ILO

Performance Standard 2 - on the elimination of forced or compulsory labour, being specifically addressed to Forest Service

Providers and occasional Employees recruited in the Communities where Portucel Moçambique operates. [ESRS 2.65a| S2.16]

In the development of these policies, reference intergovernmental documents were taken into account, including the

United Nations Guiding Principles on Business and Human Rights, the Fundamental Conventions of the International Labour

Organisation and the OECD Guidelines for Multinational Enterprises, in addition to the ISO standards that support our

Management Systems Policy. [ESRS 2.65d | S2.19]

Our Human Rights Policy

assumes specific commitments aimed at Workers in the value chain from the outset: to promote the

different levels of The Navigator Company's value chains to respect Human Rights and labour rights, namely through appropriate

contractual rules that encourage the adoption of the necessary preventive and corrective measures and the transparent treatment

of information regarding possible violations of Human or Labour Rights, as well as the assessment of their compliance in these

matters. This commitment is included in the matrix of responsibilities associated with the governance model of the Human Rights

Policy.

Also the Code of Conduct for Suppliers refers to Workers in the value chain, namely [ESRS 2.65to| S2.16 | S2.17]: (1)

compliance with applicable laws and regulations; (2) respect and promotion of Human Rights; (3) non-discrimination; (4) working

hours; (5) health and safety; (6) freedom of association and collective bargaining; (7) environmental practices.

We emphasise, regarding the respect and promotion of Human Rights: that Navigator respects universal Human Rights in its

operations and promotes their implementation in its sphere of influence and expects its Suppliers to do the same. The Code

expresses the prohibition of child or forced labour of any kind, respect for the personal dignity, privacy and personal rights of each

individual must be respected, further stating that all Navigator Supplier Workers must not be subject to physical punishment or

physical, sexual, psychological or verbal abuse or harassment. [S2.17]

To reinforce this commitment, we have implemented a Third Party Integrity Verification System and included compliance

clauses in agreements entered into with Suppliers, through which we ensure the adoption of several criteria – namely in matters

of prevention of corruption and related offences, prevention of money laundering and financing of terrorism, compliance with

international sanctions, including, among others, Human Rights protection.

Also in this context, it is worth mentioning that, during 2024, cases of non-compliance with the United Nations Guiding Principles

on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for

Multinational Enterprises involving Workers in the value chain were not reported in the channels available for this purpose.

[S2.19]

The following information is included by reference to other parts of the Non-Financial Statement (MDR-P, ESRS 2, §65 a/b/c/d/f):

ANNUAL REPORT 2024 • MANAGEMENT REPORT 266

Presentation of the Human Rights Policy and Supplier Codes of Conduct: Chap. 5.4.1

Presentation of the Management Systems Policy: Chap. 5.2.5

Major Accident Prevention Presentation: Chap. 5.3.1

Presentation of Forest Policies: Chap. 5.2.6

5.3.2.2.2. Processes for engaging with value chain workers about impacts (S2-1)

Engagement with value chain workers is essential to ensure actions that generate positive impacts and mitigate potential negative

impacts. This involvement is particularly relevant when Employees perform functions similar to the Group's own operations, such

as industrial and/or forestry operations.

Occupational Health and Safety issues are a priority for Navigator. The Company's internal health and safety (OHS) program

includes engagement with value chain workers. These Workers must adopt the occupational safety practices established by the

Company and comply with the established standards and regulations. In addition, they must participate in Navigator safety

training, which addresses the Company's specific safety requirements, as well as external training. [S2.22a]

Navigator does not currently have any global framework agreements or agreements with global trade union federations. [S2.22d]

In addition, we have a Whistleblowing Channel and carry out consultations with Employees (see next section).

[S2.22a]

5.3.2.2.3. Processes to remediate negative impacts and channels for value chain workers to express

concerns (S2-3)

The material negative impacts identified for value chain workers are related to health and safety. The general approach to

providing or help remediate these material negative impacts is based on a structured process of accountability and

continuous improvement, under which the following processes are implemented: [S2.27 a] [S2.33 a]

• Accident penalisation and mischaracterisation procedure – whenever a Service Provider causes or contributes to

a significant negative impact, a corrective action plan is required, which must be implemented by that Service Provider

and followed up by the Navigator team. [S2.33b] [S2.23]

• Monitoring and assessing implementation – the Navigator team monitors the implementation of corrective measures

to ensure that the incident causes are properly addressed and do not recur. [S2.33b] [S2.23]

• Evaluation of the effectiveness of the corrective measure – if the action implemented is not effective, the

Provider may be suspended or excluded from the list of qualified Providers, thereby making sure ensuring that only

Partners committed to safety are part of the value chain. [S2.33b] [S2.23]

In Mozambique, the first approach implemented is to ensure that all external Workers, especially occasional workers – whether

hired by the Service Providers or hired directly – have inclusive, fast and efficient communication channels with Navigator and vice

versa.

We have a complaint management mechanism that allows the monitoring and individualised analysis of each situation. A

complaint is considered resolved only when the complainant signs their agreement with the solution presented. In the case of

Occasional Workers in the field, complaints can be forwarded through the Technical Experts or Community Liaison Agents

(Chap. 5.3.3) – through the complaint management mechanism for the local Communities, as these Workers are people residing

in the local Communities –, who, in turn, direct them to the Company through the Communication Technicians, for analysis

ANNUAL REPORT 2024 • MANAGEMENT REPORT 267

and resolution at the Management level. The remediation of negative impacts and assessment of the effectiveness of the

implemented processes is thus ensured. [S2.27a] [S2.23]

In Portugal, we carry out an annual consultation with external workers on aspects of health and safety at work, where,

through a digital and anonymous questionnaire, we identify strengths and development needs in Navigator's OSH area [S2.27a]

[S2.22e].

In addition, the Group has a Whistleblowing Channel

(Chap. 5.4.1) allowing value chain Workers to communicate any and all

issues or concerns they may have. Personal data are treated confidentially and anonymously, ensuring protection against any type

of reprisals that may arise. [S2.23]

The following information is included by reference to other parts of the Non-Financial Statement: more information on following up

and monitoring the issues raised and addressed and ensuring the effectiveness of the Reporting Channel (Chap. 5.4.1

5.3.2.2.4. Taking action on material impacts on value chain workers, and approaches to managing material

risks and pursuing material opportunities related to value chain workers, and effectiveness of

those actions (S2-4)

We focus on conducting training, disseminating good practices and carrying out labour inspections (see table below), in order to

prevent, remedy or correct negative material impacts on workers in the value chain. [S2.32b | S2.32a |S2.32c | S2.32d]

On-the-Job Training (forestry activity) is carried out in the workplace for external workers, addressing environmental and

social aspects. The mitigating measures to be adopted as regards the surrounding environment are disclosed, as well as the

occupational health and safety requirements applicable to the operations in question. [S2.31 | S2.22and | S2.35]

Concerning actions to disseminate good practices for exploration and transport companies, these are co-organised with

external Partners, including organisations of Forest Producers and forest certification and chain of custody groups. These initiatives

are related to safety in the performance of forestry exploration and transport operations, covering wood suppliers. [S2.31 | S2.35]

The Work Inspections action on the work fronts consists of visits to the several work fronts, with the main objective of

managing the Safety risk. These are follow-up visits to the different work fronts in forestry operations, to assess compliance with

regulations and the use of equipment (emergency and other), culminating in awareness/training for the working groups – mostly

Workers from the surrounding Communities, on several health and safety matters [S2.31 | [S2.33 a | S2.33c | S2.22and |

S2.35].

For the development of the actions presented in the following table, in 2024, capital expenditures (CapEx) and operating expenses

(OpEx) do not apply, except the Safe Pro Forestry action, where the Corporate SST Budget was allocated. [ESRS 2.69b]

Main actions Status Scope of action Time Horizon Results

[ESRS 2.68 a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68 a]

ESRS 2.68e]

On-the-Job Training

(forestry activity)

Held and planned

It focuses on its own

operations,

upstream, with an

impact on

Employees of

Service Providers in

the forestry activity.

(Portugal and

Mozambique)

Continuous

In 2024, 185 workers from Service Providers

in the forestry activity were covered,

corresponding to 264 hours of training.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 268

Main actions

Status

Scope of action

Time Horizon

Results

[ESRS 2.68 a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68 a]

ESRS 2.68e]

Actions to

disseminate good

OSH practices for

exploration and

transportation

companies

Held and planned

It focuses on

downstream

operations, with an

impact on

Employees of Wood

Suppliers. (Portugal)

Continuous

In 2024, 120 Workers from Wood Supply

companies were covered, corresponding to

420 hours of training.

Work inspections on

the work fronts

Held and planned

It focuses on

upstream

operations, with an

impact on

Employees of

Service Providers in

the forestry activity.

(Mozambique)

Continuous

Visits to the work fronts to assess potential

"non-compliance" of the several forestry

operations (within the scope of Safety).

In 2024, 450 assessments were carried out on

the work fronts.

164 hours of training were carried out covering

about 2300 people.

SafePro Forestry Planned

Own operations,

upstream, with an

impact on

Employees of

Service Providers in

the production of

plants and forest

activity. It will cover

Portugal

2025 - 2026

Under these action 100% of the external

workers are trained for the activity to be

carried out at Navigator

This is also the action we envisage in order to

make solutions available to people injured by

real material impacts. [ESRS 2.68d]

Awareness of safety

issues of Suppliers

and Workers of

logistics and

inbound

transportation

Planned

Own operations and

amount in Portugal

2025

Awareness of the use of PPE and compliance

with safety procedures at the factory doors,

forests and wood parks.

In addition to the actions identified above, other projects were developed with the same objective of training all those who work in

the forest, including: the II Forest Workplace Safety Seminar (Spain and Portugal), hosted in partnership by Navigator, ACT –

Authority for Working Conditions and the ACF Minho Lima Certification Group; the Advance Forest Project for the advanced

training of Technicians, Producers and Owners, of Biond, in partnership with Ascendum Máquinas, where they were carried out.

[S2.32c and S2.32d] [S2.33c]

With the implementation of the actions undertaken, referred to above, and the planned action for the future SafePro Forestry,

among others already implemented or to be implemented within the scope of Mission Zero, it is intended to reduce the probability

of incidents and to eliminate occupational accidents and diseases. [ESRS 2.68a] [S2.33c]

No serious human rights issues or incidents related to our upstream and downstream value chain were reported. S2-36

The following information is included by reference to other parts of the Annual Report:

• More information on the relationship between current financial resources allocated to shares or action plans and the most

relevant amounts are contained and presented in the financial statements: Consolidated income statement of the Annual

Report. [ESRS 2.69b]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 269

5.3.2.3. Targets and Metrics

5.3.2.3.1. Targets related to managing material negative impacts, advancing positive impacts, and

managing material risks and opportunities (S2-5, MDR-T)

In our 2030 Sustainability Roadmap (Chap. 3.4.4), we have set several goals aimed at reducing the negative impacts on Workers

and promoting the positive impacts identified with materials [S2.39 | ESRS 2.80c]:

• The reduction of the frequency rates of occupational accidents in Iberia and Mozambique, with target values

that cover Navigator Employees and external workers;

• The reduction of accidents mischaracterised for non-compliance with rules and procedures, with a target

value that covers Navigator Employees and external workers;

• Continuous training courses in OSH in the forestry activity for Service Providers, Suppliers and agents in the

sector.

In the broader context of sustainability, these goals contribute to SDGs 8 and 3, aimed at promoting safe and healthy working

conditions, reinforcing the well-being of workers in the value chain. [ESRS 2.80f]

These targets are in line with our Integrated Safety Policy in Management Systems, namely with the commitments to promote,

from a perspective of continuous improvement, safe and healthy working conditions, preventing occupational injury and

disease and to foster the consultation and participation of Workers, while helping their personal and professional development.

In line with the Major Accident Prevention Policy, it defines roles, responsibilities and skills, ensuring the availability of

information and/or training to internal Employees, Suppliers, Service Providers and other Stakeholders. It is also associated

with the Forest Policy within the scope of the commitment to "ensure the health and safety of its Employees, including third

parties’ Employees providing forestry activity services, offering them adequate training/ information for the assessed risks".

[ESRS 2.80a]

We emphasise that External Workers receive training and information on the rules and procedures and are covered by a penalty

regime in case of non-compliance with rules, standards and/ or procedures (cardinal rules).

The following information is included by reference to other parts of the Non-Financial Statement:

• More information on the targets related to the reduction of frequency rates (Iberia and Mozambique) and the percentage

of accidents mischaracterised for non-compliance with rules and procedures: MDR-T, ESRS 2, §80 – Chap. 5.3.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 270

Goal and

Target

Baseline

Associated

metric

2022

performance

2023

performance

2024

performance

Results

to achieve

[ESRS 2.80d]

[ESRS 2.75]

[ESRS 2.80J]

[ESRS 2.80 b)]

[ESRS 2.80 e)]

Hold

continuous

training

courses in

OSH in the

forestry

activity for

Service

Providers,

Suppliers

and agents

in the

sector,

trying to

offer more

than 600

annual

hours

Baseline

Value:

628 h

457 Workers

Baseline

Year:

2021

No. of people

involved

Total hours of

training

544 hours

432 Workers

698 hours

567 Workers

655 Service

Providers and

Suppliers Workers

and actors in the

sector making a

total of 2434

hours of

training/sessions

to disseminate

good practices

(Portugal)

1382 Service

Providers and

Occasional

Workers making a

total of 89 hours

of training in the

field of safety.

(Includes

classroom

sessions, field

sessions and

awareness

sessions in the

safety inspections

carried out on the

work fronts).

(Mozambique)

Total: 2037

Workers and

2523 hours of

training

Results to achieve:

600 h/year

Year:

2030

In setting the goal, there was no involvement of the Stakeholders. [ESRS 2.80h]

Target monitoring is done based on the number of hours of training and the number of participants involved (absolute values)

[ESRS 2.80b]. Its scope is the continuous performance of OSH training courses in the forestry activity, aimed at Service Providers,

Suppliers and agents in the sector [ESRS 2.80c], covering: [ESRS 2.80f]

• No. of Workers of Service Providers in the forestry activity (in Portugal) and respective hours of training

offered on the work front;

• No. of Workers of Wood Suppliers, of forestry exploration and transportation activities (in Portugal), and

respective training hours to disseminate good practices;

• No. of actors in the sector (Technicians and Owners in Portugal) and respective training hours to disseminate

good practices, demonstration and innovation in the forest;

• No. of Workers of Service Providers and Occasional Workers in the forestry activity (in Mozambique) and

respective hours of training offered.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 271

In addition, it is worth mentioning that these actions are developed in collaboration with external Partners and the contents are

defined by the Company to ensure promotion and dissemination of good practices, in line with its sustainability principles and

commitments. [ESRS 2.80f]

In 2024, the method to calculate the metric associated with the target changed, including Workers who received

training/awareness and the training hours offered by Portucel Moçambique. These changes provided greater visibility to the

training/awareness held in Mozambique, without compromising the comparability between reporting years. The factor that

impacted this comparability was the increase in the number of Workers of Suppliers and agents of the sector who participated in

the actions to disseminate good practices. [ESRS 2.80i] The assessment of the effectiveness of the target is carried out based on

the management indicators, with a base period of three years. [ESRS 2.81b]

In 2024, there was a significant increase in the participation in actions to disseminate good practices, which resulted in a relevant

increase in the number of Workers of Suppliers and agents of the sector covered, as well as in the total training hours. This trend

may have future implications for setting new goals, requiring analysis to determine whether it is a permanent change or a one-off

effect.

5.3.2.3.2 Entity-specific metrics- MDR-M

[ESRS 2.77b – Entity-specific metrics]

202

Frequency index

3.1

No. of accidents with sick

leave

Note: These metrics are subject to external verification within the scope of this report and are not verified by other entities. These indicators refer to

Outside workers. [ESRS 2.77b]

To calculate the frequency index of occupational accidents, accidents with sick leave were accounted for and the normalisation

factor of hours worked of 1 000 000 was used. [ESRS 2.80f]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 272

5.3.3. ESRS S3: Affected communities

5.3.3.1. Strategy

5.3.3.1.1. Material impacts, risks and opportunities and their interaction with the strategy and business

model (ESRS 2 SBM-3)

Description

Impact, Risk

or Opportunity

Time Horizon

Location

in the value chain

Sub-topic or related

sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

Promotion of the local

economy, territorial

cohesion and settlement of

populations (example in the

inner areas of the

countries) by generating

decent jobs, improving

infrastructure, investing in

social welfare and ensuring

respect for the cultural and

environmental rights of

Communities, contributing

to better living conditions

and balanced development

in the regions.

Positive impact -- Own operations

Economic, social and

cultural rights of the

Communities

Promotion of SDGs 1 and 2

with impacts on the

Communities in

Mozambique where the

Company operates,

improving their well-being

Positive impact -- Own operations

Economic, social and

cultural rights of

Communities – Adequate

food

Promotion of access to

drinking water for local

communities in

Mozambique

Positive impact -- Own operations

Water abstraction – Water

& Sanitation

Note: The identified material impacts are real and not time-specific.

We have a significant presence in several regions, with industrial operations in Portugal, Spain and the United Kingdom and a

forestry base in Portugal, Galicia (Spain) and Mozambique. In line with our Purpose (Chap. 2.1), we assume the responsibility of

creating effective mechanisms for sharing value with our Stakeholders (Chap. 3.4.5), with special attention to local

communities. These play a fundamental role in our interaction with companies, as they are the first link in the chain to experience

the impacts of our forestry and industrial activities.

Following the double materiality analysis, we identified several positive material impacts on the Communities covered by our

operations, and which are aligned with our strategy and business model, in which we propose to create long-term value,

contributing to the rural economy, through the development of the regions where we operate and the improvement of the forest

spaces we manage. [ESRS 2.48a | S3.8a-i] No material risks and opportunities have been identified for Navigator arising from

the impacts and dependencies on the affected Communities. [S3.9d]

By investing in infrastructure and investing in the hiring and qualification of talent from the Communities, as well as in

development programs, we reinforce the social well-being and development of the regions. [ESRS 2.48a | S3.8a-i]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 273

At the same time, the implementation of sustainable management initiatives – such as forest conservation, fostering the active

participation of Communities, free technical support and the training we provide to Forest Producers (Chap. 5.2.6), the contracting

of local services for forestry activity, the continuous maintenance of infrastructures (network of forest paths) and the prospecting

and development of business opportunities within the scope of multiple use of the forest, among others – allows us to improve

management practices, increasing the productivity of products extracted from the forest. These factors strengthen the local

economy, generating employment and creating conditions that encourage the settlement of populations in rural areas, while

respecting local cultural and environmental values, contributing to the sustainable development of the regions. [ESRS 2.48a |

S3.8a-i]

We believe that sharing with society is not only limited to our results, but also to our knowledge, experience and resources.

Strategic partnerships with academic, institutional and community entities promote knowledge transfer and innovation (Chap.

3.4.5), and these are important factors in strengthening territorial cohesion, as well as driving the creation of economic value by

integrating the community into the circular bioeconomy value chain, improving the quality of life and resilience of local

populations. [ESRS 2.48a | S3.8a-i]

Through a robust strategy of dialogue and direct engagement with Communities, we try to create close ties, in all its

dimensions, and we are committed to consolidating and strengthening them, ensuring that our contribution to local development

is always significant and positive.

In the case of forestry operations in Mozambique, which are related to positive impacts associated with SDGs 1 and 2 and access

to drinking water, one of the objectives is for the sustainable development of the Communities to follow the evolution of the

project, given the great interaction that exists from the Mosaic Model, where plantations "live together" with the Communities and

everything that concerns them, such as areas of high conservation value, agricultural areas, housing, places of worship, among

others. Thus, only with an intrinsic and interconnected relationship is it possible to maintain the development of the project,

ensuring respect for the expectations and needs of the Communities. In Mozambique, the Social Development Program has

been adapted, where new lines of action have emerged based on the impacts and methods of implementing the activities that

lead to changing or adapting development strategies. An example of this was the repair of existing water boreholes (executed by

other entities), which had not been foreseen at the start of the Program, arose due to the requests of the Communities and which,

after analysis, was considered to impact well-being improvement greatly. [ESRS 2.48a | S3.8a-i]

The Company identifies and assesses the impacts on the Communities in which it operates, using this information to adjust the

strategy and business model, promoting the creation of shared value and ensuring that its operations are aligned with the

needs of the Communities, through initiatives that enhance social and environmental benefits. [S.38a-ii]

The disclosure of this report is focused on the affected Communities: (i) in the vicinity of forestry operations in the Iberian

Peninsula – Communities and local entities that benefit from the impacts generated by forestry activity; (ii) in the vicinity of

forestry operations in Mozambique – Local communities and local entities that benefit from the impacts generated by forestry

activity (employment generated by the need for labour) and by the implementation of the Social Development Program, where

there are family and community benefits, namely water holes and improvement and construction of paths and infrastructures; (iii)

in the vicinity of factories – Local population, Municipalities, Parish Councils, local entities, Non-Governmental Organizations and

Universities. [S3.9a]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 274

5.3.3.2. Impacts, risks and opportunities management

5.3.3.2.1. Policies related to Affected Communities (S3-1, MDR-P)

We have adopted a range of policies that reflect our commitment to the Communities involved in our operations, with special

attention to the rights of local populations. Of these, we highlight: the Code of Ethics and Conduct and the Human Rights

Policy – of transversal application to our Organisation and extendable to the counterparts we have relations with; the Forest

Policies of Portugal and Mozambique; and in the context of Portucel Moçambique, the Community Engagement Policy and the

Social Development Program of Portucel Moçambique.

These policies are aligned with widely recognised international instruments, such as the United Nations (UN) Guiding Principles on

Business and Human Rights, which guide business performance in respecting and promoting Human Rights. We thus ensure that

our practices are in line with these principles by implementing actions ensuring protection and respect for Communities and their

rights, including the consultation and active involvement of local populations in managing the impacts of our activities. [S3.17-1]

With this focus, we assume our social responsibility to the Communities we operate in, contributing to their progress and well-

being, as stated in article 18. Social Responsibility and Sustainable Development, of the Code of Ethics and Conduct

(Chap. 5.4.1

We have implemented a Human Rights Policy (Chap. 5.4.1), expressing our commitment to: (i) promote the involvement of

Communities to obtain feedback on Human Rights and labour rights, acknowledging the importance of their consultation and

continuous dialogue to integrate their concerns into internal decision-making processes; and (ii) act in a way that respects the

Human Rights of local Communities, including, where applicable, indigenous peoples, namely by adopting measures to minimise

negative impacts and protect their values, culture and traditions. [ESRS 2.65a | S3.15]

It is worth mentioning that, as the forest is our main source of resources, we also have Forestry Policies in Portugal and

Mozambique (Chap. 5.2.6. One of the priorities is to promote knowledge about its benefits and the importance of the sustainable

use of forest-based products for society. These policies have two underlying principles, e.g. reinforcing the commitment to: (i)

maintain and improve the responsible management of forest spaces, in balance with their natural and social environment,

developing and promoting actions, including with third parties, that guarantee the non-deforestation, degradation and/or

conversion of the forest; and, (ii) availability to receive and respond to questions posed by stakeholders, disseminating the Forest

Policy, promoting a relationship of high social and environmental responsibility with the surrounding Communities and abiding by

the principles of the International Labour Organization. These commitments are guaranteed, in Portugal, through the application

of the processes DGF N8 - Land Use, DGF S9 - Communication with Stakeholders and DGF S10 - Procurement of Goods and

Services and, in Mozambique, by the Relationship Management Mechanism and the Social Development Program, developed later.

Through the application of the Forest Policy in Portugal, Navigator undertakes to respect the pan-European criteria for sustainable

forest management in accordance with the Portuguese Standard NP 4406 for Sustainable Forest Management and the FSC

Principles and Criteria (FSC

-C010852) [ESRS 2.65d], thus assisting in the preservation of natural values and ecosystems, soil

formation and the fight against erosion, protection of the forest against fires and regularisation of the water cycle, valuing a land

use that stimulates territorial cohesion and the creation of wealth.

The Community Engagement Policy

developed for Mozambique is a fundamental pillar of our Corporate Social Responsibility. This

policy reflects our commitment to cooperate, dialogue and support the Communities in the areas close to our forest areas, to build

inclusive and long-term relationships, based on transparency and mutual respect between the parties involved, in a context in

which we intend to contribute to their sustainable socioeconomic development. [ESRS 2.65] Portucel Moçambique's relationship

with the Communities is based on dialogue and the regular implementation of the following principles: (i) proactively ensure the

regular involvement of all key Stakeholders; (ii) respect all the rights, traditions and cultural heritage of the Communities, always

within the framework of national legislation and respect for Human Rights; (iii) ensure proactive involvement, with a view to

effective communication, based on informed and participatory consultations; (iv) create opportunities for socio-economic

development in the Communities, through the employment generated in forestry operations and the activities of the Social

Development Program; (v) respecting labour legislation, as well as promoting gender equality in access to employment

ANNUAL REPORT 2024 • MANAGEMENT REPORT 275

opportunities; (vi) promoting a culture of health and safety at work; (vii) defending the interests of the community against any

corrupt practices; (viii) providing a Relationship Management Mechanism, so that any person or entity can be heard, ensuring

their protection from any reprisals; and, (ix) raising the Communities’ awareness to the benefits of adopting good environmental

practices.

Document

Community Engagement Policy

Description of key

contents and general

objectives

[ESRS 2.65 a]

Portucel Mozambique's relationship with the Communities is based on dialogue and the

implementation of a relationship we wish to be inclusive and long-term, based on transparency

and mutual respect between the parties involved, in a context in which we intend to contribute

to their sustainable socioeconomic development.

Scope

[ESRS 2.65b]

It focuses on the Group's own operations and the entire value chain, involving Employees,

Stakeholders (government) and Local Communities. It covers the geography of Mozambique.

Most senior level

position accountable for

its implementation

[ESRS 2.65c]

Executive Committee of Portucel Moçambique

Standards or third party

initiatives

which the Company

undertakes to comply

with

[ESRS 2.65d]

Universal Declaration of Human Rights and ILO Conventions;

Availability

[ESRS 2.65f]

Made available to all employees and materially relevant stakeholders, and in all consultation

processes.

Available through the Intranet and Internet pages.

Employees are also trained in this matter.

Thus, Portucel Moçambique, committed to the involvement of the Communities in the development of its project, developed the

Social Development Program (SDP)

, to contribute to the sustainable socio-economic development of the Communities [ESRS

2.65]. The SDP responds, in part, to the specific risks to Communities identified in the Environmental and Social Impact Study

(ESIS), between 2011 and 2013. The ESIS identified a base scenario where the approximately 24,000 families present in the

project's implementation areas have high rates of food insecurity, low income, low agricultural productivity (e.g: cassava, corn),

low access to drinking water, among others. The ESIS provided the baseline objective for establishing the three priorities of the

SDP that seek to minimise these risks – strengthening food security, encouraging income generation, and improving the well-

being of Communities.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 276

Figure 1 - Priorities of the Social Development Program

Document

Social Development Program of Portucel Moçambique

Description of key

contents and general

objectives

[ESRS 2.65 a]

Portucel Moçambique is committed to the involvement of the Communities in the development

of its project in Mozambique, in a context in which it intends to contribute to its sustainable

and inclusive socioeconomic development.

Scope

[ESRS 2.65b]

It focuses on the Group's own operations and the entire value chain of the Group, involving

Employees, Stakeholders (Government, Local Communities and Civil Society). It covers the

geography of Mozambique.

Most senior level

position accountable for

its implementation

[ESRS 2.65c]

Board of Directors

Standards or third party

initiatives

which the Company

undertakes to comply

with

[ESRS 2.65d]

Universal Declaration of Human Rights and ILO Conventions;

Availability

[ESRS 2.65f]

Made available to all employees and materially relevant stakeholders, and in all consultation

processes.

Available through the Intranet and Internet pages.

Employees are also trained in this matter.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 277

It is worth mentioning that, during the reporting year, there were no significant changes in the policies adopted [AR9].

The following information is included by reference to other parts of the Non-Financial Statement (MDR-P, ESRS 2, §65 a/b/c/d/f):

• Presentation of the Code of Ethics and Conduct: Chap. 5.4.1

• Presentation of the Human Rights Policy: Chap. 5.4.1

• Presentation of the Forestry Policy: Chap. 5.2.6.

5.3.3.2.2. Processes for engaging with affected communities about impacts (S3-2)

At Navigator, we are committed to involving national, international and local institutional stakeholders, listening to and aligning

their expectations with the Company's strategy and needs. To this end, we use several forms of communication and engagement,

whose channels and frequency change according to the stakeholder group and the needs identified. [S3.21]

Among the formal mechanisms for direct interaction with the several stakeholder groups, we highlight the established bilateral

communication channels, such as the Community Monitoring Committees, the Community Relationship Management

Mechanism and regular contact with stakeholders in relation to forestry activity. In addition, we promote the

Sustainability Forum (Cap. 3.4.5), a dialogue space that meets twice a year, with one of these sessions of regional focus, to

enhance greater proximity to local communities and benefit the cooperation between Navigator and the several municipalities

where we develop activities. In this way, we seek to consolidate relationships of trust and the social license to operate,

increasing transparency and identifying possible risks and opportunities.

In addition, we have developed other initiatives that promote the approach to Communities, such as the Navigator Tour, which

provides a direct view of our work and the way we operate in factories, RAIZ and nurseries. [S3.21 and S3.21d]

It is worth mentioning that Navigator does not have operations in geographies where indigenous peoples are present. Even so,

the Company's commitment to this matter is enshrined in its Human Rights Policy, under point 2. g) [S3.23].

Community Monitoring Committees (CMCs)

The Community Monitoring Committees (CMCs) are structures that fall within the areas of operation of the Company's

industrial complexes in Portugal, namely in Aveiro, Figueira da Foz, Setúbal and Vila Velha de Ródão. These meetings, held in

the surroundings of each Navigator industrial unit, are of great relevance to understanding the concerns of the Communities,

seeking to meet their needs and bring the Company closer to the local Communities. [S3.21 and S3.22] Two meetings are held

annually in each of Navigator's four industrial complexes – in the 2nd and 4th quarters. [S3.21d]

These Committees are led by a President (independent personality external to Navigator), with representatives of Navigator's

Management and areas such as Public Affairs, Industrial, Environment, Human Resources and Sustainability and various

Stakeholders – representatives of Municipalities, local entities, Non-Governmental Organisations, Universities, among others.

[S3.21, S3.21 and S3.22]

The interaction generated in the meetings of the CMC facilitates joint reflection on matters that concern the life of the

Communities, and the comments of its members are recorded, for later monitoring by Navigator's internal structures. The entities

ANNUAL REPORT 2024 • MANAGEMENT REPORT 278

are subsequently informed of the progress/results of the initiatives developed. [S3.21 and S3.22] There are several topics

addressed, with emphasis on industrial development projects, focusing on decarbonisation, environmental performance,

environmental and forestry investments, the strategy of sustainability plans, the social environment and people development,

among others. These are exposed with transparency, being analysed and discussed together, and minutes are prepared that are

approved by the parties involved and that allow the subsequent monitoring of the progress achieved in the various situations

analysed. In each meeting there is room for questions and answers, through an open and plural dialogue with participants. This

active voice in the themes that concern the Communities, and that can range from the impacts of the Company's activity

(environmental and social) to projects, has the potential to increase the well-being and quality of life of people. [S3.21 and S3.22]

It is important to highlight the institutional cooperation that characterises the Monitoring Committee for the Communities of

Figueira da Foz, which is carried out by the two companies in the Pulp and Paper sector present in this region – Navigator and

Celbi – in a joint effort to build relationships with local stakeholders. In this context, both companies seek to collaborate with the

Parish Councils in order to support the populations and the different local associations. All these agents participate in the

Community Monitoring Committees, expressing, in a close and direct manner, their concerns and suggestions for improvement to

the representatives of the two companies, who cooperate in order to find solutions to the situations presented. [S3.21]

Community Relationship Management Mechanism in Mozambique

By establishing the Community Relationship Management Mechanism, Portucel Moçambique reaffirms its commitment to try to

ensure a balanced and fair relationship and contribute to the development of communities and families in the geographical areas

covered by its project. The Mechanism is a process of receiving, analysing and responding to questions posed by

Stakeholders. Portucel Moçambique assumes this Mechanism as a tool to manage aspects of potential or actual conflict, but also

as a tool to assess the interconnection of the project with the Community and, to that extent, better understand the areas to

improve its practices. [S3.21d]

The Community Relationship Management Mechanism is an appropriate tool for projects with potential environmental and social

impact, as it defines the interlocutors and the formats by which the Company must be guided to relate to stakeholders, so that

information, suggestions and/or complaints may be assessed and followed effectively for both parties – the Company and

communities and families – ensuring that communities and families have prior information to decide freely and in an informed

manner on issues common to both parties (FPIC-Free, Prior and Informed Consent). This procedure is shared by the IFC -

International Finance Corporation – World Bank –, within the scope of its Performance Standards, which recommend that, in

projects with potentially significant adverse impacts on the Communities, involvement with Stakeholders be carried out based on

an informed and participatory consultation and that a Community Relationship Management Mechanism be installed. [S3.21]

The implementation of this Mechanism has several advantages. In addition to the management component of a balanced and fair

relationship, it serves as an instrument for monitoring and evaluating the project, allowing conclusions and lessons learned for the

improvement of its systems and processes. On the other hand, it is an instrument of accountability to the Communities and other

Stakeholders in a transparent way, since, periodically, the Company publicise its performance in the scope of relationship

management and social actions. [S3.21d]

To this end, there are several strategies for the implementation of this interaction, such as community meetings, "village

meetings" (in the villages), "door-to-door" visits and the regular presence in the Communities of Community Liaison Agents

(CLA) [S3.21d]. Community Liaison Agents (CLAs) are appointed by the Community and supported by Portucel Moçambique,

which interconnect the communication between the Company and the families of one or more Communities. CLA speak the local

language, thus helping the inclusion of all participants and promoting good communication in the Company's regular meetings

with the Community and families. They interact regularly with the team of Communication Technicians of Portucel Moçambique, to

manage the relationship with the Communities at a more comprehensive level and coordinate and plan the work to be developed,

ensuring the consistency of the actions developed in this scope. CLAs and Communication Technicians receive regular training,

namely on topics such as Human Rights, non-discrimination by gender or age, avoiding corruption and others. They also receive

technical training, including the use of equipment and software to improve communication. Both Liaison Agents and

Communication Technicians, as well as any Employee of the Company, are possible interfaces of the Relationship Management

ANNUAL REPORT 2024 • MANAGEMENT REPORT 279

Mechanism, anyone can have access to and which is intended to register complaints, suggestions or other concerns of the

Company's Stakeholders, especially members of the Communities, in their relationship with the Company.

We should be mindful of the fact that, in its values and principles, this Mechanism establishes equal access, regardless of its

social, racial, cultural or physiological status. The principles of non-discrimination are common practice in the several activities of

the Company, both in terms of employment and in the relationship with Communities and families. For example, the Community

Environmental Awareness Program, and taking into account cultural characteristics, includes meetings organised to give a voice

specifically to women. [S3.22]

Forestry Activity

In Portugal, in the forestry activity, regular contact is made with the Stakeholders to receive feedback regarding the impacts (social

and environmental) of our operations. Information gathering is operationalised through consultations, informal conversations

or circumstances provided by events: (i) in assessments made before operational planning and project preparation, by

completing the Operational Planning and Project Preparation Support checklist, selecting stakeholders in light of current values or

the framework of the area to be intervened; (ii) before or during forestry operations, through communication occurs by filling in the

Local Stakeholder Consultation form; (iii) in meetings held for specific purposes, whereby minutes of those meetings or reports are

produced; and (iv) whenever there are forestry operation impacts these are registered as events. [S3.21 and S3.22]

Assessment of the effectiveness of the dialogue with the affected communities is carried out through annual consultations with

stakeholders by the certifying entity on forest management in the areas managed by the Company. [S3.21d]

If the impacts identified through these regular contacts and the measures defined to mitigate them are not yet reflected in the

technical reference of the Forest Management System, we proceed to incorporate them so they can be taken into account in the

next interventions.

5.3.3.2.3. Processes to remediate negative impacts and channels for affected communities to raise

concerns (S3-3)

So far no negative impacts on the economic, social and cultural rights of the Community have been identified but, nonetheless, we

adopted a systemic approach in the company to identify and assess environmental and social impacts of forestry

activities. This process results in matrices used in the planning and execution phase of operations, to prevent negative impacts

and necessary action should such impacts occur. [S3.27b]

Under this assessment and as referred to in the previous section, we have conducted local consultations with Stakeholders,

including local Communities and/or Experts on the different natural, social and cultural aspects involved. We provide several

contact channels (Chap. 5.4.1) to ensure effective communication with the relevant Stakeholders We have a Regulation and a

Whistleblowing Channel

(Chap. 5.4.1), accessible to any member of the affected Communities. This Channel allows

communication and analysis of potential human rights violations, including non-compliance with the Code of Ethics and Conduct

and the Human Rights Policy. In addition, Stakeholders may also refer directly to our Employees via email

and/or telephone

In Mozambique, we rely also on Community Liaison Agents as an important bridge for direct communication with the

Communities. These channels provide a transparent and accessible way for communities and other Stakeholders to express

concerns and seek remediation, if necessary. [S3.27b]

37 Email for Portugal and Spain: cadastro.f[email protected] / | Email for Mozambique:

comunicacao.mz@thenavigatorcompany.com

38 Phone contact for Portugal and Spain: (+351) 265 709 000 | Phone contacts for Mozambique (+258) 2148 3645/6/7

ANNUAL REPORT 2024 • MANAGEMENT REPORT 280

5.3.3.2.4. Taking action on material impacts on affected communities, and approaches to managing

material risks and pursuing material opportunities related to affected communities, and

effectiveness of those actions (S3-4)

We commit to implementing assorted actions to enhance dialogue and reinforce the positive impacts on the Communities involved

in our operations, thus helping achieve the defined objectives and goals (see next section). [ESRS 2.68a | S3.32c]

Main actions

Status

Scope of action

Time Horizon

Results

[ESRS 2.68 a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68 a]

ESRS 2.68e]

Community Monitoring Committees in Portugal

Community Monitoring

Committees (CMCs)

Executed and

planned

They are held in

Aveiro, Figueira da

Foz, Vila Velha de

Ródão and Setúbal,

relying on the

presence of

representatives of local

living forces (e.g.

public entities, local

authorities, NGOs,

schools). It has a

downstream impact on

the value chain.

Continuous Actions

In 2024, in those meetings

environmental issues of each industrial

unit, and ongoing investments were

put forward. Topics related to human

resources and forest fires that have

occurred in the 2nd semester - causes,

what happened and how to mitigate -

were also addressed.

Forestry Activity in Portugal and Spain

Communication with

Stakeholders

Executed and

planned

Carried out in its own

operations and

involves all

stakeholders in

Portugal and Spain.

Continuous Actions

Conducting regular contact with

Stakeholders to collect points of view

regarding the impacts (social and

environmental) of our operations.

During 2024, a first analysis was

carried out, incorporating positive and

negative impacts, and the adoption of

an approach allowing centralisation of

information is under analysis.

Land use

Executed and

planned

It is carried out

downstream of the

value chain. It involves

third parties in

Portugal and Spain.

Continuous Actions

Prospecting and development of

business opportunities within the

scope of multiple forest use, for the

use of agroforestry spaces:

- Sale of 4360 arrobas of cork

(revenue: €145,224);

- Sale of pasture for grazing in 1142

ha (revenue: €8666)

- Provision of 9393 ha for hunting

activities (revenue: €37,128)

- Provision of 2868 ha for field

boundary-setting purposes (revenue:

€162,555)

- Sale of eucalyptus branches in 564

ha (revenue: € 48,746)

Community Relationship Management Mechanism in Mozambique

Settlement Meetings

Executed and

planned

Carried out in its own

operations and

throughout the value

chain. It involves the

communities and local

entities of

Mozambique.

Continuous Actions

In 2024, 41 prior consultation and

information meetings were held with

the Communities.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 281

Main actions

Status

Scope of action

Time Horizon

Results

[ESRS 2.68 a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68 a]

ESRS 2.68e]

Door-to-door visits

Executed and

planned

Carried out in its own

operations and

throughout the value

chain. Involves the

communities and local

entities of

Mozambique.

Continuous Actions

Family visits, consultation on their

needs and assessment of the level of

satisfaction.

Visits to the work

fronts

Executed and

planned

Carried out in its own

operations and

throughout the value

chain. Involves local

Communities and

Service Providers in

Mozambique.

Continuous Actions

In 2024, we carried out 307 visits by

Liaison Agents to the work fronts, to

verify compliance with the rules of

contracting, good practices and Human

Rights, based on established forms.

Social Development Program in Mozambique

Strengthening food

safety and diversity

Executed and

planned

Value chain, with an

impact on local

communities in

Mozambique

Continuous Actions since

2015

Included agricultural extension,

through the delivery of seeds, sweet

potato branches and cassava cuttings

and the monitoring of the production

process, with a team of Technical

Experts who assisted families

individually, as well as in

demonstration fields from several

families to figure out the most suitable

crops and the best practices.

The construction of barns was also

supported, to store seeds and cereals

for longer periods, for consumption or

marketing, and the construction of 15

gardens in schools, irrigated and non-

irrigated to improve young people's

knowledge of best farming practices

and inducing improvements in food

safety and diversity, as well as the

means to increase income. For further

information on the results obtained

see the goals and metrics section

Increasing the means

to improve yield

Executed and

planned

Value chain, with an

impact on local

communities in

Mozambique

Continuous Actions since

2015

It includes beekeeping, fish farming,

goat herding. In all these actions,

Portucel Moçambique supported the

start of activity, with materials and

technical assistance. Beneficiaries also

assumed some obligations, within the

scope of the commitment to develop

the respective activity autonomously –

see the targets and metrics section for

information on the results obtained.

Improving well-being

Executed and

planned

Value chain, with an

impact on local

communities in

Mozambique

Continuous Actions since

2015

Included actions such as access to

drinking water, renewable energy,

renovation of schools (21 thousand

euros investment), support for the

construction of hospital

infrastructures, building and

renovation of access roads and

bridges. The

improvement/construction of hydraulic

passages (bridges and aqueducts) was

also carried out, amounting to 65

thousand euro – see the goals and

metrics section for further information

on the results obtained.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 282

Note: No negative material impacts associated with the economic, social and cultural rights of the Community were identified, only positive impacts

[S3.32c] and hence no remediation actions are identified. [ESRS 2.68d]

In 2024, we held the Community Monitoring Committees meetings in Aveiro, Figueira da Foz, Vila Velha de Ródão and

Setúbal. The focus of the debate was immigration and the need to integrate foreign people, both in the Communities and in

companies, creating effective conditions for inclusion. The presence of representatives from local schools was crucial to engage in

an informed debate on the mechanisms to be developed in order to integrate immigrants, namely through lessons on Portuguese

language and national culture and customs, as well as respect for women's rights. This theme was particularly highlighted in the

industrial centre of Vila Velha de Ródão, a region in the hinterland where it is more difficult to attract talent and labour [S3.22].

This year, a survey was made to learn about the environmental, social and economic issues Community representatives

considered most relevant. In view of this active listening, also in 2024, we took into account forest management, making

Navigator's good practices known. Thus, in the 4th quarter, we addressed forest fires, in particular the events of September 2024,

proving that the problem does not lie in the type of species planted, but rather in the type of forest management, which increases

the resilience of territories, betting on fire prevention. In addition, topics from the social sphere were introduced in the meetings

of the CMC meetings, namely programs for the recruitment, training and integration of Technical Experts in the industrial front.

[S3.21d]

As regards forestry in Portugal and Spain, we made a regular contact with the Stakeholders to collect points of view regarding

the impacts (social and environmental), prospecting and developing business opportunities within the scope of the multiple forest

uses, for the use of agroforestry spaces. Only the implementation of this action – Land Use – required significant operating expenses

(OpEx) (current and future), via the Land Use budget. [ESRS 2.68] [ESRS 2.69b]

The Social Development Program in Mozambique has three priority areas of intervention – (i) strengthening food

security and diversity, (ii) increasing the means to increase income and (iii) improving well-being – which were continued during

the reporting year. It is worth mentioning the incentive to adopt conservation agriculture techniques as a widespread practice in

this process with a view to improving production and productivity and promoting access to drinking water for local Communities in

Mozambique. The water protocol implemented by Portucel Moçambique shows that the water upstream of the operations already

has microbiological contamination levels due to the intensive use of this resource for hygiene and cleaning. To mitigate this

problem, community environmental awareness initiatives were created where, calling for, among other topics addressed, the need

for water protection, including safety distances to the river for certain activities and the need to boil water intended for

consumption. These actions are associated with the Social Development Program focused on conservation agriculture, promoting

better use of soil humidity and resilience to extreme weather events (torrential rains and severe droughts).

In the future, we intend to invest in the Community Monitoring Committees, promoting greater involvement of the Municipalities

in Portugal in the strategic regions for Navigator's industrial activities. In Mozambique, Village Meetings, door-to-door visits, and

visits to the work fronts will be the main initiatives to be implemented.

As for the type of financial and other resources, current and future, allocated to the action plan, it is worth mentioning that

Navigator adopted additional measures and initiatives, aimed especially at generating positive impacts for the affected

Communities, such as the promotion of forest and biodiversity literacy, following these projects through metrics, in its 2030

roadmap. [S3.32c and S3.32d] [S3.38]

Assessing the effectiveness of the initiatives developed is an ongoing process and the good results of such initiative are there

given the absence of negative feedback. Under these actions, comprehensive consultation is promoted with Stakeholders,

including the local Community and Experts from several areas with potential impact on them.

In addition, we provide multiple communication channels, so that Stakeholders may express their opinions and concerns, such as

The Navigator Company's website and the Reporting Channel.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 283

In forestry operations in Portugal, Spain and Mozambique, contact can be made in person, with our Employees, by email or

telephone.

In Mozambique, there are also Community Liaison Agents, play an essential role in maintaining a fluid communication between

the Community and the Company. There is also a relationship management mechanism, which systematizes all requests —

information, complaints, doubts, among others — seeking to provide an assessment and response in a timely manner.

[ESRS3.32d]

Current financial resources are invested in actions or action plans with community impact, mainly in the form of staff costs and

payments to Suppliers, as well as through the Social Development Program. [ESRS 2.69b]

5.3.3.3. Targets and Metrics

5.3.3.3.1. Targets related to managing material negative impacts, advancing positive impacts, and

managing material risks and opportunities (S3-5, MDR-T)

Under our 2030 Roadmap (Cap. 3.4.4), we intend to hold, annually, eight Community Monitoring Committee meetings in the

surroundings of the industrial units of Aveiro, Figueira da Foz, Setúbal and Vila Velha de Ródão [ESRS 2.80]. This goal is in line

with SDG 12 – Sustainable Production and Consumption, as it falls under target 12.8 – Until 2030, to ensure that people

everywhere have relevant information and awareness for sustainable development and lifestyles in harmony with nature.

[S3.AR35]

Note: Intermediate targets [ESRS 2.80e] have not been developed, nor have there been changes in relation to the value and year of the target, the

calculation or data collection methodology, the assumptions, the sources or the limitations, as these are new targets for Navigator [ESRS 2.80i]. None of

the metrics were validated by an external body. [ESRS 2.77b]

The target covers the downstream value chain in Portugal [ESRS 2.80c] and is not directly related to the previously described

policies [ESRS 2.80a]. It was defined based on the following qualitative assumptions: the holding of a meeting in the 2nd quarter

and another in the 4th quarter of each year, in the four Navigator industrial units in Portugal – Aveiro, Figueira da Foz, Setúbal

and Vila Velha de Ródão –, with the participation of the representatives of the main Stakeholders of the regions in which the

39 Email PT and ES: cadastro.florestal@thenavigatorcompany.com | Phone contact PT and ES: (+351) 265 709 000 |

Email MZ: [email protected]

Target and

goal

Baseline Associated metric

2022

performance

2023

Performance

2024

performance

Results to

achieve

[ESRS 2.80d]

[ESRS 2.75]

[ESRS 2.80J]

[ESRS 2.80e]

Hold, annually, 8

meetings of the

Community

Monitoring

Committees, in

the surroundings

of the industrial

units of Aveiro,

Figueira da Foz,

Setúbal and Vila

Velha de Ródão.

Baseline

value:

3 CMCs

meetings

Baseline

year:

2022

No. of CMC meetings

3 CMC meetings 8 CMC meetings 8 CMC meetings

8 CMC

meetings/yea

Target Year:

2030

ANNUAL REPORT 2024 • MANAGEMENT REPORT 284

Company develops its operations. Meetings are scheduled upon availability of the CMC Chairman, an independent personality, and

Navigator members. For each meeting, there is a call with an agenda of environmental and social issues relevant to Navigator and

the Communities. The model and the periodicity were agreed between the parties – Navigator, Chairman of the Committee and

Stakeholders involved and was calculated based on the minutes of the meetings held [ESRS 2.80f/h and ESRS 2.77 a/c]. In 2024,

we met the goal by holding the eight planned meetings.

5.3.3.3.2 Entity-specific metrics- MDR-M

In addition to the metrics associated with the goals explained, other entity-specific metrics were also defined, related to: (i)

investment in infrastructure and services for Communities in Portugal, including investment in euros in Communities; and

(ii) the Social Development Program in Mozambique. [ESRS 2.77c]

Metrics

2024

Investment in infrastructure and services for Communities

Paper donations, in Portugal

41.9 t

Over €50,000

Donation of nursery plants in Portugal 875 plants

Monetary support in Portugal €37,096

Investment, in euros, in initiatives for the Community 1.6 M

Social Development Program in Mozambique

Households covered 7000

Improved and distributed seeds 1.153 t

Improved barns 2465

Orange-fleshed sweet potato slices 111,928 kg

Cassava seedlings and cuttings

1,113,982

Cassava seedlings (96,738) and cuttings

(1,017,244)

Assigned kits 2922

Fish tanks 65

Distributed hives 1757

Honey produced 6326 kg

Constructed water holes 38

Water holes rehabilitated 64

Solar lanterns delivered 4203

Vaccines given to poultry against Newcastle disease 949,201

People involved in environmental awareness 15,175 (45% women)

Investment, in US dollars, in the initiatives of the Social Development Program in

Mozambique

8.2M

Note: None of the metrics were validated by an external body [ESRS 2.77b]

40 On 12/31/2024, accumulated since the beginning of the Social Development Program in Mozambique

ANNUAL REPORT 2024 • MANAGEMENT REPORT 285

In 2024, investment in the Mozambique Social Development Program amounted to about 600 thousand euros. It is also worth

mentioning that, with this Program, we have responded to requests from several Stakeholders, in emergencies resulting from

natural disasters and extreme weather events, such as cyclones, floods and the like, contributing with resources, equipment and

essential goods. In 2024, these contributions totalled about 16 thousand euros, in the provinces of Manica and Zambezia. Portucel

Moçambique also supplies construction materials and eucalyptus stakes for health, education and public administration

institutions. [ESRS 2.77a]

Navigator Tour

With a view to approaching the Communities, we carried out 112 visits within the scope of the Navigator Tour in 2024, with a total

of 2855 visitors:

• 48 school visits (includes higher education), with 1539 participants;

• 56 institutional visits, with 760 participants;

• 7 Employee visits, with 556 participants.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 286

5.4. Governance Information

5.4.1. ESRS G1: Bussiness Conduct

5.4.1.1. Strategy

5.4.1.1.1. Material impacts, risks and opportunities and their interaction with the strategy and business

model (ESRS 2 SBM-3)

Description

Impact, Risk

or Opportunity

Time Horizon

Location

in the value chain

Sub-topic or related

sub-sub-topic

[ESRS 2.48a]

[ESRS 2.48ciii]

[ESRS 2.48a]

[ESRS 2.48h]

Development of a responsible

corporate culture increases the

sense of belonging of

Employees, their motivation and

the Navigator's retention

capacity.

Positive impact - Own operations Corporate culture

Responsible management of

Suppliers, establishing

partnerships that share social

and environmental responsibility

values, can contribute positively

to the Community and the

environment.

Positive impact - Own operations

Management of Supplier

relations, including

payment practices

Robust corruption prevention

practices contribute to a fairer

and more transparent business

environment.

Positive impact - Own operations Corruption and bribery

Disclosure of incorrect

information may have

consequences on Navigator's

reputation and may even incur

fines.

Risk

Short Term - Reporting

Year

Own operations Corporate culture

The use of artificial intelligence,

robotics, loT technologies in

industrial processes

(cybersecurity) can result in

production losses

Risk

Short Term - Reporting

Year

Own operations Corporate culture

Note: The identified material impacts are real and not time-specific.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 287

5.4.1.2. Impacts, risks and opportunities management

5.4.1.2.1. Business conduct policies and corporate culture (G1-1, MDR-P)

Promotion of corporate culture

We are committed to ensuring Responsible Business Conduct, supported by the basic principles of Trust, Integrity,

Entrepreneurship, Innovation, Sustainability and Excellence, reflected in a comprehensive set of Group Codes and Policies

– including Codes of Ethics and Conduct, Human Rights Policy, Compliance Policies, among other documents.

To effectively implement these principles, we have a robust and efficient compliance system, ensuring clarity in responsibilities

and promoting effective communication between the several parties involved. This system is in line with international best

practices, with its structure and organisation based on the coordinated performance of the internal functional units, together with

the management and supervisory bodies, to support the decision-making process, ensuring transparency and integrity throughout

the value chain [G1.9]. To this end, we have established a Compliance Area, integrated into the Legal, Compliance and Public

Affairs Department, in charge of implementing the Compliance Policies that frame the Navigator Group's activity throughout the

legal and regulatory value chain, in a logic of transparency and justice, within the scope of preventing and combating unlawful

acts. The main mission of this Area is to ensure compliance with applicable legal requirements, preventing corruption, money

laundering, terrorist financing, compliance with international sanctions, conflicts of interest and promoting the protection of

Human Rights and personal data [G1.9].

We highlight the Ethics and Integrity Committee, which plays a fundamental role in promoting and supervising the ethical

principles that guide our performance. Its regulation defines the competencies, operation and responsibilities, ensuring the

effective application of ethics and conduct standards. By analysing and monitoring ethical issues, this committee reinforces

Navigator's commitment to integrity, transparency and responsibility [G1.9].

To promote a culture of compliance, based on ethical and integrated performance, we invest in the training of our Employees. To

this end, we provide continuous training on compliance matters, namely regarding the Code of Ethics and Conduct, Internal

Policies, Communication of Irregularities, Procedures to Address Corruption and Related Infractions (see section G1-3). Available

in e-learning format, these trainings are addressed to all Employees and use practical cases to promote an interactive learning of

the response that the Company's internal tools offer in everyday situations. The objective is to publicise and reinforce the

importance of these instruments, stimulating the understanding of the principles expressed in them. In 2025, the Compliance

Area should complement the existing training providing more complete and specific training on the protection of personal data and

Human Rights. [G1.9 | G1.10g]

We also invest in the evolution and development of our organisational culture, encouraging employee engagement through

innovative programs. The “CRESCER” (GROWING) project (Chap. 5.3.1), for example, aims to strengthen corporate identity

and promote a collaborative and inclusive working environment. [G1.9]

Focusing on the involvement, alignment and development of young people, we created programs such as the Future Leaders

Forum and the Future Leaders Board, promoting the active participation of emerging talents in business strategy. In addition, the

Straight To The Top program encourages innovation and continuous improvement through the sharing of ideas and is open to all

employees (Cap. 5.3.1) [G1.9].

Internal communication, essential for the development of corporate identity – by aligning values, strengthening organisational

culture and promoting the involvement of Employees in Navigator's strategic vision – is also a priority area, with emphasis on the

periodic holding of the Directors' Forum and the Supervisors' Forum, to ensure alignment between top management and

operational teams.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 288

Recognition and appreciation of Employees are important means to develop a solid corporate culture, promote motivation,

engagement and a positive and productive work environment. Thus, the performance and productivity awards, combined with the

celebration of special dates – such as the Remembrances of Antiquity, awarding those who have contributed to Navigator's history

over the years – and the commitment to initiatives of approximation – such as the Family Open Doors program and the holiday

colony for the children of Employees – reinforce the sense of belonging and involvement with the corporate culture [G1.9].

Policies and documents structuring corporate culture

Among the structuring documents of our business culture, we highlight the Code of Ethics and Conduct, which defines the model

of ethical and professional conduct to be complied with by all Employees – both in the pursuit of Navigator's business activity and

in the relationship with third parties – and its basic principles, promoting an organisational culture based on excellence,

transparency, respect and sustainable development. Regulated issues under the Code of Ethics and Conduct are later translated

into policies, specific codes of conduct, internal procedures and guidelines.

[G1.7 | ESRS 2.65]

Document

Code of Ethics and Conduct

Description of key

contents and general

objectives

[ESRS 2.65 a]

The Code of Ethics and Conduct mirrors Navigator's values, namely: Trust, Integrity, Entrepreneurship,

Innovation, Sustainability and Excellence.

In addition, it deals with central topics such as: Prevention of corruption and money laundering; Conflicts of

interest; Relations with Shareholders; Competition; Intellectual and industrial property; Social responsibility

and sustainable development; Safety and working conditions; Professional development and progression;

Discrimination and protection of personal data, among others.

Scope

[ESRS 2.65b]

It focuses on its own operations. It has an impact on all Group Stakeholders, in particular Employees and

Communities. It is transversal to all geographies where Navigator operates.

Most senior level

position accountable for

its implementation

[ESRS 2.65c]

Board of Directors

Third party standards

or initiatives

the Company undertakes

to respect

[ESRS 2.65d]

In line with the Universal Declaration of Human Rights and ILO Conventions;

Availability

[ESRS 2.65f]

This document is communicated to all Employees, Business Partners and Stakeholders through the Intranet

and Internet sites.

Employees are also trained in this matter.

References throughout

of the non-financial

Statement

S1 – Own workforce (Chap. 5.3.1)

S3 – Affected communities (Chap. 5.3.3)

Through our Human Rights Policy

, we assume the importance of respect for Human Rights and labour rights as an integral part of

the global development of our business activity, in accordance with the principles established in reference intergovernmental

documents.

[ESRS 2.65d]

Document

Human Rights Policy

Description of key contents

and general objectives

It affirms Navigator's commitment to Human and Labour Rights, integrating them into the development of

its activity, under international reference standards.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 289

[ESRS 2.65 a]

Scope

[ESRS 2.65b]

It focuses on its own operations and the upstream and downstream value chain. It has an impact on all

Group Stakeholders, in particular Employees and Communities. It is transversal to all geographies where

Navigator operates.

Most senior level position

accountable for its

implementation

[ESRS 2.65c]

Board of Directors

Third-party standards

or initiatives the Company

undertakes to respect

[ESRS 2.65d / S1.20]

•International Bill of Human Rights

• OECD Guidelines for Multinational Enterprises

• Fundamental Conventions of the International Labour Organization (ILO)

• The United Nations Guiding Principles on Business and Human Rights.

Availability

[ESRS 2.65f]

This document is communicated to all Employees, Business Partners and Stakeholders through the

Intranet and Internet sites.

Employees are also trained in this matter.

Most relevant

complementary

documentation

Internal Regulations and Good Practices Policies for Occasional Workers and Service Providers of Portucel

Moçambique

References throughout of

the non-financial

Statement

S1 – own workforce (Chap. 5.3.1)

S2 – Workers in the value chain (Chap. 5.3.2)

S3 – Affected communities (Chap. 5.3.3)

In order to prevent and mitigate the risks inherent in the relationships established with third parties, we have a set of

Compliance Policies and Codes of Conduct for Suppliers. In order to ensure compliance with our commitment, we have

implemented compliance clauses with duties Navigator's counterparties have to comply with as regards money laundering,

corruption prevention, Human Rights and international sanctions, and a Third Party Integrity Verification System to assess

counterparties risk in these matters.

We also undertake to ensure exemption and transparency in decision-making processes, preventing potential conflicts of

interest that could compromise the integrity of our operations. In this context, we highlight the

Regulation on Conflicts of

Interest and Transactions with Related Parties, which establishes clear guidelines for the identification, communication and

mitigation of these situations, promoting an environment of trust and impartiality. [ESRS 2.65d]

With regard to the Policy on the Corruption Prevention and Related Offences (see additional information in sections G1-3 and

G1-4), it is aligned and complies with the applicable legal requirements, namely with the General Regime on the Prevention of

Corruption [ESRS 2.65d]. The departments in charge of contracting goods or services, sales, institutional relations and

marketing are most exposed to the risk of corruption and bribery, according to our Corruption and Related Infringements Risk

Prevention Plan.

[G1.10h]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 290

Document

Compliance Policies - International Sanctions Compliance Policy; Third Party

Integrity Verification Policy and Money Laundering and Terrorist Financing

Prevention Policy

Description of key contents and

general objectives

[G1.7 | ESRS 2.65]

They reflect the general principles of operation of the Navigator Group in its relations with third

parties and the conduct that is expressly prohibited in the context of the relations established by it

within the scope of its activity, and define the measures to prevent these risks, by carrying out

adequate due diligence procedures, to assess the risk of criminal activities and the integrity of

Navigator's counterparties.

Scope

[G1.7 | ESRS 2.65]

They cover all Navigator geographies.

Most senior level position

accountable for its

implementation

[ESRS 2.65c]

Board of Directors

Third party standards or

initiatives the Company

undertakes to respect

[ESRS 2.65d]

- International Sanctions envisaged by the EU or UN

- Recommendations of the Financial Action Task Force (FATF)

Availability

[ESRS 2.65f]

This document is communicated to all Employees, Business Partners and Stakeholders through the

Intranet and Internet pages.

Employees are also trained in this matter.

Document

Compliance Policies - Policy on the Prevention of Corruption and Related Infractions

Description of key contents and

general objectives

[G1.7 | ESRS 2.65]

Its structuring principles are Navigator's total commitment to the prevention of corruption, the

generic and transversal prohibition of the practice of acts of corruption and related infractions and

the acknowledgement and reinforcement of the ethical and integrity culture already established,

whether in its direct relationship with third parties or in the relationship of its Employees, in the

exercise of their functions, with third parties.

Scope

[G1.7 | ESRS 2.65]

It covers all Navigator geographies.

Most senior level position

accountable for its

implementation

[ESRS 2.65c]

Board of Directors

Availability

[ESRS 2.65f]

This document is communicated to all Employees, Business Partners and Stakeholders through the

Intranet and Internet pages.

Employees are also trained in this matter.

Document

Supplier Code of Conduct

Key contents and objectives

[G1.7 | ESRS 2.65]

Made available to all materially relevant Suppliers, and in all consultation processes [G1.20], it

sets the expected ethical standards in the supply chain. It covers topics such as: anti-corruption

and bribery practices, respect for Human Rights, working arrangements, health and safety and

environmental practices.

Scope

[G1.7 | ESRS 2.65]

It is aimed at upstream operations of the value chain. Impact all Group Stakeholders, in particular

Employees and Communities. It is transversal to all geographies where Navigator operates.

Most senior level position

accountable for its

implementation

[ESRS 2.65c]

Board of Directors

ANNUAL REPORT 2024 • MANAGEMENT REPORT 291

Third party standards or

initiatives the Company

undertakes to respect

[ESRS 2.65d]

- Universal Declaration of Human Rights and ILO Conventions;

OHSAS 18001

- ISO 14001 -

Availability

[ESRS 2.65f]

Made available to all materially relevant Suppliers, and in all consultation processes.

Available through the Intranet and Internet pages.

Employees are also trained in this matter.

References throughout of the

non-financial

Statement

S2 – Workers in the value chain (Chap. 5.3.2)

Document

Supplier Code of Conduct (Mozambique)

Key contents and objectives

[ESRS 2.65 a]

It presents the responsibilities of Suppliers and Service Providers, with the objective of the long-

term pursuit of a sustainable business, based on solid ethical foundations and responsibility, taking

into account matters such as the global economy, human, social and environmental factors.

Scope

[ESRS 2.65b]

It focuses on upstream operations of the value chain and impacts Employees, Stakeholders and

Local Communities. It covers Navigator's Mozambique geography.

Most senior level position

accountable for its

implementation

[ESRS 2.65c]

Board of Directors

Availability

[ESRS 2.65f]

Made available to all materially relevant Suppliers, and in all consultation processes.

Available on the Internet.

Employees are also trained in this matter.

Most relevant complementary

documentation

Internal Regulations and Good Practices Policies for Occasional Workers and Service Providers of

Portucel Moçambique

References throughout of the

non-financial

Statement

S2 – Workers in the value chain (Chap. 5.3.2)

Reporting channel and whistleblower protection

We have implemented and made available a Whistleblower Channel accessible to Employees, Suppliers, Customers,

Service Providers or any other interested parties, as provided for in our Whistleblower Regulation, allowing the secure

and anonymous communication of irregularities. The channel covers a wide range of offences, including but not limited to

corruption and related offences, discrimination, harassment, health and safety, human and labour rights and environmental

protection [G1.10 a | G1.10e].

This channel is made available through an online portal, managed by an external entity, contracted by Navigator, and allows

reports of irregularities to be submitted through an effective, fast and suitable system for their detection, investigation and

resolution – under the rules of conduct established internally and with the principles of ensuring anonymity, confidentiality,

safeguarding and non-retaliation in relations with whistleblowers, complying with data protection and information security

standards and legal requirements under national legislation transposing Directive (EU) 2019/1937 [G1.10 a | G1.10e].

The handling of complaints is ensured by a multidisciplinary team – the Whistleblowing Committee (CDI) – composed of

the Legal, Compliance and Public Affairs Director (DLC), the Risk Management Director (DGR) and the Compliance Officer.

Whenever a complaint involves a member of the CDI, it is forwarded to the Audit Committee, ensuring impartiality and

independence in the treatment of each case. In addition, all reports of irregularities received are reported to the Audit

Committee and, if they involve members of the Board of Directors or the Audit Committee itself, also to the Ethics Committee

[G1.10 a | G1.10e | G1.18 a | G1.19].

ANNUAL REPORT 2024 • MANAGEMENT REPORT 292

The person in charge of following up on the complaints must ascertain whether the complaint contains the minimum grounds to

trigger an investigation process, and decide on the involvement of other bodies, departments or Employees in light of certain

requirements. If the complaint meets the minimum grounds, the investigation process is initiated, which consists of verifying

all the facts necessary to assess the alleged irregularity. The investigation process may result in the filing of the complaint or in

the proposal of corrective measures, forwarded to the Executive Committee and the Audit Committee, or to the Board of

Directors, when the measures exceed the powers of the Executive Committee. To reinforce confidence in this mechanism, we

provide specific training on reporting irregularities, ensuring that all Employees understand its operation and the protection

guaranteed to whistleblowers [G1.9 | G1.10 a | G1.10e | G1.10g].

5.4.1.2.2. Management of the relationship with Suppliers (G1-2, MDR-P)

The management of the relationship with Suppliers is a fundamental strategic axis for the Navigator Group, taking into

account the significant impact of its purchasing policies on the creation and distribution of value. With thousands of companies

and Workers integrated into our supply chain, we are committed to establishing partnership relationships and stimulating

positive change, promoting a more sustainable, resilient and efficient supply chain [G1.15 a | G1.15b].

Our activity involves the supply of wood, biomass, chemicals and other products essential to the industrial process, in addition

to the acquisition of energy necessary for production and consumption. These processes have environmental and social

impacts, from resource extraction and production to transportation and use. The shipment of products to more than 134

countries and approximately 4170 delivery points requires complex logistics management, using maritime, rail and road

transport, always with the commitment to minimise the environmental footprint and optimize the efficiency of the supply chain.

In total, we work with more than 7718 Suppliers, the most relevant being wood and biomass, chemicals and packaging,

logistics and transportation, energy and specialized services [G1.15 a | G1.15b].

Commitments entered into

Our operations reflect not only environmental but also social concerns, especially with regard to the safety of the people

involved. Supply chain resilience and responsiveness are key factors in ensuring business continuity. The sustainable

management of Suppliers has become a priority topic in the latest materiality analyses, leading to the definition of

commitments and objectives under the 2030 Roadmap. Among the main goals established, we highlight the increase in

certified wood and the promotion of chain of custody certification, the reinforcement of the evaluation of Suppliers based on

ESG criteria, the encouragement of the adoption of sustainable practices and the commitment to the health, safety and training

of Service Providers operating in Navigator's forest areas in Portugal (Cap. 3.4.4) [G1.15a | G1.15b].

Reducing CO₂ emissions associated with the value chain is also a priority, in line with the targets approved by the

Science Based Targets initiative (SBTi) in 2022. We are committed to reducing scope 3 carbon emissions, namely those

associated with our network of Suppliers and Logistics Partners (Cap. 3.4.4) [G1.15a | G1.15b].

Regarding the economic impact, we invest more than 1900 million euros annually in supplies and services. We play a major

role in the Portuguese economy, being responsible for a high volume of purchases from national Suppliers, which contributes

significantly to the generation of employment and the dynamics of the industrial sector. To support our Suppliers, especially

those in the national and Spanish wood market, we have consolidated several measures, including financial support for the

acquisition of machinery, facilitating treasury and segmentation of Suppliers, as well as the expansion of the

payment solution via a confirming solution. These initiatives aim at fostering a more qualified, sustainable supply chain

adapted to the requirements of the sector [G1.15 a | G1.15b].

We also promote active engagement with Suppliers through collaborative initiatives and knowledge sharing. Supplier's

Day, held since 2015, is a platform for dialogue and continuous improvement, addressing topics such as cost reduction,

ANNUAL REPORT 2024 • MANAGEMENT REPORT 293

industrial efficiency and sustainability. At the same time, the Forest Producers Club, launched in 2023, reflects our

commitment to sustainable forest management and aims to unite and support the community of Forest Producers, Suppliers

and Service Providers [G1.15 a | G1.15b].

The commitment to the security of the value chain (Chap. 3.4.4) translates into the adoption of strict criteria for Workers

in forestry and industrial operations. The year 2024 was marked by the visit of the Security Coordinator of Portucel

Moçambique to Portugal, where he had the opportunity to physically meet the security teams of the different sites – from the

perspective of sharing experiences – and also attended meetings that will strengthen the relationship between the security

structures of both geographies. It was also a year where the assumptions for the calculation of safety indexes were made and

where the identification of documentary gaps began, a subject that will continue to be discussed in 2025 [G1.15 a | G1.15b].

With regard to logistics efficiency and the reduction of the carbon footprint, we have been focusing on the optimisation

of transportation flows and the complementarity between the different modes of transport. In 2024, we continued the

consolidation of maritime services in nearby ports and increased deliveries to central and northern France by sea, significantly

reducing CO₂ emissions associated with road transport, resulting in an emission reduction of about – 786 t CO2. In addition,

we maintained the carrier loyalty program and encouraged fleet renewal, promoting the adoption of more efficient and

sustainable vehicles. [G1.15a | G1.15b]

Energy contracting is also a strategic area, aligned with our decarbonisation commitments. In 2024, about 66% of the

electricity purchased was of renewable origin, highlighting the supplies through a 115 GWh Power Purchasement Agreement

(PPA), established with Endesa, which includes the delivery of guarantees of renewable origin, as well as the supply of

electricity through physical PPA with the photovoltaic plants of Figueira da Foz and Ejea. [G1.15a | G1.15b]

Through these initiatives, we reaffirmed our commitments to responsible management of the relationship with suppliers,

promoting long-term partnerships based on transparency, sustainability and innovation [G1.15 a | G1.15b].

Selection and management of Suppliers

With regard to the selection and management of Suppliers, we follow strict social and environmental criteria, ensuring that

our supply chain operates in accordance with ethical and sustainability standards. Structuring documents such as the Code of

Conduct for Suppliers, Compliance Policies and the Human Rights Policy (see section G1-1) establish due diligence

procedures, promoting transparency and risk mitigation. We have implemented a Third Party Integrity Verification

System, allowing us to evaluate suppliers according to ESG criteria and ensure compliance with regulations on matters such as

corruption prevention, money laundering, terrorist financing and Human Rights protection. In addition, compliance clauses are

now included in contracts with Suppliers, ensuring the adoption of these principles [G1. [G1.15a | G1.15b]

In the forestry activity, we maintain a strict quality control of operations, evaluating the compliance of Service Providers with

technical references, legal and environmental requirements. In Mozambique, these assessments are essential, due to the

significant involvement of Workers and local Communities, ensuring that the practices adopted meet the highest standards of

social and environmental responsibility [G1.15 a | G1.15b].

We have been developing tools and methodologies to monitor the activity of our Suppliers, promoting their qualification

and approval. The sourcing and contracting procedure, created in 2023, integrates ESG criteria in the evaluation of Suppliers,

reinforcing the commitment to sustainability. In addition, the attribution of the European Union Ecological Label to UWF

(Uncoated Woodfree Paper) and tissue products requires a rigorous Supplier qualification process, considering

environmental and performance criteria [G1.15 a | G1.15b].

Finally, our due diligence methodologies for wood procurement ensure compliance with international laws and standards

such as the Forest Stewardship Council (FSC

) and the Programme for the Recognition of Forest Certification (PEFC™). We

ensure that the wood purchased is not associated with illegal or harmful practices to the environment, conducting audits and

risk assessments throughout our supply chain [G1.15 a | G1.15b].

ANNUAL REPORT 2024 • MANAGEMENT REPORT 294

5.4.1.2.3. Procedures to address corruption and bribery (G1-3, MDR-P)

Taking into account the international context in which we operate and the increasing participation of the private sector in the fight

against corruption and related offences, as well as the legal obligations we are bound to, we have adopted the Policy on the

Prevention of Corruption and Related Offences (see section G1-1). Its structuring principles, in addition to those already detailed

in the Code of Ethics and Conduct, are Navigator's total commitment to the prevention of corruption, the absolute and transversal

prohibition of the practice of acts of corruption and related infractions and the implementation of an ethical and integrity culture,

whether in the exercise of their functions or in the relationship with third parties with whom Navigator establishes any business

relationship, or other third parties with whom Navigator's Employees relate in the exercise of their functions. [G1.18a].

In addition, we have defined a Corruption and Related Infringements Risk Prevention Plan, in which we identify the risks of

corruption and related infractions the Company is exposed to and the criteria for evaluating these risks are defined, taking into

account the probability of occurrence and the impact of their materialization, according to a qualitative scale of evaluation of these

two variables. Given the severity of the risk, a risk matrix is constituted, which classifies them according to a scale of insignificant,

low, moderate, high or critical. [G1.18a].

We also have effective mechanisms to prevent, detect and respond to allegations of bribery and other violations, through the

Whistleblowing Channel (see section G1-1) [G1.18 a | G1.19]. In order to ensure the effectiveness of the irregularity reporting

system, the responsibility for monitoring the Reporting Channel is shared by several Navigator bodies, including the Audit Council,

which periodically evaluates the internal control system and suggests improvements when necessary [G1.18c].

We communicate the existing mechanisms and instruments to all Employees, Business Partners and Stakeholders through the

Intranet and Internet pages [G1.20]. In addition to the publication on the websites, the commitments are published in

management reports and specific contractual clauses [G1.20]. In addition, internal training is provided to all Employees in

compliance issues, namely as regards prevention of corruption and related offences (see section G1-1) [G1.21c].

Training on the Prevention of Corruption and Related Infractions is made available to Employees in e-learning format,

based on practical cases and everyday scenarios, to ensure that Employees understand and correctly apply Navigator's ethical

principles and internal standards. Training is provided to the members of the Management, Management and Supervision bodies,

in the same way as provided to the other Employees. In 2024, we carried out training actions on Code of Ethics and Conduct,

Communication of Irregularities, Internal Policies and Prevention of Corruption and Related Infractions, involving about 2800

Employees [G1.10g]. Topics covered include the acceptance and offer of goods and advantages, travel, meals, hospitality and

entertainment, political sponsorships and donations, social and corporate responsibility, money laundering, international sanctions

and KYC - Know Your Counterparty. The topic of Conflicts of Interest was reinforced in this training, following the implementation

of measures to strengthen internal control in this matter [G1.9 | G1.10g | G1.21c].

Anti-corruption and

anti-bribery training

Functions at

risk

Manager

AMSB (Administrative,

Management and Supervisory

bodies)

Other Workers

Number of non-employees

2 934

292

2,603

Number of employees who received

training

303 9 2 292

Percentage of employees who received

training

10% 3% 5% 11%

Note: To integrate the term “functions at risk”, Employees from the following areas were taken into account: Materials Management Directorate; Wood

Supply Directorate; Logistics Directorate; Forest Management Directorate; Industrial Directorates (including Tissue); Digital Technology Directorate;

Financial Directorate; Marketing Directorate; Communication and Brand Directorate; Environment and Circularity Directorate; Energy and Energy

Transition Directorate; Investor Relations Office; Portucel Moçambique; Public Affairs Directorate; Project Directorate; Paper Sales Directorate Europe;

International Paper Sales Directorate; Folder Sales Directorate; Tissue Commercial Directorate; gKRAFT Commercial Department and E-Commerce.

Within the "Managers" category, all employees with leadership roles, including Supervisors, were included, and in the "ASMB" category, the members

of the Board of Directors and the Officers.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 295

It is worth mentioning that the Training on the Prevention of Corruption and Related Infractions was started in 2023, in e-learning

format and held once. Thus, the number of completions recorded in 2024 does not reflect the total number of trainees, since a

significant part of the Employees had already completed the training in the previous year.

5.4.1.2.4. Actions and resources related to material sustainability themes (MDR-A)

Under the topic of Responsible Business Conduct, the material impact was identified: "Robust corruption prevention practices

contribute to a fairer and more transparent business environment". In order to address this Group’s concern, several actions have

been developed and adopted in order to achieve a high standard of integrity, strengthen transparency in business relationships

and mitigate corruption risks, ensuring compliance with Navigator's regulatory requirements and ethical principles. [ESRS 2.68 |

ESRS 2.69]

Thus, the

actions adopted and planned are part of Navigator's Corruption and Related Infringements Risk Prevention

Plan (PPR), through which the risks of corruption and related infractions the Navigator is exposed to are identified, the criteria

for their evaluation are defined and the preventive and corrective measures aimed at mitigating their probability of occurrence are

established. In this context, these initiatives represent the implementation of these measures, resulting in the creation of

mechanisms reinforcing the integrity and transparency of business activity, ensuring compliance with applicable ethical and

regulatory principles and contributing to a more responsible business environment. [ESRS 2.68a]

Within the scope of the

actions developed, the resources mobilised essentially included human resources – the Compliance

team led the implementation of the measures, with the support of other departments, when necessary - and specialised external

support – and a Service Provider was hired to support in the preparation and execution of the PPR and in the preparation of

Procedures that aim to mitigate the identified risks. No sustainable financing instruments were used, such as green bonds, social

bonds or green loans, and the execution of the plan was not dependent on specific preconditions. [ESRS 2.69a]

In 2025, the Compliance Area will complement the existing training, by providing more complete and specific training on the

protection of personal data and Human Rights.

Main actions

Status

Scope of action

Time Horizon

Results

[ESRS 2.68 a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68a | ESRS 2.68d | ESRS 2.68e]

Design procedures within

the scope of the

Plan for

the Prevention of

Corruption and Related

Infractions

Planned

All locations, in all

geographies

Affected Stakeholders are

Employees, Suppliers,

Customers, but also other

Stakeholders

2025

Achieve the goal of a fairer and more

transparent

business environment.

Verification of the

integrity of

counterparties

Executed and

planned

Upstream and

downstream locations, in

all geographies

Affected Stakeholders are

Suppliers and Customers

Continuous

Risk reduction through monitoring of

counterparties.

Corruption and Related

Infringements Risk

Prevention Plan

evaluation reports

Executed and

planned

It focuses on its own

operations, in all

geographies

Affected stakeholders are

Employees, Suppliers and

Customers, but also other

Stakeholders

2x per year: Annual

Report, in April, and

Interim Report (optional),

in October

Quantify the degree of implementation of the

defined preventive and corrective measures

and plan their full implementation.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 296

Main actions

Status

Scope of action

Time Horizon

Results

[ESRS 2.68 a]

[ESRS 2.68 b]

[ESRS 2.68 c]

[ESRS 2.68a | ESRS 2.68d | ESRS 2.68e]

Training on the

Prevention of Corruption

and Related Infractions

Executed and

planned

It focuses on its own

operations, in all

geographies

Affected Stakeholders are

Employees

Continuous

Ensure knowledge of internal policies and

reinforce the internalization of Navigator's

values by Employees.

The following information is included by reference to other parts of the Non-Financial Statement:

4) More information on the implemented actions of the “CRESCER” (GROWING) project and participation in the Business &

Human Rights Accelerator Program: MDR-A, ESRS 2, §68 b/c/e, §69 b/c – Chap. 5.3.1

5) More information on the actions implemented within the scope of Supplier management: MDR-A, ESRS 2, §68 b/c/e, §69

b/c – Chap. 5.3.2.2.4

5.4.1.3. Targets and Metrics

5.4.1.3.1. Monitoring the effectiveness of policies and actions through targets (MDR-T)

In our 2030 Roadmap, we have several defined goals that target Navigator's Supplier chain. The goals set by Navigator are

aligned with several Sustainable Development Goals (SDGs), reinforcing the Company's commitment to responsible practices.

SDG 17 (target 17.16) is transversal to the goals of promoting the financial evaluation and ESG performance of Suppliers, as

well as promoting partnerships for the use of more sustainable means of transportation, since all promote strategic collaborations

and multi-sector partnerships for sustainability. The financial and ESG assessment of Suppliers also contributes to SDG 8 (targets

8.4 and 8.7), by encouraging resource efficiency and the eradication of inappropriate working practices. These initiatives also

strengthen SDG 12 (targets 12.2 and 12.6), promoting the adoption of sustainable business practices and efficient management

of natural resources. In addition, by integrating ESG criteria in the relationship with Suppliers, we act in line with SDG 13 (targets

13.1 and 13.3), reinforcing resilience and capacity to mitigate climate impacts. SDG 15 (target 15.2) is also addressed, ensuring

responsible management of forests and natural resources. Finally, the Suppliers' ESG assessment also includes aspects related to

water efficiency, contributing to SDG 6 (target 6.4) by encouraging more sustainable consumption of this resource. [ESRS 2.80f]

ANNUAL REPORT 2024 • MANAGEMENT REPORT 297

Goal and Target Scope Baseline

Associated

metric

2024 performance Results to achieve

[ESRS 2.80c]

[ESRS 2.80d]

ESRS 2.75 |

ESRS 2.80b]

[ESRS 2.80J]

[ESRS 2.80e]

Promote the financial

evaluation of

materially relevant

Suppliers, on an

annual basis, to

ensure the

sustainability of

supply to Navigator

Transversal

Baseline value:

Baseline year:

2023

% of

Suppliers

with financial

evaluation

100% of materially relevant

suppliers

evaluated.

Results to achieve:

100% of materially relevant

suppliers

Year:

2030

ESG performance

assessment

(decarbonisation,

water management

and respect for

human

rights) for

materially relevant

Suppliers.

Upstream and

downstream of

the value chain

Baseline value:

Chemical and

packaging

suppliers:

0%;Logistics and

transportation

suppliers: 25% of

materially relevant

Suppliers.

Base year:

2023

% of

Suppliers

with ESG

evaluation

100% of materially relevant

chemical and packaging suppliers

evaluated;

100% of materially relevant

logistics and transportation

suppliers evaluated.

Results to achieve:

100% for chemical and packaging

suppliers;

80% for logistics and

transportation suppliers.

Year:

2025

Materially relevant

contracts covered by

Navigator's Supplier

Code of Conduct

Upstream and

downstream of

the value chain

Logistics and

transportation

suppliers: 0% Wood

suppliers: 0%

Chemical and

packaging suppliers:

100%

Baseline year:

2023

% of

agreements

100%

Results to achieve:

100%

Year:

2026

Define a program to

support the

development of

decarbonisation plans,

water management

and respect for the

Human Rights of our

Suppliers

Transversal

Baseline value:

Baseline year:

2023

Logistics and transportation

suppliers: For 2024, it was not

possible to develop a plan. It will

be a target for 2026

Wood suppliers: In 2024, a

decarbonization plan was drawn

up by 2033, under the scope 3 of

the European Union.

Results to achieve:

100%

Year:

2026

Promote partnerships

for the use of more

sustainable means of

transport (own and

Suppliers)

Transversal

Baseline value:

Baseline year:

2023

Logistics and transportation

suppliers: Consolidation of the

maritime service to

central/northern France with Wec

Lines, increasing shipments by

sea, to the detriment of road,

resulting in an emission

reduction of about -786 t CO

2024 (compared to 2023);

Results to achieve:

Year:

2026

41 Materially relevant suppliers of chemicals and packaging – representing about 80% of the total volume of purchases (spend).

Materially relevant logistics and transportation suppliers – representing about 80% of the volume (in number).

Materially relevant suppliers of wood – representing about 80% of the volume of wood supplied (

ANNUAL REPORT 2024 • MANAGEMENT REPORT 298

Goal and Target Scope Baseline

Associated

metric

2024 performance Results to achieve

[ESRS 2.80c]

[ESRS 2.80d]

ESRS 2.75 |

ESRS 2.80b]

[ESRS 2.80J]

[ESRS 2.80e]

Wood suppliers: Design a

decarbonisation plan for the

area, which includes

partnerships.

Note: The method of calculating the metrics remained unchanged compared to the previous year [ESRS 2.13], and no errors were identified for previous

periods [ESRS 2.14]. These metrics are subject to external verification within the scope of this report and are not verified by other entities [ESRS 2.77 b]

No interim targets have been developed. [ESRS 2.80e]

The goal of promoting the financial evaluation of materially relevant Suppliers on an annual basis, ensuring the sustainability of

supply, although not related to any existing policy in the Company, aims to ensure a regular analysis of the financial health of the

main Suppliers. For its definition, wood and outbound logistics suppliers were classified based on the volume of wood delivered

and the number of transports carried out, respectively, and the financial evaluation was conducted using Moody's tool. This

analysis covered indicators such as turnover, net income, EBITDA and share of wallet Navigator, focusing on the main Suppliers,

responsible for approximately 80% of the volume delivered. The data used refers to the year available on the platform,

corresponding to n-1, where n represents the reporting year. There was no Stakeholder involvement in its definition process.

[ESRS 2.80a | ESRS 2.80f | ESRS 2.80h]

The goal of evaluating the ESG performance of materially relevant suppliers by 2025, ensuring the evaluation of 100% of

Chemical and Packaging Suppliers and 80% of Logistics and Transport Suppliers is aligned with the Company's Decarbonization

Plan, Human Rights Policy and Environmental Policy, reinforcing Navigator's commitment to sustainable practices in its supply

chain. [ESRS 2.80a]

The goal of ensuring that, by 2026, 100% of new materially relevant contracts are covered by the Code of Conduct for Suppliers is

directly aligned with the Company's own Code of Conduct for Suppliers, reinforcing Navigator's commitment to ethics and

sustainability in its supply chain. For its implementation, the inclusion of the Code of Conduct for Suppliers in all new contracts

established was adopted as a procedure, ensuring Suppliers compliance with the principles defined by the Company. [ESRS 2.80a

| ESRS 2.80f]

The goal of defining, by 2026, a program to support its Suppliers in the development of decarbonisation plans, water management

and respect for Human Rights is aligned with the Company's Decarbonization Plan, Human Rights Policy and Environmental Policy,

reinforcing Navigator's commitment to sustainable and responsible practices in its supply chain. To define this goal, a State of the

Art study was carried out in 2023/2024, with 2020 as the reference year, in which areas for improvement were identified and

action plans were defined in line with the decarbonisation process. [ESRS 2.80a | ESRS 2.80f]

The goal of promoting partnerships for the use of more sustainable means of transport, both its own and its Suppliers, by 2026, is

aligned with the Company's Decarbonisation Plan, reinforcing the commitment to reduce emissions in the logistics sector. To

define this goal, a State of the Art study was carried out in 2023/2024, with the reference year 2020, in which areas for

improvement were identified and action plans were established for the decarbonisation process. Among the solutions analysed,

the possibility of partnerships for the adoption of biofuels and fleet renewal stands out. In addition, new projects were developed

in collaboration with existing Partners, namely for the creation of more sustainable transport solutions, including the use of short

sea shipping, with special emphasis on the service of France, which allowed the conversion of cargoes, previously transported by

road, to maritime transport. However, no milestones associated with this objective have been set. [ESRS 2.80a | ESRS 2.80f]

The following information is included by reference to other parts of the Non-Financial Statement:

ANNUAL REPORT 2024 • MANAGEMENT REPORT 299

• More information on the target related to the for continuous monitoring of employees’ main motivational stimuli: MDR-T,

ESRS 2, §80: Chap. 5.3.1

5.4.1.3.2. Incidents of corruption or bribery (G1-4)

During 2024, no cases of violations of anti-corruption and bribery procedures and standards were confirmed, nor were any fines

imposed for violations of anti-corruption and bribery laws. [G1-4.24a]

Following the events that occurred in 2020 and 2021, sustained in the 2020 criminal investigation related to the alleged corruption

in the wood receiving activity of one of our manufacturing centres, which led to the dismissal with just cause of the Workers

involved in that activity, legal proceedings continue in the labour and criminal jurisdictions. In fact, during 2024, Navigator

continued to monitor, in the competent labour courts, the actions of judicial challenge of the regularity and lawfulness of the

dismissals of 28 Workers, and, to date, there have been no additional developments of the said processes. On the other hand, in

the criminal forum, Navigator, as an assistant, continues to monitor said process, and it has continued to the trial phase and the

respective production of evidence has already begun. [G1.24b].

5.4.1.3.3. Expenditure with local Suppliers (Entity-Specific Disclosure, MDR-M)

In addition to the metrics to be reported under the ESRS, Navigator monitors an additional set of metrics that support the

analysis of the evolution of its performance. We maintain an active commitment to the development of the Communities we

operate in, prioritising the hiring of local Suppliers when possible. This approach not only strengthens the national economy,

but also contributes to creating shared value and building more sustainable and resilient supply chains. [ESRS 2.77a | ESRS

2.77c]

The metric of "Expenses with local Suppliers" allows to evaluate the weight of purchases made from Suppliers based in Portugal

in the total of Navigator's acquisitions. This analysis includes the proportion of the procurement budget allocated to relevant

operating units and the total number of Suppliers accounted for as of December 31, 2024. [ESRS 2.77a | ESRS 2.77c]

The methodology used follows the GRI 204-1 reference, considering the total expenses with Suppliers, expressed in thousands of

euros, including the VAT amount. These values are in line with the Consolidated income statement of Navigator's Annual Report,

ensuring the consistency of the reported information. [ESRS 2.77a | ESRS 2.77c]

Given the strategic importance of this metric, Navigator will continue to monitor and optimise its hiring policies, reinforcing its

positive impact on the local economy and the sustainability of its business model. [ESRS 2.77a | ESRS 2.77c]

[ESRS 2.77c – Entity specific metrics]

Expenses with local Suppliers

2024

2023

2022

Total number of Suppliers

7 718

7 490

7 303

% of local Suppliers

70%

73%

% of foreign Suppliers

30%

27%

Total expenses with Suppliers (thousand €)

1 937 431

1 793 052

1 934 460

% of expenses with local Suppliers

75%

74%

72%

% of expenses with foreign Suppliers

25%

26%

28%

ANNUAL REPORT 2024 • MANAGEMENT REPORT 300

6. Proposed allocation of profits

The individual accounts show net income of 286 948 195.0 euros, determined on an IFRS basis:

The Board of Directors proposes the following allocation:

Dividends for outstanding shares ............................................................. 174 993 706.0 euros

(0.24606 per share)

Employee profit sharing for the period up to ............................................. 19 000 000.0 euros*

Retained Earnings ...................................................................................... 92 954 489.0 euros

*Already stated in financial statements

The proposed appropriation of results includes an additional dividend distribution of 75 million euros, corresponding to 0.10545

euros per share, taking into account the interim distribution of 100 million euros carried out on January 14, 2025. It further

includes a proposal for employee profit-sharing of up to 16 million euros, net of the 3 million euros distributed in advance in

December.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 301

7. Declaration required under

Article 29-G,1 c) of Securities

Code

Article 29-G,1 c) of the Securities Code requires that each of the persons responsible for issuers, whose names and duties must

be clearly indicated, make a number of declarations, as described in the sub-paragraph in question. In the case of The

Navigator Company, a uniform declaration has been adopted, worded as follows:

"I hereby declare, under the terms and for the purposes of Article 29-G.1 c) of the Securities Code that, to the best of my

knowledge, the management report, annual accounts, legal accounts certificate and other financial statements required by law

or regulation, even if they have not been submitted for approval at the general meeting, of The Navigator Company, S,A., for

the financial year of 2023, were drawn up in accordance with the relevant accounting rules, and provide a true and fair view of

the assets and liabilities, financial affairs and profit or loss of the Company and other companies included in the consolidated

accounts, and that the management report contains a faithful account of the business, performance and position of the

Company and other companies included in the consolidated accounts, describing the main risks and uncertainties which they

face.

As required by this rule, we provide below a list of the persons signing the declaration and their office in the company:

Ricardo Miguel dos Santos Pacheco Pires Chairman of the Board of Directors

António José Pereira Redondo Chief Executive Officer

José Fernando Morais Carreira de Araújo Executive director

Nuno Miguel Moreira de Araújo dos Santos Executive director

João Paulo Cabete Gonçalves Lé Executive director

Dorival Martins de Almeida Executive director

António Quirino Soares Executive director

Ana Teresa Cunha de Pinho Tavares Lehmann Non-executive director

Hugo Alexandre Lopes Pinto Non-executive director

Maria Isabel da Silva Marques Abranches Viegas Non-executive director

Maria Teresa Aliu Presas Non-executive director

Mariana Rita Antunes Marques dos Santos Non-executive director

Sandra Maria Soares Santos Non-executive director

ANNUAL REPORT 2024 • MANAGEMENT REPORT 302

Vítor Paulo Paranhos Pereira Non-executive director

José Manuel Oliveira Vitorino Chairman of the Audit Board

Gonçalo Nuno Palha Gaio Picão Caldeira Member of the Audit Board

Maria da Luz Gonçalves de Andrade Campos Member of the Audit Board

ANNUAL REPORT 2024 • MANAGEMENT REPORT 303

8. Our performance

The tables in the following sub-chapters provide a summary of Economic, Environmental and Social indicators.

8.1 Economic indicators

Economic Indicators

2024

2023

2022

GRI

ESRS

Chap.

Total sales

2,088

1,953

2,465

EBITDA

(million €)

547

502

736

Operating profits (EBIT)

379

366

573

Finantial Results

-25,8

-19

-57

Net Income (million €)

287

275

393

Operanting Cash flow

454,8

410

555

Free Cash Flow

22,5

463

Capital expenditure

241

187

113

Interest Bearing Net Debt

617

490

382

EBITDA/Sales (%)

ROCE

20,1%

21%

35%

ROE

21,5%

21%

34%

Interest Bearing Net Debt /EBITDA

1.13

0.98

0.52

Direct Economic Value Generated - Revenues

(I) (thousand €)

2,188,933

2,033,559 2,535,783 201-1

2.3

Direct Economic Value Distributed (II)

(thousand €)

1,824,737

1,848,089 2,122,950

Operating costs

1,384,528

1,294,457 1,514,271

Employee pay and benefits

202,709

171,127 185,194

Payments to capital providers

175,835

219,305 356,967

Operating profits + depreciation + provisions.

Variation net debt + dividends + purchase of own shares.

Interest-bearing liabilities - liquid assets (not including effect of IFRS 16).

ROCE = Annualised operating income / Average Capital invested (N+(N-1))/2.

ROE = Annualised net income / Average Shareholders' Funds (N+(N-1))/2.

Interest-bearing liabilities - liquid assets/ EBITDA corresponding to last 12 months. Impact of IFRS 16: Net Debt / EBITDA 2024 on 1.3; Net Debt / EBITDA 2023 of 1.1.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 304

Impostos

60.065

161.741

64.765

Investimentos na Comunidade

1.600

1.459

1.752

Valor Económico Acumulado (I-II) (milhares

de €)

364.196

185.470 412.834

Apoios financeiros recebidos do Governo

(milhares de €)

17.958 16.781 16.405 201-4

Incentivos Fiscais / Créditos

3.952

1.701 2.557

Subsídios

10.814

12.280 12.314

Apoios para pesquisa e I&D

3.192

2.800

1.533

Número total de Fornecedores

7.718

7.490

7.303

MDR-M

5.4.1.3.3

Percentagem de Fornecedores locais (%)

Gastos totais com Fornecedores (€)

1.937.431

1.793.052

1.934.460

204-1

MDR-M

5.4.1.3.3

Percentagem de gastos com

Fornecedores locais (%)

74 72

8.2 Environmental indicators

Environmental Indicators

2024

2023

2022

GRI

ESRS

Cap.

Forest

% of Forest Area Managed with

Certification, in Mainland Portugal

100 100 100

MDR-M 5.2.6.3

Wood purchased with FSC® and

PEFC™ certification

MDR-M 5.2.6.3

% Portuguese

% overall

Materials

Raw materials (tons)

5,241,400

4,714,216

5,156,843

301-1

Renewable

4,569,007

4,251,275 4,619,939

Non-renewable

672,361

462,940 536,904

% of renewable raw materials

% of recycled materials used

0.00

0.01

301-2

Energy

Energy consumption within the

organization (GJ)

41,376,730 39,746,832 41,165,471 302-1 E1-5

5.2.2.3.2

Primary energy from non-

renewable sources

8,392,059 7,788,102 9,825,584

Revised methodology for greater alignment with ESRS, now including UWF and Tissue packaging materials, compounds associated with production (retention, resistance

and bleaching agents), lubricants and materially relevant MROs (maintenance, repair and operation).

Data available in MWh.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 305

Primary energy from

renewable sources

32,234,878 31,688,941 31,802,148

Electricity acquired for

consumption

4,922,607 5,400,128 4,910,655

Electricity sold

4,172,815

5,130,339

5,372,917

% primary renewable energy

consumed

79 80 76

% primary renewable energy

consumed in Portugal

80 81 76

Energy intensity In Portugal (GJ/t

output)

12.8 12.9 12.0 302-3

Reduction in energy consumption

(GJ)

19,483 5,604 65,682 302-4

Water

Water intake (thousand m3)

62,858

61,989

63,503

303-3

E3-4

5.2.3.3.2

Industrial operations

60,799

60,096 61,857

Forestry operations

2,055

1,892 1,647

Specific water use in industrial

operations in Portugal (m3/t)

20.5 21.2 19.1 MDR-M

Biodiversity

Facilities in or close to protected

areas and areas of high biodiversity

value

304-1 MDR-M 5.2.4.3

National Network of Protected

Areas (RNAP) (ha)

7,608 11,877 10,253

% of total holdings

managed

7.0 11 10

Classified sites in Natura 2000

Network (ha)

26996 44,990 43,699

% of total holdings

managed

24.8 42 41

Special Protection Zones

(ZPE) in the Natura 2000

Network (ha)

20359 33,680 31,533

% of total holdings

managed

18,7 31 30

The primary renewable energy consumed includes, since 2021, the electricity produced in photovoltaic solar power stations.

The calculation of energy intensity took into account energy consumption by primary sources (excluding energy from Biomass Thermoelectric Plants - BTC) and the total

quantity of products manufactured. The energy used by BTCs is included in the total energy consumed, but these figures are not taken into account when calculating

energy intensity, since this consumption is not related to the production process.

These indicators do not include Navigator Tissue UK.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 306

Total classified areas (ha)

54,963

56,684

53,738

MDR-M

5.2.4.3

% of total holdings

managed

50 53 51

Habitats protected or restored (ha)

4,597

4,611

4,314

304-3

MDR-M

5.2.4.3

Protected habitats (ha)

4,474

4,420

4,243

Restored habitats (ha)

123

191,3

71,2

Emissions

Scope 1 (tCO2e)

509,037 508,833 592,428 305-1 E1-6 5.2.2.3.3

Assets at plants

(CELE scope)

454,234 457,990 552,587

Other Scope 1

Emissions

54,803 50,843 39,842

Scope 2 (tCO2e)

305-2 E1-6 5.2.2.3.3

Purchase of power

(location based)

140,633 230,642 352,517

Scope 3 (tCO2e)

1,388,883 1,397,752 1,589,138 305-3 E1-6 5.2.2.3.3

Category 1: Purchased Goods and

Services

856,601

792,005 1,006,540

Category 3: Fuel- and Energy-Related

Activities (not included in Scope 1 or 2)

90,324 100,052 107,036

Category 4: Upstream Transportation

and Distribution

95,383

90,208 124,566

Category 9: Downstream Transportation

and Distribution

96,808

116,597 81,182

Category 10: Processing of Sold Product

102,467

154,224 108,080

Category 12: End-of-Life Treatment of

Sold Products

147,402

144,667 161,734

Reduction in GHG emissions as

direct result of initiatives

undertaken

(tCO2e)

11,415 12,230 4,576 305-5

Waste

Total waste generated (t)

446,601

441,642 410,717 306-3 E5-5 5.2.5.3.3

Reclaimed

300,927

296,348

279,862

The GHG Protocol guidelines have been followed.

Scope 1, 2 and 3 emissions include emissions associated with all Navigator activities in all geographies, except for emissions associated with international offices due to

their low materiality (<0.02%). Emissions from Navigator Tissue UK, which was integrated into Navigator in May 2024, have been included in scopes 1 and 2, with an

extension to scope 3 planned for next year.

Other scope 1 emissions represent emissions associated with industrial assets outside of the scope of the EU ETS, ioemissions associated with fluorinated gases, methane

and nitrous oxide and emissions associated with travelling in the company's own fleet. The data for 2023, including emissions within the scope of the EU ETS, fluorinated

gases, methane and nitrous oxide, has been updated, incorporating the EU ETS verification that took place after the publication of the 2023 Annual Report, information that

was not previously available. The materiality of the update is less than 0.2%.

Scope 2 location-based emissions were calculated using the most recent emission factors from the International Energy Agency (IEA). Market-based emissions take into

account the emission factors of commercialisers, as well as the supply of 100% renewable energy under PPA - Power Purchase Agreement contracts. The figures for 2024

are provisional, as the final emission factor figures are not yet available.

Categories 2, 5, 6 and 7 are excluded from scope 3 due to their low materiality. Navigator carried out a materiality analysis in 2022, and these categories were identified as

not material. Categories 8, 11, 13, 14 and 15 are excluded due to their non-applicability to Navigator's business.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 307

Disposed of

145,674

148,587

133,342

Non-hazardous waste (t)

455,622

440,709 410,021 E5-5 5.2.5.3.3

Reclaimed

300,307

295,687

279,330

Disposed of

145,315

148,316

133,177

Hazardous waste (t)

979

933

697

E5-5

5.2.5.3.3

Reclaimed

620

662

532

Disposed of

359

271

165

Rate of disposal of waste in

industrial landfill in Portugal (%)

12 12 11 MDR-M 5.2.5.3.1

8.3 Social indicators

Social Indicators

2024

2023

2022

GRI

ESRS

Cap,

Human resources

Number of Employees

3,965

3,467

3,246

2-7

S1-6

5.3.1.3.2

Permanent contract

3,717

3,279

3,082

Men

3,213

2,686

2,549

Women

752

593

533

Fixed-term contract

248

188

164

Men

192

135

123

Women

Safety and Health 

403-9

Number of accidents at work

254

228

262

S1-14

5.3.1.3.8

Frequency rate

4.1

5.8

7.3

S1-14

5.3.1.3.8

Index of fatalities as a result of work-

related injury

00 0.0 0.0

Training and development

Training hours per Employee

404-1

S1-13

5.3.1.3.7

By gender

Men

100

Women

Performance assessment (%)

404-3

S1-13

5.3.1.3.7

By gender

The figures presented relate to 2023, as the 2024 Performance Management Cycle has not yet been finalised. All employees in Portugal, Mozambique and International

Offices have been taken into account, with neither the Tissue units in Ejea nor Tissue in the United Kingdom being covered.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 308

Men

Women

100

Diversity

% of women in the organisation

19.0

17.7

S1-6

5.3.1.3.2

Employees by age (%)

405-1

S1-9

5.3.1.3.5

<30 years

14.1

13.0 12.5

30-50 years

61.7

61.8 61.1

>50 years

24.2

25.2

26.4

Data available on the total number of women in the organisation.

Data available on total number of employees by age group.

ANNUAL REPORT 2024 • MANAGEMENT REPORT 309

9. Annexes

9.1 Correspondence Tables [ESRS, Non-Financial

Information, WEF]

9.1.1. ESRS

ESRS 2 IRO-2 - Disclosure Requirements in ESRS covered by the undertaking’s

sustainability statement

Disclosure Requirements

Location

ESRS 2 - General Disclosures

BP-1 - General basis for preparation of the sustainability statements

Chap. 5.1.1.1

BP-2 - Disclosures in relation to specific circumstances

Chap. 5.1.1.2

Chap. 9.1.1

GOV-1 - The role of the administrative, management and supervisory bodies

Chap. 5.1.2.1

GOV-2 - Information provided to and sustainability matters addressed by the undertaking’s administrative,

management and supervisory bodies

Chap. 5.1.2.2

GOV-3 - Integration of sustainability-related performance in incentive schemes

Chap. 5.1.2.3

GOV-4 - Statement on due diligence

Chap. 9.1.1

GOV-5 - Risk management and internal controls over sustainability reporting

Chap. 5.1.2.4

SBM-1 - Strategy, business model and value chain

Chap. 5.1.3.1

SBM-2 - Interests and views of stakeholders

Chap. 5.1.3.2

SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model

Chap. 5.1.3.3

Chap. 5.2.2.1.1

Chap. 5.2.3.1.1

Chap. 5.2.4.1.1

Chap. 5.2.5.1.1

Chap. 5.2.6.1.1

Chap. 5.3.1.1.1

Chap. 5.3.2.1.1

Chap. 5.3.3.1.1

Chap. 5.4.1.1.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 310

ESRS 2 IRO-2 - Disclosure Requirements in ESRS covered by the undertaking’s

sustainability statement

Disclosure Requirements

Location

IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities

Chap. 5.1.4.1

IRO-2 - Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement

Chap. 5.1.4.2

Chap. 9.1.1

E1 - Climate change

ESRS 2 GOV-3 Integration of sustainability-related performance in incentive schemes

Chap. 5.1.2.3

E1-1 - Transition plan for climate change mitigation

Chap. 5.2.2.1.2

ESRS 2 SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model

Chap. 5.2.2.1.1

ESRS 2 IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities related

to climate

Chap. 5.1.4.1

E1-2 - Policies related to climate change mitigation and adaptation

Chap. 5.2.2.2.1

E1-3 - Actions and resources in relation to climate change policies

Chap. 5.2.2.2.2

E1-4 - Targets related to climate change mitigation and adaptation

Chap. 5.2.2.3.1

E1-5 - Energy consumption and mix

Chap. 5.2.2.3.2

E1-6 - Gross Scopes 1, 2, 3 and Total GHG emissions

Chap. 5.2.2.3.3

E1-9 - Anticipated financial effects from material physical and transition risks and potential climate-related

opportunities

Chap. 5.2.2.3.4

E3 - Water and marine resources

ESRS 2 IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities related

to Water and marine resources

Chap. 5.1.4.1

E3-1 - Policies related to water and marine resources

Chap. 5.2.3.2.1

E3-2 - Actions and resources related to water and marine resources

Chap. 5.2.3.2.2

E3-3 - Targets related to water and marine resources

Chap. 5.2.3.3.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 311

ESRS 2 IRO-2 - Disclosure Requirements in ESRS covered by the undertaking’s

sustainability statement

Disclosure Requirements

Location

E3-4 - Water consumption

Chap. 5.2.3.3.2

E3-5 - Anticipated financial effects from water and marine resources-related risks and opportunities

Chap. 5.2.3.3.3

E4 - Biodiversity and ecosystems

E4-1 - Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Chap. 5.2.4.1.2

ESRS 2 SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model

Chap. 5.2.4.1.1

ESRS 2 IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities related

to Biodiversity and ecosystems

Chap. 5.1.4.1

E4-2 - Policies related to biodiversity and ecosystems

Chap. 5.2.4.2.1

E4-3 - Actions and resources related to biodiversity and ecosystems

Chap. 5.2.4.2.2

E4-4 - Targets related to biodiversity and ecosystems

Chap. 5.2.4.3.1

E4-5 - Impact metrics related to biodiversity and ecosystems change

Chap. 5.2.4.3.2

E4-6 - Anticipated financial effects from material biodiversity and ecosystem-related risks and opportunities

Chap. 5.2.4.3.3

E5 - Resource use and circular economy

ESRS 2 IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities related

to Resource use and circular economy

Chap. 5.1.4.1

E5-1 - Policies related to resource use and circular economy

Chap. 5.2.5.2.1

E5-2 - Actions and resources related to resource use and circular economy

Chap. 5.2.5.2.2

E5-3 - Targets related to resource use and circular economy

Chap. 5.2.5.3.1

E5-4 - Resource inflows

Chap. 5.2.5.3.2

E5-5 - Resource outflows

Chap. 5.2.5.3.3

ANNUAL REPORT 2024 • MANAGEMENT REPORT 312

ESRS 2 IRO-2 - Disclosure Requirements in ESRS covered by the undertaking’s

sustainability statement

Disclosure Requirements

Location

E5-6 - Anticipated financial effects from resource use and circular economy-related risks and opportunities

Chap. 5.2.5.3.4

S1 - Own workforce

ESRS 2 SBM-2 - Interests and views of stakeholders

Chap. 5.1.3.2

ESRS 2 SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model

Chap. 5.3.1.1.1

S1-1 - Policies related to own workforce

Chap. 5.3.1.2.1

S1-2 - Processes for engaging with own workforce and workers' representatives about impacts

Chap. 5.3.1.2.2

S1-3 - Processes to remediate negative impacts and channels for own workforce to raise concerns

Chap. 5.3.1.2.3

S1-4 - Taking action on material impacts on own workforce, and approaches to managing material risks and

pursuing material opportunities related to own workforce, and effectiveness of those actions

Chap. 5.3.1.2.4

S1-5 - Targets related to managing material negative impacts, advancing positive impacts, and managing

material risks and opportunities

Chap. 5.3.1.3.1

S1-6 - Characteristics of the undertaking's employees

Chap. 5.3.1.3.2

S1-7 - Characteristics of non-employee in the undertaking's own workforce

Chap. 5.3.1.3.3

S1-8 - Collective bargaining coverage and social dialogue

Chap. 5.3.1.3.4

S1-9 - Diversity indicators

Chap. 5.3.1.3.5

S1-10 - Adequate wages

Chap. 5.3.1.3.6

S1-13 - Training and skills development indicators

Chap. 5.3.1.3.7

S1-14 - Health and safety metrics

Chap. 5.3.1.3.8

S1-15 - Work-life balance metrics

Chap. 5.3.1.3.9

S1-16 - Remuneration metrics (pay gap and total remuneration)

Chap. 5.3.1.3.10

ANNUAL REPORT 2024 • MANAGEMENT REPORT 313

ESRS 2 IRO-2 - Disclosure Requirements in ESRS covered by the undertaking’s

sustainability statement

Disclosure Requirements

Location

S1-17 - Incidents, complaints and severe human rights impacts

Chap. 5.3.1.3.11

S2 - Workers in the value chain

ESRS 2 SBM-2 - Interests and views of stakeholders

Chap. 5.1.3.2

ESRS 2 SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model

Chap. 5.3.2.1.1

S2-1 - Policies related to value chain workers

Chap. 5.3.2.2.1

S2-2 - Processes for engaging with value chain workers about impacts

Chap. 5.3.2.2.2

S2-3 - Processes to remediate negative impacts and channels for value chain workers to raise concerns

Chap. 5.3.2.2.3

S2-4 - Taking action on material impacts on value chain workers, and approaches to managing material risks and

pursuing material opportunities related to value chain workers, and effectiveness of those actions

Chap. 5.3.2.2.4

S2-5 - Targets related to managing material negative impacts, advancing positive impacts, and managing

material risks and opportunities

Chap. 5.3.2.3.1

S3 - Affected communities

ESRS 2 SBM-2 - Interests and views of stakeholders

Chap. 5.1.3.2

ESRS 2 SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model

Chap. 5.3.3.1.1

S3-1 - Policies related to affected communities

Chap. 5.3.3.2.1

S3-2 - Processes for engaging with affected communities about impacts

Chap. 5.3.3.2.2

S3-3 - Processes to remediate negative impacts and channels for affected communities to raise concerns

Chap. 5.3.3.2.3

S3-4 - Taking action on material impacts on affected communities, and approaches to managing material risks

and pursuing material opportunities related to affected communities, and effectiveness of those actions

Chap. 5.3.3.2.4

S3-5 - Targets related to managing material negative impacts, advancing positive impacts, and managing

material risks and opportunities

Chap. 5.3.3.3.1

G1 - Business conduct

ANNUAL REPORT 2024 • MANAGEMENT REPORT 314

ESRS 2 IRO-2 - Disclosure Requirements in ESRS covered by the undertaking’s

sustainability statement

Disclosure Requirements

Location

ESRS 2 GOV-1 - The role of the administrative, management and supervisory bodies

Chap. 5.1.2.1

ESRS 2 IRO-1 - Description of the process to identify and assess material impacts, risks and opportunities

Chap. 5.1.4.1

G1-1- Business conduct policies and corporate culture

Chap. 5.4.1.2.1

G1-2 - Management of relationships with suppliers

Chap. 5.4.1.2.2

G1-3 - Procedures to address corruption and bribery

Chap. 5.4.1.2.3

G1-4 - Incidents of corruption or bribery

Chap. 5.4.1.3.2

Entity-specific disclosures – Sustainable Forestry Management

MDR-P - Policies adopted to manage material sustainability matters

Chap. 5.2.6.2.1

MDR-A - Actions and resources in relation to material sustainability matters

Chap. 5.2.6.2.2

MDR-T - Tracking effectiveness of policies and actions through target

Chap. 5.2.6.3.1

MDR-M - Metrics in relation to material sustainability matters

Chap. 5.2.6.3.2

ANNUAL REPORT 2024 • MANAGEMENT REPORT 315

List of data points that derive from other EU legislation

Disclosure

Requiremen

Datapoint

Description

Referenc

e SFDR

Pillar 3

Referenc

Regulatio

n of

Referenc

climate

legislatio

referenc

Location

Materialit

ESRS 2 GOV-

Paragraph 21 (d)

Board's gender diversity

Chap. 5.1.2.1

ESRS 2 GOV-

Paragraph 21 (e)

Percentage of independent board members

Chap. 5.1.2.1

ESRS 2 GOV-

Paragraph 30

Disclosure of mapping of information provided in sustainability statement about due diligence

process

Chap. 9.1.1

ESRS 2 SBM-

Paragraph 40 (d)

Undertaking is active in fossil fuel

Chap. 5.1.3.1

ESRS 2 SBM-

Paragraph 40 (d)

Undertaking is active in chemicals production

Chap. 5.1.3.1

ESRS 2 SBM-

Paragraph 40 (d)

iii

Undertaking is active in controversial weapons

Chap. 5.1.3.1

ESRS 2 SBM-

Paragraph 40 (d)

Undertaking is active in cultivation and production of tobacco

Chap. 5.1.3.1

ESRS E1-1

Paragraph 14

Disclosure of transition plan for climate change mitigation

Chap.

5.2.2.1.2

ESRS E1-1

Paragraph 16 (g)

Undertaking is excluded from EU Paris-aligned Benchmarks

Chap.

5.2.2.1.2

ESRS E1-4

Paragraph 34

GHG emission reduction targets

Chap.

5.2.2.3.1

ESRS E1-5

Paragraph 38

Energy consumption from fossil sources broken down by source (only sectors with a high

climate impact)

Chap.

5.2.2.3.2

ESRS E1-5

Paragraph 37

Energy consumption and energy mix

Chap.

5.2.2.3.2

ESRS E1-5

Paragraphs 40-

Energy intensity from activities in high climate impact sectors (total energy consumption per

net revenue)

Chap.

5.2.2.3.2

ANNUAL REPORT 2024 • MANAGEMENT REPORT 316

List of data points that derive from other EU legislation

Disclosure

Requiremen

Datapoint

Description

Referenc

e SFDR

Pillar 3

Referenc

Regulatio

n of

Referenc

climate

legislatio

referenc

Location

Materialit

ESRS E1-6

Paragraph 44

Gross Scopes 1, 2, 3 and Total GHG emissions

Chap.

5.2.2.3.3

ESRS E1-6

Paragraphs 53-

GHG emissions intensity

Chap.

5.2.2.3.3

ESRS E1-7

Paragraph 56

Disclosure of GHG removals and storage

Non-

material

ESRS E1-9

Paragraph 66

Exposure of the reference portfolio to climate-related physical risks

Chap.

5.2.2.3.4

ESRS E1-9

Paragraph 66 (a)

Breakdown of monetary amounts by acute and chronic physical risk

Chap.

5.2.2.3.4

ESRS E1-9

Paragraph 66 (c)

Disclosure of location of significant assets at material physical risk

Chap.

5.2.2.3.4

ESRS E1-9

Paragraph 67 (c)

Total carrying amount of real estate assets by energy efficiency classes

Chap.

5.2.2.3.4

ESRS E1-9

Paragraph 69

Degree of exposure of the portfolio to climate-related opportunities

Chap.

5.2.2.3.4

ESRS E2-4

Paragraph 28

Quantity of each pollutant listed in Annex II of the E-PRTR Regulation emitted into air, water

and soil

Non-

material

ESRS E3-1

Paragraph 9

Water and marine resources

Chap.

5.2.3.2.1

ESRS E3-1

Paragraph 13

Dedicated policy

Chap.

5.2.3.2.1

ESRS E3-1

Paragraph 14

Sustainable oceans and seas

Non-

material

ESRS E3-4

Paragraph 28 (c)

Total water recycled and reused

Non-

material

ANNUAL REPORT 2024 • MANAGEMENT REPORT 317

List of data points that derive from other EU legislation

Disclosure

Requiremen

Datapoint

Description

Referenc

e SFDR

Pillar 3

Referenc

Regulatio

n of

Referenc

climate

legislatio

referenc

Location

Materialit

ESRS E3-4

Paragraph 29

Total water consumption in m³ per net income from own operations

Non-

material

ESRS 2-

SBM3 - E4

Paragraph 16 (a)

Disclosure of activities negatively affecting biodiversity sensitive areas

Chap.

5.2.4.1.1

ESRS 2-

SBM3 - E4

Paragraph 16 (b)

Material negative impacts with regards to land degradation, desertification or soil sealing

have been identified

Chap.

5.2.4.1.1

ESRS 2-

SBM3 - E4

Paragraph 16 (c)

Own operations affect threatened species

Chap.

5.2.4.1.1

ESRS E4-2

Paragraph 24 (b)

Sustainable land or agriculture practices or policies have been adopted

Chap.

5.2.4.2.1

ESRS E4-2

Paragraph 24 (c)

Sustainable oceans or seas practices or policies have been adopted

Non-

material

ESRS E4-2

Paragraph 24 (d)

Policies to address deforestation have been adopted

Chap.

5.2.4.2.1

ESRS E5-5

Paragraph 37 (d)

Non-recycled waste

Non-

material

ESRS E5-5

Paragraph 39

Total amount of hazardous and radioactive waste

Non-

material

ESRS 2-

SBM3 - S1

Paragraph 14 (f)

Information about type of operations at significant risk of incidents of forced labour or

compulsory labour

Chap.

5.3.1.1.1

ESRS 2-

SBM3 - S1

Paragraph 14 (g)

Information about type of operations at significant risk of incidents of child labour

Chap.

5.3.1.1.1

ESRS S1-1

Paragraph 20

Description of relevant human rights policy commitments relevant to own workforce

Chap.

5.3.1.2.1

ESRS S1-1

Paragraph 21

Disclosure of whether and how policies are aligned with relevant internationally recognised

instruments (ILO conventions 1 to 8)

Chap.

5.3.1.2.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 318

List of data points that derive from other EU legislation

Disclosure

Requiremen

Datapoint

Description

Referenc

e SFDR

Pillar 3

Referenc

Regulatio

n of

Referenc

climate

legislatio

referenc

Location

Materialit

ESRS S1-1

Paragraph 22

Processes and measures to prevent human trafficking

Chap.

5.3.1.2.1

ESRS S1-1

Paragraph 23

Workplace accident prevention policy or management system is in place

Chap.

5.3.1.2.1

ESRS S1-3

Paragraph 32 (c)

Grievance or complaints handling mechanisms related to employee matters exist

Chap.

5.3.1.2.3

ESRS S1-14

Paragraph 88 (b)

e (c)

Number of fatalities and number and rate of work-related accidents in own workforce as

result of work-related injuries and work-related ill health

Chap.

5.3.1.3.8

ESRS S1-14

Paragraph 88 (e)

Number of days lost to work-related injuries and fatalities from work-related accidents, work-

related ill health and fatalities from ill health related to employees

Chap.

5.3.1.3.8

ESRS S1-16

Paragraph 97 (a)

Gender pay gap

Chap.

5.3.1.3.10

ESRS S1-16

Paragraph 97 (b)

Excessive remuneration ratio for executive directors

Chap.

5.3.1.3.10

ESRS S1-17

Paragraph 103

(a)

Number of incidents of discrimination

Chap.

5.3.1.3.11

ESRS S1-17

Paragraph 104

(a)

Non-compliance with the UNGPs on business and human rights and the OECD guidelines

Chap.

5.3.1.3.11

ESRS 2-

SBM3 – S2

Paragraph 11 (b)

Disclosure of geographies or commodities for which there is significant risk of child labour, or

of forced or compulsory labour, among workers in undertaking’s value chain

Chap.

5.3.2.1.1

ESRS S2-1

Paragraph 17

Description of relevant human rights policy commitments relevant to value chain workers

Chap.

5.3.2.2.1

ESRS S2-1

Paragraph 18

Policies explicitly address trafficking in human beings, forced labour or compulsory labour and

child labour

Non-

material

ESRS S2-1

Paragraph 19

Disclosure of extent and indication of nature of cases of non-respect of the UN Guiding

Principles on Business and Human Rights and Fundamental Principles and Rights at Work or

OECD Guidelines for Multinational Enterprises that involve value chain workers

Chap.

5.3.2.2.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 319

List of data points that derive from other EU legislation

Disclosure

Requiremen

Datapoint

Description

Referenc

e SFDR

Pillar 3

Referenc

Regulatio

n of

Referenc

climate

legislatio

referenc

Location

Materialit

ESRS S2-1

Paragraph 19

Due diligence policies on issues covered by ILO conventions 1 to 8

Chap.

5.3.2.2.1

ESRS S2-4

Paragraph 36

Disclosure of severe human rights issues and incidents connected to upstream and

downstream value chain

Chap.

5.3.2.2.4

ESRS S3-1

Paragraph 16

Description of relevant human rights policy commitments relevant to affected communities

Non-

material

ESRS S3-1

Paragraph 17

Disclosure of extent and indication of nature of cases of non-respect of the UN Guiding

Principles on Business and Human Rights and ILO Declaration on Fundamental Principles and

Rights at Work or OECD Guidelines for Multinational Enterprises that involve affected

communities

Non-

material

ESRS S3-4

Paragraph 36

Disclosure of severe human rights issues and incidents connected to affected communities

Non-

material

ESRS S4-1

Paragraph 16

Description of relevant human rights policy commitments relevant to consumers and/or end-

users

Non-

material

ESRS S4-1

Paragraph 17

Disclosure of extent and indication of nature of cases of non-respect of the UN Guiding

Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and

Rights at Work or OECD Guidelines for Multinational Enterprises that involve consumers

and/or end-users

Non-

material

ESRS S4-4

Paragraph 35

Disclosure of severe human rights issues and incidents connected to consumers and/or end-

users

Non-

material

ESRS G1-1

Paragraph 10 (b)

UN Convention against Corruption

Chap.

5.4.1.2.1

ESRS G1-1

Paragraph 10 (d)

Protection of whistleblowers

Non-

material

ESRS G1-4

Paragraph 24 (a)

Amount of fines for violation of anti-corruption and anti- bribery laws

Chap.

5.4.1.3.2

ESRS G1-4

Paragraph 24 (b)

Prevention and detection of corruption or bribery

Chap.

5.4.1.3.2

RELATÓRIO ANUAL 2024 • RELATÓRIO DE GESTÃO 320

ESRS 2 BP-2 - List of disclosure requirements/datapoints incorporated by reference

Disclosure Requirements

Location

List of disclosure requirements/datapoints incorporated by reference

BP-2

Chap. 9.1.1 ESRS

Disclosure of the composition and diversity of the members of the

administrative, management and supervisory bodies (ESRS 2.21a/c/d/e)

GOV-1

Chap. 3.2 – Governance model of this report and in

sections 11, 17, 21, 31 and 39 of the Corporate

Governance Report | Part I –

Information on Shareholder

Structure, Organisation and Corporate Governance

Representation of employees and other workers on the company's

administrative, management and supervisory bodies (ESRS 2.21b)

GOV-1

Chap. 3.2 – Governance model of this report and in

sections 11, 17, 21, 31 and 39 of the Corporate

Governance Report | Part I –

Information on Shareholder

Structure, Organisation and Corporate Governance

Disclosure of the identity of the administrative, management and supervisory

bodies (ESRS 2.22a)

GOV-1

Sections 11, 17, 21, 31 and 39 of the Corporate

Governance Report | Part I –Information on Shareholder

Structure, Organisation and Corporate Governance

Roles and responsibilities of the administrative, management and supervisory

bodies in monitoring risks (ESRS 2.22a/b/c)

GOV-1

Chap. 3.3 – Risk managment of this report and in sections

50 - 51 of the Corporate Governance Report | Part I –

Information on Shareholder Structure, Organisation and

Corporate Governance

The role of the administrative, management and supervisory bodies with

regard to business conduct (ESRS G1.5a)

GOV-1

Chap. 3.2 – Governance model of this report and in

sections 11-38 of the Corporate Governance Report | Part

I –Information on Shareholder Structure, Organisation

and Corporate Governance | B.

Corporate Bodies and

Committees | II.

Management and Supervision | III.

Supervision

Disclosure of the competences of the members of the administrative,

management and supervisory bodies in terms of sustainability and business

conduct (ESRS 2.23/ G1.5b)

GOV-1

Chap. 3.2 – Governance model of this report and in

section16 of the Corporate Governance Report | Part I –

Information on Shareholder Structure, Organisation and

Corporate Governance

Disclosure of whether, by whom and how frequently administrative,

management and supervisory bodies are informed about the IRO (ESRS

2.26a/b/AR6)

GOV-2

Sections 21, 24 e 25 of the Corporate Governance Report

| Part I –Information on Shareholder Structure,

Organisation and Corporate Governance

Incentive schemes and remuneration policies linked to sustainability matters

for members of administrative, management and supervisory bodies exist

(ESRS 2.29a/b/c/e)

GOV-3

Sections 24–25 e 70 of the Corporate Governance Report

| Part I –Information on Shareholder Structure,

Organisation and Corporate Governance

Disclosure of mapping of information provided in sustainability statement

about due diligence process

GOV-4

Chap. 9.1.1 ESRS

Description of risk assessment approach followed (ESRS 2.36a/b)

GOV-5

Sections 50-55 of the Corporate Governance Report | Part

I –Information on Shareholder Structure, Organisation

and Corporate Governance

Description of main risks identified and their mitigation strategies (ESRS

2.36c)

GOV-5

Chap. 3.3 - Risk management of this report and section

53 of the Corporate Governance Report | Part I -

Information on Shareholder Structure, Organisation and

Corporate Governance and section of this chapter

referring to the review of the Double Materiality Analysis.

Description of significant groups of products and (or) services offered (ESRS

2.40a-i/ii)

SBM-1

Chap.2.2 Company profile, Chap. 3.1- Business strategy,

Chap. 4 - Performance in Business

Number of employees (headcount) (ESRS 2.40a-iii)

SBM-1

Chap. 5.3.1.3.2 | Characteristics of the undertaking's

employees (S1-6)

Description of sustainability-related goals in terms of significant groups of

products and services, customer categories, geographical areas and

relationships with stakeholders (ESRS 2.40e)

SBM-1

Chap.2.2 Company Profile; Chap. 2.3 Creating sustainable

value; Chap. 3.1 Business strategy; Chap. 3.4.4 2030

Roadmap; Chap. 3.4.5 Stakeholder Engagement

Assessment of current significant products and/or services and significant

markets and customer groups in relation to their sustainability-related

objectives (ESRS 2.40f)

SBM-1

Chap. 3.4.4 2030 Roadmap

ANNUAL REPORT 2024 • MANAGEMENT REPORT 321

ESRS 2 BP-2 - List of disclosure requirements/datapoints incorporated by reference

Disclosure Requirements

Location

Disclosure of elements of strategy that relate to or impact sustainability

matters (ESRS 2.40g)

SBM-1

Chap. 3.1 Business Strategy and Chap. 3.4 2030 Agenda

and Roadmap, including sub-chapters 3.4.1 - Global

Trends and Challenges for Navigator, 3.4.2 - 2030 Agenda

and 3.4.3 - Contribution to the SDGs

Exemption from disclosure of the information referred to in Article 18(1)(a) of

Directive 2013/34/EU (ESRS 2.41)

SBM-1

Note 2.1 Revenue and segment reporting of the

Consolidated Financial Statements Report

Bussiness Model (ESRS 2.42 a/b)

SBM-1

Chap. 2.2 Company Profile

Revenues from the various sectors in which Navigator operates

SBM-1

Note 2.1 Revenue and segment reporting of the

Consolidated Financial Statements Report

Description of stakeholder engagement (ESRS 2, §45a/b)

SBM-2

Chap. 3.4.5 Stakeholder engagement

Description of material impacts resulting from materiality assessment (ESRS

2.48a)

SBM-3

Chap. 5.2.2.1.1

Chap. 5.2.3.1.1

Chap. 5.2.4.1.1

Chap. 5.2.5.1.1

Chap. 5.2.6.1.1

Chap. 5.3.1.1.1

Chap. 5.3.2.1.1

Chap. 5.3.3.1.1

Chap. 5.4.1.1.1

Description of material risks and opportunities resulting from materiality

assessment (ESRS 2.48a)

SBM-3

Disclosure of reasonably expected time horizons of material impacts (ESRS

2.48ciii)

SBM-3

Disclosure of specification of impacts, risks and opportunities that are covered

by ESRS (ESRS 2.48h)

SBM-3

Climate resilience analysis (ESRS 2.48f)

SBM-3

Chap. 5.2.2.1.1

Disclosure of list of requirements complied with in preparing sustainability

statement following outcome of materiality assessment (IRO-2)

IRO-2

Chap. 9.1.1 ESRS

Disclosure of list of data points that derive from other EU legislation and

information on their location in sustainability statement

IRO-2

Chap. 9.1.1 ESRS

Minimum Disclosure Requirements for Policies- General presentation of policies

MDR-P

Explanation of relationship of significant CapEx and OpEx required to

implement actions taken or planned to relevant line items or notes in financial

statements (ESRS 2.69b)

E1-3

Notes 3.2, 3.3 and 3.6 of the Consolidated Financial

Statements Report

Disclose the reconciliation to the relevant line item or notes in the financial

statements of the net revenue amount (E1.55)

E1-6

Note 2.1 Revenue and segment reporting of the

Consolidated Financial Statements Report

Explanation of how the current financial resources allocated to actions or

action plans relate to the most relevant amounts presented in the financial

statements (ESRS 2.69b)

E3-2

Notes 3.2, 3.3 and 3.6 of the Consolidated Financial

Statements Report

Explanation of how time horizons are defined, financial amounts are estimated

and critical assumptions made (water and marine resources) (E3.33a, E3.33b,

E3.33c)

E3-5

Chap. 5.2.2.1.1

Target ‘Contribute to reducing fires in rural areas, ensuring that the area burnt

under Navigator's management is less than 1% per year’, which falls under

prevention in the mitigation hierarchy (MDR-T, ESRS 2, §80)

E4-4

Chap. 5.2.6.3.1

Performance achieved in 2024 in relation to Navigator's commitments under

the act4nature Portugal initiative (MDR-T, ESRS 2, §80j)

E4-4

Chap. 8.3

Explanation of how the current financial resources allocated to actions or

action plans relate to the most relevant amounts presented in the financial

statements (ESRS 2.69b)

E5-2

Notes 3.2, 3.3 and 3.6 of the Consolidated Financial

Statements Report

Information on the follow-up and monitoring of issues raised and addressed

and ensuring the effectiveness of the Whistleblowing Channel

S1-3

Chap. 5.4.1.2.1

Information on the relationship between current financial resources allocated

to actions or action plans and the most significant amounts presented in the

financial statements (ESRS 2.69b)

S1-4

Notes 7.1 and 7.2 of the Consolidated Financial

Statements Report

Total number of employees (S1.50f)

S1-6

Notes 7 and 7.1 of the Consolidated Financial Statements

Report

ANNUAL REPORT 2024 • MANAGEMENT REPORT 322

(*) Given that Navigator has several corporate policies that are mentioned several times throughout the chapters, in order to

avoid redundancy of information, they have been referred to via: summary tables which, whenever applicable, have a field

labelled ‘References throughout the non-financial statement’; text at the end of the policy section. Given their large number, they

are not presented in this table.

ESRS 2 BP-2 - List of disclosure requirements/datapoints incorporated by reference

Disclosure Requirements

Location

Information on the follow-up and monitoring of issues raised and addressed

and ensuring the effectiveness of the Whistleblowing Channel

S2-3

Chap. 5.4.1.2.1

Information on the relationship between current financial resources allocated

to actions or action plans and the most significant amounts presented in the

financial statements (ESRS 2.69b)

S2-4

Consolidated Financial Statements Report

Information on the targets for reducing frequency indexes (Iberia and

Mozambique) and the percentage of accidents uncharacterised by non-

compliance with rules and procedures (MDR-T, ESRS 2, §80)

S2-5

Chap. 5.3.1.3.1

Information on the implemented actions of the CRESCER project (Grow) and

participation in the Business & Human Rights Accelerator Programme (MDR-A,

ESRS 2, §68 b/c/e, §69 b/c)

G1.MDR-A

Chap. 5.3.1.2.4

Information on the actions implemented in terms of supplier management

(MDR-A, ESRS 2, §68 b/c/e, §69 b/c)

G1.MDR-A

Chap. 5.3.2.2.4

Information on the target for continuous monitoring of employees' main

motivational stimuli (MDR-T, ESRS 2, §80)

G1.MDR-T

Chap. 5.3.1.3.1

ESRS 2 GOV-4 - Statement on Due Diligence

Core Elements of Due Diligence

Points in the Non-Financial Statement

Location

Embedding due diligence in governance, strategy and business model

ESRS 2 GOV-2

Chap. 5.1.2.2

ESRS 2 GOV-3

Chap. 5.1.2.3

ESRS 2 SBM-3

Chap. 5.1.3.3

Chap. 5.2.2.1.1

Chap. 5.2.3.1.1

Chap. 5.2.4.1.1

Chap. 5.2.5.1.1

Chap. 5.2.6.1.1

Chap. 5.3.1.1.1

Chap. 5.3.2.1.1

Chap. 5.3.3.1.1

Chap. 5.4.1.1.1

Engaging with affected stakeholders in all key steps of the due diligence

ESRS 2 GOV-2

Chap. 5.1.2.2

ESRS 2 SBM-2

Chap. 5.1.3.2

ESRS 2 IRO-1

Chap. 5.1.4.1

ESRS 2 MDR-P

Chap. 5.2.2.2.1

Chap. 5.2.3.2.1

Chap. 5.2.4.2.1

Chap. 5.2.5.2.1

Chap. 5.2.6.2.1

Chap. 5.3.1.2.1

Chap. 5.3.2.2.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 323

ESRS 2 GOV-4 - Statement on Due Diligence

Core Elements of Due Diligence

Points in the Non-Financial Statement

Location

Chap. 5.3.3.2.1

Chap. 5.4.1.2.1

Chap. 5.4.1.2.2

Chap. 5.4.1.2.3

Identifying and assessing adverse impacts

ESRS 2 IRO-1

Chap. 5.1.4.1

ESRS 2 SBM-3

Chap. 5.1.3.3

Chap. 5.2.2.1.1

Chap. 5.2.3.1.1

Chap. 5.2.4.1.1

Chap. 5.2.5.1.1

Chap. 5.2.6.1.1

Chap. 5.3.1.1.1

Chap. 5.3.2.1.1

Chap. 5.3.3.1.1

Chap. 5.4.1.1.1

Taking actions to address those adverse impacts

ESRS 2 MDR-A

Chap. 5.2.2.2.2

Chap. 5.2.3.2.2

Chap. 5.2.4.2.2

Chap. 5.2.5.2.2

Chap. 5.2.6.2.2

Chap. 5.3.1.2.4

Chap. 5.3.2.2.4

Chap. 5.3.3.2.4

Chap. 5.4.1.2.4

Tracking the effectiveness of these efforts and communicating

ESRS 2 MDR-M

Chap. 5.2.2.3.1

Chap. 5.2.3.3.1

Chap. 5.2.3.3.2

Chap. 5.2.4.3.1

Chap. 5.2.4.3.2

Chap. 5.2.5.3.1

Chap. 5.2.5.3.2

Chap. 5.2.5.3.3

Chap. 5.2.6.3.2

Chap. 5.3.1.3.1

Chap. 5.3.1.3.12

Chap. 5.3.2.3.1

Chap. 5.3.3.3.1

Chap. 5.4.1.3.3

ESRS 2 MDR-T

Chap. 5.2.2.3.1

Chap. 5.2.3.3.1

Chap. 5.2.4.3.1

Chap. 5.2.5.3.1

Chap. 5.2.6.3.1

Chap. 5.3.1.3.1

Chap. 5.3.2.3.1

Chap. 5.3.3.3.1

Chap. 5.4.1.3.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 324

9.1.2. DNFI Table (Disclosure of Non-Financial Information)

This table shows the correspondence between the content of Navigator's 2024 Management Report and the information

required in the report template for disclosure of non-financial information, recommended by CMVM (Portuguese Securities

Exchange Commission). This template applies to issuers of securities admitted to trading on regulated markets and reflects the

applicable legal rules.

A. Information about policies adopted

Chapters Sub-chapters ESRS Corresponding Content

A. Introduction 1. Description of the Company’s general policy

regarding sustainability issues, indicating any

changes to previously approved policy.

SBM-1

Chap. 3.1

Chap. 3.4

Chap. 5.1.3.1

2. Description of non-financial information reporting

methodology and reasons for its adoption, including

any changes in relation to previous years and

reasons for them.

BP-1

BP-2

Chap. 5.1.1

B. Business model 1. General description of the Company’s/Group’s

business model and form of organization, stating the

main business areas and markets of operation (if

possible, using organizational charts, graphs or

functional diagrams).

SBM-1

Chap. 2.2

Chap. 5.1.3.1

C. Main risk factors 1. Identification of the main risks relating to the

matters under report and arising from the Company’s

activities, products, services or business relations,

including, where applicable and possible, supply and

subcontracting chains.

SBM-3 Chap. 3.3

Chap. 5.1.2.1

Chap. 5.1.2.4

Chap. 5.1.3.3

Chap. 5.2.2.1.1

Chap. 5.2.3.1.1

Chap. 5.2.4.1.1

Chap. 5.2.5.1.1

Chap. 5.2.6.1.1

Chap. 5.3.1.1.1

Chap. 5.3.2.1.1

Chap. 5.3.3.1.1

Chap. 5.4.1.1.1

2. Indication of how the Company identifies and

manages these risks.

GOV-1

GOV-5

SBM-3

IRO-1

3. Explanation of the functional division, including

governing bodies, commissions, committees, or

departments responsible for identification and

management/monitoring of risks.

GOV-1

4. Express indication of any new risks identified by

the Company in relation to those reported in

previous years, and also of risks no longer identified.

SBM-3

5. Indication and brief description of the main

opportunities identified by the Company regarding

the matters subject to reporting.

SBM-3

D. Implemented policies

I. Environmental policies

1. Description of the Company’s strategic objectives

and key actions taken to achieve them.

E1-1

E1-2

E1-3

Chap. 3.4.2

Chap. 3.4.3

Chap. 3.4.4

Chap. 5.2.2.1.2

Chap. 5.2.2.2.1

Chap. 5.2.2.2.2

ANNUAL REPORT 2024 • MANAGEMENT REPORT 325

Chapters Sub-chapters ESRS Corresponding Content

E1-4

E2-1

E2-2

E2-3

E3-1

E3-2

E3-3

E4-1

E4-2

E4-3

E4-4

E5-1

E5-2

E5-3

MDR-P (entity specific)

MDR-A (entity specific)

MDR-T (entity specific)

Chap. 5.2.2.3.1

Not material

Chap. 5.2.3.2.1

Chap. 5.2.3.2.2

Chap. 5.2.3.3.1

Chap. 5.2.4.1.2

Chap. 5.2.4.2.1

Chap. 5.2.4.2.2

Chap. 5.2.4.3.1

Chap. 5.2.5.2.1

Chap. 5.2.5.2.2

Chap. 5.2.5.3.1

Chap. 5.2.6.2.1

Chap. 5.2.6.2.2

Chap. 5.2.6.3.1

2. Description of the main established key

performance indicators.

E1-4

E1-5

E1-6

E2-3

E2-4

E2-5

E3-3

E3-4

E4-4

E4-5

E5-3

E5-4

E5-5

MDR-T (entity specific)

MDR-M (entity specific)

Chap. 3.4.4

Chap. 8.2

Chap. 5.2.2.3.1

Chap. 5.2.2.3.2

Chap. 5.2.2.3.3

Not material

Chap. 5.2.3.3.1

Chap. 5.2.3.3.2

Chap. 5.2.4.3.1

Chap. 5.2.4.3.2

Chap. 5.2.5.3.1

Chap. 5.2.5.3.2

Chap. 5.2.5.3.3

Chap. 5.2.6.3.1

Chap. 5.2.6.3.2

3. Indication, on a year-over-year basis, of the

degree to which these objectives were achieved, by

reference to at least:

Chap. 3.4.4

i. Sustainable use of resources E3-3

E5-3

MDR-T (entity specific)

Chap. 5.2.3.3.1

Chap. 5.2.5.3.1

Chap. 5.2.6.3.1

ii. Pollution and climate change

E1-4

Chap. 5.2.2.3.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 326

Chapters Sub-chapters ESRS Corresponding Content

E2-3

Not material

Chap. 8.2

iii. Circular economy and waste management E5-3

Chap. 5.2.5.3.1

iv. Protection of biodiversity E4-4

Chap. 5.2.4.3.1

II. Social and tax

1. Description of the Company’s strategic objectives

and key actions taken to achieve them

S2-1

S2-4

S2-5

S3-1

S3-4

S3-5

S4-1

S4-4

S4-5

G1-2

Chap. 3.4.2

Chap. 3.4.3

Chap. 3.4.4

Chap. 4.10

Chap. 5.3.2.2.1

Chap. 5.3.2.2.4

Chap. 5.3.2.3.1

Chap. 5.3.3.2.1

Chap. 5.3.3.2.4

Chap. 5.3.3.3.1

Not material

Chap. 5.4.1.2.2

2. Description of the established key performance

indicators

MDR-M (S2)

MDR-M (S3)

MDR-M (S4)

MDR-M (G1)

Chap. 3.4.4

Chap. 5.3.2.3.2

Chap. 5.3.3.3.2

Not material

Chap. 5.4.1.3.3

3. Indication, on a year-over-year basis, of the

degree to which these objectives were achieved, by

reference to at least:

Chap. 3.4.4

i. Company's commitment to the community S3-5 Chap. 5.3.3.3.1

ii. Subcontracting and Suppliers S2-5

MDR-T (G1)

Chap. 5.3.2.3.1

5.4.1.3.1

iii. Consumers S4-5 Not material

iv. Responsible investment Not Applicable Chap. 2.3

v. Stakeholders

SBM-2

S1-2

S2-2

S3-2

S4-2

Chap. 3.4.5

Chap. 5.1.3.2

Chap. 5.3.1.2.2

Chap. 5.3.2.2.2

Chap. 5.3.3.2.2

Not material

vi. Tax information Not Applicable Chap. 4.10

ANNUAL REPORT 2024 • MANAGEMENT REPORT 327

Chapters Sub-chapters ESRS Corresponding Content

III. Employees and

gender equality and

non-discrimination

1. Description of the Company’s strategic objectives

and key actions taken to achieve them

S1-1

S1-4

S1-5

Chap. 3.4.2

Chap. 3.4.3

Chap. 3.4.4

Chap. 5.3.1.2.1

Chap. 5.3.1.2.4

Chap. 5.3.1.3.1

2. Description of the established key performance

indicators

S1-5

S1-6

S1-7

S1-8

S1-9

S1-10

S1-11

S1-12

S1-13

S1-14

S1-15

S1-16

S1-17

MDR-M (S1)

Chap. 3.4.4

Chap. 8.2

Chap. 5.3.1.3.1

Chap. 5.3.1.3.2

Chap. 5.3.1.3.3

Chap. 5.3.1.3.4

Chap. 5.3.1.3.5

Chap. 5.3.1.3.6

Not material

Chap. 5.3.1.3.7

Chap. 5.3.1.3.8

Chap. 5.3.1.3.9

Chap. 5.3.1.3.10

Chap. 5.3.1.3.11

Chap. 5.3.1.3.12

3. Indication, on a year-over-year basis, of the

degree to which these objectives were achieved, by

reference to at least:

Chap. 3.4.4

i. Employment S1-5 Chap. 5.3.1.3.1

ii. Organization of work S1-5 Chap. 5.3.1.3.1

iii. Health and Safety S1-5 Chap. 5.3.1.3.1

iv. Social relations S1-5 Chap. 5.3.1.3.1

v. Training S1-5 Chap. 5.3.1.3.1

vi. Equality S1-5 Chap. 5.3.1.3.1

IV. Human Rights 1. Description of the Company’s strategic objectives

and key actions taken to achieve them

S1-1

S1-4

S1-5

S2-1

S2-4

S2-5

S3-1

Chap. 3.4.2

Chap. 3.4.3

Chap. 3.4.4

Chap. 5.3.1.2.1

Chap. 5.3.1.2.4

Chap. 5.3.1.3.1

Chap. 5.3.2.2.1

Chap. 5.3.2.2.4

Chap. 5.3.2.3.1

Chap. 5.3.3.2.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 328

Chapters Sub-chapters ESRS Corresponding Content

S3-4

S3-5

S4-1

S4-4

S4-5

G1-1

MDR-A (G1)

MDR-T (G1)

Chap. 5.3.3.2.4

Chap. 5.3.3.3.1

Not material

Chap. 5.4.1.2.1

Chap. 5.4.1.2.4

Chap. 5.4.1.3.1

2. Description of the established key performance

indicators

S1-5

S1-17

S2-5

MDR-M (S2)

S3-5

MDR-M (S3)

S4-5

MDR-M (S4)

Chap. 5.3.1.3.1

Chap. 5.3.1.3.11

Chap. 5.3.2.3.1

Chap. 5.3.3.3.1

Chap. 5.3.3.3.2

Not material

3. Indication, on a year-over-year basis, of the

degree to which these objectives were achieved, by

reference to at least:

i. Due diligence procedures

ii. Risk prevention measures

iii. Judicial proceedings

GOV-4

S1-5

S1-17

S2-5

S3-5

S4-5

G1-2

MDR-T (G1)

Chap. 9.1.1

Chap. 5.3.1.3.1

Chap. 5.3.1.3.11

Chap. 5.3.2.3.1

Chap. 5.3.3.3.1

Not material

Chap. 9.1.1

Chap. 5.4.1.3.1

V. A n t i -corruption and anti-

bribery

1. Corruption prevention: measures and instruments

adopted to prevent corruption and bribery; policies

implemented to deter workers and Suppliers from

engaging in these practices; information on the

compliance system, indicating the relevant functional

managers, if any; indication of legal proceedings

involving the Company, its directors or employees

related to corruption or bribery; measures adopted in

relation to public procurement, if relevant.

G1-1

G1-3

G1-4

MDR-A (G1)

Chap. 5.4.1.2.1

Chap. 5.4.1.2.3

Chap. 5.4.1.3.2

Chap. 5.4.1.2.4

Corporate Governance Report

2. Prevention of money laundering (for issuers

subject to these rules): information on measures to

prevent and combat money laundering;

indication of number of cases reported each year.

G1-1

Chap. 5.4.1.2.1

Corporate Governance Report

3. Codes of ethics: indication of any code of ethics to

which the Company may have acceded or which it

may have implemented; indication of the respective

mechanisms for implementation and monitoring of

compliance with the code, if applicable.

G1-1

Chap. 5.4.1.2.1

Corporate Governance Report

4. Management of conflicts of interest: measures to

manage and monitor conflicts of interest, namely

requiring managers and employees to sign

declarations of interest, incompatibilities and

impediments.

G1-1

Chap. 5.4.1.2.1

Corporate Governance Report

ANNUAL REPORT 2024 • MANAGEMENT REPORT 329

B. Disclosures on standards followed

1. Identification of the

standards followed for

reporting non-financial

information

Identification of the standards / guidelines followed

for preparation of non-financial information, including

the respective options, and other principles

considered in the Company’s conduct, if applicable. If

the Company refers to the United Nations 2030

Agenda Sustainable Development Goals (SDGs),

include identification of those to which the Company

is committed to contribute, indicating the measures

taken each year to achieve the goals set for each of

these SDGs. In other words, identify concrete actions,

projects or investments with a view to attaining these

SDGs.

BP-1

BP-2

Chap. 3.4.3

Chap. 5.1.1.1

Chap. 5.1.1.2

2. Identification of the

scope and methodology for

calculating indicators

Description of the scope and calculation methodology

(including the calculation formula) for the indicators

presented, including any limitations on this reporting.

Where possible, a table should be presented showing

correspondence between the indicators presented and

principles or objectives considered, indicating where

the information is detailed (e.g. the page of the

stand-alone report on non-financial information, the

annual report, any other document or the Company’s

website).

BP-2

E1-5

E1-6

E2-4

E2-5

E3-4

E4-5

E5-4

E5-5

MDR-M (entity specific)

S1-6

S1-7

S1-8

S1-9

S1-10

S1-11

S1-12

S1-13

S1-14

S1-15

S1-16

S1-17

MDR-M (S1)

MDR-M (S2)

MDR-M (S3)

MDR-M (S4)

G1-3

G1-4

MDR-M (G1)

Chap. 8

Chap. 5.1.1.2

Chap. 5.2.2.3.2

Chap. 5.2.2.3.3

Not material

Chap. 5.2.3.3.2

Chap. 5.2.4.3.2

Chap. 5.2.5.3.2

Chap. 5.2.5.3.3

Chap. 5.2.6.3.2

Chap. 5.3.1.3.2

Chap. 5.3.1.3.3

Chap. 5.3.1.3.4

Chap. 5.3.1.3.5

Chap. 5.3.1.3.6

Not material

Chap. 5.3.1.3.7

Chap. 5.3.1.3.8

Chap. 5.3.1.3.9

Chap. 5.3.1.3.10

Chap. 5.3.1.3.11

Chap. 5.3.1.3.12

Chap. 5.3.2.3.2

Chap. 5.3.3.3.2

Not material

Chap. 5.4.1.2.3

Chap. 5.4.1.3.2

Chap. 5.4.1.3.3

3. Explanation of

nonapplication of policies

If the Company does not apply policies with respect to

one or more issues, the non-financial reporting

provides an explanation of the reasons for this.

-- --

ANNUAL REPORT 2024 • MANAGEMENT REPORT 330

4. Other information Additional data or information that is not included

above but is relevant to understanding and explaining

non-financial information and the respective

background, in particular regarding networks/groups

of entities in the field of sustainability and

responsibility to which it belongs, at national or

international level, and sustainability commitments

that the Company has made voluntarily, at local or

global level.

-- --

9.1.3. Table summarising World Economic Forum’s

Stakeholder Capitalism core metrics

The following table presents The Navigator Company's response to the WEF framework (core metrics), through the alignment

between the metrics established by the WEF, the GRI standards (which underpin the new framework), and the ESRS standards.

Although some of these metrics do not have a direct correspondence with the GRI, the Company addresses them indirectly

through related content on the respective topics presented throughout the sustainability report.

Pillar Topic Metrics

Alignment with

GRI

Alignment with

ESRS

Governance

Governance Purpose Purpose established GRI 2-12

GOV-1

SBM-1

Quality of

Governance

Body

Governance Body Composition

GRI 2-9

GRI 405-1

GOV-1

Stakeholder

Engagement

Stakeholder Engagement

GRI 2-12

GRI 2-29

GRI 3-2

SBM-2/3

IRO-1

Ethical behaviour Anti-corruption

GRI 205-2

GRI 205-3

G1-1

G1-3

G1-4

Ethical behaviour Advice mechanisms GRI 2-26

S1-3

S2-3

S3-3

S4-3

G1-1

Risks and

Opportunities

Integration of risks and opportunities No associated GRI

SBM-3

IRO-1

Planet Climate Change

Greenhouse Gas Emissions (GHG) GRI 305-1/2/3 E1-6

Implementation of the recommendations from the

TCFD (Task Force on Climate-related Financial

Disclosures)

No associated GRI

GOV-1/2/3

SBM-3

IRO-1

Não incluido no presente relatório (Not material)

ANNUAL REPORT 2024 • MANAGEMENT REPORT 331

Pillar Topic Metrics

Alignment with

GRI

Alignment with

ESRS

E1-1/2/3/4/6/9

Biodiversity Loss

Land use and ecological protection focused on

protected areas or key biodiversity areas.

GRI 304-1 E4-5

Fresh water

availability

Water consumption and withdrawal in

waterstressed areas

GRI 303-3/5 E3-4

People

Dignity and equality

Diversity and inclusion: % of Employees by

occupational category, gender, age range and

other diversity categories

GRI 405-1 and

405-2

S1-9

S1-12

Pay ratio between men and women, ethnic

minorities and majorities, and other groups.

S1-16

Ratio (%) of entry-level wage compared to

national minimum wage, by gender.

GRI 202-1 S1-10

Ratio (%) of CEO’s total annual compensation to

median total annual compensation of all

Employees (excluding the CEO)

GRI 2-21 S1-16

Risk for incidents of child, forced or compulsory

labour

GRI 408-1 and

409-1

SBM-3

S1-17

Health and well-being

Health and safety (%). Number and rate of work-

related injuries, highconsequence injuries and

fatalities.

GRI 403-9 S1-14

An explanation of how the organization facilitates

workers’ access to non-occupational medical and

healthcare services and the scope of access

provided.

GRI 403-6

S1-4/S2-4

S1-11

Skills for the future

Training hours (no.) per Employee GRI 404-1 S1-13

Training investment (€) per Employee No associated GRI

No associated

ESRS

Prosperity

Employment and

wealth generation

Rate of Employee turnover (%), by age group,

gender, or other indicators of diversity.

GRI 401-1 S1-6

Economic contribution: Direct economic value

generated and distributed (EVG&D) by revenue;

operating costs; employee wages and benefits,

payments to providers of capital, payments to

government (by country) and community

investment.

GRI 201-1 No associated ESRS

Financial assistance received from the

government: tax benefits and credits; subsidies;

grants for investment, research and development

and other relevant types of assistance, among

others.

GRI 201-4 No associated ESRS

Financial investment contribution Total capital

expenditures or investment in capital goods

No associated GRI

No associated

ESRS

Não incluido no presente relatório (Not material)

Em função dos temas materiais.

Não incluido no presente relatório (Not material)

Não incluido no presente relatório

ANNUAL REPORT 2024 • MANAGEMENT REPORT 332

Pillar Topic Metrics

Alignment with

GRI

Alignment with

ESRS

(CapEx) undepreciated, supported by narrative to

describe the company’s investment strategy.

Share buybacks + Dividend payments supported

by narrative to describe the Company’s strategy

for returns of capital to shareholders.

No associated GRI

No associated

ESRS

Innovation in better

products and services

R&D expenditure

No associated GRI No associated ESRS

Total costs relating to development

Community and social

vitality

Taxes: The total global tax borne by the company,

including corporate income taxes, property taxes,

non-creditable VAT and other sales taxes,

employer-paid payroll taxes and other taxes that

constitute costs to the company, by category of

taxes

GRI 201-1 and

207-4

No associated ESRS

9.2 GRI Table

This index identifies the GRI Standards and indicators to which Navigator is responding, referring to the respective sections of the

Report (or other external resources) and detailing the response, in the table, wherever applicable.

Statement of use

The Navigator Company has reported in accordance with the GRI

Standards for the period from 1 January 2024 to 31 December 2024

Reporting in accordance with:

GRI 1: Grounds 2021

UNIVERSAL CONTENT

GRI 2: GENERAL DISCLOSURES 2021

ESRS

LOCATION

Relating to the standard published in 2021

THE ORGANISATION AND ITS REPORTING PRACTICES

2-1 Organizational Details

Chap. 2

2-2 Entities included in the organisation's sustainability reporting

BP-1

Chap. 5.1.1.1

2-3 Reporting period, frequency and contact point

Chap. 5.1.1.1

2-4 Restatements of information

BP-2

Chap. 5.1.1.2

2-5 External verification

Chap. 5.1.1.1

ACTIVITIES AND WORKERS

2-6 Activities, value chains and other business relationships

SBM-1

Chap. 2.2

Chap. 5.1.3.1

2-7 Employees

SBM-1

S1-6

Chap. 5.1.3.1

Chap. 5.3.1.3.2

Chap. 8.3

2-8 Workers who are not Employees

S1-7

Chap. 5.3.1.3.3

GOVERNANCE

Não incluido no presente relatório

ANNUAL REPORT 2024 • MANAGEMENT REPORT 333

2-9 Governance structure and management

GOV-1

Chap. 5.1.2.1

2-10 Nominating and selecting the highest governance body

Sections 16 and 17, Corporate

Governance Report | Part I –

Information on Shareholding

Structure, Organisation and

Corporate Governance | B.

Corporate Bodies and

Committees | II.

Management

and Supervision.

2-11 Chair of the highest governance body

Chap. 3.2

2-12 Role of highest governance body in overseeing the management of impacts

GOV-1

GOV-2

SBM-2

Chap. 5.1.2.1

Chap. 5.1.2.2

Chap. 5.1.3.2

2-13 Responsibility for managing impacts

GOV-1

GOV-2

Chap. 5.1.2.1

Chap. 5.1.2.2

2-14 Role of highest governance body in sustainability reporting

GOV-1

IRO-1

Chap. 5.1.2.1

Chap. 5.1.4.1

2-15 Conflicts of interest

Section 10, Corporate

Governance Report | Part I –

Information on Shareholding

Structure, Organisation and

Corporate Governance | A.

Shareholding Structure | 1.1.2.

Shareholdings and Bonds Held

and

Sections 89, 90 and 91,

Corporate Governance Report |

Part I – Information on

Shareholding Structure,

Organisation and Corporate

Governance | E. Related Party

Transactions and Conflicts of

Interest | I. Procedural and

Control Mechanisms

2-16 Communicating critical concerns

GOV-2

G1-3

Chap. 5.1.2.2

Chap. 5.4.1.2.3

2-17 Collective knowledge of highest governance body

GOV-1

Chap. 3.2

Chap. 5.1.2.1

2-18 Evaluation the performance of the highest governance body

Sections 24–25, Corporate

Governance Report | Part I –

Information on Shareholding

Structure, Organisation and

Corporate Governance | A.

Shareholding Structure | 1.1.2.

Shareholdings and Bonds Held

2-19 Remuneration policies

GOV-3

Chap. 5.1.2.3

Section 70, Corporate

Governance Report | Part I –

Information on Shareholding

Structure, Organisation and

Corporate Governance | D.

Remuneration | III.

Remuneration Structure

2-20 Process to determine remuneration

GOV-3

Chap. 5.1.2.3

Sections 66 and 67, Corporate

Governance Report | Part I –

Information on Shareholding

Structure, Organisation and

Corporate Governance | D.

Remuneration | II.

Remuneration

Committee

2-21 Annual total compensation ratio

S1-16

Chap. 5.3.1.3.10

STRATEGIES, POLICIES AND PRACTICES

2-22 Statement on sustainable development strategy

SBM-1

Chap.1.1/1.2

Chap. 3.4

Chap. 5.1.3.1

2-23 Policy commitments

GOV-4

E1-2

E3-1

E4-2

E5-1

MDR-P

S1-1

S2-1

S3-1

G1-1

Chap. 3.4

Chap. 9.1.1

Chap. 5.2.2.2.1

Chap. 5.2.3.2.1

Chap. 5.2.4.2.1

Chap. 5.2.5.2.1

Chap. 5.2.6.2.1

Chap. 5.3.1.2.1

Chap. 5.3.2.2.1

Chap. 5.3.3.2.1

Chap. 5.4.1.2.1

2-24 Embedding policy commitments

GOV-2

E1-3

E3-2

E4-3

E5-2

MDR-A

Chap. 5.1.2.2

Chap. 5.2.2.3.1

Chap. 5.2.3.2.2

Chap. 5.2.4.2.2

Chap. 5.2.5.2.2

Chap. 5.2.6.2.2

ANNUAL REPORT 2024 • MANAGEMENT REPORT 334

S1-4

S2-4

S3-4

G1-1

Chap. 5.3.1.2.4

Chap. 5.3.2.2.4

Chap. 5.3.3.2.4

Chap. 5.4.1.2.1

2-25 Processes to remediate negative impacts

S1-3

S2-3

S3-3

Chap. 5.3.1.2.3

Chap. 5.3.2.2.3

Chap. 5.3.3.2.3

2-26 Mechanisms for seeking advice and raising concerns

S1-3

S2-3

S3-3

G1-1

Chap. 5.3.1.2.3

Chap. 5.3.2.2.3

Chap. 5.3.3.2.3

Chap. 5.4.1.2.1

STAKEHOLDER ENGAGEMENT

2-28 Membership of associations

---

2-29 Approach to stakeholder engagement

SBM-2

S1-2

S2-2

S3-2

Chap. 3.4.5

Chap. 5.1.3.2

Chap. 5.3.1.2.2

Chap. 5.3.2.2.2

Chap. 5.3.3.2.2

2-30 Collective bargaining agreements

S1-8

Chap. 5.3.1.3.4

GRI 3: Material Topics

ESRS

LOCATION

Relating to the standard published in 2021

3-1 Process to determine material topics

IRO-1

Chap. 5.1.4.1

3-2 List of material topics

SBM-3

Chap. 5.1.3.3

Chap. 5.2.2.1.1

Chap. 5.2.3.1.1

Chap. 5.2.4.1.1

Chap. 5.2.5.1.1

Chap. 5.2.6.1.1

Chap. 5.3.1.1.1

Chap. 5.3.2.1.1

Chap. 5.3.3.1.1

Chap. 5.4.1.1.1

3-3 Management of material topics

SBM-3

MDR-P/A/T/M

Chap. 3.4

Chap. 5.1.3.3

Chap. 5.2.2

Chap. 5.2.3

Chap. 5.2.4

Chap. 5.2.5

Chap. 5.2.6

Chap. 5.3.1

Chap. 5.3.2

Chap. 5.3.3

Chap. 5.4.1

Specific Contents

GRI 200: ECONOMIC PERFORMANCE

GRI 201: ECONOMIC PERFORMANCE

ESRS

LOCATION

Relating to the standard published in 2016

201-1 Direct economic value generated and distributed

Chap. 2.3

Chap. 8.1

201-2 Financial implications and other risks and opportunities due to climate change

SBM-3

SBM-3 (E1)

E1-9

Chap. 5.1.3.3

Chap. 5.2.2.1.1

Chap. 5.2.2.3.4

201-3 Defined benefit plan obligations and other retirement plans

Consolidated Financial

Statements 2023 | 7. Personnel –

7.2. Employee Benefits

201-4 Financial assistance received from government

Chap. 8.1

GRI 202: MARKET PRESENCE

ESRS

LOCATION

Relating to the standard published in 2016

202-1 Ratios of standard entry level wage by gender compared to local minimum wage

S1-10

Chap. 5.3.1.3.6

GRI 203: INDIRECT ECONOMIC IMPACTS

ESRS

LOCATION

Relating to the standard published in 2016

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203-1 Infrastructure investments and services supported

Chap. 5.2.6.2.2

Chap. 5.2.6.3.2

Chap. 5.3.3.2.4

Chap. 5.3.3.3.2

203-2 Significant indirect economic impacts

Chap. 2.3

GRI 204: PROCUREMENT PRACTICES

ESRS

LOCATION

Relating to the standard published in 2016

204-1 Proportion of spending on local Suppliers

Chap. 5.4.1.3.3

Chap. 8.1

GRI 205: ANTI-CORRUPTION

ESRS

LOCATION

Relating to the standard published in 2016

205-2 Communication and training about anti-corruption policies and procedures

G1-3

Chap. 5.4.1.2.3

205-3 Confirmed incidents of corruption and actions taken

G1-4

Chap. 5.4.1.3.2

GRI 207: TAX

ESRS

LOCATION

Relating to the standard published in 2019

207-1 Approach to Tax

Chap. 4.9

207-2 Tax governance, control, and risk management

Chap. 4.9

207-3 Stakeholder engagement and management of concerns related to tax

Chap. 4.9

207-4 Country-by-country reporting

Chap. 4.9

Chap. 4.10

GRI 300: ENVIRONMENTAL PERFORMANCE

GRI 301: MATERIALS

ESRS

LOCATION

Relating to the standard published in 2016

301-1 Materials used by weight or volume

E5-4

Chap. 8.2

Chap. 5.2.5.3.2

301-2 Recycled input materials used

E5-4

Chap. 8.2

Chap. 5.2.5.3.2

GRI 302: ENERGY

ESRS

LOCATION

Relating to the standard published in 2016

302-1 Energy consumption within the organization

E1-5

Chap. 8.2

Chap. 5.2.2.3.2

302-3 Energy intensity

E1-5

Chap. 8.2

Chap. 5.2.2.3.2

302-4 Reduction of energy consumption

Chap. 8.2

GRI 303: WATER AND EFFLUENTS

ESRS

LOCATION

Relating to the standard published in 2018

303-1 Interactions with water as a shared resource

SBM-3 (E3)

E3-1

E3-2

E3-3

5.2.3.1.1

5.2.3.2.1

5.2.3.2.2

5.2.3.3.1

303-3 Water Withdrawal

E3-4

5.2.3.3.2

Chap. 8.2

303-4 Effluents

E3-4

303-5 Water Consumption

E3-4

GRI 304: BIODIVERSITY

ESRS

LOCATION

ANNUAL REPORT 2024 • MANAGEMENT REPORT 336

Relating to the standard published in 2016

304-1 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of

high biodiversity value outside protected

areas

E4-5

Chap. 8.2

Chap. 5.2.4.3.2

304-2 Significant impacts of activities, products, and services on biodiversity

E4-5

Chap. 5.2.4.3.2

304-3 Habitats protected or restored

E4-3

E4-4

Chap. 8.2

5.2.4.2.2

5.2.4.3.1

304-4 Number of IUCN Red List species and national conservation list species with habitats in

areas affected by operations

E4-5

MDR-M

Chap. 5.2.4.3.2

GRI 305: EMISSIONS

ESRS

LOCATION

Relating to the standard published in 2016

305-1 Direct (Scope 1) GHG emissions

E1-6

Chap. 5.2.2.3.3

Chap. 8.2

305-2 Energy indirect (Scope 2) GHG emissions

E1-6

Chap. 5.2.2.3.3

Chap. 8.2

305-3 Other indirect (Scope 3) GHG emissions

E1-6

Chap. 5.2.2.3.3

Chap. 8.2

305-4 GHG emissions intensity

E1-6

Chap. 5.2.2.3.3

Chap. 8.2

305-5 Reduction of GHG emissions

E1-7

Chap. 8.2

305-7 Nitrogen oxides (NOx), sulphur oxides (SOx), and other significant air emissions

E2-4

GRI 306: WASTE

ESRS

LOCATION

Relating to the standard published in 2020

306-1 Waste generation and significant waste-related impacts

SBM-3 (E5)

E5-4

Chap. 5.2.5.1.1

Chap. 5.2.5.3.2

306-2 Management of impacts

E5-2

E5-5

Chap. 5.2.5.2.2

Chap. 5.2.5.3.3

306-3 Waste generated

E5-5

Chap. 5.2.5.3.3

Chap. 8.2

306-4 Waste diverted from disposal

E5-5

Chap. 5.2.5.3.3

Chap. 8.2

306-5 Waste directed to disposal

E5-5

Chap. 5.2.5.3.3

Chap. 8.2

GRI 308: SUPPLIER ENVIRONMENTAL ASSESSMENT

ESRS

LOCATION

Relating to the standard published in 2016

308-1 New Suppliers that were screened using environmental criteria

G1-2

5.4.1.2.2

308-2 Negative environmental impacts in the supply chain and actions taken

SBM-3 (G1)

MDR-A

5.4.1.1.1

5.4.1.2.4

GRI 400: SOCIAL PERFORMANCE

GRI 401: EMPLOYMENT

ESRS

LOCATION

Relating to the standard published in 2016

401-1 New employee hires and employee turnover

S1-6

Chap. 5.3.1.3.2

401-3 Parental leave

S1-15

Chap. 5.3.1.3.9

GRI 403: OCCUPATIONAL HEALTH AND SAFETY

ESRS

LOCATION

Relating to the standard published in 2018

403-1 Occupational health and safety management system

S1-1

Chap. 5.3.1.2.1

403-2 Hazard identification, risk assessment, and incident investigation

S1-3

Chap. 5.3.1.2.3

ANNUAL REPORT 2024 • MANAGEMENT REPORT 337

403-3 Occupational Health Services

S1-4

Chap. 5.3.1.2.4

403-4 Worker participation, consultation, and communication on occupational health and safety

S1-2

Chap. 5.3.1.2.2

403-5 Worker training on occupational health and safety

S1-4

Chap. 5.3.1.2.4

403-6 Promotion of worker health

S1-4

Chap. 5.3.1.2.4

403-7 Prevention and mitigation of occupational health and safety impacts directly linked by

business relationships

S2-4

Chap. 5.3.2.2.4

403-8 Workers covered by an occupational health and safety management system

S1-14

Chap. 5.3.1.3.8

403-9 Work-related injuries

S1-14

Chap. 5.3.1.3.8

Chap. 8.3

403-10 Work-related ill health

S1-14

Chap. 5.3.1.3.8

GRI 404: EDUCATION AND TRAINING

ESRS

LOCATION

Relating to the standard published in 2016

404-1 Average hours of training per year per employee

S1-13

Chap. 5.3.1.3.7

404-2 Programs for upgrading employee skills and transition assistance programs

S1-1

S1-5

Chap. 5.3.1.2.1

Chap. 5.3.1.3.1

404-3 Percentage of employees receiving regular performance and career development reviews

S1-13

Chap. 5.3.1.3.7

GRI 405: DIVERSITY AND EQUAL OPPORTUNITY

ESRS

LOCATION

Relating to the standard published in 2016

405-1 Diversity of governance bodies and employees

GOV-1

S1-6

S1-9

Chap. 5.1.2.1

Chap. 5.3.1.3.2

Chap. 5.3.1.3.5

405-2 Ratio of basic salary and remuneration of women to men

S1-16

Chap. 5.3.1.3.10

GRI 406: DISCRIMINATION

ESRS

LOCATION

Relating to the standard published in 2016

406-1 Incidents of discrimination and corrective actions taken

S1-17

Chap. 5.3.1.3.11

GRI 408: CHILD LABOUR

ESRS

LOCATION

Relating to the standard published in 2016

408-1 Operations and Suppliers at significant risk for incidents of child labour

S1-1

S2-1

Chap. 5.3.1.2.1

Chap. 5.3.2.2.1

GRI 409: FORCED OR COMPULSORY LABOUR

ESRS

LOCATION

Relating to the standard published in 2016

409-1 Operations and Suppliers at significant risk for incidents of forced or compulsory labour

S1-1

S2-1

Chap. 5.3.1.2.1

Chap. 5.3.2.2.1

GRI 413: LOCAL COMMUNITIES

ESRS

LOCATION

Relating to the standard published in 2016

413-1 Operations with local community engagement, impact assessments, and development

programs

S3-2

S3-3

S3-4

Chap. 5.3.3.2.2

Chap. 5.3.3.2.3

Chap. 5.3.3.2.4

GRI 414: SUPPLIER SOCIAL ASSESSMENT

ESRS

LOCATION

Relating to the standard published in 2016

414-1 New Suppliers that were screened using environmental criteria

G1-2

5.4.1.2.2

414-2 Negative environmental impacts in the supply chain and actions taken

SBM-3 (S2)

S2-4

SBM-3 (G1)

5.3.2.1.1

5.3.2.2.4

5.4.1.1.1

ANNUAL REPORT 2024 • MANAGEMENT REPORT 338

MDR-A

5.4.1.2.4

9.3 Progress Report on Meeting Act4nature Portugal

Commitments

INDIVIDUAL COMMITMENT 1 | Finalise the approach to integrating B&ES conservation into corporate strategy, in

line with available scientific knowledge and voluntarily accepted commitments by Dec. 2024.

2024 |

Generic lines of the updated biodiversity conservation strategy approved; final document under review.

INDIVIDUAL COMMITMENT 2 | Carry out the annual species and habitat monitoring plans and work to maintain,

improve the state of conservation and restore B&ES in the forestry holdings managed by the Company, in the following

areas: (i) conservation; (ii) rehabilitation; and (iii) ecological restoration. Regarding ecological restoration, start and/or

maintain actions on at least 110 hectares by 2030; Maintain the remaining conservation status maintenance and

improvement activities (actions on at least 30 ha/year) until 2030; Carry out at least one recovery project for an

endangered species and support another until 2030.

2024 | Monitoring carried out in annual plans and specific projects.

Overall cumulative results of the annual monitoring plans:

In 2024, 19 properties were monitored by experts. In mainland Portugal, across the properties managed by the Company by

the end of 2024, a total of 268 native fauna species and 1,195 native flora species and subspecies have been identified. Of

these, and considering only mainland Portugal, 5 are classified as Critically Endangered, 17 as Endangered, 46 as Vulnerable,

and 30 as Near Threatened, according to the classification of the International Union for Conservation of Nature (IUCN).

Additionally, 51 different habitat types included in the EU Habitats Directive have been identified. This represents a slight

increase in species recorded, resulting from the broader monitoring effort and the presence of more diverse habitat types

across the surveyed areas. Monitoring of breeding birds revealed 5 nesting sites of the Bonelli’s eagle (Aquila fasciata), a

species classified as Vulnerable (VU). Of these, two were occupied, but only one was successful, resulting in two hatchlings,

while two sites were severely affected by wildfires. Notably, two new nesting sites were discovered near company-managed

properties by SPEA. Monitored a nest of the black stork (Ciconia nigra), a species classified as Endangered (EN), which resulted

in the successful rearing of three juveniles.

About 11.8% of the area managed in mainland Portugal is made up of areas of conservation interest, which 4,474 hectares are

classified as protected habitats under the Natura 2000 Network, dividing into 51 different habitat types. Approximately 123

hectares were subject to restoration or rehabilitation in 2024, aiming to maintain or improve the conservation status of natural

and semi-natural habitats, including the continued ecological restoration of the Zambujo area, covering around 110 hectares.

As part of this effort, the Company converted 40 hectares of eucalyptus plantations into holm oak woodland (Quercus ilex). In

total, 40 hectares of eucalyptus were converted into holm oak, and 70 hectares underwent conservation improvement actions

targeting the 9340 habitat type – Quercus ilex and Quercus rotundifolia forests. Additionally, 50 kg of acorns from Quercus

ANNUAL REPORT 2024 • MANAGEMENT REPORT 339

rotundifolia were collected on the Zambujo property for germination in nurseries and later planting on-site. This action is

promoted by The Navigator Company in partnership with RAIZ – Forest and Paper Research Institute, with a total budget of

€225,774.79, financed by the COMPETE 2020 Programme, under the measure “Support for climate transition / Territorial

resilience to risk: Combating desertification through reforestation and actions that promote increased carbon and nutrient

sequestration in the soil” (REACT-EU/FEDER).

Following the positive results observed in 2023 and considering the importance of insects for pollination and the goals of

reversing their decline, the Company expanded the sowing of flowering species for pollinators and birds at the Espirra Estate. A

study conducted in 2023 showed that the sown plot registered a higher number of individuals and nearly double the number of

species compared to the unsown plot, indicating that the sowing of floristic species significantly enhanced local biodiversity.

Continuation of the project “Genetic Improvement and Forest Reproductive Materials – Transform PRR”, which includes a

dedicated activity focused on Biodiversity conservation:

Genetic conservation and ecosystem restoration, with particular emphasis on some of the most threatened tree species in

Portugal, such as the Critically Endangered Quercus canariensis and associated tree species. The recovery of the Monchique oak

(Quercus canariensis) and its habitat is part of the project “Genetic improvement, production and conservation of forest

reproductive materials”, which aims to enhance the resilience of Portuguese forests to the impacts of climate change. The

project is supported by the RRP – Recovery and Resilience Plan and is being implemented between late 2022 and 2025. It is

coordinated by RAIZ – Forest and Paper Research Institute and INIAV – National Institute for Agrarian and Veterinary Research.

Navigator’s forestry division, the Polytechnic Institute of Castelo Branco, and Viveiros Aliança are project partners, with

technical support provided by BIOPOLIS–CIBIO and the Botanical Garden of the University of Porto.

Summary of project results (presented by BIOPOLIS-CIBIO at the 23rd National Ecology Meeting):

Seven oak stands were selected that had previously been identified as containing individuals with morphological characteristics

resembling Quercus canariensis — five in Portugal and two in Spain (Algeciras, Andalusia) — along with two Quercus faginea

(Portuguese oak) stands to serve as reference populations for molecular comparison between the two species. In each

population, samples were collected from 12 to 18 individuals for molecular analysis and leaf morphometric study. Opportunistic

acorn collection was also carried out for seed propagation, along with cuttings taken from individuals with morphological traits

suggesting a high degree of genetic purity, intended for grafting and in vitro micropropagation. Spectral and structural

information was gathered to assess Portuguese oak stands using an unmanned aerial vehicle equipped with a multispectral

imaging sensor and LiDAR. The resulting imagery and point clouds were later compared with ground-based data to evaluate the

conservation status of each stand, including information on floristic diversity, species composition, structural characteristics,

disturbance levels, and microhabitats.

Molecular studies involved whole-genome resequencing (WGS) of 80 individuals across the nine populations, followed by

bioinformatic analyses of population structure. The results revealed a geographic pattern of hybridisation toward the Monchique

nucleus, with peripheral populations in the Mira and Ribeiras Aljezur valleys showing strong levels of introgression with

Portuguese oak (Quercus faginea). Nevertheless, genetically pure individuals were clearly identified in Monchique and in the

Seixe river valley, even when compared to populations from southern Spain (Algeciras). Acorn collection enabled the

germination of approximately 1,558 plants from Quercus canariensis, Quercus faginea, and Quercus lusitanica, originating from

eight distinct provenances. Germination rates varied between 20.8% and 87.5%. These seedlings will support restoration

actions and the establishment of meta-collections in various botanical gardens and arboreta. Additionally, grafting was

successfully carried out on Quercus robur subsp. broteroana rootstocks for potential large-scale application, and the

micropropagation process has already yielded highly promising results.

Continuing its collaboration with FCUL (Faculty of Sciences of the University of Lisbon) and the University of Aveiro on the

WildForests project (http://wildforests.pt/pt/), the Company is providing logistical support for a new FCT-funded project entitled

“ForCe – FORest .”Certification as a tool to preserve vertebrate biodiversity in exotic forestry plantations, with the main

objective of understanding the role of Forest Certification as a mechanism to ensure the functional and conservation value of

ANNUAL REPORT 2024 • MANAGEMENT REPORT 340

Eucalyptus plantations for vertebrate species. The Company is also a partner in the project “Adapting Serras do Porto to

Climate Change – LIFE SERRAS DO PORTO” (LIFE21 CCA/PT/4476), which has forests as its central theme and includes a

comprehensive set of interventions with a high positive impact on landscapes and ecosystems, as well as monitoring,

communication, awareness-raising, and civic engagement activities. Among other actions, the Company aims to strengthen the

alignment of productive forestry activities with conservation and climate change adaptation goals in the region. Restoration and

requalification activities are currently underway to improve the conservation status of natural habitats over approximately 55

hectares (total project area). By February 2025, 6.34 hectares of retanchas (replacing trees that did not survive) of maritime

pine and strawberry tree had been completed, along with 1.22 hectares of chemical stump devitalisation and manual planting of

strawberry trees, totalling 7.11 hectares (12% of the project area). In addition, 16.42 hectares of thinning and chemical stump

devitalisation are being carried out, followed by manual planting of cork oaks and strawberry trees (densification). Felled woody

material is being arranged into palisades, and shrub clearance is being performed in targeted locations. At Ribeira das

Silveirinhos, 0.98 hectares are being manually cleared and invasive acacias are being cut and uprooted, amounting to 17.40

hectares (31% of the project area).

In 2023, natural values were monitored, and, in 2024, water analyses were carried out to assess the ecological status of the

riparian galleries. These actions are complementary to those implemented by other project partners, enabling an intervention

with a positive impact on the landscape and ecosystems. The aim is also to monitor the evolution of the restored plots to

evaluate the positive impact on biodiversity. In addition to the project partners, the Company worked with the support of

Montis-ACN and Floradata to achieve the proposed objectives.

INDIVIDUAL COMMITMENT 3 | By 2026, define a simplified framework aligned with key elements of global

reference frameworks (e.g. Natural Capital Protocol) to systematise the assessment of B&ES impacts and

dependencies, testing the approach in a pilot project.

2024 |

Estimated to begin in 2025, with the alignment of the Biodiversity strategy to the LEAP approach of the Taskforce on

Nature-related Financial Disclosures (TNFD).

INDIVIDUAL COMMITMENT 4 | Ensure that the Company’s wood consumption include no less than 80% certified

wood by 2030 and promote forest management certification in Portugal to help achieve it.

2024 | 72.94% certified wood originated from the national market, and 73.39% considering the total certified wood

received by Navigator.

91.7% of wood suppliers have a certified chain of custody.

INDIVIDUAL COMMITMENT 5 | By 2030, run training programmes with content relating to

B&ES conservation topics and raise awareness of good business practices, for internal and

external Employees.

2024|

Tec4Forest – Training and technical knowledge transfer programme for external stakeholders. In 2024, a total of

470 participants took part in 57 sessions: the training syllabus covered good practices applicable to the main activities of

Forest Producers’ Organisations (FPOs) and certification groups.

In addition, the company supported sessions organised by Biond under the “Melhor Eucalipto” (Better Eucalyptus) and

“Melhor Floresta” (Better Forest) programmes in 2024, aimed at promoting best forest management practices.

• Melhor Eucalipto: 20 sessions | 510 participants

ANNUAL REPORT 2024 • MANAGEMENT REPORT 341

• Melhor Floresta: 51 sessions | 550 participants

The training syllabus on good practices applicable to core forestry activities (plantation establishment, maintenance, and

operations) included guidelines and procedures related to soil and water conservation, preservation of areas of conservation

interest — including buffer zones along watercourses — protection of nests and dens, safeguarding of cultural and

archaeological heritage, protection of flora species of conservation interest, and waste management arising from various

activities. One of the Tec4Forest sessions was entirely dedicated to supporting forestry associations by providing tools to help

identify fauna and flora species with threatened status.

AFLOBEI, in partnership with the Company, carried out an awareness-raising initiative at one of the properties managed by

NVG, entitled “Reconciling the Management of Eucalyptus Areas with Natural Values and High Conservation Value Areas”. The

event highlighted NVG's actions in these areas and provided a platform for discussing various measures and issues related to

forest management with different forest producers.

Preliminary results of the ForCe project – Forest Certification as a tool to preserve vertebrate biodiversity in exotic forestry

plantations – were presented to Company staff, particularly those from Forest Management, Sustainability, Communication and

Brand, and RAIZ.

INDIVIDUAL COMMITMENT 6 | By 2030, promote and/or participate in innovation projects and the development of

nature-based solutions applicable to the management of natural areas, processes or products.

2024|

Ongoing development of research agenda projects under “From Fossil to Forest”, focused on the use of eucalyptus

fibre in the production of rigid moulded cellulose packaging under the “gKRAFT Bioshield” brand.

INDIVIDUAL COMMITMENT 7 | Disclose, on a regular basis, information from multistakeholder initiatives in which

the company takes part in order to promote B&ES conservation, directly or indirectly.

2024 | Ongoing participation in the BCSD Act4nature initiative and the Biodiversity Working Group of BCSD Portugal. Under

the scope of the project Natura Connect – Designing a Resilient and Coherent Trans-European Network for Nature and

People, funded by the European Union, the Company (through its forestry division) was invited to take part in a Think Tank

aimed at “establishing prolific dialogues on the political, socio-economic and technical challenges related to the

implementation of the EU Biodiversity Strategy for 2030 in terrestrial systems in mainland Portugal.” This Think Tank

includes representatives from civil society, businesses, NGOs, and public institutions such as ICNF – Institute for Nature

Conservation and Forests, FlorestGal, DGT – Directorate-General for Territory, APA – Portuguese Environment Agency, with

the support of the Ministry for the Environment and Climate Action.

Outreach content on biodiversity and ecosystem services, including Portuguese forest habitats and their importance for

conservation, was shared via social media and the platforms Biodiversidade.com.pt.

An article on biodiversity was published in the November 2024 edition of the BCSD Pt “é-Sustentável” newsletter:

https://bcsdportugal.org/noticias/a-importancia-de-agir/

INDIVIDUAL COMMITMENT 8 | Publicly report, on an annual basis, the progress made in implementing the

Act4nature Portugal commitments and provide visibility to the Company’s main actions under this initiative.

2025

Progress report available online on The Navigator Company’s website on the 2024

Annual Report .

ANNUAL REPORT 2024 • MANAGEMENT REPORT 342

ANNUAL REPORT 2024 • MANAGEMENT REPORT 343

9.4 Independent Auditor’s Limited Assurance Report

on Sustainability Statement

ANNUAL REPORT 2024 • MANAGEMENT REPORT 344

ANNUAL REPORT 2024 • MANAGEMENT REPORT 345

ANNUAL REPORT 2024 • MANAGEMENT REPORT 346

ANNUAL REPORT 2024 • MANAGEMENT REPORT 347

RELATÓRIO ANUAL 2024 • RELATÓRIO DE GESTÃO 348

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 349

Consolidated Income Statement

For the periods ended 31 December 2024 and 31 December 2023

Amounts in Euro

Note

2024

2023

Revenue

2.1

2,088,276,553

1,953,242,900

Other operating income

2.2

100,793,477

80,315,713

Fair value adjustments of biological assets

3.8

(1,016,252)

(6,907,896)

Costs of goods sold and materials consumed

4.1

(880,548,487)

(848,515,663)

Variation in production

4.1

(3,499,808)

(23,719,799)

External services and supplies

2.3

(500,867,221)

(422,373,519)

Payroll costs

7.1

(203,780,154)

(172,252,203)

Other operating expenses

2.3

(52,595,670)

(58,241,591)

Net provisions

10.1

(32,178)

1,006,041

Depreciation, amortisation and impairment losses in non-financial assets 3.7 (167,860,464) (136,198,800)

Operating income 378,869,796

366,355,183

Financial income and gains

5.10

17,376,371

14,033,284

Financial expenses and losses

5.10

(43,215,938)

(33,353,202)

Financial profit/(loss) (25,839,567) (19,319,918)

Gains/(losses) of associates and joint ventures

Profit/(loss) before income tax

353,030,229

347,035,265

Income tax

6.1

(66,046,016)

(72,086,123)

Net profit/(loss) for the period 286,984,213

274,949,142

Attributable to Navigator's equity holders

286,948,195

274,923,820

Attributable to non-controlling interests

5.6

36,018

25,322

Earnings per share

Basic earnings per share, Euro

5.3

0.403

0.387

Diluted earnings per share, Euro

5.3

0.403

0.387

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 350

Consolidated statement of comprehensive income

For the periods ended 31 December 2024 and 31 December 2023

Amounts in Euro

Note

2024

2023

Net profit/(loss) for the period

before non-controlling interests

286,984,213

274,949,142

Items that may be reclassified to the income statement

Derivative financial instruments - hedging

Changes in fair value

8.2

(1,526,544)

(29,102,154)

Tax on items above

639,231

8,003,092

Changes in the currency translation reserve

8,287,642

(34,683)

Tax on items above

Tax on conventional capital remuneration

(77,000)

Items that cannot be reclassified to profit/(loss)

Remeasurement of post-employment benefits

Remeasurement

7.2.5

563,776

3,738,766

Tax on items above

7.2.5

17,693

(115,461)

Comprehensive income of associates and joint ventures

(1,511,704)

Total other comprehensive income net of taxes

7,981,798

(19,099,144)

Total comprehensive income

294,966,011

255,849,998

Attributable to:

Navigator's equity holders

294,932,682

255,820,957

Non-controlling interests

33,329

29,041

294,966,011

255,849,998

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 351

Consolidated statement of financial position

As at 31 December 2024 and 2023

Amounts in Euro

Note

2024

2023

ASSETS

Non-current assets

Goodwill

3.1

422,627,337

381,496,008

Intangible assets

3.2

119,600,687

46,198,240

Property, plant and equipment

3.3

1,415,945,085

1,233,223,791

Right-of-use assets

3.6

98,651,166

65,044,454

Biological assets

3.8

115,250,198

115,591,979

Investment properties

3.4

360,170

463,404

Other financial assets

7.2

1,347,318

Non-current receivables

4.2

13,142,937

44,399,506

Deferred tax assets

6.2

59,110,851

23,653,501

2,246,035,749

1,910,070,883

Current assets

Inventories

4.1

303,198,367

286,490,362

Current receivables

4.2

496,698,621

424,740,973

Income tax

6.1

20,621,461

18,385,534

Cash and cash equivalents

5.9

286,628,866

169,464,967

1,107,147,315

899,081,836

Total assets

3,353,183,064

2,809,152,719

EQUITY AND LIABILITIES

Capital and Reserves

Share capital

5.2

500,000,000

Currency translation reserve

5.5

13,829,407

5,309,023

Fair value reserves

5.5

12,011,454

12,898,767

Legal reserve

5.5

100,000,000

Other reserves

5.5

(5,960,836)

3,481,014

Retained earnings

5.5

548,900,068

418,633,191

Net profit/(loss) for the period

286,948,195

274,923,820

Prepaid dividends

5.4

(99,999,451)

Equity attributable to Navigator's equity holders 1,355,728,837

1,315,245,815

Non-controlling interests

5.6

360,347

327,018

Total Equity

1,356,089,184

1,315,572,833

Non-current liabilities

Interest-bearing liabilities

5.7

726,229,071

560,085,341

Lease liabilities

5.8

98,627,669

62,848,761

Deferred tax liabilities

6.2

135,938,603

95,856,013

Provisions

10.1

28,371,069

27,837,286

Non-current payables

4.3

117,161,513

114,670,790

1,106,327,925

861,298,191

Current liabilities

Interest-bearing liabilities

5.7

177,748,681

99,259,122

Lease liabilities

5.8

13,109,231

7,148,060

Current payables

4.3

658,569,674

503,046,782

Income tax

6.1

41,338,369

22,827,731

890,765,955

632,281,695

Total liabilities

1,997,093,880

1,493,579,886

Total Equity and Liabilities

3,353,183,064

2,809,152,719

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 352

Statement of Changes in Equity

For the periods ended 31 December 2024 and 31 December 2023

Amounts in Euro

Note Share capital

Currency

translation

reserve

Fair value

reserves

Legal

reserves

Other

reserves

Retained

earnings

Net

profit/(loss)

for the period

Prepaid

dividends

Total

Non-

controlling

interests

Total

Equity as at 1 January 2024 500,000,000

5,309,023

12,898,767

100,000,000

3,481,014

418,633,191

274,923,820

1,315,245,815

327,018

1,315,572,833

Net profit/(loss) for the period

286,948,195

36,018

286,984,213

Other comprehensive income (net of

taxes)

8,287,642

(887,313) -

584,158

7,984,487

(2,689) 7,981,798

Total comprehensive income for the

period

8,287,642

(887,313) -

584,158

286,948,195

294,932,682

33,329

294,966,011

Appropriation of 2023 net profit/(loss) for

the period:

- Dividends paid 5.4 -

(149,995,621) -

(149,995,621)

- Application of prior period's net

profit/(loss)

288,923,820

(274,923,820) -

14,000,000

- Bonus to employees -

(14,000,000) -

(14,000,000)

Prepaid dividends 5.4 -

(99,999,451) (99,999,451) -

(99,999,451)

Acquisition/disposal of non-controlling

interests

5.5 -

(9,441,850) 4,987,262

(4,454,588) -

(4,454,588)

Other movements -

232,742

(232,742) -

Total transactions with shareholders -

232,742

(9,441,850) 129,682,719

(274,923,820) (99,999,451) (254,449,660) -

(254,449,660)

Equity as at 31 December 2024 500,000,000

13,829,407

12,011,454

100,000,000

(5,960,836) 548,900,068

286,948,195

(99,999,451) 1,355,728,837

360,347

1,356,089,184

Amounts in Euro

Note

Share capital

Currency

translation

reserve

Fair value

reserves

Legal

reserves

Other

reserves

Retained

earnings

Net

profit/(loss)

for the period

Prepaid

dividends

Total

Non-

controlling

interests

Total

Equity as at 1 January 2023 500,000,000

5,343,706

33,997,828

100,000,000

3,481,014

224,049,919

392,537,070

1,259,409,537

297,977

1,259,707,514

Net profit/(loss) for the period -

274,923,820

25,322

274,949,142

Other comprehensive income (net of

taxes)

(34,683) (21,099,061) -

2,030,881

(19,102,863) 3,719

(19,099,144)

Total comprehensive income for the

period

(34,683) (21,099,061) -

2,030,881

274,923,820

255,820,957

29,041

255,849,998

Appropriation of 2022 net profit/(loss) for

the period:

- Dividends paid

5.4

(199,984,679)

- Application of prior period's net

profit/(loss)

426,537,070

(392,537,070) -

34,000,000

- Bonus to employees -

(34,000,000) -

(34,000,000)

Total transactions with shareholders -

192,552,391

(392,537,070) -

(199,984,679) -

(199,984,679)

Equity as at 31 December 2023

500,000,000

5,309,023

12,898,767

100,000,000

3,481,014

418,633,191

274,923,820

1,315,245,815

327,018

1,315,572,833

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 353

Consolidated Statement of Cash Flows

For the periods ended 31 December 2024 and 31 December 2023

Amounts in Euro

Notes

2024

2023

OPERATING ACTIVITIES

Receipts from customers

2,155,210,508

2,132,485,021

Payments to suppliers

(1,549,556,848)

(1,539,344,186)

Payments to employees

(162,689,686)

(145,375,584)

Cash flow from operations

442,963,974

447,765,251

Income tax received/ (paid)

6.1.2

(61,094,930)

(162,921,486)

Other receipts / (payments) relating to operating activities

29,625,402

84,296,005

Cash flows from operating activities (1) 411,494,446

369,139,770

INVESTING ACTIVITIES

Inflows:

Property, plant and equipment

371,904

658,527

371,904

658,527

Outflows:

Property, plant and equipment (223,709,648) (201,067,497)

Intangible assets

(391,306)

(522,645)

Investments in subsidiaries

1.2

(150,779,060)

(55,210,602)

(374,880,014)

(256,800,744)

Cash flows from investing activities (2)

(374,508,110)

(256,142,217)

FINANCING ACTIVITIES

Inflows:

Interest-bearing liabilities

5.7

352,162,243

15,000,000

Government grants

3.5

43,952,298

27,529,156

396,114,541

42,529,156

Outflows:

Interest-bearing liabilities

5.7

(124,542,159)

(107,276,122)

Amortisation of lease agreements

3.6

(15,661,601)

(10,694,178)

Interest and similar expense

(18,934,665)

(4,861,601)

Distribution of dividends

5.4

(149,995,621)

(199,984,679)

Repayable grants

5.7

(7,219,439)

(7,219,438)

(316,353,485)

(330,036,018)

Cash flows from financing activities (3)

79,761,056

(287,506,862)

CHANGES IN CASH AND CASH EQUIVALENTS (1)+(2)+(3)

116,747,392

(174,509,309)

Effect of exchange rate differences

416,507

890,488

CASH AND CASH EQUIVALENTS AT THE BEGINNING OF THE PERIOD

5.9

169,464,967

343,083,788

CASH AND CASH EQUIVALENTS AT THE END OF THE PERIOD

5.9

286,628,866

169,464,967

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 354

Notes to the Consolidated Financial Statements

As at 31 December 2024

1. Introduction 356

1.1. The Group 356

1.2. Acquisition of Accrol Group's United Kingdom consumer tissue business 358

1.3. Subsequent events 360

1.4. Basis for preparation 360

1.5. New IFRS standards adopted and to be adopted 365

1.6. Significant accounting estimates and judgements 369

2. Operational performance 370

2.1. Revenue and segment reporting 370

2.2. Other operating income 377

2.3. Other operating expenses 378

3. Investments 380

3.1. Goodwill 380

3.2. Intangible assets 385

3.3. Property, plant and equipment 388

3.4. Investment properties 391

3.5. Government grants 392

3.6. Right-of-use assets 395

3.7. Depreciation, amortisation and impairment losses 397

3.8. Biological assets 398

4. Working capital 401

4.1. Inventories 401

4.2. Receivables 404

4.3. Payables 408

5. Capital structure 410

5.1. Capital management 410

5.2. Share Capital and treasury shares 411

5.3. Earnings per share 412

5.4. Dividends and reserves allocated 412

5.5. Reserves and retained earnings 413

5.6. Non-controlling interests 415

5.7. Interest-bearing liabilities 416

5.8. Lease liabilities 421

5.9. Cash and cash equivalents 422

5.10. Net financial results 423

6. Income tax 424

6.1. Income tax for the period 424

6.2. Deferred taxes 429

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 355

7. Payroll 431

7.1. Payroll costs 431

7.2. Employee benefits 432

7.3. Remuneration of corporate bodies 438

8. Financial instruments 438

8.1. Financial risk management 438

8.2. Derivative financial instruments 448

8.3. Financial assets and liabilities 452

9. Operational risk management 454

9.1. Specific risks inherent to the sectors of activity in which the Navigator Group operates455

10. Provisions, commitments and contingencies 471

10.1. Provisions 471

10.2. Commitments 472

10.3. Contingent assets and liabilities 473

11. Group structure 475

11.1. Companies included in the consolidation perimeter 475

11.2. Changes in the consolidation perimeter 476

11.3. Transactions with related parties 476

12. Explanation added for translation 477

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 356

1. Introduction

The following symbols are used in the presentation of the Notes to the financial statements:

Accounting policies

This symbol indicates the disclosure of accounting policies specifically applicable to the items

in the respective Note.

Significant Estimates and Judgements

This symbol indicates the disclosure of the

estimates and/or judgements made regarding the

items in the respective Note. Significant estimates and judgements are indicated in Note 1.6.

References

This symbol indicates a reference to another Note or another section of the Financial

Statements where more information about the items disclosed is presented.

1.1. The Group

The Navigator Group (Group) is comprised by The Navigator Company, S.A., whose name remained unchanged during the period,

(until 2015 designated as Portucel, S.A.) and its subsidiaries.

The Navigator Group was created in 1953, when a group of technicians from “Companhia Portuguesa de Celulose de Cacia” made

this company the first in the world to produce bleached eucalyptus sulphate pulp.

In 1976 Portucel EP was created as a result of the nationalisation of all of Portugal’s cellulose industry. As such, Portucel –

Empresa de Celulose e Papel de Portugal, E.P. resulted from the merger with CPC – Companhia de Celulose, S.A.R.L. (Cacia),

Socel – Sociedade Industrial de Celulose, S.A.R.L. (Setúbal), Celtejo – Celulose do Tejo, S.A.R.L. (Vila Velha de Ródão), Celnorte

– Celulose do Norte, S.A.R.L. (Viana do Castelo) and Celuloses do Guadiana, S.A.R.L. (Mourão) incorporated Portucel - Empresa

de Celulose e Papel de Portugal, E.P., converted into a Public Limited Company of mainly public capital by Decree-Law 405/90, of

21 December.

Years after, as a result of the restructuring of Portucel – Empresa de Celulose e Papel de Portugal, S.A., which was renamed

Portucel, SGPS, S.A., towards to its privatisation, Portucel S.A. was created, on 31 May 1993, through Decree-law 39/93, of 13

February, with the former assets of the two main companies, based in Aveiro and Setúbal.

In 1995, the Company was privatised, and became a publicly traded company.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 357

Aiming to restructure the paper industry in Portugal, Portucel acquired Papéis Inapa, S.A. (Setúbal), in 2000, and Soporcel –

Sociedade Portuguesa de Papel, S.A. (Figueira da Foz), in 2001. Those key strategic decisions resulted in the Portucel Soporcel

Group (currently Navigator Group), which is currently the largest European and one of the world’s largest producers of bleached

eucalyptus pulp and the largest European producer of uncoated wood-free paper (UWF), with a capacity of 1.6 and 1.6 millions of

tons, respectively, and it sells approximately 389 thousand tons of pulp (462 thousand tons in 2023), annually, integrating the

remainder in the production of UWF paper and Tissue paper.

In June 2004, the Portuguese State sold 30% of Portucel's equity, which was acquired by Semapa Group. In September of the

same year, Semapa launched a public acquisition offer tending to assure the Group’s control, which was accomplished by

guaranteeing a 67.1% stake of Portucel’s equity.

In November 2006, the Portuguese State concluded the third and final stage of the sale of Portucel, S.A., and Párpublica, SGPS,

S.A. (formerly Portucel, SGPS, S.A.) sold the remaining 25.72% it still held, thus increasing the free-float.

From 2009 to June 2015, more than 75% of the company’s share capital was held directly and indirectly by Semapa – Sociedade

de Investimento e Gestão SGPS, S.A.. (excluding treasury shares) having the percentage of voting rights been reduced to around

70% following the conclusion of the offer for the acquisition, in the form of an exchange offer, of the ordinary shares of Semapa in

July 2015. The voting rights currently amount to 70.03%.

In February 2015, the Group started its activity in the Tissue segment with the acquisition of AMS-BR Star Paper, S.A. (currently

denominated Navigator Tissue Ródão, S.A.), a Company that holds and explores a tissue paper mill, located in Vila Velha de

Ródão. A new industrial facility was built in Aveiro, in August 2018, being operated by Navigator Tissue Aveiro, S.A., which is

currently the largest Portuguese producer and the third in the Iberian Peninsula, with a production and transformation capacity of

130 thousand tons and 120 thousand tons, respectively.

On 31 March 2023 the acquisition of the Gomà-Camps Group's consumer Tissue business in Spain was concluded, with a view to

strengthen the Group's presence in this business segment. The integration of this new mill has elevated Navigator to the position

of second largest Iberian tissue producer, with a production capacity of 165 thousand tons and converting capacity of 180

thousand tons.

In May 2024, The Navigator Company acquired all the shares representing the share capital of Accrol Group Holdings plc

(“Accrol”), a leader in the tissue paper converting segment in the United Kingdom, producing private label toilet rolls, kitchen rolls

and facial tissues for most of the main UK retailers, bringing total converting capacity to 311,000 tons.

The Group’s main business is the production and sale of writing and printing thin paper (UWF) and domestic consumption paper

(Tissue), and it is present in the entire value-added chain, from research and development of forestry and agricultural production

to the purchase and sale of wood and the production and sale of bleached eucalyptus kraft pulp – BEKP – and electric and thermal

energy, as well as its commercialisation.

The Navigator Company, S.A. The Navigator Company, S.A. (hereafter referred to as The Navigator Company or Company) is a

publicly traded company, listed in Euronext Lisbon, with its share capital represented by nominal shares.

Company: The Navigator Company, S.A.

Head Office: Mitrena – Apartado 55 | 2901-861 Setúbal | Portugal

Legal Form: Public Limited Company

Share Capital: €500,000,000

TIN: 503 025 798

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 358

Shares Issued: 711,183,069

A more detailed description of the activity in each business line of the Group is disclosed in Note 2.1 - Revenue and

segment reporting.

Navigator is included in the consolidation perimeter of Semapa – Sociedade de Investimento e Gestão, SGPS, S.A.,

the Parent Company, and Sodim - SGPS, S.A., the final controlling entity.

In turn, Filipa Mendes de Almeida de Queiroz Pereira, Mafalda Mendes de Almeida de Queiroz Pereira and Lua Mónica

Mendes de Almeida de Queiroz Pereira hold joint control of Sodim - SGPS, S.A. (Sodim) through the combination of

a shareholders' agreement. (Sodim) with their respective direct and indirect shareholdings in the share capital of this

company, joint control of Sodim, Semapa and Navigator is attributable to each of them and to Sodim, under the

terms of Article 20 of the Portuguese Securities Code, 83.221% of the non-suspended voting rights relating to

shares representing the share capital of Semapa and also to each of them, Sodim and Semapa, 70.03% of the non-

suspended voting rights relating to shares representing the share capital of Navigator.

1.2. Acquisition of Accrol Group's United Kingdom consumer tissue

business

On 24 May 2024, the Navigator Group concluded a public takeover bid, in the form of a “Recommended Firm Cash Offer”, for the

entire share capital of Accrol Group Holdings Plc, a company based in Blackburn, England, which holds 9 subsidiaries, 5 of which

operational.

As part of its diversification and growth strategy, the acquisition of the Accrol Group, a leading player in the UK tissue market (4

in the ranking), provided additional capacity to the tissue business segment, with a production and converting capacity of 131

thousand tons based on 5 sites: Blackburn (rolls and facials); Leicester (rolls); Leyland (rolls); Flint (wet wipes) and Bridgewater

(wet wipes).

Following the entry into the British market through the acquisition of the main independent Group in the tissue paper processing

sector, whose competitive advantages and values are aligned with those of the Navigator Group, sales volume and EBITDA

benefited from the integration of Accrol on 1 May 2024.

With this acquisition, the Navigator Group expects a number of synergies in the Tissue segment, as well as an increase in its

market share by accessing the Accrol Group's customer portfolio, namely in markets where it intends to strengthen its presence,

as well as a reduction in costs through economies of scale.

In the eight months to December 31, 2024, the Accrol Group contributed Euro 142,690,517 to sales, Euro 7,991,873 to EBITDA

and Euro 3,000,680 to the Group's net profit/(loss). If the acquisition had occurred on 1 January 2024, management estimates

that consolidated sales would have amounted to Euro 2,161,240,841, EBITDA Euro 551,602,627, and a net profit/(loss) for the

period of Euro 280,703,147. When determining these amounts, the Board assumed that any provisionally determined fair value

adjustments arising on the acquisition date would be the same if the acquisition date was 1 January 2024.

Transferred consideration

As part of the acquisition of Accrol Group Holdings Ltd, the consideration transferred amounted to Euro 153,765,152 (GBP

130,823,390) and was paid entirely in cash and cash equivalents, with no contingent consideration associated with this

acquisition. At the purchase date, the Group's cash and cash equivalents amounted to Euro 2,986,092, meaning that the net effort

amounted to Euro 150,779,060.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 359

Identification of assets and liabilities acquired and goodwill

As at this date, the Group concluded the necessary procedures to recognise and measure the identifiable assets acquired, the

liabilities assumed and consequently the calculation of the goodwill, in accordance with IFRS 3. This valuation was carried out by

specialized and independent external valuers and resulted in the recognition of the fair value of the customer portfolio, the

acquired brands and an increase in property, plant and equipment, as well as the respective deferred tax liabilities. The goodwill

arising from this transaction is not expected to be tax deductible.

The valuation techniques used to determine the fair value of the assets acquired were as follows:

The multi-period excess earnings method (MPEEM) was used to determine the fair value of the customer portfolio, Customer portfolio considering the present value of the expected net cash flows of the portfolio and the excess earnings that the customer portfolio will contribute to the Group in the coming years. The useful life assigned to the customer portfolio was 18 years. Four brands with the highest intrinsic value were identified and valued within the scope of this purchase: Elegance, Magum, Softy and Litle Heroes according to the relief from royalty (RfR) method. According to this method, the fair value of the Brands brands is determined on the basis of the discounted value of the royalties that the Group would have to pay if it did not own them. The fair value of the land was determined using the Market Approach, by analysing real transactions or offers for assets which are economically comparable and were available on the valuation date. Property, plant and The fair value of the industrial property, plant and equipment acquired was determined in accordance with the replacement equipment cost method, which consists of identifying the replacement value of the assets acquired adjusted for depreciation, in accordance with the useful life of the assets on the date of purchase. According to the study, the basic assumption was a useful life of 25 years.

The net assets acquired, the fair value attributed and the goodwill calculated at the date of acquisition are summarised as follows:

Value Navigator Navigator allocation to Holding Group Holding Tissue net assets Tissue Amounts in Euro UK, Ltd acquired Adjusted Non-current assets - Other intangible assets 4,216,879 74,045,509 78,262,388 Property, plant and equipment 69,391,552 25,734,059 95,125,611 Right-of-use assets 31,878,471 - 31,878,471 Deferred tax assets 14,271,453 - 14,271,453 Other non-current assets 2,758,801 - 2,758,801 Current assets Inventories 24,383,078 - 24,383,078 Current receivables 31,379,589 - 31,379,589 Cash and cash equivalents 2,986,092 - 2,986,092 Non-current liabilities Interest-bearing liabilities (2,093,024) (2,093,024) Lease liabilities (34,297,272) - (34,297,272) Provisions (293,841) - (293,841) Deferred tax liabilities (8,865,765) (24,944,891) (33,810,656) Current liabilities Interest-bearing liabilities (22,421,695) - (22,421,695) Lease liabilities (5,789,939) - (5,789,939) Current payables (68,590,054) - (68,590,054) Income tax (69,975) - (69,975) Total identifiable assets and liabilities 38,844,350 74,834,677 113,679,027 Initial Goodwill 114,920,802 (74,834,677) 40,086,125 Total purchase price 153,765,152 - 153,765,152 Cash and cash equivalents (2,986,092) - (2,986,092) Net effect on cash and cash equivalents 150,779,060 - 150,779,060

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 360

Acquisition-related costs

The Group incurred costs related to this acquisition amounting to Euro 3,499,552, related to legal fees incurred in the Public

Takeover Bid process and other due diligence costs. These costs are recognised as external services and supplies in the

Consolidated income statement and Consolidated statement of comprehensive income.

Accounting policies

Business combinations

Under IFRS 3 (Business Combinations), in a business combination, the acquirer must recognise and measure the assets acquired

and liabilities assumed at fair value on the acquisition date in the consolidated financial statements. The difference between the

acquisition price and the fair value of the assets and liabilities acquired gives rise to the recognition of goodwill or a gain resulting

from a bargain purchase.

The fair value of the assets acquired and liabilities assumed is determined internally or through independent external valuers,

using the discounted cash flow method, replacement cost or other techniques for determining fair value, which are based on the

use of assumptions including macroeconomic indicators such as inflation rates, interest rates, exchange rates, discount rates,

energy sales and purchase prices, the cost of raw materials, production estimates and business forecasts. Consequently, the

determination of fair values and goodwill or gains resulting from low-price purchases is subject to various assumptions and

judgements, so changes could result in different impacts on profit/(loss).

1.3. Subsequent events

There were no events that resulted in additional adjustments or disclosures in the Group's consolidated financial statements in the

period ended 31 December 2024.

1.4. Basis for preparation

1.4.1. Authorisation to issue financial statements

These consolidated financial statements were approved by the Board of Directors on 27 March 2025. However, they are still

subject to approval by the General Shareholders Meeting, in accordance with the Portuguese commercial legislation.

The Group’s senior management, which are the members of the Board of Directors who sign this report, declare that, to the best

of their knowledge, the information contained herein was prepared in conformity with the applicable accounting standards,

providing a true and fair view of the assets and liabilities, the financial position and results of the companies included in the

Group’s consolidation scope.

1.4.2. Accounting principles

The consolidated financial statements for the period ended 31 December 2024 were prepared in accordance with the International

Financial Reporting Standards (IFRS), effective 1 January 2024 and as adopted by the European Union.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 361

1.4.3. Scope of consolidation

1.4.3.1. Subsidiaries

Subsidiaries are all entities over which the Group has control, which occurs when the Group is exposed or entitled to the variable

returns resulting from its involvement with the entities and has the capacity to affect that return through the exercise of power

over the entities, regardless of the percentage they hold over equity.

The existence and the effect of potential voting rights which are currently exercisable, or convertible are considered when the

Group assesses whether it has control over another entity.

Subsidiaries are consolidated using the full consolidation method with effect from the date on which control is transferred to the

Group while they are excluded as from the date control ceases.

These companies’ equity and net profit/(loss) corresponding to the third-party investment in such companies are presented under

non-controlling interests in the consolidated statement of financial position (in a separate component of equity) and in the

Consolidated income statement. The companies included in the consolidated financial statements are detailed in Note 11.

The purchase method is used in recording the acquisition of subsidiaries. The cost of an acquisition is measured by the fair value

of the assets transferred, the equity instruments issued, and liabilities incurred or assumed on acquisition date, and the best

estimate of any agreed contingent payment.

The identifiable assets and liabilities acquired, and contingent liabilities assumed in a business combination are initially measured

at fair value on the date of acquisition, irrespective of the existence of non-controlling interests. The excess of the acquisition cost

over the fair value of the Group’s share of the identifiable assets and liabilities acquired is recorded as goodwill, as described in

Note 3.1.

If the acquisition cost is less than the fair value of the net assets of the acquired subsidiary (negative goodwill), the difference is

recognised directly in the Income Statement in the period it takes place.

Transaction costs directly attributable to the acquisition are immediately expensed.

Intercompany transactions, balances, unrealised gains on transactions and dividends distributed between group companies are

eliminated. Unrealised losses are also eliminated, except where the transaction displays evidence of impairment of a transferred

asset.

When, at the date of the acquisition of control, The Navigator Company already holds a previously acquired interest in the

subsidiary, its fair value is considered in determining the goodwill or negative goodwill.

On a step acquisition process resulting in the acquisition of control, the revaluation of any participation previously held is

recognised against the income statement when Goodwill is calculated.

When subsequent transactions of disposal or acquisition of shares with non-controlling interests with no impact in control take

place, no gain, loss or goodwill is determined, and the differences between the transaction cost and the book value of the share

acquired are recognised in equity.

Losses generated in each period by subsidiaries with non-controlling interests are allocated, in the percentage held, to non-

controlling interests, regardless of whether they become negative.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 362

In the case of disposals of interests, resulting in a loss of control over a subsidiary, any remaining interest is revalued to the

market value at the date of sale, and the gain or loss resulting from such revaluation, is recorded against profit/(loss), as well as

the gain or loss resulting from such disposal.

The subsidiaries’ accounting policies are adjusted, whenever necessary, so as to ensure that they are applied consistently by all

the Group's companies.

1.4.3.2 Associates

Associates are all the entities in which the Group exercises significant influence but does not have control, which is generally the

case with investments representing between 20% and 50% of the voting rights. Investments in associates are accounted under

the equity method.

In accordance with the equity method, financial investments are recorded at their acquisition cost, adjusted by the amount

corresponding to the Group’s share of changes in the associates’ Shareholders’ equity (including net income/loss) with a

corresponding gain or loss recognised for the period on earnings or on changes in capital, and by dividends received.

Differences between the acquisition cost and the fair value of the assets and liabilities attributable to the associate on the

acquisition date are, if positive, recognised as Goodwill and recorded as investments in associated. If negative, goodwill is

recorded as profit/(loss) for the period under the caption “Group share of (loss)/gains of associates and joint ventures”.

Transaction costs directly attributable to the acquisition are immediately expensed.

In the event that impairment loss indicators arise on investments in associates, an evaluation of the potential impairment is made,

and if deemed necessary, a loss is recognised in the consolidated income statement.

When the Group’s share of losses in associate companies equals or exceeds its investment in that associate, the Group ceases the

recognition of additional losses, unless it has incurred in liabilities or has made payments on behalf of that associate.

Unrealised gains on transactions with associates are eliminated to the extent of the Navigator Group’s investment in the

associates. Unrealised losses are also eliminated, except where the transaction displays evidence of impairment of a transferred

asset.

The associates’ accounting policies used in the preparation of the individual financial statements are adjusted, whenever

necessary, so as to ensure consistency with the policies adopted by the Group.

1.4.4. Presentation currency and foreign currency transactions

i. Functional and reporting currency

The items included in the Financial Statements of each one of the Group’s entities are measured using the currency of the

economic environment in which the entity operates (functional currency).

These consolidated financial statements are presented in Euro, which is the Group’s functional and reporting currency.

ii. Balances and Transactions expressed in foreign currencies

All the Group’s assets and liabilities denominated in currencies other than the reporting currency have been translated to Euro

using the exchange rates prevailing at the consolidated statement of financial position date (Note 8.1.1).

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 363

Currency adjustments, favourable and unfavourable, arising from differences between the exchange rates prevailing at the date of

the transaction and those at the date of collection, payment, or statement of financial position, are recorded as income and/or

expenses in the Consolidated income statement for the period.

iii. Group companies

The profit/(loss) and the financial position of the Group’s entities which have a different functional currency from the Group’s

reporting currency are translated into the reporting currency as follows:

i. The assets and liabilities of each Statement of financial position are translated at the exchange rates prevailing at the date of

the consolidated statement of financial position;

ii. Equity balances are translated at the historical exchange rate;

iii. The income and expenses disclosed in the Income Statement are converted at the exchange rate prevailing at the dates of

the transactions. When this is not possible or when benefits do not arise from the use of this procedure, income and

expenses are translated at the average exchange rate of the period.

The exchange differences resulting from the topics i) and iii) are recognised in the Consolidated comprehensive income under the

equity caption “Currency translation reserves”, being transferred to Financial profit/(loss) when the disposal of the investments

occur.

Long-term loans granted to subsidiaries in currencies other than the Group's functional currency, which are neither planned nor

likely to be settled in the foreseeable future, are treated as a net extension of the investment in the foreign subsidiary. On this

basis, exchange rate differences arising on these loans, which have not been eliminated on consolidation, are recognised in

Comprehensive income under Currency translation reserves, being transferred to profit/(loss) for the period when the loans are

settled, to the extent that such settlement represents an absolute reduction in the subsidiary's interest and exposure.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 364

iv. Exchange rates used

Appreciation / 31-12-2024 31-12-2023 (Depreciation) GBP (Sterling pound) Average exchange rate for the period 0.8466 0.8698 2.67%) Closing exchange rate for the period 0.8292 0.8691 4.59%) USD (American dollar) Average exchange rate for the period 1.0824 1.0813 -0.10%) Closing exchange rate for the period 1.0389 1.1050 5.98%) PLN (Polish zloti) Average exchange rate for the period 4.3058 4.5420 5.20%) Closing exchange rate for the period 4.2750 4.3395 1.49%) SEK (Swedish krona) Average exchange rate for the period 11.4325 11.4788 0.40%) Closing exchange rate for the period 11.4590 11.0960 -3.27%) CZK (Czech koruna) Average exchange rate for the period 25.1198 24.0043 -4.65%) Closing exchange rate for the period 25.1850 24.7240 -1.86%) CHF (Swiss franc) Average exchange rate for the period 0.9526 0.9718 1.97%) Closing exchange rate for the period 0.9412 0.9260 -1.64%) DKK (Danish krone) Average exchange rate for the period 7.4589 7.4509 -0.11%) Closing exchange rate for the period 7.4578 7.4529 -0.07%) HUF (Hungarian forint) Average exchange rate for the period 395.3039 381.8527 -3.52%) Closing exchange rate for the period 411.3500 382.8000 -7.46%) AUD (Australian dollar) Average exchange rate for the period 1.6397 1.6288 -0.67%) Closing exchange rate for the period 1.6772 1.6263 -3.13%) MZM (Mozambican metical) Average exchange rate for the period 69.1732 69.1060 -0.10%) Closing exchange rate for the period 66.7900 70.6500 5.46%) MAD (Moroccan dirham) Average exchange rate for the period 10.7549 10.9552 1.83%) Closing exchange rate for the period 10.5190 10.9445 3.89%) NOK (Norway kroner) Average exchange rate for the period 11.6290 11.4248 -1.79%) Closing exchange rate for the period 11.7950 11.2405 -4.93%) MXN (Mexican peso) Average exchange rate for the period 19.8314 19.1830 -3.38%) Closing exchange rate for the period 21.5504 18.7231 -15.10%) AED (Dirham) Average exchange rate for the period 3.9751 3.9710 -0.10%) Closing exchange rate for the period 3.8154 4.0581 5.98%) CAD (Canadian dollar) Average exchange rate for the period 1.4821 1.4595 -1.55%) Closing exchange rate for the period 1.4948 1.4642 -2.09%) ZAR (South African rand) Average exchange rate for the period 19.8297 19.9551 0.63%) Closing exchange rate for the period 19.6188 20.3477 3.58%) BRL (Brazilian real) Average exchange rate for the period 5.8283 5.4010 -7.91%) Closing exchange rate for the period 6.4253 5.3618 -19.83%) EGP (Egyptian pound) Average exchange rate for the period 49.1213 33.1117 -48.35%) Closing exchange rate for the period 53.0349 34.2710 -54.75%) TRY (Turkish lira) Average exchange rate for the period 35.5734 25.7597 -38.10%) Closing exchange rate for the period 36.7372 32.6531 -12.51%)

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 365

1.4.5.Basis for measurement

The accompanying consolidated financial statements have been prepared on the going concern basis from the accounting books

and records of the companies included in the consolidation (Note 11.1), and under the historical cost convention, except for

biological assets (Note 3.8), and for financial instruments measured at fair value through profit/(loss) or at fair value through

other comprehensive income (Note 8.3), in which derivative financial instruments are included (Note 8.2). The liability related to

responsibilities for defined benefits is recognised at its present value deducted from the respective asset.

1.4.6. Comparability

These financial statements are comparable in all material respects with those of the previous year.

1.5. New IFRS standards adopted and to be adopted

1.5.1. Other standards, amendments and interpretations adopted or to be adopted

Standards, amendments and interpretations adopted in 2024

Date of Amendment applicationStandards and amendments endorsed by the European Union The IASB issued on 23 January 2020 an amendment to IAS 1 Presentation of Financial Statements to clarify how to classify debt and other liabilities as current and non-current. The amendments clarify an IAS 1 criteria for classifying a liability as non-current: the requirement for an entity to have the right to defer the liability’s settlement at least 12 months after the reporting period. Clarification requirements for The amendments aim to: classifying liabilities as current a) specify that an entity's right to defer settlement must exist at the end of the reporting period and 01 January or non-current (amendments to must be substantive; 2024 IAS 1 – Presentation of Financial b) clarify that the ratios that the company must fulfil after the balance sheet date (i.e. future ratios) do Statements) not affect the classification of a liability on the balance sheet date. However, when non-current liabilities are subject to future ratios, companies must disclose information that allows users to understand the risk that these liabilities may be repaid within 12 months of the balance sheet date; and c) clarify the requirements to classify the liabilities that an entity will settle, or may settle, by issuing its own equity instruments. (ex: convertible debt). The amendment had no significant impact on the Navigator Group.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 366

Date of Amendment application Standards and amendments endorsed by the European Union The IASB issued amendments to IFRS 16 - Leases in September 2022 that introduce a new accounting model for variable payments in a sale and leaseback transaction. The amendments confirm that: a) On initial recognition, the seller-lessee includes variable lease payments in measuring a lease liability arising from a sale and leaseback transaction. b) After initial recognition, the seller-lessee applies the general requirements for subsequent accounting for the lease liability so that it does not recognise any gain or loss relating to the right of Lease liabilities in sale and use it retains. leaseback transactions 01 January A seller-lessee may use different approaches to comply with the new requirements for subsequent (amendments to IFRS 16 - 2024 measurement. Leases) In accordance with IAS 8 - Accounting Policies, Changes in Accounting Estimates and Errors, a seller-lessee shall apply the amendments retrospectively to sale and leaseback transactions entered into on or after the date of initial application of IFRS 16. This means that it will have to identify and reassess sale and leaseback transactions entered into since the implementation of IFRS 16 in 2019, and potentially restate those that include variable lease payments. The amendment had no significant impact on the Navigator Group. On 25 May 2023, the International Accounting Standards Board (IASB) published Supplier Finance Arrangements with amendments to IAS 7 - Statement of Cash Flows and IFRS 7 - Financial Instruments Disclosures. The amendments refer to the disclosure requirements relating to supplier finance arrangements - also known as supply chain financing, accounts payable financing or reverse-factoring arrangements. Amendments to IAS 7 The new requirements supplement those already included in the IFRS standards and include disclosures Statement of Cash Flows and on: 01 January IFRS 7 Financial Instruments: a) terms and conditions of supplier finance agreements; 2024 Disclosures - Supplier Finance b) the amounts of the liabilities which are the subject of such arrangements, for which part of them the Arrangements suppliers have already received payments from the providers of funds and under which caption these liabilities are presented in the balance sheet; c) maturity date intervals; and d) information on liquidity risk. The amendment had no significant impact on the Navigator Group.

Standards, amendments and interpretations to be adopted in subsequent periods

Date of Amendment application Standards and amendments endorsed by the European Union which the Group has chosen not to apply early On 15 August 2023, the International Accounting Standards Board (IASB) issued Lack of Exchangeability (Amendments to IAS 21 - The Effects of Changes in Foreign Exchange Rates) (the amendments). The amendments clarify how an entity should assess whether a currency is exchangeable or not and how it should determine a spot exchange rate in situations of lack of exchangeability. A currency is exchangeable for another currency when an entity is able to exchange that currency for another currency on the measurement date and for a specific purpose. When a currency is not Amendments to IAS 21 - The exchangeable, the entity must estimate a spot exchange rate. Effects of Changes in Foreign 01 January Exchange Rates: Lack of 2025 According to the amendments, entities will have to provide new disclosures to help users assess the Exchangeability impact of using an estimated exchange rate on financial statements. These disclosures could include: a) the nature and financial impacts of the currency not being exchangeable; b) the spot exchange rate used; c) the estimation process; and d) the risks to the company because the currency is not exchangeable. This amendment is effective for periods starting after 1 January 2025. Earlier application is permitted.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 367

Date of Amendment application Standards and amendments not endorsed by the European Union On 9 April 2024, the International Accounting Standards Board (IASB or Board) issued the new standard, IFRS 18 Presentation and Disclosure in Financial Statements. The main amendments introduced by this Standard are: a) promotion of a more structured income statement. In particular, it introduces a new subtotal ‘operating profit’ (as well as its definition) and the requirement that all income and expenses be classified into three new separate categories based on a company's main business activities: Operating, Investing and Financing. b) requirement for companies to analyse their operating expenses directly on the face of the income statement - either by nature, by function or in a mixed way. c) requirement for some of the ‘non-GAAP’ measures that the Group uses to be reported in the financial IFRS 18 Presentation and statements. The standard defines non-GAAP performance measures (MPMs) as a subtotal of income and 01 January Disclosure in Financial expenses that: 2027 Statements - are used in public communications outside the financial statements; and - communicate management's view of financial performance. For each MPM presented, companies will need to explain in a single note in the financial statements why the measure provides useful information, how it is calculated, and reconcile it with a value determined in accordance with IFRS. d) introduction of improved guidance on how companies group information in financial statements. It includes guidance on whether material information is included in the primary financial statements or is more detailed in the notes. The amendments are effective for periods beginning on or after 1 January 2027 and apply retrospectively. Earlier application is permitted. On 9 May 2024, the International Accounting Standards Board (IASB) issued the new Standard, IFRS 19 Subsidiaries without Public Accountability: Disclosures, which allows eligible subsidiaries to use IFRS with reduced disclosures. The application of IFRS 19 will reduce the costs of preparing the financial statements of subsidiaries, while maintaining the usefulness of the information for the users of their financial statements. A subsidiary may opt to apply the new Standard in its consolidated, individual or separate financial IFRS 19 Subsidiaries without 01 January statements, provided that, at the reporting date: Public Accountability 2027 a) it has no public accountability; b) its parent company prepares consolidated financial statements in accordance with IFRS. A subsidiary that applies IFRS 19 is required to state clearly in its explicit and unconditional statement of compliance with IFRS that IFRS 19 has been adopted. The amendments are effective for periods beginning on or after 1 January 2027 and apply retrospectively. Earlier application is permitted. On 30 May 2024, the International Accounting Standards Board (IASB or Board) issued amendments regarding the classification and measurement requirements of IFRS 9 - Financial Instruments. The amendments aim to resolve the diversity in the application of the standard, making the requirements more understandable and consistent. The purpose of these amendments is to: a) clarify the classification of financial assets with environmental, social and corporate governance (ESG) characteristics and similar, since these characteristics in loans can affect whether loans are measured at amortised cost or fair value. To resolve any potential diversity in practical application, the amendments clarify how the contractual cash flows of loans should be valued. b) clarify the date on which a financial asset or financial liability is derecognised when it is settled IFRS 9 - Amendments through electronic payment systems. There is an accounting policy option that allows a financial liability Regarding the Classification and to be derecognised before the cash is delivered on the settlement date, if certain criteria are met. 01 January Measurement of Financial c) improve the description of the term ‘non-recourse’, according to the amendments, a financial asset 2026 Instruments has non-recourse characteristics if the ultimate right to receive cash flows from an entity is contractually limited to the cash flows generated by specific assets. The presence of non-recourse features does not necessarily exclude the financial asset from complying with the SPPI, but its characteristics need to be carefully analysed. d) clarify that a contractually linked instrument must have a cascading payment structure that creates a concentration of credit risk by allocating losses disproportionately between different instalments. The underlying pool can include financial instruments that are not within the scope of the classification and measurement of IFRS 9 (e.g. finance leases) but must have cash flows equivalent to the SPPI criterion. The IASB has also introduced additional disclosure requirements relating to equity investments designated at fair value through other comprehensive income and financial instruments with contingent features, for example features linked to ESG targets.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 368

The amendments are effective for periods beginning on or after 1 January 2026. Earlier application is permitted. Date of Amendment application Standards and amendments not endorsed by the European Union On 18 July 2024, the International Accounting Standards Board (IASB) issued limited amendments to the IFRS and respective guidelines, resulting from the regular maintenance carried out on the Standards. The amendments include clarifications, simplifications, corrections and modifications made with the aim of improving the consistency of various IFRS. The IASB amended: a) IFRS 1 First-time Adoption of International Financial Reporting Standards, to clarify certain aspects related to the application of hedge accounting by an entity that is preparing financial statements in accordance with IFRS for the first time; b) IFRS 7Financial Instruments: Disclosures and the respective Implementation Guidance, in order to clarify: - the application guidance, regarding Gain and loss on derecognition; and Annual improvements (IFRS1, - the implementation guidance, namely its Introduction, Fair value paragraph (disclosures regarding 01 January IFRS7, IFRS9, IFRS10 and the difference between fair value and transaction price) and Credit risk disclosure. 2026 IAS7) c) IFRS 9 Financial Instruments to: - require companies to initially measure a receivable without a significant financing component at the amount determined by applying IFRS 15, and - clarify that when a lease liability is derecognised, the derecognition is accounted for under IFRS 9. However, when a lease liability is modified, the modification is accounted for under IFRS 16 Leases. The amendment establishes that when lease liabilities are derecognised under IFRS 9, the difference between the carrying amount and the consideration paid is recognised in profit/(loss). d) IFRS 10 Consolidated Financial Statements, clarification on the determination of a “de facto agent”; and e) IAS 7 Cash Flow Statements, amendment of detail in the paragraph relating to Investments in subsidiaries, associates and joint ventures. The amendments are effective for periods beginning on or after 1 January 2026. Earlier application is permitted. On 18 December 2024, the International Accounting Standards Board (IASB) issued amendments to help companies better report the financial effects of nature-dependent electricity contracts, which are often structured as power purchase agreements (PPAs). Nature-dependent electricity contracts help companies to secure their electricity supply from sources such as wind and solar power. The amount of electricity generated under these contracts can vary based on uncontrollable factors such as weather conditions. Current accounting requirements may not adequately capture how these contracts affect a company’s performance. Amendments to IFRS 9 and 01 January IFRS 7 - Nature-dependent To allow companies to better reflect these contracts in the financial statements, the IASB has made 2026 electricity contracts targeted amendments to IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures. The amendments include: a) clarifying the application of the ‘own-use’ requirements; b) permitting hedge accounting if these contracts are used as hedging instruments; and c) adding new disclosure requirements to enable investors to understand the effect of these contracts on a company’s financial performance and cash flows. The amendments are effective for periods beginning on or after 1 January 2026. Earlier application is permitted.

With respect to the above standards, which are not yet mandatory, the Group has not yet completed the calculation of all impacts

arising from their application and has therefore elected to apply them early, although these impacts are not expected to be

material.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 369

1.6. Significant accounting estimates and judgements

The preparation of consolidated financial statements requires that the Group’s Board of Directors make judgements and estimates

that affect the amount of revenue, costs, assets, liabilities and disclosures at the date of the consolidated statement of financial

position. To that effect, the Group’s Board of Directors are based on:

i) the best information and knowledge of current events and in certain cases on the reports of independent experts; and

ii) the actions that the Group considers it may have to take in the future.

On the date on which the operations take place, the outcome could differ from those estimates.

More significant estimates and judgements are presented below:

Estimates and judgements Notes Business combinations 1.2 – Acquisition of Accrol Group's UK consumer tissue business Recoverability of Goodwill 3.1 – Goodwill Recoverability of brands, useful life and depreciation of other intangible 3.2 – Intangible assets assets Recoverability, useful life and depreciation of property, plant and equipment 3.3 – Property, plant and equipment Fair value of biological assets 3.8 – Biological assets 6.1 - Income tax for the period Uncertainty over Income Tax Treatments 6.2 - Deferred taxes Actuarial assumptions 7.2 – Employee benefits Recognition of provisions 10.1 - Provisions

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 370

2. Operational performance

2.1. Revenue and segment reporting

Accounting policies

Navigator Group business areas

The Navigator Group’s main business is the production and sale of writing and printing thin paper (UWF) and

domestic consumption paper (Tissue), and it is present in the whole value-added chain, from research and development of

forestry and agricultural production to the purchase and sale of wood and the production and sale of bleached eucalyptus kraft

pulp – BEKP and electric and thermal energy, as well as its commercialisation. In the last quarter of 2024, the group also started

producing moulded fibre packaging at the Aveiro industrial complex. This new production unit is aimed at a market with high

growth potential, fully aligned with the challenges of reducing the use of single-use plastics.

The Navigator Group currently has ten industrial sites - four in Portugal, one in Spain and five in the United Kingdom. Of the

industrial complexes in Portugal, two are dedicated to the production of BEKP pulp, electricity and UWF paper (Figueira da Foz and

Setúbal), one is dedicated to the production of BEKP pulp, energy, moulded cellulose packaging and tissue paper (Aveiro) and a

fourth, in Vila Velha de Ródão, produces tissue. In Spain, the Group owns an industrial complex in Zaragoza where it produces

tissue paper. In May 2024, with the acquisition of the Navigator Tissue Uk Group (formerly the Accrol Group), the Navigator Group

now has five production sites in the UK related to the tissue business: Blackburn (rolls and facials); Leicester (rolls); Leyland

(rolls); Flint (wet wipes) and Bridgewater (wet wipes).

Wood is produced from woodlands owned or leased by the Group in Portugal and Spain, and also form granted lands in

Mozambique. The production of cork and pine wood are sold to third parties while the eucalyptus wood is mainly consumed in the

production of BEKP.

A significant portion of the Group’s own BEKP production is consumed in the production of UWF and tissue paper. Sales of BEKP

pulp, UWF paper and tissue paper – to 118 (2023: 134) countries and territories around the world.

Regarding energy production, the Group has three cogeneration plants, integrated in the production of pulp. Heat production is

used for internal consumption while electricity is sold to the national energy grid. The Group also owns two cogeneration plants

fuelled by natural gas and two independent plants fuelled by biomass, integrated into paper production in Figueira da Foz and

Setúbal, the majority of whose output is sold to the national energy grid.

In addition, the Group currently has eight photovoltaic plants in operation for self-consumption: three in Setúbal - two at the

factory complex and one at Herdade de Espirra, two at the Figueira da Foz industrial complex (one of which came into operation in

2024), one at the Zaragoza industrial complex, one at Raiz (in Aveiro) and also two plants that came into operation during 2024,

at the Aveiro and Vila Velha de Ródão industrial complexes.

With the conclusion of the construction of new photovoltaic plants in 2024, on a self-consumption basis, at the industrial sites of

Figueira da Foz, Aveiro and Vila Velha de Ródão, Navigator, with around 38 MW of installed photovoltaic solar energy capacity, will

become the largest self-consumption producer in Portugal, in an industrial context.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 371

Segment reporting

In accordance with IFRS 8, the Group considers an operating segment as a component of the group that develops business

activities from which it can obtain revenue and incur expenses, whose operating profit/(loss) are regularly reviewed by the

Executive Committee, which is primarily responsible for the Group's operational decision-making for allocation of resources to the

segment and the assessment of its performance and for which separate financial information is available.

Each reportable segment corresponds to the value chain of the integrated production process associated with the product of each

business segment, (Market Pulp, UWF paper, Tissue Paper and Energy) considering the sales activity of the respective products on

the market, in a manner consistent with the information used by the Executive Committee for operational monitoring of its

businesses.

Accordingly, intra-segmental sales are those that occur within the same manufacturing plant and whose production inputs are

used in the production process of that segment. Thus, the values reported for each operating segment result from the

aggregation of the business units and subsidiaries defined in the perimeter of each segment, as well as the cancellation of intra-

segment transactions.

Intra-segmental sales correspond to sales between business segments or when there are transactions between manufacturing

plants, which are eliminated for consolidation purposes, being this effect reported in the “Cancellations”. When aggregating the

Group's operating segments, Management defined as reportable segments those that correspond to each of the business areas

developed by the Group, as follows:

i. Market pulp – bleached eucalyptus BEKP for sale in the market;

ii. UWF paper – production and sale of UWF uncoated writing and printing thin paper;

iii. Tissue Paper – production and sale of domestic consumption paper;

iv. Biomass renewable energy – which includes the cogeneration units and the two independent thermoelectric power plants;

v. Support - segment that includes the corporate centre (mixed holding).

Regarding the allocation of assets and liabilities to business segments, it should be noted that:

• All equipment allocated to the UWF pulp and paper production are included in Property, plant and equipment of the

respective segments.

• The Group's real estate assets are allocated to the respective business segment.

• The assets related to forests are allocated to the pulp and UWF paper segments, according to the production capacity of

each segment.

• The majority of the assets allocated to each of the individual segments, with the exception of receivables, is located in

Portugal.

• In accordance with the Navigator Company Group's financing policy, all loans are contracted by the Group's holding

company, The Navigator Company, S.A., which is responsible for bearing all debt and related charges. Accordingly,

interest-bearing liabilities (Note 5.7) are allocated to the “Support” segment, which includes the Group's corporate centre

(Holding), with the exception of the repayable grant related to the construction of the new tissue mill, allocated to the

“Tissue Paper” segment and a portion of the “Inpactus” grant allocated to the “UWF Paper” segment.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 372

Revenue

Revenue is presented by operating segment and by geographic area, based on the country of destination of the goods and

services sold by the Group.

Commercial contracts with Customers refer essentially to the sale of goods such as paper, pulp, tissue and energy, and to an

extent, to the transportation inherent to those goods, when applicable.

Revenue recognition in each operating segment is described as follows:

Pulp revenue results from sales to international paper and decor producers. Revenue is recognised point in time, by the amount of the performance obligation satisfied, the price of the transaction corresponding to a fixed amount invoiced on the basis of quantities sold, less Market pulp cash discounts and quantity discounts, which are reliably determinable. On the export side, the transfer of control of the products occurs in general when there is a transfer of control to the Customer, according to the Incoterms negotiated. Paper revenue refers to sales made through Commercial Distributors (B2B) which include large distributors, wholesalers or commercial operators. Revenue is recognised point in time, on the date of delivery of the product to the customer when the transfer of control occurs, UWF by the amount of the performance obligation satisfied, and the price of the transaction corresponds to a fixed amount invoiced according to the quantities sold, less cash discounts and quantity discounts, which are reliably determinable. Tissue revenue results from sales of tissue paper produced for the private label of modern national and international retail chains. Revenue is recognised point in time, by the amount of the performance obligation satisfied, and the price of the transaction corresponds Tissue to a fixed amount invoiced according to quantities sold, less cash discounts and quantity discounts, which are reliably determined. Revenue is recognised against the delivery of the product, at which time the transfer of control over the product is deemed to take place. Energy revenue results from the valuation of the sale of electricity to the national grid. Renewable biomass cogeneration and thermoelectric plants sell all their production and benefit from a regulated sales tariff defined in accordance with the current legal Energy framework. In turn, the natural gas cogeneration plant in Setúbal has been operating on a self-consumption basis since January 2024, selling its surplus production at market prices. The revenue from the sale of other products such as waste, or services (brokerage, for example) is recognised on the date of delivery of Support the product to the Customer by the amount of the performance obligation satisfied. The income related to this segment is reclassified to other operating income or to less costs.

The Navigator Group considers the facts and circumstances when analysing the terms of each Customer contract and its usual

business practices in determining the transaction price. In this sense, in terms of sales tax, from the assessment performed by

Navigator, there are no situations that could be included in the transaction price. Regarding specifically to the anti-dumping tax,

this is a tax for the entry of goods into the country (in the case of the USA) and is not a tax determined a priori but depends on

the analysis of the Department of Commerce a posteriori. Therefore, it represents a decrease to the gross margin obtained in the

United States and not an adjustment to the price of the individual transaction.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 373

Financial information by operating segment in 2024 and 2023

2024 Market * Amounts in Euro Pulp UWF Paper Tissue Paper Energy Support Cancellations Total REVENUE Sales and services - external 237,730,013 1,271,500,425 456,257,281 122,788,834 - - 2,088,276,553 Sales and services – intersegment 2,831,203 - - 46,217,863 - (49,049,066) - Total revenue 240,561,216 1,271,500,425 456,257,281 169,006,697 - (49,049,066) 2,088,276,553 PROFIT/(LOSS) (1)Operating income 31,891,469 303,861,737 76,451,601 22,129,153 (55,464,164) - 378,869,796 Financial profit/(loss) - - - - (25,839,567) - (25,839,567) Income tax - - - - (66,046,016) - (66,046,016) Net profit/(loss) for the period 286,984,213 Non-controlling interests - - - - (36,018) - (36,018) Profit/ (loss) attributable to 286,948,195 equity holders - - - - - - OTHER INFORMATION Capital expenditure 32,565,167 177,743,951 22,413,518 2,764,530 5,141,354 - 240,628,520 Depreciation (including impairments) (17,791,078) (92,148,909) (31,386,430) (19,074,713) (7,459,334) - (167,860,464) Provisions (increases) / (reversals) - 276,870 12,500 - (321,548) - (32,178) OTHER INFORMATION SEGMENT ASSETS Goodwill - 376,756,383 45,870,954 - - - 422,627,337 Property, plant and equipment 151,004,952 808,310,338 320,668,615 129,491,427 6,469,753 - 1,415,945,085 Right-of-use assets 14,003,867 52,461,957 30,557,574 - 1,627,768 - 98,651,166 Biological assets 28,812,550 86,437,648 - - - - 115,250,198 Non-current receivables - 4,696,897 8,136,600 - 309,440 - 13,142,937 Inventories 19,393,981 217,527,247 63,786,298 927,446 1,563,395 - 303,198,367 Trade receivables 39,090,634 155,681,370 102,019,064 744,650 7,506,779 - 305,042,497 Other current receivables 18,865,900 66,902,642 18,614,765 1,159,038 86,113,779 - 191,656,124 Other assets 8,892,098 70,163,195 97,428,633 6,015 311,179,412 - 487,669,353 Total Assets 280,063,982 1,838,937,677 687,082,503 132,328,576 414,770,326 - 3,353,183,064 SEGMENT LIABILITIES Interest-bearing liabilities - 415,573 48,532,818 - 855,029,361 - 903,977,752 Lease liabilities 15,411,571 57,006,275 37,587,262 - 1,731,792 - 111,736,900 Other current payables 42,756,779 264,028,115 59,464,303 4,137,851 288,182,626 - 658,569,674 Other liabilities 30,381,754 141,657,502 72,132,454 7,026,567 71,611,277 - 322,809,554 Total Liabilities 88,550,104 463,107,465 217,716,837 11,164,418 1,216,555,056 - 1,997,093,880

* Cancellation of Intersegment Operations. Consolidation adjustments related to inter-segmental transactions are considered not significant.

(1)

Includes the effects of hedging derivatives of Euro 1,018,419 in the Pulp segment and of Euro 4,695,937 in the UWF Paper segment.

In 2024, The Navigator Company recorded turnover in the amount of Euro 2,088,276,553, the second best result in the Group's

history, with paper sales, including packaging accounting for approximately 61% of turnover (vs.64%), pulp sales 11% (vs.13%),

tissue sales 22% (vs.15%) and energy sales 6% (vs.9%).

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 374

The year 2024 began in an adverse macroeconomic and geopolitical context, with high volatility expected in the international

markets (financial, energy, logistics and raw materials). However, the international economy turned out to be remarkably

resilient, exceeding expectations.

In the Pulp and Paper sector, after a first half marked by a rapid rise in the pulp price benchmarks, the second half of the year

witnessed a significant price correction in China and a consequent adjustment in Europe.

This volatility in the price of pulp

contrasted with the resilience in the benchmark prices of printing and writing paper. The year ended with a positive trend in orders

for printing and writing paper, packaging paper, especially in the first half and at the end of the year, and tissue paper.

The Navigator Group's competitiveness is based on efficient management of the business mix, commercial strategy, cost control

and a focus on innovation and business sustainability. This year it acquired a new tissue operation in the UK, Navigator Tissue UK,

and started integrated production of moulded fibre to replace single-use plastic and aluminium packaging in the food service and

food packaging markets. This commitment to reinforce the tissue segment and the packaging business line strengthens the

Navigator Group's business diversification strategy, with these two segments accounting for 26% of total sales.

The Group maintains its commitments to investment and innovation in all segments, exploring growth opportunities in tissue,

packaging, and energy. The positioning of the brands, the sustainability of the business, the scale of operations and financial

strength support a resilient business model, allowing consistent results even in uncertain economic contexts.

The amount corresponding to total energy sales was Euro 122,788,834 compared to Euro 168,623,237 in 2023, a decrease of

approximately 27%. This reduction is essentially due to the transfer of the Setúbal natural gas combined cycle power station to

self-consumption from January onwards, whereas last year it had operated under the total sale of its production regime.

On the other hand, the lower sales of electricity resulting from the self-consumption operation of the Setúbal plant, as detailed

below by plant, corresponds to a lower volume of electricity purchases from the group's main paper machine.

Energy sales are broken down by type of plant as follows:

2024 2023 Mwh Amount Mwh Amount Biomass Thermoelectric Plants 179,525 24,714,238 178,216 24,046,637 Renewable Cogeneration Plants Pulp 852,396 92,797,452 905,045 86,311,170 Non-Renewable Cogeneration Plant Paper 106,327 4,669,926 338,766 29,668,929 Derivatives, Guarantees of Origin and others - 607,218 - 28,596,501 1,138,248 122,788,834 1,422,027 168,623,237

The year 2024 was also marked by the participation of the Group's industrial units in the Frequency Restoration Reserve Band

Market with manual activation (mFRR Band), a system service provided to the electricity transmission network operator by agents

authorised for the purpose, which aims to help safeguard the security of supply of the National Electricity System.

The fixed capital expenditure in 2024 stood at Euro 240,628,520, compared with Euro 183,504,098 in the previous year. This

amount mainly includes investments aimed at maintaining production capacity, modernising equipment and factory facilities,

environmental and efficiency improvements, and structural and safety projects, of which around 50% are sustainable

investments.

Among the investments are the following projects: the new high-efficiency recovery boiler in Setúbal for the collection and

incineration of odorous gases (NCGs); moulded pulp in Aveiro; the new biomass lime kiln in Figueira da Foz; the conversion of the

lime kilns in Setúbal and Aveiro to burn biomass; the new photovoltaic plants in Figueira da Foz and Vila Velha de Ródão; oxygen

delignification in Setúbal; the new tower and washing presses in Aveiro and the biomass boiler in Vila Velha de Ródão. A total of

1,358 projects, of which 31 individually cost more than Euro 1 million.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 375

The Group is making progress with all the projects it committed to under the Recovery and Resilience Plan (RRP), the

implementation of which is going according to plan. For eligible investments under the RRP, an incentive rate of about 40% is

expected, which corresponds to close to Euro 100 million, with the company receiving approximately Euro 25 million in 2024 and

Euro 21 million in 2023.

2023 Market *Amounts in Euro Pulp UWF Paper Tissue Paper Energy Support Cancellations Total REVENUE Sales and services - external 249,482,366 1,241,037,335 294,099,962 168,623,237 - - 1,953,242,900 Sales and services – intersegment 2,635,447 - - 35,402,245 - (38,037,692) - Total revenue 252,117,813 1,241,037,335 294,099,962 204,025,482 - (38,037,692) 1,953,242,900 PROFIT/(LOSS) (1)Operating income 11,343,636 291,631,405 62,743,854 55,592,967 (54,956,679) - 366,355,183 Financial profit/(loss) - - - - (19,319,918) - (19,319,918) Income tax - - - - (72,086,123) - (72,086,123) Net profit/(loss) for the period 274,949,142 Non-controlling interests - - - - (25,322) - (25,322) Profit/ (loss) attributable to equity - - - - - - 274,923,820 holders OTHER INFORMATION Capital expenditure 35,311,974 131,075,558 10,493,749 3,354,938 3,267,879 - 183,504,098 Depreciation (including impairments) (18,840,621) (81,276,204) (12,086,871) (17,405,496) (6,589,608) - (136,198,800) Provisions (increases) / (reversals) (279,769) 93,550 (19,496) - 1,211,756 - 1,006,041 OTHER INFORMATION SEGMENT ASSETS Goodwill - 376,756,383 4,739,625 - - - 381,496,008 Property, plant and equipment 147,861,864 721,149,816 223,228,954 136,456,809 4,526,348 - 1,233,223,791 Right-of-use assets 13,507,060 49,592,030 - - 1,945,364 - 65,044,454 Biological assets 28,897,995 86,693,984 - - - - 115,591,979 Non-current receivables 7,428,808 26,728,233 4,854,435 - 5,388,030 - 44,399,506 Inventories 39,517,952 215,446,716 30,030,696 472,257 1,022,741 - 286,490,362 Trade receivables 34,908,856 145,075,440 66,242,331 2,752,026 10,082,188 - 259,060,841 Other current receivables 23,498,980 60,606,258 9,133,886 898,563 71,542,445 - 165,680,132 Other assets 2,630,947 52,496,500 9,706,306 - 193,331,893 - 258,165,646 Total Assets 298,252,462 1,734,545,360 347,936,233 140,579,655 287,839,009 - 2,809,152,719 SEGMENT LIABILITIES Interest-bearing liabilities - 415,573 30,031,736 - 628,897,154 - 659,344,463 Lease liabilities 14,641,258 53,286,690 - - 2,068,873 - 69,996,821 Other current payables 46,633,651 253,045,785 39,478,866 2,674,579 161,213,901 - 503,046,782 Other liabilities 26,787,188 131,454,901 35,696,564 7,684,383 59,568,784 - 261,191,820 Total Liabilities 88,062,097 438,202,949 105,207,166 10,358,962 851,748,712 - 1,493,579,886

* Cancellation of Intersegment Operations. Consolidation adjustments related to inter-segmental transactions are considered not significant.

(1)

Includes the effects of hedging derivatives of Euro 1,973,497 in the UWF Paper segment and Euro 26,550,098 in the Energy segment.

The Energy segment also includes revenues associated with guarantees of origin of Euro 3,252,121

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 376

Revenue by business segment, by geographic area and by recognition pattern

2024 Total Total Amounts in Euro Pulp UWF Paper Tissue Paper Energy Amount % Portugal 11,344,979 66,027,268 91,859,908 122,784,554 292,016,709 13.98%) Rest of Europe 139,131,658 735,280,377 361,125,414 4,280 1,235,541,729 59.17%) America* 6,295,801 175,856,336 1,467,789 - 183,619,926 8.80%) Africa and Middle East 40,021,254 183,976,854 1,804,170 - 225,802,278 10.81%) Asia 40,936,321 110,106,670 - - 151,042,991 7.23%) Oceania - 252,920 - - 252,920 0.01%) 237,730,013 1,271,500,425 456,257,281 122,788,834 2,088,276,553 100.00%) Recognition pattern Point in time 237,730,013 1,271,500,425 456,257,281 122,788,834 2,088,276,553 100.00%) Over time - - - - - 0.00% * Includes North America and Latin America

2023 Total Total Amounts in Euro Pulp UWF Paper Tissue Paper Energy Amount % Portugal 3,312,700 68,015,492 88,070,809 168,623,237 328,022,238 16.79%) Rest of Europe 84,919,648 755,558,561 200,164,742 - 1,040,642,951 53.28%) America* 1,566,715 109,186,480 2,122,037 - 112,865,232 5.78%) Africa and Middle East 29,064,688 173,712,207 3,666,154 - 206,443,049 10.57%) Asia 130,618,615 134,431,052 86,220 - 265,135,887 13.57%) Oceania - 133,543 - - 133,543 0.01%) 249,482,366 1,241,037,335 294,099,962 168,623,237 1,953,242,900 100.00%) Recognition pattern Point in time 249,482,366 1,241,037,335 294,099,962 168,623,237 1,953,242,900 100.00%) Over time - - - - - 0.00% * Includes North America and Latin America

Group's revenue distribution by geographic area

In 2024 and 2023, no single Customer accounted for 10% or more of the Group's total revenues.

M€ 151M€ 265M€ 292M€ 328M€ 226PortugalM€ 206M€ 184Rest of EuropeAmerica20232024Africa and Middle EastM€ 51AsiaOceaniaM€ 1.236M€ 1.041

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 377

2.2. Other operating income

For the periods ended 31 December 2024 and 31 December 2023, Other operating income is detailed as follows:

Amounts in Euro 2024 2023 Gains on disposal of non-current assets 178,066 618,244 Grants - CO2 emission allowances 35,508,908 39,687,379 Supplementary gains 1,298,108 1,046,911 Operating grants 14,005,693 15,885,357 Impairment reversal on receivables 4,105,821 4,634,383 Impairment reversal on inventories (Note 4.1.4) 5,068,999 317,928 Gains on inventories 755,198 733,097 Own work capitalised 7,533,597 1,053,861 Compensations 638,497 1,465,910 Waste sales 15,208,232 7,659,998 Other operating income 16,492,358 7,212,645 100,793,477 80,315,713

Gains on CO2 emission allowances correspond to the recognition of free allocation of allowances for 480,955 tons of CO2, at the

average price of Euro 73.83 (473,314 tons of CO2, at the average price of Euro 83.85 in 2023) (Note 3.2).

Operating grants include Euro 9,736,412 (Euro 10,258,265 in 2023) related to the receipt of the indirect cost aid measure for

facilities covered by the European Emissions Trading Scheme (EU ETS), under Decree-Law 12/2020 of 6 April, as well as the

incentive related to the Recovery and Resilience Plan (RRP) of Euro 3,017,300 (Euro 2,225,213 in 2023). In 2023, this caption

also included the amount of Euro 1,704,435 from the Incentive relating to the Programa Apoiar Gás (Support Gas Programme).

The caption Impairment reversal on receivables includes the amount of Euro 1,017,249 (Euro 2,006,715 in 2023) relating to the

impairment reversal on trade receivables from Egypt and the caption Impairment reversal on inventories includes Euro 3,121,270

and Euro 861,503 relating to the impairment reversal on UWF waste paper and spare parts, respectively.

Other operating income includes Euro 8,000,000 of the deposit paid by Start - Sines Transatlantic Renewable & Technology

Campus, S.A. as a result of the revocation of the promissory purchase and sale agreement signed in 2021 for the acquisition of

land in Sines.

Accounting policies

Government grants

Operating grants

Government grants are only recognised when there is a reasonable assurance that the grant will be received, and the Group will

comply with all required conditions. Operating grants, received with the purpose of compensating the Group for costs incurred, are

systematically recorded in the income statement during the periods in which the costs that those grants are intended to

compensate are recorded.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 378

Grants related to biological assets

Grants related to biological assets (Note 3.8) carried at fair value, in accordance with IAS 41, are recognised in the income

statement when the terms and conditions of the grant are met.

Grants – CO

Emission allowances

Grants related to CO

emission allowances (Note 3.2) are recognised as deferred income and are systematically recorded in the

income statement during the periods in which the expenses that those grants are intended to compensate are recorded.

2.3. Other operating expenses

Operating expenses are detailed as follows for the periods ended 31 December 2024 and 31 December 2023:

Amounts in Euro 2024 2023 Cost of goods sold and materials consumed (Note 4.1.2) 880,548,487 848,515,663 External services and supplies Energy and fluids 138,428,891 96,858,336 Transportation of goods 152,884,413 134,873,147 Specialised work 100,751,347 93,678,739 Maintenance and repair 40,758,036 36,368,632 Rentals 8,688,495 9,216,917 Advertising and marketing 11,835,995 10,332,278 Insurance 13,322,369 10,556,973 Travel and accommodation 5,134,588 5,105,412 Fees 6,539,574 5,027,626 Subcontracts 2,723,064 2,719,386 Materials 4,161,889 3,503,308 Communications 1,409,739 1,301,725 Other 14,228,821 12,831,040 500,867,221 422,373,519 Variation in production (Note 4.1.3) 3,499,808 23,719,799 Payroll costs (Note 7.1) 203,780,154 172,252,203 Other operating expenses Costs with CO2 emission allowances 33,434,013 37,815,953 Impairment on receivables (Note 8.1.4) 340,564 596,813 Impairment losses on inventories (Note 4.1.4) 3,165,457 4,152,419 Other inventory losses 4,491,888 5,102,146 Indirect taxes 4,594,801 3,984,895 Water resource fee 2,076,795 1,701,536 Other operating expenses 4,492,152 4,887,829 52,595,670 58,241,591 Net provisions (Note 10.1) 32,178 (1,006,041) Total operating expenses 1,641,291,340 1,525,102,775

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 379

The last quarter of 2024 was negatively impacted by the extension of the annual maintenance stoppage at one of the plants and

by a series of extraordinary events at the energy assets: i) problems identified following a scheduled stoppage at an electricity

generating turbine; ii) a breakdown at an electricity supply transformer; and unforeseen stoppages at biomass boilers. This

sequence of events, which have now been regularised, resulted in a reduction in energy sales and an increase in purchases of

natural gas and electricity, during a period of high prices for these commodities, which had a significant impact on the Energy and

fluids caption.

On the other hand, the increase in the Transportation of goods caption is essentially due to the integration of the Navigator Tissue

UK Group. It should be noted that, despite the fact that 2024 was marked by the Red Sea crisis, which led to changes in maritime

transport routes and generated an overall upward trend in freight rates, the Navigator Group maintained its path of reducing

logistics costs, cutting them by 6% compared to 2023.

Moreover, the increase in the Specialised work caption is mainly due to the costs of the acquisition of the Navigator Tissue Uk

Group (Note 1.2) as well as its integration into the Navigator Group's accounts.

In 2024 and 2023, external services and supplies costs incurred for investigation and research activities amounted to Euro

5,349,558 and Euro 5,234,381, respectively. The Group plans to apply for SIFIDE approximately Euro 11 million (Euro 14 million

in 2023) relating to research and development expenditure (which also includes eligible payroll costs). These expenses will allow

the Group to benefit from incentives of approximately Euro 3.9 million (2023: Euro 5.3 million) if the eligibility criteria required by

the application are met.

The expenses with CO

correspond to the emission of 466,992 tons of CO

(31 December 2023: 471,757 tonnes), achieving a

34.9% reduction in CO

emissions compared to 2020, the base year used for the validation of the targets by the Science Based

Targets Initiative (466,992 tonnes vs. 717,121 tonnes of CO

in 2020). The reduction in costs for the period is mainly due to the

12% reduction in the price of licences allocated (Euro 73.83€/ton in 2024 vs Euro 83.85/ton in 2023) corresponding to the basis

for valuing the cost of emissions and the reduction in consumption compared to the previous year.

In 2024 impairment losses in inventories essentially include the recognition of Euro 1,724,970 in impairment losses for UWF and

tissue paper waste and Euro 1,248,818 for slow movers. In 2023, this caption mainly includes the recognition of an impairment of

Euro 2,071,836 for the inventory of damaged paper identified on the platform of Navigator North America Inc.

Audit fees

2024 2023 Other entities Other entities KPMG & belonging to KPMG & belonging to Associados the same Associados the same Amounts in Euro SROC network SROC network The Navigator Company, S.A. Audit fees 252,500 - 169,000 - Other assurance services 116,500 - 34,010 - Other services 3,500 328,278 475 - 372,500 328,278 203,485 - To entities belonging to Navigator Group Audit fees 215,353 33,117 173,856 17,678 Other assurance services 51,850 - 58,000 - Other services - - 2,000 -

emissions from assets in mills, Scope 1 - EU ETS basis.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 380

267,203 33,117 233,856 17,678 639,703 361,395 437,341 17,678

In 2024, the services other than auditing services invoiced to the company or to entities in a parent-subsidiary relationship with it

by the External Auditor and Statutory Auditor, including entities in a holding relationship with it or that are part of the same

network, represented 50.0% (2023: 21.4%) of the total services rendered.

2024 2023 Expenses in Expenses in Fees Amounts in Euro the period Fees invoiced the period invoiced KPMG (SROC) and other entities belonging to the same network Audit fees 643,224 500,970 404,940 357,534 Other assurance services 113,900 168,350 56,760 95,010 Other services 331,778 331,778 2,000 2,475 1,088,902 1,001,098 463,700 455,019

The services indicated as "Other assurance services" relate to the reporting of financial information and verification services for

Sustainability Information. With regard to services other than auditing, these refer to the provision of financial information

auditing services to a number of companies in a Group within the scope of the acquisition by the Navigator Group, as well as

agreed procedures on financial information.

The Board of Directors believes there are adequate procedures safeguarding the independence of auditors, through the

Supervisory Board process analysis of the work proposed and careful definition of the work to be performed by the auditors.

3. Investments

3.1. Goodwill

Goodwill – net amount

Goodwill is attributed to the Group’s cash generating units (CGU’s), as follows:

Amounts in Euro 2024 2023 CGU of UWF paper production on Figueira da Foz site 376,756,383 376,756,383 (goodwill resulting from the acquisition of Navigator Brands, S.A.) CGU of Tissue paper production on Vila Velha de Ródão site 583,083 583,083 (goodwill resulting from the acquisition of Navigator Tissue Ródão, S.A.) CGU for the production and commercialisation of Tissue paper in Ejea and France (goodwill resulting from the acquisition of Navigator Tissue Ejea, SL. and Navigator 4,156,542 4,156,542 Tissue France, EURL) CGU for the production and commercialisation of Tissue paper in the United Kingdom 41,131,329 - (initial goodwill resulting from the acquisition of the Accrol Holdings Plc Group) 422,627,337 381,496,008

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 381

Navigator Brands, S.A. / Navigator Paper Figueira, S.A.

Following the acquisition of 100% of the former Soporcel - Sociedade Portuguesa de Papel, S.A. (currently Navigator Brands,

S.A.), for Euro 1,154,842,000, Goodwill amounting to Euro 428,132,254 was determined.

The goodwill generated on the acquisition of Navigator Paper Figueira was deemed to be allocable to the integrated paper

production in Figueira da Foz Industrial Complex cash generating unit.

The book value of Goodwill amounts to Euro 376,756,383 for having been subject to annual amortisations until 31 December

2003 (date of transition to IFRS: 1 January 2004), and amortisation, as from that date, the accumulated amount of which was

Euro 51,375,871, has ceased. From that date on, depreciation ceased and was replaced by annual impairment tests. If this

amortisation had not been interrupted, the net book value of the Goodwill as at 31 December 2024 would amount to Euro

17,125,290 (31 December 2023: €34,250,580).

Navigator Tissue Ródão, S.A.

On 6 February 2015 the procedures and agreements for the acquisition of AMS-BR Star Paper, S.A. (later merged into Navigator

Tissue Ródão, S.A.) were concluded, with the authorisation to conclude this transaction being formalised on 17 April 2015.

To the initial acquisition difference, of Euro 21,337,916, was deducted the AICEP’s investment grant and the fair value of the

acquired property, plant and equipment, with a goodwill amounting to Euro 583,083.

Navigator Tissue Ejea, S.L.U.

On 31 March 2023, the Navigator Group acquired all the shares representing the share capital of Gomà-Camps Consumer, S.L.U.,

based in Zaragoza, Spain, which in turn holds the entire share capital of Gomà-Camps France SAS, based in Castres, France.

These companies have been renamed Navigator Tissue Ejea, S.L.U. and Navigator Tissue France SAS, respectively.

The Enterprise Value of this acquisition amounted to Euro 60,951,811 and was realised entirely in cash and cash equivalents, with

no contingent consideration associated with this acquisition.

The initial acquisition difference of Euro 34,037,142 was deducted from the fair value attributed to property, plant and equipment

and intangible assets acquired in the amount of Euro 38,240,800 and Euro 1,600,000, respectively, as well as the associated

deferred tax liabilities, resulting in final goodwill of Euro 4,156,542 (Note 1.2).

Navigator Tissue UK

On 24 May 2024, the Navigator Group concluded a public takeover bid, in the form of a “Recommended Firm Cash Offer”, for the

entire share capital of Accrol Group Holdings Plc (Accrol), currently Navigator Tissue UK Group, a company based in Blackburn,

England, which holds 9 subsidiaries, 5 of which operational. Accrol Group is a leader in the tissue paper converting segment in the

United Kingdom, producing private label toilet rolls, kitchen rolls and facial tissues for most of the main retailers in the UK.

As part of this acquisition, the consideration transferred amounted to Euro 153,765,152 (GBP 130,823,390) and an initial goodwill

of Euro 114,920,802 (GBP 97,774,618) was calculated, from which was deducted the fair value attributed to property, plant and

equipment and intangible assets of Euro 25,734,059 and Euro 74,045,509, respectively, as well as the associated deferred tax

liabilities (Note 1.2). The final goodwill amounted to Euro 40,086,125 (GBP 34,105,275), which on 31 December corresponded to

an amount of Euro 41,131,329 as a result of the exchange rate update at the rate of 0.82918.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 382

Goodwill recoverability analysis

Every year, the Navigator Group calculates the recoverable amount of each business, based on value-in-use calculations, in

accordance with the Discounted Cash Flow method. The calculations are based on past performance and business expectations

with the actual production structure, using the budget for the following year and projected cash flows for the following 4 years. As

a result of the calculations, up to this date no impairment losses relating to Goodwill have been identified.

The main assumptions for the above-mentioned calculation were as follows:

Assumptions on the basis of the business plan

Assumptions 2024 2023 (CAGR 2024-2028) (CAGR 2024-2028) Amount of sales (kt) Reference UWF Paper UWF Paper CAGR amount of sales (kt) 0.8% 0.0% Reference Tissue Paper Tissue Paper CAGR amount of sales (kt) 0.6% 0.6% Average price of sale ML/t Reference UWF Paper UWF Paper CAGR average price of sale ML/t 0.0% 0.3% Reference Tissue Paper Tissue Paper CAGR average price of sale ML/t (0.5%) 0.3% Perpetuity growth rate – UWF Paper (1.0%) (1.0%) Perpetuity growth rate – Tissue Paper 2.0% 2.0%

Macroeconomic assumptions

The main assumptions considered at the macroeconomic level are forecasts of GDP growth rate and inflation in Portugal. The

sources of forecasts are the IMF and Banco de Portugal.

2024 Financial Year Macroeconomic assumptions 2025 2026 2027 2028 Real GDP growth rate 2.10% 2.20% 1.90% 1.90% Inflation EUR 2.10% 2.00% 2.00% 2.00%

2023 Financial Year Macroeconomic assumptions 2024 2025 2026 2027 Real GDP growth rate 1.50% 2.10% 2.00% 1.90% Inflation EUR 3.30% 2.10% 2.20% 2.00%

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 383

The perpetuity growth rate reflects the Boards of Directors' vision of the medium and long term for the different Cash Generating

Units (CGUs), bearing in mind the macroeconomic assumptions.

Financial assumptions

2024 2023 Risk-freePerpetuity Risk-freePerpetuity interest WACC growth interest WACC growth Financial assumptions rate* rate EUR rate EUR Tax rate rate* rate EUR rate EUR Tax rate UWF Paper Explicit Planning Period 2.73% 6.00% 0.00% 27.50% 3.52% 6.85% 0.00% 27.50% Perpetuity 2.73% 6.00% (1.0%) 27.50% 3.52% 6.85% (1.0%) 27.50% * Includes Country Risk Premium

Estimates and judgements

Recoverability of Goodwill

The Group tests Goodwill impairment annually, recorded in its Statement of Financial Position. For impairment tests of CGUs, the

recoverable amount was determined based on the value in use, according to the discounted cash flow method. The recoverable

amount of CGUs derives from assumptions related to the activity, namely, sales volumes, average sales prices and variable costs

that in the projection periods result from a combination of economic forecasts for the regions and markets where the Group

operates, industry forecasts, including changes in markets derived from changes in installed capacity for each operating activity,

internal management projections and historical performance. These calculations require the use of estimates. The impact of

climate change has also been considered in the estimates of future cash flows, although the impact is not material. The risks and

opportunities related to climate change identified in accordance with the TCFD recommendations are disclosed in the notes to the

Management Report.

Sensitivity analysis

As at 31 December 2024, a possible increase of 0.5% in the discount rate used in the impairment test of Goodwill allocated to the

cash-generating unit in Figueira da Foz integrated Paper, would imply a decrease in the assessment in the amount of Euro

273,710,850 (31 December 2023: Euro 214,028,739), which is still approximately 4 times higher than the book value of this

cash-generating unit.

Moreover, the 0.5% increase in the discount rate used in the impairment test for Navigator Tissue Ejea would imply a decrease in

the valuation as at 31 December 2024 of Euro 15,985,812, which is still around 2 times higher than the book value of this cash-

generating unit.

With regard to the Goodwill allocated to Navigator Tissue Ródão, given the immateriality of its value, any impacts would not be

materially relevant.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 384

Accounting policies

Goodwill

Goodwill represents the difference between the fair value of the cost of acquisition and the fair value of the

identifiable assets, liabilities and contingent liabilities of the subsidiaries included in the consolidation on the acquisition date and is

allocated to each CGU or to the lower group of CGUs to which it belongs.

Amortisation and impairment

Goodwill is not amortised. The Group carries out annual impairment tests on goodwill, or where there are signs of impairment.

The recoverable amounts of cash-generating units are determined as the higher of value in use and fair value less cost of sale.

Impairment losses on goodwill cannot be reversed.

Disposal and loss of control

Gains or losses arising from the sale or loss of control over an entity or business to which Goodwill is allocated include the amount

of the corresponding goodwill.

Tax deductibility

Derived from the current tax legislation in Portugal, it is not expected that Goodwill generated or to be recognised will be tax

deductible.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 385

3.2. Intangible assets

Movements in intangible assets

Industrial property CO2 Other Intangible Amounts in Euro and other emission intangible assetsrights allowances assets in progress Total Gross amount Balance as at 01 January 2023 70,983 44,781,151 - - 44,852,134 Change in the perimeter (Note 1.2) - - 3,346,282 - 3,346,282 Allocations - 39,687,379 - - 39,687,379 Acquisitions 2,400,000 - - 522,645 2,922,645 Adjustments, transfers and write-offs 248,236 (42,966,321) - (522,645) (43,240,730) Balance as at 31 December 2023 2,719,219 41,502,209 3,346,282 - 47,567,710 Change in the perimeter (Note 1.2) 28,471,792 - 53,596,615 509,174 82,577,581 Allocations - 35,508,908 - - 35,508,908 Acquisitions - - 391,306 391,306 Adjustments, transfers and write-offs (39,267) (38,532,530) - - (38,571,797) Exchange rate adjustment 741,770 - 1,397,476 18,234 2,157,480 Balance as at 31 December 2024 31,893,514 38,478,587 58,340,373 918,714 129,631,188 Accumulated amortisation and impairment losses Balance as at 01 January 2023 (39,043) - - - (39,043) Change in the perimeter (Note 1.2) - - (1,341,517) - (1,341,517) Depreciation and amortisation for the period (Note 3.7) (263,319) - - - (263,319) Adjustments, transfers and write-offs 274,409 - - - 274,409 Balance as at 31 December 2023 (27,953) - (1,341,517) - (1,369,470) Change in the perimeter (Note 1.2) (4,315,193) - - - (4,315,193) Depreciation and amortisation for the period (Note 3.7) (1,543,687) - (2,500,420) - (4,044,107) Impairment losses for the period (Note 3.6) (145,674) - (145,674) Adjustments, transfers and write-offs 13,089 - - - 13,089 Exchange rate adjustment (138,373) - (30,773) - (169,146) Balance as at 31 December 2024 (6,012,117) (145,674) (3,872,710) - (10,030,501) Net book value as at 1 January 2023 31,940 44,781,151 - - 44,813,091 Net book value as at 31 December 2023 2,691,266 41,502,209 2,004,765 - 46,198,240 Net book value as at 31 December 2024 25,881,397 38,332,913 54,467,663 918,714 119,600,687

The increase in intellectual property and other rights and other intangible assets corresponds to the fair value attributed to the

brands and customer portfolio as part of the process of acquiring the Navigator Tissue UK Group (Note 1.2).

allowances

31-12-2024 31-12-2023 CO2 emission allowances (units) 516,373 494,850 Average unit value (Euro) 74.52 83.87 Market quotation (Euro) 71.57 78.06

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 386

allowances – movements of the period

2024 2023 Amounts in Euro Tons Amount Tons Amount Opening balance 494,850 41,502,209 574,122 44,781,151 CO2 allowances awarded free of charge (Note 2.2) 480,955 35,508,908 473,314 39,687,379 CO2 allowances returned to the Licensing Coordinating Entity (459,432) (38,532,530) (552,586) (42,966,321) Closing balance 516,373 38,478,587 494,850 41,502,209

Accounting policies

Intangible assets are recorded at acquisition cost less depreciation and impairment losses.

The Group carries out impairment tests whenever events or circumstances may indicate that the book value of an asset exceeds

its recoverable amount, being any impairment recognised in the income statement.

Emission Rights

emission Allowances attributed to the Group within the European Union Emissions Trading Scheme (EU ETS) for the

assignment of CO2 emission allowances at no cost, gives rise to an intangible asset for the allowances, a Government grant and a

liability for the obligation to deliver allowances equal to the emissions that have been made during the compliance period.

Emission allowances are only recorded as intangible assets when the Group is able to exercise control and are measured at fair

value (level 1) at the date of initial recognition. When the market value of the emission allowances falls significantly below its book

value and such decrease is considered permanent, an impairment charge is booked for allowances which the group will not use

internally.

The liability to deliver allowances is recognised based on actual emissions. This liability will be settled using allowances on hand,

measured at the book value of those allowances. Any additional emissions are valued at market value as at the reporting date.

FIFO is used in the costing of intangible asset decreases by the refund to the Licensing Coordinating Entity.

In the Consolidated Income Statement, the Group expenses, under Other costs and losses, actual emissions at fair value at the

grant date, except for acquired allowances, where the expense is measured at their purchase price.

Such costs will offset other operating income resulting from the recognition of the original Government grant (also recognised at

fair value at grant date) as well as any disposal of excess allowances.

The effect on the income statement will, therefore, be neutral regarding the consumption of granted allowances. Any net effect on

the Income Statement will result from the purchase of additional allowances to cover excess emissions, from the sale of effective

consumption or from impairment losses booked to allowances that are not used at operational level.

Brands

Whenever brands are identified in a business combination, the Group records them separately in the consolidated financial

statements as an asset at cost, which represents their fair value on the acquisition date.

As at 31 December 2024 and 31 December 2023, the fair value of the brands acquired by the Group was as follows:

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 387

Amounts in Euro 2024 2023 My Tissue 1,257,549 1,257,549 My Tissue Ecologic + 1,142,451 1,142,451 Elegance 6,753,660 - Magnum 8,562,676 - Softy 4,703,442 - Little Heroes 964,809 - 23,384,587 2,400,000

On subsequent valuation exercises, brands are recognised in the Group’s consolidated financial statements at cost. They are not

subject to annual amortisation, but instead tested for impairment at each reporting date.

Own brands are not recognised in the Group’s financial statements, as they represent internally generated intangible assets.

Customer Portfolio

Within the scope of a business combination, whenever identifiable, the Group recognises separately in the consolidated financial

statements as an asset measured at cost the value of the customer portfolio acquired, which corresponds to its fair value on the

acquisition date.

As at 31 December 2024 and 31 December 2023, the customer portfolios acquired were as follows:

Useful lifeUseful lifeAmounts in Euro 2024 2023 2024 2023 Customer portfolio - Consumer tissue business in Spain 1,400,000 1,600,000 7 8 Customer portfolio - Consumer tissue business in the United 52,957,272 - 18 -Kingdom 54,357,272 1,600,000

In the subsequent measurement, the customer portfolio is deducted from the respective amortisations and impairment losses, if

applicable.

The Group carries out impairment tests whenever events or circumstances may indicate that the book value of an asset exceeds

its recoverable amount, being any impairment recognised in the income statement.

Intangible assets developed internally

Development expenses are only recognised as intangible assets to the extent that the technical capacity to complete the

development of the asset is demonstrated and that it is available for own use or commercialisation. Expenses that do not meet

these requirements, namely research expenses, are recorded as costs when incurred.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 388

3.3. Property, plant and equipment

Movements in property, plant and equipment

Buildings and Equipment and other other tangible Assets under Amounts in Euro Land constructions assets construction Total Gross amount Balance as at 1 January 2023 115,774,318 544,499,868 3,727,191,728 92,156,485 4,479,622,399 Change in the perimeter 3,894,076 31,344,927 86,159,207 74,053 121,472,263 Acquisitions - 377,216 9,988,083 172,616,154 182,981,453 Disposals (41,843) (136,266) (357,628) - (535,737) Adjustments, transfers and write-offs 1,967,153 1,142,848 99,693,497 (104,092,298) (1,288,800) Balance as at 31 December 2023 121,593,704 577,228,593 3,922,674,887 160,754,394 4,782,251,578 Change in the perimeter (Note 1.2) - 2,875,637 96,215,441 3,122,596 102,213,674 Acquisitions - - 20,444,600 219,792,614 240,237,214 Disposals (24,289) - (152,538) (15,309) (192,136) Adjustments, transfers and write-offs 4,466,734 5,715,034 164,219,952 (179,727,640) (5,325,920) Exchange rate adjustment - 74,979 2,517,537 92,269 2,684,785 Balance as at 31 December 2024 126,036,149 585,894,243 4,205,220,052 204,718,751 5,121,869,195 Accumulated depreciation and impairment losses Balance as at 1 January 2023 - (381,686,338) (2,998,246,654) - (3,379,932,992) Change in the perimeter - (8,940,894) (31,324,474) - (40,265,368) Depreciation for the period (Note 3.7) - (13,799,813) (116,382,228) (130,182,041) Disposals - 120,107 316,423 - 436,530 Adjustments, transfers and write-offs - 5,228,860 (4,312,776) - 916,084 Balance as at 31 December 2023 - (399,078,078) (3,149,949,709) - (3,549,027,787) Change in the perimeter (Note 1.2) - - (7,088,063) - (7,088,063) Depreciation for the period (Note 3.7) - (14,130,046) (133,405,316) - (147,535,362) Impairments (Note 3.7) - (7,364,638) (308,965) (7,673,603) Disposals - - 27,662 - 27,662 Adjustments, transfers and write-offs - 1,380,299 4,253,777 - 5,634,076 Exchange rate adjustment - (937) (260,096) (261,033) Balance as at 31 December 2024 - (411,828,762) (3,293,786,383) (308,965) (3,705,924,110) Net book value as at 1 January 2023 115,774,318 162,813,530 728,945,074 92,156,485 1,099,689,407 Net book value as at 31 December 2023 121,593,704 178,150,515 772,725,178 160,754,394 1,233,223,791 Net book value as at 31 December 2024 126,036,149 174,065,481 911,433,669 204,409,786 1,415,945,085

As at 31 December 2024, Assets under construction include investments related to ongoing development projects, in particular

the new recovery boiler in Setúbal (Euro 99,388,025), the collection and incineration of NCGs (Non-Condensable Gases) (Euro

9,951,457), oxygen delignification (Euro 3,237,829), the new bleaching tower in Aveiro (Euro 2,500,000), the new cogeneration

plant in Aveiro (Euro 2,500,000), the new Aveiro cogeneration plant (Euro 6,100,607) the new biomass boiler in Vila Velha de

Ródão (Euro 2,951,519), the new Figueira da Foz cogeneration plant (Euro 5,722,951), adapting the firing process for hydrogen

(Euro 3,151,337) and the new biomass lime kiln (Euro 10,981,633) in Figueira da Foz. The remainder is related to several

projects for improving and optimising the production process.

Of the total investment of Euro 240,237,214, approximately 50% relates to investments classified as ESG and Euro 62,926,641

relates to investments under the Recovery and Resilience Plan (RRP).

Lands includes Euro 116,798,934 (31 December 2023: Euro 115.903.357) classified in the individual financial statements as

investment properties, from which Euro 79,989,817 (31 December 2023: Euro 76,765,242) relate to forestry land and Euro

36,945,028 (31 December 2023: Euro 39,138,115) to land allocated to industrial sites.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 389

In 2024, the Group decided to proceed with the pre-engineering project for the rebuild of the PM3 machine in Setúbal, with the

aim of converting the current production of high-grammage products into the production of more high-quality and efficient low-

grammage products (LBW - Low Basis Weight), the market segment with the greatest potential for growth in replacing plastic.

Accordingly, an impairment loss of Euro 7,116,061 was recognised on the entire net book value of PM3 as at 31 December 2024.

The commitments assumed by the Group for the acquisition of property, plant and equipment are detailed in Note

10.2 - Commitments.

Estimates and judgements

Recoverability of Property, plant and equipment

The recoverability of property, plant and equipment requires the Board of Directors to use estimates and assumptions, namely,

whenever applicable, regarding the determination of the value in use for impairment tests to the Group's cash-generating units.

Useful life and depreciation

Property, plant and equipment present the most significant component of the Group's total assets. These assets are subject to

systematic depreciation for the period that is determined to be their economic useful life. The determination of assets useful lives

and the depreciation method to be applied is essential to determine the amount of depreciation to be recognised in the

consolidated income statement of each period.

These two parameters are defined according to the best judgement of the Board of Directors for the assets and businesses in

question, also considering the practices adopted by companies of the sector at the international level and the evolution of the

economic conditions in which the Group operates.

Under IFRS, the estimate of the useful lives of assets should be reviewed if expectations regarding the expected economic benefits

as well as the technical use planned for the assets differ from previous estimates. Changes resulting in depreciation charges for

the period are accounted for prospectively.

Given the importance of this estimate, the Group uses, with some regularity, external and independent experts to assess the

adequacy of the estimates used having the last report been completed during the second half of 2024, with reference to 1 January

2024, with no significant impact on the Group's useful lives.

Accounting policies

Property, plant and equipment

Recognition and initial measurement

Property, plant and equipment are shown at cost, less accumulated depreciation and impairment losses.

Depreciation and impairment

We use the straight-line method from the moment the asset is available for use and using the rates that best reflect their

estimated useful life.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 390

Average useful lifeAverage useful life2024 2023 Land (cost of preparing for afforestation) 50 50 Buildings and other constructions 10 – 30 10 – 30 Basic equipment 4 – 20 4 – 20 Transportation equipment 4 – 9 4 – 9 Tools 2 – 8 2 – 8 Administrative equipment 4 – 8 4 – 8 Other property, plant and equipment 4 – 10 4 – 10

The residual values of the assets and respective useful lives are reviewed and adjusted, on the date of the consolidated statement

of financial position. If there are changes to useful lives, they are treated as a change in accounting estimate and are applied

prospectively.

When the book value of the asset exceeds its realisable value, the asset is written down to the estimated recoverable amount, and

an impairment charge is booked (Note 3.7).

Subsequent costs

Scheduled maintenance expenses are considered a component of the acquisition cost of property, plant and equipment and are

fully depreciated by the next forecasted maintenance date.

All other repairs and maintenance costs are charged to the income statement in the financial period in which they are incurred.

Spare and maintenance parts

Spare parts are considered strategic as they are directly related to production equipment and their use is expected to last for

more than two economic years. Maintenance parts considered as “critical spare parts” are recorded under non-current assets, as

Property, plant and equipment. In accordance with this classification, spare parts are depreciated from the moment they become

available for use and are assigned a useful life that follows the nature of the equipment, where they are expected to be

integrated, not exceeding the remaining useful life of these.

Spare parts are accounted for as property, plant and equipment if they are material and used for more than one period, or if they

are used only in relation to an item of property, plant and equipment. In other situations, spare parts are accounted for as part of

inventories and recognized in the period when consumed.

Borrowing costs

Borrowing costs directly related to the acquisition or construction (if the construction or development period exceeds one year) of

property, plant and equipment are capitalised and form part of the asset’s cost.

During the periods presented, no financial charges for loans directly related to the acquisition or construction of property, plant

and equipment were capitalised.

Write-offs and disposals

Gains or losses arising from write-offs or disposals are determined by the difference between the proceeds from the disposals

when applicable less transaction costs and the carrying amount of the asset and are recognised in the income statement as Other

operating income (Note 2.2) or Other operating expenses (Note 2.3).

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 391

3.4. Investment properties

Movement in investment properties

Buildings and Amounts in Euro other Land constructions Total Gross amount Balance as at 1 January 2023 424,744 82,307 507,051 Acquisitions - - - Impairment losses - - - Disposals - - - Adjustments, transfers and write-offs 142,288 530,684 672,972 Balance as at 31 December 2023 567,032 612,991 1,180,023 Acquisitions - - - Disposals (25,371) (82,308) (107,679) Adjustments, transfers and write-offs - - - Balance as at 31 December 2024 541,661 530,683 1,072,344 Accumulated depreciation and impairment losses Balance as at 1 January 2023 (399,372) (16,735) (416,107) Depreciation for the period (Note 3.7) - - - Disposals - - - Impairment losses (Note 3.7) - (1,646) (1,646) Adjustments, transfers and write-offs - (298,866) (298,866) Balance as at 31 December 2023 (399,372) (317,247) (716,619) Depreciation for the period (Note 3.7) - - - Disposals - 19,480 19,480 Impairment losses (Note 3.7) - (15,035) (15,035) Adjustments, transfers and write-offs - - - Balance as at 31 December 2024 (399,372) (312,802) (712,174) Net book value as at 1 January 2023 25,372 65,572 90,943 Net book value as at 31 December 2023 167,660 295,744 463,404 Net book value as at 31 December 2024 142,289 217,881 360,170

The amount for adjustments, transfers and write-offs as at 31 December 2023 pertains to the building at Rua São José 35, 2º - A

Lisboa 1150-321. The building is owned by the subsidiary Empremédia – Corretores de Seguros, S.A. It is no longer used for the

Group's operational activity since the transfer of this subsidiary's employees to the Navigator building on Avenida Fontes Pereira

de Melo.

These assets are not allocated to the Group's operating activity, nor do they have any future use determined.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 392

3.5. Government grants

Government grants - movements

2024 2023 Amounts in Euro Financial Tax Total Financial Tax Total Opening balance 99,667,539 16,234,048 115,901,587 15,916,110 17,900,449 33,816,559 Allocation 8,765,668 - 8,765,668 85,800,391 - 85,800,391 Charge-off (Note 3.7) (3,056,921) (1,666,401) (4,723,322) (2,048,962) (1,666,401) (3,715,363) Closing balance (Note 4.3) 105,376,286 14,567,647 119,943,933 99,667,539 16,234,048 115,901,587

The allocations for the period relate to the sums allocated under the mobilizing agendas of the Recovery and Resilience Plan

(RRP).

Only Euro 43,952,298 of the amount allocated was received in the period, (Euro 27,529,156 as at 31 December 2023) as

reflected in the Statement of Cash Flows.

As at 31 December 2024 and 2023, government grants, by company, were detailed as follows:

2024 2023 Amounts in Euro Financial Tax Total Financial Tax Total AICEP investment contracts Enerpulp, S.A. 105,727 - 105,727 179,890 - 179,890 Navigator Pulp Aveiro, S.A. 1,806,126 721,286 2,527,412 2,781,642 1,138,676 3,920,318 Navigator Pulp Setúbal, S.A. - - - 19,692 - 19,692 Navigator Pulp Figueira, S.A. 144,135 6,755,137 6,899,272 5,293 7,465,212 7,470,505 Navigator Parques Industriais, S.A. 1,691,570 - 1,691,570 1,750,927 - 1,750,927 Navigator Tissue Aveiro, S.A. 2,429,628 7,091,224 9,520,852 2,612,638 7,630,160 10,242,798 6,177,186 14,567,647 20,744,833 7,350,082 16,234,048 23,584,130 Under the Recovery and Resilience Plan Navigator Forest Portugal, S.A. 36,510 - 36,510 36,510 - 36,510 Viveiros Aliança, SA 18,161 - 18,161 20,800 - 20,800 Navigator Tissue Aveiro, S.A. 11,968,393 - 11,968,393 12,016,780 - 12,016,780 Navigator Paper Setúbal, S.A. 10,966,135 - 10,966,135 10,980,533 - 10,980,533 Navigator Pulp Aveiro, S.A. 17,752,757 - 17,752,757 18,692,916 - 18,692,916 Navigator Pulp Setúbal, S.A. 21,480,000 - 21,480,000 21,480,000 - 21,480,000 Navigator Tissue Ródão S.A. 8,462,427 - 8,462,427 - - - Navigator Pulp Figueira, S.A. 16,408,219 - 16,408,219 16,408,219 - 16,408,219 Navigator Paper Figueira, S.A. 4,621,122 - 4,621,122 4,621,122 - 4,621,122 Raiz 2,048,251 - 2,048,251 2,157,854 - 2,157,854 93,761,975 - 93,761,975 86,414,734 - 86,414,734 Other Navigator Pulp Setúbal, S.A. 4,488,046 - 4,488,046 4,488,046 - 4,488,046 Raiz 949,079 - 949,079 1,154,590 - 1,154,590 Viveiros Aliança, SA - - - 11,610 - 11,610 Navigator Tissue Ejea, S.L. - - - 248,477 - 248,477 5,437,125 - 5,437,125 5,902,723 - 5,902,723 105,376,286 14,567,647 119,943,933 99,667,539 16,234,048 115,901,587

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 393

The Group expects to recognise grants in profit/(loss) as follows:

2024 2023 Amounts in Euro Financial Tax Total Financial Tax Total 2024 - - - 1,685,836 1,666,401 3,352,237 2025 2,543,940 1,398,687 3,942,627 1,335,087 1,398,687 2,733,774 2026 2,424,840 1,390,347 3,815,187 1,215,985 1,390,347 2,606,332 2027 1,787,665 1,390,304 3,177,969 585,137 1,390,304 1,975,441 2028 1,756,644 1,390,304 3,146,948 572,417 1,390,304 1,962,721 2029 1,517,326 1,209,424 2,726,750 - - - After 2029 95,345,871 7,788,581 103,134,452 94,273,077 8,998,005 103,271,082 105,376,286 14,567,647 119,943,933 99,667,539 16,234,048 115,901,587

Non-repayable Government grants

Incentive to increase pulp production capacity in Figueira da Foz

On 27 December 2018, Navigator Pulp Figueira, S.A signed a tax investment agreement with AICEP, related to the investment

associated with the increase of pulp production capacity in Figueira da Foz, which includes a tax incentive up to the maximum

amount of Euro 17,278,657, corresponding to 19.5% of the investment made, through the fulfilment, until 31 December 2025 of

the contractually defined objectives. This grant, drawn on by the subsidiary to the amount of Euro 14,437,235, is being recognised

over 20 years, until 2038, in proportion to the depreciation of the assets, although it has been fully utilised since 2018, by means

of a tax rebate.

Incentives for the expansion project of the Cacia pulp mill

On 18 June 2014, the Group’s subsidiary, Navigator Pulp Aveiro, S.A., signed two financial and tax incentive agreements with the

AICEP – Agência para o Investimento e Comércio Externo de Portugal (Agency for Investment and Foreign Trade of Portugal),

effective until 2023 and 2024, respectively, to support the investment to be promoted by that company in the capacity increase

project of Aveiro pulp mill, with a total amount of Euro 49.3 million.

The approved grants amount to Euro 9.753 million (repayable) and Euro 5.644 million (tax incentive). This amount has been fully

utilised since 2016 and will be recognised in profit/(loss) in 20 years, until 2034. The contract includes an achievement bonus

already recognised in the balance sheet and received in April 2024, which corresponds to the conversion of 75% of the repayable

grant in a non-repayable grant, in the amount of Euro 7,314,397, subject to compliance with the objectives established in the

contract.

In March 2014, the subsidiary Navigator Tissue Ródão, S.A. signed investment contracts with AICEP - Agência para o

Investimento e Comércio Externo de Portugal (Agency for Investment and Foreign Trade of Portugal), effective between 2014 and

2022, for the construction of a second tissue paper machine at its Vila Velha de Ródão unit, with the aim of contributing part of

the investment through EU funds by means of refundable financial incentives amounting to Euro 9,647,700, convertible into non-

refundable incentives, up to a limit of 50%, i.e. Euro 4,823,850.

The incentive should have been paid in two instalments, on 31 December 2016 and 31 December 2018, however on 31 December

2024 the amount of Euro 2,407,395 remains to be received (Note 4.2).

Grant to the Setúbal Lime Kiln Conversion project

As part of the Carbon Neutrality Roadmap, the Group has signed a financial investment contract with the European Union to support

investment by Navigator Pulp Setúbal in the conversion of the lime kiln at the Setúbal pulp mill, with a planned total investment of

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 394

Euro 7,500,000. The maximum approved grant amounts to Euro 4,488,046 and will be paid through a single non-repayable

instalment, up to the end of the third year of operation of the equipment, which is expected to begin in the third quarter of 2025.

Recovery and Resilience Plan

The Navigator Group is involved in four Agendas for Business Innovation of the Recovery and Resilience Plan (RRP), through

investment of Euro 91.8 million. The Group, through Navigator Paper Setúbal, S.A., is leading the “From Fossil to Forest” (FF2F)

Agenda, whose main goal is to develop a range of packaging solutions—focused on the gKRAFT brand to be launched in 2021—and

the production of micro fibrillated cellulose for developing mechanical properties and functional barriers (to fats and liquids, amongst

others) in these papers. In total, the Group will benefit from support of around Euro 25.9 million from this component of the RRP

(C5 - Corporate Capitalization and Innovation).

During 2022, the Group companies Navigator Paper Setubal, S.A., Navigator Pulp Setúbal, S.A., Navigator Paper Figueira, S.A.,

Navigator Pulp Figueira, S.A., Navigator Pulp Aveiro, S.A. and Navigator Tissue Aveiro, S.A. applied for “Apoio à Descarbonização

da Indústria” (Support for Decarbonisation of Industry) under the RRP. This support is part of a set of measures under Component

11 (C11) of the RRP, which aims to contribute to the goal of carbon neutrality by promoting energy transition through energy

efficiency, support for renewable energy, focusing on the adoption of low-carbon processes and technologies in industry, the adoption

of energy efficiency measures in industry and the incorporation of energy from renewable sources and energy storage. Recently,

this was extended to a second phase of application, in which Navigator Tissue Ródão S.A., like the other companies, presented a

series of initiatives related to its carbon neutrality. In the future, the Group expects to invest Euro 173.1 million in these initiatives,

of which it hopes to receive Euro 75.8 million in funding.

Also in 2022, Group companies applied for RRP incentives for the “Rede Nacional de Test Bed” (National Test Bed Network), which

aims to create a national network providing services to companies for the development and testing of new products and services.

The application, involving an investment of Euro 2.2 million, was approved at the end of the year and IAPMEI decided to award

Navigator Pulp Figueira. S.A. Euro 1.4 million.

However, the Group's participation in the RRP is not complete without RAIZ's participation in Component 12 of the RRP, related to

the Bioeconomy, where it plans to invest Euro 1.7 million and receive an incentive of Euro 1.4 million to accelerate, in partnership

with CITEVE and other 52 promoters, the creation of high value-added products from biological resources as an alternative to

fossil-based materials, while maintaining and even improving quality standards, with great potential in different market segments.

Repayable government grants

On 13 December 2017, the subsidiary Navigator Tissue Aveiro, S.A. entered into an investment agreement with AICEP, effective

until 2026, for the construction of the new tissue mill in Aveiro. This agreement comprises a financial incentive in the form of a

repayable grant, which includes a grace period of two years, without payment of interest, up to a maximum amount of Euro

42,166,636, corresponding to 35% on the amount of expenses considered eligible, which were estimated at Euro 120,476 million.

As at 31 December 2024, the repayable grant has been fully received.

On 20 April 2018, the same entity was also awarded with a tax incentive granted through the compliance of contractually defined

requirements until 31 December 2028, whose maximum amount will be Euro 11,515,870, corresponding to 10% of the expenses

associated with the project investment. See Note 5.7. This amount has been fully utilised since 2019 and will be recognised in

profit/(loss), on average, in 24 years, until 2043.

There are no unfulfilled conditions and other contingencies linked to Government grants that have been recognised and Navigator

is complying with the conditions according to plan.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 395

Accounting policies

Government grants

Government grants received to compensate the Group for investments made in Property, plant and equipment,

including those attributed as tax credits, are classified as Deferred income (Note 4.3 - Payables) and are recognised in income

over the estimated useful life of the respective subsidised assets, and are associated with the depreciation of the period (Note

3.7), for presentation purposes.

Repayable government grants

Government grants, in the form of repayable loans at a subsidised rate, are discounted on the date of initial recognition based on

the market interest rate at the date of grant, the value of the discount constituting the value of the grant to be amortised over the

period of the loan or asset whose acquisition it is intended to finance, depending on the activities financed. These liabilities are

included in the caption Interest-bearing liabilities (Note 5.7). Grants received are classified as a financing activity in the statement

of cash flows.

3.6. Right-of-use assets

Movements in right-of-use assets

Forestry Software Other lease Amounts in Euro lands Buildings Vehicles licenses assets Total Gross amount Balance as at 1 January 2023 58,830,098 4,655,055 11,577,961 1,556,613 9,420,387 86,040,114 Acquisitions 11,116,077 53,744 3,069,783 - 1,764,073 16,003,677 Adjustments, transfers and write-offs - (356,397) (2,711,330) (342,519) - (3,410,246) Balance as at 31 December 2023 69,946,175 4,352,402 11,936,414 1,214,094 11,184,460 98,633,545 Change in the perimeter (Note 1.2) - 930,133 276,256 175,801 42,512,894 43,895,084 Acquisitions 5,630,367 117,679 4,275,979 35,253 5,340,453 15,399,731 Adjustments, transfers and write-offs (1,344,968) (7,922) (1,365,244) (49,559) (3,902,749) (6,670,442) Exchange rate adjustment 24,252 7,613 3,823 1,092,764 1,128,452 Balance as at 31 December 2024 74,231,574 5,416,544 15,131,018 1,379,412 56,227,822 152,386,370 Accumulated depreciation and impairment losses (12,821,764(28,105,273Balance as at 1 January 2023 (2,400,948) (7,281,667) (1,113,577) (4,487,317) ) ) Depreciation (Note 3.7) (3,961,429) (520,165) (2,532,286) (350,435) (2,102,841) (9,467,156) Adjustments, transfers and write-offs 356,397 3,240,702 342,519 43,721 3,983,339 Exchange rate adjustment - - - - - - (16,783,193(33,589,090Balance as at 31 December 2023 (2,564,716) (6,573,251) (1,121,493) (6,546,437) ) ) Change in the perimeter (Note 1.2) (681,574) (72,706) (142,632) (11,119,701) (12,016,613) Depreciation (Note 3.7) (4,219,898) (695,288) (2,517,949) (154,255) (5,582,615) (13,170,005) Adjustments, transfers and write-offs 1,344,968 7,922 1,252,660 49,559 2,715,166 5,370,275 Exchange rate adjustment (20,060) (2,765) (3,364) (303,582) (329,771) (19,658,123(20,837,169(53,735,204Balance as at 31 December 2024 (3,953,716) (7,914,011) (1,372,185) ) ) ) Net book value as at 1 January 2023 46,008,334 2,254,107 4,296,294 443,036 4,933,070 57,934,840 Net book value as at 31 December 2023 53,162,982 1,787,686 5,363,163 92,601 4,638,023 65,044,454 Net book value as at 31 December 2024 54,573,451 1,462,828 7,217,007 7,227 35,390,653 98,651,166

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 396

The caption Forestry Lands relates essentially to the land use rights of existing forest exploration, whose agreements usually have

a duration of 24 years, and may be cancelled in advance if the 2

harvest takes place before the 24

year of the agreement term.

The caption Buildings refers to the lease agreement entered into between The Navigator Company, S.A. e a MaxiRent - Fundo de

Investimento Imobiliário Fechado for the building located at Avenida Fontes Pereira de Melo, in Lisbon, for use as an office until

May 2027.

Other lease assets include the Navigator Tissue UK Group's rental contracts for forklifts, warehouses and converting equipment.

Cash flows associated with lease payments correspond to the financial amortisation of Euro 11,764,677 and interest of Euro

3,896,924 (Note 5.10), amounting to Euro 15,661,601, as shown in the Statement of Cash Flows.

Accounting policies

At the date the lease enters into force, the Group recognises a right-of-use asset at its cost, which corresponds to

the initial amount of the lease liability adjusted for: i) any prepayments; ii) lease incentives received; and iii) initial

direct costs incurred.

To the right-of-use asset, the estimate of removing and/or restoring the underlying asset and/or the location where it is located

may be added, when required by the lease agreement.

The right-of-use asset is subsequently depreciated using the straight-line method, from the start date until the lower between the

end of the asset's useful life and the lease term. Additionally, the right-of-use asset reduced of impairment losses, if any, and

adjusted for any remeasurement of the lease liability. The useful life considered for each class of right-of-use asset is equal to the

useful life of Property, plant and equipment (Note 3.3) in the same class when there is a call option, and the Group expects to

exercise it.

Short-term leases and low-value asset leases

The Group recognises payments for leases of 12 months or less and for leases of assets whose individual acquisition value is less

than Euro 5,000 directly as operating expenses of the period (Note 2.3), on a straight-line basis.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 397

3.7. Depreciation, amortisation and impairment losses

Amounts in Euro 2024 2023 Depreciation of property, plant and equipment for the period (Note 3.3) 147,535,362 130,182,041 Charge-off of investments grants (Note 3.5) (4,723,322) (3,715,363) Depreciation of property, plant and equipment, net of grants charged-off 142,812,040 126,466,678 Impairment of property, plant and equipment - losses (Note 3.3) 7,673,603 - Impairment of property, plant and equipment for the period 7,673,603 - Amortisation of intangible assets for the period (Note 3.2) 4,044,107 263,319 Impairment on intangible assets – losses 145,673 - Impairment of intangible assets for the period (Note 3.2) 145,673 - Depreciation of right-of-use assets for the period (Note 3.6) 13,170,005 9,467,156 Impairment of investment properties (Note 3.4) 15,035 1,646 167,860,464 136,198,800

The Group regularly uses external and independent experts to assess its industrial assets, as well as to assess the adequacy of the

estimates used in terms of the useful lives of these assets.

In 2024, the Group requested an external valuation of its assets by an independent and specialised entity, which estimated the

useful life of the assets, considering current conditions and functional obsolescence. The study took into account technical

information on the assets allocated to the production centres, including the technical, physical and technological durability of the

equipment, but no significant differences were identified between the estimated useful lives and those practised by the Group,

other than those referred to in Note 3.3.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 398

3.8. Biological assets

Movements in biological assets

Amounts in Euro 2024 2023 Opening balance 115,591,979 122,499,875 Logging (22,275,720) (23,005,571) Growth 25,895,749 27,648,002 New planted areas and replanting 3,091,316 3,871,701 Other changes in fair value - change in the price of wood 21,818,100 15,908,400 - change in the cost-of-capital rate 6,890,813 (238,400) - impact of forest fires (3,030,511) (1,386,701) - changes in other species 554,567 (2,235,892) - transport logistics costs (24,407,600) (8,928,000) - fixed structure costs (3,253,000) (10,505,800) - other changes in expectations (6,299,966) (8,035,635) Total changes (1,016,252) (6,907,896) Exchange rate adjustment 674,471 - Closing balance 115,250,198 115,591,979

The Navigator Group considers, in accordance with IAS 41, mature assets to be those that have reached the necessary

specifications to obtain the maximum yield based on their profitability, supply needs and opportunity cost. Typically, the forest in

Portugal reaches its maturity between 8 and 12 years, and this reference depends on the species, soil conditions, as well as

edaphoclimatic conditions. Data on the forest, its condition and its future potential are measured at least twice throughout its

growth cycle. As at 31 December 2024, mature assets accounted for approximately 52% (53% in 31 December 2023) of

Navigator’s forest in Portugal, being recognised at fair value.

As at 31 December 2024 and 31 December 2023, biological assets, by species, is detailed as follows:

Amounts in Euro 2024 2023 Eucalyptus (Portugal) 85,569,146 88,244,919 Eucalyptus (Spain) 3,081,361 1,628,022 Pine (Portugal) 5,798,144 5,898,445 Cork oak (Portugal) 1,490,017 835,149 Other species (Portugal) 73,107 73,107 Eucalyptus (Mozambique) 19,238,423 18,912,337 115,250,198 115,591,979

The decrease in the fair value of Eucalyptus and Pine is mainly due to the effects of increased costs for cutting, replanting and

transportation.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 399

These amounts correspond to Board of Directors’ expectation of the volumes to be extracted from its woodlands in the future, as

follows:

Amounts in Euro 2024 2023 3 Eucalyptus (Portugal) – Potential future of wood extractions k mssc 9,909 10,447 3 Eucalyptus (Spain) - Potential future of wood extractions k mssc 244 252 Pine (Portugal) – Potential future of wood extractions k ton 282 290 Cork oak (Portugal) – Potential future of cork extractions k @ 458 488 3 Eucalyptus (Mozambique) – Potential future of wood extractions k mssc 5,165 3,570

Concerning Eucalyptus, the most relevant biological asset in the financial statements, the Group extracted, in 2024, 611,862

ssc of wood from its owned and explored forests (31 December 2023: 594,709 m

ssc).

As at 31 December 2024 and 2023, (i) there are no amounts of biological assets whose property is restricted and/or pledged as

guarantee for liabilities, nor there are non-reversible commitments related to the acquisition of biological assets, and (ii) there are

no government grants related to biological assets recognised in the Group's consolidated financial statements.

Estimates and judgements

Assumptions

Assumptions corresponding to the nature of the assets being valued were considered:

• Productivity of forests;

• Wood sales price (when there is an active market) less the cost of harvesting, rents for own, rented and leased land,

replanting and transport, planting and maintenance costs, the cost inherent in leasing forest land; the trend value for 2024

worsened by 6% compared to 2023.

• Discount rate, 2024: 4.27% (2023: 5.19 %) for Portugal and Spain and 21.6% (2023:13.55%) in determining the fair

value of Mozambique. In 2024, the Group started to determine the fair value of biological assets in meticals, which implied

an increase in the discount rate compared to the previous year due to the incorporation of the risk associated with that

currency. Note that the group incorporates the fire risk into the model's cash flows. If this risk were incorporated into the

discount rate, it would be of 6.51% and 22.22%, in Portugal and Mozambique, respectively.

Sensitivity analysis

The Group takes into account the discount rate used in Portugal and Mozambique and the forward price of wood as the most

significant variables.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 400

Changes in the assumptions may imply the appreciation/depreciation of these assets:

Amounts in Euro 2024 2023 1) Increase of 0.5% in the discount rate in Portugal 5,868,859 5,990,023 Depreciation of Portugal's forest assets 2) Decrease of 3% in forward price 11,978,891 10,733,022 Depreciation of Portugal's forest assets 3) Increase of 0.5% in the discount rate in Mozambique 206,777 244,194 Depreciation of Mozambique's forest assets 4) Decrease of 3% in forward price 769,860 776,149 Depreciation of Mozambique's forest assets

Accounting policies

The Group’s biological assets comprise the forests held for the production of timber, suitable for incorporating in the

production of BEKP or for sale on the market, mostly eucalyptus, but also include other species such as pine and

cork oak.

Forest land owned by the Group is included in Property, plant and equipment in the consolidated balance sheet and is valued in

accordance with the accounting policy described in Note 3.3. Forest land that is not owned by the Navigator Group and that is

leased is valued in accordance with the accounting policy described in Note 3.6 and is presented in the consolidated balance sheet

under “Right-of-use assets”.

Fair Value (level 3 of the IFRS 13 fair value hierarchy)

When calculating the fair value of forests, the Group uses the discounted cash flows method, based on a model developed in

house, regularly tested by independent external assessments.

In the model developed, assumptions are considered corresponding to the nature of the assets being assessed, namely, the

development cycle of the different species, the productivity of the forests, climate and other environmental considerations, the

wood sales price (when there is an active market) less the cost of harvesting, the rents of own, leased land, replanting and

transport, the costs of planting and maintenance, the cost inherent in leasing the forest land, and the discount rate.

The main unobservable inputs of the fair value model are detailed as follows, and the amount of the fair value of biological assets

will increase / (decrease) respectively if:

• Wood sales prices increase / (decrease);

• Estimated cutting, replanting and transport costs decrease / (increase);

• Estimated planting and maintenance costs decrease / (increase); and

• The discount rate decrease / (increase).

The discount rate corresponds to a market rate without inflation, in a manner consistent with the structure of forecasts,

determined on the basis of the Navigator Group’s expected rate of return on its forests, which are intended to be sold intragroup.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 401

Concession areas

The costs incurred with the site preparation before the first forestation are recorded as property, plant and equipment and

depreciated in line with its expected useful lives corresponding to the concession period.

Change of estimates

Changes in estimates of growth, growth period, price, cost and other assumptions are recognised in the income statement as fair

value adjustments of biological assets.

Harvesting

At the time of harvesting, wood is recognised at fair value less estimated costs since that point until the point of sale, which is the

initial cost of the inventory.

4. Working capital

4.1. Inventories

4.1.1. Inventories - detail by nature

Amounts net of accumulated impairment losses

2024 2023 net realisable net realisable Amounts in Euro Gross amount Impairment value Gross amount Impairment value Raw materials 166,750,856 (8,473,131) 158,277,725 157,488,326 (9,121,113) 148,367,213 Goods 117,304 (25,591) 91,713 863,897 (20,222) 843,675 Subtotal (Note 4.1.4) 166,868,160 (8,498,722) 158,369,438 158,352,223 (9,141,335) 149,210,888 Finished and intermediate 147,341,926 (5,882,791) 141,459,135 139,515,678 (4,540,071) 134,975,607 products Goods and work in progress 3,410,862 (296,503) 3,114,359 2,254,789 (252,405) 2,002,384 By-products and waste 5,507,278 (5,251,843) 255,435 6,949,626 (6,648,143) 301,483 Subtotal (Note 4.1.3) 156,260,066 (11,431,137) 144,828,929 148,720,093 (11,440,619) 137,279,474 Total 323,128,226 (19,929,859) 303,198,367 307,072,316 (20,581,954) 286,490,362

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 402

Inventories of finished and intermediate products - distribution by geographical area

Amounts in Euro 2024 % 2023 % Portugal BEKP pulp 11,414,966 8.07% 28,177,344 20.88% UWF Paper 49,648,137 35.10% 42,911,373 31.79% Tissue Paper 18,818,456 13.30% 13,888,808 10.29% Other - 0.00% 2,780 0.00% 79,881,559 56.47% 84,980,305 62.96% Rest of Europe BEKP pulp 4,204,139 2.97% 3,033,932 2.25% UWF Paper 5,624,482 3.98% 4,357,667 3.23% Tissue Paper 19,397,059 13.71% 7,357,575 5.45% 29,225,680 20.66% 14,749,174 10.93% USA UWF Paper 29,715,421 21.01% 35,246,128 26.11% 29,715,421 21.01% 35,246,128 26.11% South Africa UWF Paper 2,636,475 1.86% - 0.00% 2,636,475 1.86% - 0.00% 141,459,135 100.00% 134,975,607 100.00%

Finished and intermediate products inventories include Euro 10,358,907 (31 December 2023: Euro 14,968,097) relating to

inventories for which invoices have already been issued but whose control has not been transferred to Trade receivables.

As at 31 December 2024 and 2023, there are no inventories in which ownership is restricted and/or pledged as collateral for

liabilities.

4.1.2. Cost of goods sold and materials consumed in the period

Amounts in Euro 2024 2023 Opening balance 149,210,888 141,167,998 Initial impairment 9,141,335 - Purchases 904,798,029 863,642,634 Changes in the perimeter (14,152,590) (3,547,108) Inventory losses (1,168,179) (2,706,600) Impairment losses - (830,373) Exchange rate effect (412,836) - Closing balance (166,868,160) (149,210,888) Cost of goods sold and materials consumed (Note 2.3) 880,548,487 848,515,663

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 403

Cost of goods sold and materials consumed - detail by product

Amounts in Euro 2024 2023 Wood / Biomass 378,528,137 388,844,251 Natural gas 36,750,618 56,364,087 Other fuels 18,570,993 41,318,258 Chemicals 171,452,982 195,611,087 BEKP pulp 20,285,603 21,844,319 Pine pulp 40,749,985 25,497,073 Paper (heavyweight) 4,712,779 4,855,216 Tissue paper (Reels) 92,789,681 155,699 Consumables / Warehouse material 35,667,390 33,637,240 Packaging material 79,725,432 78,922,743 Other materials 1,314,887 1,465,690 880,548,487 848,515,663

The cost of wood / biomass only relates to wood purchases to entities outside the Group, either domestic or foreign.

In 2024, the increase in the cost of tissue paper is essentially due to the incorporation of the Navigator Tissue UK Group.

4.1.3. Variation in production in the period

Amounts in Euro 2024 2023 Opening balance (137,279,474) (157,561,219) Initial impairment (11,440,619) - Adjustments (1,886,593) (450,088) Changes in the perimeter (11,422,914) (7,654,533) Inventory losses 2,568,511 1,662,449 Impairment losses - 3,004,118 Exchange rate effect (298,785) - Closing balance 156,260,066 137,279,474 Variation in production (Note 2.3) (3,499,808) (23,719,799)

4.1.4. Movements in impairment losses in inventories

Amounts in Euro 2024 2023 Opening balance (20,581,954) (16,374,423) Increases (Note 2.3) (3,165,457) (4,152,419) Reversals (Note 2.2) 5,068,999 317,928 Impact in profit/(loss) for the period 1,903,542 (3,834,491) Perimeter inputs (1,192,426) - Exchange rate effect (35,719) - Charge-off (23,302) (373,040) Closing balance (19,929,859) (20,581,954)

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 404

As mentioned in note 2.3, the increase in impairment losses in inventories essentially include the recognition of Euro 1,724,970 in

impairment losses for UWF and tissue paper waste and Euro 1,248,818 for slow movers. In 2023, this caption mainly includes the

recognition of an impairment of Euro 2,071,836 for the inventory of damaged paper identified on the platform of Navigator North

America Inc..

Accounting policies

Inventories are valued in accordance with the following criteria:

i. Goods and raw materials

Goods and raw, subsidiary and consumable materials are valued at the lower of their purchase cost or their net realisable value.

The purchase cost includes ancillary costs and it is determined using the weighted average cost as the valuation method.

ii. Finished and intermediate products and work in progress

Finished and intermediate products and work in progress are valued at the lower of their production cost (which includes

incorporated raw materials, labour and general manufacturing costs, based on a normal production capacity level) or their net

realisable value.

The net realisable value corresponds to the estimated selling price, after deducting estimated completion and selling costs. The

difference between production cost and net realisable value, if lower, are recorded as an operational cost.

4.2. Receivables

2024 2023 Non-Non-Amounts in Euro current Current Total current Current Total Trade receivables - 305,042,497 305,042,497 - 259,060,841 259,060,841State - 57,969,739 57,969,739 - 57,026,840 57,026,840 Grants receivable 10,684,900 56,582,606 67,267,506 39,821,344 52,821,895 92,643,239 Department of Commerce (EUA) 718,183 - 718,183 2,872,289 - 2,872,289 Accrued income - 17,223,776 17,223,776 - 12,304,428 12,304,428 Deferred expenses - 19,981,490 19,981,490 - 14,955,574 14,955,574 Derivative financial instruments (Note 8.2) - 21,022,301 21,022,301 - 19,458,938 19,458,938 Other 1,739,854 18,876,212 20,616,066 1,705,873 9,112,457 10,818,330 13,142,937 496,698,621 509,841,558 44,399,506 424,740,973 469,140,480

State

State is detailed as follows:

Amounts in Euro 2024 2023 Value added tax - recoverable 10,943,833 4,299,693 Value Added Tax - repayment requests 47,025,906 52,727,147 57,969,739 57,026,840

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 405

As at 31 December 2024, the amount of repayment requests comprised the following, by company and by month:

Amounts in Euro Nov/2024 Dec/2024 Total The Navigator Company, S.A. 25,926,796 14,349,110 40,275,906 Navigator Tissue Ródão, S.A. - 1,940,000 1,940,000 Navigator Abastecimento de Madeira, A.C.E. 440,000 - 440,000 Navigator Paper Setúbal, S.A. - 1,700,000 1,700,000 Navigator Pulp Setúbal, S.A. - 1,970,000 1,970,000 Navigator Pulp Figueira, S.A. - 700,000 700,000 26,366,796 20,659,110 47,025,906

Up to the date of issuing this report, the outstanding amounts as at 31 December 2024, had already been received.

As at 31 December 2023, the amount of repayment requests comprised the following, by company and by month:

Amounts in Euro Nov/2023 Dec/2023 Total The Navigator Company, S.A. 14,904,962 24,056,600 38,961,562 Navigator Tissue Ródão, S.A. 1,500,000 - 1,500,000 Navigator Paper Figueira S.A. 9,000,000 - 9,000,000 Bosques do Atlântico, S.L. - 3,265,585 3,265,585 25,404,962 27,322,185 52,727,147

All these amounts were received during the first half of 2024.

Grants receivable

Grants receivable are detailed as follows:

2024 2023 Non-Non-Amounts in Euro current Current Total current Current Total AICEP Contracts - 2,407,395 2,407,395 - 9,721,792 9,721,792 Recovery and Resilience Plan 6,738,024 53,054,466 59,792,490 37,890,496 37,890,496 75,780,992 Other 3,946,876 1,120,745 5,067,621 1,930,848 5,209,607 7,140,455 10,684,900 56,582,606 67,267,506 39,821,344 52,821,895 92,643,239

The amount of Euro 2,407,395 (Note 3.5) receivable from AICEP corresponds to the second instalment of the non-repayable grant

awarded under the investment incentive for the construction of the second tissue paper machine at its Vila Velha de Ródão unit.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 406

Department of Commerce (EUA)

As at 31 December 2024, the balance corresponds to the amount receivable from the Department of Commerce (DoC) following

the investigation initiated in 2015 of alleged dumping practices in exports of UWF paper to the United States by the subsidiary

Navigator.

During 2023, the Department of Commerce confirmed the final rate to be applied for the 6

review period from March 2021 to

February 2022 at 7.11%, therefore the Group received in 2024 the amount of Euro 1,674,082 for the difference between the

deposits made and the final rate payable.

In 2024, the rate for the 7

review period, from March 2022 to February 2023, was also confirmed at 1.07%,and the amount of

Euro 2,095,637 was also received. The subsequent review periods (8 and 9) remain open and Navigator estimates that it has to

pay the DoC approximately Euro 1,160,207 (Note 4.3) for the 8th review period and a receivable of Euro 718,183 for the 9th

review period.

Amounts paid by the Group in respect of review periods 1 to 7 amount to Euro 26,809,402 as follows:

Amount paid by the Amounts in Euro Group Period of Review (POR) POR 1: Aug 15 - Feb 17 3,718,475 POR 2: Mar 17 - Feb 18 2,011,029 POR 3: Mar 18 - Feb 19 7,089,677 POR 4: Mar-19 - Feb 20 2,767,437 POR 5: Mar-20 - Feb 21 3,006,925 POR 6: Mar-21 - Feb 22 7,011,948 POR 7: Mar-22 - Feb 23 1,203,911 26,809,402

Accrued Income and Deferred Expenses

Accrued income and deferred expenses are detailed as follows:

Amounts in Euro 2024 2023 Accrued income Interest receivable - 570,646 Energy sales 11,535,948 10,280,593 Other 5,687,828 1,453,189 17,223,776 12,304,428 Deferred expenses Insurance 2,735 91,023 Rentals 14,295,170 12,587,120 Other 5,683,585 2,277,431 19,981,490 14,955,574 37,205,266 27,260,002

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 407

Other receivables

Other current and non-current receivables consist of the following:

Other non-current receivables

Amounts in Euro 2024 2023 Labour Compensation Fund - 769,982 Collateral 49,513 45,707 Pensions and other post-employment benefits - 777,147 Other shareholdings (Almascience, Forestwise, Cecolab, Colab BIOREF) 69,800 69,800 Receivables - leasing 1,572,232 - Other debtors 48,309 43,237 1,739,854 1,705,873

Other current receivables

Amounts in Euro 2024 2023 Advances to personnel 86,822 114,765 Advances to suppliers 14,653,095 7,432,928 Other debtors 4,136,295 1,564,764 18,876,212 9,112,457

The increase in advances to suppliers is due to advances paid at the end of the year for timber imports.

Accounting policies

Trade receivables and other debtors

Classification

Trade receivables result from the Group's main activities and the business model followed is the collection of contractual cash

flows.

Balances from other debtors generally assume the business model of collecting contractual cash flows.

Initial measurement

At fair value.

Subsequent measurement

At amortised cost, net of impairment losses.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 408

Impairment from Trade receivables

Impairment losses are recorded based on the simplified model provided for in IFRS 9, recording expected losses until maturity.

The expected losses are determined on the basis of the experience of historical actual losses over a statistically significant period

and representative of the specific characteristics of the underlying credit risk (Note 8.1.4).

Impairment from other debtors

Impairment losses are recorded on the basis of the general estimated credit loss model of IFRS 9.

4.3. Payables

Amounts in Euro 2024 2023 Trade payables – current account 215,175,131 209,023,299 Suppliers invoices pending - Logistics 17,471,405 12,915,733 Suppliers invoices pending - Other 86,751,313 60,955,309 Trade payables – Property, plant and equipment – current account 52,669,840 14,588,147 State 25,877,177 47,238,622 Related parties (Note 11.3) 1,496,697 1,542,197 Other creditors - CO2 emission allowances 34,607,846 39,325,970 Shareholders 99,999,451 - Other payables 21,613,139 21,675,082 Derivative financial instruments (Note 8.2) 6,311,500 5,691,818 Payroll costs accruals 40,827,184 39,402,872 Accrued expenses - interest payable 4,733,532 4,192,903 Wood supplier bonus 2,575,541 3,266,604 Water resource fee 1,858,098 1,570,025 Rent liabilities 20,040,608 18,723,772 Other accrued expenses 15,995,099 9,874,933 Non-repayment grants 10,566,113 13,059,496 Payables – current 658,569,674 503,046,782 Non-repayment grants 116,001,306 112,549,349 Department of Commerce (USA) (Note 4.2) 1,160,207 2,121,441 Payables – non-current 117,161,513 114,670,790 775,731,187 617,717,572

The increase in the balance of Trade payables – fixed assets – current account is due to the greater volume of investments made

in 2024, as mentioned in Note 2.1.

As at 31 December 2024, CO

emission allowances relate to the effect of recognising allowances granted free of charge for 2024.

The outstanding balance under Shareholders as at 31 December 2024 corresponds to the advance on profits for 2024, which was

paid on 9 January 2025 (Note 5.4).

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 409

State - Details

Amounts in Euro 2024 2023 Personal income tax withhold (IRS) 3,630,991 2,388,230 Value added tax 18,939,864 41,208,469 Social Security contributions 3,051,986 2,721,253 Other 254,336 920,670 25,877,177 47,238,622

As at 31 December 2024 and 31 December 2023, there were no arrears with the State.

Non-repayable grants - details

Amounts in Euro 2024 2023 Government grants (Note 3.5) 3,942,627 3,352,238 Other grants 6,623,486 9,707,258 Non-repayable grants - current 10,566,113 13,059,496 Government grants (Note 3.5) 116,001,306 112,549,349 Non-repayable grants – non-current 116,001,306 112,549,349 126,567,419 125,608,845

Accounting policies

Trade payables and other current liabilities are initially recorded at fair value and subsequently at their amortised

cost.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 410

5. Capital structure

5.1. Capital management

Capital management policy

For capital management purposes, the Group defines capital as including equity and net debt.

The Group's objectives in relation to capital management are:

I. To safeguard its ability to continue as a going concern and thus provide returns for Shareholders and benefits for its

remaining Stakeholders;

II. To keep a solid capital structure to support the growth of its business; and

III. To maintain an optimal capital structure that enables it to reduce the cost of capital.

In order to maintain or adjust its capital structure, the Group can adjust the amount of dividends payable to its Shareholders,

return capital to its Shareholders, issue new shares or sell assets to lower its borrowings.

In line with the sector, the Group monitors its capital based on the gearing ratio, defined as the proportion between net debt

and total capital.

Net interest-bearing debt is calculated by adding the total amount of loans (including the current and non-current portions as

disclosed in the statement of financial position) and deducting all cash and cash equivalents. Total equity is calculated by

adding Shareholders’ equity (as shown in the statement of financial position), to interest-bearing net debt, and excluding

treasury shares and non-controlling interests.

The Group calculates the gearing ratio as follows:

Amounts in Euro 2024 2023 Interest-bearing liabilities (Note 5.7) 903,977,752 659,344,463 Cash and cash equivalents (Note 5.9) (286,628,866) (169,464,967) Net debt 617,348,886 489,879,496 Equity 1,356,089,184 1,315,572,833 Non-controlling interest (Note 5.6) (360,347) (327,018) Equity, except for treasury shares and non-controlling interests 1,355,728,837 1,315,245,815 Total equity 1,973,077,723 1,805,125,311 Gearing 31.29% 27.14%

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 411

5.2. Share Capital and treasury shares

Navigator's Shareholders

The Navigator Company is a public company with its shares quoted on the Euronext Lisbon.

As at 31 December 2024, The Navigator Company, S.A.’s share capital of Euro 500,000,000 is fully subscribed and paid up and is

represented by 711,183,069 shares without nominal value (31 December 2023: 711,183,069 shares).

As at 31 December 2024 and 2023, the Shareholders with qualified shareholdings in the Company’s capital were as follows:

2024 2023 Entity No. of shares % No. of shares % Semapa, SGPS, S.A. 498,042,299 70.03% 497,617,299 69.97% Floating shares 213,140,770 29.97% 213,565,770 30.03% 711,183,069 100.0% 711,183,069 100.0%

In June 2024, Semapa, SGPS, S.A. acquired 425,000 shares representing 0.060% of Navigator's share capital.

As at 31 December 2024 and 31 December 2023, Navigator did not hold any treasury shares.

Accounting policies

Ordinary shares are classified in Shareholders’ equity.

Costs directly attributable to the issue of new shares or other equity instruments are reported as a deduction, net of taxes, from

the proceeds of the issue.

Costs directly attributable to the issue of new shares or options for the acquisition of a new business are deducted from the

amount issued.

When any Group company acquires shares of the parent company (treasury shares), the payment, which includes directly

attributable incremental costs, is deducted from the Shareholders’ equity attributable to the Company’s equity holders until such

time the shares are cancelled, reissued or sold.

When such shares are subsequently disposed or reissued, any proceeds, net of the directly attributable transaction costs and

taxes, is directly reflected in the Shareholders’ equity and not in profit/(loss) for the period.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 412

5.3. Earnings per share

2024 2023 Profit attributable to Navigator's equity holders (Euro) 286,948,195 274,923,820 Total number of shares issued 711,183,069 711,183,069 Weighted average number of shares 711,183,069 711,183,069 Basic earnings per share (Euro) 0.403 0.387Diluted earnings per share (Euro) 0.403 0.387

Accounting policies

Basic earnings per share are determined based on the division of profits or losses attributable to the ordinary

Shareholders of the Company by the weighted average number of common shares outstanding during the period.

For the purpose of calculating diluted earnings per share, the Company adjusts the profits or losses attributable to ordinary equity

holders, as well as the weighted average number of outstanding shares for the purposes of all potential dilutive common shares.

5.4. Dividends and reserves allocated

Dividends and reserves allocated in the period

Dividends per Amounts in Euro Amount approved share (Euro) Allocations in 2024 Distribution of retained earnings 149,995,621 0.211 Early dividend resolution 99,999,451 0.141 Allocations in 2023 Distribution of retained earnings 199,984,679 0.281

At the Annual Shareholders' Meeting of 24 May 2024, The Navigator Company, S.A. decided to distribute dividends in the amount

of Euro 149,995,621.

On 19 December 2024, the Board of Directors of The Navigator Company, S.A. decided to make an advance on 2024 profits to

Shareholders, in the amount of Euro 99,999,451, equivalent to the gross value of Euro 0.141 per share, which was paid on 9 January

2025.

At the General Shareholders Meeting of 17 May 2023, The Navigator Company, S.A. resolved to distribute dividends in the amount

of Euro 199,984,679.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 413

Accounting policies

The distribution of dividends to equity holders is recognised as a liability in the Group’s financial statements in the

period in which the dividends are approved by the Shareholders at the General Shareholders Meeting and up until

the time of their payment or, in the case of anticipated distributions, when approved by the Board of Directors.

5.5. Reserves and retained earnings

Amounts in Euro 2024 2023 Currency translation reserve 13,829,407 5,309,023 Fair value reserves 12,011,454 12,898,767 Legal reserve 100,000,000 100,000,000 Other reserves (5,960,836) 3,481,014 Retained earnings 548,900,068 418,633,191 Reserves and retained earnings 668,780,093 540,321,995

Currency translation reserve - detail

Amounts in Euro 2024 2023 Navigator North América (USD) 13,491,391 (6,699,934) Navigator Paper Mexico (MXN) (192,140) (186,032) Navigator Middle East Trading DMCC (AED) (4,275) (8,036) Navigator Egypt (EGP) 12,005 16,092 Navigator Paper Company UK (GBP) (3,118,216) 69,824 Navigator Eurasia (TYR) 799 799 Navigator Afrique du Nord (MAD) 395 395 Navigator Paper Poland (PLN) (2,897) (2,897) Portucel Moçambique (MZM) 718,714 12,118,812 Navigator Paper Southern Africa (ZAR) 5,602 - Navigator Holding Tissue UK, Ltd (GBP) 2,918,029 - 13,829,407 5,309,023

Fair value reserves - details

2024 2023 Gross Gross Amounts in Euro amount Tax Net amount amount Tax Net amount Interest rate risk hedging 5,068,875 (1,343,252) 3,725,623 16,015,134 (4,404,162) 11,610,972 Hedging exchange rate risk and others 11,273,239 (2,987,408) 8,285,831 1,776,268 (488,473) 1,287,795 16,342,114 (4,330,660) 12,011,454 17,791,402 (4,892,635) 12,898,767

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 414

Fair value reserves - movements

Amounts in Euro 2024 2023 Opening balance 12,898,767 33,997,828 Change in the fair value of derivative financial instruments (Note 8.2) (1,526,544) (29,102,154) Deferred taxes 639,231 8,003,093 Closing balance 12,011,454 12,898,767

The transfer from fair value reserves to profit/(loss) resulting from the settlement or maturity of hedging instruments is net of the

following effects:

a) The transfer from fair value reserves to profit/(loss) resulting from the settlement or maturity of hedging instruments.

• Sales price hedging instruments, recognised under paper and pulp sales, which generated negative results of Euro

5,714,356 (in 2023, the net positive impact of pulp and energy sales of Euro 28,523,595) (Note 2.1);

• Hedging instruments for energy and gas purchase prices, recognised under External Supplies and Services,

generated positive results of Euro 6,775,518 and Euro 11,997,819, respectively;

• interest rate hedging instruments, which generated a positive impact of Euro 11,328,732 (in 2023 Euro 9,722,523)

in financial results (Note 5.10);

b) Negative changes in the fair value of hedging derivatives amounting to Euro 22,861,169 (in 2023 Euro 9,143,964).

Other reserves – details

Amounts in Euro 2024 2023 Transfer of legal reserve surplus to free reserves 9,790,475 9,790,475 Free reserves arising from the share capital reduction not distributed 5,994 5,994 Adjustments to the application of 2014 profits (balance sheet bonus) 1,476 1,476 Incorporation of capital reserves (6,316,931) (6,316,931) Acquisition/disposal of non-controlling interests (9,441,850) - (5,960,836) 3,481,014

In 2014, the Group signed agreements with IFC – Internacional Finance Corporation, a Subscription Agreement and a Put and Call

option for the entry of this institution into the share capital of the subsidiary Portucel Moçambique, S.A., thus ensuring the

construction phase of the Group's forestry project in Mozambique. In 2015, this Company performed a capital increase from MZM

1,000 million to MZM 1,680.798 million subscribing MZM 332,798 million corresponding to 19.98% of the capital at that date.

On 23 May 2018, the General Shareholders' Meeting decided to transfer the excess of the legal reserve in the amount of Euro

9,790,475 to free reserves as a result of the share capital reduction operation carried out on 4 October 2017.

In February 2019, there was a reduction in the subscribed, underwritten and paid-up capital of the shareholder The Navigator

Company, S.A. to MZM 456,596,000, corresponding to 90.02% of the Company’s share capital, and the IFC’s holding was revised

to MZM 50,620,000, corresponding to 9.98% of the Portucel Moçambique’s share capital.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 415

On 19 December 2023, an addendum was made to the agreements initially signed with the IFC - International Finance

Corporation, extending the date of entry of this institution into the capital of the subsidiary Portucel Moçambique, S.A. from 31

December 2023 to 31 December 2028.

In the current period, the Group considered that the put option on the shares of the subsidiary Portucel Moçambique, S.A. to The

Navigator Company, S.A. by IFC – International Finance Corporation was expected to be exercised and recorded the amount of

Euro 9,441,850 relating to that transaction under Other reserves.

Accounting policies

Fair value reserves

It corresponds to the accumulated change in fair value of derivative financial instruments classified as hedging instruments (Note

8.2), net of deferred taxes.

Changes related to derivatives are reclassified to profit/(loss) for the period (Note 5.10) as the hedged instruments affect

profit/(loss) for the period. The fair value adjustments of financial investments recorded under this caption is not recycled to

profit/(loss).

Currency translation reserve

The currency translation reserve corresponds to the accumulated amount related to the settlement by the Group of the exchange

rate differences resulting from the translation of the financial statements of the subsidiaries operating outside the Euro zone.

Legal reserve

The Portuguese commercial legislation prescribes that at least 5% of annual net profit must be transferred to the legal reserve,

until this is equal to at least 20% of the share capital. This reserve cannot be distributed unless the company is liquidated. It may,

however, be drawn on to absorb losses, after other reserves are exhausted, or incorporated in the share capital.

The legal reserve is constituted by its maximum amount in the periods presented.

Other reserves and Retained earnings

This caption corresponds to reserves available for distribution to Shareholders that were constituted through the appropriation of

prior period’s earnings, the reduction of share capital and other movements. The portion of the balance corresponding to the

acquisition value of treasury shares held is not distributable (Note 5.2).

5.6. Non-controlling interests

Detail of non-controlling interests, by subsidiary

% Equity Net profit Amounts in Euro held 2024 2023 2024 2023 Raiz - Instituto de Investigação da Floresta e Papel 3.0% 360,347 327,018 36,018 25,322 Portucel Moçambique 0% - - - - 360,347 327,018 36,018 25,322

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 416

Non-controlling interests are related to RAÍZ – Instituto de Investigação da Florestal e Papel, where the Group owns 97% of the

capital and voting rights. The remaining 3% are owned by external associates.

In 2024, the Group recorded the exercise of the put option on Portucel Moçambique shares, representing 9.98% of the share capital,

by IFC – International Finance Corporation, as stated in Note 5.5.

As at the reporting date, there are no rights of protection of non-controlling interests that significantly restrict the entity's ability to

access or use assets and settle liabilities of the Group.

Movements of non-controlling interests

Amounts in Euro 2024 2023 Opening balance 327,018 297,977 Net profit/(loss) for the period 36,018 25,322 Other comprehensive income (2,689) 3,719 Closing balance 360,347 327,018

5.7. Interest-bearing liabilities

2024 2023 Non-Amounts in Euro current Current Total Non-current Current Total Bond loans 547,500,000 100,000,000 647,500,000 397,500,000 22,500,000 420,000,000 Commercial paper 85,000,000 35,000,000 120,000,000 70,000,000 35,000,000 105,000,000 Bank loans 81,266,782 35,529,242 116,796,024 71,972,222 34,539,683 106,511,905 Charges with bond issuances (3,442,860) - (3,442,860) (2,614,750) - (2,614,750) Refundable grants 15,905,149 7,219,439 23,124,588 23,227,869 7,219,439 30,447,308 Debt securities and bank debt 726,229,071 177,748,681 903,977,752 560,085,341 99,259,122 659,344,463 Average interest rate, considering charges for annual fees and hedging 2.4% 2.0% operations

The evolution of financing in 2024 was marked by the contracting of a significant volume of new long-term lines (maturities

between 5 and 7 years), amounting to Euro 355 million, all indexed to ESG indicators.

Of this total, Euro 250 million were issued in the form of bonds, maturing in 2029 (Euro 50 million) and 2031 (Euro 200 million). A

commercial paper issue was also made (Euro 50 million), with a firm underwriting until 2030. All the bonds and commercial paper

were issued under the Sustainability-Linked Bonds Framework.

This operation contributed to extending the average life of the Group's debt, as well as maintaining a low cost of financing for the

Company, in addition to having conditions adjusted to the fulfilment of sustainability commitments. The conditions of the bond

loans are indexed to three ESG indicators already included in the Group's Sustainability Agenda and, in turn, aligned with the

Sustainable Development Goals of the United Nations.

The repayable incentives include incentives from AICEP - Agência para o Investimento e Comércio Externo de Portugal, as part of

a number of research and development projects, which includes the incentive under the investment agreement entered into with

Grupo Navigator Tissue Aveiro, S.A. subsidiary for the construction of the new tissue mill in Aveiro. This agreement comprises a

financial incentive in the form of a repayable grant, up to a maximum amount of Euro 42,166,636, without interest payment, with

a grace period of two years, with the last refund taking place in 2027.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 417

In December 2023, the Navigator Group signed a new long-term loan agreement with the European Investment Bank (EIB) for

Euro 115 million, maturing in 12 years. The loan will be disbursed in up to 3 instalments within 18 months of signing the contract.

The loan will support the project to build and operate the high-efficiency recovery boiler at the Setúbal Industrial Complex, a key

step in the decarbonisation roadmap. This green loan is part of the REPowerEU Plan, which aims to increase financing for green

energy and support the autonomy and competitiveness of the European Union.

The maturity analysis of interest

-bearing liabilities is presented in the Note 8.1.3 - Liquidity risk.

Interest-bearing liabilities - details

2024 Outstanding Non-Amounts in Euro Amount amount Maturity Interest rate Current current Bond loans Variable rate indexed to Navigator 2022-2028 ESG 150,000,000 150,000,000 June 2028 Euribor, with swap to fixed 50,000,000 100,000,000 rate Navigator 2019-2026 50,000,000 50,000,000 January 2026 Fixed rate - 50,000,000 Variable rate indexed to Navigator 2019-2025 10,000,000 10,000,000 March 2025 Euribor, with swap to fixed 10,000,000 - rate Variable rate indexed to Navigator 2021-2026 12,500,000 12,500,000 April 2026 2,500,000 10,000,000 Euribor Variable rate indexed to Navigator 2020-2026 75,000,000 75,000,000 December 2026 Euribor, with swap to fixed 37,500,000 37,500,000 rate Variable rate indexed to Navigator 2021-2026 ESG 100,000,000 100,000,000 August 2026 Euribor, with swap to fixed - 100,000,000 rate Variable rate indexed to Navigator 2024-2029 50,000,000 50,000,000 June 2029 Euribor, with swap to fixed - 50,000,000 rate Variable rate indexed to Navigator 2024-2031 50,000,000 50,000,000 June 2031 Euribor, with swap to fixed - 50,000,000 rate Variable rate indexed to Navigator 2024-2031 50,000,000 50,000,000 October 2031 - 50,000,000 Euribor Variable rate indexed to Navigator 2024-2031 SLB 100,000,000 100,000,000 May 2031 - 100,000,000 Euribor Fees - (3,442,861) - (3,442,861) European Investment Bank (EIB) Variable rate indexed to EIB Loan - Energy - - December 2024 - - Euribor EIB Loan – Cacia 9,722,222 9,722,222 May 2028 Fixed rate 2,777,778 6,944,444 EIB Loan – Figueira 25,714,286 25,714,286 February 2029 Fixed rate 5,714,286 20,000,000 EIB Loan – Biomass Boiler 25,535,714 25,535,714 March 2031 Fixed rate 3,928,571 21,607,143 up to 12 years Indexed to the cost of EIB EIB Loan 115,000,000 - - - after repayment funds, on disbursement Commercial Paper Program Commercial Paper Programme 175M 70,000,000 70,000,000 February 2026 Fixed rate 35,000,000 35,000,000 Variable rate indexed to Commercial Paper Programme 65M ESG 19,500,000 - February 2026 - - Euribor Variable rate indexed to Commercial Paper Programme 75M 75,000,000 - January 2026 - - Euribor Variable rate indexed to Commercial Paper Programme 50M 50,000,000 - December 2025 - - Euribor Variable rate indexed to Commercial Paper Programme 50M ESG 50,000,000 50,000,000 June 2030 - 50,000,000 Euribor Interest-bearing liabilities

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 418

Variable rate indexed to Long-term investment 55,000,000 30,000,000 March 2031 - 30,000,000 Euribor Finance leases 9,645,897 4,432,695 December 2027 Variable rate indexed to Libor 1,717,499 2,715,195 Refundable grants AICEP 23,124,589 23,124,588 7,219,439 15,905,150 Bank credit facilities Short-term facility 20M 20,450,714 - - - Short-term facility 20M GBP 21,391,108 21,391,108 Variable rate indexed to Libor 21,391,108 - 1,217,584,530 903,977,752 177,748,681 726,229,071 2023 Outstanding Non-Amounts in Euro Amount amount Maturity Interest rate Current current Bond loans Variable rate indexed to Navigator 2022-2028 ESG 150,000,000 150,000,000 June 2028 Euribor, with swap to fixed - 150,000,000 rate Navigator 2019-2026 50,000,000 50,000,000 January 2026 Fixed rate - 50,000,000 Variable rate indexed to Navigator 2019-2025 30,000,000 30,000,000 March 2025 Euribor, with swap to fixed 20,000,000 10,000,000 rate Variable rate indexed to Navigator 2021-2026 15,000,000 15,000,000 April 2026 2,500,000 12,500,000 Euribor Variable rate indexed to December Navigator 2020-2026 75,000,000 75,000,000 Euribor, with swap to fixed - 75,000,000 2026 rate Variable rate indexed to Navigator 2021-2026 ESG 100,000,000 100,000,000 August 2026 Euribor, with swap to fixed - 100,000,000 rate Fees - (2,614,750) - (2,614,750) European Investment Bank (EIB) December Variable rate indexed to EIB Loan - Energy 10,625,000 7,083,333 7,083,333 - 2024 Euribor EIB Loan – Cacia 13,888,889 12,500,000 May 2028 Fixed rate 2,777,778 9,722,222 February EIB Loan – Figueira 31,428,571 31,428,571 Fixed rate 5,714,286 25,714,286 2029 EIB Loan – Biomass Boiler 27,500,000 27,500,000 March 2031 Fixed rate 1,964,286 25,535,714 up to 12 Rate indexed to the cost of EIB EIB Loan 115,000,000 - years after - - funds on disbursement disbursement Commercial Paper Program February Commercial Paper Programme 175M 105,000,000 105,000,000 Fixed rate 35,000,000 70,000,000 2026 February Variable rate indexed to Commercial Paper Programme 65M ESG 42,250,000 - - - 2026 Euribor Variable rate indexed to Commercial Paper Programme 75M 75,000,000 - January 2026 - - Euribor December Variable rate indexed to Commercial Paper Programme 50M 50,000,000 - - - 2025 Euribor Interest-bearing liabilities Variable rate indexed to Long-term investment 13,000,000 13,000,000 March 2026 2,000,000 11,000,000 Euribor Refundable grants November AICEP 30,447,309 30,447,309 Fixed rate 7,219,439 23,227,869 2027 Bank credit facilities Short-term facility 20M 20,450,714 15,000,000 15,000,000 - 954,590,483 659,344,463 99,259,122 560,085,341

As at 31 December 2024, the average cost of issued debt, considering interest rate, the annual fees and hedging operations, was

2.4% (31 December 2023: 2%). At this date, 89% of the debt is remunerated at a fixed rate, either by direct contracting on this

basis or by hedging the interest rate with derivative financial instruments (95% as at 31 December 2023).

At 31 December 2024, 65% of the Group's financing is linked to compliance with sustainability commitments (31 December 2023:

46%).

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 419

The repayment terms for the interest-bearing liabilities recorded as non-current are detailed as follows:

Amounts in Euro 2024 2023 Non-current 1 to 2 years 252,140,074 156,640,074 2 to 3 years 19,640,074 261,140,074 3 to 4 years 113,746,941 19,640,074 4 to 5 years 56,785,714 112,601,298 More than 5 years 287,359,128 12,678,571 729,671,931 562,700,091 Fees (3,442,860) (2,614,750) 726,229,071 560,085,341

As at 31 December 2024, the Group had contracted Commercial Paper Programmes, contracted and undisbursed long-term

financing, as well as available and undrawn credit facilities of Euro 310,163,917(31 December 2023: €287,714,714).

As at 31 December 2024 and 31 December 2023, the Group’s interest-bearing net debt was as follows:

Amounts in Euro 2024 2023 Interest-bearing liabilities 903,977,752 659,344,463 Cash and cash equivalents (Note 5.9) (286,628,866) (169,464,967) Interest-bearing net debt 617,348,886 489,879,496 Lease liabilities (Note 5.8) 111,736,900 69,996,821 Interest-bearing net debt with lease liabilities 729,085,786 559,876,317

Financial Covenants in force

Ratio Definition Loans Limit Interest coverage EBITDA 12M / Annual net interest Bank >= 4.5 - 5.5 Indebtedness Interest-bearing debt / EBITDA 12M Bank <= 4.5 Bank <= 4.0 Net Debt / EBITDA (Interest-bearing debt - Cash) / EBTDA 12M Commercial Paper <= 4.0 - 5.0 Bonds <= 4.0

Based on the financial statements presented in this report, these ratios were as follows as at 31 December 2024 and 2023:

Ratio 2024 2023 Interest coverage 41.93 36.01 Indebtedness 1.65 1.31 Net Debt / EBITDA 1.13 0.98

The amounts presented in the table above exclude lease liabilities.

Considering the contracted limits, in 2024 and 2022, the Group is in compliance with the covenants negotiated. As at 31

December 2024 and 2023, the company presents a minimum safety margin above 80% on the fulfilment of its covenants.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 420

Movements in liabilities of the Group's financing activities

Amounts in Euro 2024 2023 Balance as at 1 January 659,344,463 725,301,722 Payment of interest-bearing liabilities (124,542,159) (107,276,122) Receipts of interest-bearing liabilities 352,162,243 15,000,000 Payment Repayable grants (7,219,439) (7,219,438) Change in financing cash flows 220,400,645 (99,495,560) Exchange rate effect 649,317 - Interest expenses (103,281) - Changes in borrowing costs (828,111) 865,333 Change in the perimeter (Note 1.2) 24,514,719 32,672,968 Other changes 23,583,327 33,538,301 Changes in interest-bearing debt 244,633,289 (65,957,259) Gross interest-bearing debt 903,977,752 659,344,463

The receipt of Euro 330,000,000 corresponds to the issue of four ESG bond loans in the amount of Euro 250,000,000 and the

payment of a bank loan with ESG features in the amount of Euro 30,000,000, and the issue of a new commercial paper programme

in the amount of Euro 50,000,000.

Estimates and judgements

Commercial paper

The Group has several commercial paper programmes negotiated, of agreements with which it is frequent to carry out emissions

with contractual maturity of less than one year but with revolving nature. Where the Group expects to roll over these loans, it

presents them as non-current liabilities.

Accounting policies

Interest-bearing liabilities includes Bonds, Commercial Paper, bank loans and other financing.

Initial measurement

At fair value, net of transaction costs incurred.

Subsequent measurement

At amortised cost, using the effective interest rate method.

The difference between the repayment amount and the initial measurement amount is recognised in the income statement over

the debt period under "Interest expenses on other loans" in Note 5.10 – Net financial results.

Fair value

The book value of short-term interest-bearing liabilities or loans contracted at variable interest rates are close to their fair value.

The fair value of interest-bearing liabilities that are remunerated at a fixed rate is disclosed in Note 8.3 – Financial assets and

liabilities.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 421

Disclosure

The Group must classify a liability as current when:

a) it expects to settle the liability in the normal course of its operating cycle;

b) it holds the liability primarily for trading purposes;

c) the liability is expected to be settled within twelve months of the reporting period; or

d) it does not have an unconditional right to defer settlement of the liability for at least twelve months after the reporting

period.

5.8. Lease liabilities

Lease liabilities – Nature

2024 2023 Amounts in Euro Non-current Current Total Non-current Current Total Forestry lands 57,264,280 3,571,330 60,835,610 55,314,521 3,183,910 58,498,431 Buildings 874,505 595,254 1,469,759 1,374,377 540,140 1,914,517 Vehicles 4,878,286 2,422,257 7,300,543 3,815,266 1,580,224 5,395,490 Software licenses - 7,537 7,537 - 94,312 94,312 Other lease liabilities 35,610,598 6,512,853 42,123,451 2,344,597 1,749,474 4,094,071 98,627,669 13,109,231 111,736,900 62,848,761 7,148,060 69,996,821

Lease liabilities – Movements

Amounts in Euro 2024 2023 Balance as at 1 January 69,996,821 61,641,049 Change in the perimeter 40,087,211 - Contract amortisation (15,661,601) (10,694,178) New contracts 15,399,731 16,003,677 Interest expense 3,896,924 2,517,826 Exchange rate effect 991,670 - Other changes (2,973,856) 528,447 Total changes in related liabilities 41,740,079 8,355,772 Balance as at 31 December 111,736,900 69,996,821

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 422

Lease liabilities – Future liabilities

2024 2023 Maturing Interest on Present value Maturing Interest on Present value Amounts in Euro rents liabilities of liabilities rents liabilities of liabilities Less than 1 year 8,979,261 4,129,971 13,109,232 4,716,806 2,431,254 7,148,060 1 to 2 years 8,889,165 3,663,989 12,553,154 3,897,834 2,229,000 6,126,834 2 to 3 years 6,181,341 3,241,953 9,423,294 3,567,730 2,044,103 5,611,833 3 to 4 years 5,558,231 2,901,466 8,459,697 2,949,250 1,867,883 4,817,133 4 to 5 years 4,835,706 2,580,681 7,416,387 2,431,219 1,711,124 4,142,343 More than 5 years 47,803,576 12,971,560 60,775,136 30,952,202 11,198,416 42,150,618 Present value of liabilities 82,247,280 29,489,620 111,736,900 48,515,041 21,481,780 69,996,821

For the periods ended 31 December 2024 and 31 December 2023, there were no changes in the liability arising from financing

activities, including changes arising from cash flows and/or other changes in lease liabilities.

Accounting policies

At the start date of the lease, the Group recognises lease liabilities measured at the present value of future lease

payments, which include fixed payments less lease incentives, variable lease payments, and amounts expected to

be paid as residual value. Lease payments also include the price of exercise of renewal options reasonably certain to be exercised

by the Group or lease termination penalty payments if the lease term reflects the Group's option to terminate the agreement.

In calculating the present value of future lease payments, the Group uses an incremental financing rate if the implied interest rate

on the lease transaction is not easily determinable.

Subsequently, the value of the lease liabilities is increased by the interest amount (Note 5.10 Net Financial Results) and decreased

by the lease payments (rents).

5.9. Cash and cash equivalents

Amounts in Euro 2024 2023 Cash 36,915 42,100 Short-term bank deposits 34,591,951 34,422,867 Other short-term investments 252,000,000 135,000,000 286,628,866 169,464,967

In 2024, Other short-terms investments records amounts invested by Navigator in a portfolio of short-term, highly liquid deposits

and issuers with adequate ratings.

As at 31 December 2024 and 31 December 2023, there are no significant balances of cash and cash equivalents that are subject

to restrictions on use by the Group.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 423

Accounting policies

Cash and cash equivalents include cash, bank accounts and other short-term investments with an initial maturity of

up to 3 months, which can be mobilised immediately without any significant risk in value fluctuations.

For cash flow statement purposes, this caption also includes bank overdrafts, which are presented in the statement of financial

position as a current liability, under the caption Interest-bearing liabilities (Note 5.7).

5.10. Net financial results

Amounts in Euro 2024 2023 Interest paid on debt securities and bank debt (27,941,200) (23,497,743) Commissions on loans and expenses with the opening of credit facilities (2,023,031) (2,747,479) Interest paid using the effective interest method (29,964,231) (26,245,222) Interest paid on lease liabilities (3,896,924) (2,517,826) Financial expenses related to the Group's capital structure (33,861,155) (28,763,048) Favourable / (Unfavourable) exchange rate differences (4,678,314) (2,021,459) Gains / (Losses) on financial instruments - hedging (Note 8.2) (2,530,279) (1,151,931) Losses on compensatory interest - (561,180) Other expenses and financial losses (2,146,190) (855,584) Financial expenses and losses (43,215,938) (33,353,202) Interest earned on financial assets at amortised cost 5,556,787 4,119,466 Gains on financial instruments - hedging (Note 8.2) 11,328,732 9,722,523 Gains / (Losses) on financial instruments - hedging (Note 8.2) - 191,295 Gains on compensatory interest 490,852 - Financial income and gains 17,376,371 14,033,284 (25,839,567) (19,319,918) Financial profit/(loss)

Financial losses amounted to Euro 25,839,567(31 December 2023: Euro 19,319,918, negative). This evolution compared to 2023

was essentially the result of changes in foreign exchange results. These exchange rate effects include the accounting effect (non-

cash), of approximately Euro 3 million, of the recognition in the income statement of part of the currency translation reserve of the

subsidiary Navigator North America, recycled through the income statement to the extent that it paid dividends to its parent company

during the period.

The evolution of financial profit/(loss), although penalised by the rise in the average cost of debt as a result of new financing issues

at higher interest rates, remained at low levels in relation to the current market interest rate curve, taking into account the debt

breakdown structure between fixed and variable interest rates and the respective levels of hedging carried out.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 424

Amounts in Euro 2024 2023 Interest paid on fixed rate financing (2,803,140) (2,987,974) Interest paid on variable rate financing (2,309,463) (1,773,693) Interest paid on variable rate financing and covered by IRS (20,298,296) (16,282,077) Interest rate hedges - IRS (Note 8.2) 11,328,732 9,722,523 Commissions on loans and expenses with the opening of credit facilities (2,023,031) (2,747,479) (16,105,198) (14,068,700) Interest paid on lease liabilities (3,896,924) (2,517,826) Interest paid on other interest-bearing liabilities (2,530,301) (2,453,999) Interest earned on financial assets at amortised cost 5,556,787 4,119,466 Net cost of capital structure (16,975,636) (14,921,059)

Accounting policies

The Group classifies as “Financial income” the income and gains resulting from treasury management activities such

as: i) interest obtained from the application of cash surplus; and ii) changes in the fair value in derivative financial

instruments negotiated to hedge interest rate and exchange rate risk on loans, regardless of the formal designation

of hedge.

6. Income tax

6.1. Income tax for the period

6.1.1. Income tax recognised in the consolidated income statement

Amounts in Euro 2024 2023 Current tax 92,286,353 83,576,447 Change in uncertain tax positions in the period (11,603,585) (10,524,611) Deferred tax (Note 6.2) (14,636,752) (965,713) 66,046,016 72,086,123

As at 31 December 2024, current tax includes Euro 81,337,182 (31 December 2023: Euro 77,442,414) regarding the liability

created under the aggregated income tax regime of The Navigator Company, S.A. in Portugal, and is as follows by country:

Amounts in Euro 2024 % 2023 % Portugal 81,638,728 88.46% 77,442,414 92.66% Spain 6,916,300 7.49% 3,576,798 4.28% United States of America 2,754,763 2.99% 1,652,446 1.98% Ireland 744,469 0.81% 297,933 0.36% France 85,073 0.09% 400,417 0.48% United Kingdom 78,999 0.09% 100,157 0.12% Other 68,021 0.07% 106,282 0.13% 92,286,353 100.00% 83,576,447 100.00%

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 425

As at 31 December 2024 and 31 December 2023, the caption Change in uncertain tax positions in the period reflects the

excess/insufficiency of tax estimates, the favourable outcome of some cases related to matters with high uncertainty, as well as

requests for binding information, claims to the Tax Authorities and jurisprudence of the courts.

There have not been, nor are any expected changes arising from variations in the rate used to determine the expected tax

amount.

Nominal tax rate

In the periods presented, the Group considers a nominal tax rate in Portugal of 27.5%, resulting from the tax legislation as

follows:

2024 2023 Portugal Nominal income tax rate 21.0% 21.0% Municipal surcharge 1.5% 1.5% 22.5% 22.5% State surcharge - on the share of taxable profits between Euro 1,500,000 and Euro 7,500,000 3.0% 3.0% State surcharge - on the share of taxable profits between Euro 7,500,000 and Euro 35,000,000 5.0% 5.0% State surcharge - on the share of taxable profits above Euro 35,000,000 9.0% 9.0%

Reconciliation of the effective income tax rate for the period

(1,701,356)

Amounts in Euro 2024 2023 Profit before income tax 353,030,229 347,035,265 Expected tax at nominal rate (21%) 74,136,348 72,877,406 Municipal surcharge (2024: 1.48%; 2023: 1.24%) 5,220,845 4,312,541 State surcharge (2024; 4.83%; 2023: 3.84%) 17,058,507 13,341,979 Income tax resulting from the applicable tax rate 96,415,700 90,531,926 Nominal tax rate for the period 27.3% 26.1% Differences (a) (5,995,539) (7,114,724) Changes in estimates relating to previous periods (13,177,106) (10,964,626) Tax benefits (11,288,005) Autonomous taxation 752,676 1,334,903 Change in tax rate (661,710) - 66,046,016 72,086,123 Effective tax rate 18.7% 20.8%

(a) This amount concerns mainly:

2024 2023 Capital gains/ (losses) for tax purposes 1,964,267 9,207 Capital gains/ (losses) for accounting purposes (2,281,507) (244,774) Taxable provisions and impairment 4,139,158 1,603,069 Tax benefits (9,179,825) (20,442,661) Post-employment benefits (2,065,106) (2,402,501) Incentive to capitalise companies (17,347,915) - Deferred taxes on right-of-use assets and liabilities (6,034,371) - International economic double taxation 13,970,336 - Other (4,966,998) (4,394,062) (21,801,961) (25,871,722) Tax effect (27.5%) (5,995,539) (7,114,724)

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 426

6.1.2. Tax recognised in the consolidated statement of financial position

Amounts in Euro 2024 2023 Assets Amounts pending repayment 20,621,461 18,385,534 20,621,461 18,385,534 Liabilities Corporate Income Tax - IRC 27,868,324 4,727,342 Additional tax liabilities (IRC) 13,470,045 18,100,389 41,338,369 22,827,731

Detail of Corporate Income Tax - IRC (net)

Amounts in Euro 2024 2023 Income tax for the period 92,286,353 83,576,447 Payments on account, special and additional payments on account (68,520,255) (75,943,340) Withholding tax recoverable (1,893,645) (1,798,031) Corporate Income Tax payable / (repayable) from previous periods 7,209,171 - Other payables / (receivables) (1,213,300) (1,107,734) 27,868,324 4,727,342

The amounts of corporate income tax paid in the period are detailed as follows:

Amounts in Euro 2024 2023 Payment / (Repayment) of corporate income tax for the previous period (8,824,662) 85,292,216 Payments on account, special and additional payments on account 68,520,255 75,943,340 Withholding tax 1,893,645 1,798,031 Repayments of tax proceedings decided in favour of the group (2,961,843) (335,564) Payments of additional tax liabilities 2,467,535 222,634 Other income tax payments / (repayments) - 829 Income tax paid / (received) 61,094,930 162,921,486

Amounts pending repayment

Amounts in Euro 2024 2023 2005 Corporate Income Tax (RETGS) – Proceeding 1259/ 09.3BESNT 13,886,728 13,886,728 2015 Proceeding – Proceeding 21/22.2BALSB 5,364,441 - 2018 Corporate Income Tax (RETGS) - Proceeding CAAD 103/2023 - 1,749,389 RFAI 2010 to 2012 - compensatory interest 494,856 494,856 2016 Corporate Income Tax – Navigator Tissue Ródão – CAAD Proceeding 575/2020 861,866 861,866 2017 Corporate Income Tax - Proceeding CAAD 756/2022 - 1,379,125 Other 13,570 13,570 20,621,461 18,385,534

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 427

The movements in the period are detailed as follows:

Amounts in Euro 2024 2023 Balance at the beginning of the period 18,385,534 16,216,543 Increases 5,364,441 3,142,084 Payments / (receipts) (2,961,843) (335,564) Reversals (166,671) (637,529) 20,621,461 18,385,534

Uncertain tax positions- Liabilities

Amounts in Euro 2024 2023 Balance at the beginning of the period 18,100,389 14,762,361 Increases 3,864,026 6,276,135 Payments / (receipts) - 222,634 Transfers (6,451,126) - Reversals (2,043,244) (3,160,741) Changes in the period (4,630,344) 3,338,028 13,470,045 18,100,389

Taxes paid in litigation

As at 31 December 2024 and 31 December 2023, the additional tax assessments that are already paid and contested, not

recognised in assets, refer to the Navigator Group and are summarised as follows:

Amounts in Euro 2024 2023 2005 Aggregate Corporate Income Tax (Note 10) 2005) – Proceeding no. 88/13.4BEALM - 10,394,386 2006 Aggregate Corporate Income Tax (Note 10.3) – Proceeding no. 909/11.6 BEALM 8,150,146 8,150,146 Aggregate Corporate Income Tax 2018 - Proceeding 648/23.5BEALM 8,014,795 11,138,180 Aggregate Corporate Income Tax 2018 - Proceeding 525/13.4BEALM 1,457,205 - 2015 Corporate Income Tax – Navigator Tissue Ródão, S.A. - Proceeding no. 235/23.8BECTB 7,586,361 7,586,361 State Surcharge 2015 II – Proceeding no. 453/23.9BEALM 6,970,541 6,970,541 State Surcharge 2016 – Proceeding no. 457/21.6BEALM 3,761,397 3,761,397 State Surcharge 2017 – Proceeding no. 456/21.8BEALM 8,462,724 8,462,724 State Surcharge 2018 – Proceeding no. 707/21.9 BEALM - 12,223,705 State Surcharge 2019 – Proceeding no. 557/23.8BEALM 2,466,974 2,466,974 State Surcharge 2020 – Proceeding no. 26/24.9BEALM 5,183,000 5,183,000 State Surcharge 2021 – Proceeding no. 702/24.6BEALM 6,154,906 - 58,208,049 76,337,414

Estimates and judgements

The Group recognises liabilities for additional tax assessments that may result from reviews by the tax authorities of

the different countries where the Group operates. When the final result of these situations is different from the

amounts initially recorded, the differences will have an impact on income tax in the period in which they occur.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 428

In Portugal, annual income statements are subject to review and possible adjustment by the tax authorities for a period of 4

years. However, if tax losses are presented, they may be subject to review by the tax authorities for a period of 6 years. In other

countries in which the Group operates, these periods are different, usually higher.

The Board of Directors considers that any corrections to those statements as a result of reviews/inspections by the tax authorities

will not have a significant impact in the consolidated financial statements as at 31 December 2024, although the periodsup to and

including 2020 have already been reviewed.

As at 31 December 2024, if the effective tax rate corresponded to the nominal rate of 27.3% (26.1% as at 31 December 2023),

there would be an increase in expenses with income taxes in the amount of Euro 30,369,6884 (31 December 2023: Euro

18,445,803, calculated at a nominal rate of 27.5%).

Uncertain tax positions

The amount of assets and liabilities recorded for tax proceedings arises from an assessment made by the Group, as at the date of

the consolidated statement of financial position, regarding potential differences of understanding with the Tax Authorities,

considering the developments in tax matters.

The Group, in relation to the measurement of uncertain tax positions, considers the provisions of IFRIC 23 - “Uncertainty over

Income Tax Treatments”, namely the measurement of risks and uncertainties in the definition of the best estimate of the expense

required to settle the obligation, by weighing all the possible results that are controlled by them and their associated probabilities.

Pillar Two Model Rules - OECD

The Navigator Group is subject to the OECD Pillar Two model rules from 1 January 2024. It has applied the exception to the

recognition and disclosure of information on deferred tax assets and liabilities related to Pillar Two income taxes, as provided for in

the amendments to IAS 12.

As at the date of this report, the Group is currently assessing the impact of the introduction of the Pillar Two regime. However,

given the analysis carried out so far, no significant impacts are expected, considering the current understanding of the

interpretation of the new rules.

Accounting policies

Current income tax is calculated based on net profit/(loss), adjusted in conformity with tax legislation in force at the

statement of consolidated financial position date.

Taxation group

In Portugal, the Navigator Group is subject to the special tax regime for groups of companies (RETGS), comprising companies in

which the shareholding is equal to or more than 75% and which meet the conditions laid down in articles 69 and following of the

Corporate Income Tax Code (IRC Code).

These companies included in the RETGS calculate income taxes as if they were taxed independently. Liabilities are recognised as

due to the controlling company of the tax business Group, currently The Navigator Company, S.A. which is responsible for the

Group’s overall assessment and payment of the corporate income tax. Where there are gains on the use of this regime, these are

recorded as income in the controlling company’s financial statements.

In 2018, a tax group was also established in Spain, which includes the three subsidiaries of the group based in that country and

owned by Bosques do Atlântico, S.L., the controlling company in the tax group.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 429

6.2. Deferred taxes

Movements in deferred taxes

Income Statement Equity As at 1 Exchange As at 31 Amounts in Euro January Change in the Increases/ rate December 2024 perimeter Increases Decreases Decreases adjustment Adjustments 2024 Temporary differences originating deferred tax assets Tax losses carried forward 52,846 56,496,586 10,330,494 (8,763,724) - 1,497,935 - 59,614,137 Provisions and impairment losses taxed 16,674,924 - 3,399,158 (6,222,935) - - - 13,851,147 Adjustment of property, plant and 32,384,050 - 3,369,216 (16,546,254) - - - 19,207,012 equipment Deferred accounting gains on intra-group 11,750,244 - 19,587,315 (2,771,964) - - - 28,565,595 transactions Valuation of biological assets 24,904,297 - 3,212,169 - - - - 28,116,466 Conventional capital remuneration 280,000 - - (280,000) - - - - Lease liabilities relating to right-of-use - 589,227 74,127,963 - - - - 74,717,190 assets Other temporary differences - - 2,688,330 - - 15,363 - 2,703,693 86,046,361 57,085,813 116,714,645 (34,584,877) - 1,513,298 - 226,775,240 Temporary differences originating deferred tax liabilities Pensions and other post-employment (795,430) - (27,809) (31) 125,312 - - (697,958) benefits Financial instruments (18,072,331) - - - 1,526,544 - 203,673 (16,342,114) Valuation of biological assets (3,519,844) - (4,329,921) - - - - (7,849,765) Adjustment of property, plant and (286,279,805) (35,345,525) (2,286,008) 30,589,642 - (880,249) - (294,201,945) equipment Fair value calculated in business (39,840,800) (99,779,568) - 10,301,191 - (2,538,614) - (131,857,791) combinations Government grants (3,714,470) - - 424,209 - - 387,483 (2,902,778) Right-of-use assets - - (68,093,592) - - - - (68,093,592) Other temporary differences - (117,536) - - - (3,065) - (120,601) (352,222,680(135,242,629) (74,737,330) 41,315,011 1,651,856 (3,421,928) 591,156 (522,066,544) ) Deferred tax assets 23,653,501 14,271,453 31,624,928 (9,287,124) - 378,325 60,641,083 Effect of the change in tax rate - - (1,530,232) - (1,530,232) Deferred tax assets 23,653,501 14,271,453 31,624,928 (10,817,356) - 378,325 - 59,110,851 Deferred tax liabilities (95,856,013) (33,810,656) (20,539,643) 11,036,624 510,271 (855,484) 97,445 (139,417,456) Effect of the change in tax rate 3,332,199 146,654 3,478,853 Deferred tax liabilities (95,856,013) (33,810,656) (20,539,643) 14,368,823 656,925 (855,484) 97,445 (135,938,603)

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 430

Income Statement Equity Amounts in Euro As at 1 Change in the Increases/ As at 31 January 2023 perimeter Increases Decreases Decreases December 2023 Temporary differences originating deferred tax assets Taxed provisions 13,913,990 - 3,358,291 (597,357) - 16,674,924 Adjustment of property, plant and equipment 43,767,507 317,077 8,579,320 (20,279,854) - 32,384,050 Deferred accounting gains on intra-group transactions 26,228,453 1,561,458 (16,039,667) - 11,750,244 Valuation of biological assets 14,456,082 10,448,215 - - 24,904,297 Conventional capital remuneration 560,000 - - (280,000) - 280,000 Other temporary differences - 52,846 - - - 52,846 98,926,032 369,923 23,947,284 (37,196,878) - 86,046,361 Temporary differences originating deferred tax liabilities Pensions and other post-employment benefits (358,483) - (34,476) 17,172 (419,643) (795,430) Financial instruments (47,174,485) - - - 29,102,154 (18,072,331) Valuation of biological assets (5,403,744) - - 1,883,900 - (3,519,844) Adjustment of property, plant and equipment (300,707,813) (3,606) (4,124,908) 18,556,522 - (286,279,805) Government grants - (39,840,800) - - - (39,840,800) Other temporary differences (3,862,494) (646,777) - 462,851 331,950 (3,714,470) (357,507,019) (40,491,183) (4,159,384) 20,920,445 29,014,461 (352,222,680) Deferred tax assets 27,204,659 92,481 6,585,503 (10,229,142) - 23,653,501 Deferred tax liabilities (98,314,430) (10,122,796) (1,143,770) 5,753,122 7,971,861 (95,856,013)

When measuring deferred taxes as at 31 December 2024, the rate of 26.50% (27.5% as at 31 December 2023) was used for

companies in Portugal as a result of the 1 p.p. reduction in the corporate income tax rate approved in the State budget for 2025.

Moreover, deferred taxes for companies in the United Kingdom and Spain were calculated at a rate of 25%.

Accounting policies

Deferred tax is calculated based on the liability of the consolidated financial position on the temporary differences

between the book values of the assets and liabilities and their respective tax base. To determine the deferred tax,

the tax rate expected to be in force in the period in which the temporary differences will be reversed is used.

Deferred tax assets are recognised whenever there is a reasonable likelihood that future taxable profits will be generated against

which they can be offset. Deferred tax assets are revised periodically and decreased, whenever it is likely that tax losses will not

be used.

Deferred taxes are recorded as an income or expense for the year, except where they result from amounts recorded directly

under equity, situation in which deferred tax is also recorded under the same caption. Tax benefits attributed to the Group

regarding its investment projects are recognised through the income statement as there is sufficient taxable income to allow its

use.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 431

7. Payroll

7.1. Payroll costs

Amounts in Euro 2024 2023 Remuneration of Corporate Bodies - fixed (Note 7.3) 3,350,825 3,571,826 Remuneration of Corporate Bodies - variable 2,691,151 2,825,009 Other remunerations 151,235,286 129,023,410 Social Security contributions 28,914,957 26,401,281 Post-employment benefits (Note 7.2.4) 1,643,708 1,344,766 Other payroll costs 15,944,227 9,085,911 Payroll costs 203,780,154 172,252,203

Navigator's good performance in 2024 made it possible to reinforce the increase in remuneration, the bonuses awarded to

employees as profit-sharing and the compensations for rejuvenating the team. It should be noted that, by resolution of the

Shareholders' Meeting of 17 May 2023, the remuneration of the Corporate Bodies will now be paid 12 times a year instead of 14.

Overall, the increase in payroll costs is due to the acquisition of the Navigator Tissue UK Group in May 2024, with an impact as at

31 December of Euro 14,213,413.

As at 31 December 2023, Other expenses includes the positive impact of the revision of the estimate of liabilities associated with

the rejuvenation programme in view of the longer delay between expressing interest in joining the programme and actually

leaving, which justifies the increase in this caption in December 2024.

Number of employees by segment at the end of the period

2024 2023 Variation 24/23 Market pulp 295 272 23 UWF 1,782 1,808 (26) Tissue 1,036 586 450 Corporate 838 801 37 3,951 3,467 484

The headcount includes 432 employees assigned to the Consumer tissue business in the UK as a result of the acquisition of

Navigator Tissue UK Group.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 432

Accounting policies

Short-term employee benefits

Acquired rights - holidays and holiday allowance

In accordance with the collective labour agreement applicable to The Navigator Company, S.A. as well as under the agreement

celebrated with the Labour Unions, the Group companies are entitled to a 25 working days leave, as well as to a month’s holiday

allowance. Moreover, employees who work continuous shifts for more than 25 or 30 years get one or two additional days' holiday,

respectively.

Productivity bonus

In 2022, the Group introduced a Productivity bonus in addition to the normal bonus paid to employees. The aim of this bonus is to

focus on increasing productivity and profitability, which are critical and fundamental prerequisites for continued investment in

business growth and sustainable improvements in salaries and benefits. Thus, the Productivity Bonus sets the achievement of

production levels at challenging thresholds corresponding to different levels of remuneration, based on a basic monthly salary.

Bonuses

According to the current Performance Management System (Sistema de Gestão de Desempenho), employees have the right to a

bonus, based on annually defined objectives. The entitlement of this bonus is usually acquired in the year preceding its payment.

These liabilities are recorded in the year in which the Employees acquire the respective right, irrespective of the date of payment,

whilst the balance payable at the date of the consolidated statement of financial position is shown under the caption Current

payables.

Benefits arising from termination of employment

The benefits arising from termination of employment are recognised when the Group can no longer withdraw the offer of such

benefits or in which the Group recognises the cost of restructuring under the provisions recording. Benefits due more than 12

months after the end of the reporting period are discounted to their present value.

7.2. Employee benefits

7.2.1. Introduction

Some Group companies grant their Employees post-retirement benefits, either in the form of defined benefit plans or in the form

of defined contribution plans.

The plans are funded through a closed Pension Fund, managed by an external entity, which subcontracts the management of its

assets to external asset management entities.

A. Pension Plan – Defined benefit

The Group has responsibilities with post-employment benefit plans for a reduced group of Employees who have chosen to

maintain the Defined Benefit Plan (The Navigator Company) or who have chosen to maintain a Safeguard Clause, the latter

following the conversion of their plan into a Defined Contribution Plan (The Navigator Company). In effect, the safeguard clause

gives the Employee the option, at the time of retirement, to pay a pension in accordance with the provisions laid down on the

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 433

Defined Benefit Plan. For those who choose to activate the Safeguard Clause, the accumulated balance in the Defined Contribution

Plan (Conta 1) will be used to finance the liability of the Defined Benefit Plan.

B. Pension Plan – Defined contribution

As at 31 December 2024, three Defined Contribution plans were in force covering 3,278 employees (2023: 3,200 Employees)

(Note 7.2.3).

7.2.2. Defined benefit plan

Policy for managing the risk associated with defined benefit plans

The Group's exposure to risk is limited to the number of existing beneficiaries and will tend to decrease, since there are no

defined benefit plans open to new employees in the Group.

The most significant risks to which the Group is exposed through defined benefit plans include:

i. Risk of change in the longevity of participants.

ii. Market rate variation risk – rate variation impacts the rate used to discount liabilities (technical interest rate) which is

based on yield curves of highly rated bonds with maturities similar to the liabilities' expiry dates and the fixed rate of

return of the assets. The Group uses yield curves in order to monitor the evolution of rates and performs sensitivity

analyses of interest rate variations with the aim of foreseeing and preventing the consequent impact on the fund's

funding level.

iii. Risk of change in the wage and pension growth rate.

iv. Return on the fund's financial assets – the Group closely monitors the evolution of the fund's assets, as well as the

evolution of the main financial market indicators, revisiting the investment policy approved for the management of the

assets whenever justifiable, and at least every three years. The investment policy is aligned with a conservative view of

asset management and defined on the basis of the responsibilities to be financed by the fund.

The Group's goal is to maintain a liability coverage level of 90%, thereby safeguarding against the above risks.

Net liabilities

Net liabilities reflected in the consolidated statement of financial position and the number of beneficiaries of the defined benefit

plans in force in the Group are detailed as follows:

2024 2023 No. of No. of Amounts in Euro Beneficiaries Amount Beneficiaries Amount Past service liabilities Active employees, including individual accounts 301 43,344,735 352 50,509,668 Alumni 114 17,567,947 112 17,469,425 Retired employees 662 98,711,371 622 90,277,782 Market value of pension funds (160,971,371) (159,034,022) Total net liabilities 1,077 (1,347,318) 1,086 (777,147)

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 434

Historical information - last five years

Amounts in Euro 2020 2021 2022 2023 2024 Present value of liabilities 191,253,527 191,002,589 157,269,646 158,256,875 159,624,053 Fair value of assets and reserves 178,691,062 185,327,671 154,433,916 159,034,022 160,971,371 Surplus / (deficit) (12,562,465) (5,674,918) (2,835,730) 777,147 1,347,318

Evolution of defined benefit plan liabilities

Current Opening services Interest Actuarial Payments Closing 2024 balance cost expense deviations performed balance Amounts in Euro Pensions with autonomous fund 158,256,875 20,101 5,414,858 3,243,001 (7,310,782) 159,624,053 158,256,875 20,101 5,414,858 3,243,001 (7,310,782) 159,624,053

Current Opening services Interest Actuarial Payments Closing 2023 balance cost expense deviations performed balance Amounts in Euro Pensions with autonomous fund 157,269,646 18,878 5,398,760 2,467,179 (6,897,588) 158,256,875 157,269,646 18,878 5,398,760 2,467,179 (6,897,588) 158,256,875

The average expected duration of the defined benefit liabilities is 12.5 years (2023: 13 years).

Funds

Funds allocated to the defined benefit pension plans - evolution

Amounts in Euro 2024 2023 Opening balance 159,034,022 154,433,916 Allocations for the period - - Expected income for the period 5,441,354 5,291,759 Remeasurement 3,806,777 6,205,945 Pensions paid (7,310,782) (6,897,598) Closing balance 160,971,371 159,034,022

The pension fund assets allocated to the defined benefit plan are managed by the following entities:

Amounts in Euro 2024 2023 Defined benefits and Conta 1: AGEAS - Pensions (51,992) (17,192) Schroders 55,790,911 64,806,718 Santander AM 56,467,629 65,605,927 Account 1 - Julius Baer 48,764,823 28,638,569 Total defined benefits and Conta 1 160,971,371 159,034,022

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 435

Funds allocated to defined benefit plans - composition of assets

Amounts in Euro 2024 % 2023 % Securities listed in the market Bonds 98,435,081 61.15% 96,701,081 60.81% Shares 41,216,140 25.60% 38,457,610 24.18% Public debt 15,406,040 9.57% 17,419,598 10.95% Liquidity 1,260,572 0.78% 2,206,803 1.39% Other short-term investments 4,653,538 2.89% 4,248,930 2.67% 160,971,371 100.00% 159,034,022 100.00%

The assets of the pension fund do not include any assets of the Group.

7.2.3. Defined contributions plan

As at 31 December 2024 and 31 December 2023, three defined contribution plans were in force on behalf of Employees.

The assets of the pension fund that finance the defined contribution plans are under the management of the AGEAS, as detailed

below:

No. of Profitability No. of Profitability Amounts in EuroBeneficiaries % 2024 Beneficiaries % 2023 Defined Contribution (Ageas Pensions): Defensive sub-fund 112 3.34% 5,608,582 122 7.17% 6,262,270 Conventional sub-fund 408 5.20% 15,773,907 392 8.50% 15,291,344 Dynamic sub-fund 771 8.54% 15,999,063 737 10.90% 15,713,487 Aggressive sub-fund 1,987 11.42% 7,209,476 1,949 13.30% 6,398,935 Total defined contribution 3,278 44,591,028 3,200 43,666,036

7.2.4. Expenses incurred with post-employment benefit plans

The effect in the income statement for the periods ended 31 December 2024 and 31 December 2023 was as follows:

2024 2023 Defined contribution Defined –Current contribution – Impact on Current Contributions Impact on services Contributions net result services for the net resultAmounts in Euro cost Net interest for the period (Note 7.1) cost Net interest period (Note 7.1) Pensions with autonomous 20,101 (26,496) - (6,395) 18,878 107,001 - 125,879 fund Defined contributions plans - - 1,650,103 1,650,103 - - 1,218,887 1,218,887 20,101 (26,496) 1,650,103 1,643,708 18,878 107,001 1,218,887 1,344,766

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 436

7.2.5. Remeasurement recognised directly in other comprehensive income

2024 Remeasurement Expected Experience return on Deferred Impact on Amounts in Euro assumptions plan assets Gross amount taxes Equity Pensions with autonomous fund (2,467,179) 3,030,955 563,776 17,693 581,469 (2,467,179) 3,030,955 563,776 17,693 581,469 775,822 775,822 - -

2023 Remeasurement Expected Experience return on Deferred Impact on Amounts in Euro assumptions plan assets Gross amount taxes Equity Pensions with autonomous fund (2,467,179) 6,205,945 3,738,766 (115,461) 3,623,305 (2,467,179) 6,205,945 3,738,766 (115,461) 3,623,305

The re-measurements referred to above result from experience gains and losses, both in financial and demographic terms.

Estimates and judgements

Actuarial assumptions

2024 2023 Social Security Benefits Formula Decree Law 187/2007 of 10 May Disability table EKV 80 EKV 80 Mortality table TV 88-90 TV 88-90 Discount rate 3.50% 3.50% Wage growth rate 2.00% 2.00% Return rate on plan assets 3.50% 3.50% Pensions growth rate 1.5% or 2.00% 1.5% or 2.00%

Sensitivity analysis

Amounts in Euro 2024 2023 0.5% decrease in the discount rate Increase in liabilities assumed 10,036,078 10,348,867 0.5% increase in the discount rate Decrease in liabilities assumed (9,123,660) (9,316,819) 0.5% decrease in the wage growth rate Decrease in liabilities assumed (1,636,291) (1,886,275) 0.5% increase in the wage growth rate Increase in liabilities assumed 1,723,903 1,976,098 0.5% decrease in the pensions growth rate Decrease in liabilities assumed (7,547,496) (7,646,125) 0.5% increase in the pensions growth rate Increase in liabilities assumed 8,111,198 8,056,199

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 437

Accounting policies

Post-employment benefits - defined benefit plan

Some of the Group subsidiaries have assumed the commitment to make payments to their employees in the form of

complementary retirement pensions, disability, early retirement and survivors’ pensions, having constituted defined-benefit plans.

The Group set up autonomous pension funds as a means of funding most of the liabilities. Based on the projected credit unit

method, the Group recognises the costs with the attribution of these benefits as the services are provided by the employees. The

total liability is estimated separately for each plan at least once every six months, on the date of closing of the interim and annual

accounts, by a specialised and independent entity.

The liability thus determined is presented in the consolidated statement of financial position, less the fair value of the funds set

up, under Pension liabilities.

Actuarial deviations resulting from changes in the value of estimated liabilities, as a consequence of changes in the financial and

demographic assumptions used and experience gains, added to the differential between the actual return on fund assets and the

estimated share of net interest, are designated as re-measurements and recorded directly in the statement of comprehensive

income, under retained earnings.

Net interest corresponds to the application of the discount rate to the value of net liabilities (value of liabilities less the fair value of

fund assets) and is recognised in the income statement for the period under Payroll costs.

The gains and losses generated by a curtailment or settlement of a defined-benefit plan are recognised in the income statement

for the period when the curtailment or settlement occurs. A curtailment occurs when there is a material reduction in the number

of employees.

Costs for past liabilities resulting from the implementation of a new plan or increases in benefits attributed are recognised

immediately in profit/(loss) for the period.

Post-employment benefits - defined contribution plan

Most of the Group subsidiaries assumed commitments regarding payments to a defined contribution plan in a percentage of the

employees’ salary, in order to provide retirement, disability, early retirement and survivors’ pensions.

To this end, Pension Funds have been set up to capitalise on those contributions, for which employees may still make voluntary

contributions, but for which the Group does not assume any additional contribution responsibilities or a pre-fixed return. Thus, the

contributions made are recorded as expenses of the period in which they are recognised, regardless of the time of their

settlement.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 438

7.3. Remuneration of corporate bodies

Amounts in Euro 2024 2023 Navigator Corporate Bodies Board of Directors 2,892,317 3,094,271 Supervisory Board 75,500 83,521 Environment Board 73,000 79,750 Board of the General Shareholders Meeting 6,000 8,000 3,046,817 3,265,542 Corporate Bodies of other Group companies 304,008 306,283 Total (Note 7.1) 3,350,825 3,571,826

Remuneration of the members of the Board of Directors

Full details of the remuneration policy for the members of Navigator's Board of Directors are described in the company's Corporate

Governance Report.

Three of the current directors are members of pension plans of Navigator Brands, S.A., a subsidiary of the Company, as

Employees of that company, before joining management positions.

As at 31 December 2024 and 2023, regarding the members of the Board of Directors of Navigator, there were no: i) any

additional liabilities allocated to other long-term benefits, ii) employment termination benefits, iii) share-based payments and iv)

any outstanding balances.

8. Financial instruments

8.1. Financial risk management

For the Navigator Group as a whole, the Company has a risk-management programme, which focuses its analysis on the financial

markets with a view to mitigate the potential adverse effects on its financial performance. Risk management is undertaken by the

Group's Financial Management in accordance with the policies approved by the Board of Directors and monitored by the Risks and

Control Commission.

The Company adopts a proactive approach to risk management, as a way to mitigate the potential adverse effects associated with

those risks, namely the exchange rate risk and interest rate risk.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 439

8.1.1. Currency risk

Currency risk management policy

A significant part of the Navigator Group’s sales is priced in currencies other than the Euro, therefore its evolution can have a

significant impact on the cash flows obtained from the Group's future sales, with the currency with the greatest impact being

the USD. Also, sales in GBP, PLN and CHF have some weight, having sales in other currencies less expression.

Purchases of some raw materials are also made in USD, namely part of wood and long-fibre pulp imports of wood and

acquisitions of long-fibre pulp. Therefore, changes in USD may have an impact on acquisition values.

Moreover, once a sale or purchase is made in a currency other than the Euro, the Group becomes exposed to exchange rate

risk until the receipt or payment of such sale or purchase, if no hedging instruments are in place. As a result, there is a

significant number of receivables and payables, the latter with lesser expression, exposed to exchange rate risk.

Use of derivative financial instruments

The Group manages foreign exchange risks by using derivative financial instruments, in accordance with a policy that is

subject to periodic review and whose purpose is to limit the exchange risk associated with future sales and purchases and

accounts receivable and payable and other assets which are denominated in currencies other than the Euro.

In the periods presented, the Group holds derivatives that are hedging the exchange rate risk of future operations in

currencies other than the presentation currency (see Note 8.2 - Derivative financial instruments).

Exposure of financial assets and liabilities to exchange rate risk and sensitivity analysis

South Amounts in Euro US Sterling Polish Turkish Swiss Mozambican Moroccan African Total dollar pound zloti lira Franc metical dirham rand (Euro) Amounts in foreign currency Cash and cash equivalents 1,855,837 1,026,550 114,545 2,182,313 1,828 47,272,452 450,239 8,949,781 4,319,282 Receivables 140,341,158 46,228,701 9,733,718 124,322 1,846,939 7,720,540 - 10,414,727 195,727,661 Total financial assets 142,196,995 47,255,251 9,848,263 2,306,635 1,848,767 54,992,992 450,239 19,364,508 200,046,943 Interest-bearing liabilities - 17,490,990 - - - - - - 21,094,322 Payables 3,046,921 17,102,563 12,888 104,309 78,966 13,405,576 135,216 3,451,095 24,037,936 Total financial liabilities 3,046,921 34,593,553 12,888 104,309 78,966 13,405,576 135,216 3,451,095 45,132,258 Financial net position in 145,243,916 81,848,804 9,861,151 2,410,944 1,927,733 68,398,568 585,455 22,815,603 245,179,201 foreign currency Financial net position in Euro 139,805,483 98,710,538 2,306,702 65,627 2,048,165 1,024,084 55,657 1,162,946 245,179,201 Impact of + 10% change in all exchange rates on profit/(loss) for the 21,633,212 period Impact of - 10% change in all exchange rates on profit/(loss) for the (26,440,592) period Impact of + 10% change in all exchange rates on profit/(loss) for the 655,806 period Impact of + 10% change in all exchange rates on profit/(loss) for the (801,541) period

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 440

2023 South Amounts in Euro US Sterling Polish Turkish Swiss Mozambican Moroccan African Total dollar pound zloti lira Franc metical dirham rand (Euro) Amounts in foreign currency Cash and cash equivalents 3,754,684 863,437 259,824 525,311 2,731 24,591,876 418,145 40,922 4,858,597 Receivables 145,638,716 21,697,447 14,349,866 124,322 1,572,289 16,154,123 - - 162,002,359 Total financial assets 149,393,400 22,560,884 14,609,690 649,633 1,575,020 40,745,999 418,145 40,922 166,860,956 Interest-bearing liabilities - - - - - - - - - Payables (12,831,555) (64,414) (25,273) (5,124,236) (84,250) - (134,963) - (11,952,451) Total financial liabilities (12,831,555) (64,414) (25,273) (5,124,236) (84,250) - (134,963) - (11,952,451) Financial net position in 136,561,845 22,496,470 14,584,417 (4,474,603) 1,490,770 40,745,999 283,181 40,922 154,908,505 foreign currency Financial net position in 123,585,380 25,884,789 3,360,852 (137,035) 1,609,903 576,730 25,874 2,011 154,908,505 Euro Impact of + 10% change in all exchange rates on profit/(loss) for the period 14,082,591 Impact of - 10% change in all exchange rates on profit/(loss) for the period (17,212,056)

In this Note, the Group discloses the exposure of financial assets and liabilities to foreign exchange rate risk, as well as the

respective sensitivity analysis. There are currencies in which the Group has carried out transactions but in which, at the balance

sheet date, it does not have relevant foreign exchange exposures, which is why the exchange rates disclosed in note 1.4.4 are

more numerous than the currencies presented in this note.

8.1.2. Interest rate risk

Interest rate risk management policy

A significant share of the Group’s financial liabilities cost are indexed to short-term reference interest rates, which are

reviewed more than once a year (generally every six months for medium and long-term debt). Hence, changes in interest

rates can have an impact on the Group’s income statement.

The Group periodically reviews its interest rate risk management strategy. In view of the current level of interest rates, we

have favoured the contracting of fixed rate debt.

Use of derivative financial instruments

When deemed appropriate by the Board, the Group uses derivative financial instruments (Note 8.2), namely swaps, with the

purpose of fixing the interest rate on loans obtained, within certain parameters, deemed appropriate by the Group's risk

management policies.

Exposure to interest rate risk

As at 31 December 2024, approximately 11% (31 December 2023: 5%) of the Navigator Group’s financial liabilities are indexed

to short-term reference interest rates, revised in periods below one year (usually 6-month rates for long-term debt), plus duly

negotiated risk spreads. Hence, changes in interest rates can impact the Group’s earnings.

The Group has favoured the contracting of fixed rate debt and has derivative financial instruments to cover its interest rate risk,

namely interest-rate swaps, with the purpose of fixing the interest rate on the Navigator Group’s borrowings within certain limits.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 441

As at 31 December 2024 and 31 December 2023, the detail of the financial assets and liabilities with interest rate exposure,

considering the maturity or the next interest-fixing date is as follows:

2024 Up to 1 3-12 More than Amounts in Euro month 1-3 months months 1-5 years 5 years Total Assets Current Cash and cash equivalents 286,628,866 - - - - 286,628,866 Total financial assets 286,628,866 - - - - 286,628,866 Liabilities Non-current Interest-bearing liabilities - - - 10,000,000 80,000,000 90,000,000 Finance leases 2,715,195 2,715,195 Current Interest-bearing liabilities - 23,891,108 - - 23,891,108 Finance leases 1,717,499 1,717,499 Total financial liabilities - - 25,608,607 12,715,195 80,000,000 118,323,802 Cumulative differential 286,628,866 286,628,866 261,020,259 248,305,064 168,305,064

From 2024 onwards, the tables above show assets and liabilities with exposure to interest rate risk, not including assets and

liabilities whose interest rate risk is fully covered by derivative financial instruments with a maturity and/or repricing identical to

the underlying. In order to make the information presented comparable, the appropriate changes were made to the table for the

homologous period, ensuring the consistency of the criteria adopted in preparing this disclosure. In liquidity risk note 8.1.3, the

contractual maturity of all financial liabilities is shown, regardless of whether the interest rate risk is hedged by derivative financial

instruments.

2023 Up to 1 3-12 More than 5 Amounts in Euro month 1-3 months months 1-5 years years Total Assets Current Cash and cash equivalents 169,464,967 - - - - 169,464,967 Total financial assets 169,464,967 - - - - 169,464,967 Liabilities Non-current Interest-bearing liabilities - - - 23,500,000 - 23,500,000 Current Interest-bearing liabilities - 2,000,000 9,583,333 - - 11,583,333 Total financial liabilities - 2,000,000 9,583,333 23,500,000 - 35,083,333 Cumulative differential 169,464,967 167,464,967 157,881,634 134,381,634 134,381,634

Estimates and judgements

Sensitivity analysis

The Group uses the sensibility analysis technique to measure impacts on the income statement and equity of

increase or decrease on interest rates maintaining the other variables constant. This is an illustrative analysis only, since changes

in market rates rarely occur separately.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 442

The sensitivity analysis is based on the following assumptions:

i) Changes in market interest rates affect interest income and expenses arising from variable financial instruments;

ii) Changes in market interest rates affect the fair value of derivative financial instruments as well as other financial assets or

liabilities;

iii) Changes in fair value of derivative financial instruments and other financial assets and liabilities are measured using the

discounted cash flows method, with market interest rates at year end.

A 0.50% increase in interest rates on which interest on loans are calculated would have an impact on its profit before income tax,

for the period ended 31 December 2024 by approximately Euro 569,456 (31 December 2023: €175,417).

8.1.3. Liquidity risk

Liquidity risk management policy

The Group manages the liquidity risk in two ways:

i. ensuring that its financial debt has a high medium- and long-term component with maturities appropriate to the

characteristics of the industries where it operates, and

ii. by contracting with financial institutions credit facilities available at all times for an amount that guarantees adequate

liquidity.

Available but not used credits

The Group's policy is to maintain credit facilities at adequate levels to, together with the amount of Cash and Cash

Equivalents in order to guarantee, with some comfort margin, the cash cycle expected for the next 12 months.

Contractual maturity of financial liabilities (undiscounted flows, including interest)

2024 3-12 More than Amounts in Euro -1 month 1-3 months months 1-5 years 5 years Total Liabilities Interest-bearing liabilities (Note 5.7) Bond loans 420,000 10,521,500 99,941,464 392,316,564 210,017,643 713,217,171 Commercial paper - 35,497,000 248,500 35,248,500 50,000,000 120,994,000 Bank loans - 4,969,536 10,158,078 70,362,247 37,668,335 123,158,196 Other loans - - 7,219,439 15,905,149 - 23,124,588 Derivative financial instruments (Note 8.2) - 1,259,512 2,879,804 2,659,143 (783,753) 6,014,706 Total liabilities 420,000 52,247,548 120,447,285 516,491,603 296,902,225 986,508,661 Of which interest (at the rates prevailing at 77,506,038 that date)

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 443

2023 3-12 More than Amounts in Euro -1 month 1-3 months months 1-5 years 5 years Total Liabilities Interest-bearing liabilities (Note 5.7) Bond loans 420,000 10,721,500 30,895,000 432,923,500 - 474,960,000 Commercial paper - 745,500 35,745,500 71,491,000 - 107,982,000 Bank loans 15,000,000 5,189,218 16,188,037 62,679,270 12,840,786 111,897,311 Other loans - - 7,219,439 23,227,870 - 30,447,309 Derivative financial instruments (Note 8.2) - - (10,087,985) (14,934,263) - (25,022,248) Total liabilities 15,420,000 16,656,218 79,959,992 575,387,376 12,840,786 700,264,372 Of which interest (at the rates prevailing at 63,327,406 that date)

The table considers the debt issued and the long-term debt contracted and not disbursed that will refinance the debt maturing in

2025 (Available and undrawn credit facilities).

The contractual maturity of the interest

bearing liabilities presupposes the fulfilment of financial covenants, as

detailed in Note 5.7

- Interest-bearing liabilities.

Available and undrawn credit facilities

Amounts in Euro 2024 2023 Undrawn credit facilities Commercial paper (with long term underwriting) 75,000,000 167,250,000 Long-term financing contracted and not disbursed 140,000,000 115,000,000 Other credit facilities 95,163,917 5,450,714 310,163,917 287,700,714 Commercial paper used (Note 5.7) 120,000,000 105,000,000 Other credit facilities used 787,420,613 561,889,769 Contracted credit facilities (nominal value) 1,217,584,530 954,590,483

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 444

8.1.4. Credit risk

Credit risk management policy

The Group is exposed to credit risk on balances receivable from Trade receivables and other debtors and has adopted a policy

of managing risk coverage within certain levels through credit insurance with a specialised independent company.

The Group has adopted a policy of credit insurance for the majority of Trade receivables, with a 5% deductible. As such, its

exposure to credit risk is considered to have been mitigated up to acceptable levels, when compared with its sales. Most sales

that are not covered by credit insurance are covered by bank guarantees, letters of credit, documentary credits or retention

of title agreements, and any unhedged exposure is within limits previously approved by the Executive Committee.

However, the worsening of global economic conditions or adversities affecting only economies on a local scale may lead to

deterioration in the ability of the Navigator Group’s Customers to meet their obligations, leading entities providing credit

insurance to significantly decrease the amount of credit facilities that are available to those Customers. This scenario may

result in limitations on the amounts that can be sold to some Group Customers without directly incurring credit risk levels t

hat

are not compatible with the risk policy in this area.

Cash equivalents

The Navigator Group adopts strict policies in approving its financial counterparties, limiting its exposure in accordance with an

individual risk analysis and within previously approved limits.

Maximum exposure to credit risk

The Group's maximum exposure to the credit risk of financial assets corresponds to their net amount, as follows:

Amounts in Euro 2024 2023 Non-current Other financial investments (Note 8.3) - - Receivables (Note 4.2) 13,142,937 44,399,506 Current Receivables (Note 4.2) 496,698,621 424,740,973 Cash and cash equivalents (Note 5.9) 286,628,866 169,464,967 796,470,424 638,605,446

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 445

Ageing structure of trade receivables balances

As at 31 December 2024 and 2023, Trade receivables balances presented the following ageing structure, considering as reference

the maturity date of the outstanding amounts before impairments:

Amounts in Euro 2024 2023 Amounts not due 273,547,400 238,684,032 from 1 to 90 days 30,245,008 20,206,869 from 91 to 180 days 1,022,452 127,789 from 181 to 360 days 215,098 42,151 from 361 to 540 days 6,341 - from 541 to 720 days 6,198 - more than 721 days - - 305,042,497 259,060,841 Balances considered impaired 3,635,137 3,293,670 Impairment (3,635,137) (3,293,670) Net balance of trade receivables (Note 4.2) 305,042,497 259,060,841 Trade receivables covered by credit insurance 264,061,504 226,072,918 Trade receivables covered by bank guarantees 2,000,000 1,300,000 Trade receivables covered by title retention agreements 1,873,390 7,046,082 Trade receivables covered by letters of credit / documentary remittances 33,593,182 22,910,875 Covered receivables 301,528,076 257,329,875 Available and undrawn credit facilities 463,762,720 503,473,207 Credit hedging facilities contracted 765,290,796 760,803,082

The amounts shown above correspond to the amounts outstanding according to the contracted due dates. The amounts not

covered of Euro 3,514,421 relate to amounts previously approved by the Executive Committee of the Navigator Group (2023:

€1,730,966).

Despite some delays in the settlement of those amounts, that does not result, in accordance with the available information, in the

identification of impairment losses other than the ones considered through the respective losses. These are calculated based on

the information periodically collected on the financial behaviour of the Group’s Customers, which allow, in conjunction with the

experience obtained in the client portfolio analysis and with the history of credit defaults, in the part not attributable to the

insurance company, to define the amount of losses to be recognised in the period. The guarantees in place for a significant part of

outstanding and long-term balances, justify the fact that no impairment loss has been recorded for those balances. The rules

defined by the credit risk insurance policy applied by the Group, ensure a significant hedge of all outstanding balances.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 446

The analysis of the open balances, by business area, is as follows:

2024 Market Amounts in Euro Pulp UWF Paper Tissue Paper Energy Support Total Amounts not due 28,197,445 140,978,332 98,205,591 600,064 5,565,968 273,547,400 from 1 to 90 days 10,833,565 14,703,039 2,951,668 144,586 1,612,150 30,245,008 from 91 to 180 days 59,624 - 654,571 - 308,255 1,022,450 from 181 to 360 days - - 194,692 - 20,407 215,099 from 361 to 540 days - - 6,341 - 6,341 from 541 to 720 days - - 6,199 - 6,199 more than 721 days - - - - - 39,090,634 155,681,371 102,019,062 744,650 7,506,780 305,042,497

2023 Market Amounts in Euro Pulp UWF Paper Tissue Paper Energy Support Total Amounts not due 25,375,941 137,661,510 63,994,452 2,752,026 8,900,103 238,684,032 from 1 to 90 days 9,532,915 7,413,930 2,077,939 - 1,182,085 20,206,869 from 91 to 180 days - - 127,789 - - 127,789 from 181 to 360 days - - 42,151 - - 42,151 from 361 to 540 days - - - - - - from 541 to 720 days - - - - - - more than 721 days - - - - - - 34,908,856 145,075,440 66,242,331 2,752,026 10,082,188 259,060,841

The table below represents the quality of the Navigator Group’s credit risk, as at 31 December 2024 and 31 December 2023, for

financial assets (cash and cash equivalents), (Highest credit rating by one of the two rating agencies: Standard and Poor’s, or

Fitch):

Financial Institutions Amounts in Euro 2024 2023 Rating AA - - AA- - - A+ 179,063,225 56,769,567 A 98,950,633 61,675,370 A- 2,305,027 42,824,483 BBB+ 1,315,948 2,643,288 BBB 4,028,844 1,546,150 BBB- 69,018 2,358,707 BB+ - BB - BB- - B+ - B - B- - Other 896,171 1,647,402 286,628,866 169,464,967

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 447

“Other” amounts include bank deposits with banks or entities with no rating, namely local banks in Mozambique and other foreign

branches.

The Navigator Group adopts strict policies in approving its financial counterparties, limiting its exposure in accordance with an

individual risk analysis and within previously approved limits.

Impairment from trade receivables and other debtors

Impairment Trade receivables Other Total Amounts in Euro debtors Balance as at 1 January 2023 (6,621,084) (283,742) (6,904,826) Increase – IFRS 9 impact on profit/(loss) for the period 1,279,362 - 1,279,362 Increases (Note 2.3) (535,067) (61,746) (596,813) Reversals 4,634,383 - 4,634,383 Charge-off (2,051,264) - (2,051,264) Balance as at 31 December 2023 (3,293,670) (345,488) (3,639,158) Change in the perimeter (40,111) - (40,111) Increase – IFRS 9 impact on profit/(loss) for the period (1,477,280) - (1,477,280) Increases (Note 2.3) (242,088) (98,476) (340,564) Reversals 3,924,074 181,747 4,105,821 Charge-off 86,270 - 86,270 Transfers (2,591,399) - (2,591,399) Exchange rate adjustment (933) - (933) Balance as at 31 December 2024 (3,635,137) (262,217) (3,897,354)

Accounting policies

Impairment of debt instruments

The Group assesses, on a prospective basis, the expected credit losses associated with its financial assets measured at amortised

cost and at fair value through other comprehensive income, in accordance with IFRS 9.

On this basis, the Group recognises expected credit losses throughout the lifetime of financial instruments that have been subject

to significant increases in credit risk since its initial recognition, assessed either individually or collectively, considering all

reasonable and sustainable information, including available prospective information.

If, at the reporting date, the credit risk associated with a financial instrument has not increased significantly since its initial

recognition, the Group measures the impairment of that financial instrument by an amount equivalent to the expected credit

losses.

IFRS 9 provides that for the calculation of these impairments, one of two models is used: the 3-step method or the use of a

matrix, the distinguishing component being the existence or not of a significant financing component. For Navigator's financial

assets, since it is not a financial institution and there are no assets that have a significant financing component, the use of a

matrix was chosen.

The model adopted for the impairment assessment in accordance with IFRS 9 is as follows:

i. Calculate the total credit sales made by the Group over the last 12 months, as well as the total amount of bad debts relating

to them;

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 448

ii. Determine the Customers’ payment profile, by setting buckets of receipt frequency;

iii. Based on I. and II. above, estimate the probability of default (i.e., the amount of bad debts calculated at I. compared to the

balance of outstanding sales in each bucket calculated at II.);

iv. Adjust the percentages of future forecasts obtained in III.;

v. Apply the default percentages as calculated in IV. to the balances of Customers still outstanding at the reporting date.

Although IFRS 9 assumes 90 days as “default”, the Navigator Group considered a period of 180 days, since the experience of real

losses before this period is low. This period is aligned with the current risk management policies of the company, namely in what

regards the credit insurance hired, and to the fact that there is no sales with significant components of funding in light of IFRS 15.

Additionally, the company evaluated the impact of considering 180 days of “default” instead of the 90 days and the Expected

Credit Loss would not change significantly.

In addition to this period, in the event of an accident in the credit insurance company, the model considers the limit of 5% paid by

the Navigator Group (10% for national Customers).

In addition, the Group recognises impairment on a case-by-case basis, based on specific balances and specific past events,

considering the historical information of the counterparties, their risk profile and other observable data in order to assess whether

there are objective indicators of impairment for these financial assets. The Group uses the write-off procedure only when the

credit is considered to be definitely uncollectible by a court decision.

8.2. Derivative financial instruments

Movements in derivative financial instruments

2024 2023 Trading Hedging Trading Hedging Amounts in Euro derivatives derivatives Net total derivatives derivatives Net total Balance at the beginning of the period (4,068,868) 17,835,988 13,767,120 (3,106,233) 46,938,143 43,831,910 New contracts / settlements 4,967,834 (11,296,062) (6,328,228) (1,999) (9,722,524) (9,724,523) Change in fair value through profit/(loss) (2,530,279) 11,328,732 8,798,453 (960,636) 9,722,523 8,761,887 (Note 5.10) Change in fair value through other - (1,526,544) (1,526,544) - (29,102,154) (29,102,154) comprehensive income (Note 5.5) Balance at the end of the period (1,631,313) 16,342,114 14,710,801 (4,068,868) 17,835,988 13,767,120

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 449

8.2.1. Detail and maturity of derivative financial instruments by nature

2024 Positive Negative Amounts in Euro Notional Currency Maturity (Note 4.2) (Note 4.3) Net amount Hedging Hedging (future sales) 272,000,000 USD 2025 - (1,103,142) (1,103,142) Hedging (future sales) 130,000,000 GBP 2025 - (262,405) (262,405) Interest rate swaps - Bonds 535,000,000 EUR 2031 8,383,516 (3,314,640) 5,068,876 Energy 24,653,150 EUR 2025 12,638,785 - 12,638,785 21,022,301 (4,680,187) 16,342,114 Trading Foreign exchange forwards (future sales) 60,500,000 USD 2025 - (1,597,134) (1,597,134) Foreign exchange forwards (future sales) 40,900,000 GBP 2025 - (34,179) (34,179) - (1,631,313) (1,631,313) 21,022,301 (6,311,500) 14,710,801

2023 Positive Negative Net Amounts in Euro Notional Currency Maturity (Note 4.2) (Note 4.3) amount Hedging Hedging (future sales) 287,500,000 USD 2024 1,348,010 (608,037) 739,973 Interest rate swaps - Bonds 355,000,000 EUR 2028 17,064,360 - 17,064,360 BHKP pulp 7,092,000 USD 2024 31,655 - 31,655 18,444,025 (608,037) 17,835,988 Trading Foreign exchange forwards (future sales) (46,000,000) USD 2024 1,014,913 (4,987,262) (3,972,349) Foreign exchange forwards (future sales) (6,099,807) GBP 2024 - (96,519) (96,519) 1,014,913 (5,083,781) (4,068,868) 19,458,938 (5,691,818) 13,767,120

Cash flow hedge | Exchange rate risk EUR/USD and EUR/GBP

During the last 6 months of 2024, the Group contracted derivative financial instruments by acquiring USD 272,000,000 and GBP

130,000,000 in Zero Cost Collar, thus guaranteeing total coverage of the estimated value of exposure for 2025.

Interest rate hedge

During the second quarter of 2024, the Group contracted two swaps in the amount of Euro 50,000,000 each to fix the interest rate

associated with the Navigator 2024-2029 bond loan and the Navigator 2024-2031 bond loan, in the amount of Euro 50,000,000,

each, both starting in June 2024.

During the first quarter of 2024, the Group contracted two swaps in the amount of Euro 50,000,000 each, to fix the interest rate

associated with the Navigator 2024-2031 bond loan in the amount of Euro 100,000,000, both starting in November 2024.

As a result, it was possible to hedge the interest rate risk on credit lines amounting to Euro 535,000,000.

Energy Hedging

In the first quarter of 2024, the Navigator Group entered into Swaps to fix the purchase price of electricity and natural gas for a

volume of approximately 199,740 MWh of electricity and 581,064 MWh of natural gas, starting in 2025, covering approximately

25% of its needs.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 450

Commodities Hedging – BHKP

The Navigator Group uses derivative financial instruments in order to minimise the exposure risk associated with the variation of

the pulp price, indexed to PIX, in USD. During the second quarter of 2023, the Group entered into a Swap valued at USD 7,092,000

to fix the price of short fibre pulp (BHKP) for 2024. Moreover, in the first quarter of 2024 the Group contracted a new Swap in the

amount of USD 23,400,000 to fix the sale price of short fibre pulp (BHKP), however, as at 31 December 2024 both instruments had

expired.

Estimates and judgements

Fair value of derivative financial instruments

Whenever possible, the fair value of derivatives is estimated on the basis of quoted instruments. In the absence of market prices,

the fair value of derivatives is estimated through the discounted cash-flow method and option valuation models, in accordance

with prevailing market assumptions.

Accounting policies

The fair value of derivative financial instruments is included under Payables (Note 4.3), when negative, and under

Receivables (Note 4.2), when positive.

In accordance with IFRS 9 - Financial Instruments, the Group has opted to continue applying the hedge accounting requirements

of IAS 39 - Financial Instruments, until there is greater visibility on the Dynamic Risk Management (macro hedging) project

currently in progress.

Whenever expectations of changes in interest or exchange rates so justify, the Group hedges these risks through derivative

financial instruments, such as interest rate swaps (IRS), interest rate and foreign exchange collars, forwards, etc.

Trading derivative financial instruments

Although the derivatives contracted by the Group represent effective economic hedges of risks, not all of them qualify as hedging

instruments in accounting terms to satisfy the applicable rules and requirements. Instruments that do not qualify as hedging

instruments are recorded in the Consolidated statement of financial position at their fair value and changes are recognised in Net

financial results (Note 5.10), when related to financing operations, or in External services and supplies (Note 2.3) or Revenue

(Note 2.1), when referring to hedging of sales receivable flows in a currency other than the presentation currency.

Derivative financial instruments - hedging

Derivative financial instruments used for hedging purposes may be recognised as hedging instruments provided that they comply,

cumulatively, with the conditions set out in IAS 39.

Cash flow hedging (interest rate, exchange rate and commodity risk - BHKP)

In order to manage its exposure to interest rate risk and exchange rate risk, the Group enters into cash flow hedges.

Those transactions are recorded in the Interim consolidated statement of financial position at their fair value, if considered

effective hedges. The effective portion of changes in the fair value of derivatives that are designated and qualify as cash flow

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 451

hedges is recognised in other comprehensive income. The gain or loss relating to the ineffective portion is recognised immediately

in the income statement.

Accumulated amounts in equity are reclassified to profit/(loss) in the periods when the hedged item affects the Income statement

(for example, when the forecast sale that is hedged takes place). The gain or loss relating to the effective portion of interest rate

swaps hedging variable rate borrowings is recognised in the income statement under Net financial results (Note 5.10). However,

when the forecast transaction that is hedged results in the recognition of a non-financial asset (for example, inventory or

property, plant and equipment), the gains and losses previously deferred in equity are transferred from equity and included in the

initial measurement of the cost of the asset.

When a hedging instrument expires or is sold, or when a hedge no longer meets the criteria for hedge accounting, any cumulative

gain or loss existing in equity is recycled to the income statement, unless the hedged item is a forecast transaction, in which case

any cumulative gain or loss existing in equity at that time remains in equity and is recognised when the forecast transaction is

ultimately recognised in the income statement.

Derivative financial instruments used by Navigator Group

Foreign exchange trading derivatives

The Navigator Group has a currency exposure on sales invoiced in foreign currencies, namely US dollars (USD) and pounds

sterling (GBP). As the Group’s financial statements are presented in Euro, it is exposed to an economic risk on the conversion of

these currency flows to the Euro. The Group is also required, albeit to a lesser degree, to make certain payments in those same

currencies which, for currency exposure purposes, act as a natural hedge. Thus, the hedge is aimed at safeguarding the net value

of items in the statement of financial position denominated in a currency other than the presentation currency against the

respective currency fluctuations.

The hedging instruments used in this operation are foreign exchange forward contracts covering the net exposure to currencies

other than the presentation currency, for amounts and due dates close to that exposure. The nature of the risk hedged is the

change in the book value on sales and purchases expressed in currencies other than the presentation currency. At the end of each

month, the balances of Trade receivables and Trade payables expressed in foreign currency are updated, with the gain or loss

offset against the fair value change of the forwards negotiated.

Cash flow hedge | Exchange rate risk EUR/USD and EUR/GBP

The Group makes use of derivative financial instruments in order to limit the net exchange risk associated with sales and future

purchases estimated at USD and GBP.

Cash flow hedge | Interest rate

The Navigator Group hedges future interest payments associated with commercial paper issues by hiring an interest rate swap,

which pays a fixed rate and receives a floating rate. This instrument is designated as hedge of cash flows from the commercial

paper programme and the bond loan.

Cash flow hedge | Commodities - BHKP

The Navigator Group uses derivative financial instruments in order to minimise the exposure risk associated with the variation of

the pulp price, indexed to PIX, in USD

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 452

8.3. Financial assets and liabilities

8.3.1. Categories of Group Financial Instruments

The financial instruments included in each caption of the consolidated statement of financial position are classified as follows:

Financial Derivative Trading assets at financial derivative amortised instruments - financial Non-financial Amounts in Euro Note cost hedging instruments assets Total 31 December 2024 Non-current receivables 4.2 13,142,937 - - - 13,142,937 Current receivables 4.2 361,625,103 21,022,301 - 114,051,217 496,698,621 Cash and cash 5.9 286,628,866 - - - 286,628,866 equivalents Total assets 661,396,907 21,022,301 - 114,051,217 796,470,425 31 December 2023 Non-current receivables 4.2 44,399,506 - - - 44,399,506 Current receivables 4.2 311,882,736 18,444,025 1,014,913 93,399,299 424,740,973 Cash and cash 5.9 169,464,967 - - - 169,464,967 equivalents Total assets 525,747,210 18,444,025 1,014,913 93,399,299 638,605,447

Financial Financial Derivative Trading liabilities liabilities at financial derivative outside the amortised instruments - financial scope of IFRS Amounts in Euro Note cost hedging instruments 9 Total 31 December 2024 Interest-bearing 5.7 903,977,752 - - - 903,977,752 liabilities Lease liabilities 5.8 - - - 111,736,900 111,736,900 Payables 4.3 769,419,687 4,680,187 1,631,313 - 775,731,187 Total liabilities 1,673,397,439 4,680,187 1,631,313 111,736,900 1,791,445,839 31 December 2023 Interest-bearing 5.7 659,344,463 - - - 659,344,463 liabilities Lease liabilities 5.8 - - - 69,996,821 69,996,821 Payables 4.3 612,025,754 608,037 5,083,781 - 617,717,572 Total liabilities 1,271,370,217 608,037 5,083,781 69,996,821 1,347,058,856

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 453

8.3.2. Fair value of financial assets and liabilities

Financial assets and liabilities measured at fair value

2024 2023 Amounts in Euro Level 1 Level 2 Level 3 Level 1 Level 2 Level 3 Financial assets at fair value through profit and loss Hedging derivatives (Note 8.2) - - - - 1,014,913 - Hedging financial instruments (Note 8.2) - 21,022,302 - - 18,444,025 - Assets measured at fair value Biological assets (Note 3.8) - - 115,250,198 - - 115,591,979 115,250,19Total assets - 21,022,302 - 19,458,938 115,591,979 8 Financial liabilities at fair value through profit/(loss) Hedging derivatives (Note 8.2) - (1,631,313) - - (5,083,781) - Hedging financial instruments (Note 8.2) - (4,680,187) - - (608,037) - Total liabilities - (6,311,501) - - (5,691,818) -

Estimates and judgements

Fair value of fixed-interest interest-bearing liabilities

The fair value of these liabilities is calculated using the discounted cash flow method at the reporting date, using a discount rate in

accordance with the characteristics of each financing, belonging to level 2 of the fair value hierarchy of IFRS 13.

Accounting policies

The fair value of financial instruments is classified according to the fair value hierarchy of IFRS 13 - Fair Value

Measurement:

Level 1 Based on quotes from active net markets at the reporting date.

Level 2 Determined using evaluation models, whose main inputs are observable in the market.

Level 3 Determined using evaluation models, the main inputs of which are not observable in the market.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 454

9. Operational risk management

The Group operates in the forestry sectors, in the production of eucalyptus for use in the production of BEKP pulp, which it

incorporates essentially in the production of UWF and tissue paper but is also sold in the market, and in energy production,

essentially through the forest biomass that is generated in the BEKP production process.

All the activities in which the Group is involved are subject to risks which could have a significant impact on its operations, its

operating profit/(loss), the cash flow generated and in its financial position.

The risk factors analysed in this chapter can be structured as follows:

i. Specific risks inherent to the sectors of activity in which the Navigator Group operates:

− Risks associated with the forestry sector (Note 9.1.1)

− Risks associated with the production and sale of BEKP pulp, UWF paper and tissue paper (Note 9.1.2)

− Risks associated with the production of energy (Note 9.1.3)

− Environmental risks (Note 9.1.4)

− Human resources and talent management (Note 9.1.5)

− Information systems and cybersecurity (Note 9.1.6)

− Other risks associated the Group’s activity (Note 9.1.7)

− General context risks (Note 9.1.8)

ii. Group risks and the way it performs its activities.

The Group has a risk-management programme in place which is focused on the analysis of the financial markets in order to

mitigate the potential adverse effects on its financial performance. Risk management is conducted by the Finance Department in

accordance with policies approved by the Board of Directors. The Finance Department evaluates and undertakes the hedging of

financial risks in strict coordination with the Group’s operating units.

The Board of Directors provides the principles of risk management as a whole and policies covering specific areas such as foreign

exchange risk, interest rate risk, liquidity risk, credit risk, the use of derivatives and other non-derivative financial instruments and

the investment of liquidity surplus. The Risk Management Department monitors the implementation of risk management policies

defined by the Board of Directors.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 455

9.1. Specific risks inherent to the sectors of activity in which the

Navigator Group operates

9.1.1. Risks associated with the forestry sector

As at 31 December 2024, the Navigator Group managed around 109,9 thousand hectares (2023: 109.0 thousand hectares)

distributed across Portugal and Spain, in 1,410 Management Units in 169 municipalities in Portugal, and 54 Management Units

distributed across 2 provinces in Galicia and 1 province in Asturias, Spain, in accordance with the principles set forth in its Forestry

Policy. Eucalyptus and areas under ongoing afforestation with this sort of species occupy 73% of this area, namely the Eucalyptus

globulus species, deemed to have the perfect fibre for high-quality papers. In the remaining area, in addition to conservation

areas that account for about 11.5% of the total area under management in Portugal, pine and cork oak forests are among the

largest privately owned national producers.

As a pioneer in Portugal in promoting certified forest management, most of its forestry assets located in Portugal are certified by

FSC® (Forest Stewardship Council®) (FSC®-C010852) and by PEFC (Programme for the Endorsement of Forest Certification

schemes) (PEFC/13-23-001), recognition that management of these areas is carried out in an environmentally, economically and

socially responsible way, following a strict and internationally recognised criteria.

Navigator operates in sophisticated markets around the world where the demand for certified products is an unavoidable reality.

Since only a small part of the national forest is certified, in 2016, the Company started a programme to encourage producers to

join sustainable forest management models that, once certified, allow the continuous improvement of management practices, the

production valuation and the answer to the demand for certified products that is felt worldwide. This effort has been increasing the

area of certified forest in Portugal between 2016 and 2024 both via FSC

(from 370,000 ha to around 649,000 ha) and PEFC

(from 260,000 ha to around 331,000 ha).

Even so, it is clear that the effort should continue in the future, given the weight that still represents the forest area not covered

by any sustainable forest management system in Portugal. As an example, at the end of 2024 the forestry area managed by the

Navigator Group, although it represents about 3% of Portugal’s total forested area, it represents, however, 33% of all certified

Portuguese forests by PEFC standards and 17% of all certified Portuguese forests by FSC

standards (2023: 34% and 19%,

respectively.

We are, however, optimistic about the path taken, which demonstrates the adherence of Forestry Production to sustainable forest

management models. In 2024, 73% of wood from national sources, excluding wood from areas managed by the group, already

came from properties that had their forest management certified (2023: 68%). It should also be noted that, within this initiative,

the Group has seen a significant increase in the number of wood Supplier chain of custody / liability certification, representing a

step further on the development of a Supplier’s portfolio which will make it possible to ensure the purposes defined in terms of

wood from sources with certified forest management.

As a way of promoting the certification of forest management in the national eucalyptus forest, since 2007, the Group has

continuously differentiated the value of the wood received at its factories, positively discriminating in the price of wood from

management units that have certified their management. sustainable forestry. This support to the system was innovative

worldwide and allowed the stabilization of forest management certified as a practice recognized in the market and which, being

remunerated in the products it incorporates, must remunerate the respective production chain.

In addition, to demonstrate its ongoing commitment to its sustainable development objectives, in June 2022 the Group issued a

Euro 150 million bond under the Sustainability Linked Bonds framework, with an interest rate linked to three ESG indicators: CO

emissions (EU ETS basis); % of certified wood purchased in the Portuguese market; energy consumption from renewable sources.

Since then, this commitment has been extended, which was most evident in 2024, with the issue of several loans (bonds or

commercial paper) amounting to Euro 300 million, with the same features.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 456

At the end of the year, the lines contracted with costs associated with ESG indicators, or drawn from financial market lines relating

to environmental investments, represented 66% of the total contracted.

The Group was awarded Land Use and Use Rights (DUAT) in Mozambique, located in the provinces of Manica and Zambezia,

comprising about 50 non-contiguous plots, and a planting permit for up to 240,000 hectares, made available under the

Investment Agreement signed with the Mozambican Government, of which around 14,000 thousand hectares have been planted.

The project foresees the installation of an industrial unit for the production of BEKP pulp and electric power in that country.

The Mozambican Government and Portucel Moçambique signed a Memorandum of Understanding (MoU) through which they

agreed on a set of preceding conditions required to proceed with the investment, namely and particularly of a logistical nature,

which will be implemented in two phases. Once the above conditions have been met, in the first phase, the forest base will be

increased to approximately 40,000 hectares, which will guarantee the supply of a unit (to be built) for the production of

eucalyptus wood chips for export with a capacity of around 1 million tons per year, in an estimated additional investment of USD

160 million.

Due to the repeated delays in guaranteeing the conditions precedent to the start of construction of this infrastructure, Portucel

continues to evaluate the possibility of alternative logistical solutions, either through the port of Nacala or by implementing a

temporary solution in Macuse.

Navigator and the Government of Mozambique have been working under the terms of the MoU signed, namely on the theme of

land and development, having advanced the first Forest Development programme in Mozambique, a Government initiative with

funding from the World Bank. The goal is to promote small and medium-scale sustainable commercial forest plantations and the

restoration of degraded areas, with about 3,000 ha of eucalyptus plantations already in full production. The plan is to plant

additional 1,000 hectares in the 2024-2025 campaign. Since the beginning of the programme, Portucel Moçambique plays an

active role in developing and implementing the programme, providing a range of support, defining the forestry model, supplying

cloned plants at subsidised prices and access to raw materials and sharing know-how.

In 2024, the harvesting of wood from Portucel Moçambique's plantations in Manica and Zambézia continued, for export from the

port of Beira and for supply to the local veneer production industry recently established in the two provinces, which will allow,

among other objectives, the work to position Mozambique on the world map of this forest-based industry to continue. In 2024,

approximately 50,000 m

of wood were harvested, with one shipment to Portugal amounting to around 34,000 m

, and a total

export volume of 285,000 m

through 9 ships.

In terms of forestry production, the main factor threatening the competitiveness of the eucalyptus forestry sector lies in the low

productivity of the Portuguese forest, which has a low intensity of management, which contributes to decreasing profitability and

increasing risks of forest fire and plant health. The combination of all these factors, in recent years, without any strategic

measures of the State in the industry, has forced the import of raw material, a process conditioning the profitability of all players.

Since the entire forest-based industrial production sector depends on the availability of raw materials in the quality and quantity

necessary to maintain the industrial units in our country, it is shocking to conclude that the lack of investment in the rehabilitation

of national forest areas is currently jeopardising the sustainability of such an important sector for Portugal, both economically,

environmentally and socially (given the impact it has on local populations and economies).

The Group considers the challenge of productivity and active forest management as a strategic axis of development. As a

company with responsibilities in the sector, Navigator has been promoting several initiatives aimed at helping to reverse this

trend. These initiatives cover several areas, from the supply of improved plants from a genetic improvement program with

decades of development, technical support to forestry producers (with programs such as Premium, e-globulus and technical

support through dozens of actions of training that, complementing those organized with the Suppliers we use, extend the transfer

of knowledge to other companies in the sector).

One of the initiatives and projects developed in 2023 was the launch of “Clube Produtores Florestais Navigator”, a pioneering

initiative aimed at all those who make a living from forestry in Portugal, with the aim of supporting the company's partners in a

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 457

collaborative way in the implementation of active and responsible forest management. The “Clube Produtores Florestais”,

launched by Navigator in November 2023, had over a hundred members by the end of the year. This figure highlights the need in

the country for a movement to enhance the capacity and competitiveness of forestry industry players.

Navigator believes that investing in the training and development of all players, through innovation in mechanical means and in

attracting, valuing and retaining human resources, as well as increasing the national area in which best forestry practices are

applied and all certification requirements are met, creates benefits that go far beyond strengthening the eucalyptus sector. It

helps reducing the risk of fires, lowering CO

emissions, increasing biodiversity through conservation areas, and boosting the

economy in the country's inland.

Moreover, through Biond (an association of forest-based bio-industries, representing the main industrial groups in the sector),

Navigator has also collaborated in the “Melhor Eucalipto” Programme, in which “Limpa & Aduba” is developed. Under this initiative,

Biond carries out at its own expense the fertilisation of the plots of land owned by private individuals who apply to the

programme,and who control the spontaneous vegetation on their eucalyptus forest properties. This measure, empowering

productivity, also enables a reduction in the risk of wildfire by reducing the fuel load on plots, impacting more than 90,900 ha by

2024 (after 6 annual campaigns) and 9,790 beneficiaries supported, most of them smallholdings, with visible effects on

productivity and reducing the incidence of fires. Biond is also implementing 2 additional programmes - “Replantar” - which aims to

provide landowners with direct financial support for the replanting of their eucalyptus forest plots, as well as an initiative of the

same nature - Recuperação de Áreas Ardidas - aimed at the recovery of burned areas hit by fires, seeking the rehabilitation of

these areas for forest management, having intervened in 1,293 ha in 3 projects in 2024 (2023: 331 hectares) and developing the

Projeto Melhor Floresta (Better Forest Project), which aims to benefit 1,640 ha of diverse forest owned by private landowners by

2025.

In addition to the risks related to the impacts of rural fires and plant health, there is a regulatory environment that strongly

affects professional forestry activity, leading to a continued decrease in the levels of forestry intervention at scale, whose leading

indicator is the evolution (continuous reduction) of forested or reforested areas in our country. The sustainability of an entire

sector, based on a large number of small suppliers of services and products, is dependent on the activity levels (regardless of the

species) that our country has not been able to ensure. This compromises the sustainability of this business network, which is

essential to ensure the interventions in rural areas that reduce risk and promote productivity and income in regions of the country

where the forest is a significant component of the income of many families.

The Navigator Group’s activity is exposed to risks related to fires in rural areas, including:

i. Destruction of current and future wood inventory, belonging to the Navigator Group as well as to third parties; and

ii. Increasing costs of forestry and subsequent land preparation for plantation.

In this respect, the manner in which the Navigator Group manages its woodlands is the front line for mitigating this risk. In

addition, the Innovation and Development effort is aimed at adapting forestry techniques to the reality of the national forest, with

a view to mitigating impacts, reducing costs and improving management practices, by the Company and by market operators.

Among the different management measures undertaken by the Group, the respect for biodiversity conservation, a proper planning

of the forest facilities to be implemented and the construction and maintenance of roads and access roads to each of the areas

under development are particularly relevant in mitigating the fire risk.

In addition, The Navigator Company, together with the companies in the ALTRI group, owns a Forest Protection company -

AFOCELCA - in the form of a Complementary Grouping of Companies. Its mission is to establish and maintain a nationwide forest

protection system to respond to the threat of rural fires to the assets of the grouped companies (approximately 200,000 hectares)

and the surrounding forest, always in close collaboration and sharing efforts with the other players in the Integrated Rural Fire

Management System. It has an annual budget of more than Euro 4.5 million, supported exclusively by the companies in the

grouping, without any sources of funding/support from public or EU funds.

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The Group also has a research institute, RAIZ, established in 1996 in partnership with three universities, a pioneering initiative in

Portugal that reflects Navigator's commitment to innovation and sustainability.

Its activities are focused on research, innovation and specialised services in the eucalyptus forestry-industrial sector, promoting

more productive and resilient forests, more efficient industrial processes and developing innovative and sustainable forest-based

bioproducts.

It has 95 employees, 30% of whom are PhDs, and is one of the 10 organisations with the most international patents in Portugal.

Their activity is aligned with the Company's purpose: “It is people, their quality of life and the future of the planet that inspire and

move us.” This positioning reflects our ongoing commitment to creating responsible value through sustainable, recyclable and

biodegradable solutions, sourced from planted eucalyptus forests.

With solid investment in R&D and innovation geared towards sustainability and the circular economy, Navigator, through RAIZ,

intends to continue to help Portugal consolidate and expand its position on the European innovation scene in the forest-based

bioeconomy.

9.1.2. Risks associated with the production and sale of BEKP pulp, UWF paper and Tissue paper

Supply of raw materials

Navigator's own supply of wood (from its own assets and leases) for the production of BEKP pulp represented only around 13% of

the Group's needs in 2024 (2023: 12%). As a result, the Company regularly has to purchase wood on the domestic market, on

the Spanish market and on non-European markets, in 2024 Brazil and Uruguay.

As new forest plantations in Portugal are subject to approval by the relevant authorities and a policy of restricting land expansion

limits the country's production potential, Navigator has developed a number of initiatives to support forest producers, including

technical support for the replanting/maintenance of eucalyptus plantations, certification of forest management to meet

commercial demand for certified products (paper and pulp) and incentives to maximise the productivity of existing areas, thereby

contributing to better national forest management and consequently greater availability of raw materials.

As there is not enough wood produced in Portugal to meet our needs, the Group usually has to import wood from Spain and

outside Europe (Brazil and Uruguay) to supply the plants with eucalyptus species that are generally purchased with similar specific

consumption to the species in Portugal, although due to the distance to be travelled between origins (Brazil and Uruguay) and

destinations (Portugal) and the use of transport, the overall cost, for these reasons alone, is higher than the cost of wood

purchased in Portugal, which has risen substantially in the last 10 years.

On 31 December 2024, a 10% decrease in the cost per m3 of eucalyptus wood consumed in BEKP pulp production would have

had a negative impact in the Navigator Group’s operating results of approximately Euro 37,800,000 (31 December 2023: Euro

37,800,000).

For other raw materials, including chemicals, the main risk identified is the scarcity of products under the growing demand for

these products in emerging markets, particularly in Asia and markets supplying them, which can create occasional imbalances of

supply and demand.

In this regard, the Navigator Group, together with the Altri Group, established in 2018 a Complementary Grouping of Companies -

Pulp Chem, ACE – intended for the joint acquisition of chemical products, benefiting from economies of scale and thus mitigating

this risk.

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The Navigator Group seeks to mitigate these risks through proactive sourcing, by identifying sources of supply geographically

dispersed, whilst seeking to secure long-term supply contracts that ensure volume, price and quality levels consistent with its

requirements.

As at 31 December 2024, a 10% worsening in the price of chemical products would have represented a negative impact on the

Group's operating results of around Euro 17,300,000 (31 December 2023: Euro 19,400,000).

Water

Considering that water is an important resource to the pulp and paper production process, the Group has taken on a special

concern for its preservation, and over the last few years, investments have been made to reduce its use. As part of the Group's

Water Use Reduction Programme (PRUA - “Programa de Redução do Uso de Água”), it has been possible to reduce the specific use

of water in Navigator's industrial complexes in Portugal by 8.5% between 2019 (base year) and 2024, and it is expected that the

use of this resource will be reduced by at least 33% by 2030. This is part of a comprehensive strategy that is being pursued

rigorously, bringing the Group closer to achieving the goals of its “Agenda 2030”.

In addition to reducing the use of water in industrial processes, achieved through major investments, particularly in reuse

processes and the closing of circuits, Navigator maintains effective control over the quality of industrial effluents. In this way,

Navigator ensures that the quality of its industrial effluents complies with the strict discharge requirements established in the

Water Use Permits (TURH).

Market Price for UWF paper, BEKP pulp and Tissue paper

Imbalances in the supply/demand ratio in the BEKP, UWF paper and tissue paper markets may have a significant impact on prices

and, as a consequence, on the Group's performance. The market prices of BEKP pulp and UWF and Tissue paper are defined in the

world global market in perfect competition and have a significant impact on the Navigator Group’s revenues and on its

profitability. Cyclical fluctuations in the prices of BEKP pulp and UWF and Tissue paper mainly arise from both changes in the world

supply and demand and the financial situation of each of the international market players (Producers, Traders, Distributors,

Customers, etc.), creating successive changes in equilibrium prices and raising the global market’s volatility.

The BEKP pulp and UWF paper markets are highly competitive. Significant variations in existing production capacities could have a

strong influence on world market prices. These factors have encouraged the Group to follow a defined marketing and branding

strategy and to invest in relevant capital expenditure to improve productivity and generate high-quality and differentiated

products.

As at 31 December 2024, a 10% drop in the price per ton of BEKP pulp and of 5% in the price per ton of UWF paper and Tissue

paper sold by the Navigator Group in the period, would have represented an impact on its operating results of approximately Euro

23,900,000 and Euro 86,700,000, respectively (31 December 2023: Euro 24,900,000 and Euro 76,400,000, respectively).

Demand for the Navigator Group’s products

Notwithstanding the references below to the concentration of the portfolio of the Navigator Group’s Customers, any decrease in

demand for BEKP, UWF and tissue paper in the European and the United States markets could have a significant impact on the

Navigator Group’s turnover. The demand for BEKP produced by the Group also depends on the evolution of the capacity for paper

production in the world, since various Navigator Group’s major Customers are themselves paper producers.

The demand for uncoated printing and writing paper has been historically related with macroeconomic factors (e.g., GDP growth,

employment, particularly in white collar jobs, confidence indices), technological (e.g., penetration of information technology and

hardware / software, and demographic (e.g., population, average level of education, age structure of society). The evolution of

these factors drives the demand for paper positively or negatively, and in the recent past, the trend of paper consumption is

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 460

negative in the more developed countries and positive or stable in the emerging / developing countries. Naturally, the

performance of the Navigator Group also depends on the evolution of demand in the various markets in which it operates.

Regarding the demand for eucalyptus market pulp, this is largely dependent on the production progress in the non-integrated

producers of printing and writing paper, tissue and speciality papers. Chinese demand for this type of pulp represents more than

1/3 of the world's demand, making China one of the most breakthrough drivers of demand.

Regarding Tissue segment, the key variables affecting the demand are:

• Expected future economic growth;

• Population growth and other social and demographic changes;

• Level of development of the service sector, namely tourism;

• Hygiene standards and product penetration levels;

• Developments in the quality of Tissue paper and product specifications; and

• Substitution effects.

Tissue paper consumption is not very sensitive to cyclical economical changes, although it tends to grow faster with higher

economic growth. On the other hand, an increase in production costs and, consequently, sales prices can create a downgrading

effect on consumption.

The importance of economic growth for the consumption of Tissue is more obvious in developing countries. When the level of the

income per capita is very low, the consumption of Tissue tends to be low. There is a threshold after which consumption

accelerates. Economic growth allows greater penetration of the product, which is one of the main drivers of demand for such

paper in the population with lower incomes. In economies with strong dependence on tourism, a gradual recovery in consumption

by the professional sector is expected, as restrictions on mobility are lifted and tourist flows are normalized. The Tissue paper is a

product that does not face major threats of substitution by other materials, and there are no expected changes at this level. In

contrast, changes in hygiene and cleaning standards that may be associated with the current health crisis will tend to boost Tissue

consumption.

Consumer preferences may have an impact on global paper demand or in certain particular types of paper, such as the demand

for recycled products or products with certified virgin fibre.

Regarding this matter, and in the particular case of UWF and Tissue paper, the Navigator Group believes that the marketing

strategy and branding that has been followed, combined with the significant investments made to improve productivity and

produce high quality and innovative products, allow it to deliver its products in market segments that are less sensitive to

variations in demand, resulting in a lower exposure to this risk.

Energy

The pulp and paper production process are dependent on the constant supply of electric and steam energy. The Group has several

cogeneration combined heat and power production units, which supply steam to the process, and redundancies have been

planned between the various units in order to mitigate the risk of any unplanned shutdowns.

Moreover, the Group owns two biomass power plants that are independent of the pulp and paper production process and are

dedicated to the production of renewable electricity for sale to the grid.

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Under the current regulatory framework, all electricity generated from renewable cogeneration is sold to the grid under the

general remuneration scheme established by Decree-Law 23/2010 of 25 March, republished by Decree-Law 68 A/2015 of 30 April,

in its current wording.

The sale of electricity produced by the group's renewable cogeneration plants is covered by the special remuneration regime for

cogeneration, established by Decree-Law 23/2010 of 25 March, in its current wording. In turn, the Setúbal Natural Gas Combined

Cycle Power Station is covered by the general modality under the same law.

In 2024, The Navigator Company provided the Frequency Restoration Reserve Band service with manual activation for consumer

agents under the terms of Procedure 15 of the Manual of Procedures for Global System Management (MPGGS). This service,

rendered by electricity consumers authorised for this purpose, contributes to the security of the national electricity system.

As at 31 December 2024, a 10% worsening in the price of electricity would have represented a negative impact on the Group's

operating results of around Euro 9,300,000 (31 December 2023: Euro 5,500,000).

Country risk - Portugal

The Navigator Group has a strong presence in Portugal. Its activity is based on assets mainly located in Portugal. Similarly, around

20% of its raw material comes from Portuguese forests.

The Group is the third largest exporter in Portugal and the largest generator of National Added Value, representing approximately

1% of the national GDP, about 2.5% of national exports of goods, close to 6% of total containerised cargo exported by national

ports.

Although open to the world, the strong dependence of its country of origin in terms of production factors exposes the Group to

Portugal's risk index.

Country risk– Mozambique

Due to the investment in the Mozambican project, the Navigator Group is exposed to the specific risk in this country. However,

consideration has been given to investments in terms of timing, choice of suppliers/partners and geographical location, taking this

risk into account, and the Group ensures that these steps are taken with reasonable certainty that there will be no effects arising

from the risk. As a result of the electoral cycle that took place in Q4 2024 and the political and social instability that followed it,

the company is monitoring and evaluating the possible need for any adjustments to be made.

At this moment, the Mozambique project is essentially a forestry project, with an option to develop an industrial project. The

planned investment will be implemented in two phases, the first being a ship production (woodchip) project and a second phase

the construction of a large-scale pulp mill. The Group is, however, prepared to move forward with the forestry plan foreseen, once

the necessary conditions—most of which are under discussion with the Mozambican authorities—are met.

Until 31 December 2024, the expenses incurred in this project amount to Euro 142.2 million (31 December 2023: Euro 137.4

million), mainly related to plantation, land preparation and forest maintenance, to the programme for land management,

environmental and social licensing, training, and the construction of what is now one of Africa's largest forest nurseries.

Considering that Navigator is still working on the conditions above for Phase 1 of the MoU, as previously mentioned, the estimated

probable liabilities are duly provisioned.

Country risk - US

The US market has a significant weight in the total turnover of UWF paper, increasing the exposure to the country’s specific risk.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 462

This exposure requires a careful evaluation of the impacts resulting, for example, from changes in regulations and taxes, or even

from their application and interpretation by Governmental entities and tax authorities.

Similarly to producers of other nationalities (Australians, Brazilians, Chinese and Indonesians), with regard to UWF paper imports

to the USA, the Group has, since 2015, been the target of anti-dumping measures by the Department of Commerce of this

country, and its products are subject to anti-dumping duties defined by the United States Department of Commerce - see Note

4.2. Until 2024 these duties affected the Group's earnings by Euro 32,636,4187 - review periods 1 to 9 (2023: €30,295,018).

Country risk – United Kingdom

With the purchase of the Navigator Tissue UK Group, the Navigator Group is more exposed to this country's risk as well as

exposure to the GBP.

The UK tissue market faces risks related to fluctuating raw material costs, rising energy prices and pressure for greater

environmental sustainability with stricter regulations. In addition, there are challenges arising from changes in consumer habits,

global competition, disruptions in supply chains and new government policies. The adoption of advanced technologies also

represents a financial risk, requiring companies to constantly adapt in order to remain competitive and meet market expectations.

Faced with these challenges, the Navigator Group's presence in the UK tissue market requires strategic management to mitigate

financial, currency, regulatory and operational risks, but this market continues to offer opportunities, especially for companies that

manage to balance production efficiency, differentiation, and an agile response to changes in the sector.

Competition

Increased competition in the paper and pulp markets may have a significant impact in price and consequently, in the Group’s

profitability.

The pulp and paper markets are highly competitive and thus the entry into the market of new production units with increased

available production capacity could have a relevant impact on prices worldwide.

BEKP producers from the southern hemisphere (namely from Brazil, Chile, Uruguay and Indonesia), with significantly lower

production costs, have been gaining weight in the market, undermining the competitive position of European pulp producers. This

year and next, capacity increases are planned in South America, strengthening the position of these producers in the global

market.

These factors have forced the Navigator Group to make significant investments in order to keep production costs competitive and

produce high-quality products as it is likely that this competitive pressure will remain strong in the future.

There has been some disinvestment in the paper sector in the US and Europe, with closures/conversions of installed capacity by

some UWF producers, in a clear attempt to adjust supply according to the negative evolution of demand. On the contrary,

investments in new UWF capacity in China in the short- and medium-term have occurred and are expected.

The Navigator Group has been adjusting its commercial strategy to the evolution of regional consumption patterns and, although

Europe remains its main market, it now has a significant presence in the United States and North Africa.

The turnover intended to the European markets represented 62% (2023: 63%), achieving particularly strong market shares in

Western European countries and relevant market shares in the other main European markets.

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Concentration of Customers’ portfolio

As at 31 December 2024, the Group’s 10 main BEKP Customer groups accounted for 12% of the period’s production of BEKP pulp

(2023: 9%) and 45% of external sales of BEKP pulp (2023: 28%). This asymmetry is a result of the strategy pursued by the

Group, consisting of a growing integration of the BEKP pulp produced into the UWF and Tissue paper produced and sold.

Nevertheless, the Group believes there is little exposure to risks of Customer concentration in the marketing of BEKP pulp.

In 2024, the Navigator Group maintained its dependence on its 10 largest UWF customer groups compared to 2023, which

accounted for 35% of the Group's sales volume.

The Navigator Group recorded 146 (2023: 134) new paper Customers with sales in 2024. Also, regarding UWF paper, the Group

follows a strategy for mitigating the risk of concentration in its customer portfolio. The Navigator Group sells UWF paper to 133

countries and to around 1,000 individual Customers, thereby allowing a dispersion of the risk of sales concentration in a reduced

number of markets and/or Customers.

In 2021, the Navigator Group launched its omnichannel platform, NVG Hub, to improve the level of service, transparency and

information provided to its customers. The omnichannel platform, NVG Hub, strengthened the relationship and services available

to all customers, representing 20% of items submitted online and high subscription rates in the various business areas available

(UWF, Tissue, Packaging, Moulded Pulp). 2024 was also marked by the launch of a new ‘pure e-commerce’ business model, aimed

at selling by the pallet to smaller customers, with direct deliveries between 24-72 hours, in strategic markets for UWF.

In the Packaging segment, the expansion of the offer continues with the development of new product ranges that will open doors

to other high value-added segments in the short term, an evolution supported by the execution of market tests (177 in 2024) on

more than 84 customers (of which 22 are already regular customers, and 62 new/potential customers). Of these tests, 29 are still

ongoing.

The Packaging business, which is still developing a consolidated base in the international market, has seen the most favourable

conditions for ‘some’ return to normality, recovering from the adverse conditions of 2023, a year marked by overstocking

throughout the distribution chain, which was reflected in the slowdown and irregular behaviour of demand.

The development of the packaging business continues to show very promising signs, reflected in the growing customer base, the

recognition of the quality of our Globulus eucalyptus fibre-based products and, consequently, of the gKRAFT™ brand, which serves

brands with high exposure in sectors as diverse as fashion, food retail, e-commerce, industry, and agriculture.

This recognition is reflected in the evolution of the customer base, which today stands at more than 352 active customers (with

sales) in 46 countries, since entering the business in 2021.Recognition that goes beyond commercial success: Navigator's work in

the field of sustainable packaging solutions was honoured in 2023 with the National Innovation Award. In turn, the "From Fossil to

Forest – Produtos de Embalagem Sustentáveis para Substituição do Plástico Fóssil" mobilizing agenda led by Navigator was

recognised by Deloitte Portugal in the "Transformation Award – Projetos de transformação e de inovação com impacto no

mercado" category.

Navigator bases its packaging paper offer on three macro gKRAFT™ segments: BAG, FLEX and BOX, which are subdivided into 12

segments for different applications, respectively addressing the Bags (retail, consumer and industrial bags) and Flexible Packaging

(serving a wide range of flexible packaging for the food and non-food sectors, base substrates for adhesives, release liners',

multilaminates for incorporation into the faces of thermal, sound and electrical insulation products, etc.), and boxes (corrugated

boxes for value-added products and food packaging, including cardboard for producing paper cups, and food trays). These are

products in which the innovative introduction of eucalyptus fibre qualities has been crucial to the enormous market acceptance

already recognised.

Navigator has continued to develop new product ranges and grammages (especially low grammages) aimed at the food industry

and a wide range of consumer products, whose testing and launch phase, which is still underway, represents a large-scale

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 464

operation to reach new customers, supported by 177 market tests carried out in 2024. Developments included the creation of new

product ranges, in particular innovative 100% eucalyptus products, and the extension to weights of up to 35 g/m2.

As part of the diversification of the packaging business, the project for the integrated production of eucalyptus-based moulded

cellulose parts to replace single-use plastic packaging in the food service and food packaging market continues to progress as

planned, having entered production expected in the second half of 2024 under the gKRAFT™ Bioshield brand. The plant will have a

production capacity of around 100 million units per year, making it one of the largest in Europe and the first integrated plant in

Southern Europe, entering a market with high potential and growth. Production started with 7 products for single-use applications

in the food sector that are fully recyclable and/or compostable: 22cm plate, 17cm plate (dessert), 500ml bowl, 1 litre take-away

container, tray (laminated for raw protein - beef, pork and poultry), fruit basket and espresso cup.

These 7 products have the production flexibility and scalability to take advantage of the many opportunities opening up to replace

single-use plastics and aluminium. Concurrently, new products have been developed in partnership with national and international

customers, and research and development work continues into new sustainable barrier property solutions, as well as testing

commercial solutions.

It should be noted that this year our moulded fibre products, branded gKRAFT™ Bioshield, received certification of compliance for

food contact with European Regulation (EC) 1935/2004 (food contact) and the German recommendation BfR XXXVI. Our

gKRAFT™ Bioshield products thus become the first moulded fibre products in the world to comply with the BfR XXXVIA

recommendation. This certificate was issued by the prestigious German laboratory ISEGA. The certification enables the

commercialisation of products intended for the food segment, for contact with greasy, wet and dry foods, and applies to our entire

tableware and take-away range.

The Packaging business volume stood at over 80 ktons in 2024 (reaffirming the growth rate of the first two years, which shows

the strong acceptance of gKRAFT products by the market and the improvement in conditions during the year), representing a

sales result of Euro 75 M.

Navigator's tissue business was in the spotlight this year, marked by the acquisition of what is now known as the Navigator Tissue

UK Group, effective during the second quarter. The integration of this new unit is part of the Navigator Group's ambitious growth

and diversification plan and reinforces its strategic position in the tissue market.

The volume of tissue sales (finished product and reels) reached 220,000 tonnes in 2024, which translates into an increase in

volume of 55% compared to 2023 and equal sales growth in value of 55%. This evolution benefited from the entry of the capacity

of the operation acquired in Spain in the second quarter of 2023, and the capacity of the Navigator Tissue UK Group in May 2024,

which in addition to boosting sales growth, broadened the customer base and generated significant income from integration

synergies.

International sales in the tissue business continue to grow, already accounting for 79% of the total volume in this segment, with

the English and Spanish markets already accounting for almost two thirds of total sales, 31% each, and the French market

accounting for 15% of sales. On the other hand, finished products accounted for 97% and reels for 3% of total sales, a mix

improvement of 8 pp compared to 2023.

As far as customer segments are concerned, the At Home or Consumer (retail) segment has been growing in weight, currently

accounting for 83% of sales (Away-from-Home and wholesalers account for the remaining 17%).

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9.1.3. Risks associated with the production of energy

In 2024, the macroeconomic environment remained unstable, influenced by the war in Ukraine and the resurgence of conflict in

the Middle East. In this context, energy prices, particularly for natural gas, remained high, albeit below the historical peaks

resulting from the 2022 energy crisis.

The production of electricity is an important activity for the Group, enabling the valuation of an endogenous renewable resource,

the biomass generated in the production of BEKP pulp. The energy generation assets also allow the Group's wood suppliers to

generate additional income from the sale of residual forest biomass from their farms, and in this way contribute to reducing the

risk of fire in the country.

The Group has played a pioneering role and has been promoting and developing a market for the sale of biomass for supplying its

renewable cogeneration units and biomass power plants. The fostering of this market in a phase prior to the start-up of the new

power-generating units has enabled it to secure a sustained raw-material supply network.

Existing incentives in Portugal only cover the use of residual forest biomass (RFB) for electricity generation, excluding the use of

wood for this purpose.

In terms of legal framework, we highlight the following diplomas:

i. Decree-Law 68-A/2015 of 30 April, which establishes provisions on energy efficiency and cogeneration and amends

Decree-Law 23/2010, of 25 March, and Order 140/2012, of 14 May, revised by Order 325-A/2012, of 16 October,

applicable to the regime of PRE- Special Regime Production in cogeneration;

ii. For the For the Biomass Power Plants (CTB - "Centrais Termoelétricas a Biomassa") in operation, dedicated to the

production of electricity the legal framework is supported by Decree-Law 33-A/2005, of 16 February, revised by Decree-

Law 225/2007, of 31 May, which changes the guaranteed remuneration period for Special Regime Production (PRE -

"Produção em Regime Especial") from 15 to 25 years. For these assets, the legal framework thus supports a tariff

framework that is expected to be stable over the coming years.

Moreover, Decree-Law 84/2022, which transposes the Renewable Energy Directive published in 2018 (Directive EU

2018/2001) into national law, sets the target of 49% for the share of energy consumption from renewable sources in

gross final energy consumption by 2030. Among other relevant provisions, the Decree-Law establishes the sustainability

criteria and the reduction of greenhouse gas emissions for the use of biomass fuels in electricity production.

iii. Decree-Law 15/2022 of 14 January establishing the organisation and operation of the National Electric System (NES),

transposing Directive (EU) 2019/944 and Directive (EU) 2018/2021.

As the period for selling electricity from cogeneration plants under a special regime comes to an end, they will gradually switch to

self-consumption, i.e. direct supply to industrial consumers, with any surpluses being sold on the market.

The Group is seeking to mitigate the risk associated with the activity by constantly seeking to optimise production costs and the

efficiency of generation units, analysing new renewable energy generation projects, long-term energy contracting and active risk

management, as well as promoting several photovoltaic solar energy projects in the self-consumption regime.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 466

9.1.4. Environmental risks

Regulatory environment

In recent years, environmental legislation in the EU has become increasingly restrictive regarding the control of effluents. The

companies within the Group comply with the current legislation in all aspects of their environmental licensing, specifically in

adhering to the various environmental parameters for which Emission Limit Values (ELVs) are established.

In 2024, within the scope of the Single Environmental Licensing Regime in accordance with Decree-Law 75/2015 of 11 May, the

Portuguese Environment Agency issued new environmental licences – Single Environmental Permits (TUA), where all licensing

decisions in the environmental domain are recorded, consolidating all information regarding the environmental requirements

applicable to the industrial establishment. These new licensing decisions consolidate the water use permits (TURH), the

greenhouse gas emission permits (TEGEE), etc., and represent new compliance challenges in the domains of air, water, waste,

and environmental noise.

In response to these new challenges, the Group is implementing its Carbon Neutrality Roadmap (“Roteiro para a Neutralidade

Carbónica”) that aims to implement, by 2035, changes in its production processes in order to minimise the use of fossil fuels and

consequently reduce their CO

emissions.

To this end, the roadmap defined in 2019 includes projects based on the use of renewable energy sources, namely biomass and

solar, with the aim of minimizing CO2 emissions resulting from its activity and promoting the improvement of its energy

performance.

On the other hand, under the terms set in Decree-Law 147/2008, dated 29 June that transposed directive 2004/35/CE to the

national law, the Navigator Group secured the environmental insurances demanded by that law, thus guaranteeing compliance

and reducing exposure to environmental risks.

Regarding the evolution of the EU Emissions Trading Scheme (EU ETS), the EU Directive 2018/410, of 14 March, was approved,

amending Directive 2003/87/EC to reinforce the cost-effectiveness of emission reductions and investment in low carbon

technologies. EU 2018/410 Directive sets out, among other things, the new EU ETS period to be in force between 2021-2030,

which will show a reduction in the amount of CO

emission allowances allocated free of charge.

This development will bring increased costs for the transformation industry in general and in particular for the paper and pulp

industry, without any compensation for the CO2 that, annually, is absorbed by the forests of this industry.

In order to mitigate the impact of this change, the Group has long undertaken a series of investments of an environmental nature

that, among other advantages, have allowed the continued reduction of CO

emissions.

In 2024 Navigator submitted a request to the national authority for the free allocation of emission allowances for the allocation

period from 2026 to 2030 in accordance with article 13 of Decree-Law 12/2020 of 6 April, which transposes EU Directive

2018/410 - NIMs 2024 Process (National Implementation Measures).

Within the scope of the General Waste Management Scheme established in Decree-Law 102-D/2020, of 10 December, amended

by Declaration of Rectification no. 3/2021 and by Law 52/2021, of 10 August, Navigator continues to make efforts to establish

partnerships that enable the recovery of waste produced at its industrial establishments, in a circular economy logic.

Navigator monitors the European Commission's policy and legislative initiatives in areas such as the EU forestry and biodiversity

strategies, the Renewable Energy Directive, the EU Emissions Trading System (EU ETS) as well as the EU taxonomy, the Non-

Financial Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 467

The publication in the Official Journal of the European Union of the Corporate Sustainability Reporting Directive (CSRD) - Directive

(EU) 2022/2464 established the sustainability reporting requirements for a broader range of companies, through the European

Sustainability Reporting Standards (ESRS). In this context, and based on the established criteria, Navigator is already included in

the first group of companies to implement the new directive and to report information related to the FY24 in accordance with the

ESRS standards.

To this end, Navigator has reviewed its double materiality analysis as well as the methodologies applied to this period and aligns

its non-financial reporting on materially relevant impacts, risks, and opportunities in accordance with the CSRD, in the Non-

Financial Statements section of this Report.

Aiming to create a positive impact on People and the Planet, Navigator has maintained its commitment to fulfilling the

commitments of its 2030 Agenda for responsible business management and achieving the corresponding objectives, integrated

into the 2030 Roadmap and aligned with the Sustainable Development Goals (SDGs).

Among the goals of the 2030 Roadmap, those that contribute to combating Climate Change stand out, supporting SDG 13

(Climate Action) To achieve this, the Group is investing in a decarbonisation plan that includes, among other measures, the use of

residual forest biomass to produce electricity from renewable sources, as well as the phased replacement of fossil energy

consumption with less carbon-intensive energy sources and investment in photovoltaic solar energy.

The company is pursuing its climate science-based greenhouse gas (GHG) emission reduction targets, approved by the Science

Based Targets initiative (SBTi), in 2022, a ‘key element’ for a net-zero decarbonisation path, as advocated in the

Intergovernmental Panel on Climate Change (IPCC) report.

Since 2023, Navigator Group has reported information on the alignment of its economic activities with the EU taxonomy and

implement the recommendations of the Task Force on Climate-related financial Disclosures (TCFD).

As a bioindustry on the right side of the future, based on the eucalyptus and pulp and paper industries, we promote a forest-

based bioeconomy with potential positive impacts based on the sustainable management of our forests.

Good management of environmental, social and governance (ESG) risks and opportunities has led the Company to once again be

distinguished as ‘ESG Industry Top Rated’ based on the assessment of the Sustainalytics rating agency and is classified as a ‘Low

ESG Risk Company’ for Investors. Also in the CDP - Disclosure Insight Action assessment, Navigator maintained its position as a

world leader in combating climate risks and deforestation, with an ‘A’ rating in CDP Climate, which earned it inclusion on the

exclusive ‘A-List’ of companies.

For more detailed information on these and other initiatives under the Navigator Group's 2030 Agenda, we recommend consulting

the Non-Financial Statements section in this Report.

9.1.5. Human resources and talent management

In 2024, work continued consolidating the Talent Management policies and processes that have been designed, digitised and

implemented in recent years. Having implemented the policies governing the Performance & Careers area, 2024 was marked by

significant progress in the area of the company's Career Paths.

The following stand out as relevant steps to meet the needs of employees and the challenges of the market:

• Continuation of programmes to attract young talents in order to meet the future needs of The Navigator Group and at the

same time increase the employability of young people:

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 468

o 50 internships for graduates and postgraduates;

o 100 for future operators, the latter with a prior training programme carried out in partnership with the IEFP

with a practical component in our mills;

o 50 summer internships, including a corporate social responsibility component for employees' children; and

o 20 curriculum development internships in corporate areas, industrial production techniques and laboratories.

• Reinforcement of our Employer branding strategy, through greater engagement of our internal ambassadors and

revamping the external image of the programmes.

• A new mobility and career path model has been developed for the company's staff in accordance with the Job Family Model,

with the aim of clarifying career paths and internal development opportunities, defining and bringing transparency to the

associated criteria.

• Developed the Potential Assessment and Succession Planning process for critical functions at Navigator, with the aim of

defining effective development and evolution plans, ensuring growth in the Company and the Group.

• As part of the remuneration policies and their alignment with the Job Family model, 2024 was marked by the continuation

of communication sessions with the employees concerned with the aim of sharing the existing policies, their scope and

rules of application with everyone.

• Work was also carried out on the implementation of the C&B policies to the reality of the units acquired by NVG, with face-

to-face sessions already held at EJEA.

• In terms of training, there was a 23% increase in training hours, with a significant contribution from the Valences

programme and the Industrial Challenge, both covering industrial teams.

• Implementation of various internal programmes to mobilise teams, generate ideas and bring them closer to the company's

strategy and the Board of Directors, namely Dia do Trainee, Future Leaders Fórum, Straight to the Top - revamp,

Lembranças de Antiguidade, Fórum de Supervisores;

• Implementation of programmes focused on the families of our employees, such as: Holiday camps (for employees'

children) and Navigator Tours for family members, including children under 12, with specific, age-appropriate activities.

• The CRESCER project continued with the aim of having "committed and fulfilled" people, always in line with the company's

purpose. More than 100 employees were involved in the project, so that the initiatives to be implemented were fully

adapted to the reality of the organisation and created an increasingly robust dynamic of proximity and interaction. A

number of initiatives have been implemented, including:

o The Navigator Referral Programme, which allows Navigator employees to refer people from outside the

organisation;

o Navigator Excellence, a recognition programme that aims to create a culture of recognition across the

organisation, recognising and thanking excellence and promoting pride and motivation in everyone;

o Navigator Digital Forum, a face-to-face event with around 200 participants where the latest news in the

company's technological development was shared, among others.

o Lead Programme, a programme to develop leadership skills and transform teams, applied to all directors and

EC, and to be extended to more leaders in 2025.

• A Pulse Questionnaire was conducted, complementary to the Climate Survey that we carry out every two years, with a view

to analysing indicators that need to be improved, with an optional participation rate of 78%, covering all employees.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 469

• 2024 was a year in which we strengthened our communication strategy aimed at industrial teams, by organising training

for all the leaders and operational technicians in our industrial departments on topics related to the career plan and the

annual and productivity bonuses.

• We have continued with the plan to develop and implement functionalities in the APPs available to all employees, with the

aim of simplifying and reducing all administrative processes related to the employee lifecycle.

• We reinforced the availability of HR indicators on our dashboards, namely by making the leader's dashboard available, and

we began integrating data from our companies outside Portugal (EJEA and Tissue UK).

• We have begun the process of reviewing the current Career Plan for our industrial technicians, involving internal teams and

the organisations representing our workers.

9.1.6. Information Systems and Cybersecurity

The Navigator Group's information systems play a fundamental role in supporting the operation of its businesses.

Given the growing reliance placed on information technologies in the several geographies and business areas in which the Group

operates, it is important to highlight the risk inherent to systems failures resulting from intentional actions such as computer

attacks or accidental actions. The Navigator Group has cybersecurity policies and procedures in place, which are in line with

industry standards and mitigate many of the risks.

In addition to its internal team, the Group uses outsourcing service providers for information systems to manage the digital

workplace, infrastructure management and operation, as well as outsourcing contracts for the management and maintenance of

applications. Moreover, in line with its business strategy, the Navigator Group is implementing a portfolio of digital transformation

projects aimed at broadening and deepening the integration of digital technologies in all sectors of the organisation, boosting its

operational efficiency and competitiveness in the market.

9.1.7. Other risks associated with the Group’s activity

The Group’s manufacturing facilities are subject to risks inherent to any industrial activity, such as accidents, breakdowns or

natural disasters that may cause losses in the assets or temporary interruptions in the production process.

Likewise, these risks may also affect the Navigator Group’s main Customers and Suppliers, which would have a significant impact

on the levels of the profitability, should it not be possible to find new Customers to ensure sales levels and new Suppliers that

would enable the Group to maintain its current cost structure.

The Navigator Group primarily exports its production of UWF paper and Tissue paper. Consequently, transportation and logistics

costs are materially relevant. A continuous rise in transport costs may have a significant impact in its earnings.

9.1.8. Context risks

The structural inefficiency of the Portuguese economy, which continues to be followed by management, adversely affects the

Group's competitiveness, mainly in the following areas:

i. Ports and railroads;

ii. Roads, particularly those providing access to the Navigator Group’s mills;

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 470

iii. Territorial planning and forest fires;

iv. Low productivity of the country’s forests;

v. Lack of certification of most of the Portuguese forest; and

vi. Volatility of the fiscal policy and no reduction of the IRC rate, as well as non-elimination of the surcharges.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 471

10. Provisions, commitments and contingencies

10.1. Provisions

Movements in provisions

Legal Amounts in Euro proceedings Other provisions Total 01 January 2023 5,106,975 23,325,900 28,432,877 Increases 601,811 217,808 819,619 Reversals (25,660) (1,800,000) (1,825,660) Impact in profit/(loss) for the period 576,151 (1,582,192) (1,006,041) Change in the perimeter - 105,854 105,854 Other transfers and adjustments 1,826,208 (1,521,612) 304,596 31 December 2023 7,509,334 20,327,950 27,837,286 Increases 462,589 169,728 632,317 Reversals (600,139) - (600,139) Impact in profit/(loss) for the period (137,550) 169,728 32,178 Charge-off - 15,339 15,339 Other transfers and adjustments 345,255 141,011 486,266 31 December 2024 7,717,039 20,654,028 28,371,069

No repayments of any nature are expected in respect of these provisions.

Legal proceedings

The outcome of provisions for legal proceedings depends on the labour or civil court decisions.

The balance as at 31 December 2024 is mainly composed of amounts relating to labour lawsuits and lawsuits with APA -

Portuguese Environment Agency regarding the water resources rate.

Other provisions

The amount presented includes provisions to cover risks related to events of a different nature, the resolution of which may result

in outflows of cash, in particular organisational restructuring processes, risks of contractual positions assumed in investments,

among others.

In 2024 and 2023, Other provisions includes Euro 15.594.728 and Euro 15.500.000, respectively, related to the Mozambique

project. Although the Memorandum of Understanding (MoU) signed with the Mozambican Government provided for a “best effort”

commitment to create the necessary conditions to carry out the investment until last 31 December 2018, that was not possible

until 31 December 2024, and both parties continued to work towards that goal.

The Group's uncertain income tax positions are disclosed in Note 6.1

- Income Tax.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 472

Estimates and judgements

Legal and tax proceedings

These provisions were made in accordance with the risk assessments carried out internally by the Group with the

support of its legal advisers, based on the probability of the decision being favourable or unfavourable to the Group.

Accounting policies

Provisions are recognised whenever the Group has a present legal or constructive obligation, as a result of past

events, in which it is probable that an outflow of resources will be required to settle the obligation and the amount

has been reliably estimated.

Provisions for future operating losses are not recognised. Provisions are reviewed on the date of the statement of financial position

and are adjusted to reflect the best estimate at that date.

The Group incurs expenditure and assumes liabilities of an environmental nature. Accordingly, expenditures on equipment and

operating techniques that ensure compliance with applicable legislation and regulations (as well as on the reduction of

environmental impacts to levels that do not exceed those representing a viable application of the best available technologies, on

those related to minimising energy consumption, atmospheric emissions, the production of residues and noise), are capitalised

when they are intended to serve the Group’s business in a durable way, as well as those associated with future economic benefits

and which serve to extend the useful lives, increase capacity or improve the safety or efficiency of other assets owned by the

Group.

10.2. Commitments

Guarantees provided to third parties

Amounts in Euro 2024 2023 Guarantees provided Navigator guarantees for EIB loans 11,666,667 22,083,333 Ocean Network Express 2,751,947 2,751,947 AT - Tax and Customs Authority 9,288,070 - Comissão Coordenação Desenvolvimento Regional 354,083 354,083 IAPMEI - 1,280,701 Agência Portuguesa Ambiente 3,337,887 2,846,271 Simria 338,829 338,829 Other 1,193,505 838,256 28,930,988 30,493,420

In the first half of 2024, a new bank guarantee was set up for the Tax and Customs Authority, in the amount of Euro 9,288,070, as

a result of the notification received by The Navigator Company at the end of 2023, relating to the additional assessment of corporate

income tax for 2019 resulting from adjustments made during a tax inspection. The Group decided to challenge this additional

assessment and refrain from payment and from setting up this bank guarantee.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 473

In the case of the Portuguese Environment Agency, bank guarantees were provided in the context of proceedings in litigation

associated with the water resources rate for the years 2017 to 2022.

Purchase commitments

Amounts in Euro 2024 2023 Purchase commitments Property, plant and equipment – Industrial equipment 145,451,837 140,885,321 Energy 103,786,050 125,753,200 Wood Commitments with acquisitions in the subsequent period 251,400,000 265,000,000 Commitments to long-term acquisitions 56,900,000 102,600,000 557,537,887 634,238,521

The Navigator Group's subsidiary Abastecimento de Madeira, ACE, signed a contract with Portline Ocean Bulk, Inc. for the

chartering of ships to transport 940,000 m

, initially planned for the period 2022, 2023 and 2024, which was extended to 2025

and 2026 without changing the overall volume to be transported.

Moreover, the Group has entered into energy purchase commitments amounting to Euro 125,753,200.

Purchase commitments of an operational nature, which are not reflected in the statement of financial position, include liabilities

associated with long-term contracts for the supply of raw materials, products and services within the scope of The Navigator

Company's activity. The value of the commitments has been estimated on the basis of the information available at the time, based

on the contractual terms and the best information available at the time on the volumes and prices applicable for the remaining

period of the contracts.

Other commitments

The Navigator Group has made a commitment to achieve carbon neutrality by 2035, with an estimated global investment of Euro

340 million, of which Euro 232.2 million have already been invested until 31 December 2024 (2023: Euro 137.6 million).

10.3. Contingent assets and liabilities

Public Debt Settlement Fund

According to Decree-Law 36/93 of 13 February, the tax debts of privatised companies relating to periods prior to the privatisation

date (25 November 2006) are the responsibility of the Public Debt Settlement Fund (FRDP). The Navigator Company submitted an

application to the FRDP on 16 April 2008, requesting the payment of the tax debts until then settled by the Tax Authorities. On 13

December 2010, The Navigator Company presented a new application requesting the payment of debts settled by the tax

authorities regarding 2006 and 2003. This application was supplemented on 13 October 2011, with the amounts already paid and

uncontested regarding these debts, as well as with expenses directly related to them, pursuant to court ruling dated 24 May 2011

(Case 0993A/02), which confirmed the Company's position regarding the enforceability of such expenses.

On 13 December 2017, The Navigator Company, S.A. has made an extra-judicial agreement with the Tax Authorities, in which it

was acknowledged the FRDP´s responsibility for refunding the amount of Euro 5,725,771 corresponding to the amount of

Corporate Income Tax (IRC) unduly paid, resulting from the alleged qualification/incorrect consideration, by the Tax Authorities, of

the tax loss calculated as a result of the operations performed by Soporcel, S.A. in 2003, as well as to promote the reimbursement

to Navigator of the mentioned amount.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 474

In January 2023, the Court, while rejecting in their entirety the defendants' pleas in law, issued a judgement against the

Navigator Group and acquitted the defendants of the claim relating to the 2006 aggregate corporate income tax. Following this

decision, the Group appealed to the Supreme Administrative Court in February 2023.

Navigator was notified on 12 December 2024 of a ruling that upheld the formal objection raised by the Defendants and acquitted

them of the claim relating to the aggregate corporate income tax for 2001 to 2005. Navigator was notified on 12 December 2024

of a ruling that upheld the formal objection raised by the Defendants and acquitted them of the claim relating to the aggregate

corporate income tax for 2001 to 2005. Following this decision, the Group filed an appeal with the Central Administrative Court -

South on 28 January 2025.

In this context, FRDP is liable for Euro 21,853,377, detailed as follows:

Proceedings decided in Amounts in Euro Amounts Decrease due to favour of the Outstanding Period requested RERD Group amounts Proceedings confirmed in court Corporate income tax 2002 18,923 - - 18,923 Corporate income tax (FR) 2004 3,324 - - 3,324 Corporate income tax 2004 766,395 - (111,544) 654,851 Expenses 314,957 - (314,957) - 1,103,599 - (426,501) 677,098 Proceedings not confirmed in court Corporate income tax 2005 11,754,680 (1,360,294) - 10,394,386 Corporate income tax 2006 11,890,071 (1,108,178) - 10,781,893 23,644,751 (2,468,472) - 21,176,279 24,748,350 (2,468,472) (426,501) 21,853,377

Regarding the aggregate Corporate Income Tax proceedings of 2005 and 2006, if Courts come to a decision in favour of Navigator

Group, the Group will withdraw the request made to FRDP.

Public Debt Settlement Fund - proceeding no. 774/11.3 BEALM

Additionally, a new petition was filed in the Administrative Court of Almada on 11 October 2011, which called for the repayment of

various amounts, amounting to Euro 136,243,949. These amounts regard adjustments in the financial statements of the Group

after its privatisation that had not been considered in formulating the price of its privatisation as they were not included in the

documentation made available for consultation by the bidders.

On 24 May 2014, the Court denied the Navigator Group’s proposal to present testimony evidence, alternatively proposing written

submissions. On 30 June 2014, the Group appealed against this decision, but continuously presented written evidence. The Court

subsequently confirmed the Navigator Group’s views on this matter, both parts appointed experts and the partial expert report

was issued on July 2017, being required either by The Navigator Company, S.A. either by the Ministério das Finanças, the

attendance of both designated experts in court hearing, in order to provide oral explanations on the expert report.

Following claims filed by Navigator on 11 September 2017 and 15 January 2019, the experts submitted redrafted Expert Reports

on 27 December 2018 and 19 March 2019, respectively.

The trial hearing took place between May and June 2019, with the parties filing closing arguments in September 2019, awaiting

the passing of sentence since the case was concluded before the judge on 5 July 2021.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 475

11. Group structure

11.1. Companies included in the consolidation perimeter

11.1.1. Navigator Group subsidiaries

Share equity owned 31-12-2024 31-12-2023 Company Head Office Direct Indirect Total Total Main activity Parent company: The Navigator Company, S.A. Portugal - - - - Sale of paper and pulp Subsidiaries: Acquisition, operation, lease or concession of the use and disposal of Navigator Brands, S.A. Portugal 100.0 - 100.0 100.0 trademarks, patents and other industrial or intellectual property Navigator Parques Industriais, S.A. Portugal 100.0 - 100.0 100.0 Management of industrial real estate Navigator Pulp Figueira, S.A Portugal 100.0 - 100.0 100.0 Paper production Empremédia - Corretores de Seguros, S.A. Portugal 100.0 - 100.0 100.0 Insurance mediation and advisory services Empremedia, DAC Ireland 100.0 - 100.0 100.0 Management of shareholdings Empremedia RE , DAC Ireland - 100.0 100.0 100.0 Insurance mediation and advisory services Applied research in the field of pulp and paper industry and forestry Raiz - Instituto de Investigação da Floresta e Papel Portugal 97.0 - 97.0 97.0 activity Enerpulp – Cogeração Energética de Pasta, S.A. Portugal 100.0 - 100.0 100.0 Energy production Production of cellulose pulp and provision of administration, Navigator Pulp Figueira, S.A. Portugal 100.0 - 100.0 100.0 management and internal advisory services Ema Cacia - Engenharia e Manutenção Industrial, ACE Portugal - 73.8 73.8 73.8 Ema Setúbal - Engenharia e Manutenção Industrial, ACE Portugal - 80.7 80.7 80.7 Provision of industrial maintenance services Ema Figueira da Foz – Engenharia e Manutenção Industrial, ACE Portugal - 79.7 79.7 79.7 Navigator Pulp Setúbal, S.A. Portugal 100.0 - 100.0 100.0 Cellulose pulp production Navigator Pulp Aveiro, S.A. Portugal 100.0 - 100.0 100.0 Cellulose pulp production Wholesale and manufacture of packaging and other articles of cellulose Navigator Fiber Solutions, S.A. Portugal - 100.0 100.0 100.0 pulp, paper and cardboard and related products . Navigator Tissue Aveiro, S.A. Portugal 100.0 - 100.0 100.0 Tissue paper production Navigator Tissue Ródão, S.A. Portugal - 100.0 100.0 100.0 Navigator Tissue Iberica , S.A. Spain - 100.0 100.0 100.0 Sale of tissue paper Navigator Tissue Ejea, SL Spain 100.0 - 100.0 100.0 Tissue paper production Navigator Tissue France, EURL France - 100.0 100.0 100.0 Sale of tissue paper Portucel Moçambique - Sociedade de Desenvolvimento Florestal e Mozambique 90.0 - 90.0 90.0 Forestry production Industrial, Lda Navigator Forest Portugal, S.A. Portugal 100.0 - 100.0 100.0 Forestry production EucaliptusLand, S.A. Portugal - 100.0 100.0 100.0 Forestry production Gavião - Sociedade de Caça e Turismo, S.A. Portugal - 100.0 100.0 100.0 Management of hunting resources Afocelca - Agrupamento complementar de empresas para protecção Portugal - 64.8 64.8 64.8 Provision of forest fire prevention and fighting services contra incêndios, ACE Viveiros Aliança - Empresa Produtora de Plantas, S.A. Portugal - 100.0 100.0 100.0 Plant production in nurseries Bosques do Atlantico, SL Spain - 100.0 100.0 100.0 Trade in wood and biomass and logging Navigator Africa, SRL Italy - 100.0 100.0 100.0 Trade in wood and biomass and logging Navigator Paper Setúbal , S.A. Portugal 100.0 - 100.0 100.0 Paper and energy production Navigator North America Inc. USA - 100.0 100.0 100.0 Sale of paper Navigator Afrique du Nord Morocco - 100.0 100.0 100.0 Navigator España, S.A. Spain - 100.0 100.0 100.0 Navigator Netherlands, BV The Netherlands - 100.0 100.0 100.0 Provision of sales intermediation services Navigator France, EURL France - 100.0 100.0 100.0 Navigator Paper Company UK, Ltd United Kingdom - 100.0 100.0 100.0 Navigator Holding Tissue UK, Ltd (formerly Accrol Group Holdings United Kingdom - 100.0 100.0 Holding company plc) Navigator Corporate UK, ltd (formerly Accrol UK, ltd) United Kingdom - 100.0 100.0 Holding company Accrol Holdings, ltd United Kingdom - 100.0 100.0 Holding company Navigator Tissue UK, ltd (formerly Accrol Papers, ltd) United Kingdom - 100.0 100.0 Tissue paper conversion LTC Parent Ltd United Kingdom - 100.0 100.0 Holding company Leicester Tissue Company ltd United Kingdom - 100.0 100.0 Tissue paper conversion Art Tissue ltd United Kingdom - 100.0 100.0 Sale of tissue paper John Dale (Holdings) ltd United Kingdom - 100.0 100.0 Holding company John Dale, ltd United Kingdom - 100.0 100.0 Tissue paper production Severn Delta, ltd United Kingdom - 100.0 100.0 Tissue paper production Navigator Italia, SRL Italy - 100.0 100.0 100.0 Navigator Deutschland, GmbH Germany - 100.0 100.0 100.0 Navigator Paper Austria, GmbH Austria - 100.0 100.0 100.0 Navigator Paper Poland SP Z o o Poland - 100.0 100.0 100.0 Navigator Eurasia Turkey - 100.0 100.0 100.0 Provision of sales intermediation services Navigator Paper Mexico Mexico 25.0 75.0 100.0 100.0 Navigator Middle East Trading DMCC Dubai - 100.0 100.0 100.0 Navigator Egypt, ELLC Egypt 1.0 99.0 100.0 100.0 Navigator Paper Southern Africa South Africa 1.0 99.0 100.0 100.0 Portucel Nigeria Limited Nigeria 1.0 99.0 100.0 100.0 Navigator Green Fuels Setúbal, S.A. Portugal 100.0 - 100.0 100.0 Production of sustainable fuels. Navigator Green Fuels Figueira da Foz, S.A. Portugal 100.0 - 100.0 100.0 Production of sustainable fuels. Navigator Abastecimento de Madeira, ACE Portugal 97.0 3.0 100.0 100.0 Sale of timber

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 476

11.1.2. Incorporated joint operations

Share equity owned 31-12-2024 31-12-2023 Company Head Office Direct Indirect Total Total Main activity Purchases of materials, subsidiary materials and services Pulpchem Logistics, A.C.E. Portugal 50 -50 50 used in the pulp and paper production processes

11.2. Changes in the consolidation perimeter

During the period ended 30 June 2024, the consolidation perimeter was changed from the previous period by the acquisition of the

Navigator Tissue UK Group, as follows:

2024

- Acquisition of Navigator Holding Tissue UK, Ltd (formerly Accrol Group Holdings plc)

- Acquisition of Navigator Corporate UK, ltd (formerly Accrol UK, ltd)

- Acquisition of Accrol Holdings, ltd

- Acquisition of Navigator Tissue UK, ltd (formerly Accrol Papers, ltd)

- Acquisition of LTC Parent Ltd

- Acquisition of Leicester Tissue Company ltd

- Acquisition of Art Tissue ltd

- Acquisition of John Dale (Holdings)ltd

- Acquisition of John Dale, ltd

- Acquisition of Severn Delta, ltd

11.3. Transactions with related parties

Balances with related parties

Other subsidiaries of Semapa Group

2024 2023 ReceivablesPayables ReceivablesPayablesAmounts in Euro (Note 4.2) (Note 4.3) (Note 4.2) (Note 4.3) Shareholders (Note 5.2) Semapa - Soc. de Investimento e Gestão, SGPS, S.A. - 1,155,456 - 952,804 Secil - Companhia Geral Cal e Cimento, S.A. - 18,970 - 40,974 Secil Britas, S.A. - 84,277 - 111,647 Unibetão, S.A. - 237,150 - 435,100 Other related parties Hotel Ritz, S.A. - 844 - 1,672 - 1,496,687 - 1,542,197

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 477

Transactions with related parties in the period

2024 2023 Purchase of Sales and Financial Purchase of Sales and Financial goods and services (expenses)/ goods and services (expenses)/ Amounts in Euro services rendered income services rendered income Shareholders (Note 5.2) Semapa - Soc. de Investimento e Gestão, 11,523,914 42 - 9,730,534 44 - SGPS, S.A. 11,523,914 42 - 9,730,534 44 - Other subsidiaries of Semapa Group Secil - Companhia Geral Cal e Cimento, S.A. 116,490 - 157,892 2,435 - Secil Britas, S.A. 206,858 - - 212,333 - - Secil Prebetão, S.A. 72 - - - - - Unibetão, S.A. 1,232,938 - - 598,752 - - 1,556,358 - - 968,977 2,435 - Other related parties Hotel Ritz, S.A. 14,916 - 1,106 7,131 - 1,106 14,916 - 1,106 7,131 - 1,106 13,095,188 42 1,106 10,706,642 2,479 1,106

On 1 February 2013, a contract to render administrative and management services was signed between Semapa - Sociedade de

Investimentos e Gestão, SGPS, S.A. (currently owner of 70.03% of the Group´s share capital) and Navigator Group, establishing

a remuneration system based in equal criteria for both parties in the continuous cooperation and assistance relationships, that

meets the rules applicable to commercial relationships between Group companies.

The operations performed with the Secil Group arise from normal market operations.

In the identification of the Navigator Company Group’s related parties for the purpose of financial reporting, the members of the

Navigator Company Group’s Board of Directors and other corporate bodies were considered as related parties.

The remuneration of the

Group's key management personnel is detailed in Note 7.3 - Remuneration of

corporate bodies.

12. Explanation added for translation

These financial statements are a translation of the financial statements originally issued in Portuguese. In the event of

discrepancies, the Portuguese language version shall prevail.

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 478

BOARD OF DIRECTORS

Ricardo Miguel dos Santos Pacheco Pires

Chairman of the Board of Directors

António José Pereira Redondo

Chairman of the Executive Committee

José Fernando Morais Carreira de Araújo

Executive Committee Member

Nuno Miguel Moreira de Araújo Santos

Executive Committee Member

João Paulo Cabete Gonçalves Lé

Executive Committee Member

Dorival Martins de Almeida

Executive Committee Member

António Quirino Vaz Duarte Soares

Executive Committee Member

Ana Teresa Cunha de Pinto Tavares Lehmann

Committee Member

Hugo Alexandre Lopes Pinto

Board Member

Maria Isabel da Silva Marques Abranches Viegas

Committee Member

Maria Teresa Aliu Presas

Member

Mariana Rita Antunes Marques dos Santos

Member

Sandra Maria Soares Santos

Member

Vítor Paulo Paranhos Ferreira

Member

2024 ANNUAL REPORT • CONSOLIDATED FINANCIAL STATEMENTS 479

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 480

STATUTORY AUDITORS’ REPORT and AUDITORS’ REPORT

REPORT ON THE AUDIT OF THE CONSOLIDATED FINANCIAL STATEMENTS

Opinion

We have audited the accompanying consolidated financial statements of

The Navigator

Company, S.A. (the Group), which comprise the consolidated statement of financial

position as at 31 December 2024 (showing a total of 3,353,183,064 euros and total equity

of 1,356,089.184 euros, including a profit for the year attributable to shareholders of

286,948,195 euros), and the consolidated income statement, consolidated statement of

comprehensive income, consolidated statement of changes in equity and consolidated

statement of cash flows for the year then ended, and the accompanying notes to the

consolidated financial statements, including a summary of accounting policies.

In our opinion, the accompanying consolidated financial statements give a true and fair

view, in all material respects, of the consolidated financial position of The Navigator

Company, S.A. as at 31 December 2024 and of its consolidated financial performance

and its consolidated cash flows for the year then ended in accordance with the

International Financial Reporting Standards as adopted by the European Union.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (ISAs) and

further technical and ethical standards and guidelines as issued by Ordem dos Revisores

Oficiais de Contas

(the Portuguese Institute of Statutory Auditors). Our responsibilities

under those standards are further described in the “Auditors’ Responsibilities for the Audit

of the Consolidated Financial Statements” section below. We are independent of the

Group in accordance with the law and we have fulfilled other ethical requirements in

accordance with the Ordem dos Revisores Oficiais de Contas’ code of ethics.

We believe that the audit evidence we have obtained is sufficient and appropriate to

provide a basis for our opinion.

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most

significance in our audit of the consolidated financial statements of the current year. These

matters were addressed in the context of our audit of the consolidated financial statements

as a whole, and in forming our opinion thereon, and we do not provide a separate opinion

on these matters.

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 481

Recoverability of Goodwill (422,627,337 euros) and Property, Plant and Equipment

(1,415,945,085 euros)

See Note 1.6 Significant accounting estimates and judgements and Notes 3.1 and 3.3 of the notes

to the Financial Statements

The Risk

Our response to the identified risk

The recoverability of goodwill and property,

plant and equipment is critical due to the

materiality of the amounts involved and the

complexity and subjectivity associated with

impairment tests, namely due to the

uncertainty inherent in financial forecasts,

which are based on the Board of Directors'

expectations, materialised in business and

investment plans, which are based on

various assumptions, associated with

discount rates, expected margins, short and

long-term growth rates and demand

behaviour, decarbonization initiatives in

response to changes in laws and

regulations and assumptions not

observable in the market.

Our audit procedures included, amongst

others, those that we describe below:

• We assessed the design and

implementation of the main controls

implemented by the Entity and analysed

the budgeting procedures on which the

projections are based, by comparing the

current performance with estimates

made in previous periods, and the

integrity of the discounted cash flow

model;

• We assessed the internal and external

assumptions used and their

reasonableness, such as current

business trends, market performance,

inflation, forecasted economic growth

and discount rates;

• We conducted sensitivity analyses of

the significant assumptions used by the

Group;

• We involved our specialists in

assessing the discount rate; and,

• We assessed the adequacy of the

respective disclosures to the financial

statements, in accordance with the

applicable accounting framework.

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 482

Fair value of biological assets (115,250,198 euros)

See Note 1.6 Significant accounting estimates and judgements and Note 3.8 of the notes to the

Financial Statements.

The Risk

Our response to the identified risk

The fair value of

biological assets is

determined using a model developed

internally, based on economic and market

forecasts, the assumptions of which,

namely the productivity of the forests, the

selling price of the wood less the cost of

logging, the rental value of the land owned

and leased, the collection and transport

costs, the planting and maintenance costs

and the discount rate, require a high degree

of estimation and judgement on the part of

the Board of Directors.

Our audit procedures included, amongst

others, those that we describe below:

• We assessed the design and

implementation of the main controls

implemented by the Group in this area;

• We validated the mathematical

correctness and underlying integrity of

the model;

• We analysed the budgeting procedures

on which the forecasts are based;

• We compared the actual performance

of variables inherent to the model with

the estimates performed in prior

periods, namely: forest productivity, the

value of own and leased land rents,

fixed costs, logging and transportation

costs, plantation and maintenance

costs;

• We compared the internal and external

assumptions used in the model, such as

the spot and trend price and the

discount rate with market data and

considered their sensitivity analysis;

and,

•

We assessed the adequacy of the

respective disclosures to the financial

statements, in accordance with the

applicable accounting framework.

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 483

Uncertainty over income tax treatments

See Note 1.6 Significant accounting estimates and judgements and Notes 6.1 and 6.2 of the notes

to the Financial Statements

The Risk

Our response to the identified risk

The application of tax legislation to the

various transactions and circumstances

with uncertain tax treatment is inherently

complex and requires judgement in

determining and measuring the risks and

uncertainties in defining the best estimate,

by weighing up all the possible outcomes it

controls and their associated probabilities.

Estimating the possible amounts to be

spent requires a high degree of judgement

on the part of the Board of Directors, which

assesses the probability of the outcome,

supported by the opinion of legal and tax

advisors.

Our audit procedures included, amongst

others, those that we describe below:

• We assessed the processes for

monitoring uncertain tax positions in

relation to the treatment of income tax,

including testing the design and

implementation of the main controls in

place and making enquiries of the

Board of Directors and tax managers on

the basis of their estimates and

judgements;

• We analysed ongoing tax proceedings

and potential uncertain tax positions,

considering the effect of uncertainty for

each uncertain tax treatment, supported

by tax experts, and reviewed the

existing documentation;

• We analysed the responses to the

confirmation requests received from

external lawyers;

• We assessed the consistency of the

criteria used in relation to previous

years; and,

• We assessed the adequacy of the

respective disclosures to the financial

statements, in accordance with the

applicable accounting framework.

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 484

Concentration of business activities

- acquisition of the Accrol Group

See Note 1.6 Significant accounting estimates and judgements and Note 1.2 of the notes to the

Financial Statements

The

Risk

Our response to the identified risk

During the year ended 31 December 2024,

the Navigator Group concluded, through a

takeover bid in the form of a

“Recommended Firm Cash Offer”, the

entirely share capital of Accrol Group

Holdings Plc, a company based in

Blackburn, England, dedicated to the

Tissue segment.

The consideration transferred from the

acquisition totalled 153,765,152 euros

(GBP 130,823,390).

This acquisition was accounted for as a

business combination and involved a

number of significant judgements on the

part of the Board of Directors, namely in the

identification and measurement of the

identifiable assets acquired, liabilities

assumed and goodwill.

Therefore, and given the materiality of the

impacts on the consolidated financial

statements, we considered the acquisition

to be a relevant audit matter.

Our audit procedures included, amongst

others, those that we describe below:

• We assessed the design and

implementation of the main controls

implemented by the Group in this area;

• We obtained and analysed the

documentation supporting the

transaction;

• We analysed the consideration

transferred;

• We analysed the methodology adopted

for valuing assets and liabilities and

verified the reasonableness of the

valuation models used to determine the

fair value of the assets acquired and

liabilities assumed, including validating

their agreement with the models used

for trading and their arithmetical

accuracy;

• We involve our specialists to validate

the fair value of the identifiable assets

acquired, the liabilities assumed and the

consequent calculation of goodwill; and,

• We assessed the adequacy of the

respective disclosures to the financial

statements, in accordance with the

applicable accounting framework.

Responsibilities of management and the supervisory body for the

consolidated financial statements

Management is responsible for:

• the preparation of consolidated financial statements that give a true and fair view of the

Group’s consolidated financial position, financial performance and the consolidated

cash flows, in accordance with the International Financial Reporting Standards as

adopted by the European Union;

• the preparation of the consolidated management report, the consolidated corporate

governance report, the consolidated non-financial information and the remunerations’

report in accordance with applicable laws and regulations;

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 485

•

the designing and maintenance of an appropriate internal control system to enable the

preparation of financial statements that are free from material misstatement, whether

due to fraud or error;

•

adopting accounting policies and criteria appropriate in the circumstances; and

•

the assessment of the Group’s ability to continue as a going concern, and disclosing,

as applicable, the matters that may cast significant doubt about the Group’s ability to

continue as a going concern.

The supervisory body is responsible for overseeing the Group’s financial reporting

process.

Auditors’ Responsibilities for the Audit of the Consolidated Financial

Statements

Our responsibility is to obtain reasonable assurance about whether the consolidated

financial statements as a whole are free from material misstatements whether due to fraud

or error, and to issue an auditors’ 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 financial statements.

As part of an audit in accordance with ISA, we exercise professional judgement and

maintain professional scepticism throughout the audit. We also:

•

identify and assess the risks of material misstatement of the 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 Group’s internal control;

•

evaluate the appropriateness of accounting policies used and the reasonableness of

accounting estimates and related disclosures made by management;

•

conclude on the appropriateness of management’s 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 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 auditors’ report to the related disclosures in the

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 auditors’

report. However, future events or conditions may cause the Group to cease to continue

as a going concern;

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 486

• evaluate the overall presentation, structure and content of the consolidated financial

statements, including the disclosures, and whether the financial statements represent

the underlying transactions and events in a manner that achieves fair presentation;

• plan and perform our audit to obtain sufficient appropriate audit evidence regarding the

financial information of the entities or units within the Group as a basis for forming an

opinion on the consolidated financial statements. We are responsible for directing,

supervising and reviewing the performance of the work carried out for the purposes of

the Group audit and are ultimately responsible for our audit opinion;

• communicate with those charged with governance, including the supervisory body,

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;

• determine, from the matters communicated with those charged with governance,

including the supervisory body, those matters that were of most significance in the

audit of the consolidated financial statements of the current year and are therefore the

key audit matters. We describe these matters in our auditors’ report unless law or

regulation precludes their public disclosure; and,

• provide the supervisory body with a statement that we have complied with the relevant

ethical requirements regarding independence and communicate with them all

relationships and other matters that may reasonably be thought to bear on our

independence, and where applicable, actions taken to eliminate threats or safeguards

applied.

Our responsibility also includes the verification that the information contained in the

consolidated management report is consistent with the financial statements, and the

verification of the requirements as provided in numbers 4 and 5 of article 451 of the

Portuguese Companies’ Code regarding the corporate governance report, as well as the

verification that the non-financial information and the remunerations report were presented.

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS

On the consolidated management report

According to Article 451, paragraph 3(e), of the Portuguese Companies' Code, it is our

opinion that the management report was prepared in accordance with the applicable legal

and regulatory requirements and the information contained therein is consistent with the

audited consolidated financial statements and, having regard to our knowledge and

assessment of the Group, we have not identified any material misstatements. As defined in

Article 451, paragraph 7, of the Portuguese Companies’ Code, this opinion is not

applicable to the non-financial statement that is included in the management report.

On the Corporate Governance Report

Pursuant to Article 451(4) of the Portuguese Companies' Code, it is our opinion that the

corporate governance report includes the information required to the Entity to provide

under Article 29-H of the Securities Code, and we have not identified any material

misstatements on the information provided therein in compliance with paragraphs c), d), f),

h), i) and l) of paragraph 1 of that Article.

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 487

On the non-financial information

Pursuant to Article 451, paragraph 6, of the Portuguese Companies' Code, we inform that

the Group has included in its management report the non-financial statement defined in

Article 508-G of the Portuguese Companies’ Code.

On the remuneration report

Pursuant to Article 26-G, paragraph 6, of Portuguese Companies’ Code, we inform that the

Entity has included in the corporate governance report in a separate chapter the

information defined in paragraph 2 of that article.

On the European single electronic format (ESEF)

The consolidated financial statements of The Navigator Company, S.A. for the year ended

31 December 2024 must comply with the applicable requirements set out in Commission

Delegated Regulation (EU) 2019/815 of 17 December 2018 (ESEF Regulation).

Management is responsible for drawing up and disclosing the annual report in accordance

with the ESEF Regulation.

We are responsible for obtaining reasonable assurance as to whether the consolidated

financial statements included in the annual report are presented in accordance with the

requirements set out in the ESEF Regulation.

Our procedures took into consideration the OROC Technical Application Guide on ESEF

reporting and included, among others:

•

understanding the financial reporting process, including the presentation of the annual

report in valid XHTML format; and

•

identifying and assessing the risks of material misstatement associated with marking

up financial statement information in XBRL format using iXBRL technology. This

assessment was based on an understanding of the process implemented by the entity

to mark up the information.

In our opinion, the consolidated financial statements included in the annual report are

presented, in all material respects, in accordance with the requirements established in the

ESEF Regulation.

On the additional matters provided in Article 10 of the Regulation (EU)

537/2014

Pursuant to Article 10 of the Regulation (EU) no. 537/2014 of the European Parliament

and of the Council, of 16 April 2014, and in addition to the key audit matters mentioned

above, we also report the following:

•

We were first appointed as auditors of The Navigator Company, S.A. (parent Entity of

the Group) in the general shareholders meeting held on 22 September 2017 to

complete the final year of the mandate between 2015 and 2018. We were reappointed

as auditors in the general shareholders meeting held on 9 April 2019 for a second

mandate from 2019 to 2022 and on 17 May 2023 for a third mandate from 2023 to

2025.

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 488

•

Management as confirmed to us that they are not aware of any fraud or suspicion of

fraud having occurred that has a material effect on the financial statements. In

planning and executing our audit in accordance with ISAs we maintained professional

scepticism, and we designed audit procedures to respond to the possibility of material

misstatement in the consolidated financial statements due to fraud. As a result of our

work, we have not identified any material misstatement of the consolidated financial

statements due to fraud.

•

We confirm that the audit opinion we issue is consistent with the additional report that

we prepared and delivered to the supervisory body of the Group on [•] April 2025.

•

We declare that we have not provided any prohibited services as described in under

Article 5 of Regulation (EU) no. 537/2014 of the European Parliament and of the

Council of 16 April 2014, and we have remained independent of the Group in

conducting the audit.

11 April 2025

SIGNED ON THE ORIGINAL

KPMG & Associados

Sociedade de Revisores Oficiais de Contas, S.A.

(no. 189 and registered at CMVM with the no. 20161489)

represented by

Rui Filipe Dias Lopes

(ROC no. 1715 and registered at CMVM with no. 20161325)

2024 ANNUAL REPORT • REPORT AND OPINION OF THE AUDIT BOARD 490

The Navigator Company, S.A.

Report and Opinion of the Audit Board

Consolidated Financial Statements

2024 Financial Year

Shareholders,

1. In accordance with the Law and the Articles of Association of the Company, and in the

performance of the mandate conferred on us, we hereby submit the report on our supervisory

activities carried out in 2024 and issue our opinion on the Consolidated Management Report and

Consolidated Financial Statements presented by the Board of Directors of the Navigator

Company, S.A., for the financial year ended 31 December 2024.

2. Over the course of the year we regularly monitored the activities of the Company and its most

significant affiliates and associates, as often and as extensively as we deemed appropriate, in

particular through periodic meetings with the Company’s directors and managers. We monitored

the verification of the accounting records and respective supporting documentation, as well as

the effectiveness of the risk management, internal control and internal audit systems. We

monitored compliance with the Law and the Articles of Association. In the course of our activities

we encountered no constraints whatsoever.

3. We also monitored the Navigator Group's consolidated sustainability reporting process. It should

be noted in this regard that the consolidated non-financial statement (Consolidated Sustainability

Report), prepared in accordance with the requirements of the European Sustainability Reporting

Standards (ESRS), contains relevant information that enables an understanding of the

performance, position and impact of the Group's activities and businesses, with regard to

environmental, social and governance issues.

4. We have met several times with the Statutory Auditor and External Auditor, KPMG & Associados,

SROC, Lda., monitoring the audit work carried out and checking their independence, and we

have analysed the Legal Certification of Accounts and Audit Report, which we agree with.

2024 ANNUAL REPORT • REPORT AND OPINION OF THE AUDIT BOARD 491

5. We have also taken note of the Independent Auditor's Limited Assurance Report on the

Consolidated Sustainability Report, for the purpose of issuing a limited assurance conclusion,

which does not include any modifications, with the exception of the fact that the comparative

information relating to 31 December 2023 has not been subject to limited assurance work, a

situation with which we agree.

6. The Audit Board analysed the proposals submitted to it for the provision of non-audit services

by the Chartered Accountants Firm and approved those that concerned permitted services, did

not affect the independence of the Chartered Accountants Firm and complied with the other legal

requirements.

7. Within the scope of our duties, we have verified that:

a) The Consolidated Income Statement, the Consolidated Statement of Financial Position, the

Consolidated Statement of Comprehensive Income, the Consolidated Statement of Changes

in Equity, the Consolidated Statement of Cash Flows and the accompanying Notes to the

Consolidated Financial Statements, provide an adequate understanding of the Company's

financial position and results, comprehensive income, changes in equity, and cash flows;

b) The accounting policies and valuation criteria adopted comply with the International Financial

Reporting Standards (IFRS) as adopted in the European Union and are suitable to ensure that

such criteria lead to a correct valuation of the Company’s assets and profits, taking due

account of the analyses and recommendations of the External Auditor;

c) The Consolidated Management Report is sufficiently clear in explaining the development of

the business and the situation of the Company and all subsidiaries included in the

consolidation, clearly highlighting the most significant aspects of the activity;

d) The Corporate Governance Report includes the information required by Article 29.º-H of the

Securities Code and takes into account the recommendations of the Code of the Portuguese

Institute for Corporate Governance (IPCG).

8. Accordingly, taking into consideration the information received from the Board of Directors and

the Company departments, and also the conclusions of the Statutory Auditor’s Report and

Auditor’s Report, we recommend that:

2024 ANNUAL REPORT • REPORT AND OPINION OF THE AUDIT BOARD 492

a) The Management Report be approved;

b) The Consolidated Financial Statements be approved.

Finally, the members of the Audit Board wish to acknowledge and express their appreciation

for the assistance received from the Board of Directors, the main managers and other staff of

the Company, as well as to the firm of Statutory Auditors, KPMG & Associados, SROC, Lda.

Lisbon, April 11, 2025

The Chairman of the Audit Board

José Manuel Oliveira Vitorino

Member

Gonçalo Nuno Palha Gaio Picão Caldeira

Member

Maria da Luz Gonçalves de Andrade Campos

RELATÓRIO ANUAL 2024 • DEMONSTRAÇÕES FINANCEIRAS CONSOLIDADAS 493

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 494

Separate Income Statement

For the periods ended 31 December 2024 and 2023

Amounts in Euro

Note

2024

2023

Revenue

2.1

2,834,653,080

2,659,705,827

Other operating income

2.2

4,038,014

5,115,697

Costs of goods sold and materials consumed

4.1

(2,476,330,691)

(2,339,940,354)

External services and supplies

2.3

(233,629,116)

(221,634,640)

Payroll costs

7.1

(5,593,834)

(7,186,383)

Other operating expenses

2.3

(2,659,370)

(2,400,470)

Net provisions

9.1

(23,630)

1,789,744

Income from subsidiaries

10.1

192,493,281

224,727,140

Depreciation, amortisation and impairment losses in non-financial assets

3.3

(626,617)

(580,489)

Operating profit/(loss)

312,321,117

319,596,072

Financial income and gains

5.10

44,956,205

36,416,925

Financial expenses and losses

5.10

(58,417,463)

(58,664,258)

Profit before income tax

298,859,859

297,348,739

Income tax

6.1

(11,911,664)

(22,424,919)

Net profit/(loss) for the period

286,948,195

274,923,820

Earnings per share

Basic earnings per share, Eur

5.3

0.403

0.387

Diluted earnings per share, Eur

5.3

0.403

0.387

The accompanying notes form an integral part of these separate financial statements.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 495

Separate statement of comprehensive income

For the periods ended 31 December 2024 and 2023

Amounts in Euro

Note

2024

2023

Net profit/(loss) for the period

286,948,195

274,923,820

Items that may be reclassified to the income statement

Hedging derivative financial instruments

Changes in fair value

8.2

(1,526,544)

(29,102,154)

Tax on items above

6.2

639,231

8,003,092

Other changes in equity of subsidiaries

10.1

9,086,118

1,013,513

Items that may not be reclassified to the income statement

Remeasurement of post-employment benefits

7.2

(214,318)

248,140

Other comprehensive income

734,546

Total other comprehensive income net of taxes

7,984,487

(19,102,863)

Total comprehensive income

294,932,682

255,820,957

The accompanying notes form an integral part of these separate financial statements.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 496

Separate statement of financial position

As at 31 December 2024 and 2023

Amounts in Euro

Note

2024

2023

ASSETS

Non-current assets

Property, plant and equipment

3.1

1,153,588

909,232

Right-of-use assets

3.2

1,359,258

1,787,685

Investments in subsidiaries

10.1

1,778,826,227

1,751,528,123

Investments in associates

44,600

46,225

Non-current receivables

4.2

6,684

27,956

Deferred tax assets

6.2

8,614,912

3,937,992

1,790,005,269

1,758,237,213

Current assets

Inventories

4.1

27,283,541

32,116,019

Current receivables

4.2

1,034,094,913

816,521,582

Income tax

6.1

19,746,025

17,510,098

Cash and cash equivalents

5.8

406,735,567

310,150,771

1,487,860,046

1,176,298,470

Total assets

3,277,865,315

2,934,535,683

EQUITY AND LIABILITIES

Capital and Reserves

Share capital

5.2

500,000,000

Reserves by applying the equity method

5.5

(395,128,709)

(404,214,827)

Fair value reserves

5.5

12,011,454

12,898,767

Legal reserve

5.5

100,000,000

Other reserves

5.5

(8,338,101)

1,103,749

Retained earnings

5.5

960,235,449

830,534,306

Net profit/(loss) for the period

286,948,195

274,923,820

Prepaid dividends

5.4

(99,999,451)

Total Equity

1,355,728,837

1,315,245,815

Non-current liabilities

Interest-bearing liabilities

5.6

707,608,727

536,857,472

Lease liabilities

5.7

876,698

1,371,022

Pensions and other post-employment benefits

7.2

408,936

167,936

Deferred tax liabilities

6.2

4,728,162

5,013,621

Provisions

9.1

16,624,744

16,344,333

730,247,267

559,754,384

Current liabilities

Interest-bearing liabilities

5.6

365,423,477

360,172,883

Lease liabilities

5.7

587,065

540,140

Current payables

4.3

789,671,835

677,666,895

Income tax

6.1

36,206,834

21,155,566

1,191,889,211

1,059,535,484

Total liabilities

1,922,136,478

1,619,289,868

Total Equity and Liabilities

3,277,865,315

2,934,535,683

The accompanying notes form an integral part of these separate financial statements.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS

497

Statement of Changes in Equity

For the periods ended 31 December 2024 and 2023

2024

Amounts in Euro

Note

capital

Reserves by

applying the

equity method

Fair value

reserves

Legal reserve

Other

reserves

Retained

earnings

Net

profit/(loss)

for the period

Prepaid

dividends

Total

Equity as at 1 January 2024

500,000,000

(404,214,827)

12,898,767

100,000,000

1,103,749

830,534,306

274,923,820

1,315,245,815

Net profit/(loss) for the period

286,948,195

Other comprehensive income (net of taxes)

9,086,118

(887,313)

(214,318)

7,984,487

Total comprehensive income for the

period

9,086,118

(887,313)

(214,318)

286,948,195

294,932,682

Appropriation of 2023 net

profit/(loss) for the period:

5.4

- Dividends paid

(149,995,621)

- Application of prior period's net

profit/(loss)

288,923,820

(274,923,820)

14,000,000

Bonus to employees

(14,000,000)

Acquisition/disposal of non-controlling

interests

(9,441,850)

4,987,262

(4,454,588)

Early dividends

5.4

(99,999,451)

Total transactions with shareholders

(9,441,850)

129,915,461

(274,923,820)

(99,999,451)

(254,449,660)

Equity as at 31 December 2024

500,000,000

(395,128,709)

12,011,454

100,000,000

(8,338,101)

960,235,449

286,948,195

(99,999,451)

1,355,728,837

2023

Amounts in Euro

Note

capital

Reserves by

applying the

equity method

Fair value

reserves

Legal reserve

Other

reserves

Retained

earnings

Net

profit/(loss)

for the period

Prepaid

dividends

Total

Equity as at 1 January 2023

500,000,000

(405,228,340)

33,997,828

100,000,000

1,103,749

636,999,230

392,537,070

1,259,409,537

Net profit/(loss) for the period

274,923,820

Other comprehensive income (net of taxes)

1,013,513

(21,099,061)

982,685

(19,102,863)

Total comprehensive income for the

period

1,013,513

(21,099,061)

982,685

274,923,820

255,820,957

Appropriation of 2022 net profit/(loss)

for the period:

- Dividends paid

5.4

(199,984,679)

- Application of prior period's net

profit/(loss)

5.4

426,537,070

(392,537,070)

34,000,000

- Bonus to employees

(34,000,000)

Total transactions with shareholders

192,552,391

(392,537,070)

(199,984,679)

Equity as at 31 December 2023

500,000,000

(404,214,827)

12,898,767

100,000,000

1,103,749

830,534,306

274,923,820

1,315,245,815

The accompanying notes form an integral part of these separate financial statements.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 498

Separate Statement of Cash Flows

For the periods ended 31 December 2024 and 2023

Amounts in Euro

Note

2024

2023

OPERATING ACTIVITIES

Receipts from customers

3,026,047,297

2,916,796,392

Payments to suppliers

(3,205,640,926)

(3,141,110,037)

Payments to employees

(4,519,061)

(8,581,366)

Cash flow from operations

(184,112,690)

(232,895,011)

Income tax received/ (paid)

(4,470,593)

(44,563,608)

Other receipts / (payments) relating to operating activities

248,443,069

292,731,522

Cash flows from operating activities (1)

59,859,786

15,272,903

INVESTING ACTIVITIES

Inflows:

Property, plant and equipment

184,016

Loans to subsidiaries

26,134,044

68,106,083

Interest and similar income

28,679,894

26,395,411

Investments in subsidiaries

372,038,000

Dividends from subsidiaries

246,013,925

243,131,096

300,827,913

709,854,606

Outflows:

Investments in subsidiaries

(29,101,294)

(62,651,861)

Loans to subsidiaries

(198,614,863)

(26,313,809)

Property, plant and equipment

(146,821)

(227,716,157)

(89,112,491)

Cash flows from investing activities (2)

73,111,756

620,742,115

FINANCING ACTIVITIES

Inflows:

Interest-bearing liabilities

5.9

330,000,000

15,000,000

330,000,000

15,000,000

Outflows:

Interest-bearing liabilities

5.9

(103,039,683)

(75,075,396)

Amortisation of lease agreements

5.7

(614,255)

(589,098)

Interest and similar expense

(41,041,598)

(54,635,392)

Distribution of dividends

5.4

(149,995,621)

(199,984,679)

Loans to subsidiaries

(21,600,000)

(372,850,000)

(316,291,157)

(703,134,565)

Cash flows from financing activities (3)

13,708,843

(688,134,565)

CHANGES IN CASH AND CASH EQUIVALENTS (1)+(2)+(3)

146,680,385

(52,119,547)

Effect of exchange rate differences

34,769

145,219

Merger by incorporation of Soc. Vinhos Herdade Espirra, S.A.

690,972

CASH AND CASH EQUIVALENTS AT THE BEGINNING OF THE PERIOD

5.8

42,017,571

93,300,927

CASH AND CASH EQUIVALENTS AT THE END OF THE PERIOD

5.8

188,732,725

42,017,571

The accompanying notes form an integral part of these separate financial statements.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 499

Notes to the Separate Financial

Statements as at 31 December 2024

1. Introduction 501

1.1. Disclosure 501

1.2. Subsequent events 504

1.3. Basis for preparation 504

1.4. New IFRS standards adopted and to be adopted 506

1.5. Significant accounting estimates and judgements 510

2. Operational performance 511

2.1. Revenue and segment reporting 511

2.2. Other operating income 514

2.3. Other operating expenses 514

3. Investments 516

3.1. Property, plant and equipment 516

3.2. Right-of-use assets 517

3.3. Depreciation, amortisation and impairment losses 518

4. Working capital 519

4.1. Inventories 519

4.2. Receivables 521

4.3. Payables 522

5. Capital structure 524

5.1. Capital management 524

5.2. Share Capital and treasury shares 525

5.3. Earnings per share 526

5.4. Dividends 526

5.5. Reserves and Retained earnings 527

5.6. Interest-bearing liabilities 529

5.7. Lease liabilities 533

5.8. Cash and cash equivalents 534

5.9. Cash flows from financing activities 534

5.10. Net financial results 535

6. Income tax 536

6.1. Income tax for the period 536

6.2. Deferred taxes 540

7. Payroll 542

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 500

7.1. Payroll costs 542

7.2. Employee benefits 543

7.3. Remuneration of Corporate Bodies 547

8. Financial instruments 548

8.1. Financial risk management 548

8.2. Derivative financial instruments 556

8.3. Financial assets and liabilities 559

9. Provisions, commitments and contingencies 561

9.1. Provisions 561

9.2. Commitments 562

9.3. Contingent assets and liabilities 562

10. Group structure 564

10.1. Investments in subsidiaries 564

10.2. Transactions with related parties 568

11. Explanation added for translation 570

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 501

1. Introduction

The following symbols are used in the presentation of the Notes to the financial statements:

Accounting policies

This symbol indicates the disclosure of accounting policies specifically applicable to the items

in the respective Note.

Significant estimates and judgements

This symbol indicates the disclosure of the estimates and/or judgements made regarding the

items in the respective Note. Significant estimates and judgements

are indicated in Note 1.5.

References

This symbol indicates a reference to another Note or another section of the Financial

Statements were more

information about the items disclosed is presented.

1.1. Disclosure

The Navigator Company, S.A. (Navigator or the Company) is a publicly traded company with its head office in Mitrena, 2901-861

Setúbal, and it is listed on NYSE Euronext Lisbon under the ISIN PTPTI0AM0006.

Company: The Navigator Company, S.A.

Head Office: Mitrena – Apartado 55 | 2901-861 Setúbal | Portugal

Legal Form: Public Limited Company

Share Capital: Euro 500,000,000

TIN: 503 025 798

Shares Issued: 711,183,069

Navigator is the parent company of the Navigator Group (Group), comprising Navigator and Subsidiaries, as presented in the

consolidated financial statements.

The Navigator Company, S.A. (until 2015 designated Portucel, S.A.), hereinafter referred to as Company or Navigator, is a publicly

traded company with its share capital represented by nominal shares and was incorporated on 31 May 1993, under Decree- Law

39/93 of 13 February, as a result of the restructuring process of Portucel - Empresa de Celulose e Papel de Portugal, E.P.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 502

The Group it currently leads was created in 1953, when a group of technicians from “Companhia Portuguesa de Celulose de Cacia”

made this company the first in the world to produce bleached eucalyptus sulphate pulp.

In 1976, Portucel EP was created as a result of the nationalisation of the cellulose industry which, through the merger of CPC –

Companhia de Celulose, S.A.R.L. (Cacia), Socel – Sociedade Industrial de Celulose, S.A.R.L. (Setúbal), Celtejo – Celulose do Tejo,

S.A.R.L. (Vila Velha de Ródão), Celnorte – Celulose do Norte, S.A.R.L. (Viana do Castelo) and Celuloses do Guadiana, S.A.R.L.

(Mourão) incorporated Portucel - Empresa de Celulose e Papel de Portugal, E.P., converted into a Public Limited Company of

mainly public capital by Decree-Law 405/90, of 21 December.

Years after, as a result of the restructuring of Portucel – Empresa de Celulose e Papel de Portugal, S.A., which was renamed

Portucel, SGPS, S.A., towards to its privatisation, Portucel S.A. was created, on 31 May 1993, through Decree-law 39/93, of 13

February, with the former assets of the two main companies, based in Aveiro and Setúbal.

In 1995, the Company was again privatised, and became a publicly traded company.

Aiming to restructure the paper industry in Portugal, Portucel, S.A. acquired Papeis Inapa, S.A. (Setúbal) in 2000 and Soporcel –

Sociedade Portuguesa de Papel, S.A. (Figueira da Foz) in 2001.

(Figueira da Foz), in 2001. These strategic moves were decisive and gave rise to the Portucel Soporcel Group (now The Navigator

Group), which is currently the largest European producer of bleached eucalyptus pulp and one of the largest European producers of

uncoated wood-free paper (UWF).

In June 2004, the Portuguese Government sold 30% of Portucel's capital, which was acquired by the Semapa Group. In September

of the same year, Semapa launched a public acquisition offer tending to assure the Group’s control, which was accomplished by

guaranteeing a 67.1% stake of Portucel’s equity.

In November 2006, the Portuguese State concluded the third and final stage of the sale of Portucel, S.A., and Párpublica, SGPS,

S.A. sold the remaining 25.72% it still held, thus increasing the free float.

In 2007 the Group invested in a new paper machine located at the Setúbal industrial site which started operating on a regular

basis in October 2009.

From 2009 to July 2015, more than 75% of the Company’s share capital was held directly and indirectly by Semapa – Sociedade

de Investimento e Gestão SGPS, S.A. (excluding treasury shares) having the percentage of voting rights been reduced to less than

70% following the conclusion of the offer for the acquisition, in the form of an exchange offer, of the ordinary shares of Semapa,

SGPS, S.A., in July 2015.

In February 2015, the Group started its activity in the Tissue segment with the acquisition of AMS-BR Star Paper, S.A. (currently

denominated Navigator Tissue Ródão, S.A.), a Company that holds and explores a production unit, located in Vila Velha de Ródão.

A new industrial facility was built in Aveiro, in August 2018, operated by Navigator Tissue Aveiro, S.A., and is currently the largest

Portuguese producer.

Also in 2015, the company sold the industrial assets used in the production of BEKP at the Setúbal Industrial Complex to its

indirect subsidiary Navigator Pulp Setúbal, S.A., thus ceasing to have any industrial activity, as it had already sold the industrial

assets used in the production to the current Navigator Paper Setúbal, S.A. in 2009.

On 6 February 2016, the PortucelSoporcel Group changed its corporate brand to The Navigator Company. This new corporate

identity represents the union of companies with a history of more than 60 years, aiming to give the Group a more appealing and

modern image.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 503

Following this event, and after approval in the General Shareholder’s Meeting, held on 19 April 2016, Portucel S.A. changed its

designation to The Navigator Company, S.A.

Also, in 2016, the Company carried out a capital increase in kind in Enerpulp - Cogeração Energética da Pasta, S.A., through the

delivery of the two biomass power generation plants located at the Setúbal and Aveiro industrial sites, and also carried out a

capital increase in kind in Navigator Parques Industriais, S.A. through the incorporation of the industrial land and buildings located

in Aveiro and Setúbal.

On 1 January 2017, the Company started to concentrate its sales of paper, cellulose pulp and Tissue products, becoming the

Group's product distributor. As a result, it quickly became one of the main national exporters, and certainly the one with the

highest added value for the national economy.

In October 2017, it started to centralise supplies to the Group, with the Group's pulp producers starting to sell pulp exclusively to

Navigator, which supplies the Group's paper producers, in addition to the sales to the market it had already been developing.

As from January 2018, it strengthened this new activity, centralising its foreign purchases and the supply of most of the raw

materials used in the production process.

Also, in 2017, Navigator started to prepare its separate financial statements in accordance with IFRS - International Financial

Reporting Standards.

Thus, from 2017 onwards, and with reinforcement in 2018, the Company focused its activities on selling paper and related

products, supplying industrial products, as well as providing administration and management services to its direct and indirect

subsidiaries, and on managing its shareholdings. In addition, the company transfers personnel to other Group companies.

On 31 March 2023 the acquisition of the Gomà-Camps Group's consumer Tissue business in Spain was concluded, with a view to

strengthening the Navigator Group's presence in this business segment. The integration of this new mill has elevated the Group to

the position of second largest Iberian tissue producer, with a production and converting capacity of 180 thousand tonnes.

In May 2024, the Navigator Group acquired all the shares representing the share capital of Accrol Group Holdings plc (“Accrol”), a

leader in the tissue paper converting segment in the United Kingdom, producing private label toilet rolls, kitchen rolls and facial

tissues for most of the main UK retailers, bringing total converting capacity to 311,000 tonnes.

The Navigator Group’s main business is the production and sale of writing and printing uncoated woodfree paper (UWF) and

domestic consumption paper (Tissue), as well as pulp, and it is present in the whole value-added chain, from research and

development of forestry and agricultural production, to the purchase of wood and the production and sale of bleached eucalyptus

kraft pulp – BEKP and electric and thermal energy, as well as its commercialisation.

A more detailed description of the activity in each business line of Navigator is disclosed in Note 2.1 - Revenue and

segment reporting.

Navigator is included in the consolidation perimeter of Semapa – Sociedade de Investimento e Gestão, SGPS, S.A., the Parent

Company, and Sodim - SGPS, S.A., the final controlling entity.

In turn, Filipa Mendes de Almeida de Queiroz Pereira, Mafalda Mendes de Almeida de Queiroz Pereira and Lua Mónica Mendes de

Almeida de Queiroz Pereira hold joint control of Sodim - SGPS, S.A. (Sodim) through the combination of a shareholders'

agreement. (Sodim) with their respective direct and indirect shareholdings in the share capital of this company, joint control of

Sodim, Semapa and Navigator is attributable to each of them and to Sodim, under the terms of Article 20 of the Portuguese

Securities Code, 83.221% of the non-suspended voting rights relating to shares representing the share capital of Semapa and also

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 504

to each of them, Sodim and Semapa, 70.03% of the non-suspended voting rights relating to shares representing the share capital

of Navigator.

1.2. Subsequent events

There were no events that resulted in additional adjustments or disclosures in the separate financial statements for the period

ended 31 December 2024.

1.3. Basis for preparation

1.3.1. Authorisation to issue financial statements

These separate financial statements were approved by the Board of Directors on 27 March 2025. However, they are still subject to

approval by the General Shareholders Meeting, in accordance with the Portuguese commercial legislation.

The Company’s senior management, which are the members of the Board of Directors who sign this report, declare that, to the

best of their knowledge, the information contained herein was prepared in compliance with the applicable accounting standards,

providing a true and fair view of the assets and liabilities, the financial position and results of the Company.

1.3.2. Accounting Standards

The separate financial statements for the period ended 31 December 2024 were prepared in accordance with the International

Financial Reporting Standards (IFRS), effective 1 January 2024 and as adopted by the European Union.

1.3.3. Presentation currency and transactions in a currency other than the presentation

currency

The items included in the Separate Financial Statements are measured using the currency of the economic environment in which

the entity operates (functional currency).

These financial statements are presented in Euro, which is the functional and reporting currency.

Transactions in currencies other than Euro are translated into the functional currency using the exchange rates at the date of the

transactions.

The currency differences arising from differences between the exchange rates ruling at the transaction date and those ruling on

collection, payment or at the separate statement of financial position date, are recorded as income and expenses in the period

(Note 5.10).

The amounts recorded in net profit/(loss) of subsidiaries were translated using the exchange rates prevailing at the dates of the

transactions. Where this is not possible, or where the cost of such a procedure exceeds the benefits to be derived therefrom, they

have been translated at the average exchange rate for the period.

The differences resulting from the application of these rates compared with the previous values were reflected as a separate

component of Equity, under Other reserves (Note 5.5).

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 505

Exchange rates used

31-12-2024

31-12-2023

Appreciation /

(Depreciation)

GBP (Sterling pound)

Average exchange rate for the period

0.8466

0.8698

2.67%

Closing exchange rate for the period

0.8292

0.8691

4.59%

USD

(American dollar)

Average exchange rate for the period

1.0824

1.0813

(0.10%)

Closing exchange rate for the period

1.0389

1.1050

5.98%

PLN (Polish zloti)

Average exchange rate for the period

4.3058

4.5420

5.20%

Closing exchange rate for the period

4.2750

4.3395

1.49%

SEK (Swedish krona)

Average exchange rate for the period

11.4325

11.4788

0.40%

Closing exchange rate for the period

11.4590

11.0960

(-3.27%)

CHF (Swiss franc)

Average exchange rate for the period

0.9526

0.9718

1.97%

Closing exchange rate for the period

0.9412

0.9260

(1.64%)

MZN (Mozambican metical)

Average exchange rate for the period

69.1732

69.1060

(0.10%)

Closing exchange rate for the period

66.7900

70.6500

5.46%

MAD (Moroccan dirham)

Average exchange rate for the period

10.7549

10.9552

1.83%

Closing exchange rate for the period

10.5190

10.9445

3.89%

NOK (Norway kroner)

Average exchange rate for the period

11.6290

11.4248

(1.79%)

Closing exchange rate for the period

11.7950

11.2405

(4.93%)

MXN (Mexican peso)

Average exchange rate for the period

19.8314

19.1830

(3.38%)

Closing exchange rate for the period

21.5504

18.7231

(15.10%)

AED (Dirham)

Average exchange rate for the period

3.9751

3.9710

(0.10%)

Closing exchange rate for the period

3.8154

4.0581

5.98%

ZAR (South African rand)

Average exchange rate for the period

19.8297

19.9551

0.63%

Closing exchange rate for the period

19.6188

20.3477

3.58%

BRL (Brazilian real)

Average exchange rate for the period

5.8283

5.4010

(7.91%)

Closing exchange rate for the period

6.4253

5.3618

(19.83%)

EGP (Egyptian pound)

Average exchange rate for the period

49.1213

33.1117

(48.35%)

Closing exchange rate for the period

53.0349

34.2710

(54.75%)

TRY (Turkish lira)

Average exchange rate for the period

35.5734

25.7597

(38.10%)

Closing exchange rate for the period

36.7372

32.6531

(12.51%)

1.3.4. Basis for measurement

The accompanying separate financial statements have been prepared on a going concern basis from Navigator's books and

accounting records and based on historical cost, except for financial instruments measured at fair value through net profit/(loss) or

at fair value through other comprehensive income (Note 8.3), in which derivative financial instruments are included (Note 8.2).

The liability related to responsibilities for defined benefits is recognised at its present value deducted from the respective asset.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 506

1.3.5. Comparability

These financial statements are comparable in all material respects with those of the previous year.

1.4. New IFRS standards adopted and to be adopted

1.4.1. Other standards, amendments and interpretations adopted or to be adopted

Standards, amendments and interpretations adopted in 2024

Amendment

Date of

application

Standards and amendments endorsed by the European Union

Clarification requirements for

classifying liabilities as current or

non

-current (amendments to IAS

– Presentation of Financial

Statements

IABS issued on 23 January 2020 narrow-scope amendments to IAS 1 Presentation of Financial

Statements to clarify how to classify debt and other liabilities as current or non-current.

1 January 2024

The amendments clarify an IAS 1 criteria for classifying a liability as non-

current: the requirement for

an entity to have the right to defer the liability’s settlement at least 12 months after the reporting

period.

The amendments aim to:

a) Specify that an entity’s right to defer settlement must exist at the end of the reporting period

must be substantive;

Clarify that the ratios that the company must fulfil after the balance sheet date (i.e. future ratios)

do not affect the classification of a liability on the balance sheet date. However, when non-

current

liabilities are subject to future ratios, companies must disclose information that allows users to

understand the risk

Lease liabilities in sale and

leaseback transactions

(amendments to IFRS 16

Leases)

The IASB issued amendments to IFRS 16 - Leases in September 2022 that introduce a new

accounting model for variable payments in a sale and leaseback transaction.

The amendments confirm that:

a) on initial recognition, the seller-lessee includes variable lease payments in measuring a lease

liability arising from a sale and leaseback transaction;

b) after initial recognition, the seller-lessee applies the general requirements for subsequent

accounting for the lease liability so that it does not recognise any gain or loss relating to the right

of use it retains.

A seller-lessee may use different approaches to comply with the new requirements for subsequent

measurement.

In accordance with IAS 8 - Accounting Policies, Changes in Accounting Estimates and Errors, a seller-

lessee shall apply the amendments retrospectively to sale and leaseback transactions entered into

since the date of initial application of IFRS 16. This means that it will have to identify and reassess

sale and leaseback transactions entered into since the implementation of IFRS 16 in 2019, and

potentially restate those that include variable lease payments.

The amendment had no significant impact on the Company.

1 January 2024

Amendments to IAS 7 Statement

of Cash Flows and IFRS 7

Financial Instruments:

Disclosures

- Supplier Finance

Arrangements

On 25 May 2023, the International Accounting Standards Board (IASB) published Supplier Finance

Arrangements with amendments to IAS 7 - Statement of Cash Flows and IFRS 7 - Financial

Instruments Disclosures.

The amendments refer to the disclosure requirements relating to supplier finance arrangements—

also

known as supply chain financing, accounts payable financing or reverse-factoring arrangements.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 507

The new requirements supplement those already included in the IFRS standards and include

disclosures on:

a) terms and conditions of supplier finance agreements;

b) The amounts of the liabilities which are the subject of such arrangements, for which part of them

the suppliers have already received payments from the providers of funds and under which caption

these liabilities are presented in the balance sheet;

c) maturity date intervals; and

d) Information on liquidity risk.

The amendment had no significant impact on the Company.

1 January 2024

Standards, amendments and interpretations to be adopted in subsequent periods

Amendment

Date of

application

Standards and amendments endorsed by the European Union which the Group has chosen not to apply early

On 15 August 2023, the International Accounting Standards Board (IASB) issued Lack of

Exchangeability (Amendments to IAS 21 - The Effects of Changes in Foreign Exchange Rates) (the

amendments).

The amendments clarify how an entity should assess whether a currency is exchangeable or not and

how it should determine a spot exchange rate in situations of lack of exchangeability.

Amendments to IAS 21 - The

Effects of Changes in Foreign

Exchange Rates: Lack of

Exchangeability

A currency is exchangeable for another currency when an entity is able to exchange that currency for

another currency on the measurement date and for a specific purpose. When a currency is not

exchangeable, the entity has to estimate a spot exchange rate.

1 January 2025

According to the amendments, entities will have to provide new disclosures to help users assess the

impact of using an estimated exchange rate on financial statements. These disclosures could include:

the nature and financial impacts of the currency not being exchangeable;

the spot exchange rate used;

the estimation process; and

the risks to the company because the currency is not exchangeable.

This amendment is effective for periods starting after 1 January 2025. Earlier application is permitted.

Amendment

Date of

application

Standards and amendments not endorsed by the European Union

On 9 April 2024, the International Accounting Standards Board (IASB or Board) issued the new

standard, IFRS 18 Presentation and Disclosure in Financial Statements.

IFRS 18 Presentation and

Disclosure in Financial

Statements

The main amendments introduced by this Standard are:

promotion of a more structured income statement. In particular, it introduces a new subtotal

‘operating profit’ (as well as its definition) and the requirement that all income and expenses be

classified into three new separate categories based on a company's main business activities:

Operating, Investing and Financing.

requirement for companies to analyse their operating expenses directly on the face of the income

statement - either by nature, by function or in a mixed way.

requirement for some of the ‘non-GAAP’ measures that the Group uses to be reported in the

financial statements. The standard defines non-GAAP performance measures (MPMs) as a subtotal of

income and expenses that:

are used in public communications outside the financial statements; and

communicate management's view of financial performance.

For each MPM presented, companies will need to explain in a single note in the financial statements

why the measure provides useful information, how it is calculated, and reconcile it with a value

1 January 2027

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 508

determined in accordance with IFRS.

d) introduction of improved guidance on how companies group information in financial statements. It

includes guidance on whether material information is included in the primary financial statements or

is more detailed in the notes.

The amendments are effective for periods beginning on or after 1 January 2027 and apply

retrospectively. Earlier application is permitted.

On 9 May 2024, the International Accounting Standards Board (IASB) issued the new Standard, IFRS

19 Subsidiaries without Public Accountability: Disclosures, which allows eligible subsidiaries to use

IFRS with reduced disclosures. The application of IFRS 19 will reduce the costs of preparing the

financial statements of subsidiaries, while maintaining the usefulness of the information for the users

of their financial statements.

IFRS 19 Subsidiaries without

Public Accountability

A subsidiary may opt to apply the new Standard in its consolidated, individual or separate financial

statements, provided that, at the reporting date:

it has no public accountability;

its parent company prepares consolidated financial statements in accordance with IFRS.

1 January 2027

A subsidiary that applies IFRS 19 is required to state clearly in its explicit and unconditional

statement of compliance with IFRS that IFRS 19 has been adopted.

The amendments are effective for periods beginning on or after 1 January 2027 and apply

retrospectively. Earlier application is permitted.

On 30 May 2024, the International Accounting Standards Board (IASB or Board) issued amendments

regarding the classification and measurement requirements of IFRS 9 - Financial Instruments. The

amendments aim to resolve the diversity in the application of the standard, making the requirements

more understandable and consistent.

IFRS 9 - Amendments

Regarding the Classification and

Measurement of Financial

Instruments

The purpose of these amendments is to:

clarify the classification of financial assets with environmental, social and corporate governance

(ESG) characteristics and similar, since these characteristics in loans can affect whether loans are

measured at amortised cost or fair value. To resolve any potential diversity in practical application,

the amendments clarify how the contractual cash flows of loans should be valued.

clarify the date on which a financial asset or financial liability is derecognised when it is settled

through electronic payment systems. There is an accounting policy option that allows a financial

liability to be derecognised before the cash is delivered on the settlement date, if certain criteria

are met.

improve the description of the term ‘non-recourse’, according to the amendments, a financial

asset has non-recourse characteristics if the ultimate right to receive cash flows from an entity is

contractually limited to the cash flows generated by specific assets. The presence of non-recourse

features does not necessarily exclude the financial asset from complying with the SPPI, but its

characteristics need to be carefully analysed.

clarify that a contractually linked instrument must have a cascading payment structure that

creates a concentration of credit risk by allocating losses disproportionately between different

instalments. The underlying pool can include financial instruments that are not within the scope of

the classification and measurement of IFRS 9 (e.g. finance leases) but must have cash flows

equivalent to the SPPI criterion.

1 January 2026

The IASB has also introduced additional disclosure requirements relating to equity investments

designated at fair value through other comprehensive income and financial instruments with

contingent features, for example features linked to ESG targets.

The amendments are effective for periods beginning on or after 1 January 2026. Earlier application is

permitted.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 509

Amendment

Date of

application

Standards and amendments not endorsed by the European Union

On 18 July 2024, the International Accounting Standards Board (IASB) issued limited amendments to

the IFRS and respective guidelines, resulting from the

regular maintenance carried out on the

Standards.

The amendments include clarifications, simplifications, corrections, and modifications made with the

aim of improving the consistency of various IFRS.

Annual improvements (IFRS1,

IFRS7, IFRS9, IFRS10 and

IAS7)

The IASB amended:

IFRS 1 First-time Adoption of International Financial Reporting Standards, to clarify certain aspects

related to the application of hedge accounting by an entity that is preparing financial statements in

accordance with IFRS for the first time;

IFRS 7 Financial Instruments: Disclosures and the respective Implementation Guidance, in order to

clarify:

the application guidance, regarding Gain and loss on derecognition; and

the implementation guidance, namely its Introduction, Fair value paragraph (disclosures regarding

the difference between fair value and transaction price) and Credit risk disclosure.

c) IFRS 9 Financial Instruments to:

require companies to initially measure a receivable without a significant financing component at the

amount determined by applying IFRS 15, and

clarify that when a lease liability is derecognised, the derecognition is accounted for under IFRS 9.

However, when a lease liability is modified, the modification is accounted for under IFRS 16 Leases.

The amendment establishes that when lease liabilities are derecognised under IFRS 9, the difference

between the carrying amount and the consideration paid is recognised in net profit/(loss).

IFRS 10 Consolidated Financial Statements, clarification on the determination of a “de facto agent”;

and

IAS 7 Cash Flow Statements, amendment of detail in the paragraph relating to Investments in

subsidiaries, associates and joint ventures.

1 January 2026

The amendments are effective for periods beginning on or after 1 January 2026. Earlier application is

permitted.

On 18 December 2024, the International Accounting Standards Board (IASB) issued limited

amendments to the IFRS and respective guidelines, resulting from the regular maintenance carried

out on the Standards.

Amendments to IFRS 9 and

IFRS 7 - Nature-dependent

electricity contracts

Nature-dependent electricity contracts help companies to secure their electricity supply from sources

such as wind and solar power. The amount of electricity generated under these contracts can vary

based on uncontrollable factors such as weather conditions. Current accounting requirements may not

adequately capture how these contracts affect a company’s performance.

To allow companies to better reflect these contracts in the financial statements, the IASB has made

targeted amendments to IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures.

The amendments include:

clarifying the application of the ‘own-use’ requirements;

permitting hedge accounting if these contracts are used as hedging instruments; and

adding new disclosure requirements to enable investors to understand the effect of these contracts

on a company’s financial performance and cash flows.

1 January 2026

The amendments are effective for periods beginning on or after 1 January 2026. Earlier application is

permitted.

With respect to the above standards, which are not yet mandatory, the Company has not yet completed the calculation of all

impacts arising from their application and has therefore elected to apply them early, although these impacts are not expected to

be material.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 510

1.5. Significant accounting estimates and judgements

The preparation of separate financial statements requires management to make judgements and estimates that affect the amount

of revenue, costs, assets, liabilities, and disclosures at the date of the statement of financial position. To that effect, the

management's estimates and judgements are based on:

(i) the best information and knowledge of current events and in certain cases on the reports of independent experts; and

(ii) the actions that the Company considers it may have to take in the future.

On the date on which the operations take place, the outcome could differ from those estimates.

Significant estimates and judgements

The estimates and assumptions which present a significant risk of generating a material adjustment to the book value of assets

and liabilities in the following financial period are presented below:

Estimates and judgements Notes

Uncertainty over Income Tax Treatments

6.1

- Income tax for the period

6.2

- Deferred taxes

Valuation of financial investments 10.1 – Investments in subsidiaries

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 511

2. Operational performance

2.1. Revenue and segment reporting

Accounting policies

Within the Navigator Group, the Company operates as a trader of the Group's products and supplier of most of the

Group's raw materials.

In preparing the separate financial statements, the accounting policies used by the Company in the areas of revenue and segment

reporting are consistent with the policies applied in the consolidated financial statements, as described below.

Navigator Group business areas

The Navigator Group’s main business is the production and sale of writing and printing uncoated woodfree paper (UWF) and

domestic consumption paper (tissue) as well as pulp, and it is present in the whole value-added chain, from research and

development of forestry and agricultural production to the purchase and sale of wood and the production of eucalyptus pulp and

the production of electric and thermal energy, as well as its commercialisation. In the last quarter of 2024, the group also started

producing moulded fibre packaging at the Aveiro industrial complex.

The Navigator Group currently has ten industrial sites - four in Portugal, one in Spain and five in the United Kingdom. Of the

industrial complexes in Portugal, two are dedicated to the production of BEKP pulp, electricity and UWF paper (Figueira da Foz and

Setúbal), one is dedicated to the production of BEKP pulp, energy, moulded cellulose packaging and tissue paper (Aveiro) and a

fourth, in Vila Velha de Ródão, produces tissue. In Spain, the Group owns an industrial complex in Zaragoza where it produces

tissue paper. In May 2024, with the acquisition of the Navigator Tissue UK Group (formerly the Accrol Group), the Navigator Group

now has five production sites in the UK related to the tissue business: Blackburn (rolls and facials); Leicester (rolls); Leyland

(rolls); Flint (wet wipes) and Bridgewater (wet wipes).

Wood is produced from woodlands from subsidiaries or leased in Portugal and Spain, and also form granted lands in Mozambique.

The production of cork and pine wood are sold to third parties while the eucalyptus wood is mainly consumed in the production of

pulp.

A significant portion of the Group’s own BEKP production is consumed in the production of UWF and tissue paper. Sales of BEKP

pulp, UWF paper and tissue paper – to 118 (2023: 134) countries and territories around the world.

With regard to energy production, the Group has three cogeneration plants, integrated in the production of pulp. Heat production

is used for internal consumption while electricity is sold to the national energy grid. The Group also owns two cogeneration plants

fuelled by natural gas and two independent plants fuelled by biomass, integrated into paper production in Figueira da Foz and

Setúbal, the majority of whose output is sold to the national energy grid.

In addition, the Group currently has nine photovoltaic plants in operation for self-consumption: two in Setúbal, one at Herdade de

Espirra, two at the Figueira da Foz industrial complex, one at the Zaragoza industrial complex, one at Raiz (in Aveiro) and also two

plants that will come into operation in 2024, at the Aveiro and Vila Velha industrial complexes.

Segment reporting

In accordance with IFRS 8, the Company considers an operating segment as a component of the group that develops business

activities from which it can obtain revenue and incur expenses, whose operating net profit/(loss) are regularly reviewed by the

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 512

Executive Committee, which is primarily responsible for the operational decision-making for allocation of resources to the segment

and the assessment of its performance and for which separate financial information is available.

The information used in segment reporting corresponds to the financial information prepared by the Company.

Although the Group has defined a series of segments, Navigator is only responsible for the marketing of the products produced by

its subsidiaries and for the management of those subsidiaries. Therefore, it is considered that all the Company's activities fall into

one single segment and so no further breakdown is required.

Revenue

Revenue is presented by goods and services sold and by geographical area, based on the country of destination of the goods and

services sold by the Company.

Commercial contracts with Customers refer essentially to the sale of goods such as tissue paper and pulp, and to an extent, to the

transportation inherent to those goods, when applicable.

Revenue recognition by group of materials is described as follows:

Pulp

Pulp revenue results from sales made to the Company's subsidiaries and international producers of paper and decoration. Revenue

is recognised at a specific time, by the amount of the performance obligation satisfied, the price of the transaction corresponding to

a fixed amount invoiced on the basis of quantities sold, less cash discounts and quantity discounts, which are reliably determinable.

On the export side, the transfer of control of the products generally occurs when the products are transferred to the control of the

customer, in accordance with the negotiated Incoterms. The Company is solely responsible for selling BEKP pulp produced by

Navigator Group companies, intended for sale to the market and to the Group's UWF paper and tissue producers.

UWF

Paper revenue refers to sales made through Commercial Distributors (B2B), which include large distributors, wholesalers or

commercial operators, as well as producers and processors of paper products. Revenue is recognised at a specific time, on the date

of delivery of the product to the customer when the transfer of control occurs, by the amount of the performance obligation

satisfied, and the price of the transaction corresponds to a fixed amount invoiced according to the quantities sold, less cash

discounts and quantity discounts, which are reliably determinable.

Tissue

Tissue revenue results from sales of tissue paper produced for the private label of national and international retail chains. Revenue

is recognised at a specific moment, by the amount of the performance obligation satisfied, and the price of the transaction

corresponds to a fixed amount invoiced according to quantities sold, less cash discounts and quantity discounts, which are reliably

determined. Revenue is recognised against the delivery of the product, at which time the transfer of control over the product is

deemed to take place.

Central

purchasing

operations

The revenue from goods purchased from producers and distributors to supply the Group's mills that use them as raw materials for

processing is recognised on the date of delivery of the product to the customer, for the amount of the performance obligation

satisfied, where the transaction price corresponds to a fixed amount invoiced based on the quantities sold that can be reliably

determined.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 513

Detail of revenue by materials/services groups and geographical areas

During the periods ended 31 December 2024 and 2023, the revenue from sales of goods and rendering of services is detailed as

follows:

Amounts in Euro

2024

2023

Sales

UWF Paper

Portugal

66,040,792

68,015,492

Rest of Europe

734,930,491

858,105,848

United States of America

67,177,021

35,416,136

Rest of World

385,196,738

260,278,799

1,253,345,041

1,221,816,275

Tissue Paper

Portugal

102,874,540

105,623,826

Rest of Europe

171,013,243

115,323,793

Rest of World

3,271,959

5,937,111

277,159,743

226,884,730

Market pulp

Portugal

11,395,309

3,312,700

Rest of Europe

139,047,737

90,461,707

Rest of World

87,286,968

155,707,960

237,730,015

249,482,367

Pulp supplied to subsidiaries

Portugal

640,288,946

545,441,729

Rest of Europe

20,011,226

12,365,173

660,300,173

557,806,902

Sales of goods - subsidiaries

292,069,555

310,890,035

Total sales

2,720,604,526

2,566,880,309

Services rendered

Management and administrative services of subsidiaries

114,048,554

92,825,518

Total services rendered

114,048,554

92,825,518

Total revenue

2,834,653,080

2,659,705,827

In 2024, the Company had a turnover of Euro 2,834,653,080, with sales of UWF paper accounting for around 44% of turnover

(2023: 46%), pulp sales 32% (2023: 30%), tissue paper sales 10% (2023: 9%) and sales of raw materials to supply the Group's

mills 10% (2023: 12%).

Sales of market pulp fell as a result of greater integration by the Group's paper mills. It should also be noted that in 2024 there

was a gradual increase in supply as a result of the 2023 projects in Chile and Uruguay, as well as the new production capacity that

started up in 2024 in Latin America and China, which put negative pressure on price levels.

As a result of the acceleration in order intake until May and again at the end of the year, the printing and packaging paper

segment recorded a 9% increase in sales. Demand for uncoated printing and writing paper (UWF) has been practically stagnant in

recent years, unlike other grades where demand has been falling since 2020.

The tissue paper segment maintained a positive performance, with positive effects from the growth in demand in Western Europe

since the start of the year and the recovery in household purchasing power.

Services rendered to subsidiaries essentially include corporate services related to the strategic orientation of holdings and an

intermediation fee for managing the wood supply of the Group's pulp producers.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 514

2.2. Other operating income

For the periods ended 31 December 2024 and 31 December 2023, Other operating income is detailed as follows:

Amounts in Euro

2024

2023

Supplementary gains

129,263

14,400

Gains on disposal of non-current assets

341

178,601

Impairment reversal on receivables

1,378,213

1,934,771

Impairment reversal on inventories (Note 4.1.3)

345,491

133,717

Discounts received on purchases

454,475

237,959

Compensations

428,875

1,359,235

Other operating income

1,301,356

1,257,014

4,038,014

5,115,697

2.3. Other operating expenses

Amounts in Euro

2024

2023

Cost of goods sold and materials consumed (Note 4.1.2)

2,476,330,691

2,339,940,354

External services and supplies

Transportation of goods

119,745,253

112,666,024

Specialised services

81,710,937

76,347,831

Royalties

23,553,592

22,826,264

Fees

1,247,887

1,251,496

Insurance

2,467,128

2,300,454

Rentals

1,221,239

1,972,532

Fees

1,223,860

1,861,555

Travel and accommodation

895,354

1,174,127

Advertising and marketing

643,642

394,109

Representation costs

425,973

312,297

Other

494,251

527,951

233,629,116

221,634,640

Payroll costs (Note 7.1)

5,593,834

7,186,383

Other operating expenses

Impairment losses on inventories (Note 4.1.3)

5,072

465,150

Impairment losses on receivables

173,733

Other inventory losses (Note 4.1.2)

1,935,119

979,581

Donations

32,936

95,985

Membership fees

319,622

352,990

Indirect taxes

51,052

177,825

Other operating expenses

141,836

328,939

2,659,370

2,400,470

Net provisions (Note 9.1)

23,630

(1,789,744)

Total operating expenses

2,718,213,011

2,571,161,847

In 2024, there was an increase in the costs borne by the company, in line with the increase in quantities sold, and this increase

was visible above all in logistics costs and specialised services.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 515

The Specialised services caption includes costs for marketing and sales agency services of Euro 21,428,790 euros (2023: Euro

19,914,058 euros) and costs for general administrative services of Euro 35,122,299 (2023: Euro 32,994,638) invoiced by

Navigator Pulp Figueira, S.A..

Audit fees

2024

2023

Amounts in Euro

Expenses

in the period

Fees invoiced

Expenses

in the period

Fees invoiced

KPMG (SROC) and other entities belonging to the same network

Audit

fees

464,611

252,500

195,000

169,000

Other assurance services

97,000

116,500

13,260

34,010

Other services

331,778

475

893,390

700,778

208,735

203,485

The services indicated as "Other assurance services" relate to the reporting of financial information and Sustainability Information

verification services. With regard to services other than auditing, these refer to the provision of financial information auditing

services to a number of companies in a Group within the scope of the acquisition by the Navigator Group, as well as agreed

procedures on financial information.

The Board of Directors believes there are adequate procedures safeguarding the independence of auditors, through the

Supervisory Board process analysis of the work proposed and careful definition of the work to be performed by the auditors.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 516

3. Investments

3.1. Property, plant and equipment

Movements in property, plant and equipment

Amounts in Euro

Land

Buildings and

other

constructions

Basic

equipment

Transportation

equipment

Administrative

equipment

Other

property,

plant and

equipment

Assets

under

construction

Total

Gross amount

Balance as at 1 January 2023

12,872 693,726 1,392,678 4,056,768 4,467,177

10,546,631 -

21,169,852

Acquisitions

117,300

Disposals

(5,415) -

- - -

(5,415)

Adjustments, transfers and write

-offs - -

(18,179) (392,191) (342,055)

(81,293)

(833,718)

Balance as at 31 December 2023

7,457

693,726

1,374,499

3,664,577

4,125,122

10,582,638

20,448,019

Acquisitions

323,689

Balance as at 31 December 2024

7,457 693,726 1,374,499 3,664,577 4,125,122

10,582,638 323,689

20,771,708

Accumulated depreciation and

impairment losses

Balance as at 1 January 2023

- (77,563) (1,380,734) (3,942,181) (4,402,684)

(10,511,665) -

(20,314,830)

Depreciation for the period (Note 3.3)

- (14,791)

(9,267) (13,014) (9,588)

(7,525)

(54,185)

Disposals

- -

- - -

Adjustments,

transfers and write-offs - -

16,180 392,166 336,147

85,735

830,228

Balance as at 31 December 2023

- (92,354) (1,373,821) (3,563,029) (4,076,125)

(10,433,455) -

(19,538,787)

Depreciation for the period (Note 3.3)

- (14,791)

(387) (13,011) (7,778)

(43,366)

(79,333)

Balance as at 31 December 2024

- (107,145) (1,374,208) (3,576,040) (4,083,903)

(10,476,821) -

(19,618,120)

Net book value as at 1 January 2023

12,872 616,163 11,944 114,587 64,493

34,966 -

855,022

Net book value as at 31

December 2023 7,457 601,372 678 101,548 48,997

149,183 -

909,232

Net book value as at 31 December 2024

7,457 586,581 291 88,537 41,219

105,817 323,689

1,153,588

Accounting policies

Recognition and initial measurement

Property, plant and equipment acquired up to 1 January 2004 (transition date to IFRS) are recorded at acquisition cost, or

revalued acquisition cost in accordance with generally accepted accounting principles in Portugal until that date, net of

amortisation and accumulated impairment losses.

Property, plant and equipment acquired after the transition date are shown at cost, less accumulated depreciation and impairment

losses.

Depreciation and impairment

We use the straight-line method from the moment the asset is available for use and using the rates that best reflect their

estimated useful life.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 517

Average useful life

2024

2023

Buildings and other constructions

20 – 50

Basic equipment

7 – 35

Transportation equipment

4 – 9

Administrative equipment

4 – 8

Other property, plant and equipment

3 – 21

The residual values of the assets and respective useful lives are reviewed and adjusted, on the date of the Separate statement of

financial position. When the carrying amount of the asset exceeds its realisable value, the asset is written down to the estimated

recoverable amount, and an impairment charge is booked.

Subsequent costs

Scheduled maintenance expenses are considered a component of the acquisition cost of property, plant and equipment and are

fully depreciated by the next forecasted maintenance date.

All other repairs and maintenance costs are charged to the income statement in the financial period in which they are incurred.

Write-offs and disposals

Gains or losses arising from write-offs or disposals are determined by the difference between the proceeds from the disposals

when applicable less transaction costs and the carrying amount of the asset and are recognised in the income statement as Other

operating income (Note 2.2) or Other operating expenses (Note 2.3).

3.2. Right-of-use assets

Movements in right-of-use assets

Amounts in Euro

Buildings

Vehicles

Total

Gross amount

Balance as at 1 January 2023

4,277,508

54,896

4,332,404

Acquisitions

Adjustments, transfers and write-offs

53,743

(35,612)

18,131

Balance as at 31 December 2023

4,331,251

19,284

4,350,535

Acquisitions

Adjustments, transfers and write-offs

117,680

(3,092)

114,588

Balance as at 31 December 2024

4,448,931

16,192

4,465,123

Accumulated depreciation and impairment losses

Balance as at 1 January 2023

(2,024,884)

(51,396)

(2,076,280)

Depreciation (Note 3.3)

(518,682)

(8,610)

(527,292)

Adjustments, transfers and write-offs

40,722

Balance as at 31 December 2023

(2,543,565)

(19,284)

(2,562,850)

Depreciation (Note 3.3)

(546,107)

(2,018)

(548,125)

Adjustments, transfers and write-offs

5,110

Balance as at 31 December 2024

(3,089,672)

(16,192)

(3,105,865)

Net book value as at 1 January 2023

2,252,624

3,500

2,256,124

Net book value as at 31 December 2023

1,787,686

1,787,685

Net book value as at 31 December 2024

1,359,259

1,359,258

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 518

The caption Buildings refers to the lease agreement entered into between The Navigator Company, S.A. e a MaxiRent - Fundo de

Investimento Imobiliário Fechado for the building located at Avenida Fontes Pereira de Melo 27, in Lisbon, for use as an office until

May 2027.

Accounting policies

At the date the lease enters into force, the Company recognises right-of-use assets at its cost, which corresponds to

the initial amount of the lease liability adjusted for: i) any prepayments; ii) lease incentives received; and iii) initial

direct costs incurred.

To the right-of-use asset, the estimate of removing and/or restoring the underlying asset and/or the location where it is located

may be added, when required by the lease agreement.

The right-of-use asset is subsequently depreciated using the straight-line method, from the start date until the lower between the

end of the asset's useful life and the lease term. Additionally, the right-of-use asset reduced of impairment losses, if any, and

adjusted for any remeasurement of the lease liability. The useful life considered for each class of right-of-use asset is equal to the

useful life of Property, plant and equipment (Note 3.1) in the same class when there is a call option and the Company expects to

exercise it.

Short-term leases and low-value asset leases

The Company recognises payments for leases of 12 months or less and for leases of assets whose individual acquisition value is

less than USD 5,000 directly as operating expenses of the period (Note 2.3), on a straight-line basis.

3.3. Depreciation, amortisation and impairment losses

Amounts in Euro

2024

2023

Depreciation of property, plant and equipment for the period (Note 3.1)

79,333

54,185

Use of government grants

(841)

(988)

Depreciation of property, plant and equipment, net of grants charged-off

78,492

53,197

Depreciation of right-of-use assets for the period (Note 3.2) 548,125 527,292

626,617

580,489

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 519

4. Working capital

4.1. Inventories

4.1.1. Inventories - detail by nature

Amounts net of accumulated impairment losses

31-12-2024

31-12-2023

Amounts in Euro

Gross

amount

Impairment

Net

amount

Gross

amount

Impairment

Net amount

BEKP pulp 4,767,828

(17,571)

4,750,257 10,621,680

(136,092)

10,485,588

UWF Paper 17,949,366

(759,316)

17,190,050 16,002,438

(963,739)

15,038,699

Tissue Paper 453,063

(2,420)

450,643 2,586,851

(24,967)

2,561,884

Goods supplied to the Group's mills

5,038,724

(146,133)

4,892,591

4,170,909

(141,061)

4,029,848

Total

28,208,981

(925,440)

27,283,541

33,381,878

(1,265,859)

32,116,019

Inventories – distribution by geographical area

Amounts in Euro

31-12-2024

31-12-2023

Portugal

BEKP pulp -

0.00% 7,463,479 22.36%

UWF Paper 8,379,808

29.71% 8,220,029 24.62%

Tissue Paper 450,643

1.60% 437,634 1.31%

Goods used for Group supply 5,038,724

17.86% 4,170,909 12.49%

13,869,175

49.17%

20,292,051

60.79%

Rest of Europe

BEKP pulp

4,767,828

16.90% 3,158,201 9.46%

UWF Paper

9,569,558

33.92%

7,782,409

23.31%

Tissue Paper

2,420

0.01%

2,149,217

6.44%

14,339,806

50.83% 13,089,827 39.21%

28,208,981

100.00% 33,381,878 100.00%

The Company's inventories include Euro 8,830,451 (2023: Euro 14,673,749) relating to UWF paper, tissue paper and pulp for

which invoices have already been issued but whose control has not been transferred to Trade receivables.

As at 31 December 2024 and 31 December 2023, there are no inventories in which ownership is restricted and/or pledged as

collateral for liabilities.

4.1.2. Cost of goods sold and materials consumed in the period

Amounts in Euro

2024

2023

Opening balance 32,116,019

25,927,585

Purchases 2,473,092,913

2,347,439,802

Gains / (losses) on inventories (Note 2.3) (1,935,119)

(979,581)

Gains / (losses) by impairment (Notes 2.2 and 2.3) 340,419

(331,433)

Closing balance (27,283,541)

(32,116,019)

Cost of goods sold and materials consumed (Note 2.3) 2,476,330,691

2,339,940,354

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 520

Costs of goods and materials consumed by type

Amounts in Euro

2024

2023

BEKP Pulp - sales to market 224,763,542 255,196,325

BEKP Pulp - included in the Group 658,246,874 559,539,342

UWF Paper 1,011,660,977 979,105,940

Tissue Paper 289,304,756 238,255,673

Goods supplied to the Group's mills 292,354,542 307,843,074

2,476,330,691 2,339,940,354

4.1.3. Movements in impairment losses in inventories

Amounts in Euro

2024

2023

Opening balance

(1,265,859)

(934,426)

Increases (Note 2.3)

(5,072)

(465,150)

Reversals (Note 2.2)

345,491

133,717

Impact in net profit/(loss) for the period 340,419

(331,433)

Charge-off

Closing balance

(925,440)

(1,265,859)

The impairment losses in inventories recorded in 2024 and 2023 relate to adjustments in the stock of UWF paper.

Accounting policies

Goods

The goods held by Navigator correspond essentially to eucalyptus pulp, UWF paper and tissue paper acquired from its subsidiaries,

for sale to the market. It also includes materials acquired from third parties to supply subsidiaries as part of the Navigator Group's

central purchasing functions.

The Company acts as the Navigator Group's central purchasing body, and most of the Group's purchases of raw materials are

made centrally by the Company, which then supplies the manufacturing companies, except for wood supply.

Goods and raw, subsidiary and consumable materials are valued at the lower of their purchase cost or their net realisable value.

The purchase cost includes ancillary costs, and it is determined using the weighted average cost as the valuation method.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 521

4.2. Receivables

31-12-2024

31-12-2023

Amounts in Euro

Non-

current

Current

Total

Non-current

Current

Total

Trade receivables

216,728,199

203,679,470

Receivables

- Related companies (Note 10.2)

681,801,808

490,767,984

State

47,422,025

38,961,563

Tax consolidation

- related parties (Note 10.2)

59,762,374

59,649,931

Accrued income

4,485,516

547,437

Deferred expenses

30,209

Derivative

financial instruments (Note 8.2)

21,022,302

19,458,938

Advances to suppliers

2,603,887

3,276,567

Other receivables

6,684

268,802

275,486

27,956

149,483

177,439

6,684

1,034,094,913

1,034,101,597

27,956

816,521,582

816,549,538

The amounts above are net of accumulated impairment losses. Analysis of impairment for receivables is presented in

Note 8.1.4 - Credit risk.

The increase in this caption is mainly due to balances with related parties, namely Navigator United Kingdom, ltd. On 24 May

2024, this company acquired the entire share capital of Accrol Group Holdings Plc, a company based in Blackburn, England, which

has 9 subsidiaries, 3 of which are operating.

Other - non-current

The amount recorded as non-current in 2024 is related to a VAT guarantee in connection with the Company's VAT registration in

Switzerland, amounting to Euro 6,684. In 2023 the balance also included financial incentives to be received, namely under the RPP

(Recovery and Resilience Plan).

State

Amounts in Euro

31-12-2024

31-12-2023

Value added tax - recoverable

7,146,118

Value Added Tax - repayment requests

40,275,907

38,961,563

47,422,025

38,961,563

Up to the issuing of this report, Euro 40,275,907 in repayments requested on 31 December 2024 had been received. The amounts

requested as at 31 December 2023, Euro 38,961,563 were received during the first half of 2024.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 522

Accounting policies

Classification

Trade receivables and other debtors

Trade receivables balances result from the Company's main activities and the business model followed is the collection of

contractual cash flows.

Balances from other debtors generally assume the business model of collecting contractual cash flows.

Initial measurement

At fair value.

Subsequent measurement

At amortised cost, net of impairment losses.

Impairment from Trade receivables

Impairment losses are recorded based on the simplified model provided for in IFRS 9, recording expected losses until maturity.

The expected losses are determined on the basis of the experience of historical actual losses over a statistically significant period

and representative of the specific characteristics of the underlying credit risk (Note 8.1.4).

Impairment from other debtors

Impairment losses are recorded on the basis of the general estimated credit loss model of IFRS 9.

4.3. Payables

Amounts in Euro

31-12-2024

31-12-2023

Trade payables

76,061,929

64,536,033

Payables - related companies (Note 10.2)

533,952,927

545,994,019

State

2,160,781

2,227,427

Advances from customers

8,898,449 6,473,115

Profit attributable to shareholders

99,999,451

Other payables

10,966,313

239,850

Derivative financial instruments (Note 8.2)

6,311,499

5,691,817

Payroll costs accruals

7,106,789

9,165,030

Accrued expenses - interest payable

4,733,532

4,192,903

Accrued expenses - logistics and sales commissions

14,844,173 11,665,248

Accrued expenses - related companies (Note 10.2)

22,755,799

25,094,238

Other accrued expenses

1,818,743

2,325,765

Deferred income - operating grants

61,450

789,671,835

677,666,895

The increase in this caption is mainly the result of the decision by the Company's Board of Directors on 19 December 2024 to pay

an early dividend of Euro 99,999,451 (Note 5.4), payable on 9 January 2025.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 523

State

Amounts in Euro

31-12-2024

31-12-2023

Personal income tax withhold (IRS)

485,334

349,695

Value added tax

1,227,802

1,456,503

Social Security contributions

447,645

421,229

2,160,781

2,227,427

As at 31 December 2024 and 2023, there were no arrears with the State.

Other payables

As at 31 December 2024, this caption essentially includes the amount of Euro 10,801,575 to be paid to the IFC - International

Finance Corporation, in accordance with the contract described in Note 5.5.

Accounting policies

Trade payables and other current liabilities are initially recorded at their fair value and subsequently measured at

amortised cost.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 524

5. Capital structure

5.1. Capital management

Capital management policy

For capital management purposes, the Company defines capital as including equity and net debt. The Company's

objectives in relation to capital management are:

i. To safeguard the Company's ability to continue as a going concern and thus provide returns for Shareholders and

benefits for its remaining Stakeholders;

ii. To keep a solid capital structure to support the growth of its business; and

iii. To maintain an optimal capital structure that enables it to reduce the cost of capital.

In order to maintain or adjust its capital structure, the Company can adjust the amount of dividends payable to its

Shareholders, return capital to its Shareholders, issue new shares or sell assets to lower its borrowings.

In line with the sector, the Company monitors its capital based on the gearing ratio, defined as the proportion between

net debt and total capital.

Net interest-bearing debt is calculated by adding the total amount of loans (including the current and non-current portions

as disclosed in the statement of financial position) and deducting all cash and cash equivalents. Total equity is calculated

by adding Shareholders’ equity (as shown in the statement of financial position), to interest-bearing net debt, and

excluding treasury shares and non-controlling interests.

The Company calculates the gearing ratio as follows:

Amounts in Euro

31-12-2024

31-12-2023

Interest-bearing liabilities (Note 5.6)

1,073,032,204

897,030,355

Cash and cash equivalents (Note 5.8) (406,735,567)

(310,150,771)

Net debt

666,296,637

586,879,584

Equity

1,355,728,835

1,315,245,815

Treasury shares

Shareholders' equity, excluding treasury shares

1,355,728,835

1,315,245,815

Total equity

2,022,025,472

1,902,125,399

Gearing

32.95%

30.85%

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 525

5.2. Share Capital and treasury shares

The Navigator Company, S.A. is a public company with its shares quoted on the Euronext Lisbon.

As at 31 December 2024, The Navigator Company, S.A.’s share capital of Euro 500,000,000 was fully subscribed and is

represented by 711,183,069 shares without nominal value (31 December 2023: 711,183,069 shares).

As at 31 December 2024 and 2023, the Shareholders with qualified shareholdings in the Company’s capital were as follows:

31-12-2024

31-12-2023

Entity

No. of shares

Semapa, SGPS, S.A.

498,042,299

70.03%

497,617,299

69.97%

Floating shares

213,140,770

29.97%

213,565,770

30.03%

711,183,069

100.0%

711,183,069

100.0%

As at 31 December 2024, the unit value of each share was Euro 3.59 (31 December 2023: Euro 3.55) and the market

capitalisation of the Company at this date amounted to Euro 2,553,147,218 (31 December 2023: Euro 2,524,699,895), compared

to equity of Euro 1,355,728,835 (31 December 2023: Euro 1,315,245,815).

Accounting policies

Ordinary shares are classified in Shareholders’ equity.

Costs directly attributable to the issue of new shares or other equity instruments are reported as a deduction, net of taxes, from

the proceeds of the issue.

Costs directly attributable to the issue of new shares or options for the acquisition of a new business are deducted from the

amount issued.

When such shares are subsequently disposed or reissued, any proceeds, net of the directly attributable transaction costs and

taxes, is directly reflected in the Shareholders’ equity and not in net profit/(loss) for the period.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 526

5.3. Earnings per share

2024

2023

Profit attributable to Navigator's equity holders (Euro) 286,948,195 274,923,820

Total number of shares issued 711,183,069 711,183,069

Weighted average number of shares

711,183,069

Basic earnings per share (Euro)

0.403

0.387

Diluted earnings per share (Euro)

0.403

0.387

Accounting policies

Basic earnings per share are determined based on the division of profits or losses attributable to the ordinary

Shareholders of the Company by the weighted average number of common shares outstanding during the period.

For the purpose of calculating diluted earnings per share, the Company adjusts the profits or losses attributable to

ordinary equity holders, as well as the weighted average number of outstanding shares for the purposes of all

potential dilutive common shares.

5.4. Dividends

Amounts in Euro

Amount approved

Dividends per share (Euro)

Allocations in 2024

Distribution of retained earnings

149,995,621

0.211

Early dividend resolution

99,999,451

0.141

Allocations in 2023

Distribution of retained earnings

199,984,679

0.281

At the General Shareholders Meeting held on 24 May 2024, The Navigator Company, S.A. resolved to distribute dividends in the

amount of Euro 149,995,621.

On 19 December 2024, the Board of Directors of The Navigator Company, S.A. decided to make an advance on profits to

Shareholders, in the amount of Euro 99,999,451, equivalent to the net value of Euro 0.14061 per share, which was paid on 9

January 2025.

At the General Shareholders Meeting held on 17 May 2023, The Navigator Company, S.A. resolved to distribute dividends in the

amount of Euro 199,984,679.

Accounting policies

The distribution of dividends to equity holders is recognised as a liability in the Financial Statements in the period in

which the dividends are approved by the Shareholders at the General Shareholders Meeting and up until the time of

their payment or, in the case of anticipated distributions, when approved by the Board of Directors.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 527

5.5. Reserves and Retained earnings

Amounts in Euro

31-12-2024

31-12-2023

Reserves by application of equity method (395,128,709) (404,214,827)

Fair value reserves 12,011,454 12,898,767

Legal reserve 100,000,000 100,000,000

Free reserves 3,481,014 3,481,014

Other reserves (11,819,114) (2,377,265)

Retained earnings 960,235,449 830,534,306

Reserves and retained earnings 668,780,094 540,321,995

Reserves by applying the equity method – details

Company

31-12-2024

31-12-2023

Subsidiaries

Navigator Paper Southern Africa 54 -

Navigator España, S.A. (489,090,119) (489,989,689)

Navigator Pulp Aveiro, S.A. (7,936,300) (7,936,300)

Enerpulp, S.A. 154,000 154,000

Navigator Parques Industriais, S.A. (1,499,369) (1,499,368)

Portucel Moçambique, S.A. 25,229,195 26,069,669

Navigator Pulp Setúbal, S.A. 154,001 154,000

Navigator Pulp Figueira, S.A. 615,954 615,954

Navigator Forest Portugal, S.A. 739,554 754,578

Navigator Paper Setúbal, S.A. (6,108,693) (15,238,322)

Navigator Tissue Aveiro, S.A. 2,117,121 2,117,121

Navigator Paper Figueira, S.A. 79,783,696 79,783,696

Raíz - Inst. Investigação Floresta e Papel 729,654 816,570

Empremédia - Corretores de Seguros, S.A. 246,570 245,721

Empremedia DAC (222,470) (222,470)

Navigator Paper Mexico (41,677) (40,150)

Navigator Egypt 120 161

Subsidiaries (395,128,709) (404,214,827)

Fair value reserves– details

31-12-2024

31-12-2023

Amounts in Euro

Gross amount

Tax amount

Net amount

Gross amount

Tax amount Net amount

Interest rate risk hedging

5,068,875

(1,343,252)

3,725,623

16,015,134

(4,404,162)

11,610,972

Hedging exchange rate risk and

others

11,273,239

(2,987,408) 8,285,830

1,776,268

(488,473)

1,287,795

16,342,114

(4,330,660) 12,011,454

17,791,402

(4,892,635) 12,898,767

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 528

Fair value reserves - movements

Amounts in Euro

31-12-2024

31-12-2023

Opening balance 12,898,767 33,997,828

Change in the fair value of derivative financial instruments (Note 8.2) (1,526,544) (29,102,154)

Deferred tax (Note 6.2) 639,231 8,003,093

Closing balance 12,011,454 12,898,767

Movements in Other reserves

In 2014, the Group signed agreements with IFC – Internacional Finance Corporation, a Subscription Agreement and a Put and Call

option for the entry of this institution into the share capital of the subsidiary Portucel Moçambique, S.A., thus ensuring the

construction phase of the Group's forestry project in Mozambique. In 2015, this Company performed a capital increase from MZM

1,000 million to MZM 1,680.798 million subscribing MZM 332,798 million corresponding to 19.98% of the capital at that date.

In February 2019, there was a reduction in the subscribed, underwritten, and paid-up capital of the shareholder The Navigator

Company, S.A. to MZM 456,596,000, corresponding to 90.02% of the Company’s share capital, and the IFC’s holding was revised

to MZM 50,620,000, corresponding to 9.98% of the Portucel Moçambique’s share capital.

On 19 December 2023, an addendum was made to the agreements initially signed with the IFC - International Finance

Corporation, extending the date of entry of this institution into the capital of the subsidiary Portucel Moçambique, S.A. from 31

December 2023 to 31 December 2028.

In the current period, Navigator considered that the put option on the shares of the subsidiary Portucel Moçambique, S.A. to The

Navigator Company, S.A. by IFC – International Finance Corporation was expected to be exercised and recorded the amount of

Euro 9,441,850 relating to that transaction.

Accounting policies

Reserves by applying the equity method

Corresponds to the accumulated change in changes in equity in the Company's subsidiaries whose investment is measured by the

equity method (Note 10.1). In accordance with the Portuguese commercial legislation, these reserves are not distributable.

Fair value reserves

It corresponds to the accumulated change in fair value of derivative financial instruments classified as hedging instruments (Note

8.2), net of deferred taxes.

Changes related to derivatives are reclassified to net profit/(loss) for the period (Note 5.10) as the hedged instruments affect net

profit/(loss) for the period. The fair value adjustments of financial investments recorded under this caption is not recycled to net

profit/(loss).

Legal reserve

The Portuguese commercial legislation prescribes that at least 5% of annual net profit/(loss) must be transferred to the legal

reserve, until this is equal to at least 20% of the share capital. This reserve cannot be distributed unless the company is liquidated.

It may, however, be drawn on to absorb losses, after other reserves are exhausted, or incorporated in the share capital.

The legal reserve is constituted by its maximum amount in the periods presented.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 529

Other reserves

This caption corresponds to reserves constituted through the transfer of prior period’s profit and other movements. The portion of

the balance corresponding to the acquisition value of treasury shares held (Note 5.2), if any, is not distributable.

5.6. Interest-bearing liabilities

31-12-2024

31-12-2023

Non-current

Current

Total

Non-current

Current

Total

Bond loans

547,500,000

100,000,000

647,500,000

397,500,000

22,500,000

420,000,000

Commercial paper

85,000,000

35,000,000

120,000,000

70,000,000

35,000,000

105,000,000

Bank loans

78,551,587

12,420,635

90,972,222

71,972,222

34,539,683

106,511,905

Charges with bond issuances

(3,442,861)

(2,614,750)

Cash pooling Navigator Group -

218,002,842

268,133,200

Debt securities and bank debt

707,608,727

365,423,477

1,073,032,204

536,857,472 360,172,883 897,030,355

The evolution of financing in 2024 was marked by the contracting of a significant volume of new long-term lines (maturities

between 5 and 7 years), amounting to Euro 355 million, all indexed to ESG indicators.

Of this total, Euro 250 million were issued in the form of bonds, maturing in 2029 (Euro 50 million) and 2031 (Euro 200 million).

A commercial paper issue was also made (Euro 50 million), with a firm underwriting until 2030. All the bonds and commercial

paper were issued under the Sustainability-Linked Bonds Framework.

This operation contributed to extending the average life of the Group's debt, as well as reducing the Company's financing cost,

in addition to having conditions adjusted to the fulfilment of sustainability commitments. The conditions of the bond loans are

indexed to three ESG indicators already included in the Group's Sustainability Agenda and, in turn, aligned with the Sustainable

Development Goals of the United Nations.

In December 2023, the Company signed a new long-term loan agreement with the European Investment Bank (EIB) for Euro 115

million, maturing in 12 years. The loan will be disbursed in up to 3 instalments within 18 months of signing the contract. The loan

will support the project to build and operate the high-efficiency recovery boiler at the Setúbal Industrial Complex, a key step in the

decarbonisation roadmap. This green loan is part of the REPowerEU Plan, which aims to increase financing for green energy and

support the autonomy and competitiveness of the European Union.

The maturity analysis of interest

-bearing liabilities is presented in the Note 8.1.3 - Liquidity risk.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 530

Interest-bearing liabilities – Details

31-12-2024

Amounts in Euro

Amount

Outstanding

amount

Maturity

Interest rate

Current

Non-current

Bond loans

Navigator 2022-2028 ESG

150,000,000

June 2028

Variable rate indexed to Euribor, with

swap to fixed rate

50,000,000

100,000,000

Navigator 2019-2026

50,000,000

January 2026

Fixed rate

50,000,000

Navigator 2019-2025

10,000,000

March 2025

Variable rate indexed to Euribor, with

swap to fixed rate

10,000,000

Navigator 2021-2026

12,500,000

April 2026

Variable rate indexed to Euribor

2,500,000

10,000,000

Navigator 2020-2026

75,000,000

December 2026

Variable rate indexed to Euribor, with

swap to fixed rate

37,500,000

Navigator 2021-2026 ESG

100,000,000

August 2026

Variable rate indexed to Euribor, with

swap to fixed rate

100,000,000

Navigator 2024-2029

50,000,000

June 2029

Variable rate indexed to Euribor, with

swap to fixed rate

50,000,000

Navigator 2024-2031

50,000,000

June 2031

Variable rate indexed to Euribor, with

swap to fixed rate

50,000,000

Navigator SLB 2024-2031

50,000,000

October 2031

Variable rate indexed to Euribor

50,000,000

Navigator 2024-2031 SLB

100,000,000

May 2031

Variable rate indexed to Euribor

100,000,000

Fees

(3,442,861)

European Investment Bank

EIB Loan – Cacia

9,722,222

May 2028

Fixed rate

2,777,778

6,944,444

EIB Loan – Figueira

25,714,286

February 2029

Fixed rate

5,714,286

20,000,000

EIB Loan – Biomass Boiler

25,535,714

March 2031

Fixed rate

3,928,571

21,607,143

EIB Loan

115,000,000

Up to

12 years after

reimbursement

Indexed to the cost of EIB funds, on

disbursement

Commercial Paper Programme

Commercial Paper Programme 175M

70,000,000

February 2026

Fixed rate

35,000,000

Commercial Paper Programme 65M ESG

19,500,000

February 2026

Variable rate indexed to Euribor

Commercial Paper Programme 75M

75,000,000

January 2026

Variable rate indexed to Euribor

Commercial Paper Programme 50M

50,000,000

December 2025

Variable rate indexed to Euribor

Commercial Paper Programme 50M

2024- 2030

50,000,000

June 2030

Variable rate indexed to Euribor

50,000,000

Interest-bearing liabilities

Long-term investment

55,000,000

30,000,000

March 2031

Variable rate indexed to Euribor

30,000,000

Bank credit facilities

Short-term facility 20M

20,450,714

Cash pooling

Navigator Group Cash Pooling Line

218,002,842

1,073,032,204

365,423,477

707,608,727

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 531

31-12-2023

Amounts in Euro

Amount

Outstanding

amount

Maturity

Interest rate

Current

Non-current

Bond loans

Navigator 2022-2028 ESG

150,000,000

June 2028

Variable rate indexed to Euribor, with

swap to fixed rate

150,000,000

Navigator 2019-2026

50,000,000

January 2026

Fixed rate

50,000,000

Navigator 2019-2025

30,000,000

December 2026

Variable rate indexed to Euribor, with

swap to fixed rate

20,000,000

10,000,000

Navigator 2021-2026

15,000,000

April 2026

Variable rate indexed to Euribor

2,500,000

12,500,000

Navigator 2020-2026

75,000,000

December 2026

Variable rate indexed to Euribor, with

swap to fixed rate

75,000,000

Navigator 2021-2026 ESG

100,000,000

August 2026

Variable rate indexed to Euribor, with

swap to fixed rate

100,000,000

Fees

(2,614,750)

Variable rate indexed to Euribor

(2,614,750)

European Investment Bank

EIB Loan - Energy

10,625,00

7,083,333

December 2024

Variable rate indexed to Euribor

7,083,333

EIB Loan – Cacia

13,888,889

12,500,000

May 2028

Fixed rate

2,777,778

9,722,222

EIB Loan – Figueira

31,428,572

February 2029

Fixed rate

5,714,286

25,714,286

EIB Loan – Biomass Boiler

27,500,000

March 2031

Fixed rate

1,964,286

25,535,714

Commercial Paper Programme

Commercial Paper Programme 175M

105,000,000

February 2026

Fixed rate

35,000,000

70,000,000

Commercial Paper Programme 65M

42,250,000

February 2026

Variable rate indexed to Euribor

Commercial Paper Programme 75M

75,000,000

January 2026

Variable rate indexed to Euribor

Commercial Paper Programme 50M

50,000,000

December 2025

Variable rate indexed to Euribor

Loans

Long-term investment

15,000,000

13,000,000

March 2026

Variable rate indexed to Euribor

2,000,000

11,000,000

Other

3,648,804

-6

Variable rate indexed to Euribor

Bank credit facilities

Short-term facility 20M

20,450,714

15,000,000

Cash pooling

Navigator Group Cash Pooling Line

268,133,200

897,030,355

360,172,883

536,857,472

As at 31 December 2024, the average cost of debt with financial institutions, considering interest rates, the annual fees and

hedging operations, was 2.5% (as at 31 December 2023 it was 2%).

As at 31 December 2024, the Company had contracted Commercial Paper Programmes, contracted and undisbursed Long-term

financing, as well as available and undrawn credit facilities of Euro 304,950,714 (31 December 2023: 287,700,714).

The repayment terms for the interest-bearing liabilities recorded as non-current are detailed as follows:

Amounts in Euro

31-12-2024

31-12-2023

Non-current

1 to 2 years

244,920,635

149,420,635

2 to 3 years

12,420,635

253,920,635

3 to 4 years

111,031,746

12,420,635

4 to 5 years

56,785,714

111,031,746

More than 5 years

285,892,857

12,678,571

711,051,588

539,472,222

Fees

(3,442,861)

(2,614,750)

707,608,727

536,857,472

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 532

Financial covenants in force

Ratio

Definition

Loans

Limit

Interest coverage

EBITDA 12M / Annual net interest

Bank

>= 4.5 - 5.5

Indebtedness

Interest-bearing debt / EBITDA 12M

Bank

<= 4.5

Net Debt / EBITDA

(Interest

-bearing debt - Cash) / EBITDA 12M

Bank Commercial Paper Bonds

<= 4.0

- 5.0

<= 4.0

Given the contractual limits, in 2024 and 2023 the Company is in compliance with the covenants negotiated. As at 31 December

2024 and 31 December 2023, the company presents a minimum safety margin above 80% on the fulfilment of its covenants.

Accounting policies

Interest-bearing liabilities includes Bonds, Commercial Paper, bank loans and other financing.

Initial measurement

At fair value, net of transaction costs incurred.

Subsequent measurement

At amortised cost, using the effective interest rate method.

The difference between the repayment amount and the initial measurement amount is recognised in the income statement over

the debt period under "Interest expenses on other loans" in Note 5.10 – Net financial results.

Fair value

The book value of short-term interest-bearing liabilities or loans contracted at variable interest rates are close to their fair value.

The fair value of interest-bearing liabilities that are remunerated at a fixed rate is disclosed in Note 8.3 – Financial assets and

liabilities.

Disclosure

The Company should classify a liability as current when: i) it expects to settle the liability in the normal course of its operating

cycle; ii) it holds the liability primarily for trading purposes; iii) settlement of the liability is expected within twelve months of the

reporting period; or iv) it does not have an unconditional right to defer settlement of the liability for at least twelve months after

the reporting period.

Estimates and judgements

Commercial paper

The Company has several commercial paper programmes negotiated; agreements with which issues with contractual

maturity below one year and with a revolving nature are often made. Where the Company expects to extend these

loans (roll over), it classifies them as non-current liabilities.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 533

5.7. Lease liabilities

Lease liabilities– nature

31-12-2024

31-12-2023

Non-current

Current

Total

Non-current

Current

Total

Buildings

876,698

587,065

1,463,763

1,371,022

540,140

1,911,162

876,698

587,065

1,463,763

1,371,022

540,140

1,911,162

Lease liabilities – movements

Amounts in Euro

31-12-2024

31-12-2023

Balance as at 1 January

1,911,162

2,381,970

Contract amortisation (614,255) (589,098)

Interest expense

50,711

64,546

Other changes

116,145

53,744

Total changes in related liabilities

(447,399)

(470,808)

Balance as at 31 December

1,463,763

1,911,162

Lease liabilities – future liabilities

Amounts in Euro

31-12-2024

31-12-2023

Less than 1 year

560,675

491,279

1 to 2 years 597,053 524,289

2 to 3 years

253,776

558,307

3 to 4 years

239,558

4 to 5 years

More than 5 years

1,411,504

1,813,433

Interest on liabilities

52,259

97,729

Present value of liabilities

1,463,763

1,911,162

Accounting policies

At the start date of the lease, the Company recognises lease liabilities measured at the present value of future lease

payments, which include fixed payments less lease incentives, variable lease payments, and amounts expected to be

paid as residual value. Lease payments also include the price of exercise of renewal options reasonably certain to be

exercised by the Company or lease termination penalty payments if the lease term reflects the Company's option to

terminate the agreement.

In calculating the present value of future lease payments, the Company uses an incremental financing rate if the implied interest

rate on the lease transaction is not easily determinable.

Subsequently, the value of the lease liabilities is increased by the interest amount (Note 5.10 – Net Financial Results) and

decreased by the lease payments (rents).

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 534

5.8. Cash and cash equivalents

Amounts in Euro

31-12-2024

31-12-2023

Cash 3,050 3,050

Short-term bank deposits 5,826,041 9,661,172

Other short-term investments 252,000,000 135,000,000

Cash pooling (Note 10.2) 148,906,476 165,486,549

Cash and cash equivalents in the statement of financial position 406,735,567 310,150,771

Bank overdrafts - cash pooling (Notes 5.6 and 10.2) (218,002,842) (268,133,200)

Cash and cash equivalents in the statement of cash flows 188,732,725 42,017,571

In 2024 and 2023, Other short-terms investments corresponds to amounts invested by Navigator in a portfolio of short-term,

highly liquid deposits and issuers with adequate ratings.

As at 31 December 2024 and 31 December 2023, there are no significant balances of cash and cash equivalents that are subject to

restrictions on use by the Company.

Accounting policies

Cash and cash equivalents include cash, bank accounts and other short-term investments with an initial maturity of up

to 3 months, which can be mobilised immediately without any significant risk in value fluctuations.

For cash flow statement purposes, this caption will also include, when applicable, bank overdrafts, which are presented in the

Statement of financial position as a current liability, under the caption Interest-bearing liabilities (Note 5.6).

5.9. Cash flows from financing activities

Movements in liabilities for financing activities

Amounts in Euro

2024

2023

Balance as at 1 January

897,030,355

985,446,453

Payment of interest-bearing liabilities

(103,039,683)

(75,075,396)

Receipts of interest-bearing liabilities

330,000,000

15,000,000

Cash pooling

(50,130,358)

(29,206,035)

Changes in borrowing costs

(828,111)

865,333

Changes in interest-bearing debt

176,001,849

(88,416,098)

Gross interest-bearing debt

1,073,032,204

897,030,355

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 535

5.10. Net financial results

Amounts in Euro

2024

2023

Interest paid on debt securities and bank debt

(25,644,861)

(21,303,488)

Interest paid on other interest-bearing liabilities

(24,543,436)

(31,272,805)

Commissions on loans and expenses with the opening of credit facilities

(2,270,403)

(2,219,631)

Interest paid using the effective interest method

(52,458,700)

(54,795,924)

Interest paid on lease liabilities

(50,711)

(64,546)

Financial expenses related to the Company's capital structure

(52,509,411)

(54,860,470)

Unfavourable exchange rate differences

(1,678,277)

(1,515,057)

Gains / (Losses) on financial instruments - hedging (Note 8.2)

(2,549,705)

(960,636)

Losses on compensatory interest

(279,895)

(671,591)

Other expenses and financial losses

(1,400,175)

(656,504)

Financial expenses and losses

(58,417,463)

(58,664,258)

Interest received from loans granted

25,978,329

18,276,509

Gains on financial instruments - hedging (Note 8.2)

11,328,732

9,722,523

Gains on compensatory interest

768,961

86,567

Other income and financial gains

6,880,183

8,331,326

Financial income and gains

44,956,205

36,416,925

Financial profit/(loss)

(13,461,258)

(22,247,333)

Accounting policies

The Company classifies as “Financial income” the income and gains resulting from treasury management activities

such as: i) interest obtained from the application of cash surplus; and ii) changes in the fair value in derivative

financial instruments negotiated to hedge interest rate and exchange rate risk on loans, regardless of the formal

designation of hedge.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 536

6. Income tax

6.1. Income tax for the period

6.1.1. Income tax recognised in the income statement

Amounts in Euro

2024

2023

Current tax

(21,492,275)

(17,607,069)

Change in uncertain tax positions in the period 5,257,463

(1,690,823)

Deferred tax (Note 6.2)

4,323,148

(3,127,027)

(11,911,664)

(22,424,919)

As at 31 December 2024 and 31 December 2023, the caption Change in uncertain tax positions in the period reflects the

excess/insufficiency of tax estimates, the favourable outcome of some cases related to matters with high uncertainty, as well as

requests for binding information, claims to the Tax Authorities and jurisprudence of the courts.

Nominal tax rate

In the periods presented, the Company considers a nominal tax rate in Portugal of 27.5%, resulting from the tax legislation as

follows:

2024

2023

Portugal

Nominal income tax rate

21.0%

Municipal surcharge

1.5%

22.5%

State surcharge - on the share of taxable profits between Euro 1,500,000 and Euro 7,500,000

3.0%

State surcharge - on the share of taxable profits between Euro 7,500,000 and Euro 35,000,000

5.0%

State surcharge - on the share of taxable profits above Euro 35,000,000

9.0%

Reconciliation of the effective income tax rate for the period

Amounts in Euro

2024

2023

Profit before income tax

298,859,858

297,348,739

Expected tax at nominal rate (21%)

62,760,570

62,443,235

Municipal surcharge (2024: 0.44% ; 2023: 0.31%)

1,327,295

910,583

State surcharge (2024: 2.13% ; 2023: 1.30%)

6,368,769

3,868,496

Income tax resulting from the applicable tax rate

70,456,634

67,222,314

Nominal tax rate for the period

23.58%

22.61%

Differences (a)

(47,716,550)

(44,491,310)

Tax losses from subsidiaries

(4,451,630)

(Excess)/ Insufficiency of income tax estimate

(530,498)

(958,103)

Effect of changes in uncertain tax positions in the period

(4,726,965)

Collection tax benefits

(529,487)

Autonomous taxation 195,198

652,018

Tax rate difference effect

(785,038)

11,911,664

22,424,919

Effective tax rate

3.99%

7.54%

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 537

(a) This amount concerns mainly:

2024

2023

Effect of application of equity method

(192,493,281)

(224,727,140)

Adjustments to investments in subsidiaries

(16,575,071)

Taxable provisions and impairment

(751,980)

14,622,035

Tax benefits - incentives to capitalise companies

(17,347,915)

(7,910,809)

Tax benefits - membership fees

(168,654)

(164,937)

Tax benefits - donations

(159,703)

(18,845)

Tax benefits - increase in energy costs

(2,059)

(9,363)

Employee benefits

26,683

32,687

Other

250,311

4,042,916

(227,221,669)

(214,133,456)

Tax impact

(47,716,550)

(44,491,310)

6.1.2. Tax recognised in the statement of financial position

Amounts in Euro

31-12-2024

31-12-2023

Assets

Amounts pending repayment (tax proceedings decided in favour of the Company)

19,746,025

17,510,098

19,746,025

17,510,098

Liabilities

Corporate Income Tax - IRC

26,999,467

4,081,875

Additional tax liabilities (IRC)

9,207,367

17,073,691

36,206,834

21,155,566

Detail of Corporate Income Tax - IRC (net)

Amounts in Euro

31-12-2024

31-12-2023

Income tax for the period 21,492,275 17,607,069

Payments on account, special and additional payments on account

(59,655,867)

(71,548,624)

Withholding tax recoverable

(1,808,486)

(1,626,501)

Corporate Income Tax of companies included in the RETGS 59,762,374 59,649,931

Corporate Income Tax payable / (repayable) from previous periods

7,209,171

26,999,467

4,081,875

Amounts pending repayment

Amounts in Euro

31-12-2024

31-12-2023

2005 Corporate Income Tax (RETGS) - Proceeding 1259/ 09.BESNT

13,886,728

RFAI 2010 to 2012 - compensatory interest

494,856

IRC 2015-I Case 21/22.2BALSB

5,364,441

2018 Corporate Income Tax (RETGS) - Proceeding CAAD 103/2023 - 1,749,389

2017 Corporate Income Tax - Proceeding CAAD 756/2022

1,379,125

19,746,025

17,510,098

The movements in the period are detailed as follows:

Amounts in Euro

2024

2023

Balance at the beginning of the period 17,510,098

15,341,107

Increases

5,364,441

3,128,514

Charge-off

(3,045,969)

(959,523)

Reversals

(82,545)

19,746,025

17,510,098

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 538

Uncertain tax positions - liabilities

Amounts in Euro

2024

2023

Balance at the beginning of the period

17,073,691

11,494,069

Increases

2,494,265

7,428,212

Charge-off

(198,590)

Transfers

(6,451,126)

Reversals

(3,909,463)

(1,650,000)

Changes in the period

(7,866,324)

5,579,622

9,207,367

17,073,691

Taxes paid in litigation

As at 31 December 2024 and 31 December 2023, the additional tax assessments that are already paid and contested, not

recognised in assets, are summarised as follows:

Amounts in Euro

31-12-2024

31-12-2023

Aggregate Corporate Income Tax 2005 - Proceeding 88/13.4BEALM

10,394,386

2006 Aggregate Corporate Income Tax Proceeding 909/11.6 BEALM

8,150,146

2018 Aggregate Corporate Income Tax – Proceeding 103/2023 and 48/23.5BEALM

8,014,795

11,138,180

State Surcharge 2015 II – Proceeding 453/23.9BEALM

6,970,541

State Surcharge 2016 – Proceeding 457/21.6BEALM

3,761,397

State Surcharge 2017 – Proceeding 456/21.8BEALM

8,462,724 8,462,724

State Surcharge 2018 – Proceeding 707/21.9 BEALM

12,223,705

State Surcharge 2019 – Proceeding 557/23.8BEALM

2,466,974

State Surcharge 2020 – Proceeding 26/24.9BEALM

5,183,000 5,183,000

State Surcharge 2021 – Proceeding 702/24.6BEALM

6,154,906

Pension Fund Contributions - Arbitration Proceeding 525/2024

1,457,205

50,621,688

68,751,053

Accounting policies

Current income tax is calculated based on net profit/(loss), adjusted in conformity with tax legislation in force at the

Statement of financial position date.

Taxation group

In Portugal, the Navigator Group is subject to the special tax regime for groups of companies (RETGS), comprising companies in

which the shareholding is equal to or more than 75% and which meet the conditions laid down in articles 69 and following of the

Corporate Income Tax Code (IRC Code).

These companies included in the RETGS calculate income taxes as if they were taxed independently. Liabilities are recognised as

due to the controlling company of the tax business Group, currently The Navigator Company, S.A. which is responsible for the

Group’s overall assessment and payment of the corporate income tax. Where there are gains on the use of this regime, these are

recorded as income in the controlling company’s financial statements.

The amounts the Company has receivable from or payable to other companies in the tax business group in respect of their

liabilities are presented under Receivables and Payables.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 539

Estimates and judgements

The Company recognises liabilities for additional tax assessments that may result from reviews by the tax authorities.

When the final result of these situations is different from the amounts initially recorded, the differences will have an

impact on income tax in the period in which they are calculated.

In Portugal, annual income statements are subject to review and possible adjustment by the tax authorities for a period of 4 years.

However, if tax losses are presented, they may be subject to review by the tax authorities for a period of 6 years.

The Board of Directors considers that any corrections to those declarations as a result of reviews/inspections by the Portuguese

Tax Authorities will not have a significant impact in the financial statements as at 31 December 2024, although the periods up to

and including 2020 have already been reviewed.

Uncertain tax positions

The amount of assets and liabilities recorded for tax proceedings arises from an assessment made by the Company, as at the date

of the Statement of Financial Position, regarding potential differences of understanding with the Portuguese Tax Authorities,

considering the developments in tax matters.

The Company, in relation to the measurement of uncertain tax positions, considers the provisions of IFRIC 23 - “Uncertainty over

Income Tax Treatments”, namely the measurement of risks and uncertainties in the definition of the best estimate of the expense

required to settle the obligation, by weighing all the possible results that are controlled by them and their associated probabilities.

Pillar Two Model Rules - OECD

The Navigator Group is subject to the OECD Pillar Two model rules from 1 January 2024. It has applied the exception to the

recognition and disclosure of information on deferred tax assets and liabilities related to Pillar Two income taxes, as provided for in

the amendments to IAS 12.

As at the date of this report, the Group is currently assessing the impact of this change. However, based on the current

understanding of the interpretation of the new rules, no significant impacts are expected.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 540

6.2. Deferred taxes

Movements in deferred taxes

As at 1 January

2024

Tax rate changes

and

regularisations

Income Statement

Equity

As at 31

December

2024

Amounts in Euro

Increases

Decreases

Temporary differences originating deferred tax

assets

Provisions and impairment losses taxed

2,569,725

2,720,023

(2,569,725)

2,720,023

Lease liabilities relating to

right-of-use assets -

1,463,763

Adjustments to investments in subsidiaries

11,750,244

19,649,962

(3,074,891)

- 28,325,315

14,319,969

23,833,747

(5,644,616)

32,509,100

Temporary differences originating deferred tax

liabilities

Adjustment of property, plant and equipment

(159,015)

18,267

(140,748)

Financial instruments

(18,072,331)

203,673

1,526,544

(16,342,114)

Right

-of-use assets -

(1,359,258)

- (1,359,258)

(18,231,346)

203,673

(1,359,258)

18,267

1,526,544

(17,842,119)

Deferred tax assets

3,937,991

6,554,281

(1,552,269)

8,940,003

Effect of the change in tax rate

(143,200)

(238,337)

56,446

- (325,091)

Deferred tax assets

3,937,991

(143,200)

6,315,943

(1,495,823)

8,614,912

Deferred tax liabilities

(5,013,621)

234,697

(373,796)

5,023

419,800

(4,727,897)

Effect of the change in tax rate

1,590

13,593

(183)

(15,265)

(265)

Deferred tax liabilities

(5,013,621)

236,287

(360,203)

4,841

404,534

(4,728,162)

As at 1 January

2023

Wine company

merger effect

Income Statement

Equity

As at 31

December

2023

Amounts in Euro

Increases

Decreases

Temporary differences originating deferred tax

assets

Provisions and impairment losses taxed

410,869

2,569,725

(410,869)

2,569,725

Adjustments to investments in subsidiaries 25,316,119

1,561,458

(15,127,333)

- 11,750,244

25,726,988

4,131,183

(15,538,202)

- 14,319,969

Temporary differences originating deferred tax

liabilities

Pensions and other post-employment benefits -

(17,386)

17,386

- -

Adjustment of property, plant and equipment

(177,644)

18,629

(159,015)

Financial instruments

(47,174,485)

29,102,154

(18,072,331)

(47,352,129) (17,386)

36,015

29,102,154 (18,231,346)

Deferred tax assets

7,074,922

1,136,075

(4,273,006)

3,937,992

Deferred tax liabilities

(13,021,836)

(4,781)

9,904

8,003,092

(5,013,621)

As at 31 December 2024, the rate of 26.50% was used and as at 31 December 2023, the rate of 27.50% was used.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 541

Accounting policies

Deferred tax is calculated based on the liability of the Statement of financial position on the temporary differences

between the book values of the assets and liabilities and their respective tax base. To determine the deferred tax, the

tax rate expected to be in force in the period in which the temporary differences will be reversed is used.

Deferred tax assets are recognised whenever there is a reasonable likelihood that future taxable profits will be generated against

which they can be offset. Deferred tax assets are revised periodically and decreased, whenever it is likely that tax losses will not

be used.

Deferred taxes are recorded as an income or expense for the year, except where they result from amounts recorded directly under

equity, situation in which deferred tax is also recorded under the same caption. Tax benefits attributed to the Company regarding

its investment projects are recognised through the income statement as there is sufficient taxable income to allow its use.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 542

7. Payroll

7.1. Payroll costs

Amounts in Euro

2024

2023

Remuneration of Corporate Bodies - fixed (Note 7.3)

911,838

1,157,161

Remuneration of Corporate Bodies - variable

530,405

1,319,093

Employee remuneration

2,710,766

3,479,121

Social Security contributions

813,347

957,547

Post-employment benefits (Note 7.2.2)

117,473

127,261

Other payroll costs

510,005

146,200

Payroll costs

5,593,834

7,186,383

Number of employees at the end of the period

As at 31 December 2024 and 2023, the number of Employees under contractual employment with the Company was 309 and 331,

respectively, of which 295 were employed by other Group companies (2023: 318). The company employed—via multiple

employment contracts—33 employees (2023: 36).

Accounting policies

Short-term employee benefits

Acquired rights - holidays and holiday allowance

In accordance with the collective agreement applicable to The Navigator Company, S.A., Workers are entitled to 25 working days

leave, as well as one month's holiday allowance, acquired in the year preceding that of the payment. Moreover, employees who

work continuous shifts for more than 25 or 30 years get one or two additional days' holiday, respectively.

Bonuses

According to the current Performance Management System (Sistema de Gestão de Desempenho), employees have the right to a

bonus, based on annually defined objectives. The entitlement of this bonus is usually acquired in the year preceding its payment.

These liabilities are recorded in the year in which the Employees acquire the respective right, irrespective of the date of payment,

whilst the balance payable at the date of the Statement of financial position is shown under the caption Payables (Note 4.3).

Benefits arising from termination of employment

The benefits arising from termination of employment are recognised when the Company can no longer withdraw the offer of such

benefits or in which the Company recognises the cost of restructuring under the provisions recording. Benefits due more than 12

months after the end of the reporting period are discounted to their present value.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 543

7.2. Employee benefits

7.2.1. Defined benefit plan

Policy for managing the risk associated with defined benefit plans

For capital management purposes, the Company defines capital as including equity and net debt.

The Company's exposure to risk is limited to the number of existing beneficiaries and will tend to decrease, since there are

no defined benefit plans open to new employees in the Company.

The most significant risks to which the Company is exposed through defined benefit plans include:

i) Risk of change in the longevity of participants.

ii) Market rate variation risk – rate variation impacts the rate used to discount liabilities (technical interest rate) which is

based on yield curves of highly rated bonds with maturities similar to the liabilities' expiry dates and the fixed rate of

return of the assets. The Company uses yield curves in order to monitor the evolution of rates and performs sensitivity

analyses of interest rate variations with the aim of foreseeing and preventing the consequent impact on the fund's

funding level.

iii) Risk of change in the wage and pension growth rate.

iv) Return on the fund's financial assets – the Company closely monitors the evolution of the fund's assets, as well as

the evolution of the main financial market indicators, revisiting the investment policy approved for the management of

the assets whenever justifiable, and at least every three years. The investment policy is aligned with a conservative

view of asset management and defined on the basis of the responsibilities to be financed by the fund.

Net liabilities

Net liabilities reflected in the Statement of financial position and the number of beneficiaries of the defined benefit plans in force in

the Company are detailed as follows:

31-12-2024

31-12-2023

No. of

Beneficiaries

Amount

No. of

Beneficiaries

Amount

Past service liabilities

Active employees, including individual accounts

927,214

752,992

Alumni

Retired employees

128

12,172,444

130

12,571,121

Market value of pension funds

(12,690,722)

(13,156,177)

Total net liabilities

142

408,936

143

167,936

Historical information - last five years

Amounts in Euro

2020

2021

2022

2023

2024

Present value of liabilities

17,087,861

16,354,196

13,760,556

13,324,113

13,099,658

Fair value of assets and reserves

15,924,756

16,798,826

13,360,257

13,156,177

12,690,722

Surplus / (deficit)

(1,163,105)

444,630

(400,299)

(167,936)

(408,936)

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 544

Evolution of defined benefit plan liabilities

2024

Opening balance

Current

services cost

Interest

expense

Actuarial

deviations

Payments

performed

Closing

balance

Amounts in Euro

Pensions with autonomous fund 13,324,113 20,101

444,522 538,376

(1,227,454)

13,099,658

13,324,113

20,101

444,522 538,376

(1,227,454)

13,099,658

2023

Opening balance

Current

services cost

Interest

expense

Actuarial

deviations

Payments

performed

Closing

balance

Amounts in Euro

Pensions with autonomous fund 13,760,556 18,879

461,493 303,971

(1,220,785)

13,324,113

13,760,556

18,879

461,493 303,971

(1,220,785)

13,324,113

The average expected duration of the defined benefit liabilities is 9 years (2023: 9 years).

Funds

Funds allocated to the defined benefit pension plans - evolution

Amounts in Euro

2024

2023

Opening balance

13,156,177 13,360,257

Expected income for the period

437,941

447,684

Remeasurement

324,058

552,111

Pensions paid

(1,227,454)

(1,220,785)

Merger effect Soc. Vinhos

16,910

Closing balance

12,690,722

13,156,177

Funds allocated to defined benefit plan - estimated contributions in the following period

The contributions planned for the next annual reporting period are, among other factors, dependent on the profitability of the

funds' assets.

Funds allocated to defined benefit plans - composition of assets

Amounts in Euro

31-12-2024

31-12-2023

Securities listed in the market

Bonds

7,769,834

61.2%

7,988,842

60.7%

Shares 3,221,083 25.4% 3,095,335

23.5%

Public debt 1,189,802 9.4% 1,413,678

10.7%

Liquidity 128,779 1.0% 230,232

1.7%

Other short-term investments

381,224

3.0%

428,090

3.3%

12,690,722

100%

13,156,177

100%

The assets of the pension fund do not include any assets of the Company.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 545

7.2.2. Expenses incurred with post-employment benefit plans

2024

2023

Amounts in Euro

Current

services cost

Net

interest

Defined

contribution –

Contributions for

the period

Impact on net

profit/(loss)

(Note 7.1)

Current

services cost

Net

interest

Defined

contribution –

Contributions for

the period

Impact on

net

profit/(loss)

(Note 7.1)

Pensions with autonomous fund 20,101 6,582 - 26,683

18,879

13,808 - 32,687

Defined contributions plans - - 90,790 90,790

- 94,574 94,574

20,101 6,582 90,790 117,473

18,879

13,808 94,574 127,261

As at 31 December 2024, the Defined Contribution plans covered 345 participants (2023: 388 participants).

Accounting policies

Post-employment benefits - defined benefit plan

The Company has assumed the commitment to make payments to their employees in the form of complementary retirement

pensions, disability, early retirement and survivors’ pensions, having constituted defined-benefit plans.

The Company set up autonomous pension funds as a means of funding most of the liabilities. Based on the projected credit unit

method, the Company recognises the costs with the attribution of these benefits as the services are provided by the employees.

The total liability is estimated separately for each plan at least once every six months, on the date of closing of the interim and

annual accounts, by a specialised and independent entity.

The liability thus determined is presented in the Statement of financial position, less the fair value of the funds set up, under

Pensions and other post-employment benefits.

Actuarial deviations resulting from changes in the value of estimated liabilities, as a consequence of changes in the financial and

demographic assumptions used and experience gains, added to the differential between the actual return on fund assets and the

estimated share of net interest, are designated as remeasurements and recorded directly in the statement of comprehensive

income, under retained earnings.

Net interest corresponds to the application of the discount rate to the value of net liabilities (value of liabilities less the fair value of

fund assets) and is recognised in the income statement for the period under Payroll costs (Note 7.1).

The gains and losses generated by a curtailment or settlement of a defined-benefit plan are recognised in the income statement

for the period when the curtailment or settlement occurs. A curtailment occurs when there is a material reduction in the number of

employees.

Costs for past liabilities resulting from the implementation of a new plan or increases in benefits attributed are recognised

immediately in net profit/(loss) for the period.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 546

Post-employment benefits - defined contribution plan

The Company assumed commitments regarding payments to a defined contribution plan in a percentage of the employees’ salary,

in order to provide retirement, disability, early retirement and survivors’ pensions.

To this end, Pension Funds have been set up to capitalise on those contributions, for which employees may still make voluntary

contributions, but for which the Company does not assume any additional contribution responsibilities or a pre-fixed return. Thus,

the contributions made are recorded as expenses of the period in which they are recognised, regardless of the time of their

settlement.

Estimates and judgements

Actuarial assumptions

31-12-2024

31-12-2023

Social Security Benefits Formula

Decree Law 187/2007 of 10 May

Disability table

EKV 80

Mortality table

TV 88-

Technical interest rate

3.50%

Wage growth rate

2.00%

Return rate on plan assets

3.50%

Pensions growth rate

2.00%

Sensitivity analysis

Amounts in Euro

31-12-2024

31-12-2023

0.5% decrease in the discount rate

Increase in liabilities assumed

552,335

570,146

0.5% increase in the discount rate

Decrease in liabilities assumed

(506,556)

(528,393)

0.5% decrease in the wage growth rate

Decrease in liabilities assumed

(24,586)

(25,179)

0.5% increase in the wage growth rate

Increase in liabilities assumed

29,373

26,713

0.5% decrease in the pensions growth rate

Decrease in liabilities assumed

(440,120)

(462,032)

0.5% increase in the pensions growth rate

Increase in liabilities assumed

472,016

489,876

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 547

7.3. Remuneration of Corporate Bodies

Amounts in Euro

2024

2023

Navigator Corporate Bodies

Board of Directors

757,338

985,890

Supervisory Board

75,500

83,521

Environment Board

73,000

79,750

Board of the General Shareholders Meeting

6,000

8,000

911,838

1,157,161

Remuneration of the members of the Board of Directors

Full details of the remuneration policy for the members of Navigator's Board of Directors are described in the Company's Corporate

Governance Report.

Three of the current directors are members of pension plans of Navigator Brands, S.A., a subsidiary of the Company, as Employees

of that company, before joining management positions.

As at 31 December 2024 and 2023, regarding the members of the Board of Directors of Navigator, there were no: i) any additional

liabilities allocated to other long-term benefits, ii) employment termination benefits, iii) share-based payments and iv) any

outstanding balances.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 548

8. Financial instruments

8.1. Financial risk management

The Company, at the level of the Navigator Group, has a risk-management programme, which focuses its analysis on the financial

markets with a view to mitigate the potential adverse effects on its financial performance. Risk management is undertaken by the

Group's Financial Management in accordance with the policies approved by the Board of Directors and monitored by the Risks and

Control Commission.

The Company adopts a proactive approach to risk management, as a way to mitigate the potential adverse effects associated with

those risks, namely the exchange rate risk and interest rate risk.

8.1.1. Exchange rate risk

Exchange rate risk management policy

A significant part of the Company’s sales is priced in currencies other than the Euro, therefore its evolution can have a

significant impact on the cash flows obtained from the Company's future sales, with the currency with the greatest

impact being the USD. Also, sales in GBP, PLN, CHF and ZAR have some weight, having sales in other currencies less

expression.

Purchases of some raw materials are also made in USD, namely part of wood and long-fibre pulp imports of wood and

acquisitions of long-fibre pulp. Therefore, changes in USD may have an impact on acquisition values.

Moreover, once a sale or purchase is made in a currency other than the Euro, the Company becomes exposed to

exchange rate risk until the receipt or payment of such sale or purchase, if no hedging instruments are in place. As a

result, there is a significant number of receivables and payables, the latter with lesser expression, exposed to exchange

rate risk.

The Company has foreign subsidiaries that expose it to exchange rate risk, namely Navigator North America in the United

States, Navigator United Kingdom, Ltd. and Portucel Moçambique. Besides those operations, the Company does not hold

materially relevant investments in foreign operations, the net assets of which are exposed to exchange rate risk.

Use of derivative financial instruments

The Company manages exchange rate risk by using derivative financial instruments, in accordance with a policy that is

subject to periodic review and whose purpose is to limit the exchange rate risk associated with future sales and purchases,

receivables and payables, as well as other assets expressed in currencies other than the Euro.

In the periods presented, the Company holds derivatives that are hedging the exchange rate risk of future operations in

currencies other than the presentation currency (see Note 8.2 - Derivative financial instruments).

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 549

Exposure of financial assets and liabilities to exchange rate risk and sensitivity analysis

31 December 2024

US dollar

Sterling

pound

Polish zloti

South African

rand

Swiss Franc

Total

(Euro)

Amounts in foreign currency

Cash and cash equivalents 291,472

3,892 33,392

1,038

1,828 295,058

Receivables

115,310,769

19,818,964

9,733,718

1,846,939

139,134,237

Total financial assets 115,602,241

19,822,856 9,767,110

1,038

1,848,767 139,429,295

Payables

(2,534,382)

(241,959)

(75,875)

(2,811,906)

Total financial liabilities

(2,534,382)

(241,959)

(75,875)

(2,811,906)

Financial net position in foreign

currency

113,067,859

19,580,897 9,767,110

1,038

1,772,892 136,617,389

Financial net position in Euro 108,834,208

23,614,772 2,284,704

1,883,651 136,617,388

Impact of + 10% change in all

exchange rates on net profit/(loss)

for the period

12,419,763

Impact of -10% change in all

exchange rates on net profit/(loss)

for the period

(15,179,710)

31 December 2023

US dollar

Sterling

pound

Polish zloti

South African

rand

Swiss Franc

Total

(Euro)

Amounts in foreign currency

Cash and cash equivalents

3,782,459

811,936

78,273

2,731

4,378,306

Receivables

120,943,141

21,697,447

14,349,866

1,572,289

139,422,401

Total financial assets 124,725,600

22,509,383 14,428,139

1,575,020 143,800,707

Payables

(6,517,284)

(48,356)

(70,250)

(6,029,501)

Total financial liabilities

(6,517,284)

(48,356)

(70,250)

(6,029,501)

Financial net position in foreign

currency

118,208,316

22,461,027 14,428,139

1,504,770 137,771,206

Financial net position in Euro 106,975,852

25,845,495 3,324,839

1,625,022 137,771,207

Impact of + 10% change in all

exchange rates on net profit/(loss)

for the period

12,524,654

Impact of -10% change in all

exchange rates on net profit/(loss)

for the period

(15,307,912)

In this Note, the Company discloses the exposure of financial assets and liabilities to exchange rate risk, as well as the respective

sensitivity analysis. There are currencies in which the Company has carried out transactions but in which, at the balance sheet

date, it does not have relevant foreign exchange exposures, which is why the exchange rates disclosed in Note 1.4.3 are more

numerous than the currencies presented in this note.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 550

8.1.2. Interest rate risk

Interest rate risk management policy

A significant share of the Company’s financial liabilities cost is indexed to short-term reference interest rates, which

are reviewed more than once a year (generally every six months for medium and long-term debt). Hence, changes in

interest rates can have an impact on the Company’s income statement.

The strategy for interest rate risk management is reviewed annually by the Company, and currently the Company

maintains the majority of its debt traded at fixed rate.

Use of derivative financial instruments

When deemed appropriate by the Board, the Company uses derivative financial instruments (Note 8.2), namely swaps,

with the purpose of fixing the interest rate on loans obtained, within certain parameters, deemed appropriate by the

Company's risk management policies.

Exposure to interest rate risk

As at 31 December 2024, approximately 11% (31 December 2023: 5%) of the Company’s financial liabilities are indexed to short-

term reference interest rates, revised in periods below one year (usually 6-month rates for long-term debt), plus duly negotiated

risk spreads. Hence, changes in interest rates can impact the Company’s earnings.

Navigator has favoured the contracting of fixed rate debt and has derivative financial instruments to cover its interest rate risk,

namely interest-rate swaps, with the purpose of fixing the interest rate on the Company’s borrowings within certain limits.

As at 31 December 2024 and 31 December 2023, the detail of the financial assets and liabilities with interest rate exposure,

considering the maturity or the next interest-fixing date is as follows:

Amounts in Euro

Up to 1 month

1-3 months

3-12 months

1-5 years

More than 5

years

Total

31 December 2024

Assets

Current

Cash and cash equivalents

406,735,567

Total financial assets

406,735,567

Liabilities

Non-current

Interest-bearing liabilities

10,000,000

80,000,000

90,000,000

Current

Interest-bearing liabilities

218,002,842

Total financial liabilities

218,002,842

10,000,000

80,000,000

308,002,842

Cumulative differential

188,732,725

178,732,725

98,732,725

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 551

Amounts in Euro

Up to 1 month

1-3 months

3-12 months

1-5 years

More than 5

years

Total

31 December 2023

Assets

Current

Cash and cash equivalents

310,150,771

Total financial assets

310,150,771

Liabilities

Non-current

Interest-bearing liabilities

23,500,000

Current

Interest-bearing liabilities 268,133,200

2,000,000

9,583,333

279,716,533

Total financial liabilities

268,133,200

2,000,000

9,583,333

23,500,000

303,216,533

Cumulative differential

42,017,571

40,017,571

30,434,238

6,934,238

From 2024 onwards, the tables above show assets and liabilities with exposure to interest rate risk, not including assets and

liabilities whose interest rate risk is fully covered by derivative financial instruments with a maturity and/or repricing identical to

the underlying. In order to make the information presented comparable, the appropriate changes were made to the table for the

homologous period, ensuring the consistency of the criteria adopted in preparing this disclosure. In liquidity risk note 8.1.3, the

contractual maturity of all financial liabilities is shown, regardless of whether interest rate risk is hedged through derivative

financial instruments.

Estimates and judgements

Sensitivity analysis

Navigator uses the sensibility analysis technique to measure impacts on the income statement and equity of increase or decrease

on interest rates maintaining the other variables constant. This is an illustrative analysis only since changes in market rates rarely

occur separately.

The sensitivity analysis is based on the following assumptions:

i) Changes in market interest rates affect interest income and expenses arising from variable financial

instruments;

ii) Changes in market interest rates affect the fair value of derivative financial instruments as well as other

financial assets or liabilities;

iii) Changes in fair value of derivative financial instruments and other financial assets and liabilities are

measured using the discounted cash flows method, with market interest rates at year end.

A 0.50% increase in interest rates on which interest on loans are calculated would have an impact on profit before taxes, for the

period ended 31 December 2024 by approximately Euro 462,500 (31 December 2023: Euro 175,417).

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 552

8.1.3. Liquidity risk

Liquidity risk management policy

The Company manages the liquidity risk in two ways:

i. ensuring that its financial debt has a high medium- and long-term component with maturities appropriate to

the characteristics of the industries where it operates, and

ii. by contracting with financial institutions credit facilities available at all times for an amount that guarantees

adequate liquidity.

Available but not used credits

The Company's policy is to maintain credit facilities at adequate levels to, together with the amount of Cash and Cash

Equivalents in order to guarantee, with some comfort margin, the cash cycle expected for the next 12 months.

Contractual maturity of financial liabilities (undiscounted flows, including interest)

Amounts in Euro

Up to 1 month

1-3 months

3-12 months

1-5 years

More than 5

years

Total

As at 31 December 2024

Liabilities

Interest

-bearing liabilities

Bond loans

420,000

10,521,500

99,941,464

392,316,564

210,017,643

713,217,171

Commercial paper

35,497,000

248,500

35,248,500

50,000,000

120,994,000

Bank loans

4,969,536

9,377,303

48,971,139

37,668,335

100,986,313

Derivative financial instruments

1,259,512

2,879,804

2,659,143

(783,753)

6,014,704

Total liabilities

420,000

52,247,548

112,447,071

479,195,346

296,902,225

941,212,188

Of which interest (at the rates prevailing at

that date)

76,725,262

Amounts in Euro

Up to 1 month

1-3 months

3-12 months

1-5 years

More than 5

years

Total

As at 31 December 2023

Liabilities

Interest

-bearing liabilities

Bond loans

420,000

10,721,500

30,895,000

432,923,500

474,959,999

Commercial paper

745,500

35,745,500

71,491,000

107,982,000

Bank loans

15,000,000

5,189,218

16,188,037

62,679,270

12,840,786

111,897,311

Derivative financial instruments

(10,087,985)

(14,934,263)

(25,022,248)

Total liabilities

15,420,000

16,656,218

72,740,553

552,159,507

12,840,786

669,817,062

Of which interest (at the rates prevailing at

that date)

63,327,406

The table considers the debt issued and the long-term debt contracted and not disbursed that will refinance the debt maturing in

2025 (Available and undrawn credit facilities).

The contractual maturity of the interest-bearing liabilities presupposes the fulfilment of financial

covenants, as detailed in Note 5.6 - Interest-bearing liabilities.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 553

Available and undrawn credit facilities

Amounts in Euro

31-12-2024

31-12-2023

Undrawn credit facilities

Commercial paper (with long term underwriting)

144,500,000

167,250,000

EIB Loan

115,000,000

Other credit facilities

45,450,714

5,450,714

304,950,714

287,700,714

Commercial paper used (Note 5.6)

120,000,000

105,000,000

Other credit facilities used

738,472,222

537,091,265

Contracted credit facilities (nominal value)

1,163,422,936 929,791,979

8.1.4. Credit risk

Credit risk management policy

The Company is exposed to credit risk on balances receivable from Trade receivables and other debtors and has adopted a

policy of managing risk coverage within certain levels through

credit insurance with a specialised independent company.

Most sales that are not covered by credit insurance are covered by bank guarantees and documentary credits, and any

exposure that is not covered remains within the limits previously approved by the Executive Committee.

However, the worsening of global economic conditions or adversities affecting only economies on a local scale may lead to

deterioration in the ability of the Company’s Customers to settle their liabilities, leading entities providing credit insurance to

significantly decrease the amount of credit facilities that are available to those Customers. This scenario may result in

limitations on the amounts that can be sold to some customers without directly incurring credit risk levels that are not

compatible with the risk policy in this area.

Cash equivalents

The Company adopts strict policies in approving its financial counterparties, limiting its exposure in accordance with an

individual risk analysis and within previously approved limits.

Maximum exposure to credit risk

The Company's maximum exposure to the credit risk of financial assets corresponds to their net amount, as follows:

Amounts in Euro

31-12-2024

31-12-2023

Non-current

Receivables (Note 4.2)

6,684 27,956

Current

Receivables (Note 4.2)

1,033,579,502 816,521,582

Cash and cash equivalents (Note 5.8)

406,735,567 310,150,771

1,440,321,753 1,126,700,309

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 554

Ageing structure of Trade receivables balances

As at 31 December 2024 and 2023, Trade receivables balances presented the following ageing structure, considering as reference

the maturity date of the outstanding amounts before impairments:

Amounts in Euro

31-12-2024

31-12-2023

Amounts not due

192,391,500

186,701,878

from 1 to 90

days

24,267,673

16,962,609

from 91 to 180 days

59,623

14,983

from 181 to 360 days

6,609

from 361 to 540 days

2,125

from 541 to 720 days

669

more than 721 days

216,728,199

203,679,470

Balances considered impaired

1,975,527

2,593,323

Impairment

(1,975,527)

(2,593,323)

Net balance of trade receivables (Note 4.2)

216,728,199

203,679,470

Trade receivables covered by credit insurance

178,533,257

172,422,513

Trade receivables covered by bank guarantees

2,000,000

1,300,000

Trade receivables covered by title retention agreements

1,873,390

7,046,082

Trade receivables covered by letters of credit / documentary remittances

33,593,182

22,910,875

Covered receivables

215,999,829

203,679,470

Available and

undrawn credit facilities

417,439,401

483,461,612

Credit hedging facilities contracted

633,439,230

687,141,082

The amounts shown above correspond to the amounts outstanding according to the contracted due dates.

Despite some delays in the settlement of those amounts, that does not result, in accordance with the available information, in the

identification of impairment losses other than the ones considered through the respective losses. These are calculated based on

the information periodically collected on the financial behaviour of the Company’s Customers, which allow, in conjunction with the

experience obtained in the client portfolio analysis and with the history of credit defaults, in the part not attributable to the

insurance company, to define the amount of losses to be recognised in the period. The guarantees in place for a significant part of

outstanding and long-term balances, justify the fact that no impairment loss has been recorded for those balances. The rules

defined by the credit risk insurance policy applied by the Company, ensure a significant hedge of all outstanding balances.

Movements in impairment losses in Trade receivables

Amounts in Euro

2024

2023

Accumulated impairment at beginning of the period (2,593,323) (5,893,593)

Changes due to:

Amounts recognised in the income statement (757,265) -

Reversal of unused amounts 1,378,213 3,214,133

Changes recognised in the income statement 620,948 3,214,133

Derecognition of uncollectible assets - 86,137

Exchange rate adjustment (3,152) -

Accumulated impairment at end of the period (1,975,527) (2,593,323)

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 555

Accounting policies

Impairment of debt instruments

The Company assesses, on a prospective basis, the expected credit losses associated with its financial assets

measured at amortised cost and at fair value through other comprehensive income, in accordance with IFRS 9.

On this basis, Navigator recognises expected credit losses throughout the lifetime of financial instruments that have been subject

to significant increases in credit risk since its initial recognition, assessed either individually or collectively, considering all

reasonable and sustainable information, including available prospective information.

If, at the reporting date, the credit risk associated with a financial instrument has not increased significantly since its initial

recognition, the Company measures the impairment of that financial instrument by an amount equivalent to the expected credit

losses.

IFRS 9 provides that for the calculation of these impairments, one of two models is used: the 3-step method or the use of a

matrix, the distinguishing component being the existence or not of a significant financing component. For Navigator's financial

assets, since it is not a financial institution and there are no assets that have a significant financing component, the use of a matrix

was chosen.

The model adopted for the impairment assessment in accordance with IFRS 9 is as follows:

i. Calculate the total credit sales made by the Group over the last 12 months, as well as the total amount of

bad debts relating to them;

ii. Determine the Customers’ payment profile, by setting buckets of receipt frequency;

iii. Based on I. and II. above, estimate the probability of default (i.e., the amount of bad debts calculated at I.

compared to the balance of outstanding sales in each bucket calculated at II);

iv. Adjust the percentages of future forecasts obtained in III.;

v. Apply the default percentages as calculated in IV. to the balances of customers still outstanding at the reporting date.

Although IFRS 9 assumes 90 days as “default”, Navigator considered a period of 180 days, since the experience of real losses

before this period is low. This period is aligned with the current risk management policies of the company, namely in what regards

the credit insurance hired, and to the fact that there is no sales with significant components of funding in light of IFRS 15.

Additionally, the company evaluated the impact of considering 180 days of “default” instead of the 90 days and the Expected

Credit Loss would not change significantly.

In the event of an accident in the credit insurance company, the model considers the limit paid, by Navigator, of 10% for national

Customers and 5% for international Customers.

In addition, the Company recognises impairment on a case-by-case basis, based on specific balances and specific past events,

considering the historical information of the counterparties, their risk profile and other observable data in order to assess whether

there are objective indicators of impairment for these financial assets. The Company uses the write-off procedure only when the

credit is considered to be definitely uncollectible by a court decision.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 556

8.2. Derivative financial instruments

Movements in derivative financial instruments

2024

2023

Trading

derivative

Hedge

derivative

Total net

Trading

derivative

Hedge

derivative

Total net

Balance at the beginning of the period

(4,068,868)

17,835,989

13,767,121

(3,106,233)

46,938,143

43,831,910

New contracts / settlements 4,987,261

(11,296,063)

(6,308,801)

(1,999) (9,722,523) (9,724,522)

Change in fair value through net profit/(loss)

(Note 5.10)

(2,549,705)

11,328,732

8,779,027

(960,636) 9,722,523 8,761,887

Change in fair value through other comprehensive

income (Note 5.5)

(1,526,544)

- (29,102,154) (29,102,154)

Balance at the end of the period

(1,631,312)

16,342,114

14,710,803

(4,068,868)

17,835,989

13,767,121

Hedging derivative contracts entered into for pulp and paper sales had a negative impact of Euro 5,714,356 on sales margin.

(2023: positive impact of Euro 1,973,497).

8.2.1. Detail and maturity of derivative financial instruments by nature

31 December 2024

Amounts in Euro

Notional

Currency

Maturity

Positive

(Note 4.2)

Negative

(Note 4.3)

Net amount

Hedging

Hedging (future sales)

272,000,000

USD

2025

(1,103,142)

Hedging (future sales)

130,000,000

GBP

2025

(262,405)

Interest rate swaps - Bonds

535,000,000

EUR

2031

8,383,516

(3,314,640)

5,068,875

Energy

24,653,150

EUR

2025

12,638,786

21,022,302

(4,680,188)

16,342,114

Trading

Foreign exchange forwards (future sales)

60,500,000

USD

2025

(1,597,132)

Foreign exchange forwards (future sales)

40,900,000

GBP

2025

(34,179)

(1,631,312)

21,022,302

(6,311,499)

14,710,803

31 December 2023

Amounts in Euro

Notional

Currency

Maturity

Positive

(Note 4.2)

Negative

(Note 4.3)

Net amount

Hedging

Hedging (future sales)

287,500,000

USD

2024

1,348,010

(608,036)

739,974

Interest rate swaps - Bonds

355,000,000

EUR

2028

17,064,360

BHKP pulp

7,092,000

USD

2024

31,655

18,444,025

(608,036)

17,835,989

Trading

Foreign exchange forwards (future sales)

(46,000,000)

USD

2024

1,014,913

(4,987,262)

(3,972,349)

Foreign exchange forwards (future sales)

(6,099,807)

GBP

2024

(96,519)

1,014,913

(5,083,781)

(4,068,868)

19,458,938

(5,691,817)

13,767,121

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 557

Cash flow hedge | Exchange rate risk EUR/USD

During the last 6 months of 2024, the Group contracted derivative financial instruments to hedge exchange rate risk, acquiring

USD 272,000,000 and GBP 130,000,000 in Zero Cost Collar, thus ensuring a significant level of hedging of the estimated exposure

for 2025.

Interest rate hedge

During the second quarter of 2024, the Company contracted two swaps in the amount of Euro 50,000,000 each to fix the interest

rate associated with the Navigator 2024-2029 bond loan and the Navigator 2024-2031 bond loan, in the amount of Euro

50,000,000, each, both starting in June 2024.

In the last quarter of 2024, the Company contracted two new swaps in the amount of Euro 50,000,000 each, to fix the interest

rate associated with the Navigator 2024-2031 bond loan in the amount of Euro 100,000,000, both starting in November 2024.

In this way, it was possible to hedge the interest rate risk on these credit lines.

Energy Hedging

In the first quarter of 2024, the Company entered into Swaps to fix the purchase price of electricity and natural gas for a volume

of approximately 199,740 MWh of electricity and 581,064 MWh of natural gas, starting in 2025.

Commodities Hedging – BHKP

As at 31 December 2024, Navigator had contracted derivatives in the amount of USD 7,092,000.

Estimates and judgements

Fair value of derivative financial instruments

Whenever possible, the fair value of derivatives is estimated on the basis of quoted instruments. In the absence of

market prices, the fair value of derivatives is estimated through the discounted cash-flow method and option valuation

models, in accordance with prevailing market assumptions.

Accounting policies

The fair value of derivative financial instruments is included under Payables (Note 4.3), when negative, and under

Receivables (Note 4.2), when positive.

In accordance with IFRS 9 - Financial Instruments, the Group has opted to continue applying the hedge accounting requirements

of IAS 39 - Financial Instruments, until there is greater visibility on the Dynamic Risk Management (macro hedging) project

currently in progress.

Whenever expectations of changes in interest or exchange rates so justify, the Group hedges these risks through derivative

financial instruments, such as interest rate swaps (IRS), interest rate and foreign exchange collars, forwards, etc.

Trading derivative financial instruments

Although the derivatives contracted by the Company represent effective economic hedges of risks, not all of them qualify as

hedging instruments in accounting terms to satisfy the applicable rules and requirements. Instruments that do not qualify as

hedging instruments are recorded in the Separate statement of financial position at their fair value and changes in fair value are

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 558

recognised in Net financial results (Note 5.10), when related to financing operations, or in External services and supplies (Note

2.3) or Revenue (Note 2.1), when referring to hedging of sales receivable flows in a currency other than the presentation currency.

Hedging derivative financial instruments

Derivative financial instruments used for hedging purposes may be recognised as hedging instruments provided that they comply,

cumulatively, with the conditions set out in IAS 39.

Cash flow hedging (interest rate, exchange rate and commodity risk - BHKP)

In order to manage its exposure to interest rate risk and exchange rate risk, the Company enters into cash flow hedges.

Those transactions are recorded in the Interim consolidated statement of financial position at their fair value, if considered

effective hedges. The effective portion of changes in the fair value of derivatives that are designated and qualify as cash flow

hedges is recognised in other comprehensive income. The gain or loss relating to the ineffective portion is recognised immediately

in the income statement.

Accumulated amounts in equity are reclassified to net profit/(loss) in the periods when the hedged item affects the Income

statement (for example, when the forecast sale that is hedged takes place). The gain or loss relating to the effective portion of

interest rate swaps hedging variable rate borrowings is recognised in the income statement under Net financial results (Note 5.10).

However, when the forecast transaction that is hedged results in the recognition of a non-financial asset (for example, inventory or

property, plant and equipment), the gains and losses previously deferred in equity are transferred from equity and included in the

initial measurement of the cost of the asset.

When a hedging instrument expires or is sold, or when a hedge no longer meets the criteria for hedge accounting, any cumulative

gain or loss existing in equity is recycled to the income statement, unless the hedged item is a forecast transaction, in which case

any cumulative gain or loss existing in equity at that time remains in equity and is recognised when the forecast transaction is

ultimately recognised in the income statement.

Derivative financial instruments used by Navigator Group

Foreign exchange trading derivatives

The Navigator Group has a currency exposure on sales invoiced in foreign currencies, namely US dollars (USD) and pounds sterling

(GBP). As the Group’s financial statements are presented in Euro, it is exposed to an economic risk on the conversion of these

currency flows to the Euro. The Group is also required, albeit to a lesser degree, to make certain payments in those same

currencies which, for currency exposure purposes, act as a natural hedge. Thus, the hedge is aimed at safeguarding the net value

of items in the statement of financial position denominated in a currency other than the presentation currency against the

respective currency fluctuations.

The hedging instruments used in this operation are foreign exchange forward contracts covering the net exposure to currencies

other than the presentation currency, for amounts and due dates close to that exposure. The nature of the risk hedged is the

change in the book value on sales and purchases expressed in currencies other than the presentation currency.

At the end of each month, the balances of Trade receivables and Trade payables expressed in foreign currency are updated, with

the gain or loss offset against the fair value change of the forwards negotiated.

Cash flow hedge | Exchange rate risk EUR/USD and EUR/GBP

The Company makes use of derivative financial instruments in order to limit the net exchange risk associated with sales and future

purchases estimated at USD and GBP.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 559

Cash flow hedge | Interest rate

Navigator hedges future interest payments associated with commercial paper issues by hiring an interest rate swap, which pays a

fixed rate and receives a floating rate. This instrument is designated as hedge of cash flows from the commercial paper

programme and the bond loan.

Cash flow hedge | Commodities - BHKP

Navigator uses derivative financial instruments in order to minimise the exposure risk associated with the variation of the pulp

price, indexed to PIX, in USD.

8.3. Financial assets and liabilities

8.3.1. Categories of Group Financial Instruments

The financial instruments included in each caption of the separate statement of financial position are classified as follows:

Amounts in Euro

Note

Financial

assets at

amortised cost

Derivative

financial

instruments -

hedging

Trading

derivative

financial

instruments

Non-

financial

assets

Total

31 December 2024

Non-current receivables 4.2 6,684 -

6,684

Current receivables 4.2 961,165,070 21,022,302

47,493,551

1,034,094,913

Cash and cash equivalents

5.8

406,735,567

Total assets

1,367,907,322 21,022,302

47,493,551

1,440,837,164

31 December 2023

Non-current receivables 4.2 27,956 -

27,956

Current receivables 4.2 757,523,435 18,444,025

1,014,913

39,539,209

816,521,582

Cash and cash equivalents 5.8 310,150,771 -

310,150,771

Total assets

1,067,702,163

18,444,025

1,014,913

39,539,209

1,126,700,309

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 560

Amounts in Euro

Note

Financial

liabilities at

amortised cost

Derivative

financial

instruments -

hedging

Trading

derivative

financial

instruments

Financial

liabilities

outside the

scope of

IFRS 9

Total

31 December 2024

Interest-bearing liabilities

5.6

1,073,032,204

Lease liabilities 5.7 - -

- 1,463,763 1,463,763

Payables 4.3 783,360,335 4,680,188

1,631,312 - 789,671,835

Total liabilities

1,856,392,539 4,680,188 1,631,312 1,463,763 1,864,167,801

31 December 2023

Interest-bearing liabilities

5.6

897,030,355

Lease liabilities

5.7

1,911,162

Payables 4.3 671,975,078 608,036

5,083,781 - 677,666,895

Total liabilities

1,569,005,433

608,036

5,083,781

1,911,162

1,576,608,412

8.3.1. Fair value of financial assets and liabilities

Financial assets and liabilities measured at fair value

31-12-2024

31-12-2023

Amounts in Euro

Level 1

Level 2

Level 3

Level 1

Level 2

Level 3

Financial assets at fair value through profit and loss

Trading derivatives

1,014,913

Hedging financial instruments

21,022,302

18,444,025

Total assets -

21,022,302 -

- 19,458,938

Financial liabilities at fair value through net profit/(loss)

Trading derivatives

(1,631,312)

(5,083,781)

Hedging financial instruments

(4,680,188)

(608,036)

Total liabilities

(6,311,499)

(5,691,817)

Estimates and judgements

Fair value of fixed-interest interest-bearing liabilities

The fair value of these liabilities is calculated using the discounted cash flow method at the reporting date, using a

discount rate in accordance with the characteristics of each financing, belonging to level 2 of the fair value hierarchy of

IFRS 13.

Accounting policies

The fair value of financial instruments is classified according to the fair value hierarchy of IFRS 13 - Fair Value

Measurement:

Level 1 Based on quotes from active net markets at the reporting date.

Level 2 Determined using evaluation models, the main inputs of which are observable in the market.

Level 3 Determined using evaluation models, the main inputs of which are not observable in the market.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 561

9. Provisions, commitments and contingencies

9.1. Provisions

Movements in provisions

Amounts in Euro

Legal proceedings

Investments in

subsidiaries

Other provisions

Total

1 January 2023

832,790

17,300,000

18,132,790

Increases

10,256

Reversals

(1,800,000)

Impact in net profit/(loss) for the period

10,256

(1,800,000)

(1,789,744)

Other transfers and adjustments

1,287

31 December 2023

843,046

1,287

15,500,000

16,344,333

Increases

94,728

Reversals

(71,098)

Impact in net profit/(loss) for the period

(71,098)

94,728

23,630

Other transfers and adjustments

256,781

31 December 2024

771,948

258,068

15,594,728

16,624,744

No repayments of any nature are expected in respect of these provisions.

Legal proceedings

The balance as at 31 December 2024 is essentially comprised of labour lawsuits. The outcome of provisions for legal proceedings

depends on the labour or civil court decisions.

Investments in subsidiaries

The amount recognised as provisions for subsidiaries relates solely to the shareholding in the subsidiary Navigator Paper Southern

Africa, Navigator Paper Mexico and Navigator Tissue Ibérica (Note 10).

Other provisions

The amount presented includes provisions to cover risks related to events of a different nature, the resolution of which may result

in outflows of cash, in particular organisational restructuring processes, risks of contractual positions assumed in investments,

among others.

In 2024, Other provisions include Euro 15,594,728 related to the Mozambique project. Although the Memorandum of

Understanding (MoU) signed with the Mozambican Government provided for a “best effort” commitment to create the necessary

conditions to carry out the investment until last 31 December 2018, that was not possible until 31 December 2024, and both

parties continued to work towards that goal.

The Group's uncertain income tax positions are disclosed in Note 6.1 - Income Tax.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 562

Accounting policies

Provisions are recognised whenever the Company has a present legal or constructive obligation, as a result of past

events, in which it is probable that an outflow of resources will be required to settle the obligation and the amount

has been reliably estimated.

Provisions for future operating losses are not recognised. Provisions are reviewed on the date of the statement of financial position

and are adjusted to reflect the best estimate at that date.

Investments in subsidiaries

Provisions are recognised for the Company's liabilities for losses on investments in subsidiaries (Note 10), after the related book

value has been reduced to zero, to the extent that the Company may have incurred legal or constructive obligations or made

payments on behalf of such subsidiaries.

9.2. Commitments

Guarantees provided to third parties

Amounts in Euro

31-12-2024

31-12-2023

Guarantees provided

Navigator guarantees for EIB loans 11,666,667

22,083,333

Ocean Network Express

2,751,947

Simria

338,829

Tax and Customs Authority

9,288,070

Administration Fédérale de Contributions

76,585

Other

56,074

74,473

24,178,172

25,325,168

Moreover, the Company has entered into energy purchase commitments amounting to Euro 103,786,050 (2023: Euro

125,753,200).

9.3. Contingent assets and liabilities

Public debt settlement fund

According to Decree-Law 36/93 of 13 February, the tax debts of privatised companies relating to periods prior to the privatisation

date (25 November 2006) are the responsibility of the Public Debt Settlement Fund (FRDP). The Navigator Company applied to the

FRDP on 16 April 2008, requesting the payment of the tax debts until then settled by the Tax Authorities. On 13 December 2010,

the company filed a new request for payment of debts assessed by the Tax Authorities for the periods of 2006 and 2003, which

was supplemented, on 13 October 2011, with the amounts already paid and uncontested relating to these same debts, as well as

the expenses directly related thereto, pursuant to the ruling dated 24 May 2011 (Case 0993A/02), which confirmed the company's

position regarding the enforceability of such expenses.

On 13 December 2017, The Navigator Company, S.A. has made an extra-judicial agreement with the Tax Authorities, in which it

was acknowledged the FRDP responsibility for refunding the amount of Euro 5,725,771 corresponding to the amount of Corporate

Income Tax (IRC) unduly paid, resulting from the alleged qualification/incorrect consideration, by the Tax Authorities, of the tax

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 563

loss calculated as a result of the operations performed by Soporcel, S.A. in 2003, as well as to promote the reimbursement to

Navigator of the mentioned amount.

In this context, FRDP is liable for Euro 21,853,377, detailed as follows:

Amounts in Euro

Period

Requested

amounts

Decrease due

to RERD

Proceedings

decided in

favour of the

Group

Outstanding

amounts

Proceedings confirmed in court

Corporate income tax

2002

18,923

Corporate income tax (FR)

2004

3,324

Corporate income tax

2004

766,395

(111,544)

654,851

Expenses

314,957

(314,957)

1,103,599

(426,501)

677,098

Proceedings not confirmed in court

Corporate income tax

2005

11,754,680

(1,360,294)

10,394,386

Corporate income tax

2006

11,890,071

(1,108,178)

10,781,893

23,644,751

(2,468,472)

21,176,279

24,748,350

(2,468,472)

(426,501)

21,853,377

Regarding the aggregate corporate income tax proceedings of 2005 and 2006, if Courts come to a decision in favour of Navigator

Group, the Group will withdraw the request made to FRDP.

Public Debt Settlement Fund - proceeding 774/11.3 BEALM

Additionally, a new petition was filed in the Administrative Court of Almada on 11 October 2011, which called for the repayment of

various amounts, amounting to Euro 136,243,949. These amounts regard adjustments in the financial statements of the Group

after its privatisation that had not been considered in formulating the price of its privatisation as they were not included in the

documentation made available for consultation by the bidders.

On 24 May 2014, the Court denied the Navigator Group’s proposal to present testimony evidence, alternatively proposing written

submissions. On 30 June 2014, the Group appealed against this decision, but continuously presented written evidence. The Court

subsequently confirmed the Navigator Group’s views on this matter, both parts appointed experts and the partial expert report was

issued on July 2017, being required either by The Navigator Company, S.A. either by the Ministério das Finanças, the attendance

of both designated experts in court hearing, in order to provide oral explanations on the expert report.

Following claims filed by Navigator on 11 September 2017 and 15 January 2019, the experts submitted redrafted Expert Reports

on 27 December 2018 and 19 March 2019, respectively.

The trial hearing sessions took place between May and June 2019, with the parties filing closing arguments in September 2019.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 564

10. Group structure

10.1. Investments in subsidiaries

31/12/2024

31/12/2023

Company

Head Office

Equity

% held

Balance

Equity

% held

Balance

Navigator Brands, S.A. (A) Portugal 32.980.074

100

409.736.461

32.643.937

100

409.400.324

Navigator Pulp Aveiro, S.A. (B) Portugal 127.514.690

100

126.968.573

106.248.123

100

106.123.853

Enerpulp, S.A. Portugal 74.815.748

100

74.815.748

74.509.637

100

74.509.637

Navigator Parques Industriais, S.A. Portugal 83.849.012

100

83.849.012

85.415.275

100

85.415.275

Portucel Moçambique, S.A. Moçambique 9.867.605

9.867.605

11.122.922

Navigator Tissue Ibérica (E) Espanha (257.003) 100

(257.003)

Navigator Pulp Setúbal, S.A. Portugal 83.278.156

100

83.278.156

72.929.757

100

72.929.757

Navigator Pulp Figueira, S.A. Portugal 207.462.036

100

207.462.036

188.359.928

100

188.359.927

Navigator Abastecimento de Madeira, ACE Portugal -

Navigator Forest Portugal, S.A. Portugal 57.395.214

100

57.395.214

59.013.396

100

59.013.396

Navigator Paper Setúbal, S.A. (B) Portugal 405.437.380

100

390.428.273

420.074.069

100

415.217.443

Navigator Tissue Aveiro, S.A. (B) Portugal 128.368.371

100

128.294.779

135.189.631

100

134.813.112

Raíz - Inst.Investigação Floresta e Papel Portugal 12.011.573

11.651.225

10.900.584

10.573.566

Navigator Tissue Ejea, S.L. (C) Espanha 81.744.640

100

85.737.531

68.206.977

100

72.363.519

Navigator Paper Figueira, S.A. (B) Portugal 89.834.744

100

77.061.617

102.186.284

100

98.565.420

Pulpchem Logistics, A.C.E. Portugal -

Empremédia - Corretores de Seguros, S.A. Portugal 5.460.865

100

5.460.865

5.193.421

100

5.193.421

Empremedia DAC Irlanda 7.651.039

100

7.651.040

7.828.845

100

7.828.845

Empremedia RE DAC (E) Irlanda 19.093.632

100

19.093.632

Navigator Paper Mexico México (2.076) 25

(519)

2.698

674

Navigator Egypt Egipto 33.541

335

35.229

352

Navigator Green Fuels Setúbal, S.A. Portugal 35.515

100

35.515

48.339

100

48.339

Navigator Green Fuels Figueira da Foz, S.A. Portugal 38.610

100

38.610

48.339

100

48.339

Navigator Fiber Solutions , S.A. (D) Portugal -

2.049

Navigator Paper Southern Africa Africa do Sul (54.639) 1

(546)

(128.742) 1

(1.287)

Portucel Nigeria Limited Nigeria -

1.778.568.159

1.751.526.836

Provisões para participadas com

situação líquida negativa

258.068

1.287

Investimentos em subsidiárias

1.778.826.227

1.751.528.123

(A) Includes Goodwill generated on the acquisition of the Figueira da Foz integrated pulp and paper business

(B) Balance sheet value reflects elimination of unrealised internal margins

(D) Shareholding disposed of in 2024.

(E) Shareholding disposed of in 2024.

The goodwill associated with the integrated pulp and paper production activity in Figueira da Foz, in the amount of Euro

376,756,383, and with the tissue production activity in Zaragoza, in the amount of Euro 4,156,542, is disclosed in the table above

as part of the value of the financial investment under the equity method, in accordance with the requirements of IAS 27 and IAS

28.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 565

Movements in the period

Movements in investments in subsidiaries - summary

Amounts in Euro

2024

2023

Opening balance

1,751,528,123

2,093,159,574

Acquisitions, incorporations and disposal of shareholdings

15,266,674

58,651,861

Mergers, demergers and liquidations

(1,838,305)

Additional capital contributions

4,000,000

36,300,000

Share of (loss)/gains from the

application of the equity method

192,493,281

224,727,140

Other comprehensive income

9,086,118

1,013,513

Dividends distributed

(193,804,947)

(295,340,074)

Capital increases and decreases

197

(372,038,000)

Transfer to provisions (Note 9.1)

256,781

1,287

Other movements

6,891,127

Closing balance

1,778,826,227

1,751,528,123

In 2024, gratuitous pecuniary instalments of Euro 4,000,000 were made to the subsidiary Portucel Moçambique, S.A..

In 2023, the General Shareholders Meeting approved the increase in Navigator Forest Portugal, S.A.'s equity through the payment

of additional pecuniary and gratuitous capital contributions in the amount of Euro 25.000.000. Also for the subsidiary Portucel

Moçambique, S.A., in that year, additional pecuniary and gratuitous capital contributions were made in the amount of Euro

4,000,000, and shareholder loans were also converted into additional capital contributions in the amount of Euro 7,300,000.

Movements in investments in subsidiaries - details

Amounts in

Euro

2024

2023

Opening balance

1,751,528,123

2,093,159,574

Mergers, demergers and liquidations

Soc. Vinhos Herdade Espirra, S.A.

(1,838,305)

Mergers, demergers and liquidations

(1,838,305)

Additional capital contributions

Navigator Forest Portugal, S.A.

25,000,000

Portucel Moçambique, Lda.

4,000,000

11,300,000

Additional capital contributions

4,000,000

36,300,000

Acquisition, incorporation and disposal of shareholdings

Navigator Tissue Ejea, S.L.

58,551,811

Empremedia RE DAC

15,165,286

Navigator Tissue Ibérica

101,097

Navigator Green Fuels Setúbal, S.A.

50,000

Navigator Green Fuels Figueira da Foz, S.A.

50,000

Navigator Fiber Solutions, S.A.

291

Acquisition, incorporation and disposal of shareholdings

15,266,674

58,651,861

Share of (loss)/gains from the application of the equity method

Navigator España, S.A.

17,330,104

19,937,534

Navigator Pulp Aveiro, S.A.

29,746,942

12,990,920

Enerpulp, S.A.

14,843,057

14,586,595

Navigator Parques Industriais, S.A.

9,554,678

7,526,789

Portucel Moçambique, Lda.

(4,414,843)

(3,275,767)

Navigator Paper Southern Africa

490

(1,287)

Navigator Pulp Setúbal, S.A.

23,348,730

17,362,431

Navigator Pulp Figueira, S.A.

38,028,653

21,604,252

Navigator Forest Portugal, S.A.

727,212

3,053,803

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 566

Amounts in Euro

2024

2023

Navigator Tissue Aveiro, S.A.

33,356,224

41,459,179

Navigator Paper Setúbal, S.A.

2,668,095

39,734,372

Raiz - Inst.Investigação Floresta e Papel

1,164,575

818,765

Navigator Tissue Ejea, S.L.

14,529,078

13,811,707

Navigator Paper Figueira, S.A.

6,945,092

29,914,903

Navigator Tissue Ibérica

(358,100)

Empremédia - Corretores de Seguros, S.A.

1,295,243

1,161,734

Empremedia RE DAC

3,928,346

Empremedia DAC

(177,805)

4,034,429

Navigator Paper Mexico

333

10,217

Navigator Egypt

(66)

Navigator Green Fuels Setúbal, S.A.

(12,824)

(1,661)

Navigator Green Fuels Figueira da Foz, S.A.

(9,729)

(1,661)

Navigator Fiber Solutions , S.A.

(294)

(48)

Share of (loss)/gains from the application of the equity method

192,493,281

224,727,140

Changes in the investee's equity not recognised in the income statement

Soc. Vinhos Herdade Espirra, S.A.

352

Navigator España, S.A.

899,567

3,036,349

Navigator Forest Portugal, S.A.

(15,024)

1,489,984

Navigator Paper Setúbal, S.A.

9,129,629

(3,842,014)

Navigator Pulp Figueira, S.A.

Raiz

- Inst.Investigação Floresta e Papel

(86,916)

149,831

Portucel Moçambique, S.A.

(840,474)

1,733,087

Navigator Paper Southern Africa

Empremédia

- Corretores de Seguros, S.A.

849

11,704

Empremedia DAC

(1,548,341)

Navigator Paper Mexico

(1,527)

(17,628)

Navigator Egypt

(40)

180

Changes in the investee's equity not recognised in the

income statement

9,086,118

1,013,513

Distribution of dividends/reserves

Navigator España, S.A.

(17,893,533)

(21,774,546)

Navigator Pulp Aveiro, S.A.

(8,902,223)

(27,747,883)

Navigator Parques Industriais, S.A.

(11,120,940)

(6,646,121)

Navigator Forest Portugal, S.A.

(2,330,370)

(10,735,721)

Navigator Pulp Setúbal, S.A.

(13,000,331)

(53,600,000)

Navigator Pulp Figueira, S.A.

(18,926,544)

(41,772,835)

Navigator Paper Setúbal, S.A.

(36,586,894)

(30,541,422)

Navigator Tissue Aveiro, S.A.

(39,874,557)

(21,483,691)

Navigator Paper Figueira, S.A.

(28,448,895)

(67,150,000)

Empremédia - Corretores de Seguros, S.A.

(1,028,647)

(835,265)

Navigator Tissue Ejea, S.L.

(1,155,065)

Enerpulp, S.A.

(14,536,945)

(13,052,590)

Distribution of dividends/reserves

(193,804,947)

(295,340,074)

Share capital increases/(decreases)

Navigator Parques Industriais, S.A.

(42,988,000)

Navigator Paper Setúbal, S.A.

(205,000,000)

Navigator Pulp Setúbal, S.A.

(124,050,000)

Navigator Paper Southern Africa

197

Share capital increases/(decreases)

197

(372,038,000)

Other movements and reclassifications

6,891,127

Closing balance

1,778,569,446

1,751,526,836

Provisions for subsidiaries (Note 9.1)

256,781

1,287

Closing balance considering Provisions

1,778,826,227

1,751,528,123

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 567

Estimates and judgements

As at 31 December 2024 the amount of equity interests recognised in the separate financial statements of The

Navigator Company, S.A., by applying the equity method amounts to Euro 1,779 million (2023:

Euro 1,751 million), which includes goodwill allocated to the integrated paper cash-generating unit in Figueira da Foz and the

tissue paper cash-generating unit in Zaragoza. Goodwill is not amortised and is subject to impairment tests, at least annually, and

whenever there are changes in the assumptions underlying the test performed at the date of the statement of financial position

which result in a possible loss of value. The recoverable amounts of cash-generating units have been determined based on value-

in-use calculations. These calculations require the use of estimates.

As at 31 December 2024, a possible increase of 0.5% in the discount rate used in the impairment test of Goodwill allocated to the

cash-generating unit in Figueira da Foz integrated Paper, would imply a decrease in the assessment in the amount of Euro

273,710,850 (31 December 2023: Euro 214,028,739), which is still approximately 4 times higher than the book value of this

cash-generating unit.

Moreover, the 0.5% increase in the discount rate used in the impairment test for Navigator Tissue Ejea would imply a decrease in

the valuation as at 31 December 2024 of Euro 15,985,812, which is still around 2 times higher than the book value of this cash-

generating unit.

Accounting policies

Subsidiaries are all entities over which the Company has control, which occurs when the Company is exposed or

entitled to the variable returns resulting from its involvement with the entities and has the capacity to affect that

return through the exercise of power over the entities, regardless of the percentage they hold over equity.

The existence and the effect of potential voting rights which are currently exercisable, or convertible are considered when the

Company assesses whether it has control over another entity.

Measurement

Investments in subsidiaries are accounted under the equity method.

In accordance with the equity method, financial investments are recorded at their acquisition cost, subsequently adjusted by the

amount corresponding to the Company's share of changes in shareholders' equity (including net profit/(loss)) of the subsidiaries,

against results for the period or against shareholders' equity, as applicable, and by dividends received.

The accounting policies of joint ventures are amended, when necessary, to ensure that they are applied consistently with those of

Navigator.

When the Company’s share in the subsidiary’s losses is equal to or exceeds its investment in the subsidiary, the Company ceases

to recognise additional losses, except where it has assumed liability or made payments in the subsidiary’s name, as detailed in

Note 9.1 - Provisions. If they subsequently report profits, the Company resumes recognising its share of those profits only after its

share of the profits equals the share of unrecognised losses.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 568

10.2. Transactions with related parties

Balances with related parties

31-12-2024

31-12-2023

Cash – Cash

Pooling

Receivables

Payables

Interest-

bearing

liabilities –

Cash Pooling

Cash –

Cash

Pooling

Receivables

Payables

Interest

bearing

liabilities –

Cash Pooling

Shareholders

Semapa – Soc. de Investimento e Gestão, SGPS, S.A.

1,155,456

956,804

Subsidiaries

Portucel Moçambique, Lda.

8,777,898

179,039

7,962,778

179,039

Soc. Vinhos Herdade Espirra, S.A.

Eucaliptusland, S.A.

549,394

4,341,162

19,636,644

986,623

19,738,746

7,940,382

Enerpulp, S.A.

13,144,987

8,256,303

22,015,848

21,151

12,085,595

Navigator Forest Portugal, S.A.

544,841

177,844,533

44,669

3,304,198

4,189,275

177,428,142

14,311,715

4,354,853

Empremédia, S.A.

394,980

2,500,000

348,905

2,500,000

Navigator Tissue Aveiro, S.A.

13,335,910

124,992,364

26,337,286

1,030,176

118,950,221

11,056,819

19,828,089

Viveiros Aliança, S.A.

1,629,545

21,084

115,247

1,098,500

13,415

23,155

Navigator Paper Setúbal, S.A.

8,024,351

81,074,841

64,083,164

29,403,323

43,037,658

65,939,575

111,673,946

Navigator Paper Figueira, S.A.

18,657,449

52,002,492

95,496,936

23,187,277

52,052,846

98,180,797

Navigator Pulp Setúbal, S.A.

64,419,401

26,437,895

18,519,994

20,279,862

11,259,662

21,224,420

Navigator Tissue Ródão, S.A.

23,252,539

117,668,427

21,514,273

168

14,747,039

130,985,491

3,848,014

Navigator Pulp Figueira, S.A.

22,061,407

40,712,675

56,588,888

6,833,461

6,833,962

42,229,134

19,850,089

Raiz - Instituto de Investigação da Floresta e Papel

203,372

6,474,989

1,853,006

125,753

6,489,243

1,437,234

Navigator España, S.A.

6,986,203

10,709,598

32,627,521

28,092,201

32,366,089

38,671,413

Navigator Pulp Aveiro, S.A.

24,719,288

13,561,674

39,022,990

52,106,399

4,930,641

13,955,564

Navigator Parques Industriais, S.A.

6,460,821

58,469

18,383,729

11,589,317

609,665

19,141,996

Navigator Abastecimento de Madeira, ACE

5,921,193

319,462

192,245

18,358,609

27,358,071

132,356

877,541

27,723,654

Bosques do Atlantico, S.L.

5,565,479

28,848,149

178,975

PulpChem Logístics, ACE

2,309,328

877,377

Navigator North America

4,862,273

17,141,844

12,021

58,349,528

Navigator Eurasia

34,540

25,208

Navigator Afrique du Nord

23,072

15,584

Navigator United Kingdom, Ltd

203,005,905

18,400,507

17,301,073

Gavião - Sociedade de Caça e Turismo, S.A.

19,772

1,335,146

192,451

17,996

1,336,474

Navigator Tissue Ibérica

11,167,315

11,769,427

14,907,513

2,723,669

Navigator Tissue UK Limited

3,644,227

Navigator France, SAS

2,469

Navigator Itália, SRL

Navigator Deutschland, GmbH

15,141

1,753

Navigator Austria

80,941

10,083

Navigator Africa SRL

2,000

Navigator Paper Poland SP Zoo

21,364

9,332

Navigator Tissue Ejea, S.L.

20,668,217

8,352,301

27,290,21

Navigator Egypt, ELLC

Navigator Paper Southern Africa

4,248,982

144,430

128,742

Navigator Tissue France

9,793,430

964,397

Empremedia DAC

40,000

7,501,300

7,491,858

100

EMA Cacia - Engenharia e Manutenção Industrial, ACE

539

248,402

219

150,601

EMA Setúbal - Engenharia e Manutenção Industrial, ACE

943

386,097

257

230,822

EMA Figueira - Engenharia e Manutenção Industrial, ACE

1,041

382,281

750

379,599

Navigator Green Fuels Setúbal, S.A.

1,890

48,130

Navigator Green Fuels Figueira da Foz, S.A.

2,003

35,553

48,130

Navigator Fiber Solutions, S.A.

418,989

11,135

224

44,670

148

14,025

Other related parties

Secil Britas, S.A.

19,709

6,082

Hotel Ritz, S.A.

- - 844

1,672

148,906,476

741,564,182

556,708,726

218,002,842

165,486,549

550,417,915

571,088,257

268,133,200

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 569

Transactions with related parties

2024

2023

Amounts in Euro

Purchase of

goods and

services

Sales and

services

rendered

Payroll

costs

Other

operating

income

Financial

(expenses)/

income

Purchase of

goods and

services

Sales and

services

rendered

Payroll

costs

Other

operating

income

Other

operating

expenses

Financial

(expenses)/

income

Shareholders

Semapa - Soc. Inv. e Gestão, SGPS, S.A.

11,523,914

9,730,534

11,523,914

9,730,534

Subsidiaries

Eucaliptusland, S.A.

1,870,732

(1,128,473)

477,942

(1,018,275)

Enerpulp, S.A.

(190,811)

3,678,536

(108,599)

242,365

(216,984)

3,821,165

(100,050)

183,888

Navigator España, S.A.

23,547,789

3,389,624

2,892,199

996

(2,166,667)

22,836,745

3,614,698

3,211,813

(1,776,882)

Navigator Forest Portugal, S.A.

(25,078)

1,501,002

(617,250)

7,435,913

(11,129)

691,259

(477,898)

(7,540)

264

7,532,631

Empremédia, S.A.

28,336

13,035

Navigator Tissue Aveiro, S.A.

114,360,950

67,949,389

4,214,637

115,236,411

55,660,935

4,409,273

Viveiros Aliança, S.A.

364,189

57,783

206,340

26,181

Navigator Paper Setúbal, S.A.

531,133,392

381,206,558

(7,591,524)

48,789

(3,598,687)

544,360,541

346,969,016

(6,581,076)

(6,400,644)

Navigator Tissue Ejea, S.L.

60,285,712

47,233,292

970,670

18,451,438

970,322

PulpChem Logístics, ACE

26,513,779

30,033,011

Navigator Pulp Setúbal, S.A.

276,956,633

45,895,237

(4,916,247)

2,162,743

256,271,792

40,816,709

(4,597,528)

(3,968,120)

Navigator Tissue Ródão, S.A.

115,722,989

65,158,826

(93,447)

(6,617,503)

123,970,800

64,860,817

(90,552)

(4,830,849)

Navigator Pulp Figueira, S.A.

403,696,768

58,915,884

(7,194,124)

(104,098)

384,802,531

58,339,089

(6,797,105)

501

(1,799,480)

Raiz

(6,598)

214,576

(145)

(331,779)

2,820

309,293

(56,837)

(286,781)

Navigator United Kingdom, Ltd

19,289,001

1,556,091

4,391,042

19,321,400

Navigator Tissue Ibérica

1,766,063

49,976,837

1,282,063

52,736,006

Navigator Paper Figueira, S.A.

484,386,102

380,886,900

(1,732,490)

438,089,123

331,413,041

(1,622,832)

Navigator Pulp Aveiro, S.A.

244,106,884

32,111,651

(2,448,841)

1,963,359

205,362,516

28,918,450

(2,361,485)

1,715,993

Navigator Parques Industriais, S.A.

2,856,483

(718,948)

2,547,324

(1,923,467)

Navigator North America

300,269

73,956,435

(953,229)

37,220,675

Portucel Moçambique, Lda.

(8,864)

(537)

9,814

(8,277)

16,560

Bosques do Atlantico, S.L.

(1,498)

(2,701)

Empremedia DAC

44,232

75,698

Navigator Afrique du Nord

1,882

8,459

Gavião, S.A.

(73,406)

(63,028)

Navigator Itália, SRL

160

Navigator France SAS

2,469

Navigator Paper Southern Africa

3,733,201

(128,766)

128,742

Navigator Deutschland, GmbH

105,606

79,111

Navigator Austria

3,093

16,006

Navigator Paper Poland SP Zoo

6,929

17,457

Navigator Eurasia

9,332

9,959

Navigator Abastecimento de Madeira, ACE

(31,670)

346

(352,327)

438,732

(42,914)

(782,889)

(411,030)

303,842

Navigator Green Fuels Setúbal, S.A.

(1,890)

Navigator Green Fuels Figueira da Foz, S.A.

(2,003)

Navigator Fiber Solutions, S.A.

(20,087)

(900)

6,005

(148)

Navigator Tissue France

865,681

59,798,139

471,828

Navigator Tissue UK Limited

3,770,847

EMA Cacia, ACE

(8,576)

(7,758)

EMA Setúbal, ACE

(12,982)

(10,363)

EMA Figueira, ACE

(15,510)

(13,023)

2,303,117,201

1,284,104,495

(20,431,743)

557,400

5,442,805

2,141,573,358

1,046,536,795

(18,261,748)

190,144

264

(8,490,787)

Other related parties

Secil Britas, S.A.

37,750

68,865

Hotel Ritz, S.A.

7,806

3,836

1,106

45,556

72,701

1,106

The remuneration of the Group's key management personnel is detailed in Note 7.3 - Remuneration of corporate bodies.

RELATÓRIO ANUAL 2024 • DEMONSTRAÇÕES FINANCEIRAS SEPARADAS 570

11. Explanation added for translation

These financial statements are a translation of the financial statements originally issued in Portuguese. In the event of

discrepancies, the Portuguese language version shall prevail.

RELATÓRIO ANUAL 2024 • DEMONSTRAÇÕES FINANCEIRAS SEPARADAS 571

BOARD OF DIRECTORS

Ricardo Miguel dos Santos Pacheco Pires

Board of Directors Chairman

António José Pereira Redondo

Chairman of the Executive Committee

José Fernando Morais Carreira de Araújo

Executive Committee Member

Nuno Miguel Moreira de Araújo Santos

Executive Committee Member

João Paulo Cabete Gonçalves Lé

Executive Committee Member

Dorival Martins de Almeida

Executive Committee Member

António Quirino Vaz Duarte Soares

Executive Committee Member

Maria Teresa Aliu Presas

Member

Mariana Rita Antunes Marques dos Santos

Member

Sandra Maria Soares Santos

Member

Vítor Paulo Paranhos Ferreira

Member

Ana Teresa Cunha de Pinto Tavares Lehmann

Member

Hugo Alexandre Lopes Pinto

Member

Maria Isabel da Silva Marques Abranches Viegas

Member

RELATÓRIO ANUAL 2024 • DEMONSTRAÇÕES FINANCEIRAS SEPARADAS 572

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 573

STATUTORY AUDITORS’ REPORT and AUDITORS’ REPORT

REPORT ON THE AUDIT OF THE FINANCIAL STATEMENTS

Opinion

We have audited the accompanying financial statements of The Navigator Company, S.A.

(the Entity), which comprise the separate statement of financial position as at 31 December

2024 (showing a total of 3,277,865,315 euros and total equity of 1,355,728,837 euros,

including a profit for the year attributable to shareholders of 286,948,195 euros), and the

separate income statement, separate statement of comprehensive income, statement of

changes in equity and separate statement of cash flows for the year then ended, and the

accompanying notes to the financial statements, including a summary of accounting policies.

In our opinion, the accompanying financial statements give a true and fair view, in all

material respects, of the financial position of The Navigator Company, S.A. as at 31

December 2024 and of its financial performance and its cash flows for the year then ended

in accordance with the International Financial Reporting Standards (IFRS) as adopted by the

European Union.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (ISAs) and

further technical and ethical standards and guidelines as issued by Ordem dos Revisores

Oficiais de Contas (the Portuguese Institute of Statutory Auditors). Our responsibilities under

those standards are further described in the “Auditors’ Responsibilities for the Audit of the

Financial Statements” section below. We are independent from the Entity under the terms of

the law, and we comply with the other ethical requirements under the code of ethics of the

Portuguese Institute of Statutory Auditors.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide

a basis for our opinion.

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most

significance in our audit of the financial statements of the current year. These matters were

addressed in the context of our audit of the financial statements as a whole, and in forming

our opinion thereon, and we do not provide a separate opinion on these matters.

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 574

Valuation of financial investments (1,778,826,227 euros)

See Note 1.5 Significant accounting estimates and judgements and Note 10.1 of the notes to the

Financial Statements

The Risk

Our response to the identified risk

The valuation of the Entity's financial

investments requires a high degree of

estimation and judgement by the Board of

Directors, particularly with regard to

determining the recoverable value of

investments made when signs of impairment

are identified.

Our audit procedures included, amongst

others, those that we describe below:

• We assessed the design and

implementation of the main controls

implemented by the Entity in this regard,

namely the budgeting procedures on

which the forecasts are based, by

reference to the comparison of current

performance with estimates made in

previous periods, and the integrity of the

discounted cash flow model;

• We assessed the existence of signs of

impairment in financial investments;

• We obtained and analysed the

impairment tests of the financial

investments, based on discounted cash

flow models, carrying out the following

procedures:

We verified the arithmetic accuracy

of the models;

We assessed the significant internal

and external assumptions used and

their reasonableness, such as

current business trends, market

performance, inflation, forecasted

economic growth and discount rates;

We conducted sensitivity analyses of

the assumptions and forecasts used;

and

We involved our specialists in

assessing the average cost of

capital;

 We assessed the adequacy of the

respective disclosures to the financial

statements, in accordance with the

applicable accounting framework.

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 575

Responsibilities of Management and the Supervisory Body for the Financial

Statements

Management is responsible for:

• the preparation of financial statements that give a true and fair view of the Entity’s

financial position, financial performance and the cash flows, in accordance with the

International Financial Reporting Standards (IFRS) as adopted by the European Union;

• the preparation of the management report, the corporate governance report and the

remunerations’ report in accordance with applicable laws and regulations;

• the designing and maintaining an appropriate internal control system to enable the

preparation of financial statements that are free from material misstatement, whether due

to fraud or error;

• adopting accounting policies and criteria appropriate in the circumstances; and

• the assessment of the Entity’s ability to continue as a going concern, and disclosing, as

applicable, the matters that may cast significant doubt about the Entity’s ability to

continue as a going concern.

The supervisory body is responsible for overseeing the Entity’s financial reporting process.

Auditor´s Responsibilities for the Audit of the Financial Statements

Our responsibility is to obtain reasonable assurance about whether the consolidated

financial statements as a whole are free from material misstatements whether due to fraud

or error, and to issue an auditors’ 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 financial statements.

As part of an audit in accordance with ISA, we exercise professional judgment and maintain

professional scepticism throughout the audit. We also:

• identify and assess the risks of material misstatement of the 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 Entity’s internal control;

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 576

• evaluate the appropriateness of accounting policies used and the reasonableness of

accounting estimates and related disclosures made by management;

• conclude on the appropriateness of management’s 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 Entity’s ability

to continue as a going concern. If we conclude that a material uncertainty exists, we are

required to draw attention in our auditors’ report to the related disclosures in the 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 auditors’ report. However,

future events or conditions may cause the Entity to cease to continue as a going

concern;

• evaluate the overall presentation, structure and content of the financial statements,

including the disclosures, and whether the financial statements represent the underlying

transactions and events in a manner that achieves fair presentation;

• communicate with those charged with governance, including the supervisory body,

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;

• determine, from the matters communicated with those charged with governance,

including the supervisory body, those matters that were of most significance in the audit

of the financial statements of the current year and are therefore the key audit matters.

We describe these matters in our auditors’ report unless law or regulation precludes their

public disclosure; and,

• provide the supervisory body with a statement that we have complied with the relevant

ethical requirements regarding independence and communicate with them all

relationships and other matters that may reasonably be thought to bear on our

independence, and where applicable, actions taken to eliminate threats or safeguards

applied.

Our responsibility also includes the verification that the information contained in the

management report is consistent with the financial statements, and the verification of the

requirements as provided in Article 451(4) and (5) of the Portuguese Companies’ Code

regarding the corporate governance report, as well as the verification that the remuneration

report was presented.

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 577

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS

On the management report

In compliance with article 451 (3), al. e) of the Portuguese Commercial Companies Code, in

our opinion the management report has been prepared in accordance with the applicable

legal and regulatory requirements and the financial information contained therein is

consistent with the audited financial statements, and no material inconsistencies have been

identified.

On the Corporate Governance Report

Pursuant to Article 451(4) of the Portuguese Companies' Code, it is our opinion that the

corporate governance report includes the information required to the Group to provide under

Article 29-H of the Securities Code, and we have not identified any material misstatements

on the information provided therein in compliance with paragraphs c), d), f), h), i) and l) of

paragraph 1 of that Article.

On the remunerations’ report

Pursuant to article 26-G, no. 6, of Portuguese Companies’ Code, we inform that the Entity

has included in the corporate governance report in a separate chapter the information

defined in no. 2 of that article.

On the European Single Electronic Format (ESEF)

The financial statements of The Navigator Company, S.A. for the year ended 31 December

2024 must comply with the applicable requirements set out in Commission Delegated

Regulation (EU) 2019/815 of 17 December 2018 (ESEF Regulation).

Management is responsible for drawing up and disclosing the annual report in accordance

with the ESEF Regulation.

We are responsible for obtaining reasonable assurance as to whether the financial

statements included in the annual report are presented in accordance with the requirements

set out in the ESEF Regulation.

Our procedures considered the OROC (Portuguese Institute of Statutory Auditors) Technical

Application Guide on ESEF reporting and included obtaining an understanding of the

financial reporting process, including the presentation of the annual report in a valid XHTML

format.

In our opinion, the financial statements included in the annual report are presented, in all

material respects, in accordance with the requirements established in the ESEF Regulation.

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 578

On the additional matters provided in Article 10 of the Regulation (EU)

537/2014

Pursuant to article 10 of the Regulation (EU) no. 537/2014 of the European Parliament and

of the Council, of 16 April 2014, and in addition to the key audit matters mentioned above,

we also report the following:

•

We were first appointed as auditors of the Entity in the general shareholders meeting

held on 22 September 2017 for a first mandate from 2015 to 2018. We were reappointed

as auditors in the general shareholders meeting held on 9 April 2019 for a second

mandate from 2019 to 2022 and on 17 May 2023 for a third mandate from 2023 to 2025.

•

Management as confirmed to us that they are not aware of any fraud or suspicion of

fraud having occurred that has a material effect on the financial statements. In planning

and executing our audit in accordance with ISA we maintained professional scepticism,

and we designed audit procedures to respond to the possibility of material misstatement

in the financial statements due to fraud. As a result of our work, we have not identified

any material misstatement of the financial statements due to fraud.

•

We confirm that the audit opinion we issue is consistent with the additional report that we

prepared and delivered to the supervisory body of the Entity on [•] April 2025.

•

We declare that we have not provided any prohibited services as described in Article 5 of

the Regulation (EU) 537/2014 of the European Parliament and of the Council, of 16 April

2014, and we have remained independent of the Entity in conducting the audit.

11 April 2025

SIGNED ON THE ORIGINAL

KPMG & Associados

Sociedade de Revisores Oficiais de Contas, S.A.

(no. 189 and registered at CMVM with the no. 20161489)

represented by

Rui Filipe Dias Lopes

(ROC no. 1715 and registered at CMVM with no. 20161325)

2024 ANNUAL REPORT • STATUTORY AUDITORS’ REPORT AND AUDITORS’ REPORT 579

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 580

The Navigator Company, S.A.

Report and Opinion of the Audit Board

Separate Financial Statements

2024 Financial Year

Shareholders,

1. In accordance with the Law and the Articles of Association of the Company, and in the

performance of the mandate conferred on us, we hereby submit the report on our supervisory

activities carried out in 2024 and issue our opinion on the Individual Management Report and

Separate Financial Statements presented by the Board of Directors of the Navigator

Company, S.A., for the financial year ended 31 December 2024.

2. Over the course of the year we regularly monitored the activities of the Company, as often

and as extensively as we deemed appropriate, in particular through periodic meetings with

the Company’s Directors and Managers. We monitored the verification of the accounting

records and respective supporting documentation, as well as the effectiveness of the risk

management, internal control and internal audit systems. We monitored compliance with the

Law and the Articles of Association. In the course of our activities we encountered no

constraints whatsoever.

3. We have met several times with the Statutory Auditor and External Auditor, KPMG &

Associados, SROC, Lda., monitoring the audit work carried out and checking their

independence, and we have analysed the Legal Certification of Accounts and Audit Report,

which we agree with.

4. The Audit Board analysed the proposals submitted to it for the provision of non-audit services

by the Chartered Accountants Firm and approved those that concerned permitted services,

did not affect the independence of the Chartered Accountants Firm and complied with the

other legal requirements.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 581

5. Within the scope of our duties, we have verified that:

a) The Separate Statement of Income by Nature, the Separate Statement of Financial

Position, the Separate Statement of Comprehensive Income, the Separate Statement

of Changes in Equity, the Separate Statement of Cash Flows and the accompanying

Notes to the Separate Financial Statements, provide an adequate understanding of

the Company's financial position and results, comprehensive income, changes in

equity, and cash flows;

b) The accounting policies and valuation criteria adopted comply with the International

Financial Reporting Standards (IFRS) as adopted in the European Union and are

suitable to ensure that such criteria lead to a correct valuation of the Company’s

assets and results, following the analyses and recommendations issued by the

External Auditor;

c) The Management Report is sufficiently clear in explaining the development of the

business and the situation of the Company, clearly highlighting the most significant

aspects of the activity;

d) The Corporate Governance Report includes the information required by Article 29.º-

H of the Securities Code and takes into account the recommendations of the Code of

the Portuguese Institute for Corporate Governance (IPCG).

6. We are of the opinion that the proposal for application of results presented by the Board of

Directors does not contravene the applicable legal and statutory provisions.

7. Accordingly, taking into consideration the information received from the Board of Directors

and the Company departments, and also the conclusions of the Statutory Auditor’s Report

and Auditor’s Report, we recommend that:

a) The Management Report be approved;

b) The Separate Financial Statements be approved;

c) The proposal for the application of results presented by the Board of Directors be approved.

8. Finally, the members of the Audit Board wish to acknowledge and express their appreciation

for the assistance received from the Board of Directors, the main managers and other staff

of the Company, as well as to the firm of Statutory Auditors, KPMG & Associados, SROC, Lda.

2024 ANNUAL REPORT • SEPARATE FINANCIAL STATEMENTS 582

Lisbon, April 11, 2025

The Chairman of the Audit Board

José Manuel Oliveira Vitorino

Member

Gonçalo Nuno Palha Gaio Picão Caldeira

Member

Maria da Luz Gonçalves de Andrade Campos

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 583

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 584

Corporate Governace Report

PART I Information on Shareholder Structure,

Organisation and Corporate Governance 585

A. Shareholder structure 585

I. Capital structure 585

II. Shareholding and Bondholding positions 587

B. CORPORATE BODIES AND COMMITTEES 589

I. GENERAL MEETING 589

II. MANAGEMENT AND SUPERVISION 591

III. SUPERVISION 621

IV. STATUTORY AUDITOR 629

V. EXTERNAL AUDITOR 630

C. INTERNAL ORGANISATION 632

I. Articles of Association 632

II. Reporting of Irregularities (Whistleblowing) 632

III. Internal Control and Risk Management 633

IV. Investor Support 651

V. Website 654

D. REMUNERATION 655

I. Powers to determine remuneration 655

II. Remuneration Committee 655

III. Remuneration structure 656

IV. Disclosure of Remuneration 660

V. Agreements with implications for remuneration 663

VI. Stocks or stock option plans 663

E. RELATED PARTY TRANSACTIONS AND CONFLICTS OF INTEREST 664

I. Control mechanisms and procedures 664

II. Details of Transactions 666

PART II Corporate Government Assessment 667

COMPLY OR EXPLAIN 676

Part III 677

Other Information 677

ANNEX 1 678

ANNEX 2 679

ANNEX 3 683

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 585

Part I

Information on Shareholder Structure, Organisation and

Corporate Governance

A. Shareholder structure

I. Capital structure

1. Capital structure (share capital, number of shares, capital distribution among shareholders, etc.),

including indication of shares not admitted to trading, different categories of shares, rights and duties

attached to the same, and the percentage of the capital represented by any such category (article 29-H,

no. 1, para. a) of the CVM)

The Navigator Company, S.A. has a share capital of Euro 500,000,000, fully paid up, represented solely by 711,183,069 ordinary

shares, without nominal value, the same rights and duties being attached to all shares.

All shares representing the Company’s share capital are listed on the regulated Euronext Lisbon market, managed by Euronext

Lisbon – Sociedade Gestora de Mercados Regulamentados, S.A.

At the end of 2024, the Company carried out a new analysis of its shareholder base, identifying and characterising its main

institutional shareholders. In addition to the Semapa Group, the majority shareholder with 70% of Navigator’s share capital, about

180 institutional shareholders were identified and characterised, representing about 14% of the shares issued.

Thus, in December 2024, the shareholder composition identified was as follows:

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 586

Navigator’s institutional shareholders, excluding the majority shareholder, at the end of 2024 were mainly from the United States

of America (USA) and Europe. The weight of US-based shareholders remains stable after the increase in exposure recorded in

2022 and currently stands at 35% (vs. 37% in 2023).

With regard to Shareholders from Europe, we highlight Portuguese Shareholders, with 34% (vs. 31% in 2023), Shareholders

based in Spain, with 10% (vs. 11% in 2023), UK Shareholders, around 6% (vs. 5% in 2023), and Shareholders based in the

Netherlands, with close to 3%.

In addition, in terms of investment style characterisation, around 32% of the shares were held by institutional investors with an

Index Funds style strategy, 25% of investors with a Value strategy, 21% by investors with a Growth strategy and around 14%

with GARP (Growth at Reasonable Price) strategies.

2. Restrictions on the transferability of shares, such as consent clauses for disposal, or limitations on

ownership of shares (Art. 29-H, no. 1, para. b))

The shares representing Navigator's share capital are freely transferable.

3. Number of own shares, corresponding percentage of share capital and percentage of voting rights

which would correspond to own shares (Art. 29-H, no. 1, para. a))

As of 31 December 2024, Navigator did not hold any own shares.

4. Significant agreements to which the Company is a party and which take effect, are amended or

terminate in the event of a change in the control of the Company as a result of a takeover bid, together

with the respective effects, unless, due to its nature, disclosure of such agreements would be seriously

detrimental to the Company, except if the Company is specifically required to disclose such information

by other mandatory provisions of law (Art. 29-H, no. 1, para. j))

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 587

The Company is not a party to any significant financing agreements, debt issuance instruments or others that come into force, are

amended or terminate in the event of a change of control of the Company following a takeover bid.

Nor has Navigator adopted any measures requiring payments or the as bsumption of charges by the Company in the event of a

change of control or of the composition of the management body, which could jeopardise the economic interest in the transfer of

shares and the free assessment by the Shareholders of the performance of the Directors.

5. Rules applicable to the renewal or revocation of defensive measures, in particular those providing for

limits on the number of votes which can be held or cast by a single shareholder individually or in a

concerted manner with other shareholders.

There are no defensive measures in place within the Company, particularly those that limit the number of votes that can be held or

exercised by a single shareholder individually or in concert with other shareholders.

6. Shareholders’ agreements known to the Company or which might lead to restrictions on the transfer of

securities or voting rights (Art. 29-H, no. 1, para. g))

The Company is not aware of any shareholders' agreement that could lead to restrictions on the transfer of securities or voting rights.

II. Shareholding and Bondholding positions

7. Identification of persons and organisations who, directly or indirectly, own qualifying holdings (articles

29-H, no. 1, para. c) and d) and 16), detailing the attributable percentage of the share capital and votes

and the respective grounds.

The holders of qualifying holdings in Navigator on 31 December 2024 are those identified in the table below:

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 588

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 589

8. Indication of the number of shares and bonds held by members of the management and supervisory

bodies.

This information is provided in Annex I of Part II of this Report.

9. Special powers of the management board, in particular concerning resolutions to increase capital

(article 29-H (1) (i)) indicating, with regard to these, the date on which they were granted, the period

during which such powers may be exercised, the upper limit for the increase in share capital, shares

already issued under the powers granted and the manner in which the powers granted are

implemented.

The Articles of Association do not authorise the Board of Directors to pass resolutions approving capital increases.

10. Information on the existence of significant dealings of a commercial nature between holders of

qualifying holdings and the Company.

All the transactions that took place in 2024 between the Company and the holders of qualifying holdings are described in Note 11.3

of the Notes to the consolidated financial statements and Note 10.2 of the Notes to the individual financial statements. There were no

significant commercial relationships between the holders of qualifying holdings and the Company in 2024 - due to the application of

the Regulation on Conflicts of Interest and Transactions with Related Parties and under the terms and conditions set out therein at

any given time, as described in paragraphs 89 et seq. of this Report.

B. CORPORATE BODIES AND COMMITTEES

I. GENERAL MEETING

a) Composition of the Board of the General Meeting*

*Throughout the reference year

11. Officers of the Board of the General Meeting and their term of office (starting and ending dates).

The officers of the Board of the General Meeting are:

Chairman: Rui Manuel Pinto Duarte (mandate from 17/05/2023 to 31/12/2025).

Secretary: Luís Nuno Pessoa Ferreira Gaspar (mandate from 17/05/2023 to 31/12/2025).

b) Exercise of voting rights

12. Any restrictions on voting rights, such as limitations on the exercise of voting rights based on the

ownership of a given number or percentage of shares, time limits for exercising voting rights, or

systems for detaching voting rights from ownership rights (Art. 29-H, no. 1, para. f).

In the Company there are no restrictions on the exercise of voting rights by its shareholders. Navigator's Articles of Association

stipulate that each share in the Company corresponds to one vote.

Despite the existence of statutory deadlines for participation in the General Meeting, provided for in the Company's Articles of

Association, mandatory legal provisions apply to this matter, such as Article 23-C of the Portuguese Securities Code. The statutory

deadline for postal voting is the day before the General Meeting.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 590

The Company's Articles of Association were amended at the annual general meeting held on 17 May 2022, at which time they

specifically regulated voting by electronic or postal means, with the Chairman of the Board of the General Meeting being

responsible for verifying their authenticity and regularity and ensuring their confidentiality until the time of the vote, observing the

following:

a) Explanations of vote must be addressed to the Chairman of the General Meeting and received at the registered office no

later than the day before the General Meeting;

b) If the right to vote is exercised electronically, the e-mail addressed to the Chairman of the Board of the General Meeting

of Shareholders must contain an attached document in PDF format, signed in accordance with the signature on the valid

identification document of the respective holder, containing the voting declarations for each of the items on the agenda as

well as a copy of the holder's identification document. The Chairman of the Board of the General Meeting of Shareholders

may establish in the notice convening the meeting in question a system other than that set out in this paragraph that

ensures equivalent security and reliability;

c) If the right to vote is exercised by post, the envelope must contain a letter addressed to the Chairman of the Board, duly

signed in accordance with the signature on the holder's valid identification document and containing the explanations of

vote relating to each of the items on the agenda, as well as a copy of the holder's identification document;

d) Votes cast by these means shall be counted together with any votes cast at the General Meeting and shall count as

negative votes in relation to proposals submitted after they have been cast.

The General Meeting may also be held by telematic means, whenever this proves to be appropriate and convenient, provided that

the Chairman of the Board of the General Meeting confirms that, for the purposes of holding the meeting, the respective means,

the authenticity of the declarations and the security of the communications are ensured, and the Company records the content

and the respective participants.

For the purposes of identifying the Company's Shareholders and final Investors, the Company has the right, under the terms and

for the purposes of the Securities Code, to be provided with information on the identity of its Shareholders by the entity managing

the centralised system or by the relevant financial intermediaries at any time, so as to be able to communicate directly with them

and facilitate the exercise of the rights inherent in their shares and their involvement in the Company.

Until this amendment, the Articles of Association authorised the Board of Directors to regulate ways of exercising voting rights

other than by paper ballots, provided that they also ensured the authenticity and confidentiality of the votes until the moment of

voting.

Although the Board of Directors has not made use of this option, the Chairman of the Board of the General Meeting has always

accepted voting by electronic mail, provided that it is received under conditions equivalent to voting by post, in terms of time,

intelligibility, guarantee of authenticity, confidentiality and other formalities.

There are no systems for highlighting property rights.

13. Indication of the maximum percentage of the voting rights which can be exercised by a single

shareholder or by shareholders connected in any of the forms envisaged in article 20 (1).

There are no statutory rules establishing rules in this regard.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 591

14. Identification of shareholder resolutions which, under the Articles of Association, can only be adopted

with a qualified majority, in addition to those provided for by law, and details of the majorities

required.

The Company's Articles of Association do not contain specific rules regarding the constitutive or deliberative quorum at General

Meetings, so the legal provisions of the Commercial Companies Code apply in full.

II. MANAGEMENT AND SUPERVISION

(Board of Directors, Executive Committee and General and Supervisory Board)

a) COMPOSITION*

15. Identification of the governance model adopted.

The Company adopted in its Articles of Association a one-tier management model, i.e. with a Board of Directors made up of

executive and non-executive members, a Supervisory Board and a Statutory Auditor, under the terms of Article 278(1)(a) and

Article 413(1)(b) of the Commercial Companies Code.

16. Rules in the Articles of Association on procedural and material requirements applicable to the

appointment and replacement of members, as the case may be, of the Board of Directors, the Executive

Committee and the General and Supervisory Board (article 29-H, no. 1, para. h). Diversity Policy.

The Company currently has no special rules in its Articles of Association regarding the appointment and replacement of directors. In

this respect, the general supplementary rules set out in the Portuguese Companies Code apply, i.e. the power to appoint directors

(between three and seventeen) and the supervisory body rests with the shareholders.

However, the Articles of Association provide that a director may be elected individually if there are proposals subscribed and

presented by groups of shareholders, provided that none of these groups holds shares representing more than twenty per cent and

less than ten per cent of the share capital. If such proposals are submitted, the election will be held separately and before the

election of the other Directors. The same shareholder may not subscribe to more than one list.

Each proposed list must identify at least two eligible persons.

If lists are presented by more than one group, the vote will be on all of these lists.

In 2020, Navigator's Board of Directors approved the following Company Diversity Principles, which were revised in 2021, setting

out the requirements and criteria for the profile of new members of corporate bodies and senior managers:

• Inclusion of members with different academic qualifications and professional experience in different areas, appropriate

and relevant to the position to be held;

• Promoting gender diversity;

• Inclusion of members of different ages, combining acquired experience with new perspectives; and

• Inclusion of members with different geographical backgrounds or experiences.

These principles are published on the Company's website (https://en.thenavigatorcompany.com/Investors/Governance).

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 592

These Diversity Principles constitute the Company's formal recognition of the benefits of diversity in its governing bodies, namely

as a way of ensuring greater balance in its composition, enhancing the performance of each member and, as a whole, of each

body, improving the quality of decision-making processes and contributing to its sustainable development.

To this end, the competences matrix below shows that there is a fairly reasonable degree of diversity in its various dimensions and

with regard to the members of Navigator's Board of Directors:

RELATÓRIO ANUAL 2024 • GOVERNO SOCIETÁRIO 593

Gender

Year of

birth Position Engineering Economics Management

Other

training

Business

Administration

and

Management

Governance

Mergers &

Acquisitions

Internationalisation Academics

Talent

Management

Research &

Development

Information

Technologies

ESG

Pulp and

Paper Energy Industry

Ricardo

Pires

M 1976 CBD

X X X X X X X X

X X X X

António

Redondo

M 1964 CEO X X X X X X X X X X X X X

Fernando

Araújo

M 1964 CFO

X X X X X X X

X X X

Nuno

Santos

M 1970 X X X X X X X X X X X

João Lé

M 1963

X X X

X X X X

Dorival

Almeida

M 1966

X X X X

X X X X X X X

António

Quirino

Soares

M 1974

X X

Ana

Lehmann

F 1972

X X

X X X

X X

Hugo Pinto

M 1978 X X X X X X X X X

Isabel

Viegas

F 1958 X X X X X

Mariana

Marques

dos Santos

F 1966 X X X X X X X

Sandra

Santos

F 1971 X X X X X X X X X X

Teresa

Presas

F 1952

X X X X X

X X

Vitor

Paranhos

Pereira

M 1957

X X X X

X X

* Includes powers for overseeing strategy, management of impacts, risks and opportunities, good practices and certification on topics

related to (i) Sustainable Forest Management and Biodiversity Conservation; (ii) Climate Action and Energy; (iii) Water Management; (iv)

Circular Economy; (v) People Management; (vi) Innovation, Development and Bioproducts; and (vii) Value Chain.

2024 ANNUAL REPORT • CORPORATE GOVERNANCE 594

It should also be noted that the Talent Committee

is the committee with advisory functions in terms of appointing governing

bodies, with powers to support the identification of potential members of the governing bodies and to assess the suitability of each

candidate for the position to be filled. It must ensure transparent selection processes and that candidates are proposed who have the

greatest merit, are best suited to the requirements of the position and promote appropriate diversity within the organisation,

including between men and women.

In this way, the Company believes that all the objectives resulting from the formal adoption of a diversity policy have been achieved,

which is also demonstrated by reality.

It should also be noted, and reinforcing the promotion of diversity, that in 2024 the Company approved the 2025 Equality Plan,

with progress compared to the 2024 Equality Plan approved in 2023, and has communicated this Plan to the CMVM, which has also

published it on Navigator's website (

https://thenavigatorcompany.com/wp-content/uploads/2025/03/2024-12-05-PLIG2025_ENG-

final.pdf).

17. Composition, as the case may be, of the Board of Directors, the Executive Committee and the General

and Supervisory Board, detailing the provisions of the Articles of Association concerning the minimum

and maximum number of directors, duration of term of office, number of full members, and the date

when first appointed and the end of their terms of office for each member.

The Company's Articles of Association stipulate that the Board of Directors comprises three to seventeen members (article 15 no.

1), elected for three-year, renewable terms (article 8 no. 3).

The date of the first appointment and the end of the term of office are individualised for each member:

Name

Date of first appointment and end

of Mandate

Ricardo Miguel dos Santos Pacheco Pires

2015-2025

António José Pereira Redondo

2007-2025

Nuno Miguel Moreira de Araújo Santos

2015-2025

José Fernando Morais Carreira de Araújo

2007-2025

João Paulo Cabete Gonçalves Lé

2020-2025

Dorival Martins de Almeida

2023-2025

António Quirino Vaz Duarte Soares

2023-2025

Ana Teresa Cunha de Pinho Tavares Lehmann

2023-2025

Hugo Alexandre Lopes Pinto

2023-2025

Maria Isabel da Silva Marques Abranches Viegas

2023-2025

Maria Teresa Aliu Presas

2019-2025

Mariana Rita Antunes Marques dos Santos

2019-2025

The Company’s Internal Commissions are identified in points 21 and 29 of this Report.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 595

Sandra Maria Soares Santos

2019-2025

Vítor Paulo Paranhos Pereira

2020-2025

The composition of the Board of Directors is freely available for consultation on the Company's website at

https://en.thenavigatorcompany.com/Investors/Governance.

18. Distinction between executive and non-executive members of the Board of Directors and, in relation to

non-executive directors, identification of those who can be regarded as independent or, if applicable,

identification of the independent members of the General and Supervisory Board.

(A) Executive and non-executive Directors; identification of independent directors

During 2024, and to this date, six members of the Board of Directors held executive positions and formed an Executive Committee,

which was elected and whose powers were delegated by the Board of Directors, and eight of the Directors hold non-executive

positions.

The executive members of the Board of Directors belong to the Executive Committee and are identified below in point 28, while the

other members are non-executive.

Given that, throughout 2023, the number of non-executive directors represented 57.1% of the members of the Board of Directors,

we consider this percentage to be adequate for the size of the Company and the complexity of the risks inherent in its activity, and

sufficient to efficiently ensure the duties entrusted to them.

This judgement of suitability took into account, in particular, the size of the Executive Committee and the delegation of powers

entrusted to it by the Board of Directors, the profile, age, professional background and experience and integrity of the members of

this body, their diverse skillset and the availability of the non-executive members to carry out their duties, which, through the close

co-operation developed with the Chairman of the Board of Directors and the members of the Executive Committee, ensure effective

monitoring, supervision and assessment of the activity of the executive members of the Board of Directors, the Company's

activities, its family nature and the stability of its shareholder capital structure.

At the Annual General Meeting held on 17 May 2023, which elected the members of the governing bodies for the current term,

three new non-executive members of the Board of Directors were elected - Ana Teresa Cunha de Pinho Tavares Lehmann, Hugo

Alexandre Lopes Pinto and Maria Isabel da Silva Marques Abranches Viegas - the first of whom can be considered independent,

thus increasing the number of independent directors to four in accordance with the criteria for measuring independence defined in

point 18.1 above and in Recommendation IV.2.4 of the IPCG Corporate Governance Code. The Company thus has 50%

independent non-executive directors, more than a third of the non-executive directors, in accordance with the Recommendations of

the IPCG Corporate Governance Code.

The remaining four non-executive directors, although not independent in accordance with the above criteria, have the necessary

suitability, experience and proven professional competence, which makes it possible to enrich and optimise the Company's

management with a view to creating value, as well as ensuring the effective defence of the interests of all shareholders and

supervising and assessing the activity of the executive directors in an impartial, independent and objective manner and, at the

same time, ensuring that there are no conflicts of interest between the interests and position of the Shareholder and the Company.

(B) Coordination mechanism which is equivalent to the appointment of a Lead Independent Director

In view of the specific characteristics of the Company, namely its family nature and the concentration of its capital structure, the

total number of non-executive Directors and, among these, independent Directors, as well as the characteristics and current

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 596

position of the Chairman of the Board of Directors, the Company considers that the appointment of a coordinator would be

inappropriate and would merely aim at formal compliance with this recommendation, which the Company does not agree with.

In reality, and as already mentioned in this report, the Company has a number of rules and procedures in place which allow for

close and regular coordination between the various members of the Board of Directors, particularly between the Chairman and the

other Directors, and the existence of the conditions and means necessary for them to carry out their duties in an independent,

informed and efficient manner, guaranteeing the supervisory and oversight role of executive management.

In this regard, we would like to highlight the various mechanisms provided for in the Regulations of the Board of Directors and the

various internal committees

of the Company, under which:

a) The members of the Board of Directors, including the non-executive members, may have access to all the information

necessary to assess the Company's performance, situation and development prospects, including, in particular, the

minutes, the documentation supporting the decisions taken, the convening notices and the archives of the meetings of

the other governing bodies, without prejudice to access to any other documents or persons from whom clarification may

be requested;

b) The Chairman of the Board of Directors shall inform the Company's Directors, at the beginning of each Board meeting, of

the most relevant resolutions and acts carried out by the Executive Committee since the previous meeting, which are not

yet known to the other Directors;

c) Minutes shall be drawn up of all meetings of the Executive Committee, which shall be kept by the Company Secretary and

made available to any member of the Board of Directors who requests them;

d) The Chairman of the Executive Committee shall, as far as possible, promote the involvement of non-executive directors;

e) in specific projects and acts so as to enable non-executive directors to be more closely involved in the Company's

activities, depending on the matters in question and the specific qualifications and preferences of each one;

f) All executive directors must be available to provide any clarification and information requested by non-executive

directors;

g) The Chairman of each of the Company's Internal Committees must inform the Board of Directors of the resolutions of the

Committee of which he is a member, which in view of their relevance should be brought to its attention. In the case of

the Executive Committee, this task falls to the Chairman of the Executive Committee;

h) All members of the Company's Internal Committees must be available to provide any clarification and information

requested by the other Directors;

i) Supporting documents relating to the various items on the agenda for meetings of the Board of Directors and the

Company's Internal Committees must be distributed to all members in advance so that they can be analysed in good

time, preferably when the meeting is convened.

In addition, at least three non-executive directors are members of the Talent Committee - the Chairman of the Board of Directors

is also chairman of the Talent Committee and the Corporate Governance Committee - thus reinforcing the coordination and

performance of the work of the non-executive members.

The Internal Commissions of the Company are identified in points 21 and 29 of this Report.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 597

The Company has therefore established a mechanism equivalent to the coordination of non-executive directors by appointing a

lead independent director.

19. Professional qualifications and other relevant biographical details of each member, as applicable, of the

Board of Directors, the General and Supervisory Board and the Executive Committee.

Ricardo Miguel dos Santos Pacheco Pires

Ricardo Pires has a degree in Business Administration and Management from Universidade Católica Portuguesa, a specialisation in

Corporate Finance from ISCTE and an MBA in Business Management from Universidade Nova de Lisboa. He began his career in

management consultancy between 1999 and 2002, first at BDO Binder and then at GTE Consultores. Between 2002 and 2008 he

worked in the Corporate Finance Department of ES Investment, where he carried out various M&A and capital markets projects in

the Energy, Pulp and Paper and Food & Beverages sectors. He has worked with Semapa since 2008, initially as Director of

Strategic Planning and New Businesses and then, from 2011, as Chief of Staff to the Chairman of the Board of Directors. Since

2014, he has been an Executive Director of Semapa and, since 2022, Chairman of its Executive Committee, while also holding

positions in other related companies. Since 2015, he has held non-executive management positions at The Navigator Company

and Secil, and in 2022 he became Chairman of the Board of Directors of these companies. In 2017 he was appointed CEO of

Semapa Next, and in 2022 he became Chairman of the Board of Directors of that company. Since 2020 he has been Chairman of

the Board of Directors of the ETSA Group and in 2023 he was appointed Chairman of the Board of Directors of Triangle's. Between

2020 and 2022 he taught on the Master’s in Finance programme at the Catholic University of Lisbon.

António José Pereira Redondo

António Redondo has a degree in Chemical Engineering from the FCT of the University of Coimbra, attended the Business

Management course and has an MBA with a specialisation in Marketing from UCP. He joined Soporcel in 1987, where he held

various positions in the technical, production, marketing and commercial management areas. He has been a member of the Board

of Directors and Executive Committee of The Navigator Company since April 2007, having been Chief Commercial Officer from

2007 to 2019, with responsibilities in the areas of Marketing, Sales, Revenue Management, Supply Chain, Logistics and Product

Development. In 2020, he was appointed CEO of the Company. He is also Chairman of Biond - Forest Fibers from Portugal,

Director of CIP (Business Confederation of Portugal), member of the Boards of CEPI (Confederation of European Paper Industries)

and Euro-Graph (European Association of Graphic Paper Producers), Member of the Board of COTEC Portugal - Business

Association for Innovation and Member of the Academy of Engineering.

José Fernando Morais Carreira de Araújo

Fernando Araújo has a degree in Law from Universidade Lusíada do Porto (2000) and a bachelor's degree in Accounting and

Administration from Instituto Superior de Contabilidade e Administração do Porto (ISCAP - 1986) and a Specialised Higher Studies

Course in Financial Control from the same institution (1992). He has been a Chartered Accountant since 1995. Certified

Accountant since 1987. He has been Vice-Chairman of the Board of the General Meeting of Biond - Forest Fibers from Portugal

since 2022. He has been a member of the Audit Board of the Portuguese Institute of Chartered Accountants since January 2021

and a member of the Board of the Portuguese Tax Association since 2019. He has a postgraduate degree in Advanced Financial

Accounting (ISCTE - 2002/2003), a postgraduate degree in Tax Law from the Lisbon Faculty of Law (FDL - 2002/2003) and a

postgraduate degree in Corporate Governance from the Lisbon Institute of Economics and Management (ISEG - 2006/2007). He

completed an MBA in Corporate Reporting at ISCTE - IUL in 2016. He began his professional career in 1987 at Sportrade, where

he was responsible for accounting at Eurofer between 1988 and 1993 and was head of Administrative Services at COLEP from

1991 to 1993. Between 1993 and 2001, he worked in the tax area at KPMG, rising to Senior Tax Manager. He was Director of Tax

and Accounting at Secil between 2001 and 2005, at Semapa between 2002 and 2006, and at the company between 2006 and

2007. He has been an executive director of the company since April 2007.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 598

Nuno Miguel Moreira de Araújo Santos

Nuno Santos has a degree in Civil Engineering from Instituto Superior Técnico (1993) and an MBA from INSEAD (1996). He began

his professional career at McKinsey & Company in 1993 and, until March 2015, was Senior Partner and leader of the Energy,

Commodities & Industry Practice in McKinsey's Iberia Office. He was also a member of the Leadership Committee of the Energy,

Commodities & Industrials Global Practice. He became an executive director of The Navigator Company in April 2015. He is

currently President of APIGCEE (Portuguese Association of Large Electricity Consumers).

João Paulo Cabete Gonçalves Lé

João Lé has a degree in Agronomy, specialising in Agricultural Economics, from the Instituto Superior de Agronomia (ISA) of the

Universidade Técnica de Lisboa, a post-graduate degree in Silviculture of Fast-Growing Species from the ISA and the Universidade

de Trás-os-Montes e Alto Douro and a post-graduate degree in Management, specialising in Finance, from ISCTE, Universidade de

Lisboa. He has been with the Navigator Group for around 30 years, having taken on responsibility for the Forestry Area in August

2007 and, in July 2016, he was appointed CEO of Portucel Moçambique, responsible for the project to implement a forestry-based

industry in Mozambique through DUATs (areas allocated by the government), with around 360,000 hectares in two provinces. He

has been an executive director of the company since January 2020.

António Quirino Vaz Duarte Soares

António Quirino Soares has a degree in Business Management from the University of Coimbra and a Master's degree in Economics

from the University of Exeter, UK. He joined The Navigator Company in 2001, where he held various positions in the Sales and

Marketing areas for 13 years. This was followed by five years as Marketing Director, during which time he boosted the

international presence of the company's mill brands and promoted the production of knowledge on market and sociological trends

in paper consumption on a global scale, including the Horizon 2030 study. Before joining the Executive Committee, Quirino Soares

was Supply Chain Director, a position in which he managed the logistical challenges arising from the global disruptions during the

pandemic. During his two years in charge of this area, he also launched the supply chain operations associated with Navigator's

new sustainable packaging line. António Quirino Soares has been a member of The Navigator Company's Executive Committee

since 1 August 2023. He is an executive director responsible for Logistics, Marketing, Supply Chain, Product Technology, European

Sales, International Sales, E-Commerce, Moulded Pulp, Packaging and Pricing.

Dorival Martins de Almeida

Dorival Almeida has a degree in Chemical Production Engineering from the Federal University of São Carlos, a postgraduate

degree in Business Management from the Armando Álvares Penteado Foundation, a specialist in Quality Engineering from the

State University of Campinas, a postgraduate degree in Production Management from the Federal University of São Carlos, a

postgraduate degree in Pulp and Paper Technology from the Federal University of Viçosa, a postgraduate degree in People and

Talent Management from the University of Coimbra and an MBA in Business Management from the Getúlio Vargas Foundation. He

worked at Votorantim Celulose e Papel, from 1992 to 2007, at International Paper, between 2007 and 2019, and at CMPC,

between 2019 and 2021. He joined Navigator in 2021 as Industrial Director of the Figueira da Foz Mill. He became an executive

director of The Navigator Company in April 2023.

Ana Teresa Cunha de Pinho Tavares Lehmann

Ana Lehmann has a degree in Management from FEP-Universidade do Porto and a Masters and PhD in Economics (International

Business) from the University of Reading (UK). She is a non-executive member of the Board of Directors of The Navigator

Company, TAP-Transportes Aéreos Portugueses, S.A. and TAP-SGPS, S.A., and Chairman of the Board of Directors of the Iberian

group Zolve-Logifrio. She chairs the General Board of the Fund for Internationalisation, the Finance, Audit and Risk Committee of

TAP-S.A. and TAP SGPS-S.A., and is a member of the Advisory Board of the Orkestra-Basque Competitiveness Institute and the U.

Fribourg Competitiveness Institute, the Strategic Council for the Digital Economy (CIP) and collaborates regularly with various

international organisations. She was Secretary of State for Industry (XXI Constitutional Government). She is a Professor at FEP-U.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 599

Porto and has taught/researched at various European and American universities (Columbia University of New York, Glasgow,

Reading, Uppsala, among others) in the areas of Foreign Direct Investment, Internationalisation and Innovation. She was Vice-

President of CCDR-N, President of the Managing Authority of the European Union's Atlantic Area Programme, Pro-Rector of the

University of Porto, President of the Investment Committee of the Social Innovation Fund and a member of the Supervisory Board

of the European Institute of Innovation and Technology (EIT) Manufacturing. She supported the founding of API-Agência

Portuguesa para o Investimento and InvestPorto. She was President of the European International Business Academy.

Hugo Alexandre Lopes Pinto

Hugo Pinto has a degree in Civil Engineering from Instituto Superior Técnico, an executive master's degree in Real Estate

Management and Finance and a master's degree in Finance from ISCTE - Instituto Universitário de Lisboa and an MBA from

INSEAD. Between 2001 and 2007, he was a structural engineer and project manager at J. L. Câncio Martins - Projecto de

Estruturas, Lda. From 2007 to 2013, he was project manager at Sonagi. From 2018 to 2020, he was a director and member of the

Semapa Next, S.A. Investment Committee. Since March 2013, he has held various positions in the Semapa Group, having been

Director of Planning and Strategic Development (07/2020-12/2021), Director of the CEO's Office (01/2019-06/2020), Deputy

Director of the CEO's Office (04/2016-12/2018), Deputy Director of Finance (11/2014-03/2016) and Deputy Director of Strategic

Planning and New Business (03/2013-10/2014). He is a director of Quotidian Podium, S.A., Secil - Companhia Geral de Cal e

Cimentos, S.A., Semapa Next, S.A., ETSA - Investimentos, SGPS, S.A., Capital Hotels - Soc. De Investimentos e Gestão, S.A. and

Hotel Ritz, S.A. She is also a member of Semapa's Executive Management Committee, a member of the Supervisory Board of

Fundação Nossa Senhora do Bom Sucesso and a member of the Remuneration Committee of Sonagi, SGPS, S.A. She joined

Navigator as a non-executive director in May 2023.

Maria Isabel da Silva Marques Abranches Viegas

Maria Isabel Viegas has a degree in Psychology from the Instituto Superior de Psicologia Aplicada (ISPA) and a master's degree in

Human Resources Policies and Management from ISCTE. She joined Marconi between 1990 and 1999, where she was responsible

for Recruitment and Development Services (between 1990 and 1994), responsible for the Labour Relations and Social Policy Area

(between 1995 and 1998) and responsible for Staff Management (between June 1998 and September 1999). From 1999 to 2003,

she joined Jazztel as Human Resources Director. At the Banco Santander Totta Group, from 2003 to 2017, she was Coordinating

Director of Human Resources for the Santander Group and Director of Santander Pensions. Between 2018 and 2021, she held

consultancy positions: she was an Advisor/Adviser to some companies within the scope of ECS Capital (Montalva Group, Vale de

Lobo, Moretextile) and Semapa, in the Talent area; she carried out consultancy projects in Strategic Human Resources

Management (e.g. Montellano Group, Pestana Group, Infraestruturas de Portugal) and was also a mentor to top executives in

several companies and, on a pro bono basis, in the PWN Mentoring Programme, where she accompanies young female executives.

She is also a lecturer at the Católica Lisbon School of Business and Economics, with a regular teaching activity, namely in the

Executive Masters and in executive training, where she has taught and coordinated various programmes since 2006. She was

recognised with the Career Award in 2017, as part of the HR Awards 2017, by the IIRH. She is also dedicated to philanthropic

activities, as co-founder and board member of the dNovo Association (since 2020), which supports highly qualified professionals

over 50 and unemployed. She joined the Semapa Group in January 2022 as Chief People Officer, as a member of the Executive

Management Committee and as a member of Semapa's Talent Committee. At Secil she is a non-executive director and a member

of the Remuneration Committee. She is a director of Semapa Next, a member of the Remuneration Committee of Semapa Next, a

member of the Remuneration Committee of ETSA Investimentos and a member of Quotidian Podium. She has been a member of

Sonagi's Remuneration Committee since 2022. She joined Navigator in May 2023 as a non-executive director.

Maria Teresa Aliu Presas

Maria Teresa Aliu Presas has a degree from the Instituto Superior de Psicologia Aplicada in Lisbon. She made her career in the

paper industry and joined the Tetra Pak Group in 1982, where she held various positions in Portugal, Switzerland, the

international headquarters, and Brussels, in the areas of Marketing and Communication, Environment and European Affairs,

namely vice-president of the Europe Region and head of Environment for the entire group. From 2003 to 2011, he headed the

European Confederation of the Paper Industry (CEPI). She has been a member of the board of directors of various European

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 600

associations and a non-executive director of the company Powerflute Oy. She currently works for the consultancy Magellan in

Brussels, is a non-executive director of the World Bioeconomy Forum and has been a non-executive director of Navigator since

2019.

Mariana Rita Antunes Marques dos Santos

Mariana Marques dos Santos graduated in Business Management from Universidade Católica Portuguesa and complemented her

training with an MBA from INSEAD (Fontainebleau), having also attended the same programme at Kellogg - Northwestern

University in Chicago. From 1989 to 2006, she taught quantitative methods at ISCTE and strategy and internationalisation policies

at the IBS-ISCTE Business School. Alongside her academic activities, she has developed a business career linked to various areas

and functions. Starting out by experiencing the dynamics of the financial markets, he collaborated with Lloyds Bank in the area of

securities portfolio management. She then joined a venture capital team - SFIR - where she was a project analyst in 1991 and

1992. She was also a consultant in Madrid for a multinational company, Arthur D. Little, where she was involved in various

projects, including the launch of the Portuguese branch in 1995 and 1996. She then took on a succession of international roles

within the Abrantina Group between 1996 and 2007, namely in Mozambique and Germany, managing projects in various areas,

such as food or the production and distribution of building materials. At the end of 2007, she took on a business project of her

own, launching NBC Medical, in the area of international trade in medicines, where she was involved as managing partner until

June 2021. She has been a non-executive director of The Navigator Company since May 2019. She has been a member of the

board of FAE - Fórum de Administradores e Gestores de Empresas since March 2022. Since January 2024, she has been Vice-

Chair of the International Trade Committee at the World Trade Centre Lisboa.

Sandra Maria Soares Santos

Sandra Maria Soares Santos has a degree in Management from the Faculty of Economics in Porto (1989-94) and an MBA from PBS

- Porto Business School (1999). She began her career at Banco Espírito Santo and at the University of Porto in 1994, where she

was a guest lecturer. At BES she held various technical and commercial positions, at a time when the bank was incorporating

young managers and substantially transforming its organisational structure and way of doing business. She began her career at

BA Group at the end of 1999 as Controller, a position she took on at a time when the group was starting to expand

geographically. Since then, she has held various positions, such as Finance Director, Human Resources Director, Factory Director

and CFO. It was as CFO (2007) that she played an active role in the acquisition and integration processes of the acquired

companies. In 2012, she was seconded to be CFO of another business, plastic packaging, in which BA's shareholders decided to

invest, an assignment she completed a year later. Until February 2024, she was CEO and a member of the Board of Directors of

the BA Group, which has industrial operations in 8 European countries and Mexico, 16 industrial units, more than 5000 employees

and an annual turnover of 1600 million euros. She has been a non-executive director of Navigator since April 2019. She is also a

non-executive director of Titan Cement International and a member of EDP's General Supervisory Board. She was a member of

the Board of the Business Roundtable Portugal Association, created in 2021 with the ambition of helping Portugal grow. She was

also a non-executive director of BPI and Chair of its Talent Committee from 2023 to 2024.

Vítor Paulo Paranhos Pereira

Vítor Paranhos Pereira has a degree in Economics from the Portuguese Catholic University and attended AESE (University of

Navarre). He began his professional career in 1982 at Gaspar Marques Campos Correia & Cª. Lda. as Finance Director until 1987.

From 1987 to 1989, he held the position of Deputy Finance Director at the Instituto do Comércio Externo de Portugal (ICEP). In

1989 he joined the Group as Finance Director of Sodim, having been appointed a member of its Board of Directors in 2009, a

position he held until May 2018 and then from March 2020 to the present. He has also held management positions in various

companies related to Sodim, namely Hotel Ritz since 1998. Between 2001 and 2016, he also held management positions at Hotel

Villa Magna. He has been a director of Sonagi since 1995 and has been Chairman of the Board of Directors since June 2020. He

was appointed a director of Refundos in 2005, serving as Chairman of the Board of Directors of that company from 2018 until May

2020. From 2006 to 2015, he was Chairman of the Supervisory Board of the Hotel Association of Portugal (AHP) and in 2019 he

was appointed Chairman of the Board of the General Meeting of this organisation. From 2007 to 2016, he was Chairman of the

General Meeting of the Portuguese Association of Investment Funds, Pensions and Assets (APFIPP). He was a member of the

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 601

Supervisory Board of Eurovida - Companhia de Seguros, S.A. and Popular Seguros - Companhia de Seguros, S.A. from 2009 to

2018. In 2014, he was appointed a member of the Board of Directors of Semapa. Since March 2020, he has been an Executive

Director of Semapa and other related companies, and since 2020 he has also held management positions at Secil and The

Navigator Company.

20. Regular and significant family, professional or business relationships of the members, as applicable, of

the Board of Directors, General and Supervisory Board and Executive Committee with shareholders with

qualified holdings exceeding 2% of voting rights.

Among the members of the Company's Board of Directors, during the year under review, Directors Ricardo Miguel dos Santos

Pacheco Pires, Vítor Paulo Paranhos Pereira were also Directors of the shareholder Semapa, while Hugo Alexandre Lopes Pinto and

Maria Isabel da Silva Marques Abranches Viegas were managers at Semapa.

21. Organisational or functional charts showing the division of powers between the different corporate

boards, committees and/or company departments, including information on delegated powers, in

particular with regard to delegation of the daily management of the Company.

2024 ANNUAL REPORT • CORPORATE GOVERNANCE 602

Between 1 January and 31 December 2024, the Executive Committee (which, according to the Statutes, can comprise between three to

nine members) was made up of six members, who shared the following list of responsibilities:

2024 ANNUAL REPORT • CORPORATE GOVERNANCE 603

The powers delegated to the Executive Committee are as follows:

a) To propose to the Board of Directors the Company's policies, objectives and strategies;

b) To propose operating budgets and medium and long-term investment and development plans to the Board of Directors,

and to implement them once approved;

c) Approving budget changes during the year, including transfers between cost centres, provided that they do not exceed

twenty million euros in any one year;

d) Approve contracts for the purchase of goods or services, the total value of which does not exceed twenty million euros

per year;

e) Approve financing contracts, request bank guarantees, or take on any other responsibilities that represent an increase in

indebtedness, with an overall value of less than twenty million euros each year;

f) Acquire, dispose of or encumber fixed assets of the Company up to an individual value of five per cent of the paid-up

share capital;

g) To take or lease any immovable property;

h) To represent the Company in or out of court, actively or passively, as well as to propose and pursue any legal or

arbitration actions, to confess and withdraw from them, to compromise;

i) Acquire, dispose of or encumber shares in other companies up to a maximum of twenty million euros each year;

j) To decide on the acquisition and disposal of own shares, when this has been decided by the General Meeting, and in

compliance with what has been decided by the General Meeting;

k) Manage shareholdings in other companies, in conjunction with the Chairman of the Board of Directors, namely by

appointing, with the latter's agreement, representatives on the respective governing bodies, and defining guidelines for

the actions of these representatives;

l) Concluding, amending and terminating employment contracts;

m) Opening, operating and closing bank accounts;

n) Appointing agents for the Company;

o) In general, all powers that may be delegated by law, subject to any limitations resulting from the provisions of the

preceding paragraphs.

Together with the Chairman of the Board of Directors, the Executive Committee may also decide on the matters referred to in

paragraphs c), d), e) and i) above, when the respective amounts, calculated in accordance with the terms referred to therein, exceed

twenty million euros, but do not exceed fifty million euros.

The Chairman of the Board of Directors has the powers attributed to him by law and the Articles of Association. The power to

amend any conditions of contracts previously entered into and covered by the aforementioned points c), d), e) and i) shall lie with

the body or bodies that would have had the power to enter into them.

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The Executive Committee may discuss all matters within the remit of the Board of Directors, although it may only decide on matters

delegated to it.

The Regulations of the Executive Committee, approved by the Board of Directors, also establish the rules governing the actions of

executive directors.

Resolutions regarding the definition of the Company's strategy, as well as its general policies and the Navigator Group's corporate

structure, are a matter for the Board of Directors, and the Executive Committee has no delegated powers in this regard. The non-

executive directors are therefore involved in defining the strategy, main policies, corporate structure and decisions that should be

considered strategic by virtue of their amount or risk, as well as assessing their fulfilment.

Company management is centred on coordination between the Board of Directors and the Executive Committee. Coordination and

rapprochement have been ensured by the close co-operation developed by the Chairman of the Board of Directors, Ricardo Pires,

with the executive team, by the availability of the members of the Executive Committee to regularly pass on all relevant or urgent

information, or that is requested, relating to the day-to-day management of the Company to the non-executive members of the

Board of Directors, in order to allow permanent monitoring of Company life, and by convening meetings of the Board of Directors for

all strategic decisions or those considered especially relevant, even if these fall within the scope of the general powers delegated,

and also by the presence of the Chairman of the Board of Directors at some meetings of the Company's Executive Committee.

Also, with regard to the other members of the governing bodies, the information requested is provided by the members of the

Executive Committee in a timely and appropriate manner.

In order to ensure regular transmission of information, the notices convening meetings and the minutes of these meetings are

available for consultation by the Supervisory Board. The Company's other committees and governing bodies also ensure the inter-

organisational flow of information and documentation necessary for the exercise of the legal and statutory powers of each of the

other bodies and committees in a timely and appropriate manner, under the terms of their respective operating regulations and in

accordance with the law and the articles of association.

With regard to strategic planning and investment policy, and without prejudice to the portfolio to which reference is made, it should

be clarified that this is by nature an area in which the non-executive members have a greater say and that the Chairman of the

Board of Directors has been significantly involved. The non-executive directors are therefore involved in defining the strategy, main

policies, corporate structure and decisions that should be considered strategic, due to their amount or risk, as well as assessing

their fulfilment.

The Company has internal regulations for the Board of Directors and Supervisory Board, as well as for the internal committees

identified below, which contain rules of operation, competence and coordination between the various bodies and committees.

Under the terms of these regulations and other applicable rules, the aforementioned governing bodies and other Company

committees draw up full minutes of their meetings.

The corporate bodies and internal committees identified above are obliged, under the terms of their respective internal operating

regulations, to make available to each other, under the terms required by law and the articles of association, all the information and

documentation necessary for the exercise of the legal and statutory powers of each of the other bodies and committees, and the

various departments and services of the Company must collaborate in the production, processing and dissemination of this

information, in an appropriate, rigorous and timely manner.

The regulations of the Board of Directors and the Supervisory Board also establish, in particular, mechanisms that guarantee,

within the limits of the applicable legislation and regulations, their members' access to all the information necessary to assess the

Company's performance, situation and development prospects, including, in particular, minutes, supporting documentation for

decisions taken, convening notices and archives of meetings of the other governing bodies, without prejudice to access to any other

documents or persons from whom clarification may be requested.

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It should be noted that the internal regulations of the Board of Directors and the Supervisory Board were revised in 2024, following

the revision in 2023 of the 2018 IPCG Corporate Governance Code.

‘With regard to sustainability, it is important to mention the competences of the Sustainability Department - which, in conjunction

with the company's different departments and the Sustainability Forum, forms various working groups to deal with specific issues

- which has carried out its activity under the supervision of the Executive Committee and involving all the Group's companies

across the board. As a result of this activity, each year the company draws up its Annual Report which, from a consolidated

perspective and in response to the legal requirements introduced by Decree-Law 89/2017 of 28 July, provides an in-depth

analysis of the company's approach and commitment to sustainability issues. With regard to sustainability information, which from

2006/2007 until 2024 was reported in accordance with the Global Reporting Initiative Standards (Cap. 9.2), it should be noted

that, for the year ending 31 December 2024, it was prepared in accordance with the requirements of the European Sustainability

Reporting Standards (‘ESRS’), with Navigator having instituted processes that ensure the collection, processing and analysis of

sustainability information, including that reported in Roadmap 2030 (Cap. 3.4.4). In this way, and through compliance with and

realisation of the aforementioned strategic principles, and in the terms further developed in the aforementioned Report, the

Company ensures long-term success, with a significant contribution to the community at large.

Navigator has a Responsible Management Agenda 2030, anchored in the concept of ‘Creating Value with Responsibility’ (Chap.

3.4), in line with the United Nations 2030 Agenda (Chap. 3.4). It was defined with the aim of increasing the company's positive

contribution in the long term - towards 2030 - and is organised around two strategic lines of action, which reflect the two

dimensions of its corporate purpose, People and Planet (Chap. 2).

It is supported by a 2030 Roadmap, made up of a set of commitments (Chap. 3.4), structured according to 11 material topics, as

a result of the revision of the dual materiality analysis carried out in 2024 (Chap. 5.1.4).

The 2030 Agenda and Roadmap aim to maximise the company's performance on environmental, social and governance (ESG)

issues, contributing to business resilience, corporate reputation and image, and creating the conditions for sustainability to

become a strategic competitive advantage, while at the same time creating value for its different stakeholders (Chap. 3).

Underpinning the various positive impacts generated by Navigator, which are intended to be maximised through its strategy and

business model, are sustainable forest management and the development of forest-based products and solutions. In fact, these

contribute to a circular, low-carbon bioeconomy, to the valorisation of the entire forestry value chain, as well as to the

development of the rural economy and the promotion of employability and qualification in the sector. We should also highlight the

fact that we are the company with the greatest contribution to National Value Added, directly impacting the country's economy

and its generation of wealth.

Navigator has defined a set of policies and codes (Chap. 3.4), among other structuring documents, as well as actions to support

the realisation of its goals and targets, and its approach to each material issue. All of Navigator's material topics have associated

commitments and objectives, action plans and KPIs, the vast majority of which are supported by policies and codes.

It should be emphasised that the 2030 Responsible Management Agenda is based on two dimensions - People and Planet - and

that the sustainability report details the management approach followed by the Company, the actions undertaken in the reporting

year and the performance achieved - in line with the objectives and targets defined in the 2030 Roadmap (Chap. 3.4).

Navigator has a sustainability governance structure supported by various corporate bodies and committees with well-defined

functions. External stakeholders also take part in some of these bodies, which support the Organisation in analysing its

performance, identifying risks and making recommendations, among other things (Chap. 5.1.4).

The Executive Committee delegates management of the 2030 Roadmap to the heads of the company's different departments, and

there is a team of sustainability key users who monitor the action plans set out therein. These departments and key users, with

the guidance and support of the Sustainability Department, assess Navigator's performance against the goals set. All proposals for

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 606

changes to the 2030 Roadmap arising from this process are submitted by the Sustainability Department to the Executive

Committee for appraisal and approval and are subsequently made public in the Annual Report.

Risk assessment (Chap. 3.3) is also supported by its own governance structure and duly defined processes, aligned with the IIA's

(Institute of Internal Auditors) 3-Line Model, as mentioned in Section 51 of this Report. It has the involvement of the

Sustainability Department and addresses risks related to environmental, social and governance (ESG) aspects.

It should be noted that data related to sustainability can be found in Chapters 3 and 5 of the Management Report, and a

compilation of the main performance indicators is also available in Chapter 8, with methodological notes in context.

Navigator, as an industrial group that produces pulp, paper, tissue and sustainable packaging solutions, manages forestry assets

and produces renewable electricity, has climate change at the centre of its concerns and therefore has a governance structure

supported by various bodies with well-defined functions in terms of sustainability management, including climate-related impacts

(Chap. 5.2.2). It should be noted that, within the scope of the remuneration policy, monetary incentives are established for EC

members, promoting the management of climate-related issues. These incentives are dependent on Navigator's environmental

performance, in order to achieve the targets and objectives set.

The 2030 Roadmap (Chap. 3.4.4) expresses a commitment to invest in low carbon solutions towards carbon neutrality, supported

by a set of objectives and targets aimed at reducing GHG emissions and increasing renewable energy in total primary energy

consumption. It should be noted that since 2019, Navigator has voluntarily adopted a roadmap for carbon neutrality, which

reflects the ambition to decarbonise industrial complexes in Portugal by 2035 (EU ETS emissions). The commitment to reducing

CO2 emissions was extended by joining the Science Based Targets initiative (SBTi) and approving the targets submitted in 2022

(Chap. 5.2.2).

The positive contribution to combating climate change and its effects is also expressed in other Roadmap commitments associated

with promoting the forest-based circular bioeconomy, with an impact on the value chain - e.g. sustainable forest management and

the development of bioproducts. Also of note is the importance of promoting efficiency in the use of energy, water and materials,

as well as the reduction and recovery of waste.

b) OPERATION

22. Existence of rules of procedure for the Board of Directors, the General and Supervisory Board and the

Executive Committee, as the case may be, and place where these may be consulted.

The internal rules of procedure for Navigator's Board of Directors are published on the Company's website, in the Investors area, in

relation to Corporate Governance, and are freely available for consultation at

www.thenavigatorcompany.com/en/investors/governance

The Regulations of the Board of Directors provide for the exercise of its powers, chairmanship, frequency of meetings, operation and

the duties of its members.

In accordance with these Regulations, within the limits of the applicable legislation:

a) The members of the Board of Directors shall be guaranteed access at all times to all the information necessary to assess

the Company's performance, situation and development prospects, including, in particular, the minutes, the

documentation supporting the decisions taken, the notices convening meetings and the archives of the meetings of the

other governing bodies, without prejudice to access to any other documents or persons from whom clarification may be

requested;

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 607

b) The Board of Directors must make available to the other governing bodies and committees, in a timely and appropriate

manner, under the terms required by law and the articles of association, the inter-organisational flow of information and

documentation necessary for the exercise of the legal and statutory powers of each of the other bodies and committees;

c) Non-executive directors must participate in the definition by the management body of the strategy, main policies,

corporate structure and decisions that should be considered strategic for the Company due to their amount, risk or special

characteristics, as well as in the assessment of their fulfilment.

Directors who are members of the Executive Committee may not carry out executive management duties in entities outside the

Company's corporate group, unless the activity of these entities is considered ancillary or complementary to the Group's activity

or does not involve a significant amount of time.

Directors who are not members of the Executive Committee may carry out management duties (executive or otherwise) in entities

outside the Company's Group, provided that they do not involve companies that carry out activities in competition with those of

the Company, or companies directly or indirectly in which it has a stake, and they must inform the Chairman of the Board of

Directors prior to commencing such duties.

The following powers cannot be delegated generically:

a) the definition of the Company's strategy and main policies, without prejudice to the Board of Directors being able to

delegate to the Executive Committee the preparation, for approval by the Board of Directors, of the proposed strategic

plan and investment policy;

b) The organisation and coordination of the Company's corporate structure; and

c) Matters that are, at any given time, considered strategic due to their amount, risk or special characteristics.

The Board of Directors shall assess its performance annually, as well as the performance of the Executive Committee and other

Committees and of the Managing Directors, if any, taking into account the fulfilment of the Company's strategic plan and budget, risk

management, its internal functioning and the contribution of each member to this end, and the functioning between the Company's

bodies and committees, identifying possibilities for improving this performance.

23. Number of meetings held and rate of meeting attendance of each member of the Board of Directors,

General and Supervisory Board and Executive Committee, as applicable.

During the 2024 financial year, the Board of Directors held eight meetings, the minutes of which were drawn up. All the members

of the Board of Directors were present at the eight meetings, corresponding to an attendance rate of 100 per cent, with the

exception of executive director Nuno Santos, who was absent from one meeting for duly justified reasons, with an attendance rate

of 87.5 per cent at the Board of Directors' meetings.

In accordance with the Regulations of the Board of Directors, detailed minutes of the respective meetings are drawn up.

The number of Board meetings held is freely available for consultation on the Company's website at

www.thenavigatorcompany.com/en/investors/governance/

24. Indication of the company bodies empowered to assess the performance of executive directors.

The Remuneration Committee draws up the Remuneration Policy, which defines how the system works, and prepares the entire

framework for the assessment of executive directors. The performance appraisal of each executive director follows an internal

process structured under the leadership of the person in charge (i.e. under the responsibility of the person who chairs the team, in

the case of the members of the Executive Committee, and under the responsibility of the Chairman of the Board of Directors, in

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 608

the case of the Chairman of the Executive Committee) and in which the non-executive directors that the person in charge sees fit

to involve also take part.

Also involved in this process is the Appointments and Appraisals Committee, currently made up of three non-executive members

of the Board of Directors, which is responsible for monitoring the performance appraisal system of the executive management and

the awarding of remuneration by the Company and for giving its opinion on the proposals for individual performance appraisals of

the executive management, which makes it unnecessary for the Board of Directors itself to be involved in the performance

appraisal of the executive directors.

Lastly, the Remuneration Committee is responsible for confirming the respective achievement factors in the performance appraisal

and ensuring the overall coherence of the process by setting the variable remuneration.

Thus, in 2024 and for the 2023 financial year, the Talent Committee met and gave its opinion on the individual performance

proposals of the members of the Executive Committee, Adriano Augusto da Silva Silveira, João Paulo Araújo Oliveira, João Paulo

Cabete Gonçalves Lé, José Fernando Morais Carreira Araújo and Nuno Miguel Moreira Araújo Santos, issued by the respective

Chairman. José Fernando Morais Carreira de Araújo and Nuno Miguel Moreira de Araújo Santos, issued by the respective

Chairman, and António José Pereira Redondo, issued by the Chairman of the Board of Directors, communicating his opinion to the

Remuneration Committee. These evaluation proposals were based on the application of the basic criteria for evaluating the

performance of executive directors in force at Navigator and further described in point 25.

For its part, and under the terms of the Regulations of the Board of Directors and the Regulations of the Remuneration

Committee, the Board of Directors, accompanied by the Remuneration Committee, must annually assess its performance, as well

as the performance of its committees, including the Executive Committee, taking into account compliance with the Company's

strategic plan and budget, risk management, its internal functioning and the contribution of each member to this effect, and the

relationship between the Company's bodies and committees. Under the terms of the respective regulations, the Appointments and

Assessment Committee monitors the overall assessment of the Board of Directors' performance.

The assessment of the executive directors, as well as the self-assessment of the Board of Directors and its committees, took place

in 2023, in relation to 2022 performance, and will take place in 2024, in relation to 2023, under the terms described above.

25. Predetermined criteria for assessing the performance of executive directors.

The basic criteria for assessing the performance of executive directors in force in 2023-2025 are those defined in point 2.2 of

chapter 2 of the Remuneration Policy for defining the variable component of remuneration. These criteria are materialised through

a system of quantitative and qualitative KPIs related to the performance of the Company and the director in question. The general

business indicators include EBITDA (with a weighting of 35%), net profits (with a weighting of 10%), cash flow (with a weighting

of 10%) and Total Shareholder Return vs. Peers (with a weighting of 10%), and the behavioural competences include the

alignment of each Director with the long-term interests and sustainability of the Company.

In addition to these criteria, in line with the commitments made by the Company in its sustainability strategy and recognising the

importance of efficient energy use and the need to reduce fossil CO2 emissions from economic activities, the implementation of

the corporate energy efficiency programme approved in 2016 is also taken into account. Therefore, the specific objectives will

always include ESG indicators, such as the result of the Company's annual climate study, the reduction of CO2 emissions, certified

wood and the consumption of water, energy and wood.

26. Availability of each of the members of the Board of Directors, the General and Supervisory Board and

the Executive Committee, as the case may be, indicating office held simultaneously in other companies,

inside and outside the Group, and other relevant activities carried out by the members of these bodies

during the period.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 609

Ricardo Miguel dos Santos Pacheco Pires

Positions held in Navigator Group companies

Chairman of the Board of Directors of The Navigator Company, S.A.

Positions held in other companies / entities

Chairman of the Board of Directors of APHELION, S.A.

Director of CIMO - Gestão de Participações, SGPS, S.A.

Director of 67 Fundação Semapa – Pedro Queiroz Pereira

Chairman of the Board of Directors of ETSA - Investimentos, SGPS, S.A.

Director of Directors of Pyrus Agricultural LLC

Director of Directors of Pyrus Investments LLC

Director of Directors of Pyrus Real Estate LLC

Chairman of the Board of Directors of Quotidian Podium, S.A.

Chairman of the Board of Directors of SECIL - Companhia Geral de Cal e Cimento, S.A.

Director of SEMAPA Inversiones, S.L.

Chairman of the Board of Directors of SEMAPA NEXT, S.A.

Director of SODIM, SGPS, S.A.

Chairman of the Board of Directors of Triangle's - Cycling Equipments, S.A.

Director of Triangle's 2 - Cycling Products, Unipessoal Lda

Director of UPSIS, S.A.

Chairman of the Board of Directors of UPSIS - Consultoria e Investimentos, S.A.

António José Pereira Redondo

Positions held in Navigator Group companies

Chief Executive Officer and Director of The Navigator Company, S.A.

Director of Accrol Holdings Limited

Director of Art Tissue Ltd.

Director of Bosques do Atlântico, S.L.

Director of Enerpulp - Cogeração Energética de Pasta, S.A.

Director of Eucaliptusland - Sociedade de Gestão de Património Florestal, S.A.

Director of John Dale (Holdings) Limited

Director of John Dale Limited

Director of Leicester Tissue Company Limited

Director of LTC Parent Ltd

Chairman of the Board of Directors of Navigator Brands, S.A.

Director of Navigator Corporate UK Limited

Chairman of the Board of Directors of Navigator Forest Portugal, S.A.

Chairman of the Board of Directors of Navigator Green Fuels Figueira da Foz, S.A.

Chairman of the Board of Directors of Navigator Green Fuels Setúbal, S.A.

Director of Navigator Holding Tissue UK Limited

Chairman of the Board of Directors of Navigator North America, Inc.

Chairman of the Board of Directors of Navigator Paper Figueira, S.A.

Director of Navigator Paper México S. de R.L. de C.V.

Chairman of the Board of Directors of Navigator Paper Setúbal, S.A.

Chairman of the Board of Directors of Navigator Parques Industriais, S.A.

Chairman of the Board of Directors of Navigator Pulp Aveiro, S.A.

Chairman of the Board of Directors of Navigator Pulp Figueira, S.A.

Chairman of the Board of Directors of Navigator Pulp Setúbal, S.A.

Chairman of the Board of Directors of Navigator Tissue Aveiro, S.A.

Chairman of the Board of Directors of Navigator Tissue Ejea, S.L.

Chairman of the Board of Directors of Navigator Tissue Iberica, S.A.

Chairman of the Board of Directors of Navigator Tissue Ródão, S.A.

Director of Navigator Tissue UK Limited

Chairman of the Board of Directors of RAIZ - Instituto de Investigação da Floresta E Papel

Director of Severn Delta Limited

Positions held in other companies / entities

Chairman of the Board of Directors of Biond – Forest Fibers from Portugal

Started functions from 29 May 2024.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 610

Director of CIP (Portuguese Industrial Confederation)

Member of the Board of CEPI (Confederation of European Paper Industries)

Member of the Board of Directors of Euro-Graph (European Association of Graphic Paper Producers)

Member of the Board of Directors of Directors of COTEC Portugal – Business Association for Innovation

Member of the Engineering Academy

José Fernando Morais Carreira de Araújo

Positions held in Navigator Group companies

Director and member of the Executive Committee of The Navigator Company, S.A.

Director of Accrol Holdings Limited

Director of Art Tissue Ltd

Director of Bosques do Atlântico, S.L.

Director of Empremedia Re Designated Activity Company

Chairman of the Board of Directors of Empremédia - Corretores de Seguros, S.A.

Director of Enerpulp - Cogeração Energética de Pasta, S.A.

Director of Eucaliptusland - Sociedade de Gestão de Património Florestal, S.A.

Director of John Dale (Holdings) Limited

Director of John Dale Limited

Director of Leicester Tissue Company Limited

Director of LTC Parent Ltd

Director of Navigator Africa, S.R.L.

Director of Navigator Afrique du Nord, SARLAU

Director of Navigator Brands, S.A.

Director of Navigator Corporate UK Limited

Director of Navigator Deutschland GMBH

Director of Navigator Egypt (LLC)

Vice-Presidente do Conselho de Administração da Navigator Eurasia Kağit Ve Kağit Ürünleri Sanayi Ve Ticaret

Anonim Şirketi

Director of Navigator Forest Portugal, S.A.

General Director of Navigator France SAS

Director of Navigator Green Fuels Figueira da Foz, S.A.

Director of Navigator Green Fuels Setúbal, S.A.

Director of Navigator Holding Tissue UK Limited

Director of Navigator Itália, S.R.L.

Director of Navigator Middle East Trading DMCC

Director of Navigator Netherlands B.V.

Director of Navigator North America, INC.

Director of Navigator Paper Austria GMBH

Director of Navigator Paper España S.A.

Director of Navigator Paper Figueira, S.A.

Director of Navigator Paper México S. de R.L. de C.V.

Director of Navigator Paper Setúbal, S.A.

Director of Navigator Paper Southern Africa Proprietary Limited

Director of Navigator Paper UK Ltd.

Director of Navigator Parques Industriais, S.A.

Director of Navigator Poland Paper Spółka Z Ograniczoną Odpowiedzialnością

Director of Navigator Pulp Aveiro, S.A.

Director of Navigator Pulp Figueira, S.A.

Director of Navigator Pulp Setúbal, S.A.

Director of Navigator Tissue Aveiro, S.A.

Director of Navigator Tissue Ejea, S.L.

General Director of Navigator Tissue France SAS

Director of Navigator Tissue Iberica, S.A.

Director of Navigator Tissue Ródão, S.A.

Director of Navigator Tissue UK Limited

Director of Portucel Moçambique - Sociedade de Desenvolvimento Florestal e Industrial, S.A.

Director of Portucel Nigeria Limited

Director of Pulpchem Logistics, ACE

Director of RAIZ - Instituto de Investigação da Floresta e Papel

Director of Severn Delta Limited

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 611

Positions held in other companies / entities

Vice-Chairman of the Board of the General Meeting of Biond - Forest Fibers from Portugal, representing Navigator

Paper Figueira, S.A.

Member of the Board of AFP - Associação Fiscal Portuguesa (Portuguese Tax Association)

Member of the Audit Board of the Portuguese Institute of Statutory Auditors

Nuno Miguel Moreira de Araújo Santos

Positions held in Navigator Group companies

Director and member of the Executive Committee of The Navigator Company, S.A.

Director of Accrol Holdings Limited

Director of Art Tissue Ltd.

Director of Bosques do Atlântico, S.L.

Director of Enerpulp - Cogeração Energética de Pasta, S.A.

Director of Eucaliptusland - Sociedade de Gestão de Património Florestal, S.A.

Director of John Dale (Holdings) Limited

Director of John Dale Limited

Director of Leicester Tissue Company Limited

Director of LTC Parent Ltd.

Director of Navigator Africa, S.R.L.

Director of Navigator Brands, S.A.

Director of Navigator Corporate UK Limited

Director of Navigator Forest Portugal, S.A.

Director of Navigator Green Fuels Figueira da Foz, S.A.

Director of Navigator Green Fuels Setúbal, S.A.

Director of Navigator Holding Tissue UK Limited

Director of Navigator North America, Inc.

Director of Navigator Paper Figueira, S.A.

Director of Navigator Paper Setúbal, S.A.

Director of Navigator Parques Industriais, S.A.

Director of Navigator Pulp Aveiro, S.A.

Director of Navigator Pulp Figueira, S.A.

Director of Navigator Pulp Setúbal, S.A.

Director of Navigator Tissue Aveiro, S.A.

Director of Navigator Tissue Ejea, S.L.

Chairman of the Board of Directors of Navigator Tissue France SAS

Director of Navigator Tissue Iberica, S.A.

Director of Navigator Tissue Ródão, S.A.

Director of Navigator Tissue UK Limited

Director of RAIZ - Instituto de Investigação da Floresta e Papel

Director of Severn Delta Limited

Positions held in other companies / entities

President of APIGCEE (Portuguese Association of Large Electricity Consumers)

João Paulo Cabete Gonçalves Lé

Positions held in Navigator Group companies

Director and member of the Executive Committee of The Navigator Company, S.A.

Director of Accrol Holdings Limited

Director of Art Tissue Ltd.

Director of Bosques do Atlântico, S.L.

Director of Enerpulp - Cogeração Energética de Pasta, S.A.

Director of Eucaliptusland - Sociedade de Gestão de Património Florestal, S.A.

Director of John Dale (Holdings) Limited

Director of John Dale Limited

Director of Leicester Tissue Company Limited

Director of LTC Parent Ltd.

Director of Navigator Abastecimento De Madeira, ACE

Chairman of the Board of Directors of Navigator Africa, S.R.L.

Director of Navigator Brands, S.A.

Director of Navigator Corporate UK Limited

Director of Navigator Forest Portugal, S.A.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 612

Director of Navigator Green Fuels Figueira da Foz, S.A.

Director of Navigator Green Fuels Setúbal, S.A.

Director of Navigator Holding Tissue UK Limited

Director of Navigator North America, Inc.

Director of Navigator Paper Figueira, S.A.

Director of Navigator Paper Setúbal, S.A.

Director of Navigator Parques Industriais, S.A.

Director of Navigator Pulp Aveiro, S.A.

Director of Navigator Pulp Figueira, S.A.

Director of Navigator Pulp Setúbal, S.A.

Director of Navigator Tissue Aveiro, S.A.

Director of Navigator Tissue Ejea, S.L.

Director of Navigator Tissue Iberica, S.A.

Director of Navigator Tissue Ródão, S.A.

Director of Navigator Tissue UK Limited

Chairman of the Board of Directors of Portucel Moçambique - Sociedade de Desenvolvimento Florestal e

Industrial, S.A.

Director of RAIZ - Forest and Paper Research Institute

Director of Severn Delta Limited

Chairman of the Board of Directors of Viveiros Aliança - Empresa Produtora de Plantas, S.A.

Positions held in other companies / entities

In 2024, he did not hold any positions in other companies/entities.

Dorival Martins de Almeida

Positions held in Navigator Group companies

Director and member of the Executive Committee of The Navigator Company, S.A.

Director of Accrol Holdings Limited

Director of Art Tissue Ltd.

Director of Bosques do Atlântico, S.L.

Director of EMA Cacia - Engenharia e Manutenção Industrial, ACE

Director of EMA Figueira da Foz - Engenharia e Manutenção Industrial, ACE

Director of EMA Setúbal - Engenharia e Manutenção Industrial, ACE

Director of Enerpulp - Cogeração Energética de Pasta, S.A.

Director of Eucaliptusland - Sociedade de Gestão de Património Florestal, S.A.

Director of John Dale (Holdings) Limited

Director of John Dale Limited

Director of Leicester Tissue Company Limited

Director of LTC Parent Ltd.

Director of Navigator Brands, S.A.

Director of Navigator Corporate UK Limited

Director of Navigator Forest Portugal, S.A.

Director of Navigator Green Fuels Figueira da Foz, S.A.

Director of Navigator Green Fuels Setúbal, S.A.

Director of Navigator Holding Tissue UK Limited

Director of Navigator North America, INC.

Director of Navigator Paper Figueira, S.A.

Director of Navigator Paper Setúbal, S.A.

Director of Navigator Parques Industriais, S.A.

Director of Navigator Pulp Aveiro, S.A.

Director of Navigator Pulp Figueira, S.A.

Director of Navigator Pulp Setúbal, S.A.

Director of Navigator Tissue Aveiro, S.A.

Director of Navigator Tissue Ejea, S.L.

Director of Navigator Tissue Iberica, S.A.

Director of Navigator Tissue Ródão, S.A.

Director of Navigator Tissue UK Limited

Director of RAIZ - Instituto de Investigação da Floresta e Papel

Director of Severn Delta Limited

Positions held in other companies / entities

In 2024, he did not hold any positions in other companies/entities.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 613

António Quirino Vaz Duarte Soares

Positions held in Navigator Group companies

Director and member of the Executive Committee of The Navigator Company, S.A.

Director of Accrol Holdings Limited

Director of Art Tissue Ltd.

Director of Bosques do Atlântico, S.L.

Director of Enerpulp - Cogeração Energética de Pasta, S.A.

Director of Eucaliptusland - Sociedade de Gestão de Património Florestal, S.A.

Director of John Dale (Holdings) Limited

Director of John Dale Limited

Director of Leicester Tissue Company Limited

Director of LTC Parent Ltd

Director of Navigator Brands, S.A.

Director of Navigator Corporate UK Limited

Director of Navigator Deutschland GMBH

Chairman of the Board of Directors of Navigator Eurasia Kağit Ve Kağit Ürünleri Sanayi Ve Ticaret Anonim Şirketi

Chairman of the Board of Directors of Navigator Fiber Solutions, S.A.

Director of Navigator Forest Portugal, S.A.

Chairman of the Board of Directors of Navigator France SAS

Director of Navigator Green Fuels Figueira da Foz, S.A.

Director of Navigator Green Fuels Setúbal, S.A.

Director of Navigator Holding Tissue UK Limited

Chairman of the Board of Directors of Navigator Italia, S.R.L.

Chairman of the Board of Directors of Navigator Netherlands B.V.

Director of Navigator North America, Inc.

Director of Navigator Paper Austria GMBH

Chairman of the Board of Directors of Navigator Paper España S.A.

Director of Navigator Paper Figueira, S.A.

Director of Navigator Paper Setúbal, S.A.

Manager of Navigator Paper Southern Africa Proprietary Limited

Manager of Navigator Paper UK Ltd.

Director of Navigator Parques Industriais, S.A.

Chairman of the Board of Directors of Navigator Poland Paper Spółka Z Ograniczoną Odpowiedzialnością

Director of Navigator Pulp Aveiro, S.A.

Director of Navigator Pulp Figueira, S.A.

Director of Navigator Pulp Setúbal, S.A.

Director of Navigator Tissue Aveiro, S.A.

Director of Navigator Tissue Ejea, S.L.

Director of Navigator Tissue Iberica, S.A.

Director of Navigator Tissue Ródão, S.A.

Director of Navigator Tissue UK Limited

Director of Portucel Nigeria Limited

Director of RAIZ - Forest and Paper Research Institute

Director of Severn Delta Limited

Positions held in other companies / entities

In 2024, he did not hold any positions in other companies/entities.

Ana Teresa Cunha de Pinho Tavares Lehmann

Positions held in Navigator Group companies

Director of The Navigator Company, S.A.

Positions held in other companies / entities

Director of TAP - Transportes Aéreos Portugueses, S.A.

Director of TAP - Transportes Aéreos Portugueses, SGPS, S.A.

Chairman of the Finance, Audit and Risk Committee of TAP Transportes Aéreos Portugueses, S.A.

Chairman of the Finance, Audit and Risk Committee of TAP Transportes Aéreos Portugueses, SGPS, S.A.

Chairman of the Board of Directors of Zolve - Logística e Transporte, S.A.

Chairman of the General Board of the Fund of Funds for Internationalisation

Member of the Advisory Board of the Orkestra-Basque Competitiveness Institute

Member of the Advisory Board of the University of Fribourg Competitiveness Institute

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 614

Member of the Advisory Board of Vibe Capital Partners

Member of the Strategic Council for the Digital Economy (CIP)

Hugo Alexandre Lopes Pinto

Positions held in Navigator Group companies

Director of The Navigator Company, S.A.

Positions held in other companies / entities

Director of Quotidian Podium, S.A.

Member of the Talent Committee of The Navigator Company, S.A.

Director of Secil - Companhia Geral de Cal e Cimentos, S.A.

Director of Semapa Next, S.A.

Director of ETSA - Investimentos, SGPS, S.A.

Member of the Executive Management Committee of Semapa - Sociedade de Investimento e Gestão, SGPS, S.A.

Member of the Remuneration Committee of Sonagi, SGPS, S.A.

Member of the Supervisory Board of the Nossa Senhora do Bom Sucesso Foundation

Director of Capital Hotels - Sociedade de Investimentos e Gestão, S.A.

Director of Hotel Ritz, S.A.

Maria Isabel da Silva Marques Abranches Viegas

Positions held in Navigator Group companies

Director of The Navigator Company, S.A.

Positions held in other companies / entities

Chief People Officer of Semapa (Vogal da Comissão de Direção Executiva)

Member of Semapa's Talent Committee

Non-executive Director of Secil

Member of Secil's Remuneration Committee

Director of Semapa Next

Member of the Remuneration Committee of Semapa Next

Member of the Remuneration Committee of ETSA Investimentos

Member of Quotidian Podium

Member of the Remuneration Committee of Sonagi

Maria Teresa Aliu Presas

Positions held in Navigator Group companies

Director of The Navigator Company, S.A.

Positions held in other companies / entities

Non executive director of the World Bioeconomy Forum.

Senior consultant of Magellan Association.

Mariana Rita Antunes Marques dos Santos

Positions held in Navigator Group companies

Director of The Navigator Company, S.A.

Positions held in other companies / entities

Director of FAE – Fórum de Administradores e Gestores de Empresas.

Co-Chairman of the International Trade Committee – Business Club, World Trade Center Lisboa

Sandra Maria Soares Santos

Positions held in Navigator Group companies

Director of The Navigator Company, S.A.

Positions held in other companies / entities

Director of BA Glass I – Serviços de Gestão e Investimentos, S.A.

Director of BPI – Banco Português de Investimento

Resigned with effects from 31 March 2025.

Resigned with effects from February 2024.

Resigned with effects from April 2024.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 615

Member of the Audit Committee and Chairman of BPI's Appointments, Appraisals and Remuneration Committee

Director of Titan Cement International

Member of the General and Supervisory Board of EDP

Non executive director of Titan Cement International

Vítor Paulo Paranhos Pereira

Positions held in Navigator Group companies

Director of The Navigator Company, S.A.

Positions held in other companies / entities

Director of Aphelion, S.A.

Director of Antasobral - Sociedade Agropecuária, S.A.

Director of Capital Hotels - Sociedade de Investimentos e Gestão, S.A.

Director of Cimo - Gestão de Participações, SGPS, S.A.

Member of the Advisory Board of the SEMAPA Foundation - Pedro Queiroz Pereira

Chairman of the Board of Directors of Galerias Ritz, S.A.

Director of Hotel Ritz, S.A.

Chairman of the Board of Directors of Parque Ritz, S.A.

Director of Quotidian Podium, S.A.

Director of Secil - Companhia Geral de Cal e Cimento, S.A.

Chairman of the Board of Directors of Semapa Inversiones, S.L.

Director and member of the Executive Committee of Semapa - Sociedade de Investimento e Gestão, SGPS, S.A.

Director of SEMAPA Next, S.A.

Director of Sodim, SGPS, S.A.

Director of Sociedade Agrícola da Herdade dos Fidalgos, Unip., Lda

Chairman of the Board of Directors of Sonagi, SGPS, S.A.

Chairman of the Board of Directors of Sonagi - Imobiliária, S.A.

Chairman of the Board of the General Meeting of the Hotel Association of Portugal

c) Committees belonging to the management or supervisory bodies and managing directors

27. Identification of committees set up by the Board of Directors, the General and Supervisory Board and

the Executive Committee, as the case may be, and place where the rules of procedure may be

consulted.

The Board of Directors includes the following committees:

i. Executive Committee

ii. Corporate Governance Committee

iii. Talent Committee

iv. Environmental Council

v. Sustainability Forum

vi. Risk Management Committee

Resigned with effects from April 2024.

Resigned with effects from February 2025.

Started functions on February 2025.

Started functions on 29 May 2024.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 616

The Operating Regulations of the Internal Committees provide for the exercise of their respective powers, chairmanship,

frequency of meetings, operation and the duties of their members. Detailed minutes of the respective meetings are drawn up and

can be consulted on the Company's website at https://en.thenavigatorcompany.com/Investors/Governance.

The composition and number of annual meetings of the Internal Committees are publicised on the Company's website at

https://en.thenavigatorcompany.com/Investors/Governance.

In accordance with their respective Operating Regulations, the Internal Committees must ensure, in a timely and appropriate

manner, the flow of information, starting with the respective convening notices and minutes, necessary for the exercise of the

legal and statutory competences of each of the other bodies and committees.

28. Composition, if applicable, of the Executive Committee and/or identification of the Managing

Director(s).

On 31 December 2024, the Executive Committee comprised the following directors:

Chairman:

- António José Pereira Redondo

Members:

- José Fernando Morais Carreira de Araújo

- Nuno Miguel Moreira de Araújo Santos

- João Paulo Cabete Gonçalves Lé

- Dorival Martins de Almeida

- António Quirino Soares

29. Indication of the powers of each of the committees created and summary of the activities carried on

the exercise of these responsibilities.

EXECUTIVE COMMITTEE

The powers of the Executive Committee are listed in point 21 of this report.

The Executive Committee is the Company's executive management body and has developed its competences within the scope of

the delegation of powers entrusted to it by the Board of Directors. This Committee meets regularly and whenever necessary,

depending on the business in progress and monitoring the Company's activity, and met 48 times during the 2024 financial year.

In addition to the members of the Executive Committee, whenever matters so warrant, these meetings are attended by non-

executive directors, directors of Group companies and members of Navigator's various departments.

CORPORATE GOVERNANCE COMMITEE

The Corporate Governance Committee is made up of four members: Ricardo Miguel dos Santos Pacheco Pires (Chairman), António

José Pereira Redondo, António Pedro Gomes Paula Neto Alves and Rui Tiago Trindade Ramos Gouveia.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 617

The Corporate Governance Committee, in addition to permanently supervising the Company's compliance with the legal,

regulatory and statutory provisions applicable to corporate governance, is responsible for critically analysing the Company's

practices and behaviour in the field of corporate governance, and for taking the initiative to propose the discussion, alteration and

introduction of new procedures aimed at improving corporate structure and governance. The Corporate Governance Committee

must also assess the Company's governance situation on an annual basis and submit any proposals it deems appropriate to the

Board of Directors.

In 2024, in addition to the day-to-day work and communications carried out by telematic means, the Committee held four

meetings, at which the following topics were analysed:

- Analysing and commenting on the Corporate Governance Report for 2023;

- Analysis of the assessment of compliance with the IPCG Corporate Governance Code carried out by the Executive Follow-up and

Monitoring Committee (CEAM), with reference to 2023;

- Comparison analysis of compliance with the IPCG CGS Recommendations by other listed companies;

- Amendments to Navigator's Internal Regulations;

- Initiatives to be carried out in 2024.

TALENT COMMITTEE

The Talent Committee is made up of three to seven members, including a majority of non-executive directors, one of whom will

be chairman, appointed by the Board of Directors for a period of four years, coinciding with the term of office of the Board of

Directors.

In 2024, the Committee had five members: Ricardo Miguel dos Santos Pacheco Pires (Chairman), António José Pereira Redondo,

Hugo Alexandre Lopes Pinto, Maria Isabel da Silva Marques Abranches Viegas and Mariana Rita Antunes Marques dos Santos.

In accordance with its Internal Regulations, the Talent Committee is responsible for monitoring and supporting the appointment of

senior executives of the Company and the Navigator Group, as well as assessing the performance of these executives.

In the performance of its duties, and without prejudice to other competences assigned to it by the Company's Board of Directors,

the Talent Committee is particularly responsible for the corporate bodies:

In terms of appointments:

− Assisting the Board of Directors in identifying and assessing the suitability of the profile, knowledge and curriculum vitae

of members of the governing bodies to be appointed, namely the appointment by co-option to fulfil the duties of a

member of the Company's Board of Directors, as well as the choice of directors to fulfil executive duties;

− Making its terms of reference available and, to the best of its ability, introduce transparent selection processes that

include effective mechanisms for identifying potential candidates, and that those who are most meritorious, best suited to

the requirements of the position and promote appropriate diversity within the organisation, including gender diversity, are

chosen for proposals;

− Whenever deemed appropriate, to be aware of and monitor the selection processes for potential candidates to fulfil

executive management functions in subsidiary companies of the Group, in cases where the Company intends to submit

the respective elective proposal.

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In terms of evaluation:

− To monitor the system for assessing management performance and awarding Company remuneration;

− To give its opinion on the proposals for the annual individual performance appraisal of the members of the Executive

Committee, issued by the respective Chairman, and of the latter, issued by the Chairman of the Board of Directors;

− To monitor the overall assessment of the performance of the Board of Directors as a body, taking into account the

fulfilment of the Company's strategic plan and budget, risk management, its internal functioning and the contribution of

each member to this end.

In addition to other duties expressly assigned to it by the Board of Directors, it is the responsibility of the Appointments and

Appraisals Committee, particularly with regard to the other managerial staff:

− To monitor and issue recommendations on the Group's internal talent management policies and procedures;

− Periodically assessing the need for and availability of talent at Group level and recommending the appropriate actions to

ensure the Group's ability to respond to the challenges that arise, namely monitoring and issuing recommendations on

internal policies and procedures relating to selection, hiring, remuneration, ongoing assessment, remuneration and

incentive policies, as well as the succession plan for senior management, and making any recommendations it deems

appropriate in this regard.

The Committee is also responsible for talent management, especially with regard to senior management: (i) monitoring and

issuing recommendations on the Group's internal talent management policies and procedures and (ii) periodically assessing the

need for and availability of talent at Group level and recommending the appropriate actions to ensure the Group's ability to

respond to the challenges that arise.

By virtue of its members and its competences in terms of remuneration, performance assessment and appointments, the

existence of this Committee reflects adherence to Recommendation II.2.5. of the IPCG Corporate Governance Code.

In line with its competences, in 2024, in addition to its day-to-day work and communications carried out by telematic means, the

Talent Committee held two meetings at which the following topics were discussed: (a) performance appraisals for the 2023

financial year; (b) the performance appraisal process for the 2023 financial year; (c) succession plans and the presentation to the

Supervisory Board of proposals for a talent development plan and a succession plan.

ENVIRONMENTAL COMMITTEE

Given the specific nature of the Navigator Group's business and the environmental concerns inherent in it, the Board of Directors

set up an Environmental Board, which is responsible for monitoring and issuing opinions on the environmental aspects of the

company's business and making recommendations on the environmental impact of its main undertakings, taking particular

account of the legal provisions, licensing conditions and the Navigator Group's policy on the matter.

The Environmental Board has four members: Maria da Conceição Cunha (Chairman), Ana Isabel Miranda, Maria Margarida Tomé

and Joaquim Poças Martins, all of whom are independent academic figures of recognised technical and scientific competence,

particularly in the most important areas of environmental concern in the Navigator Group's current activity.

The Environmental Board has direct contact with the Navigator Group's business world, through meetings held at its industrial

sites, its main forestry plantations and its research institute, RAIZ.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 619

In 2024, two meetings of the Environmental Council were held, covering the following topics: environmental performance; future

industry scenarios; forests and climate change; Pedrogão - reforestation projects; WWTP 2 retrofit; community monitoring; EUDR

- impacts; O2 delignification in Setúbal; and forest fires.

SUSTAINABILITY FORUM

Recognising the fundamental role that sustainability plays in the Navigator Group's strategic development, the Navigator

Sustainability Forum was set up in 2015.

The main aim of the Forum is to foster collaboration between the Navigator Group and personalities who are part of its sphere of

activity, from non-governmental organisations to universities, social organisations, Customers and Suppliers.

This is an initiative that seeks to strengthen dialogue with its main stakeholders, promoting debate and active listening on issues

that are relevant to the Company and society.

As a rule, the Sustainability Forum meets twice a year, with one session involving permanent members only and the other

extending participation to various stakeholders, with a central theme for debate. The aim of the Sustainability Forum sessions is to

delve more deeply into issues essential to sustainability as a pillar of business strategy, and to receive contributions for

formulating corporate policy on social and environmental responsibility issues, positioning themselves as platforms for

understanding and co-operation between the Navigator Group and its main stakeholders.

The Sustainability Forum is made up of internal and external members and is chaired by the Chairman of the Executive

Committee, António Redondo, with Teresa Presas as Secretary General. The internal members are Ana Miranda, António Quirino

Soares, Dorival Almeida, João Paulo Cabete Gonçalves Lé, Joaquim Poças Martins, José Fernando Morais Carreira de Araújo,

Margarida Tomé, Maria da Conceição Cunha, Nuno Miguel Moreira de Araújo dos Santos and Vitor Paranhos Pereira.

The following people are external members of the Sustainability Forum, linked to activities of the company's main stakeholder

groups: Filipe Duarte Santos, Francisco Ferreira, Francisco Gomes da Silva, José Júlio Norte, Luís Neves da Silva, Rosário Alves,

Helena Freitas, Assunção Cristas, Rita Nabeiro and Filipe Santos.

In 2024, two sessions of the Sustainability Forum were held, one internal, attended by permanent members of the Forum,

members of the Board of Directors, managers and staff from various areas of Navigator's activity, and the other external,

attended by a wide range of the company's stakeholders. The Forum's internal session took place at the Figueira da Foz Industrial

Complex on 5 June, and its theme was ‘Sustainability Reporting in the context of CSRD: The particular case of Supply Chain

Management’, while the external session took place in Santarém on 4 November and was dedicated to the theme ‘2030 Agenda

for Responsible Management - Commitment to the Future’.

ETHICS AND INTEGRITY COMMITTEE

Following the drafting and approval of the Code of Ethics and Conduct by the Executive Committee in 2010, the Ethics and

Integrity Committee was set up to draw up an annual report on compliance with the rules contained in the Code of Ethics. This

report must explain all irregular situations of which the Committee is aware, as well as the conclusions and follow-up proposals it

has adopted in the various cases analysed.

The members of this Committee are Henrique Reynaud Campos Trocado, Jaime Alberto Marques Sennfelt Fernandes Falcão and

Rui Tiago Trindade Ramos Gouveia.

The Ethics and Integrity Committee is responsible for providing impartial and independent support to the company's bodies in

publicising and complying with the Code of Ethics in all Navigator Group companies.

the Ethics and Integrity Committee is particularly responsible for the following duties:

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 620

a) Checking that the Code of Ethics and Conduct is integrated into the Company's usual internal control systems;

b) To analyse the conclusions drawn by the Risk Management Department from any audits it carries out in relation to issues

covered by the Code of Ethics and Conduct;

c) Ensuring the operation of a mechanism for reporting breaches of the Code of Ethics and Conduct, as part of the

Company's whistleblowing mechanism;

d) Assessing and evaluating any situation that arises in relation to compliance with the precepts included in the Code of

Ethics and Conduct in which a member of a corporate body is involved;

e) To submit to the Corporate Governance Committee the adoption of any measures it deems appropriate in this area,

including the review of internal procedures;

f) To submit to the Board of Directors, should it deem it necessary, proposals for amendments to the Company's Code of

Ethics and Conduct;

g) Draw up an annual report on its performance in complying with the rules contained in the Code of Ethics and Conduct in

Navigator Group companies.

In carrying out its duties, the Ethics and Integrity Committee may obtain information and reports from the Compliance Area on

matters and initiatives related to the Code of Ethics and Conduct.

The Ethics and Integrity Committee also acts as an advisory body to the Board of Directors on matters concerning the application

and interpretation of the Code of Ethics and Conduct.

Under the terms of the Whistleblowing Regulations, whenever a communication involving a member of the Board of Directors or

the Supervisory Board is received, the Ethics and Integrity Committee is informed.

Three meetings were held in 2024, at which the activities carried out in 2023 were analysed, the main issues that have been

reported and raised within the scope of the Company's Code of Ethics and Conduct and the Company's Whistleblowing Channel, in

Portugal and abroad, and its functioning and mode of operation were discussed. The Ethics Committee's activity report for the

year ending 31 December 2023 was also discussed and approved.

RISK OVERSIGHT COMMITTEE

In July 2023, the Board of Directors set up the Risk Oversight Committee as part of the implementation of a new risk management

system (ERM NVG) that will allow closer, continuous and integrated monitoring of operations, carrying out real actions that will

help mitigate the risks that exist within the scope of the Group's activities.

The Committee includes the CEO, the Financial Director, a non-executive Director appointed by the Board of Directors, the Risk

Management Director, the Sustainability Director, the Legal, Compliance and Public Affairs Director and the person responsible for

Empremédia - Insurance Brokers, respectively.

The Committee's competences and responsibilities are:

a) To assess and comment on The Navigator Company Group's risk management policy;

b) To supervise the application of the defined risk management policy, including the definition of the risk appetite and the

maximum tolerance levels to be respected;

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 621

c) Supervising the operationalisation of the Risk Management Model (ERM - Enterprise Risk Management) defined by the

Group, specifically with regard to risk inventory and selection of the main business risks;

d) Anticipating the existence of new exogenous risks, namely those related to the use of new information technologies and

artificial intelligence mechanisms;

e) Monitoring the company's main risks, the level of effective exposure to risk and its potential evolution;

f) Monitoring the effectiveness of plans to mitigate the company's main risks;

g) To monitor the implementation of the Risk Management Committee's activity plans;

h) To take cognisance of the risk management monitoring reports issued by the Risk Management Committee and propose

the adoption of the necessary or appropriate measures in the light of these reports;

i) Contributing to the promotion of a risk culture within The Navigator Company Group.

III. SUPERVISION

(Audit Board, Audit Committee or General Supervisory Board)

a) COMPOSITION*

30. Identification of the supervisory body (Audit Board, Audit Committee or General Supervisory Board)

corresponding to the model adopted.

Under the single-tier management model adopted, the Company’s supervisory body is the Audit Board and the Statutory Auditor,

in accordance with section b) of no. 1 of article 413 of the Companies Code.

31. Composition, as applicable, of the Audit Board, the Audit Committee, the General and Supervisory

Board or the Committee for Financial Affairs, indicating the minimum and maximum numbers of

members and duration of their term of office, as established in the Articles of Association, number of

full members, date of first appointment and end date of the term of office of each member; reference

may be made to the item in the report where this information is contained in accordance with

paragraph 18.

In accordance with the Articles of Association, the Company’s Audit Board includes three full members, one of whom is Chairman,

and one substitute member, whose terms of office are three years - at the same time as the members of the Board of Directors -

and renewable.

Name

Date of first appointment and

end of Mandate

José Manuel Oliveira Vitorino

(Chairman)

2016

-2025

Gonçalo Nuno Palha Gaio Picão Caldeira

(Full Member)

2007-2025

He was an alternate member from 2015 to 2016. He joined the Audit Board as a full member in 2016 and as Chairman since 2018.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 622

Maria da Graça Torres Ferreira da Cunha Gonçalves

(Full Member)

2018-2024

Maria da Luz Gonçalves de Andrade Campos

(Full Member)

2024-2025

Marta Isabel Guardalino da Silva

(Alternate Member)

2024

-2025

The Company believes that the number of members of the Audit Board is perfectly adequate for its size and the complexity of the

risks inherent in its activity, ensuring that the duties entrusted to them are carried out efficiently. This judgement of adequacy

took into account, in particular, the Company's activities, the stability of the shareholder structure, as well as the diverse skills and

availability of the members of the Audit Board to carry out their duties, namely through close collaboration with the other bodies

and committees of the Company and the External Auditor and Statutory Auditor.

32. Identification, as applicable, of the members of the Supervisory Board, the Audit Committee, the

General and Supervisory Board or the Committee for Financial Affairs who are deemed independent, in

accordance with article 414 (5) of the Companies Code; reference may be made to the item in the

report where this information is contained in accordance with item 19.

The members of the Audit Board, José Manuel Oliveira Vitorino (Chairman) and Maria da Luz Gonçalves de Andrade Campos, are

considered by Navigator to be independent, in the light of the criteria set out in Article 414(5) of the Companies Code, the former

serving his third term and the latter her first. Maria da Graça Torres Ferreira da Cunha Gonçalves was considered independent, in

the light of the same criteria.

Gonçalo Nuno Palha Gaio Picão Caldeira, appointed at the Annual General Meeting of 17 May 2023 for a fifth term as a member of

the Audit Board, is a non-independent member of this corporate body, as results from the application of Article 414(5)(B) of the

Companies Code.

33. Professional qualifications, as applicable, of each of the members of the Audit Board, the Audit

Committee or the General and Supervisory Board or the Committee for Financial Affairs and other

relevant biographical details; reference may be made to the item in the report where this information is

contained in accordance with item 21.

José Manuel Oliveira Vitorino

(Chairman of the Audit Board)

José Manuel Vitorino has a degree in Business Organisation and Management from the Instituto Superior de Economia of the

University of Lisbon. He qualified as a Chartered Accountant and in the Executive Training Programme at Universidade Nova de

Lisboa. He was an Assistant Professor at the Faculty of Economics of the University of Coimbra, where he remained until 1980,

after which he joined PricewaterhouseCoopers and divided his activity between the areas of auditing and financial advisory

services, both in national and foreign companies and groups, and in projects in which he was part of international teams. He had

been a Partner for several years when he left PricewaterhouseCoopers in 2013 due to reaching the age limit. He also served as

Chairman of the Audit Board of Novo Banco, S.A., until 2017, and is a member of the Audit Board of ANA - Aeroportos de

Portugal, S.A. He has been a member of the internal control committee of Jerónimo Martins, SGPS, SA since May 2022. He has

Termination of duties due to death on April 12, 2024.

Was an alternate member from 2023 to 2024. She joined the Audit Board as an effective member on 12 April 2024, and her mandate was confirmed at the General

Meeting on 24 May 2024.

Firt appointment at the General Meeting of 24 May 2024.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 623

been a member of the Audit Board of The Navigator Company since 2015, and of Semapa and Secil since 2016, serving as

Chairman of these supervisory bodies since 2018.

Gonçalo Nuno Palha Gaio Picão Caldeira

(Full member of the Audit Board)

Gonçalo Picão Caldeira has a degree in Law and was admitted to the Portuguese Bar Association in 1991, after completing his

traineeship. He has a postgraduate degree in Management (MBA - Universidade Nova de Lisboa) and attended the Real Estate

Management and Evaluation course at ISEG. He has been working in property management and development through family

companies since 2004. Before that, he worked with the BCP Group from 1992 to 1998 and with the Sorel Group from October

1998 to March 2002. He also worked for Semapa from April 2002 to February 2004. He has been a member of the Audit Board of

the Company since 2007, of Semapa since 2006 and of Secil since 2013.

Maria da Luz Gonçalves de Andrade Campos

(Full member of the Audit Board)

Maria da Luz Campos has a degree in Finance from the Lisbon School of Economics and Management (ISCEF) and attended the

AESE/IESE Senior Management Programme (PADE), as well as various specialised training courses in finance and leadership. She

developed her professional career at ANA, EP/SA, where she held several important positions, most notably as Administrative and

Financial Director between 1995 and 2019, during which time she also held responsibilities in the Planning and Management

Control Department (2003-2004). She was a director and later Chairman of the Board of Directors of Portway Handling de

Portugal (2002-2005) and Audit Director of ANA, EP (1994-1995). She represented ANA on various international committees,

including Eurocontrol and ACI (Airports Council International), and was a member of the Investment Committee of Futuro,

Sociedade Gestora de Fundos de Pensões. She has extensive experience in financial management, auditing and strategic

processes, having actively participated in ANA's financing strategy, the split between airport management and air navigation, as

well as the privatisation process of ANA, SA. Since April 2024, she has been a member of the Audit Boards of Semapa - Sociedade

de Investimento e Gestão, SGPS, S.A., The Navigator Company, S.A. and Secil - Companhia Geral de Cal e Cimento, S.A.

Maria da Graça Torres Ferreira da Cunha Gonçalves

(Full member of the Audit Board)

Maria da Graça Torres Ferreira da Cunha Gonçalves had a degree in Business Organisation and Management from the Instituto de

Ciências do Trabalho e da Empresa (ISCTE) and was a chartered accountant. From June 1978 to November 1985, she held

various positions in the areas of General Accounting, Analytics and Financial Planning and Analysis at Magnetic Peripherals Inc.

Portugal. She was a financial analyst at Shell Portuguesa, S.A. between December 1985 and November 1989. Between December

1989 and July 1994, she was Controller and CFO of United Distillers Comp. Velha, Lda., with responsibility for the entire Finance,

IT and Purchasing areas. Between August 1994 and July 1995, she was CFO of ITT Automotive Europe GmbH, with responsibility

for the entire Financial and Personnel Area. From August 1995 to June 2015, she was Back Office Director at Pernod Ricard

Portugal, responsible for Finance, Management Control, Purchasing, Logistics, Production, Human Resources and Legal. In 2001

and 2002, she was responsible in Portugal for the acquisition of Seagram (Sandeman & Co.). Later, in 2005 and 2006, she was

responsible for the Financial and Human Resources areas of the Allied Domecq (Cockburn Smithes & C.ª) acquisition process. She

was vice-president of the sector's association, ACIBEV, representing Pernod Ricard. She was a member of the Audit Board of the

Company, Semapa and Secil, from 2018 to 2024.

b) OPERATION

34. Existence of operating regulations, and place where they can be consulted, as applicable, of the

Supervisory Board, the Audit Committee, the General and Supervisory Board or the Committee for

Financial Affairs; reference may be made to the item in the report where this information is contained in

accordance with item 24.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 624

The Company's Supervisory Board has its own internal rules of procedure, which are published on the Company's website, in the

Investors area, relating to Corporate Governance, and are freely available for consultation via the following link

https://en.thenavigatorcompany.com/Investors/Governance.

The annual report issued by the Supervisory on its activities is published together with the Annual Report and is available on the

Navigator Group's website.

35. Number of meetings held and rate of attendance at meetings of the Supervisory Board, the Audit

Committee or the General and Supervisory Board and the Committee for Financial Affairs, as the case

may be; reference may be made to the item in the report where this information is contained in

accordance with item 25.

The Audit Board held twenty-eight meetings during the 2024 financial year. All agendas and the respective minutes were sent to

the Chairman of the Board of Directors and are also available to the Risk Management Department.

Its current members were present at all the meetings held while they were in office, so their attendance rate was 100 per cent.

Maria da Graça Torres Ferreira da Cunha Gonçalves attended only one meeting, as her position was terminated for health reasons.

The number of Audit Board meetings held is freely available for consultation on the company's website at

www.thenavigatorcompany.com/en/investors/governance/

In accordance with the Regulations of the Audit Board, detailed minutes of the respective meetings are drawn up.

36. Availability of each of the members of the Audit Board, the Audit Committee or the General and

Supervisory Board and the Committee for Financial Affairs, as the case may be, indicating offices held

simultaneously in other companies, inside and outside the group, and other relevant activities carried

out by the members of these bodies during the period; reference may be made to the item in the report

where this information is contained in accordance with item 26.

José Manuel Oliveira Vitorino

Positions held in Navigator Group companies

Does not hold any positions in other Navigator Group companies.

Positions held in other companies / entities

Member of the Audit Board of ANA – Aeroportos de Portugal, S.A.

Member of the Internal Control Committee of Jerónimo Martins, SGPS, SA.

Chairman of the Audit Board of Secil – Companhia Geral de Cal e Cimento, S.A.

Chairman of the Audit Board of Semapa – Sociedade de Investimento e Gestão, SGPS, S.A.

Gonçalo Nuno Palha Gaio Picão Caldeira

Positions held in Navigator Group companies

Does not hold any positions in other Navigator Group companies.

Positions held in other companies / entities

Director at Linha do Horizonte Investimentos Imobiliários, Lda.

Director at Loftmania – Gestão Imobiliária, Lda.

Member of the Audit Board of Secil – Companhia Geral de Cal e Cimento, S.A.

Member of the Audit Board of Semapa – Sociedade de Investimento e Gestão, SGPS, S.A.

Director of Topologia II – SIC Imobiliária Fechada, S.A.

Maria da Luz Gonçalves de Andrade Campos

Positions held in Navigator Group companies

Does not hold any positions in other Navigator Group companies.

Positions held in other companies / entities

Started functions on 21 October 2024.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 625

Member of the Audit Board of Secil – Companhia Geral de Cal e Cimento, S.A.

Member of the Audit Board of Semapa – Sociedade de Investimento e Gestão, SGPS, S.A.

c) POWERS AND RESPONSIBILITIES

37. Description of applicable procedures and criteria for the supervisory body’s involvement in hiring

additional services from the external auditor.

In accordance with the rules laid down in the European Audit Regulation, Article 77(10) and (11) of the Statute of the Portuguese

Institute of Statutory Auditors, approved by Law no. 140/2015, the Internal Regulations of the Audit Board, as amended, and the

Internal Regulations on the approval of non-audit services, approved on 1 June 2016. º 140/2015, of 7 September, in the Internal

Regulations of the Audit Board, in the version in force, and in the Internal Regulations on the approval of non-audit services,

approved on 1 June 2016, the contracting of non-audit services - which are neither required by law nor constitute prohibited

services for the External Auditor and Statutory Auditor or any member of their network, by Navigator or by companies in a control

or group relationship with it - is subject to prior approval by Navigator's Audit Board, duly substantiated.

Accordingly, the proposals submitted by the external auditor are forwarded to the Audit Board for analysis and validation, seeking

essentially to safeguard (i) that these are permitted services, (ii) that the provision of these services does not affect the

independence and impartiality of the External Auditor, necessary for the provision of audit services, (iii) that the cumulative value

of the fees received for the provision of non-audit services does not exceed the limit defined in the EOROC and (iv) that the

additional services in question are provided with high quality and autonomy.

The Audit Board has therefore applied the rules laid down in the European Audit Regulation and the Statute of the Portuguese

Institute of Statutory Auditors, approved by Law 140/2015 of 7 September, and observes the internal procedures laid down in the

Internal Regulations on the approval of non-audit services to ensure that the legal provisions are complied with.

38. Other duties of the supervisory bodies and, if applicable, of the Committee for Financial Affairs.

1. The Audit Board has the competences that result from the law, and there are no delegated powers or assigned areas of

responsibility. The functions and duties of the Audit Board are expressly set out in its Operating Regulations, which provide for the

exercise of its powers, chairmanship, frequency of meetings, operation and the duties of its members. Detailed minutes of the

respective meetings are drawn up and can be consulted on the Company's website at

https://en.thenavigatorcompany.com/Investors/Governance.

In accordance with the Operating Regulations, revised in December 2023, the Audit Board ensures, in a timely and appropriate

manner, the flow of information, starting with the respective convening notices and minutes, necessary for the exercise of the

legal and statutory competences of each of the other bodies and committees.

2. In carrying out its duties, and without prejudice to other competences attributed to it by law, namely in article 420 of the

Companies Code, in accordance with its operating regulations, the Audit Board is particularly responsible for:

a) Supervising the management of the Company, including, in this context, annually assessing the budget, the internal

functioning of the Board of Directors and its committees, as well as the relationship between the various bodies and

committees of the Company;

b) To ensure compliance with the law and the articles of association;

c) Checking that the books, accounting records and supporting documents are in order;

d) Verify, when it deems it appropriate and in the manner it deems appropriate, the extent of cash and stocks of any kind of

goods or valuables belonging to the Company or received by it as a guarantee, deposit or other security;

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 626

e) Checking the accuracy of the accounting documents;

f) Verify that the accounting policies and valuation criteria adopted by the Company lead to a correct assessment of assets

and results;

g) Draw up an annual report on its supervisory activities and issue an opinion on the report, accounts and proposals

presented by the board of directors;

h) To convene the general meeting when the chairman of the general meeting does not do so;

i) Evaluate and comment on the strategic guidelines and risk policy prior to their final approval by the board of directors;

j) Supervising and evaluating the effectiveness of the internal control system, comprising risk management, compliance and

internal audit functions, and may propose any necessary Adjustments;

k) To give its opinion on the work plans and resources allocated to the services of the internal control system, including the

risk management, compliance and internal audit functions, and to propose any necessary adjustments;

l) Receiving reports of irregularities submitted by shareholders, Company employees or others;

m) To hire experts to assist one or more of its members in the performance of their duties, and the hiring and remuneration

of experts shall take into account the importance of the matters entrusted to them and the economic situation of the

Company;

n) Supervising the adequacy of the process of preparation and disclosure of financial information by the Board of Directors,

including the adequacy of accounting policies, estimates, judgements, relevant disclosures and their consistent application

between financial years, in a duly documented and communicated manner;

o) Propose to the General Meeting the appointment of the statutory auditor and the respective remuneration, indicating the

criteria that led to the choice of the proposed statutory auditor and describing the selection process conducted by the

auditor;

p) To propose to the General Meeting the dismissal of the statutory auditor or the termination of the contract for the

provision of their services whenever there is just cause for this;

q) Supervising the audit of the Company's financial statements;

r) To supervise the independence of the statutory auditor, in particular with regard to the provision of additional services,

and to assess annually the work carried out by the statutory auditor and its suitability for the performance of the duties

assigned to it;

s) To certify that the report on the structure and practices of corporate governance disclosed includes the elements referred

to in article 29-H of the Securities Code;

t) To issue a prior and binding opinion on the Regulation on Conflicts of Interest and Transactions with Related Parties to be

drawn up and approved by the Board of Directors or, in the absence of such a regulation, on the definition to be made by

the management as to whether the transactions that the Company carries out with related parties are carried out within

the scope of its current activity and under market conditions;

u) To issue, within a reasonable period of time, a prior opinion on any business with related parties that is not carried out

within the scope of the Company's current activity and under market conditions;

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 627

v) Verify that the transactions with related parties that the Company carries out are carried out within the scope of the

Company's current activity and under market conditions;

w) To fulfil the other duties laid down by law or the Articles of Association.

3. In accordance with its operating regulations, in the performance of its duties, and without prejudice to other powers attributed

to them by law, the members of the Supervisory Board may, acting jointly or separately:

a) To obtain from the management the presentation, for examination and verification, of the books, records and documents

of the Company, as well as to verify the stocks of any class of valuables, namely money, securities and merchandise;

b) Obtain from management, or from any of the Directors, information or clarification on the course of the Company's

operations or activities or on any of its businesses;

c) To have access to all the Company's information and employees in order to assess the Company's performance, situation

and development prospects, including, in particular, the minutes, the documentation supporting the decisions taken, the

notices convening meetings and the archives of the meetings of the other governing bodies, without prejudice to access

to any other documents or persons from whom clarification may be requested;

d) Obtain the reports made by the Company's internal control services, including the risk management, compliance and

internal audit functions, in particular those on matters relating to the rendering of accounts, the identification or

resolution of conflicts of interest and the detection of potential irregularities;

e) Obtain from the Company's statutory auditor the clarifications necessary for the annual assessment by the Audit Board of

the work carried out by the statutory auditor, as well as their independence and suitability to carry out their duties;

f) Obtain from third parties who have carried out transactions on the Company's behalf the information they need to

properly clarify such transactions;

g) Attend board meetings whenever they see fit.

4. In order to carry out its duties, the Audit Board may be assisted by experts specially appointed for this purpose and also by a

Company specialising in auditing work, and may decide to hire the services of experts to assist one or more of its members in

carrying out their duties.

5. In the performance of their duties, and without prejudice to other duties imposed on them by law, in accordance with their

operating regulations, the members of the Audit Board have the duty to:

a) Be informed and diligently prepare for Council meetings;

b) Participate in board meetings and attend general meetings, as well as board meetings called by the chairman or at which

the accounts for the financial year are examined;

c) Carry out conscientious and impartial supervision;

d) To keep secret the facts and information they become aware of as a result of their duties;

e) To inform the board of the checks, inspections and due diligence they have carried out and of the results;

f) To report, at the first meeting held, all irregularities and inaccuracies that they have verified, as well as whether they

have obtained the clarifications, they need to carry out their duties;

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g) Record in writing all the checks, inspections, complaints received and endeavours that have been carried out and the

results of these;

h) Inform the management body of the results of the statutory audit and explain how it contributed to the integrity of the

process of preparing and disclosing financial information, as well as the role that the supervisory body played in this

process;

i) Monitor the process of preparing and disclosing financial information and make recommendations or proposals to ensure

its integrity;

j) Supervising the effectiveness of the internal quality control and risk management systems and, if applicable, internal

auditing, with regard to the process of preparing and disclosing financial information, without violating their

independence;

k) Monitoring the statutory audit of the individual and consolidated annual accounts, including their execution;

l) Verify and monitor the independence of the statutory audit firm in the exercise of its statutory audit activity or in the

provision of other legally permitted services under the terms defined in the applicable law and regulations, namely

through:

Demonstration, during the selection process for the firm of statutory auditors, that the firm has internal mechanisms

in place to ensure independence and avoid conflicts of interest;

ii.

Regular proof by the audit firm that these internal mechanisms are adequate and comply with the applicable

legislation and regulations;

iii.

Obtaining an annual declaration of independence;

iv.

Annual communication of the separate audit services that have been provided;

A reasoned proposal as to whether the statutory audit firm's duties should be extended beyond the maximum legal

period, weighing up the respective conditions of independence and the advantages and costs associated with its

replacement;

vi.

Communication from the audit firm about exceeding the fee threshold; and

vii.

The joint analysis of possible threats to its independence and the application of safeguards to mitigate them;

m) Select the firms of statutory auditors to propose to the General Meeting for election and justifiably recommend a

preference for one of them;

n) Treating confidentially all Company documentation to which they have access in the performance of their duties, including

the content of meetings of the Board and other governing bodies in which they participate and information preparatory

thereto; and

o) To make available to the other governing bodies and committees, as required by law and the articles of association, all

the information and documentation necessary for the exercise of the legal and statutory competences of each of these

bodies and committees.

6. Members of the Audit Board must report to the Public Prosecutor's Office any offences of which they become aware and which

constitute public offences.

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7. Whenever any member of the Audit Board becomes aware of facts that reveal difficulties in the normal pursuit of the

Company's object, they must immediately notify the statutory auditor.

The Audit Board is also the main interlocutor of the External Auditor and Statutory Auditor, having direct access to and knowledge

of their work. The Company believes that this direct supervisory action by the Audit Board is possible, without interference from

the Board of Directors, in relation to the work carried out by the External Auditor and Statutory Auditor, as long as it does not

jeopardise the timely and adequate knowledge of the management body, which is ultimately responsible for what happens in the

Company and for the financial statements, in relation to this same work.

Respecting this principle, the reports of the External Auditor and Statutory Auditor are sent to the Audit Board and discussed at

joint meetings of this body with a member of the Board of Directors, including the results of the statutory audit, and the Audit

Board ensures that the necessary conditions for the provision of auditing services are in place within the Company. The Audit

Board is also responsible for proposing and monitoring, with the support of the Company's internal services, the remuneration of

the External Auditor and Statutory Auditor.

The Statutory Auditor also co-operates with the Audit Board in order to provide, immediately and in accordance with the

applicable laws and regulations, information on irregularities relevant to the performance of the Audit Board's duties that it has

detected, as well as any difficulties it has encountered in carrying out its duties.

In accordance with the Regulation of the Audit Board, the Statutory Auditor and the Company maintain permanent and adequate

channels of communication, namely by holding regular meetings with the management, the Audit Board and the departments and

directorates with responsibilities in the matters in question, and with the consequent discussion and analysis of all the information

that is pertinent to the exercise of the corresponding activity.

The Audit Board is also close to the Risk Management Committee. In fact, according to this committee's regulations, its chairman

must inform the Supervisory Board of any resolutions which, given their relevance, it should be aware of. On the other hand, all

the members of the Committee must be available to provide any clarification and information requested by the members of the

Audit Board; however, requests for information and clarification should preferably be made through the Chairman. Finally, the

members of the Audit Board may attend meetings of the Committee at the request of its Chairman or at the request of the Audit

Board, depending on the item on the agenda.

IV. STATUTORY AUDITOR

39. Identification of the statutory audit firm and the partner and statutory auditor representing the same.

The Company's Statutory Auditor is KPMG & Associados - Sociedade de Revisores Oficiais de Contas, S.A., registered with the

Portuguese Association of Statutory Auditors under no. 189 and with the CMVM under no. 20161489, represented by Rui Filipe

Dias Lopes (ROC no. 1715).

The substitute Statutory Auditor is Vítor Manuel da Cunha Ribeirinho (ROC no. 1081).

40. Indication of the consecutive number of years for which the statutory audit firm has held office in the

Company and/or Group.

The Statutory Auditor mentioned in point 39 has been working for the Company since 2018.

41. Description of other services provided by the statutory auditor to the company.

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In addition to the statutory audit services provided to the Company and its subsidiaries, the Statutory Auditor also provided other

assurance and reliability services, as well as financial information review services, in accordance with the provisions of Law

140/2015 of 7 September.

The amounts paid for these services throughout 2024 are detailed in points 46 and 47 below.

V. EXTERNAL AUDITOR

42. Identification of the external auditor appointed for the purposes of article 8 and the partner and

statutory auditor representing such firm in the performance of these duties, together with their

respective registration number with the Portuguese Securities Market Commission.

The Company's external auditor is KPMG & Associados - Sociedade de Revisores Oficiais de Contas, S.A., registered with the

Portuguese Institute of Statutory Auditors under no. 189 and with the CMVM under no. 20161489, represented in the fulfilment of

these duties by partner Rui Filipe Dias Lopes (ROC no. 1715).

43. Indication of the consecutive number of years for which the external auditor and the respective partner

and statutory auditor representing the same in the performance of these duties has held office in the

Company and/or Group.

The External Auditor and the respective Statutory Auditor who represents him in carrying out these duties were appointed at the

General Meeting in September 2017, for the financial year starting on 1 January 2018. They were re-elected to office at the General

Meeting held on 9 April 2019. Thus, 2023 was their sixth year in office with the Company and/or the Group.

44. Policy on rotation of the external auditor and the respective partner and statutory auditor representing

the same in the performance of these duties, and the respective frequency of rotation.

The policy and frequency of rotation of the External Auditor and Statutory Auditor and their representative is determined by article

54 of Law 140/2015 of 7 September (Statute of the Portuguese Institute of Statutory Auditors), which establishes the legal regime

applicable to the mandatory rotation of Statutory Auditors in public interest companies, such as Navigator.

In 2023, at the proposal of the Audit Board, which considered that the applicable legal conditions had been met, the Shareholders'

General Meeting approved the reappointment of KPMG & Associados - Sociedade de Revisores Oficiais de Contas, S.A. as the

Company's Statutory Auditor for the three-year period 2023-2025, under the terms of the Statute of the Portuguese Institute of

Statutory Auditors and the maximum time limits for carrying out statutory audit duties set out therein.

45. Indication of the body responsible for assessing the external auditor and the intervals at which this

assessment is conducted.

As part of its supervisory role and its review of the Company's financial statements, the Audit Board assesses the External Auditor

and Statutory Auditor on an ongoing basis, particularly in the context of the preparatory work for its Report and Opinion on the

annual accounts.

As well as being responsible for proposing the appointment of the Statutory Auditor and the respective remuneration to the

General Meeting, the Audit Board is the body responsible for assessing and monitoring all the audit work carried out by the

External Auditor on an ongoing basis, with the possibility of proposing its dismissal with just cause at the General Meeting,

provided the appropriate formalities are met. To this end, throughout the year the Audit Board meets regularly with the Statutory

Auditor and External Auditor, establishing a permanent and direct relationship between these two bodies, the latter being the

recipient of their reports, including when matters relating to the rendering of accounts and the detection of potential irregularities

are at issue. At these meetings, the Audit Board will be able to analyse all the accounting and financial information it deems

necessary at any given time and may request from them any information it deems necessary for its supervision.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 631

In addition, the Audit Board, in carrying out its supervisory duties and reviewing the Company's financial statements, carries out

an overall assessment of the External Auditor's performance each year as part of the preparatory work for its Report and Opinion

on the annual accounts and also monitors its independence, namely by obtaining written confirmation of the auditor's

independence; confirming compliance with the rotation requirements of the partner responsible and identifying threats to

independence and the safeguard measures adopted to mitigate them.

To this end, the Audit Board has unrestricted access to the documentation produced by the Company's auditors, being able to

request any information it deems necessary and being the first recipient of the final reports drawn up by the external auditors.

In accordance with the provisions of Article 420(2) of the Companies Code, the Audit Board is responsible for proposing the

appointment of the Company's Statutory Auditor to the General Meeting.

46. Identification of work, other than auditing, done by the external auditor for the company and/or for

companies in a control relationship with it, together with internal procedures for approving the hiring of

such services, specifying the reasons for doing so.

As described in point 47, in the year ended 31 December 2024 KPMG, Sociedade de Revisores Oficiais de Contas and other

entities belonging to the same network were invoiced for fees relating to the statutory audit of annual accounts, limited audit of

interim accounts and reliability assurance services and services other than auditing. The breakdown of the invoicing for these

services is detailed below in point 47.

The services indicated as ‘assurance services’ relate to the issuing of reports on financial information and verification services for

Sustainability Information. With regard to services other than auditing, they refer to the provision of financial information auditing

services to a group of companies within the scope of the acquisition by the Navigator Group, as well as agreed procedures

services on financial information. As mentioned above, these services are not included in the list of prohibited services set out in

Article 5(1) of Regulation (EU) No 537/2014 of the European Parliament and of the Council. As mentioned above, these services

are not included in the prohibited services list in Article 5(1) of Regulation (EU) No 537/2014 of the European Parliament and of

the Council of 16 April 2014, and the legal requirements for independence, threats to independence and safeguards to limit these

threats by the auditor have been guaranteed.

In 2024, the provision of non-audit services by the Statutory Audit Firm to the Company and subsidiaries is regulated in the

Internal Regulation on the approval of non-audit services, approved on 1 June 2016, which provides for non-audit services that

cannot be provided by the SROC and prior control and authorisation processes for these services by the Audit Board. The regime

defined in this internal rule is fully in line with the provisions of the Statute of the Order of Statutory Auditors, approved by Law

no. 99-A/2021, the Legal Regime for Audit Supervision, approved by Law no. 148/2015 and Regulation (EU) no. 537/2014 of the

European Parliament and of the Council. º537/2014 of the European Parliament and of the Council of 16 April 2014.

Therefore, the services provided by the External Auditor and Statutory Auditor, other than auditing, were always approved by the

Audit Board, in compliance with the applicable legal rules in force in 2024 and the internal procedures put in place for this

purpose.

47. Indication of the annual remuneration paid by the company and/or controlled, controlling or group

entities to the auditor and other individuals or organisations belonging to the same network, specifying

the percentage relating to the following services (for the purposes of this information, the concept of

network is as defined in Commission Recommendation No. C [2002] 1873 of 16 May 2002).

By the Company *

Value of audit services (€)

252,500 36%

Value of reliability assurance services (€) 116,500 17%

Value of tax consultancy services (€) 0 0%

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Value of services other than audits (€) 331,778 47%

By entities that are part of the Group*

Value of audit services (€) 248,470 83%

Value of reliability assurance services (€) 51,850 17%

Value of tax consultancy services (€) 0 0%

Value of services other than audits (€) 0 0%

* Including individual and consolidated accounts

In 2024, services other than auditing services billed to the Company or to entities in a controlling relationship with it by the

External Auditor and Statutory Auditor, including entities in a holding relationship with them or which are part of the same

network, represented 50 per cent of the total services provided.

C. INTERNAL ORGANISATION

I. Articles of Association

48. Rules applicable to the amendment of the Company’s Articles of Association (art. 29-H, no. 1, al. h).

The Company's Articles of Association do not define any specific rules for amending them, so the general rules of the Commercial

Companies Code apply.

II. Reporting of Irregularities (Whistleblowing)

49. Means and policy for reporting of irregularities (whistleblowing) occurring in the company.

The Navigator Company, as a listed company with a rigorous governance system, has implemented a Whistleblowing Channel,

which is available through a portal accessible from its websites, thus reinforcing the company's aim of having an internal

mechanism in which reports of irregularities are submitted in an effective system, in accordance with the rules of conduct

established by Navigator and the principles of guaranteeing anonymity, confidentiality, safeguarding and non-retaliation in

relations with whistleblowers, while complying with data protection and information security standards.

This Whistleblowing Channel is an independent service for reporting possible irregular practices, managed by an external entity

representing Navigator and intended for communications from Collaborators, Suppliers, Customers, Service Providers or any other

interested parties, as provided for in the Whistleblowing Regulations.

The Whistleblowing Regulations enshrine the general duty to report alleged irregularities within the Navigator Group, helping to

ensure that it continues to position itself as an upstanding, reputable and credible business group, as well as a fair, honest and

safe place to work.

In accordance with these Regulations, irregularities include violations of the rules set out in the Code of Ethics and Conduct and

other internal regulations, as well as non-compliance with external legislation or regulations to which The Navigator Company is

subject (e.g. violation of rules of conduct or ethics, fraud, corruption and related offences, protection of privacy and personal data,

health and safety, environmental protection, human rights, among others).

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The Regulation appoints a multidisciplinary team with the power to follow up on complaints received, known as the Whistleblowing

Committee (CDI), which is made up of the Director of Legal, Compliance and Public Affairs (DLC), the Director of Risk

Management (DGR) and the Compliance Officer, respectively. In cases where the complaint may concern any member of the

aforementioned Committee, it is referred to the Audit Board.

The person responsible for following up the complaint must determine whether the complaint contains the minimum grounds to

trigger an investigation process, as well as determining the involvement of other bodies, departments or Employees, when certain

requirements are met.

If the complaint has the minimum grounds, the investigation process begins, which consists of verifying all the facts necessary to

assess the alleged irregularity. This process ends with either the closure of the case or a proposal to apply the most appropriate

measures to the irregularity in question.

All persons with a conflicting interest in the situation being reported are excluded from the investigation and decision process, in

order to ensure that it is received, screened, analysed and filed in an independent, autonomous and impartial manner.

Reflecting a proactive approach on the part of our Stakeholders in identifying and reporting issues relevant to the Company,

during 2024 the Whistleblowing Channel received a total of 37 reports of irregularities, covering topics such as harassment or

discrimination, health, safety and environmental protection, as well as issues related to violations of policies or procedures,

privacy and data protection and food safety. Of these reports, only one was substantiated, concerning a situation of moral

harassment between employees.

Although all the cases were identified and dealt with due diligence, in relation to the substantiated situation, the appropriate

measures were taken to resolve it. This channel has proved to be a vital tool for promoting a culture of transparency,

responsibility and compliance within the organisation.

Following the events that took place in 2020 and 2021, underpinned by the 2020 criminal investigation into alleged corruption in

the wood reception activity at one of our manufacturing centres, which led to the dismissal with just cause of the workers involved

in that activity, legal proceedings are still underway in the labour and criminal courts. In fact, during 2024, Navigator continued to

monitor, in the competent labour courts, the legal challenges to the regularity and lawfulness of the dismissals of 28 workers, and

to date there have been no further developments in these cases. On the other hand, in the criminal courts, Navigator, as an

assistant, continues to monitor the case, and it has proceeded to the trial stage, with the production of evidence having already

begun.

III. Internal Control and Risk Management

50. People, bodies or committees responsible for internal audits and/or implementation of internal control

systems.

The Company's management and supervisory bodies have attached increasing importance to developing and improving the

Navigator Group's internal control and risk management systems.

In 2023, the Group improved its internal risk management process by implementing a new Enterprise Risk Management (ERM)

tool aligned with the guidelines of COSO - Committee of Sponsoring Organisations of the Treadway Commission and the ISO

31000 Standard. The implementation of this tool was carried out in conjunction with the Group's different departments and

initially focused on the UWF Pulp and Paper business lines. In 2024, ERM was extended to new businesses, namely the Tissue

Paper and Packaging businesses. This tool has brought greater alignment with the Group's strategy and objectives, as well as

targeted and continuous monitoring of risks, with the responsibilities of the different players in the process clearly defined.

In this context, the Navigator Group's Risk Management Governance Model was improved with the creation of two additional

bodies: the Risk Oversight Committee and the Risk Management Committee.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 634

The Governance Model is aligned with the Institute of Internal Auditors (IIA) 3-Line Model, which involves: (1) in the first line, all

the business units responsible for carrying out daily risk management activities; (2) in the second line, the Chief Executive Officer,

the Risk Management Department, the Compliance Area, Empremédia - Corretores de Seguros, the Sustainability Department and

the Risk Management Committee; (3) in the supervisory line, there is the Audit Board, the Risk Oversight Committee and Internal

Audit.

The internal control and risk management system is based on a systematic and explicit assessment of business risks by all the

Navigator Group's organisational departments and the identification of the main controls in place in all business processes. This

basis will enable the company to constantly assess the adequacy of its internal control system to the risks perceived as most

critical at any given time.

As part of this periodic assessment, an annual internal audit programme is established, to be carried out by the Internal Audit

department (Risk Management Department) in conjunction with each directorate involved, to monitor and assess the adequacy of

the said internal control system to the perceived risks and to support the organisation in implementing improvement programmes

for this system.

The external auditor checks the effectiveness and functioning of the internal control mechanisms as part of its statutory audit

work and reports any deficiencies to the Audit Board.

Within the framework of the Governance Model adopted for Risk Management, the responsibilities of the main players are defined

below.

BOARD OF DIRECTORS

The responsibilities of the Board of Directors in this area are:

− Reviewing and approving the risk management policy defined for The Navigator Company Group, including risk appetite

and tolerance;

− Setting risk-taking objectives and ensuring that they are met;

− Approve the risk management governance model adopted by The Navigator Company Group;

− Supervising the application of the risk management policy in The Navigator Company Group;

− Discuss and approve the strategic plan, including the definition of acceptable risk levels;

− Approve strategies for dealing with risks, particularly very high risks;

− Promote a risk culture within The Navigator Company Group.

AUDIT BOARD

The powers and responsibilities of the Audit Board in this area are:

− Supervising and assessing the effectiveness of the internal control system, comprising the risk management, compliance

and internal audit functions, and may propose any necessary adjustments;

− Evaluate and propose improvements to the risk management and internal control model, processes and procedures;

− Monitor the implementation of activity plans within the scope of risk management and internal control;

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 635

− Monitor, assess and comment on the strategic lines and objectives and the risk management policy defined by the Board

of Directors, proposing and implementing periodic control mechanisms and procedures with a view to ensuring that the

risks actually incurred by the company are consistent with the objectives set by the management body;

− Give its opinion on the work plans and resources allocated to the internal control services, including the control of

compliance with the rules applied to the Company and internal auditing;

− Take cognisance of the internal control and risk assessment reports issued by the External Auditor and propose the

adoption of measures deemed necessary or appropriate in the light of these reports;

− Take cognisance of the risk management monitoring reports issued by the Risk Management Department and to propose

the adoption of measures deemed necessary or appropriate in the light of these reports in terms of internal control;

− Take cognisance of and express an opinion on the activity carried out in this area by the Risk Management Department,

on the resources allocated to the services that also perform internal control functions, being the recipient, where

available, of the reports or opinions produced by these services when matters relating to the rendering of accounts, the

identification or resolution of conflicts of interest and the detection of potential illegalities and irregularities are concerned;

− Receive reports of irregularities submitted by shareholders, company employees or others, under the terms of the

Whistleblowing Regulations in force.

RISK OVERSIGHT COMMITTEE

The powers and responsibilities of the Risk Oversight Committee are:

− To assess and express an opinion on The Navigator Company Group's risk management policy;

− Supervise the application of the defined risk management policy, including the definition of the risk appetite and the

maximum tolerance levels to be respected;

− Supervise the operationalisation of the Risk Management Model (ERM - Enterprise Risk Management) defined by the

Group, specifically with regard to risk inventory and selection of the main business risks;

− Anticipate the existence of new exogenous risks, namely those related to the use of new information technologies and

artificial intelligence mechanisms;

− Monitor the company's main risks, the level of effective exposure to risk and its potential evolution;

− Monitor the effectiveness of plans to mitigate the company's main risks;

− Monitor the implementation of the Risk Management Committee's activity plans;

− Take cognisance of the risk management monitoring reports issued by the Risk Management Committee and proposing

the adoption of the necessary or appropriate measures in the light of these reports;

− Contribute to the promotion of a risk culture within The Navigator Company Group.

INTERNAL AUDIT

Internal Audit's responsibilities in this area are:

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− Defining a systematic and disciplined approach to evaluating the effectiveness of the internal control system, including

the risk management and compliance functions, and being able to propose any necessary recommendations;

− Defining and implementing the annual audit plan for risk management and internal control;

− Testing risk management and internal control procedures and proposing improvements;

− Regularly reporting on the status of audits, as well as the main conclusions of audits carried out and proposing

recommendations for improvement in the light of these reports.

CHIEF EXECUTIVE OFFICER

The responsibilities of the Chief Executive Officer in this area are:

− Defining The Navigator Company Group's risk management policy, including the risk appetite;

− Taking the risk management policy into account when defining the Navigator Group's strategic objectives;

− Provide means and resources for effective and efficient risk management;

− Approve the risk management model, processes and procedures;

− Define the risk management governance model to be adopted by the Navigator Group, including the responsibilities to be

assigned;

− Approve risk management activity plans;

− Ensure that the main risks to which The Navigator Company Group is exposed are identified and reduced to acceptable

levels, in line with the defined risk appetite and tolerance;

− Discuss and approve options for treating risks whose residual risk level is above the risk tolerance levels;

− Monitoring and reviewing the work carried out by the Risk Management Department within the scope of risk

management;

− Reporting results to the Board of Directors.

RISK MANAGEMENT DEPARTMENT

The responsibilities of the Risk Management Department in this area are:

− Proposing the risk management policy, standards and procedures and their respective revisions;

− Defining the risk management methodology, processes and procedures;

− Drawing up risk management activity plans;

− Identify and implement means and resources (human, procedural and technological) to facilitate risk identification,

analysis and management;

− Alerting to potential risks when defining strategic and operational objectives;

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 637

− Streamlining and monitoring the process of identifying, analysing, assessing and treating risks by risk owners;

− Supporting the definition of risk appetite and risk tolerance;

− Supporting the definition of responsibilities to be assigned within the scope of risk management;

− Supporting the identification and characterisation of risks;

− Monitoring risk indicators;

− Supporting the definition of risk mitigation measures;

− Evaluating the effectiveness of risk mitigation measures;

− Assessing compliance with risk tolerance;

− Ensuring compliance with risk mitigation action plans;

− Drawing up risk management monitoring reports.

LEGAL, COMPLIANCE AND PUBLIC AFFAIRS DEPARTMENT

In line with the evolution of best international practices, Navigator has set up a Compliance Department, part of the Legal,

Compliance and Public Affairs Department, emphasising the importance of pursuing a compliance policy that frames its activity

throughout the entire value chain, both legal and regulatory, with a view to transparency and fairness, in order to prevent and

combat illegal acts.

Navigator therefore considers it a structuring element for the proper management and mitigation of compliance risks associated

with its business and economic activities to have a system that promotes legal compliance and ethical conduct.

The compliance system aims to ensure compliance with applicable legal requirements, especially from the perspective of

preventing corruption, money laundering, terrorist financing, violation of international sanctions, protection of human rights and

protection of personal data, as well as reinforcing the ethical culture of the company and several of its stakeholders, namely

members of governing bodies, employees and suppliers, by promoting training and communication activities on matters of legal

compliance and ethical conduct.

This system is crucial if the company is to have adequate capacity to pursue its activities in accordance with the applicable legal

requirements in these areas and to promote ethical behaviour on the part of the relevant stakeholders, fostering respect for the

most appropriate standards and practices in the decision-making process, in the context of the challenges posed by the business

environment, and also contributing to the creation of value and the sustainability of the Navigator Group.

To achieve these goals, the compliance system is aligned with the following fundamental organisational dimensions of the Group:

− The governance model set out in the respective articles of association and in the internal regulations of the management

and supervisory bodies;

− The business strategy and objectives, in particular by focussing on the prevention, detection and remediation of non-

compliances that could have an impact on its economic and financial value;

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 638

− The risk management and internal control system, to allow the second line of defence of the COSO (Committee of

Sponsoring Organisations of the Treadway Commission) model to be incorporated and acted upon effectively in managing

the compliance risks to which the company is exposed; and

− The organisational culture, to promote assimilation of the importance of compliance matters for the organisation's

operation, resilience and reputation, and at the same time encourage the adoption of conduct that minimises the tangible

and intangible costs of non-compliance for the company and its people.

In order to make its compliance system effective, Navigator has implemented an effective and efficient compliance system

governance model which clearly identifies the competencies of the various players involved in the processes associated with its

business and which fosters appropriate coordination and communication between them, based on simple processes and

procedures guided by business objectives, so as to avoid bureaucratisation and loss of agility in business development.

The structure and organisation of the Navigator Group's compliance system is based on the coordinated action of the functional

units within the Group's internal structure, in conjunction with the management and supervisory bodies and in accordance with

generally accepted best practice, with a view to supporting the decision-making process.

With regard to the prevention of corruption and related offences, and compliance with the General Regime for the Prevention of

Corruption and Related Offences (RGPC), in particular, the company has one of its executive directors as the Regulatory

Compliance Officer and the Head of Compliance as the General Officer responsible for the Execution, Control and Review of the

Plan for the Prevention of Risks of Corruption and Related Offences (PPR).

Also in this context, over the course of 2024, the Navigator Group consolidated the Third Party Integrity Verification process and

developed a set of procedures with a view to the proper implementation of the policies in force and the mitigation of risks

identified in the PPR, in order to ensure more transparent action in line with its ethical principles.

Within the scope of internal control and risk management, the responsibilities of the Compliance Area are as follows:

− Preventing and detecting situations of legal non-compliance or inadequate ethical conduct;

− Presenting and coordinating the implementation of corrective or remedial measures for situations of legal non-compliance

or ethical misconduct;

− Drawing up and proposing a three-year plan for developing and updating the compliance system, assessing the need to

update/amend this plan on an annual basis;

− Preparing and proposing internal compliance standards and procedures;

− Carry out an integrity assessment of third parties that have dealings with the Navigator Group;

− Identify and manage compliance risks relevant to Navigator;

− Define compliance guidelines;

− Coordinating the activities of compliance officers and establishing the appropriate communication and reporting

mechanisms for their respective functions;

− Promote training and other capacity-building initiatives in compliance matters for Employees, Members of governing

bodies and other relevant Stakeholders;

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− Ensuring compliance with the duty to provide periodic information to the Supervisory Authorities and other requests from

these entities, in matters within their remit;

− Supporting the Ethics Committee in dealing with reports of irregularities concerning breaches of the Code of Ethics and

Conduct;

− Monitoring the handling of irregularities reported through the Whistleblowing Channel, by integrating the Compliance Area

Manager into the Whistleblowing Committee;

− Monitoring the level of compliance of Navigator Group companies.

EMPREMÉDIA - INSURANCE BROKERS

As part of the review of The Navigator Company Group's Risk Management Governance Model, it was decided to abolish the

previous Asset Risk Analysis and Monitoring Committee and integrate this component into the current Governance Model, in terms

of risk monitoring, to be carried out by Empremédia, which is the Group company responsible for insurance management.

Thus, Empremédia's responsibilities in this area include commenting on the risk prevention systems in place in the Group and

assessing the suitability of the risk insurance policies and the policies that they translate into.

RISK MANAGEMENT COMMITTEE

In order to implement the Risk Management Model (ERM), the Risk Management Committee was set up, comprising:

− Chief Executive Officer

− Financial Director

− Representatives from each monitoring area (Risk Management Department, Legal, Compliance and Public Affairs

Department, Sustainability Department and Empremédia - Insurance Brokers)

− Representatives from each of the defined risk families (Productive Commercial, Resilient, Capacity Building and

Reputational)

The responsibilities of the Risk Management Committee are:

− Evaluate and comment on the risk management policy;

− Propose the definition of the risk appetite and maximum tolerance levels to be respected;

− Review and approve the risk inventory;

− Reviewing the Group's risk matrix;

− Monitoring the follow-up and effectiveness of action plans for mitigation measures;

− Monitoring risk indicators;

− Evaluate the effectiveness of the risk management process;

− Defining those responsible for the risks identified;

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− Promote liaison between different Risk Management areas and subsystems;

− Regularly informing the Executive Committee and the Risk Oversight Committee of its activity and decisions.

BUSINESS AREAS/DEPARTMENTS

The responsibilities of the business areas/directorates in this area are:

− Participate in the process of identifying, analysing, assessing and treating risks;

− Defining risk tolerance;

− Identifying and characterising risks;

− Define and monitor risk indicators;

− Defining, implementing and executing risk mitigation measures in accordance with risk mitigation action plans;

− Carry out risk and control assessments.

51. Description of the lines of command in this area in relation to other bodies or committees; an

organisational chart may be used to provide this information.

The organisational and governance structure for internal control and risk management is based on the 3-line model of the IIA -

Institute of Internal Auditors, as shown in the figure below. This model ensures that:

− The first line is responsible for day-to-day risk management and internal control activities. Those responsible for risks and

internal control activities must carry out their daily duties in accordance with the business strategy and internal policies,

standards and procedures, including The Navigator Company Group's Risk Management Policy;

− The second line is responsible for defining compliance, sustainability and risk and internal control regulations and

verifying their implementation across the board, as well as challenging the risk identification and assessment carried out

by the first line and regularly monitoring risk levels;

− The third line supervises, controls and evaluates the effectiveness of risk management and internal control processes and

monitors the efficiency and effectiveness of risk mitigation measures.

In terms of the hierarchical and functional framework, it is important to emphasise that Internal Audit (Risk Management

Department), as well as reporting functionally to the Chairman of the Executive Committee, reports hierarchically to the

Supervisory Board, thus ensuring the necessary support for the proper execution of its competences. These relationships are

shown schematically in the organisational chart below:

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52. Existence of other departments with responsibilities in the field of risk control.

The company has the following committees, which complement the work of the Supervisory Board and the Chairman of the

Executive Committee in controlling and monitoring specific risks:

− Corporate Governance Committee - supervises the application of the Navigator Group's Corporate Governance rules and

the Code of Ethics, as well as overseeing internal procedures relating to matters of conflicts of interest, particularly with

regard to relations between the Navigator Group and its Shareholders or other Stakeholders.

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− Ethics and Integrity Committee - supervises compliance with the Code of Ethics and identifies situations that may

jeopardise compliance.

− Talent Committee - responsible for monitoring and supporting the appointment of senior executives in the company and

the Navigator Group, as well as assessing the performance of senior executives.

− Sustainability Forum - implements corporate and strategic policy on matters of social and environmental responsibility,

and the prevention of potential risks affecting these matters.

53. Identification of the main risks (economic, financial and legal) to which the company is exposed in the

course of its business.

The Navigator Company Group has a Risk Taxonomy, a tool to support risk management and which systematises the Group's

main risks, organised into 6 categories: strategic, financial, operational, compliance, technology and people (which includes

economic, financial and legal risks).

The Risk Taxonomy is a dynamic document that is reviewed annually by the Risk Management Department to reflect changes in

the organisation's internal and external environment. This approach ensures that risks are continually identified, categorised and

monitored in a consistent manner, allowing for proactive management in line with the Group's strategic objectives.

The Navigator Group's matrix of main risks in terms of impact and probability of occurrence is as follows:

# Main risks

(not exhaustive)

Summary Description

Main Mitigation Measures

1 Cybersecurity, information

systems and artificial

intelligence

(Technology Risk)

Risk of loss of security, confidentiality,

transparency, integrity and availability of data

and systems due to exposure to undue access

or new forms of cyber-attacks or information

theft, which exploit vulnerabilities in information,

corporate and industrial control technologies,

• Definition of the cybersecurity governance model;

• Information security policies and procedures;

• Cybersecurity incident response plan;

• Monitoring and access control;

• Intrusion testing and analysing security vulnerabilities;

•

Registration and control of IT/OT assets;

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# Main risks

(not exhaustive)

Summary Description

Main Mitigation Measures

or the improper use of artificial intelligence

technologies.

NB: In the year under review, the members of

the Company's governing bodies did not use

artificial intelligence mechanisms as a decision-

making tool.

• Third party risk management;

• Regular training and awareness-raising activities

in cybersecurity and artificial intelligence.

2 Access to wood

(Operational Risk)

Risk of actual unavailability of wood due to

regulatory or legislative restrictions (e.g.

restrictions on planting eucalyptus) and failures

to promote productivity, resilience and

sustainability of national forests.

• Sustainable Forest Management through certification by

the FSC and PEFC systems;

• Promoting chain of custody certification for all the

Group's wood suppliers;

• Communication, education and awareness of eucalyptus

among key stakeholders;

• Development (RAIZ) and production (nurseries) of

improved plants from a genetic improvement

programme;

• Prospecting for raw materials in national and

international markets;

• Drawing up an annual wood supply plan;

• Optimising wood inbound flows;

• Programme to encourage producers to join sustainable

and certified forest management models;

• Programmes to support forestry producers and enhance

production forests.

3 Talent management

(People Risk)

Risk of inability to attract, retain and develop

talent to cope with the departure of resources in

critical or difficult to replace business areas or to

respond to additional resource needs.

• Diversification of attraction and employer brading

strategies;

• Grow Project;

• Carrying out organisational climate studies;

• Human resources development and talent management

policy;

• Human Rights Policy;

• Gender equality plan;

• Existence of a competitive career plan that is up to date

with existing needs;

• Flexibility of the remote working model (partial regime);

• Implementation of development, recognition and

continuous improvement programmes (e.g. Future

Leaders Forum, Future Leaders Board, Straight to the

Top Programme);

• Ongoing training programmes tailored to employee

needs;

• Succession strategy and plan for critical positions;

• Adherence to the UN Global Compact.

4 Evolution of the regulatory

environment

(Compliance Risk)

Risk of regulatory changes arising from political

choices, particularly in fiscal, environmental or

economic terms, significantly affecting, directly or

indirectly, the Group's operations and/or results.

• Monitoring the most pressing issues on the political and

regulatory agenda in Europe, Portugal and Mozambique;

• Carrying out advocacy initiatives by the Public Affairs

Department in the regulatory, environmental and social

spheres;

• Participation in national and international industry

associations and events;

•

Business Round Table.

5 Adverse weather events

(Operational Risk)

Risk associated with adverse climatic events,

whether chronic (e.g. water stress) and/or acute

(e.g. cyclones or floods)

• Identifying and assessing environmental risks and

opportunities in accordance with national and

international benchmarks (e.g. TCFD) and integrating

them into decision-making processes;

• Carrying out studies and analysing climate risks at the

main plants;

• Environmental management system;

• Sustainable forest management through certification by

the FSC

and PEFC systems;

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# Main risks

(not exhaustive)

Summary Description

Main Mitigation Measures

• Roadmap to carbon neutrality and decarbonisation

targets approved by SBTi - Science Based Targets

initiative;

• Gradual elimination of fossil fuel energy consumption

and investment in renewable energy sources;

• Natural capital insurance.

6 Logistics chain

(Operational Risk)

Risk of lack or unavailability of sufficient logistics

resources to operate, as a result of natural

constraints (e.g. bad weather) or market

constraints (e.g. relocation of suppliers).

• Diversification of suppliers and means of transport;

• Developing partnerships/services in neighbouring ports,

achieving regularity and stability in services;

• Continuous monitoring of market prices, holding supply

tenders and regular requests for quotations;

• Regular monitoring of the use of logistical resources.

7 Access to utilities

(Operational Risk)

Risk of effective unavailability of utilities (e.g.

water and energy) in industrial activity.

• Realisation of investment projects aimed at reducing

water use in the Group's manufacturing complexes (e.g.

PRUA);

• Investments in energy efficiency;

• Decarbonisation plan;

• Permanent monitoring of water and energy

consumption;

• Preventive maintenance strategy for assets;

•

Diversification of supply sources.

8 Price volatility

(Strategic Risk)

Risk of fluctuating prices or margins due to

changes in market conditions.

•

Continuous and proactive market monitoring, enabling

assessment of short-term price expectations and

understanding of long-term trends;

• Frequent revision of the gross margin calculation in

order to monitor the evolution of prices to customers;

• Focus on strategic markets;

•

Definition of marketing and branding strategies.

9 Competitive environment

(Strategic Risk)

Risk of increased competitive pressures due

essentially to the competitive positioning of

producers with significantly lower production

costs.

• Cost reduction policy;

• Monitoring innovation and optimising processes;

• Diversification of products, markets and business

segments;

• R&D&I activities and investment in bioproducts;

• Definition of marketing and branding strategies;

• Providing new customer services (e.g. NVG Hub

omnichannel platforms);

• Monitoring technological developments with suppliers.

10 Fraud

(Compliance Risk)

Risk of fraudulent acts, corruption (e.g. conflicts

of interest) and/or unethical behaviour on the

part of the Group or third parties.

• Code of ethics and conduct;

• Code of Conduct for Suppliers;

• Regulations on conflicts of interest and transactions with

related parties;

• Definition of policies for the prevention of corruption and

related offences and compliance;

• Internal and external audits;

•

Regular compliance training sessions.

11 Access to financing

(Financial Risk)

Risk of unavailability of internal or external

financing due to endogenous causes (e.g. over-

indebtedness) or exogenous causes (e.g.

contraction and negative outlook for business

development, decrease in market liquidity).

• The Group's financing policy;

• Minimum liquidity stock policy;

• Definition and monitoring of compliance with financial

covenants;

• Diversification of sources (internal and external) and

financing instruments.

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# Main risks

(not exhaustive)

Summary Description

Main Mitigation Measures

12 External context

(Operational Risk)

Risk of significant or disruptive changes in the

Group's external context caused, for example, by

the occurrence of pandemics (e.g. Covid-19)

and/or serious economic recession in the main

markets or at European/global level.

• Continuous assessment of the macroeconomic context;

• Diversification of markets and clients;

• Diversification of suppliers and sources of raw

materials;

• Solid capital structure;

• Cost reduction policy;

• Insurance cover.

13 Occupational health and

safety

(Operational Risk)

Risk of accidents at work and/or failure to protect

the health of employees as a result of non-

compliance with safety procedures and rules or

the occurrence of unexpected public health

events (e.g. Covid-19).

• Certified safety management systems (ISO 45001);

• Continuous improvement plans;

• Employee assistance programme and health and well-

being initiatives;

• Mandatory use of personal protective equipment (PPE)

in the workplace;

• Training programmes on health and safety at work;

• Internal and external emergency plans.

14 Public perception

(Strategic Risk)

Risk of degradation, inability to monetise or

increase the value of existing reputational capital

in the medium to long term, due to reputationally

damaging events or inaction in the management

of existing reputational capital.

• Existence of various policies and standards to prevent

irregular conduct or inappropriate behaviour, supported

by a governance structure involving the compliance area

and by well-established reporting lines;

• Implementation of regular stakeholder consultation

mechanisms;

• Continued investment in raising awareness of the

Navigator Group's brands;

• Reinforced positioning and commitment to

environmental sustainability issues;

• Continuous strengthening of the market's perception of

the natural and sustainable origin of the Navigator

Group's paper and other products;

• Compliance with certifications and requirements for both

the materials purchased and the products produced.

15 Financial markets

(Financial Risk)

Risk of exposure to unfavourable variations in the

exchange rate and/or interest rate and applicable

ratings, which have a significant negative impact

on the Group's financial results.

• Hedging instruments;

• Definition of hedging strategies and exposure limits;

• Daily monitoring of exposure by currency;

• Definition of exposure limits to counterparties;

•

Permanent monitoring of commodity prices.

16 Biodiversity conservation

(Strategic Risk)

Risk of losing genetic variety, species and

ecosystems, jeopardising the resilience of natural

resources, sustainability and compliance with

legal requirements.

• Development of a biodiversity strategy;

• Certification of sustainable forest management by the

FSC

and PEFC systems;

• Assessment of natural values and the potential impacts

of operations, including mapping and inventorying them

and assessing their conservation status;

• Support programmes for forestry producers and the

enhancement of production forests;

• Training for suppliers and service providers on

sustainable forest management practices;

• Implementation of regular stakeholder consultation

mechanisms;

• Carrying out ecosystem restoration and requalification

projects.

17 Changes in consumption

(Strategic Risk)

Risk of a significant irreversible drop or

discontinuity in the consumption of the Group's

products or markets as a result of the emergence

of alternative products and technologies.

• Development of a quality product portfolio with

innovative solutions;

• Definition of marketing and branding strategies;

• Market and customer diversification;

• R&D&I activities and investment in bioproducts;

• Searching for market segments that are less sensitive to

variations in demand;

•

Monitoring market trends.

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# Main risks

(not exhaustive)

Summary Description

Main Mitigation Measures

18 Valuation of assets

(Operational Risk)

Risk of loss in the valuation of assets that

significantly impacts the value of the Group's

balance sheet.

• Asset diversification;

• - Maintenance of industrial and forestry assets;

• - Regular asset valuation;

•

- Regular impairment testing.

19. Knowledge Management

(People Risk)

Risk of losing accumulated knowledge within the

Group (intellectual capital), driven by the

departure of employees in key roles with specific

knowledge and/or experience, and by the

absence of effective knowledge-sharing and

transfer policies.

• Succession strategy and planning for critical positions;

• Conducting organizational climate surveys;

• Talent rejuvenation program;

• Investment in training and the Learning Center offering;

• Digital transformation projects aimed at streamlining

and simplifying processes.

20. Business Diversification

(Strategic Risk)

Risk of failing to identify opportunities for new

businesses, products, or processes.

•

Development of analyses and market research,

including market studies;

• Definition of a business diversification strategy;

• Alignment of synergies between new opportunities and

the core business;

• Empowerment and upskilling of internal teams;

• Regular monitoring of progress against objectives and

industry benchmarks.

21. Access to Raw Materials

(Operational Risk)

Risk of effective unavailability of raw materials

(e.g., chemicals) due to disruptions in supply

chains.

•

Sourcing of raw materials in national and international

markets;

• Partnership strategy with suppliers;

• Ongoing monitoring of market prices, conducting supply

tenders, and regularly requesting quotations from

suppliers;

• Monitoring of the entire supply chain;

• Specialized team exclusively dedicated to procurement;

• Diversification of raw material supply sources;

• Implementation of safety stocks based on the

complexity of the logistics chain;

• Existence of purchasing policies and procedures.

22. Non-Natural

Environmental Disasters

(Operational Risk)

Risk of a serious environmental accident caused

by non-natural incidents occurring at assets

under the Group's responsibility, originating

internally or externally, such as explosions of

industrial equipment or spills of toxic and

environmentally harmful substances.

• Existence of environmental operational control plans for

the Group’s industrial units;

• Existence of industrial maintenance plans;

• Regular audits of industrial facilities;

• Mandatory training and awareness-raising of employees

on safety and environmental matters;

• Existence of internal and external emergency plans;

• Fire detection and suppression systems;

•

Insurance coverage.

23. ESG Performance

(Strategic Risk)

Risk of weak strategic focus in the management

of ESG components, with significant impact on

the Group’s reputation and financial performance.

• Assignment and formalization of ESG performance

responsibilities at top management level;

• Integration of ESG considerations into corporate

decision-making, including investment decisions;

• Risk management framework aligned with international

best practices;

• ESG reporting alignment and compliance with global and

regulatory frameworks (e.g., Global Reporting Initiative,

SDGs, TCFD, SBTi);

• Continuous improvement of the reliability and quality of

ESG data collection, control, and validation systems;

• Issuance of debt linked to sustainability criteria (e.g.,

Green Bonds and Sustainability-Linked Loans).

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# Main risks

(not exhaustive)

Summary Description

Main Mitigation Measures

24. Climate Transition

(Operational Risk)

Risk arising from the process of adapting to a

low-carbon economy, namely the Group’s

inability to adjust to long-term and structural

changes in technology, regulation, and market

dynamics (e.g., changes in consumer

preferences).

• Monitoring of GHG emissions across the value chain and

use of an internal carbon price in investment analysis;

• Setting targets for GHG and water reduction;

• Alignment of investment decision-making and reporting

with global and regulatory frameworks (e.g., TCFD,

SBTi);

• Decarbonization plan.

25. Production Efficiency

(Operational Risk)

Risk of production inefficiency caused by errors

and/or failures in the production process.

• Benchmarking to optimize production;

• Operational cost reduction policy;

• Production efficiency targets;

• Technical integrity assessments of key facilities by

external experts;

• Preventive maintenance strategy;

• Predictive maintenance through digital initiatives using

advanced analytics, sensors, and process automation;

• Existence of internal and external emergency plans;

• Regular training for industrial teams;

• Culture of continuous and on-the-job learning;

• Investment in R&D&I (Research, Development, and

Innovation);

• Implementation of a rigorous quality control system;

• Implementation of safety stocks;

• Internal and external audits.

26. Governance

(Strategic Risk)

Risk of inability or unintentional failures in the

Group's governance model.

• Responsible business conduct based on ethics,

accountability, and transparency;

• Codes of ethics and conduct for employees and

suppliers;

• Ongoing evaluations of Group board members and

directors;

• Implementation of diversity and independence within

the Board of Directors and Executive Committee;

• Evaluation and nomination committees;

• Implementation of regular stakeholder engagement

mechanisms;

• Risk management framework aligned with international

best practices;

• Oversight through internal and external audits;

• Comprehensive discussion forums (e.g., Sustainability

Forum and Community Engagement Forum).

27. Innovation Management

(Strategic Risk)

Risk of low innovation activity with a

transformative impact on the business, mainly

due to a lack of focus on the effectiveness of

R&D&I processes from a business-oriented and

impact-driven perspective.

• Implementation of a Capex investment plan for

continuous improvement and technological R&D

objectives;

• Investment in R&D&I;

• Promotion of participation in collaborative/co-creation

projects with external entities (R&D, suppliers, clients,

innovative companies);

• Active promotion of intellectual property valorisation;

• Optimization and automation of industrial and business

support processes.

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# Main risks

(not exhaustive)

Summary Description

Main Mitigation Measures

28. Adverse Labor Situations

(Operational Risk)

Risk of occurrence of adverse labour situations

due to non-compliance with applicable labour

laws and/or inadequate management of labour

relations with employees, workers' representative

organizations, and unions.

• Compliance with labour laws and other applicable

worker regulations;

• Adherence to labour legislation;

• Development of occupational health and safety

programs;

• Implementation and monitoring of the labour

negotiation process;

• Promotion of initiatives that foster equality/equity,

diversity, and inclusion;

• Promotion of social dialogue with workers'

representative organizations and unions.

29. Customer Satisfaction

(Operational Risk)

Risk of declining customer satisfaction levels due

to product degradation and/or service delivery

failures.

• Maintenance of quality and innovation control

standards;

• Monitoring of market prices;

• Definition of minimum service level thresholds for

customers;

• Provision of new customer services (e.g., omnichannel

platforms like NVG Hub);

• Regular customer surveys to assess satisfaction levels.

30. Investment Decision-

Making

(Strategic Risk)

Risk of difficulties in executing investments

considered strategic and necessary for business

development and operational efficiency.

• Monitoring and evaluation of market and industry

trends;

• Investment analysis, including an integrated risk

assessment;

• Ongoing monitoring of investment projects;

• Regular cost control discipline;

•

Insurance coverage.

31. Customer Credit

(Financial Risk)

Risk of difficulty or inability to collect the full

amounts granted as customer credit within the

agreed timeframes.

•

Formal customer approval process by the Executive

Committee Member responsible for commercial matters;

• Credit insurance coverage for all operations;

• Existence of alternative mitigation measures (e.g., Cash

in Advance, Cash Against Documents);

• Continuous monitoring of customer exposure and

overdue accounts.

The risks posed by climate change, alongside the evolution of ESG topics, have taken on particular importance in The Navigator

Company’s risk management framework. In addition to being directly linked to Navigator’s business processes—with mitigation

controls in place and subject to monitoring—climate change is reflected across multiple areas of our risk management structure.

For example, risks such as access to raw materials or CO₂ licensing may, to a large extent, stem from drought phenomena or the

(de)carbonization of economies. These are issues that Navigator seeks to anticipate and which are extensively addressed in

another section of this Report.

54. Description of the process of identification, assessment, monitoring, control and management of risks.

Risk management represents a key tool for The Navigator Company in supporting decision-making, through the continuous

monitoring of the risks to which it is exposed. It fosters a broad awareness across the organisation of a risk culture that not only

emphasizes risk avoidance but also embraces the positive perspective of taking calculated risks.

In addition, the various business areas and departments benefit from risk management by being able to anticipate uncertain

scenarios—mitigating risks with adverse consequences while leveraging those that carry potential opportunities. This results in

greater and more sustainable decision-making capabilities across the organisation, enabling Navigator to respond in a coordinated

and integrated manner to risks whose causes, impacts, or vulnerabilities span multiple areas.

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From an Internal Audit and internal control perspective, risk management is particularly relevant, as it allows for continuous

evaluation of The Navigator Company’s risk profile and contributes to strengthening internal controls. Risk management also plays

a vital role in guiding Internal Audit activities, directing efforts toward the areas and processes that present higher levels of risk

and concern for the business—an approach known as “Risk-Based Internal Auditing.” As an immediate outcome of this approach,

audit activities can be planned and executed with a focus on the most relevant risks to The Navigator Company, supported by a

structured audit planning methodology.

The Navigator Company’s risk management process follows internationally recognized best practices, models, and frameworks,

including the COSO II – Integrated Framework for Enterprise Risk Management and ISO 31000.

Risk management at Navigator is guided by the Risk Management Policy, which: (i) establishes the principles, guidelines, and

responsibilities for the proper identification, analysis, evaluation, treatment, and response to risks; and (ii) ensures that risk

management is aligned with the Group’s strategic objectives, fostering a risk-aware culture across the organization.

The risk management process has been developed with ISO 31000 as a reference for its main phases, and COSO II as a basis for

the systematization and structuring of risks. This process consists of seven interrelated stages and incorporates an iterative cycle

of continuous improvement, underpinned by communication and consultation, as well as monitoring and review mechanisms. The

following figure schematically illustrates the risk management process flow.

Establishing the Context

The purpose of establishing the context is to define the scope of risk management and includes: (i) identifying the internal and

external environments in which the Group operates and assessing potential changes in these environments; (ii) identifying the

organisational scope of risk management; and (iii) defining a set of criteria through which risks will be assessed.

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Risk Identification

Risk identification is supported by the Risk Taxonomy, a risk management tool that systematises the Group's main risks,

organised into six categories: strategic, financial, operational, compliance, technology, and people. This identification is further

supported by meetings and workshops with business areas, risk benchmarking analyses, and market trend assessments.

In the area of information security, risk identification is also based on internal and external vulnerability analyses, cyber security

incident investigations, and both internal and external audits.

Risk Analysis

The objectives of this stage are to identify ways of mitigating the impact and likelihood of risks, as well as to define indicators that

signal a risk event may be imminent or has already occurred. Risks are prioritised and mapped onto a risk matrix, and mitigation

measures are identified to reduce the likelihood and/or impact of each risk. These are compiled into risk registers.

The risk matrix allows for the categorisation and ranking of risks in order of importance and supports the definition of any

additional mitigation measures deemed necessary. Following risk identification, risk appetite is also defined—i.e., the level of risk

the Group is willing to accept in order to achieve its strategic and business objectives.

At this stage, risk indicators (KPIs/KRIs) are also established. These act as early warning tools, allowing the anticipation of

potential or emerging risk events.

Risk Assessment

Risk assessment is carried out using both qualitative and quantitative criteria, based on the likelihood of occurrence and the

magnitude of the impact, evaluated on a five-point scale in accordance with the Group’s defined risk appetite.

The risk level for each individual risk is calculated by multiplying the probability of occurrence by the potential impact. Probability

is measured by how often or likely a risk may occur within a given period and can be based on historical data, expectations, or

frequency of occurrence.

The impact is measured across six dimensions: (1) Financial; (2) Reputation; (3) Compliance; (4) Human Capital; (5)

Environmental and (6) Information Security.

This process is reviewed annually or whenever justified by changes in the business or context.

Risk Treatment

Once risks are identified and assessed, the decision-making process begins to determine and implement the risk response

strategy, in accordance with the established risk appetite. Possible types of risk response include accept; mitigate; transfer; or

avoid.

The Risk Management Department monitors the implementation of risk response measures and reports their status to the

Executive Committee, Risk Oversight Committee, Risk Management Committee, and Audit Board.

Communication and Consultation

Communication is a key element at every stage of the risk management process. The Risk Management Department produces

regular reports for both internal and external Stakeholders — namely the Risk Management Committee and the Risk Oversight

Committee — on risk exposure, follow-up on mitigation measures, and the evolution of KPIs and KRIs.

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Monitoring and Review

Ongoing monitoring and periodic review of the risk management process are essential to ensure it remains effective, relevant, and

up to date over time. The Risk Management Department continuously monitors the evolution of the Group's risks, the

implementation of risk responses, and the risk indicators as part of the Group’s annual risk management cycle.

The Risk Management Committee, the Risk Oversight Committee, and the Audit Board are responsible for overseeing the risk

management process, contributing suggestions for improvements or changes to risks, mitigation measures, or risk indicators.

In addition, Internal Audit provides independent assurance regarding the effectiveness of controls and recommends improvements

whenever necessary. In this context, during 2024, a series of internal control audits were carried out, along with follow-ups on

previously identified audit issues.

This year’s work focused primarily on internal control processes, particularly mapping the main organisational processes with the

identification of associated risks and operational controls, strengthening risk assessment and operational information systems—

especially in the area of cyber security—analysing paper pulp stock traceability processes, and assessing performance in forest

protection.

Furthermore, monitoring of internal control topics identified by the External Auditor continued.

The external audit is conducted by KPMG. The Company’s External Auditor verifies the effectiveness and operation of internal

control mechanisms based on the information provided by the Company. The findings from these audits are reported to the Audit

Board, which in turn reports any deficiencies identified, where applicable.

55. Main components of internal control and risk management systems implemented at the company for the

disclosure of financial information (art. 29-H, no. 1, para. l).

The Company has an internal control system in place regarding the preparation and disclosure of financial information, which is

ensured by the Company’s departments and business areas, namely the Accounting and Tax Department, the Management

Control Department, the Risk Management Department, and the Investor Relations Department, and is regularly monitored by the

Audit Board.

Within the scope of this system, the Audit Board reviews the financial information on a quarterly basis, based on reports prepared

by the relevant departments and, on a half-yearly and annual basis, relies on the opinion issued by the Statutory Auditor and

External Auditor.

In this context, meetings are also held involving the Risk Management Department, members of the Executive Committee, the

Statutory Auditor and External Auditor, as well as those responsible for accounting and for Planning and Management Control, in

order to monitor ongoing processes.

The components of the internal control and risk management system are described in Section 54.

IV. Investor Support

56. Office responsible for investor support, composition, functions, information provided and contact

details.

The Company has had an Investor Relations Office since 1995. This Office's mission is to ensure permanent and appropriate

contact with the financial community - Investors, Shareholders, Financial Analysts and Regulatory Entities - and to promote the

communication of relevant information on the Company's performance, historical and current performance and future strategy.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 652

In accordance with the principles of coherence, integrity, regularity, fairness, credibility and timeliness, it contributes to facilitating

the investment decision-making process and the sustained creation of shareholder value.

The Investor Relations Office is also responsible for monitoring all matters relating to the relationship with the Portuguese

Securities Market Commission (CMVM), the fulfilment of legal obligations to inform the regulator and the market, as well as

responding to requests for information from investors, both institutional and private, domestic and foreign, and from financial

analysts who draw up opinions and recommendations on the company's shares.

The Investor Relations Office is made up as follows:

Head: Ana Canha, who also fulfils the duties of Market Relations and CMVM Representative, whose contact details are

detailed in the following section.

Team: Catarina Augusto

All mandatory information, such as information on the company, the registered office and the other details mentioned in article

171 of the Companies Code, is available on the Navigator Group's website, whose address is www.thenavigatorcompany.com/en.

In addition to the mandatory information, in Portuguese and English, the site provides a range of general information about the

Group, namely:

− Financial information (presentations, disclosure of results and quarterly reports and accounts, annual reports and

information on debt);

− Insider information releases to the market and other releases;

− Information on the performance of Navigator's shares on the stock exchange and the recommendations issued by

analysts;

− Annual calendar of corporate events, including, among others, the General Shareholders' Meeting and the disclosure of

annual, half-yearly and quarterly accounts;

− Corporate Governance Information;

− The Navigator Company's Code of Conduct;

− Description of the governing bodies, as well as the Company's Articles of Association;

− Regulations in force;

− Information on General Shareholders‘ Meetings, such as notices convening General Shareholders’ Meetings, proposals

submitted for discussion and voting at General Shareholders' Meetings, resolutions passed and attendance statistics;

− Minutes of General Shareholders' Meetings.

In order to provide the market with a clear, transparent and up-to-date view of the company's strategy, both in terms of

operational performance and future prospects, the Office organises and participates in various events. These events aim to

present the company's strategies and prospects to the market, as well as monitoring the development of activities throughout the

year and clarifying any doubts. In this way, an open dialogue is maintained with all stakeholders throughout the year. Among the

activities organised, the following stand out:

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 653

− Virtual and face-to-face meetings with financial analysts and investors;

− Responses to questions addressed to the Office, sent by e-mail to a specific address or by telephone;

− Virtual and face-to-face meetings with members of the management team, namely the Group's CEO and CFO;

− Investor meetings held at the industrial complexes;

− Dissemination of announcements to the market through the CMVM, and sending email messages to all investors and

financial analysts in the database created and updated by the Office;

− Quarterly results presentation conference calls with Navigator's Executive Committee;

− Presentations to the financial community: presentation of results, conferences and Annual General Meeting of

Shareholders;

− Continuous process of updating the Investors Area at the institutional address.

Contacts:

Contact with the Office is possible through the Market Relations Representative, the Company's general telephone contacts (+351

219 017 300) and the email address: investidores@thenavigatorcompany.com

These contacts are available on Navigator's website, in the Investors area.

57. Investor Relations Officer.

The Company's Market Relations representative is Ana Rosa Pinelo Esteves Canha and can be contacted via the Company's

general telephone number (+351 219 017 300) or the following email address: ana[email protected].

These contacts are available on Navigator's website, in the Investors area.

58. Information on the proportion and response time to information requests during the year or pending

from previous years.

Navigator is keen to ensure proximity to the capital market community, through transparent, objective and consistent

communication of the Company's strategy. Over the course of 2024, the Company took part in eight events - the same number as

in 2023 - bringing together Investors, Financial Analysts and other entities, and went on a field trip to the Figueira da Foz

Industrial Complex. These events resulted in a total of 96 meetings (90 in 2023), of which 65 were face-to-face (37 in 2023) and

31 virtual (53 in 2023). In addition, four conference calls were held to present the quarterly results, which were attended by

analysts and institutional investors.

At the same time, several follow-up meetings were held throughout the year with the 8 Analysts who cover Navigator's shares,

and contacts and meetings were held with private and institutional Investors90 in 2023.

The Investor Relations Office also received enquiries and requests by electronic means (email and telephone), with an average of

20 contacts/month, and received and answered around 240 requests over the course of 2024, with an estimated average

response time of less than 3 working days. There were no outstanding requests for information at the end of the year.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 654

V. Website

59. Address(es).

Navigator's website address is available in Portuguese and English:

− www.thenavigatorcompany.com

− www.thenavigatorcompany.com/en/

60. Location information on the company name, public company status, registered office and other items

referred to in article 171 the Companies Code.

The above information is available on Navigator's website, in the Investors area, a:

− https://en.thenavigatorcompany.com/Investors/Navigator-Share.

61. Location of the articles of association and operating regulations of boards and/or committees.

The above information is available on Navigator's website, in the Investors area, in the Corporate Governance section, at:

− https://en.thenavigatorcompany.com/Investors/Governance.

62. Location of information on the identities of members of statutory bodies, the market relations officer

and the Investor Support Office or equivalent structure, and their respective duties and means of

access.

The aforementioned information is available on Navigator's website, in the Investors area, specifically in the section on Corporate

Governance, as well as in the section entitled Profile, available, respectively, at:

− https://www.thenavigatorcompany.com/en/investors/governance/

− https://www.thenavigatorcompany.com/en/investors/investor-support-office/.

63. Location for consultation of financial statements and reports, which must be accessible for no less than

five years, together with the six-monthly corporate diary, disclosed at the start of each semester,

including, amongst other things, General Meetings, disclosure of annual, half-yearly and (if applicable)

quarterly accounts.

Navigator's quarterly, half-yearly and annual results, published since 2003, are available in the Investors area, in the section

entitled ‘Financial information’, available at:

− https://www.thenavigatorcompany.com/en/investors/financial-information/

The calendar of company events for the current year has its own tab in the Investors area entitled ‘Calendar’, available at:

− https://thenavigatorcompany.com/en/investors/calendar/

64. Location for publishing the meeting notice for the General Meeting and all preparatory and subsequent

information related to it.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 655

The notice for the General Meeting, as well as all the preparatory and subsequent information related to it, is available in the

Investors' area, in a separate tab entitled "General Meetings", available at:

− https://en.thenavigatorcompany.com/Investors/General-Meetings.

65. Location for publishing a historical archive of decisions made at the company’s general meetings, share

capital representation and voting results for the 3 preceding years.

The aforementioned information is available in the same place as the information on General Meetings, i.e. in the Investors' area, in a

separate tab entitled "General Meetings", available at:

− https://en.thenavigatorcompany.com/Investors/General-Meetings

D. REMUNERATION

I. Powers to determine remuneration

66. Indication of the powers for determining the remuneration of statutory bodies, members of the

executive committee or managing director and company managers.

The body responsible for determining the remuneration of the Board of Directors and the Supervisory Board is the Remuneration

Committee.

With regard to the Company's directors, this competence belongs to the Board of Directors.

II. Remuneration Committee

67. Composition of the Remuneration Committee, including identification of individuals or organisations

contracted to provide support, and declaration regarding the independence of each member and

adviser.

The Remuneration Committee is made up of Maria Eduarda Faria e Maia de Oliveira Luna Pais, João do Passo Vicente Ribeiro and

Carlota Infante da Câmara Albergaria Caldeira.

The Company considers that all members of the Remuneration Committee are independent.

The Remuneration Committee does not have any people hired to assist it. The Company is free to appoint the services it deems

necessary or convenient, within the Company's budgetary limits, a right it has exercised in the past, in which case it must ensure

that the services are provided independently and that the respective providers are not contracted to provide other services to the

Company itself or others in a controlling or group relationship without the express authorisation of the committee. The Company

believes that the composition of the Remuneration Committee ensures its independence from management, as all its members

are independent.

At the Company, the Remuneration Committee provides all information or clarification to the Shareholders at the respective

Annual General Meetings or at any other General Meetings, if the respective agenda includes a matter related to the remuneration

of the members of the Company's bodies and committees or if such attendance is requested by the Shareholders, doing so

through the presence of at least one of its members. This was the case at the Annual General Meeting of 17 May 2023, which was

attended by all its members.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 656

68. Expertise and experience of the members of the Remuneration Committee in the field of remuneration

policy.

Two of the members of the Remuneration Committee, Eduarda Luna Pais and Carlota Albergaria Caldeira, have extensive

knowledge and experience of remuneration policy.

Eduarda Luna Pais was a consultant at Egon Zehnder for several years and subsequently Office Leader and Partner at this

Company, which has extensive experience and is a leader in executive recruitment, involving in-depth and constantly updated

knowledge of assessment processes and criteria and the associated remuneration packages.

For her part, Carlota Albergaria Caldeira has solid experience in human resources consultancy with a focus on managing executive

search projects (national and international markets) and assessments. For several years, she carried out various consultancy

projects for companies providing services in the area of talent management and executive recruitment, such as Jason Associates,

Argo Talents and Mercer. He was also a Senior Associate at Heidrick & Struggles, where he managed several Human

Capital/Leadership Services consultancy projects.

III. Remuneration structure

69. Description of the remuneration policy of the management and supervisory bodies referred to in article

2 of Law no. 28/2009, of June 19.

The remuneration policy for the management and supervisory bodies ("Remuneration Policy") for the 2023 financial year, drawn up

by the Remuneration Committee, was approved at the Annual General Meeting of 17 May 2023, and corresponds to Annex 2 of this

Report, and there is no departure from the procedure for applying the approved remuneration policy or derogations from it.

70. Information on the means of structuring remuneration to align the interests of managing board’s

members with the long-term interests of the company, and how this is based on performance

assessment, discouraging the assumption of excessive risk.

The way in which the remuneration of the governing bodies was structured and how the assessment of the performance of the

executive management in 2024 was based complied with the model and principles - duties performed, the Company's economic

situation and market criteria - set out in the Remuneration Policy for members of Navigator's management and supervisory bodies

in force, to which reference is made. Point 24 above describes the process and the bodies involved in assessing the performance

of executive directors.

The remuneration system in force at Navigator ensures its business strategy and also, in the long term, the alignment of the

interests of the members of the board of directors with the interests of the Company and its sustainability, in particular, because it

is a remuneration that seeks to be fair and equitable, within the scope of the principles set out, and because it associates the

members of the board of directors with results, through a variable component of remuneration that has results as the

preponderant factor, but also takes into account the behavioural skills of each director, such as their alignment with the long-term

interests of the Company and its sustainability.

Regarding the remuneration components:

(a) Non-executive Directors

The remuneration of the non-executive members of the Board of Directors consists only of a fixed component, corresponding to an

annual amount, payable 12 times a year, which may be differentiated due to the accumulation of functions and increased

responsibilities (for example, members of specialised commissions or committees, or a predetermined amount for each attendance

at a Board meeting). The remuneration of the non-executive members of the Board of Directors does not include any component

whose value depends on the Company's performance or its value.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 657

(B) Executive Directors

The remuneration of the executive members of the Board of Directors consists of a fixed component, corresponding to an annual

amount, payable 12 times a year.

The annual variable remuneration of executive directors is occasional and, overall, may correspond to a percentage not exceeding

five per cent of the net profit for the previous financial year, in accordance with the Company's Articles of Association.

The Remuneration Committee is responsible for setting this component, and the performance assessment of each executive

director follows an internal process structured under the responsibility/leadership of the person in charge (i.e. under the

responsibility of the person who chairs the team, in the case of the members of the Executive Committee, and under the

responsibility of the Chairman of the Board of Directors, in the case of the Chairman of the Executive Committee) and in which the

non-executive directors who the person in charge deems relevant are also involved. Also involved in this process is the Talent

Committee, which is responsible for monitoring the system for assessing management performance and awarding remuneration,

and for giving its opinion on the proposals for individual performance assessments for executive management. Finally, the

Remuneration Committee is responsible for confirming the respective achievement factors in the performance appraisal and

ensuring the overall coherence of the process by setting the variable remuneration.

The annual variable remuneration is based on a target value applicable to each director, which is paid under conditions of

performance by the director and the Company that correspond to the expectations and objectives previously set. This target value is

defined by weighing up the general principles mentioned above - market, specific functions, the Company's situation - with emphasis

on comparable market situations in functions of equivalent relevance.

The weightings of actual performance in relation to expectations and objectives, which determine the variation in relation to the

target, are based on a set of quantitative and qualitative KPIs related to the Company's performance (corresponding to general

business indicators, with a weight of 65%) and the performance of the Director in question (corresponding to specific objectives, with

a weight of 20%, and behavioural indicators, with a weight of 15%).

The general business indicators and their respective weightings, which may be adjusted annually by a maximum of 5 per cent, are as

follows:

a) EBITDA, with a weighting of 35%

b) Net results, with a weight of 10%

c) Cash flow, with a weight of 10 per cent, and

d) Total Shareholder Return vs Peers, with a weight of 10%.

The specific objectives will always include ESG indicators, such as the result of the Company's annual climate survey, the

reduction

of CO

emissions

, certified wood and the consumption of water, energy and wood.

On the other hand, and within the behavioural indicators, the alignment of each executive director with the existing leadership model

and the Company's long-term interests stands out.

The performance criteria referred to above are applied mathematically in their quantitative part - using the values of the business

plans approved by the Board of Directors as a reference, and at the end of each period these commitments are compared with the

results actually obtained - and through evaluative assessments with regard to the qualitative part.

In addition to the statutory limit on management's share of profits for the year, the Company also has mechanisms in place to limit

variable remuneration: (i) the variable component is eliminated if the results show a significant deterioration in the Company's

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 658

performance in the last financial year or when this is expected in the current financial year and (ii) the amount of annual variable

remuneration attributable has a defined cap, corresponding to 1.8 times the target, in order to prevent good performance at one

time, with immediate remuneration advantages for management, from being made at the expense of good future performance.

The determination of the annual variable remuneration may take into account reasonable adjustments relating to exogenous

factors and unforeseen economic decisions, as defined in advance by the Remuneration Committee.

The nature of the indicators, their respective weight in determining the effective variable remuneration and the limits on the

application of variable remuneration create a remuneration model based on recognising merit by reference to the Company's actual

performance and discouraging excessive risk-taking, while at the same time contributing to the realisation of the strategy defined

by The Navigator Company and ensuring that the interests of the executive members of the board of directors are aligned with the

company's long-term interests.

The remuneration of the members of the Audit Board consists only of a fixed component, which will consist of a fixed annual

amount, payable 12 times a year, with the remuneration of the Chairman of the Audit Board being higher than that of the other

members of the Audit Board, taking into account the special duties he performs. There are not and never have been any agreements

set by this Committee regarding payments by The Navigator Company for the dismissal or termination of office of members of the

Audit Board.

The remuneration of the members of the Board of the General Meeting consists only of a fixed component, consisting of a

predetermined amount for each meeting that actually takes place, with a lower amount for the second and subsequent meetings

that take place during the same year. The remuneration of those who chair the Board of the General Meeting shall be higher than

that of those who act as secretaries, taking into account the greater responsibility of the duties performed.

Although there is no independent remuneration mechanism in the Company with the specific aim of discouraging excessive risk-

taking, Navigator does not include any specific objectives in the directors' performance objectives that promote excessive risk-

taking, nor has it instituted any mechanism that allows for advance payments of future remuneration. Risk is an inherent

characteristic of any act of management and, as such, inevitably and permanently subject to consideration in any management

decision. Its qualitative or quantitative assessment as good or bad cannot be made in isolation in itself, but only in its result on the

Company's performance over time, thus blending in with long-term interests, and therefore benefiting from the incentives for

general long-term alignment and sustainability mentioned above.

71. Reference, if applicable, to the existence of a variable remuneration component and information on any

impact on this from performance assessments.

The existence of a variable component in the remuneration of executive directors and information on the possible impact of

performance appraisals on this component are described above, in point 70, and in the Remuneration Policy in Annex 2, to which

reference is made.

The remuneration of the members of the Audit Board does not include any variable component.

72. Deferred payment of the variable remuneration component, with reference to the deferral period.

The Company does not defer payment of the variable component of remuneration.

73. Criteria applied in allocating variable remuneration in shares and on the continued holding by executive

directors of these shares, on any contracts concluded with regard to these shares, specifically hedging

or transferring risk, the respective limits and the respective proportion represented of total annual

remuneration.

The Company's variable remuneration does not include any share component.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 659

74. Criteria applied on the allocating of variable remuneration in options and an indication of the deferral

period and value.

The Company's variable remuneration does not include any options.

75. Main parameters and grounds for any annual bonus system and any other non-cash benefits.

The criteria used to set annual bonuses are those relating to variable remuneration, as described in point 2.2.2 of chapter 2 of the

Remuneration Policy, and in points 25 and 70 above.

In addition to the variable component that may be attributed to members of the executive management bodies, no other non-

pecuniary benefits are attributed to members of the management and supervisory bodies, without prejudice to the means made

available to them for the performance of their duties, life insurance, health insurance and personal accident insurance in line with

market practices.

76. Main features of complementary or early retirement schemes for directors, and the date of approval by

the General Meeting for each individual.

The Company currently has no supplementary pension or early retirement schemes for directors.

In 2019, a proposal was submitted to the Insurance and Pension Funds Supervisory Authority (ASF) to amend the Pension Fund's

Constitutive Contract, whereby The Navigator Company Pension Plan was altered, and the Directors were no longer entitled to a

retirement supplement under the Plan. This amendment was approved by the ASF for 2022 with retroactive effect from 2

December 2021.

However, under the terms of the Regulations of The Navigator Company Pension Plan (formerly Portucel S.A. Pension Plan) in

force until the effective date of the amendment to the Articles of Association, the Company's Directors who were paid as such, and

who had served at least one full term of office in accordance with the articles of association, were entitled, upon retirement or

disability, if this occurred during their term of office, to a monthly supplement to their old-age or disability pension, respectively.

If the invalidity occurred after the end of their term of office, these members of the Board of Directors would only be entitled to

the invalidity pension supplement if they were awarded the corresponding invalidity pension by the social security organisation

with which they were registered and if they requested this from the Company.

This supplement was defined according to a formula that takes into account gross monthly pay and the number of years of

service, with a minimum of 10 years and a maximum of 30 years.

The directors António José Pereira Redondo, João Paulo Cabete Gonçalves Lé and António Quirino Vaz Duarte Soares are members

of the pension plans of Navigator Brands, S.A., a subsidiary of the Company, as employees of that company, before taking up

management positions.

Due to the specific nature of the Navigator Group's pension plan, there has been no intervention by the General Meeting to date in

approving the main features of the specific rules applicable to the retirement of Directors.

It should be noted in this regard that the Company was a state-owned company until 1991, with its activity and form of operation

regulated by the special law applicable to this type of company, and during this period the specific rules applied to the retirement of

the members of the Board of Directors were approved.

However, it should be noted that the supplementary pension plans in force at the Company are described in Note 7 of the notes to

the consolidated accounts for the financial year, which form part of the Annual Report subject to approval by the General Meeting.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 660

IV. Disclosure of Remuneration

77. Indication of the annual amount of remuneration earned, in aggregate and individual form, by the

members of the management bodies of the company, from the company, including fixed and variable

remuneration and, in relation to this, mention of the different components that gave rise to it.

The amount of remuneration earned in 2024 is shown below, where the variable remuneration was paid in 2024 but relates to

2023 performance, by the members of the Company's management body, from Navigator, with a distinction between fixed and

variable remuneration, and relative percentages, but without distinguishing the different components that gave rise to the variable

remuneration, because the variable component is defined as a whole, weighting the elements explained in the Remuneration Policy,

without identifying components.

Fixed Remuneration

Variable Remuneration

Amount

(Euros)

Relative

Percentage

Amount

(Euros)

Relative

Percentage

António José Pereira Redondo

701 766

48.82%

735 572

51.18%

Adriano Augusto da Silva Silveira

180 000

43.78%

231 101

56.22%

João Paulo Cabete Gonçalves Lé

335 175

39.77%

507 561

60.23%

João Paulo Araújo Oliveira

290 622

100%

José Fernando Morais Carreira de Araújo

335 175

40.69%

488 513

59.31%

Nuno Miguel Moreira de Araújo Santos

335 175

38.49%

535 538

61.51%

Dorival Martins de Almeida

335 175

100%

365 011

52.13%

António Quirino Vaz Duarte Soares

335 175

100%

231 101

40.81%

Maria Teresa Aliu Presas

77 000

100%

Mariana Rita Antunes Marques dos Santos

105 000

100%

Sandra Maria Soares Santos

77 000

100%

Ana Teresa Cunha de Pinho Tavares Lehmann

77 000

100%

The table above shows the annual amount corresponding to the period in which the members of the Board of Directors held office.

The tables below show, for the purposes of Article 26-G(2)(c) of the Securities Code, the annual variations over the last five

financial years in the remuneration paid individually by the Company to the members of the Board of Directors, as well as the

average remuneration of the Company's full-time equivalent Employees, and the Company's performance indicators:

(Amounts in euros)

Board of Directors

2020 2021 2022 2023 2024

António José Pereira

Redondo

Fixed Remuneration (€) 655 699 668 349 651 780 707 196 701 766

Variable Remuneration (€) 185 984 839 967 777 486 982 603 735 572

Total Remuneration (€) 841 683 1 508 316 1 429 266 1 689 799 1 437 338

Variation in % -3.0% 79.2% -5.2% 18.2% -14.9%

Adriano Augusto da

Silva Silveira

Fixed Remuneration (€) 313 172 319 214 319 214 238 006 180 000

Variable Remuneration (€) 117 000 628 891 625 240 792 842 231 101

Total Remuneration (€) 430 172 948 105 944 454 1 030 848 411 101

Variation in % 44.8% 120.4% -0.4% 9.1% -60.1%

Fixed Remuneration (€) 315 392 319 214 319 214 329 855 335 175

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 661

Board of Directors

2020 2021 2022 2023 2024

João Paulo Cabete

Gonçalves Lé

Variable Remuneration (€) 15 074 524 141 602 857 735 822 507 561

Total Remuneration (€) 330 466 843 355 922 071 1 065 677 842 736

Variation in % 100% 155.2% 9.3% 15.6% -20.9%

João Paulo Araújo

Oliveira

Fixed Remuneration (€) 313 157 319 806 319 199 190 193 0

Variable Remuneration (€) 121 627 582 448 567 308 718 958 290 622

Total Remuneration (€) 434 784 902 254 886 507 909 151 290 622

Variation in % -46.0% 107.5% -1.7% 2.6% -68.0%

José Fernando Morais

Carreira de Araújo

Fixed Remuneration (€) 313 171 319 213 319 213 329 854 335 175

Variable Remuneration (€) 175 663 599 173 623 780 717 151 488 513

Total Remuneration (€) 488 834 918 386 942 993 1 047 005 823 688

Variation in % -44.0% 87.9% 2.7% 11.0% -21.3%

Nuno Miguel Moreira de

Araújo Santos

Fixed Remuneration (€) 313 157 319 199 319 199 329 850 335 175

Variable Remuneration (€) 128 915 474 022 612 855 740 185 535 538

Total Remuneration (€) 442 073 793 221 932 054 1 070 035 870 713

Variation in % -39.8% 79.4% 17.5% 14.8% -18.6%

Dorival Martins de

Almeida

Fixed Remuneration (€)

230 946 335 175

Variable Remuneration (€)

365 011

Total Remuneration (€)

230 946 700 186

Variation in %

100% 203.2%

António Quirino Vaz

Duarte Soares

Fixed Remuneration (€)

139 656 335 175

Variable Remuneration (€)

231 101

Total Remuneration (€)

139 656 566 276

Variation in %

100% 305.5%

Manuel Soares Ferreira

Regalado*

Fixed Remuneration (€) 75 543 77 000 77 000 32 083 0

Variable Remuneration (€)

Total Remuneration (€) 75 543 77 000 77 000 32 083 0

Variation in % -1.9% 1.9% 0.0% -58.3% 0.0%

Maria Teresa Aliu Presas

Fixed Remuneration (€) 75 522 77 000 77 000 77 000 77 000

Variable Remuneration (€)

Total Remuneration (€) 75 522 77 000 77 000 77 000 77 000

Variation in % 100% 2.0% 0.0% 0.0% 0.0%

Mariana Rita Antunes

Marques dos Santos

Fixed Remuneration (€) 102 984 105 000 105 000 105 000 105 000

Variable Remuneration (€)

Total Remuneration (€) 102 984 105 000 105 000 105 000 105 000

Variation in % 100% 2.0% 0.0% 0.0% 0.0%

Sandra Maria Soares

Santos

Fixed Remuneration (€) 75 522 77 000 77 000 77 000 77 000

Variable Remuneration (€)

Total Remuneration (€) 75 522 77 000 77 000 77 000 77 000

Variation in % 100% 2,0% 0.0% 0.0% 0.0%

Ana Teresa Cunha de

Pinho Tavares Lehmann

Fixed Remuneration (€)

47 707 77 000

Variable Remuneration (€)

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 662

Board of Directors

2020 2021 2022 2023 2024

Total Remuneration (€)

47 707 77 000

Variation in %

100% 100%

Vítor Manuel Galvão

Rocha Novais

Gonçalves*

Fixed Remuneration (€) 96 145 77 000 98 000 40 833 0

Variable Remuneration (€)

Total Remuneration (€) 96 145 77 000 98 000 40 833 0

Variation in % 0.0% -19.9% 27.3% -58.3% 0.0%

Luís Alberto Caldeira

Deslandes*

Fixed Remuneration (€)

77 000

Variable Remuneration (€)

Total Remuneration (€)

77 000

Variation in %

100% -100.0% 0.0%

Audit Board 2020 2021 2022 2023 2024

José Manuel Vitorino

Fixed Remuneration (€)

21 994

35 147

30 000

Variation in % 0.00% 0.00% 0.00% 59.80% -14.64%

Gonçalo Picão Caldeira

Fixed Remuneration (€)

16 002

25 593

21 840

Variation in % 0.00% 0.00% 0.00% 59.94% -14.66%

Maria da Luz Gonçalves de

Andrade Campos

Fixed Remuneration (€)

15 056

Variation in % - - - - 100%

Maria da Graça Gonçalves

Fixed Remuneration (€)

16 002

25 593

Variation in % 0.00% 0.00% 0.00% 59.94% -100%

78. Amounts paid on any basis by other controlled, controlling or group companies or companies under

common control.

It is important to clarify that the amounts referred to in this number pertain only to companies not controlled by The Navigator

Company. They also include amounts that are unrelated to Navigator and its corporate bodies, as they concern its Shareholders,

the Shareholders of its Shareholders, and other companies controlled by Shareholders, provided there is a control relationship.

In 2024, the following directors received remuneration from other companies that are either in a control relationship with, or

subject to common control with, Navigator: Ricardo Miguel dos Santos Pacheco Pires (€1,244,836.38), Hugo Alexandre Lopes

Pinto (€380,454.04), Maria Isabel da Silva Marques Abranches Viegas (€234,250.72), and Vítor Paulo Paranhos Pereira

(€834,969.77). It is clarified that the remaining members of the Board of Directors did not receive remuneration from other

companies within the same group as Navigator, based on the definition of "group" under point (g) of paragraph 1 of Article 2 of

Decree-Law No. 158/2009 of July 13, in accordance with point (d) of paragraph 2 of Article 26-G of the Portuguese Securities

Code (CVM).

79. Remuneration paid in the form of profit sharing and/or payment of bonuses, and the grounds on which

these bonuses and/or profit sharing were granted.

The amount of remuneration paid by the Company in the form of profit-sharing and/or bonus payments corresponds to the variable

remuneration set out in point 77 of this Report, and these amounts were set on the basis of the Remuneration Committee's actual

application of the criteria described in chapter 2 of the Remuneration Policy.

80. Compensation paid or due to former executive directors for their dismissal during the year.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 663

No compensation was paid during the year, nor is any due from the Company to former executive directors for leaving office.

81. Indication of the annual remuneration earned, on an aggregate and individual basis, by the members of

the Company’s supervisory bodies, for the purposes of Law 28/2009 of 19 June.

Fixed Remuneration

Variable Remuneration

Amount Relative Percentage

José Manuel Vitorino €30 000 100%

0 0%

Gonçalo Picão Caldeira

€21 840

100%

Maria da Luz Campos

€15 056

100%

Maria da Graça Gonçalves

0 0%

82. Indication of remuneration earned in the reporting period by the Chairman of the General Meeting.

The Chairman of the Board of the General Meeting only receives fixed remuneration, taking into account the number of meetings of

the General Meeting each year.

During 2023, the Chairman of the General Meeting received a fixed remuneration of €5,000 (five thousand euros).

V. Agreements with implications for remuneration

83. Contractual limits on severance pay for directors, and the respective relationship with the variable

remuneration component.

The Company has no contract with directors that limits or otherwise alters the supplementary legal regime for cases of

termination of office, with or without just cause. The Remuneration Policy approved by the Company's Remuneration Committee

stipulates that, in the event of directors leaving office, the supplementary legal regime in this area will apply.

Therefore, considering the absence of individual contracts with Directors in this area and the provisions of the aforementioned

Remuneration Policy, in the event of dismissal that is not due to a serious breach of duty by the Director or to the Director's

inability to fulfil his duties normally, the Company will be obliged to pay compensation under the general terms of the law, without

this compensation exceeding the amount of remuneration that he would presumably receive until the end of the period for which

he was elected.

Leaving office before the end of the term of office does not therefore give rise, directly or indirectly, to the payment to the

Director of any amounts other than those provided for by law.

84. Reference to the existence and description, with an indication of the amounts involved, of agreements

between the company and members of the board of directors and senior managers, within the meaning

of Article 29-R(3) of the Securities Code, which provide for compensation in the event of resignation,

unfair dismissal or termination of the employment relationship following a change of control of the

company (Article 29-H(1)(k)).

There are also no agreements between the Company and members of the board of directors and senior managers that provide for

compensation in the event of resignation, unfair dismissal or termination of the employment relationship following a change of

control of the Company.

VI. Stocks or stock option plans

85. Identification of plan and beneficiaries.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 664

Not applicable, as there are no remuneration payments through share award plans or stock option plans.

86. Description of plan (terms of allocation, non-transfer of share clauses, criteria on the price of shares

and the price of exercising options, the period during which the options may be exercised, the

characteristics of the shares to be distributed, the existence of incentives to purchase shares and/or

exercise options).

Not applicable.

87. Stock-option rights for which the company’s workers and Employees are the beneficiaries.

Not applicable.

88. Control mechanisms in an employee ownership scheme insofar as voting rights are not directly

exercised by Employees (article 29-A (1) (e)).

There is no employee ownership scheme in Navigator.

E. RELATED PARTY TRANSACTIONS AND CONFLICTS OF INTEREST

I. Control mechanisms and procedures

89. Procedures implemented by the Company for controlling related party transactions (reference is made

for this purpose to the concept deriving from IAS 24).

The Company has adopted a Regulation on Conflicts of Interest and Transactions with Related Parties, which sets out the rules on

conflicts of interest and transactions with related parties to which the company is a party, in addition to the internal mechanisms

the company has in place, for the purposes of complying with international accounting standard IAS 24 (Related Party

Disclosures), and is applicable, without prejudice to the obligations of the Company and its directors in terms of Insider

Information, the legal regime for the Company's dealings with Directors, and the internal regulations on Reporting Irregularities

and other applicable legislation in this area.

These regulations were approved with the favourable and binding opinion of the Audit Board, taking into account the applicable

legal and regulatory framework in force on this matter, namely Law no. 50/2020, of 25 August, and Law no. 99-A/2021, of 31

December.

These regulations are available for consultation on the company's website

(www.thenavigatorcompany.com/en/investors/governance/)

In accordance with the Regulation on Conflicts of Interest and Related Party Transactions, transactions between the Company and

related parties - qualified as such by the international accounting standards adopted under Regulation (EC) 1606/2002 of the

European Parliament and of the Council of 19 July, namely by the international accounting standard IAS 24 (Related Party

Disclosures) - are subject to the following approval procedures:

The following transactions are approved by the Executive Committee:

a) Loans made to the Company by its shareholder companies for an amount equal to or less than one hundred million

euros;

b) Transactions within the scope of the group taxation regime, with a value equal to or less than one hundred million euros;

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 665

c) Transactions carried out with controlled companies that consolidate accounts with the Company, with an individual or

cumulative annual value equal to or less than two per cent of the controlled Company's turnover, calculated in accordance

with the last approved annual accounts;

d) Loans to controlled companies that consolidate accounts with the Company, as well as underwriting their debt, (i) with a

term of less than six months, (ii) with an individual or cumulative annual value of less than one fifth of the turnover of the

respective controlled company, calculated in accordance with the last approved annual accounts, and which does not

exceed one hundred million euros, and (iii) provided that the controlled company guarantees credit lines for the

repayment of the operation; and

e) Any other transactions whose individual or cumulative annual value is equal to or less than one million euros.

Transactions that (i) do not fall within the scope of the preceding paragraphs, or (ii) fall within those paragraphs but are not

carried out as part of the Company's day-to-day business, are approved by resolution of the Board of Directors, preceded by a

favourable opinion from the Audit Board.

In accordance with the aforementioned Regulation, transactions may only be carried out under market conditions and if there is a

justified self-interest on the part of the Company.

With regard to the procedures for informing, verifying and formalising related parties’ transactions, the Regulation states that:

a) The Board of Directors is informed every six months of resolutions relating to transactions in which it has not

participated;

b) The Audit Board is informed of transactions carried out by the Company for the purposes of verifying that the transactions

comply with the regime described above and with the applicable legislation and regulations, and related parties may not

take part in the verification in question;

c) It is also the responsibility of the Company's managers who intervene in the formalisation of transactions with related

parties to ensure that the transactions are previously submitted to the resolutions required by the regulations and

applicable laws and regulations; and

d) The formalisation and execution of resolutions on related parties’ transactions must be particularly monitored by the

Executive Committee.

The Company will disclose transactions that must be disclosed under the terms of the applicable legislation and regulations,

namely because they have not fulfilled any of the legal requirements, and according to the value in question, under the terms and

within the timeframe laid down in the applicable legislation and regulations.

The Regulation shall not apply to transactions treated as exempt under applicable laws and regulations.

As part of its ongoing commitment to ethics and integrity, Navigator is responsible for adopting measures to ensure impartiality in

decision-making processes, preventing cases of potential conflict of interest involving the Company or its employees.

This commitment is reflected in the way the Company manages conflicts of interest and is materialised through:

−

Implementation of clear policies and procedures that define what constitutes a conflict of interest and establish

guidelines for its identification, disclosure and resolution;

−

Promoting an organisational culture that values transparency, honesty and integrity in all business interactions

and decisions made;

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 666

−

Regular training for all employees on how to recognise, report and resolve conflicts of interest appropriately;

−

Maintaining communication channels where employees and interested parties can report concerns about possible

conflicts of interest.

With regard to the procedures applicable to conflicts of interest, the Regulation on Conflicts of Interest and Related Parties

Transactions stipulates that a situation of conflict exists whenever a manager is in a position which, viewed objectively, is likely to

compromise their independence and cause their judgement to be influenced by interests other than the interests of the Company,

whether or not these interests are in their own assets or those of third parties. For the purposes of their adequate prevention,

identification and resolution, the manager must:

− Communicate the existence of a conflict of interest, even if potential, to their hierarchical superior or, in the case of a

member of a collegiate body, to the body in question, under the terms of the respective operating regulations; and

− Refrain from interfering or participating in the event of a conflict of interest and, in the case of a decision-making process,

record this impediment in the minutes or other written document documenting the decision, without prejudice to the duty

to provide the information and clarifications requested by the body in question and its members.

In addition, all the operating regulations of the governing bodies and internal committees contain provisions on conflicts of

interest, in line with the rules described above.

The Company also has internal control mechanisms for identifying situations of potential conflict of interest, including a procedure

for reporting and verifying these situations. In this context, it maps employees who, by virtue of their duties, find themselves in

situations that could give rise to conflicts of interest, and then identifies third parties who may be related parties in transactions

with Navigator, periodically updating this analysis.

In addition, all the operating regulations of the governing bodies and internal committees lay down provisions on conflicts of

interest, in line with the rules described above.

90. Indication of transactions subject to control in the reporting period.

In 2024, there were no transactions subject to control, given that, by applying the criteria referred to in point 91 below, none of

the Company's business with qualified shareholders or entities in any way related to the Company, under the terms of article 20 of

the Securities Code, was subject to the prior opinion of the Supervisory Board. It should also be noted that there were no

transactions between the Company and holders of qualifying holdings outside normal market conditions.

91. Description of the procedures and criteria applicable to intervention by the supervisory body for the

purposes of prior evaluation of transactions to be carried out between the Company and qualifying

shareholders or related entities, under article 20 of the Securities Code.

The procedures and criteria applicable to intervention by the supervisory body for the purposes of prior evaluation of transactions

to be carried out between the Company and qualifying shareholders or related entities, under article 20 of the Securities Code, are

described in item 89.

II. Details of Transactions

92. Indication of the place in the financial reports and account where information is available on related

party transactions, in accordance with IAS 24, or, alternatively, reproduction of this information.

The information available on related party transactions is included in the Company’s Report and Accounts, in Note 11.3 of the Notes

to the Consolidated Financial Statements.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 667

PART II

Corporate Government Assessment

1. IDENTIFICATION OF THE CORPORATE GOVERNANCE CODE ADOPTED

In 2023, Navigator adopted the Corporate Governance Code of the Portuguese Institute of Corporate Governance (“IPCG”) of

2018, as it has done since 2018, in accordance with and for purposes of article 2 of CMVM Regulation no. 4/2013.

The adopted Code was revised by the IPCG in 2020 and 2023. It is released by the IPCG and can be accessed on the respective

website, at https://cgov.pt/images/ficheiros/2023/en_cgs_revisao-de-2023_ebook.pdf.

2. ANALYSIS OF COMPLIANCE WITH THE CORPORATE GOVERNANCE CODE ADOPTED

Navigator has adopted most of the IPCG Corporate Governance Code Recommendations. The Principles and Recommendations

of this Code are listed in the table below, with indication of the Recommendations adopted, not applicable and not adopted, and

reference is made to the points in this Report where the matter is developed. In relation to the Recommendations not adopted,

justification for non-adoption and a mechanism equivalent to the adopted “explain”.

Compliance Comments

GENERAL PRINCIPLES

A. Corporate governance promotes and fosters the pursuit of the respective long-term interests, performance and

sustained development, and is structured in order to allow the interests of shareholders and other investors, staff, clients,

creditors, suppliers and other stakeholders to be weighed, contributing to the strengthening of confidence in the quality,

transparency and ethical standards of administration and supervision, as well as to the sustainable development of the

community the companies form part of and to the development of the capital market.

The Code is voluntary, and compliance is based on the comply or explain principle, applicable to all

Recommendations.

Chapter I – Company’s relationship with Shareholders, Interested Parties and the Community at Large

Principles

I.A. In their organisation, operation and in the definition of their strategy, companies shall contribute to the pursuit of

the Sustainable Development Goals defined within the framework of the United Nations Organisation, in terms that are

appropriate to the nature of their activity and their size. In their organisation, operation and in the definition of their strategy,

companies shall contribute to the pursuit of the Sustainable Development Goals defined within the framework of the United

Nations Organisation, in terms that are appropriate to the nature of their activity and their size.

I.B. The company periodically identifies, measures and seeks to prevent negative effects related to the environmental

and social impact of the operation of its activity, in terms that are appropriate to the nature and size of the company.

I.C. In its decision-making processes, the management body considers the interests of shareholders and other investors,

employees, suppliers and other stakeholders in the activity of the company.

Recommendations

I.1. The company specifies how its strategy seeks to ensure fulfilment of

its long-

term objectives and what its main contributions are to the

community at large.

Adopted

Part I, no. 21

Annual Report, Ch. 3.4

Roadmap 2030

I.2. The company identifies the main policies and measures adopted

with regard to the fulfilment of its environmental and social objectives.

Adopted

Part I, no. 21, 29, 49

and 53

Annual Report Ch. 5,

Non-financial statement

Chapter II – Composition and functioning of the Corporate Bodies

II.1. Information

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 668

Principle

II.1.A. Companies and, in particular, their directors treat shareholders and other investors in an equitable manner, namely

by ensuring mechanisms and procedures for the adequate treatment and disclosure of information.

Recommendation:

II.1.1. The company establishes mechanisms to adequately and

rigorously ensure the timely circulation or disclosure of the information

required to its bodies, the company secretary, shareholders, investors,

financial analysts, other stakeholders and the market at large.

Adopted

Part I, no. 21, 22, 38

and 56 to 65

Annual Report Ch. 2.3

and Section 5

II.2. Diversity in the Composition and Functioning of the Corporate Bodies

Principles:

II.2.A. Companies have adequate and transparent decision-

making structures, ensuring maximum efficiency in the

functioning of their bodies and committees.

II.2.B. Companies ensure diversity in the composition of their management and supervisory bodies and the adoption of

individual merit criteria in the respective appointment processes, which shall be the exclusive responsibility of shareholders.

II.2.C. Companies ensure that the performance of their bodies and committees is duly recorded, namely in minutes of

meetings, which allow for knowing not only the sense of the decisions taken but also their grounds and the opinions expressed

by their members.

Recommendations:

II.2.1. Companies establish, previously and abstractly, criteria and

requirements regarding the profile of the members of the corporate bodies

that are adequate to the function to be performed, considering, notably,

individual attributes (such as competenc

e, independence, integrity,

availability and experience), and diversity requirements (with particular

attention to equality between men and women), that may contribute to

the improvement of the performance of the body and of the balance in its

composition.

Adopted

Part I no. 16

II.2.2. The management and supervisory bodies and their internal

committees are governed by regulations – notably regarding the exercise

of their powers, chairmanship, the frequency of meetings, operation and

the duties framework of their members – fully disclosed on the website of

the company, whereby minutes of the respective meetings shall be drawn

up.

Adopted

Part I no. 22, 27, 29, 34

and 38

II.2.3. The composition and number of meetings for each year of the

management and supervisory bodies and of their internal committees are

disclosed on the website of the company.

Adopted

Part I no. 22, 27, 34 and

II.2.4. The companies adopt a whistle-blowing policy that specifies the

main rules and procedures to be followed for each communication and an

internal reporting channel that also includes access for non- employees,

as set forth in the applicable law.

Adopted

Part I no. 49, 50, 54 and

II.2.5. The companies have specialised committees for matters of

corporate governance, remuneration, appointments of members of the

corporate bodies and performance assessment, separately or

cumulatively. If the Remuneration Committee provided for in Article 399

of the Portuguese Commercial Companies Code has been set up, the

present Recommendation can be complied with by assigning to said

committee, if not prohibited by law, powers in the above matters.

Adopted

Part I no. 21, 27 and 29

II.3. Relations between Corporate Bodies

Principle:

II.3.A. The corporate bodies create the conditions for them to act in a harmonious and articulated manner, within the scope

of their responsibilities, and with information that is adequate for carrying out their functions.

Recommendations:

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 669

II.3.1. The Articles of Association or equivalent means adopted by the

company set out the mechanisms to ensure that, within the limits of the

applicable laws, the members of the management and supervisory bodies

have permanent access to all necessary information to assess the

performance, situation and development prospects of the company,

including, specifically, the minutes of the meetings, the documentation

supporting the decisions taken, the convening notices and the archive of

the meetings of the executive management body, without prejudice to

access to any other documents or persons who may be requested to

provide clarification.

Adopted

Part I no. 21, 22 and 38

II.3.2. Each body and committee of the company ensures, in a timely

and adequate manner, the interorganic flow of information required for

the exercise of the legal and statutory powers of each of the other bodies

and committees.

Adopted

Part I no. 21, 22, 27 and

Ii.4. Conflicts of Interests

Principle:

II.4.A. The existence of current or potential conflicts of interest between the members of bodies or committees and the

company shall be prevented, ensuring that the conflicted member does not interfere in the decision-making process.

Recommendations:

II.4.1. By internal regulation or an equivalent hereof, the members of

the management and supervisory bodies and of the internal committees

shall be obliged to inform the respective body or committee whenever

there are any facts that may constitute or give rise to a conflict between

their interests and the interest of the company.

Adopted

Part I no. 89

II.4.2. The company adopts procedures to ensure that the conflicted

member does not interfere in the decision-

making process, without

prejudice to the duty to provide information and clarification requested by

the body, committee or respective members.

Adopted

Part I no. 89

II.5. Related Party Transactions

Principle:

II.5.A. Transactions with related parties shall be justified by the interest of the company and shall be carried out under

market conditions, being subject to principles of transparency and adequate supervision.

Recommendation:

II.5.1. The management body discloses, in the corporate governance

report or by other publicly available means, the internal procedure for

verification of transactions with related parties.

Adopted

Part I no. 38 and 89 to

Chapter III – Shareholders and General Meeting

Principles:

III.A. The adequate involvement of shareholders in corporate governance constitutes a positive factor for the efficient

functioning of the company and the achievement of its corporate objective.

III.B. The company promotes the personal participation of shareholders at general meetings as a space for reflection on

the company and for shareholders to communicate with the bodies and committees of the company.

III.C. The company implements adequate means for shareholders to attend and vote at the general meeting without being

present in person, including the possibility of sending in advance questions, requests for clarification or information on the

matters to be decided on and the respective proposals.

Recommendations:

III.1. The company does not set an excessively large number of shares

to be entitled to one vote and informs in the corporate governance report

of its choice whenever each share does not carry one vote.

Adopted

Part I no. 12 and 13

III.2. The company that has issued special plural voting rights shares

identifies, in its corporate governance report, the matters that, pursuant

Not applicable

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 670

to the company’s Articles of Association, are excluded from the scope of

plural voting.

III.3. The company does not adopt mechanisms that hinder the

passing of resolutions by its shareholders, specifically fixing a quorum for

resolutions greater than that foreseen by law.

Adopted

Part I, no. 14

III.4. The company implements adequate means for shareholders to

participate in the general meeting without being present in person, in

proportion to its size.

Adopted

Part I, no. 12

III.5. The company also implements adequate means for the exercise

of voting rights without being present in person, including by

correspondence and electronically.

Adopted

Part I, no. 12

III.6. The Articles of Association of the company that provide for the

restriction of the number of votes that may be held or exercised by one

single shareholder, either individually or jointly with other shareholders,

shall also foresee that, at least every five years, the general meeting shall

resolve on the amendment or maintenance of such statutory provision –

without quorum requirements greater than that provided for by law – and

that in said resolution, all votes issued are to be counted, without applying

said restriction.

Not applicable

III.7. The company does not adopt any measures that require

payments or the assumption of costs by the company in the event of

change of control or change in the composition of the management body

and which are likely to damage the economic interest in the transfer of

shares and the free assessment by shareholders of the performance of the

Directors.

Adopted

Part I, no. 4, 83 and 84

Chapter IV – Management

IV.1. Management Bodies and Executive Directors

Principles:

IV.1.A. The day-to-day management of the company shall be the responsibility of executive directors with the qualifications,

skills, and experience appropriate for the position, pursuing the corporate goals and aiming to contribute to its sustainable

development.

IV.1.B.

The determination of the number of executive directors shall take into account the size of the company, the

complexity and geographical dispersion of its activity and the costs, bearing in mind the desirable flexibility in the running of

the executive management.

Recommendations:

IV.1.1. The management body ensures that the company acts in

accordance with its object and does not delegate powers, notably with

regard to:

i) definition of the corporate strategy and main policies of the company;

ii) organisation and coordination of the corporate structure;

iii) matters that shall be considered strategic due to the amounts, risk and

particular characteristics involved.

Adopted

Part I, no. 21 and 22

IV.1.2. The management body approves, by means of regulations or

through an equivalent mechanism, the performance regime for executive

directors applicable to the exercise of executive functions by them in

entities outside the group.

Adopted

Part I, no. 22

IV.2. Management Body and Non-Executive Directors

Principles:

IV.2.A. For the full achievement of the corporate objective, the non-executive directors shall exercise, in an effective and

judicious manner, a function of general supervision and of challenging the executive management, whereby such performance

shall be complemented by committees in areas that are central to the governance of the company.

IV.2.B. The number and qualifications of the non-executive directors shall be adequate to provide the company with a

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 671

balanced and appropriate diversity of professional skills, knowledge and experience.

Recommendations:

IV.2.1. Notwithstanding the legal duties of the chairman of the board of

directors, if the latter is not independent, the independent directors – or,

if there are not enough independent directors, the non- executive directors

– shall appoint a coordinator among themselves to, in particular (i) act,

whenever necessary, as interlocutor with the chairman of the board of

directors and with the other directors, (ii) ensure that they have all the

conditions and means required to carry out their duties, and (iii)

coordinate their performance assessment by the administration body as

provided for in Recommendation VI.1.1.; alternatively, the company may

establish another equivalent mechanism to ensure such coordination.

Adopted

Part I no. 18

IV.2.2. The number of non-executive members of the management body

shall be adequate to the size of the company and the complexity of the

risks inherent to its activity, but sufficient to ensure the efficient

performance of the tasks entrusted to them, whereby the formulation of

this adequacy judgement shall be included in the corporate governance

report.

Adopted

Part I, no. 18, 31, 50, 51

and 54

IV.2.3. The number of non-executive directors is greater than the

number of executive directors.

Adopted

Part I, no. 18

IV.2.4. The number of non-executive directors that meet the

independence requirements is plural and is not less than one third of the

total number of non-executive directors. For the purposes of the present

Recommendation, a person is deemed independent when not associated

to any specific interest group in the company, nor in any circumstances

liable to affect his/her impartiality of analysis or decision, in particular in

virtue of:

i) Having carried out, continuously or intermittently, functions in any

corporate body of the company for more than twelve years, with this

period being counted regardless of whether or not it coincides with the

end of the mandate;

ii) Having been an employee of the company or of a company that is

controlled by or in a group relationship with the company in the last three

years;

iii) Having, in the last three years, provided services or established a

significant business relationship with the company or with a company that

is controlled by or in a group relationship with the company, either directly

or as a partner, director, manager or officer of a legal person;

iv) Being the beneficiary of remuneration paid by the company or by a

company that is controlled by or in a group relationship with the company,

in addition to remuneration stemming from the performance of the

functions of director;

v) Living in a non-marital partnership or being a spouse, relative or kin in

a direct line and up to and including the 3rd degree, in a collateral line, of

directors of the company, of directors of a legal person owning a qualifying

stake in the company or of natural persons owning, directly or indirectly,

a qualifying stake;

vi) Being a holder of a qualifying stake or representative of a shareholder

that is holder of a qualifying stake.

Adopted

Part I, no. 18

IV.2.5. The provisions of paragraph (i) of the previous Recommendation

do not prevent the qualification of a new Director as independent if,

between the end of his/her functions in any corporate body and his/her

new appointment, at least three years have elapsed (cooling-off period).

Adopted

Part I, no. 18

Chapter V – Supervision

Principles:

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 672

V.A. The supervisory body carries out permanent supervision activities of the administration of the company, including,

also from a preventive perspective, the monitoring of the activity of the company and, in particular, the decisions of

fundamental importance for the company and for the full achievement of its corporate object.

V.B. The composition of the supervisory body provides the company with a balanced and adequate diversity of professional

skills, knowledge and experience.

Recommendations:

V.1. With due regard for the competences conferred to it by law, the

supervisory body takes cognisance of the strategic guidelines and

evaluates and renders an opinion on the risk policy, prior to its final

approval by the administration body.

Adopted

Part I, no. 38 and 50

V.2. The number of members of the supervisory body and of the

financial matters committee should be adequate in relation to the size of

the company and the complexity of the risks inherent to its activity, but

sufficient to ensure the efficiency of the tasks entrusted to them, and this

adequacy judgement should be included in the corporate governance

report.

Adopted

Part I, no. 18, 31, 50, 51

and 54

Chapter VI - Performance Assessment, Remuneration and Appointments

VI.1. Annual Performance Assessment

Principle:

VI.1.A. The company promotes the assessment of performance of the executive body and its individual members as well as

the overall performance of the management body and its specialised committees.

Recommendation:

VI.1.1. The management body – or committee with relevant powers,

composed of a majority of non-executive members –

evaluates its

performance on an annual basis, as well as the performance of the

executive committee, of the executive directors and of the company

committees, taking into account the compliance with the strategic plan of

the company and of the budget, the risk management, its internal

functioning and the contribution of each member to that end, and the

relationship between the bodies and committees of the company.

Adopted

Part I, no. 22, 24 and 25

VI.2. Remuneration

Principles:

VI.2.A. The remuneration policy for members of the management and supervisory bodies shall allow the company to attract

qualified professionals at a cost that is economically justified by their situation, provide for the alignment with the interests of

the shareholders – taking into consideration the wealth effectively created by the company, the economic situation and the

market situation – and shall constitute a factor for developing a culture of professionalism, sustainability, merit promotion and

transparency in the company.

V.2.B. Taking into consideration that the position of directors is, by nature, a remunerated position, directors shall receive

a remuneration:

i) that adequately rewards the responsibility undertaken, the availability and competence placed at the service of the company;

ii) that ensures a performance aligned with the long-term interests of shareholders and promotes the sustainable performance

of the company; and

iii) that rewards performance.

Recommendations:

VI.2.1. The company constitutes a remuneration committee, whose

composition shall ensure its independence from the board of directors,

whereby it may be the remuneration committee appointed pursuant to

Article 399 of the Portuguese Commercial Companies Code.

Adopted

Part I no. 24, 27, 66 and

VI.2.2. The remuneration of the members of the management and

supervisory bodies and of the company committees is established by the

remuneration committee or by the general meeting, upon proposal of such

Adopted

Part I no. 24, 27, 66 and

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 673

committee.

VI.2.3. The company discloses in the corporate governance report, or in

the remuneration report, the termination of office of any member of a

body or committee of the company, indicating the amounts of all costs

related to the termination of office borne by the company, for any reason,

during the financial year in question.

Adopted

Part I no. 17, 18 e 21

VI.2.3.(II) Not

applicable

VI.2.4. In order to provide information or clarification to shareholders,

the president or another member of the remuneration committee shall be

present at the annual general meeting and at any other general meeting

at which the agenda includes a matter related to the remuneration of the

members of bodies and committees of the company, or if such presence

has been requested by shareholders.

Adopted

Part I no. 76

VI.2.5. Within the budget constraints of the company, the remuneration

committee may freely decide to hire, on behalf of the company,

consultancy services that are necessary or convenient for the performance

of its duties.

Adopted

Part I no. 67

VI.2.6. The remuneration committee ensures that such services are

provided independently.

Adopted

Part I no. 67

VI.2.7. The providers of said services are not hired by the company itself

or by any company controlled by or in group relationship with the

company, for the provision of any other services related to the

competencies of the remuneration committee, without the express

authorisation of the committee.

Adopted

Part I n. 67

VI.2.8. In view of the alignment of interests between the company and

the executive directors, a part of their remuneration has a variable nature

that reflects the sustained performance of the company and does not

encourage excessive risk-taking.

Adopted

Part I no. 70 and 71

Part III Annex II

VI.2.9. A significant part of the variable component is partially deferred

over time, for a period of no less than three years, and is linked to the

confirmation of the sustainability of performance, in terms defined in the

remuneration policy of the company.

Not adopted

Explanation of not

adopted

Recommendations

below

VI.2.10. When the variable remuneration includes options or other

instruments directly or indirectly subject to share value, the start of the

exercise period is deferred for a period of no less than three years.

Not applicable

VI.2.11. The remuneration of non-executive directors does not include

any component whose value depends on the performance of the company

or of its value.

Adopted

Part I no. 71

VI.3. Appointments

Principle:

VI.3.A. Regardless of the method of appointment, the knowledge, experience, professional background, and availability of the

members of the corporate bodies and of the senior management shall be adequate for the job to be performed.

Recommendations:

VI.3.1. The company promotes, in the terms it deems adequate, but in

a manner susceptible of demonstration, that the proposals for the

appointment of members of the corporate bodies are accompanied by

grounds regarding the suitability of each of the candidates for the function

to be performed.

Adopted

Part I no. 16

VI.3.2. The committee for the appointment of members of corporate

bodies includes a majority of independent directors.

Not adopted

Explanation of not

adopted

Recommendations

below

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 674

VI.3.3. Unless it is not justified by the size of the company, the task of

monitoring and supporting the appointments of senior managers shall be

assigned to an appointment committee.

Adopted

Part I no. 29

VI.3.4. The committee for the appointment of senior management

provides its terms of reference and promotes, to the extent of its powers,

the adoption of transparent selection processes that include effective

mechanisms for identifying potential candidates

, and that for selection

those are proposed who present the greatest merit, are best suited for the

requirements of the position and promote, within the organisation, an

adequate diversity including regarding gender equality.

Adopted

Part I no. 16 and 29

Chapter VII – Internal Control

Principle:

VII.A. Based on the medium and long-term strategy, the company shall establish a system of internal control, comprising the

functions of risk management and control, compliance and internal audit, which allows for the anticipation and minimisation

of the risks inherent to the activity developed.

Recommendations:

VII.1. The management body discusses and approves the strategic plan

and risk policy of the company, which includes setting limits in matters of

risk-taking.

Adopted

Part I no. 22, 24 and 50,

VII.2. The company has a specialised committee, or a committee

composed of specialists in risk matters, which reports regularly to the

management body.

Adopted

Part I no. 27, 29 and 50

VII.3. The supervisory body is organised internally, implementing

periodic control mechanisms and procedures, in order to ensure that the

risks effectively incurred by the company are consistent with the

objectives set by the administration body.

Adopted

Part I no. 38, 50 and 54

VII.4. The internal control system, comprising the risk management,

compliance, and internal audit functions, is structured in terms that are

adequate to the size of the company and the complexity of the risks

inherent to its activity, whereby the supervisory body shall assess it and,

within the ambit of its duty to monitor the effectiveness of this system,

propose any adjustments that may be deemed necessary.

Adopted

Part I no. 50 and 52, 54

and 55

VII.5. The company establishes procedures of supervision, periodic

assessment and adjustment of the internal control system, including an

annual assessment of the degree of internal compliance and performance

of such system, as well as the prospects for ch

anging the previously

defined risk framework.

Adopted

Part I no. 38 and 49 to

VII.6. Based on its risk policy, the company sets up a risk management

function, identifying (i) the main risks to which it is subject in the operation

of its business, (ii) the probability of their occurrence and respective

impact, (iii) the instruments and meas

ures to be adopted in order to

mitigate such risks, and (iv) the monitoring procedures, aimed at following

them up.

Adopted

Part I no. 38 and 49 to

VII.7. The company establishes processes to collect and process data

related to the environmental and social sustainability in order to alert the

management body to risks that the company may be incurring and

propose strategies for their mitigation.

Adopted

Part I no. 21, 25, 29,

30, and 50 to 54

VII.8. The company reports on how climate change is considered within

the organisation and how it takes into account the analysis of climate risk

in the decision-making processes.

Adopted

Part I no. 21, 29, 30,

and 50 to 54

Annual Report Ch. 5.2.1

and 5.2.2.

VII.9. The company informs in the corporate governance report on the

Adopted

Part I no. 53

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 675

manner in which artificial intelligence mechanisms have been used as a

decision-making tool by the corporate bodies.

VII.10. The supervisory body pronounces on the work plans and

resources allocated to the services of the internal control system, including

the risk management, compliance, and internal audit functions, and may

propose adjustments as deemed necessary.

Adopted

Part I no. 38 and 50

VII.11. The supervisory body is the addressee of reports made by the

internal control services, including the risk management, compliance, and

internal audit functions, at least when matters related to accountability,

identification or resolution of conflicts of interest and detection of potential

irregularities are concerned.

Adopted

Part I no. 45 and 50

Chapter VIII – Information and statutory audit of the accounts

VIII.1. Information

Principles:

VIII.1.A.

The supervisory body, diligently and with independence, ensures that the management body observes its

responsibilities in choosing policies and adopting appropriate accounting criteria and establishing adequate systems for

financial and sustainability reporting, and for internal control, including risk management, compliance and internal audit.

VIII.1.B. The supervisory body promotes a proper articulation between the work of the internal audit and that of the statutory

audit of accounts.

Recommendation:

VIII.1.1. The regulations of the supervisory body requires that the

supervisory body monitors the suitability of the process of preparation and

disclosure of information by the management body, including the

appropriateness of accounting policies, estimates, judgements, relevant

disclosures and their consistent application from financial year to financial

year, in a duly documented and reported manner.

Adopted

Part I no. 38

VIII.2. Statutory audit and supervision

Principle:

VIII.2.A. It is the responsibility of the supervisory body to establish and monitor formal, clear, and transparent procedures as

to the relationship between the company and the statutory auditor and the supervision of compliance, by the statutory auditor,

with the rules of independence imposed by law and by professional standards.

Recommendations:

VIII.2.1. By means of regulation, the supervisory body defines, in

accordance with the applicable legal regime, the supervisory procedures

to ensure the independence of the statutory auditor.

Adopted

Part I no. 37, 38 and 46

VIII.2.2. The supervisory body is the main interlocutor of the statutory

auditor within the company and the first addressee of the respective

reports, and is competent, namely, for proposing the respective

remuneration and ensuring that adequate conditions for the provision of

the services are in place within the company.

Adopted

Part I no. 38 and 45

VIII.2.3. The supervisory body annually evaluates the work carried out by

the statutory auditor, its independence and suitability for the exercise of

its functions and shall propose to the competent body its dismissal or

termination of the contract for the provision of its services whenever there

is just cause to do so.

Adopted

Part I no. 38 and 45

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 676

COMPLY OR EXPLAIN

Explanation of non-adoption of recommendations

VI.2.9. A significant part of the variable component is partially deferred over time, for a period of no less than three

years, and is linked to the confirmation of the sustainability of performance, in terms defined in the remuneration

policy of the company.

The explanation for the non-adoption of this recommendation is set out in the statement on the remuneration policy in force,

which corresponds to Annex 2 to this Report, and reads as follows:

“Several writings sustain profusely the deferral of the payment of the variable part of remuneration to a later time, which will

enable the establishment of a direct relation between remuneration and the impact of management on the Company over a longer

period.

We accept this principle as theoretically sound, but the historical element, associated to the stability and the practice that has

been followed successfully for years without the element of deferral, leads us to not adopt that option for the time being.” The

Company has not therefore accepted this recommendation, without prejudice to ensuring the substance which justifies it to an

even greater extent than would result from compliance with it.

It should also be noted that Navigator's consolidated results for the financial year have repeatedly and consistently been very

positive, demonstrating the sustainability of performance which the Recommendation seeks to safeguard. It follows from this

background that the possible partial deferral for a period of no less than three years of the variable component of remuneration

would have no impact on the right to the variable component for Navigator's directors. However, it should be clarified that

Navigator is currently analysing the model for deferring payment of part of the variable remuneration with a view to its possible

implementation.

VI.3.2. The committee for the appointment of members of corporate bodies includes a majority of independent

directors.

The Company's Nominations and Evaluation Committee includes four non-executive directors, but only one is independent -

Mariana Rita Antunes Marques dos Santos. In choosing the members of this Committee, preference was given to a diversity of

profiles (age, gender, qualifications, experience and professional career), ensuring that all of them have full impartiality of analysis

and decision, and demonstrated integrity of character.

The Company believes that this diversity of profiles, together with the fact that the Nominations and Evaluation Committee uses,

whenever necessary, market studies and the analysis of comparable situations within the Group, is sufficient to guarantee that its

analyses are in line with the best practices and strengthen independent and impartial decision-making.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 677

Part III

Other Information

There are no other elements or additional information that are relevant to the understanding of the governance model and

practices adopted.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 678

ANNEX 1

1) DISCLOSURES REFERRED TO IN ARTICLE 447 OF THE COMPANIES’ CODE

(WITH REFERENCE TO 2024)

Securities issued by Company and held by company officers:

António José Pereira Redondo: 6000 shares

2) INFORMATION ON OWN SHARES (required by Articles 66 and 324 no. 2 of the

Companies Code)

On 31 December 2024, Navigator did not hold any own shares.

2024 ANNUAL REPORT • CORPORATE GOVERNANCE 679

ANNEX 2

REMUNERATION POLICY OF THE DIRECTORS AND THE AUDITORS OF THE

NAVIGATOR COMPANY (2023 TO 2025)

The Remuneration Committee of The Navigator Company,

S.A. (The Navigator Company) has analysed and reviewed

the Remuneration Policy for its directors and auditors

adopted at The Navigator Company's Annual General

Meeting of 2021 to be in force from 2021 to 2024, in view of

strengthening its alignment with sustainability and

preserving Company's long-term interests in line with good

market practices, having decided to replace the current

Policy with a new Remuneration Policy to be in force from

2023 to 2025, in order to make its period of application

coincide with the mandate of the governing bodies.

The remuneration policy is the exclusive responsibility of the

Remuneration Committee, which has three members, all

independent from the Board. According to the law, it must

be approved by the General Meeting at least every four

years and whenever a relevant change occurs.

In its work, namely in determining, reviewing and applying

the Policy, the Remuneration Committee complies with

applicable legislation and The Navigator Company's current

policies and regulations, namely the regulation on Conflicts

of Interest and Related Party Transactions, which sets out

rules for preventing, identifying and resolving conflicts of

interest between the Company and its managers.

1. General Principles

This Remuneration Policy is founded on the following general

principles that guide the setting of the remuneration of the

governing bodies:

(a) Duties performed.

The duties performed by each member of the governing

bodies cover both the functions in a formal sense and the

duties in the broader sense of the concrete level of

responsibility of the position held, considering different

criteria, such as the commitment and time dedicated, the

nature, size, complexity, and skills required for the function,

or the added value to the company that results from a

specific intervention or institutional representation.

The fact that time is spent by the officer on duties performed

in other controlled companies also cannot be taken out of

the equation, due to the added responsibility this represents

and to the existence of another source of income.

(b) The state of the Company’s affairs.

The size of the company and the inevitable complexity of the

related management responsibilities are clearly relevant

aspects of the economic situation, understood in the

broadest sense. These aspects have implications for the

need to suitably remunerate directors holding high

managerial duties, considering the size and complexity of

the business models.

It is essential to be able to attract, develop and retain the

best professionals. Consequently, the Remuneration Policy

must competitive and appealing in order to ensure the

legitimate interests of individuals are aligned with The

Navigator Company’s interests and the creation of

sustainable value for shareholders.

Given its characteristics and size, the market criteria and

practices to be taken into account are, in The Navigator

Company 's case, both national and international. In order to

keep up to date with these practices, The Navigator

Company regularly uses market research and benchmarking.

In this context, the different components of the directors’

remunerations are calculated at least based on the

remuneration of the directors of the Portuguese companies

listed on the PSI Index, while also taking into account, at

each moment, the remuneration conditions applied in other

companies with characteristics similar to those of The

Navigator Company.

The remuneration system in place at The Navigator

Company, in particular this Policy, contributes to the

implementation of the business strategy of The Navigator

Company and, in the long term, to the alignment of the

interests of members of the management body with those of

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 680

the Company and its sustainability, in particular for the

reasons set out below.

Firstly, because the remuneration is intended to be fair and

equitable in the light of the principles set out, and secondly,

because it lays down the evaluation criteria (indicators

defined by the Remuneration Committee), which are aligned

with the Company’s own strategic objectives. Such indicators

help to align the performance of the members of its

corporate bodies with the long-term interests and

sustainability of the Company.

The alignment between this Policy and the remuneration

scheme and employment conditions of The Navigator

Company employees is assured, given that both

remuneration systems are based on the same General

Principles set out in this Remuneration Policy, in particular

the market conditions in the reference markets for the duties

performed. Furthermore, the annual variation of the

compensation paid individually by the Company to the

members of the Board of Directors, as well as the average

compensation of the company's full-time equivalent

Employees is analysed.

Accordingly, this Policy aligns The Navigator Company with

market best practices on remuneration, and with the

recommendations of the IPCG Governance Code.

2. Board

2.1. Non-Executive Directors

The remuneration of non-executive directors shall comprise

only a fixed component of an annual amount, paid 12 times

per year, which may vary according to the piling on of added

responsibilities,

e.g. committee and specialised committee members, or a

fixed amount per Board meeting attended.

The remuneration of non-executive members of the Board of

Directors does not include components dependent on the

performance of the Company or on its value.

2.2. Executive Directors

The remuneration of the Executive Directors consists of two

components: fixed and variable.

2.2.1. Fixed Remuneration

The remuneration of the executive Directors consists of a

fixed component, corresponding to an annual amount

payable 12 times per year.

2.2.2. Annual Variable Remuneration

The annual variable remuneration of the executive directors

is contingent, and may amount, globally, to a percentage

that does not exceed five per cent of the previous year’s net

profit, in accordance with the Company's articles of

association.

The Remuneration Committee decides on this component,

and the performance of each executive director is assessed

following an internal process lead by the respective person in

charge (i.e. the responsibility of the person who manages

the team in the case of the members of the Executive

Committee, and the responsibility of the Chairman of the

Board of Directors in the case of the CEO) and with the

participation of the non-executive directors that the person

in charge deems pertinent to involve.

The Nomination and Assessment Committee is also involved

in this process. It is responsible for monitoring the system

for assessing management performance and distributing the

remuneration and delivering its opinion on the proposals for

individual performance assessment of the Executive

Committee.

Finally, the Remuneration Committee must confirm that the

factors have been met for the performance evaluation and

ensure the overall consistency of the process by setting the

variable remuneration.

The annual variable remuneration is based on the target

amount applied to each director and is paid according to the

individual's performance and performance of the Company

that meet the expectations, and the criteria set previously.

The target amount is weighted by the aforementioned

general principles - market, specific functions, state of the

Company -, in particular comparable market circumstances

in equivalent functions. Another important factor taken into

account when setting the targets is The Navigator

Company’s option not to provide any stock or stock option

plans.

Actual performance compared to the expectations and goals,

which determine target variations is weighed against a set of

quantitative and qualitative KPIs of the company's

performance (which consist of general business indicators

weighing 65%) and of the relevant director performance

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 681

(which consists of specific objectives weighing 20% and

behavioural indicators that account for 15%).

Overall business indicators and their relative weights, which

may be adjusted annually up to 5% in relative terms, are as

follows:

- EBITDA, accounting for 35%

- Net results, accounting for 10%

- Cash flow, accounting for 10%, and

- Total Shareholder Return vs Peers, accounting for

10%.

The specific objectives always include ESG indicators, such

as the findings of the annual Corporate environment survey,

the reduction of CO2 emissions, the certified wood and the

consumption of water, energy and wood.

On the other hand, within the behavioural indicator, the

alignment of each executive director with the existing

leadership model and the long-term interests of the

Company is relevant.

The performance criteria mentioned in the previous

paragraph are applied mathematically for their quantitative

part - based on the values of the business plans approved by

the Board of Directors, and at the end of each period these

commitments are compared with the actual income - and

using value assessments for the qualitative part.

In addition to the statutory limit on management's share of

profits for the year, the Company also has mechanisms in

place to limit variable compensation: (i) the variable

remuneration is eliminated in the event of the results

showing a significant deterioration in the company’s

performance in the last reporting period or when such

deterioration may be expected in the period underway, and

(ii) the amount of the annual variable remuneration

attributable has a cap corresponding to 1.8 times the target,

to prevent good performance at one moment, with

immediate remuneration benefits for the Board, from being

achieved to the detriment of good performance in the future.

The annual variable remuneration is subject to reasonable

adjustments related to exogenous factors and unforeseen

economic decisions, as decided in advance by the

Remuneration Committee.

The nature of the indicators, their weight in determining

actual variable remuneration and the limits on the

application of variable remuneration create a remuneration

model based on recognising merit against the actual

performance of the Company and discouraging excessive

risk-taking, whilst helping to implement the strategy defined

by The Navigator Company and ensuring that the interests

of the executive directors are aligned with the Company's

long-term interests.

3. Other benefits

In addition to the variable component that may be paid to

the members of the management bodies, no other non-cash

benefits are paid to directors and auditors, without prejudice

to the means made available to them for the performance of

their duties, a life insurance, a personal health insurance,

and an accident insurance policy in line with market

practices.

4. Other Considerations

There are no agreements, and no such provisions have been

defined by this Committee, on payments by The Navigator

Company relating to dismissal or termination of Directors’

duties. This fact is the natural result of the particular

situations existing in the Company, and not a position of

principle taken by this Committee against the existence of

agreements of this nature. Only the supplementary legal rule

in this matter applies here, as established in the Companies

Code, which governs the payment to the Directors of any

amounts before the end of the mandate.

Similarly, there are no complementary or early retirement

arrangements for directors currently in place in the

company.

With regard to the obligation to return variable remuneration

that has been paid, and without prejudice to the applicable

legal provisions, if, by final court decision, The Navigator

Company or the members of the Executive Committee of

The Navigator Company are found liable for unlawful and

wilful acts of misconduct resulting in the need to restate its

financial statements or to record reductions in the value of

assets unfavourable to The Navigator Company, the

Remuneration Committee may, at its discretion and by

means of a resolution, demand from the executive directors

the refund of the variable remuneration in respect of the

period when such depreciation of the assets occurred or

another period deemed relevant, in order to compensate The

Navigator Company for the damage caused.

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 682

5. Audit Board

The remuneration of the members of the Audit Board shall

consist only of a fixed component, i.e. a fixed annual

amount, payable 12 times a year; the remuneration of the

Chairman of the Audit Board is higher than that of the other

board members, taking into account the special functions

performed by him/her.

There are no agreements, and no such provisions have been

defined by this Committee, on payments by The Navigator

Company relating to dismissal or termination of duties by

the Members of the Audit Board.

6. General Meeting

The remuneration of the officers of the General Meeting shall

consist of a fixed amount only (as decided) for each meeting

held, whereas the remuneration of the second and

subsequent meetings held in the same year shall be lower

than that of the first general meeting. The remuneration of

the Chairman of the General Meeting shall be higher than

that of the Secretary, taking into account the greater

responsibility of the duties performed.

Lisbon, 24 April 2023

The Remuneration Committee

ANNUAL REPORT 2024 • CORPORATE GOVERNANCE 683

ANNEX 3

CODE OF ETHICS AND CONDUCT

I. General Objectives and Values

1. The Code of Ethics and Conduct as the basis of

the culture of The Navigator Group

The pursuit of the objectives, respect for the values and

compliance with the rules of conduct set out in this

Code of Ethics and Conduct constitute the ethical

culture of The Navigator Company, S.A. (hereinafter

"Navigator").

The Code of Ethics and Conduct is to be viewed as

setting standards of conduct interpreted as a

benchmark for behaviour, which Navigator and all those

who work for it should follow and respect.

2. Fundamental Mission and Objectives

The Navigator Group aspires to extend the leadership

earned in the printing and writing paper business to

other businesses, thereby asserting Portugal in the

world, as a global company, renown for developing, in

an innovative and sustainable manner, the forest and

providing products and services which contribute to the

prosperity of individuals.

The fundamental aims pursued by Navigator are based

on the sustained creation of value and the protection of

shareholders’ interests, with an appropriate level of

investor return, by offering the highest standards of

quality in the supply of goods and services to

customers, and through the recruitment, motivation

and development of the most able and highly skilled

professionals. Navigator will always promote a

meritocratic culture which allows the personal and

professional development of its Collaborators and,

through their commitment, position Navigator's

business at the forefront of the markets in which it

operates, maintaining a policy on the sustainable

management of natural resources, mitigation of

environmental impacts and fostering social

development in the areas in which it carries on its

business operations.

Due to their being core principles and of a general

nature, the matters governed in the Code of Ethics and

Conduct may be detailed in internal guidelines, policies

and procedures, or in specific codes of conduct.

3. Values

The principles and rules of conduct set out in the Code

of Ethics and Conduct result from the establishment of

values deemed to be fundamental to Navigator, and

which should be permanently pursued within its

corporate activity, in particular:

(a) Trust – We believe in people, we welcome

everyone’s contribution, we respect their identity,

promoting development, cooperation and

communication;

(b) Integrity – We are guided by principles of

transparency, ethics and respect in our dealings

amongst ourselves and with others;

we do, we like to get out of our comfort zone, we

have the courage to take decisions and to accept

risks in a responsible way;

(d) Innovation – We seek to bring out everyone’s skills

and creative potential to do the impossible;

(e) Sustainability – Corporate, social and environmental

sustainability is our business model;

(f) Excellence –In our work we focus on quality,

efficiency, safety and getting it right.

II. Scope of Application and Interpretation

4. Scope of Application

The Code of Ethics and Conduct applies to all

Collaborators of all entities in Navigator Group.

The rules set out herein should govern the ethical and

professional conduct of all those working in The

Navigator Group, in the pursuance of its corporate

activity and in their relationships with third parties and

are an essential tool of the corporate policy and culture

followed and fostered by Navigator.

5. Interpretation

For the purposes of this Code of Ethics and Conduct,

the following defined terms shall have the following

meanings:

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Collaborators – Any person who, irrespective of their

position at Navigator, has a permanent or temporary

employment relationship with Navigator, as well as any

person with employment and/or regular employment

relationship with companies subcontracted by Navigator

who, directly or indirectly, perform duties for Navigator

(members of corporate bodies, employees, service

providers, agents, auditors and consultants);

Clients – natural or legal persons to whom Navigator

Group companies supply their products or provide their

services;

Suppliers – natural or legal persons who supply

products or provide services to any Navigator Group

entity;

Group – the Navigator Group comprises all legal

persons over which The Navigator Company exercises,

directly or indirectly, a dominant influence, including,

but not limited to, all companies in a control or group

relationship with The Navigator Company;

Stakeholders – natural or legal persons with whom the

Navigator Group companies relate in their business,

institutional or social activities, including shareholders,

members of governing bodies, Employees, Customers,

Suppliers, business partners or members of the

community with which the Navigator Group interacts.

III. Rules of Conduct

6. Compliance with Legislation and Regulation

The activities of Navigator and its employees shall be

guided by strict compliance with the legal, statutory

and regulatory rules applicable to the Navigator Group's

business and companies in the jurisdictions in which

they operate, as well as strict compliance with the

internal instruments it has implemented.

7. Public Authorities

Navigator's conduct and that of its Employees shall be

guided by ongoing cooperation with the public

authorities, in particular the regulatory authorities,

complying with requests legitimately addressed to them

and within their reach, and adopting behaviour that

enables them to exercise the powers entrusted to those

authorities.

8. Integrity

Any practice of corruption and bribery, in all its active

and passive forms, whether through acts and omissions

or through the creation and maintenance of favourable

or irregular situations, as well as the adoption of

behaviour that may create expectations of favouritism

in interlocutors in their relations with Navigator, as set

out in the Policy for the Prevention of Corruption and

Related Offences.

9. Transparency

Navigator is committed to report its performance in a

transparent way, taking into consideration applicable

legal duties and good practices of the capital and

financial markets.

10. Confidentiality

10.1. Collaborators must keep the confidentiality of all

information concerning The Navigator Group, other

Collaborators, Clients, Suppliers or Stakeholders, of

which they have knowledge by virtue of carrying out

their duties and which is not publicly known or

notorious. Such information is restricted and only for

internal use in The Navigator Group.

10.2. Collaborators must maintain confidential the

information mentioned in the previous paragraph, even

after termination of their functions in Navigator and

regardless of the cause of such termination.

10.3. Confidential information may only be disclosed to

third parties in accordance with legal requirements or

provided disclosure thereof is previously authorized, in

writing, by the Board of Directors.

11. Business information, insider information and

Securities Transactions

11.1. Employees must not use business information

obtained in the course of their duties at Navigator to

take advantage of illicit business opportunities.

11.2. Employees in possession of specific and concrete

information concerning The Navigator Company that

has not been made public, but which, if made public,

would be likely to have a significant influence on The

Navigator Company's share price, may not, during the

period prior to its disclosure, trade in securities of

Navigator, strategic partners or companies involved in

transactions or relations with Navigator, nor disclose

such information to third parties.

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11.3. Types of inside information include estimates of

results, decisions regarding acquisitions, sales or

significant partnerships and the acquisition or loss of

relevant contracts.

12. Conflicts of Interest

12.1. Navigator undertakes to adopt measures to

ensure that it is exempt from acting in decision-making

processes in cases of potential conflict of interest

involving Navigator or its Employees. For the purposes

of this Code, an Employee shall be in conflict whenever

he/she has a personal or private interest in a particular

business relationship or activity carried out, which may

constitute an advantage for him/herself or for a third

party related to him/her, in particular to whom he/she

is linked by kinship, proximity or influence.

12.2. Employees may not pursue private objectives in

competition with Navigator, and are also prevented

from obtaining personal benefits, advantages or favours

by virtue of the position held or duties performed.

12.3. Employees must immediately report to their

superior any situation that may constitute a conflict of

interest as soon as they become aware of it,

particularly if, in the course of their duties, they are

called upon to intervene in proceedings or decisions

involving, directly or indirectly, organisations, entities

or persons with whom they collaborate or have

collaborated, or to whom they are linked by ties of

kinship, proximity or influence. In addition to these, in

any other cases where their impartiality may be

questioned, they must make that communication, as

detailed in the Policy for the Prevention of Corruption

and Related Offences and in the Regulation on Conflicts

of Interest and Related Party Transactions.

13. Shareholder relations and governance

13.1. Navigator's primary objective is to protect the

interests of shareholders and investors, and to seek to

create value for shareholders.

13.2. Navigator undertakes to respect the principle of

equal treatment of shareholders, taking into account

their proportions in the share capital of The Navigator

Company, namely by ensuring that information is made

available in a timely manner, in compliance with

applicable legal duties.

13.3. Navigator discloses annually in its corporate

governance report the governance practices applied

and incorporates national and international best

practices in this area.

14. Competition

The competition practices of Navigator shall comply

strictly with applicable competition laws, in accordance

with market rules and criteria, and with a view to

promoting fair competition.

15. Intellectual and Industrial Property

Navigator and its Collaborators must respect

Intellectual and Industrial Property of Suppliers, Clients

and Stakeholders.

16. Relations with Clients, Suppliers, Services

Providers and Third Parties

16.1. Navigator shall ensure that the terms and

conditions for the sale of products to its Customers are

clearly defined, and Group companies and their

Employees shall ensure that they are complied with.

16.2. Navigator's Suppliers and service providers shall

be selected on the basis of objective criteria, taking into

account the conditions proposed, the guarantees

actually given and the overall optimisation of benefits

for Navigator.

16.3. Navigator's Suppliers and service providers shall

comply with the provisions of The Navigator Company's

Code of Conduct for Suppliers.

16.4. Navigator and its Employees shall at all times

negotiate in compliance with the principles of good faith

and the applicable legal obligations and best practices.

16.5. In order to ensure that Customers, Suppliers,

Service Providers and other third parties pursue

legitimate activities, whose sources of income are

lawful and which do not represent a direct or indirect

risk of criminal practices, the relations established with

them must comply with the provisions of the applicable

internal policies and procedures.

17. Relations with Political Parties and

Movements

17.1. Navigator's and its Employees' relations with

political movements or parties, where they exist, shall

be conducted in compliance with the legal provisions

and internal instruments in force.

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17.2. If Navigator's Employees make contributions

of the nature described in their personal capacity, they

must take into account any conflict of interest with their

professional responsibility and refrain from invoking

their relationship with Navigator.

18. Social Responsibility and Sustainable

Development

18.1. Navigator accepts its social responsibility to the

communities in which it carries on its business

activities, as a means of contributing to their

advancement and well-being.

18.2. Navigator undertakes to adopt, comply with and

promote a Policy on sustainability and environment

protection.

19. Safety and Working Conditions

19.1. Navigator will never employ child or forced

labour, nor will it ever collude with such practices, and

it shall adopt the measures deemed appropriate to

combat such situations, notably by public denunciation,

whenever they come to its attention.

19.2. The health and safety of its Collaborators is a

priority for Navigator, and accordingly all Collaborators

shall seek to know and comply with the legislation in

force and with internal rules and recommendations on

such matters.

19.3. Employees must immediately report any accident

or situation that may compromise hygiene, safety and

health in the workplace, in accordance with the

applicable rules, and the preventive measures that

prove necessary or recommendable must be adopted.

20. Professional development and progression

20.1. Navigator provides appropriate training activities

to its Collaborators and fosters their continued training,

as a driver of their motivation and improved

performance, recognizing the added value of their

professional and personal development.

20.2. Navigator values and holds responsible

Collaborators in the performance of their functions,

taking into consideration their individual merit, allowing

them to assume the level of independence and

responsibilities associated with their skills and

commitment.

20.3. The selection, hiring, remuneration and

professional development policies adopted are guided

by merit criteria and market reference practices.

20.4 Navigator shall ensure equality of opportunities

and respect for gender equality in recruitment, hiring

and professional development, attaching value only to

professional aspects. To that effect, all Collaborators

shall adopt the measures deemed appropriate to

combat and prevent any form of discrimination or

differentiated treatment based on, notably, ethnic or

social origin, religious beliefs, nationality, gender,

marital status, sexual orientation or physical disability.

21. Respect

In their relations with other Collaborators and

Suppliers, counterparts, Clients and Stakeholders, all

Collaborators shall proactively act in a correct,

respectful, loyal and civil manner.

22. Non-discrimination and harassment

22.1. Collaborators may not act in a discriminatory

manner in relation to other Collaborators or other

persons, notably based on race, religion, gender, sexual

orientation, origin, age, language, territory of origin,

political or ideological convictions, economic situation,

social and economic situation or type of contract, and

must foster respect for human dignity as one of the

basic principles of the culture and policy of Navigator.

22.2. Any practice which may correspond to a form of

harassment, notably through personal offence,

mobbing, moral or sexual harassment or bullying is

strictly forbidden, under the terms of the

Whistleblowing Regulation and the Code of Good

Conduct on Preventing and Combating Harassment at

Work.

23. Use of Assets

23.1. Collaborators shall make sensible and reasonable

use of the working resources at their disposal, avoiding

waste and undue use.

23.2. Collaborators shall care for the property of

Navigator and not behave wilfully or negligently in any

manner which might undermine its state of repair.

24. Personal Data Protection

24.1. Navigator understands the key role of privacy and

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protection of personal data of its Clients, Stakeholders,

Suppliers, Collaborators or any other natural persons or

collaborators of any other entities. Accordingly,

Navigator and its Collaborators undertake to use such

information in a responsible manner, in strict

compliance with laws and regulations governing the

protection of personal data.

24.2 Collaborators must not collect personal data,

create lists of personal data or process or transfer

personal data without prior consultation and

authorisation from the area which is responsible for

data protection.

25. External Communication – Media and

Advertising

Information provided by Navigator and its Collaborators

to the media, including for advertising purposes, shall:

(a) Be released exclusively by management and

departments authorised for that purpose and to act

as representative or spokesman of Navigator;

(b) Comply with the principles of legality, accuracy,

opportunity, objectivity, truthfulness and clarity;

information, in order to protect the interests of

Navigator;

(d) Respect cultural and ethical parameters of the

community and human dignity;

(e) Contribute to an image of consistency, creation of

value and dignity of Navigator, promoting its good

name in society.

26. Communicating in social networks and media

Collaborators are fully aware that the new forms of

communication, which are continually evolving, may

have a strong impact on Navigator and its Collaborators

and that the dissemination and distribution of

information through those channels may easily

represent loss of control over those contents.

Accordingly, Collaborators undertake as their

commitment that, when using social networks and

means of communication (both traditional and recent),

they:

Shall act in an ethically responsible way, contributing to

the creation of value and dignity of The Navigator

Group and to reinforce its image in society;

Shall respect, comply with and reflect the principles,

values and rules of conduct established in this Code of

Ethics and Conduct;

Shall not post or otherwise disclose confidential or

internal information of Navigator;

Shall not communicate, identifying themselves as

Collaborators of Navigator, without authorization for

that purpose.

IV. Supervision, Default and Communication

27. Non-compliance

Failure to comply with the rules of conduct established

in this Code of Ethics and Conduct shall constitute

serious misconduct, subject to disciplinary proceedings,

in addition to any possible civil, administrative or

criminal liability, in accordance with applicable laws and

regulations.

28. Reporting

28.1. Collaborators should report the occurrence of any

conduct which is not compatible with the rules set out

in this Code of Ethics and Conduct, of which they are

aware or justifiably suspicious, in a timely and efficient

way, through the proper channels, in accordance with

the internal rules of the Whistleblowing Regulation and

the Code of Good Conduct for Preventing and

Combating Harassment at Work.

28.2. Navigator guarantees the confidentiality of

information conveyed in reports, in accordance with the

internal rules of the Whistleblowing Regulation.

28.3. Navigator shall not retaliate, in any way, against

a person who reports any non- compliance with the

Code of Ethics and Conduct or another irregularity, shall

ensure a fair treatment of the persons addressed

therein and will not allow the resulting detrimental

treatment where a Collaborator has acted in good faith,

thoughtfully and diligently.

28.4 In accordance with the general terms of the law,

misuse or abuse of the arrangements for reporting

irregularities may render the author of a report liable to

disciplinary measures and/or legal proceedings.

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29. Criteria for action, doubts and questions

Employees must act in accordance with this Code of

Ethics and Conduct and with good judgment, assessing

the alignment of their conduct with the company's risk

culture and policy, including from the point of view of

reputational risk, and its appropriateness in the event

of public disclosure.

Employees may submit doubts and questions regarding

the interpretation or application of the Code of Ethics

and Conduct to the Compliance Area, through the

following email address

[email protected]

30. Reporting of Irregularities

Any non-compliance with the provisions of this Code

must be reported in accordance with The Navigator

Company's Whistleblowing Regulations.

31. Annual Report

31.1. The Ethics Committee shall draw up an annual

report on compliance with the rules established in this

Code of Ethics and Conduct, detailing all irregularities of

which it is aware, and setting out the conclusions and

follow-up proposals adopted in the different cases

which it examined.

31.2. For the purposes of the preceding paragraph, the

Risk Management and Compliance Area shall report to

the Ethics Committee all relevant facts which come to

their attention.

Communication

32. Communication of the Code of Ethics and

Conduct

32.1. The Navigator Company's Code of Ethics and

Conduct shall be disclosed on Navigator's digital

internet platform and together with the annual financial

statements, so that it may be known to Shareholders,

Customers, Suppliers, Stakeholders, Investors and

other entities with whom the Navigator relates.

32.2. Navigator shall make the Code of Ethics and

Conduct available to all Collaborators and will promote

its dissemination, widespread awareness and

mandatory practice.

Lisbon, July 21, 2023

The Board of Directors,

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