05 | Non-Financial Highlights 2024

5.4.2 ESRS E2 – POLLUTION 

At the core of Wolftank Group’s mission is the reduction of environmental pollution. The company develops advanced solutions for soil remediation, sustainable management of hazardous substances, and reduction of pollutant emissions. Its operations are guided by a technology-driven approach focused on the prevention, monitoring, and mitigation of environmental impacts, both from its own activities and those of its customers – on air, water, and soil. 

In line with CSRD and European environmental regulations, Wolftank Group adopts strategies to minimize the release of harmful substances, improve air quality, and ensure responsible industrial waste management. The group continuously invests in research and development to optimize its processes and provide innovative solutions in the field of decontamination and energy transition. 

Through a business model oriented toward sustainability and circularity, Wolftank Group is committed to driving pollution reduction across the industrial and energy sectors. The company promotes responsible practices throughout the value chain and actively contributes to global goals for improving environmental quality. The Double Materiality analysis identified the following Impacts, Risks and Opportunities (IRO) for Theme E2 Pollution.

5.4.2.1 Positive Impacts 

• Treatment plants purify water to make it reusable. 
• Limitation of environmental damage to (open) waters through environmental emergency interventions. 
• Soil quality is improved through on-site treatments (directly in the soil) or at the Wolftank Rovereta soil remediation plant, allowing the soil to be reused. 
• Limitation of environmental ground damage through environmental emergency interventions. 
• Wolftank Group company reclaims contaminated soil by subjecting it to a microbiological bioremediation process. This way, contaminated areas can be reused after soil remediation.

5.4.2.2 Negative Impacts 

• Air pollution due to transport of materials, employee travel, and business trips. 
• Water pollution in the upstream supply chain caused by metal ore mining and the use of chemicals in textile production for protective clothing. 
• Tank cleaning generates water contaminated with substances from the tanks. 
• Soil pollution in the upstream supply chain caused by metal ore mining and the use of chemicals in textile production for protective clothing. 

5.4.2.3 Risks and opportunities 

• The double materiality analysis revealed no material risks and opportunities for E2 Pollution. 

5.4.2.4 Impact material analysis for Pollution 

For Wolftank Group, the issue of pollution represents one of the most critical areas of environmental impact, both due to the inherent nature of its operations and the  strategic, solution-oriented role the company plays in environmental remediation. The double materiality analysis confirmed that ESRS E2 – Pollution is to be considered a material topic, as it can lead to significant direct and indirect environmental impacts, both positive and negative. 

• The Group’s core business – including water treatment, contaminated site remediation, and environmental emergency response – plays a significant role in mitigating pollution impacts on water and soil and to a lesser extent, on air. In particular: Wastewater treatment and reuse. Through technologically advanced facilities, the Group treats contaminated water and makes it suitable for reuse. This reduces the need for water abstraction from primary sources and actively supports the conservation of water resources. This type of intervention is of high strategic relevance – not only due to its intrinsic environmental value but also because of its alignment with the goals of ecological transition and the efficient use of natural resources. The impact of this activity has been assessed as absolute and critical (5/5 on the materiality scale), with its effects primarily felt at the regional or national level. It represents a cornerstone of the Group’s environmental sustainability strategy.  
• Environmental emergency management and damage prevention. The Group is frequently called upon to respond to critical incidents, such as accidental spills or industrial accidents. Through rapid intervention and technical expertise, Wolftank Group is able to contain and mitigate the impact of harmful substances, thereby protecting surface water, groundwater, and soil from contamination. These actions have proven to be highly effective, with their materiality level assessed as ‘significant’. 
• Soil remediation and restoration. Leveraging innovative microbiological remediation methods and in-situ treatment technologies, Wolftank Group facilitates the recovery of contaminated land, contributing to the restoration of ecological and economic value in degraded areas. These interventions not only enhance environmental quality but also create social and territorial value, enabling the revitalization of previously contaminated sites and opening new opportunities for local communities and businesses.  

Alongside the numerous environmental benefits, Wolftank Group also recognizes the existence of negative environmental impacts associated with specific aspects of its operations and supply chain: 

• Air pollution. Waste transport activities, business travel, and employee commuting contribute to air emissions, leading to an increase in greenhouse gases. Although these are indirect emissions (Scope 3), the impact is significant and unevenly distributed across the territory. The materiality assessment recognizes the need for targeted reduction strategies, including the logistical optimization of waste delivery to disposal and/or treatment facilities and the promotion of sustainable mobility solutions. 
• Water contamination. Certain industrial activities, such as tank cleaning and vitrification, and industrial remediation can pose risks of water contamination, especially if not managed according to strict protocols. The possibility of accidental spillage and the complexity of the treatments required make this impact particularly critical, especially in high-intensity and environmentally vulnerable operating environments. 
• Soil pollution along the supply chain. The Group also carefully monitors the indirect impacts generated by its suppliers, particularly those related to the extraction of raw materials or the use of chemicals in the production of materials and equipment. In some cases, these activities could result in soil contamination and biodiversity loss, issues that require responsible supply chain management, based on environmental criteria and due diligence. 

In light of this analysis, Wolftank Group has outlined several strategic priorities to strengthen its ability to contribute to pollution reduction and to manage residual negative impacts more effectively: 

1. Expanding the scale of application of environmental treatment technologies, increasing intervention capacity, and replicating the most effective solutions in new geographical contexts. 
2. Reducing indirect atmospheric emissions through actions on logistical organization, corporate mobility, and energy efficiency at operational sites. 
3. Adopting more stringent protocols for water and soil management, integrating the best treatment technologies, and preventing degradation phenomena before they occur. 
4. Actively collaborating with the supply chain, promoting less impactful production practices and selecting suppliers who share the company’s environmental and social responsibility standards. 

5.4.2.5 Financial materiality analysis Financial for Pollution 

The double materiality analysis revealed no material financial impact for E2 Pollution. 

5.4.2.6 ESRS E2 – MDR – PAT 

The analysis of the MDR (Mandatory Disclosure Requirements) related to ESRS E2 – Pollution provides an overview of the policies, actions, and financial resources allocated by Wolftank Group to address the challenges and opportunities related to environmental pollution management and reduction. 

The objective of these requirements is to provide an overview of air, water, and soil pollution management, pollutant reduction, and the integration of sustainability into corporate strategy.  

The main information requirements for pollution (E2) include: 

• E2-1 (MDR-P): Company policies for pollution management. 
• E2-2 (MDR-A): Concrete actions implemented to reduce air, water and soil pollution 
• E2-3 (MDR-M, MDR-T): Operational objectives and metrics to monitor the effectiveness of policies and actions. 
• E2-4, E2-5, E2-6: Monitoring and management of pollution, hazardous substances and related financial impacts. 

5.4.2.7 E2 MDR-P – E2 – 1 – Policies related to pollution 

§ MDR-P, 65; § 12-15 

Wolftank Group has adopted a strategic approach to managing environmental pollution, grounded in the principles of prevention, mitigation, remediation and technological innovation. The company’s policies are closely aligned with the core values of operational sustainability, resource circularity, and the implementation of low-impact technologies. These efforts aim to reduce pollution by optimizing industrial processes, increasing resource efficiency, and deploying advanced technologies for the treatment and reuse of natural resources. In particular: 

• Reducing air, water, and soil pollution by controlling emissions, adopting low environmental impact processes and optimizing production and logistical resources. 
• Efficient management and treatment of environmental resources, focusing on regenerating water resources, reducing industrial waste, and increasing treatment capacity at company facilities. 
• Implementation of the best available technologies for the treatment and remediation of contaminated sites, with a focus on wastewater reuse and containment of hazardous substances. 
• Control and reduction of chemical and hazardous substances, minimizing the risk of soil and groundwater contamination. 
• Active engagement of suppliers and strategic partners, promoting a circular economy and ensuring compliance with national and European environmental standards. 
• Adhering to and exceeding environmental regulations, committing to European and international regulations through innovative and sustainable practices. 
• Awareness-raising and continuous staff training to integrate environmental best practices into all company operations and improve overall environmental performance. 

Wolftank Group will continue to develop innovative solutions to improve its environmental footprint, promoting a culture of sustainability both within the organization and in its relationship with stakeholders and local communities. 

5.4.2.8 E2 MDR-A – E2 – 2 – Actions and resources related to pollution 

§ MDR-A, 68-69; § 16-19 

To translate its policies into concrete actions, Wolftank Group has implemented a multi-layered intervention strategy, investing in advanced technologies and targeted programs designed to reduce pollution and optimize resource use. 

The main initiatives include: 

• Efficient management of water resources by increasing the share of treated and reused water compared to disposed water, thanks to advanced treatment and reuse systems. 
• Reclamation and reuse of soil as a secondary raw material/end-of-waste, with the reduction of the amount of land for landfill and the advanced treatment of materials for reuse. 
• Optimizing logistics and transport, minimizing CO₂ emissions through direct management of suppliers, reducing the number of transport trips and improving efficiency in the handling of waste and materials. 
• Advanced emission monitoring through the adoption of sensors and predictive analysis tools to reduce the atmospheric impact of production activities. 
• Development of innovative technologies for wastewater treatment, with a focus on recovering water resources and reducing environmental impact. 
• Energy efficiency and reduction of air emissions through advanced technological solutions in production processes and offices. 
• Environmental contingency plans to respond promptly to incidents and reduce the potential impact on the environment. 
• Sustainable waste management through the rotation of treated land in multi-purpose waste treatment platforms to optimize the utilization and reduce raw material waste. 
• Adoption of sustainable materials and products, including recycled and recyclable workwear. 
• Awareness-raising of customers and partners, with the issuing of certificates quantifying the pollution avoided or mitigated thanks to the solutions implemented by Wolftank. 
• Innovation in plant engineering for multifunctional waste treatment platforms. 

To support these initiatives, Wolftank Group is allocating dedicated financial resources for investments in environmental technologies and staff training.  

5.4.2.9 E2 MDR-M – Metrics for pollution assessment 

§ MDR-M, 75-77 

Wolftank Group applies a structured system of environmental performance metrics and indicators to monitor the effectiveness of its initiatives and to assess progress in reducing pollution. These include, among others: 

• Percentage of treated and reused water compared to disposed water. 
• Reduction of CO₂ emissions from logistics and waste management. 
• Volume of industrial waste sent to landfill and treatment, relative to the total generated. 
• Number of reclaimed sites and amount of soil recovered through decontamination processes. 
• Efficiency of treatment and reclamation processes, measured in terms of reduction of pollutants in treated waste. 
• Number of suppliers and partners qualified according to environmental sustainability criteria. 

5.4.2.10 E2 MDR-T – E2 – 3 – Targets related to pollution 

§ MDR-T, 80-81; § 20-25 

Wolftank Group has established clear and measurable targets to reduce its environmental impact and ensure compliance with sustainability standards, in alignment with the disclosure requirements of ESRS E2 MDR-T and E2-3. These objectives are multi-dimensional, aiming to reduce emissions, optimize resource management, and promote circular economy principles (5.5 Sustainability Plan). Key targets include: 

• Reduction of water pollution, by enhancing wastewater treatment and recycling technologies, and reducing the discharge of pollutants. 
• Reduction of air emissions, through the optimization of logistics, use of low-emission vehicles, and adoption of renewable energy in industrial processes. 
• Increase in the share of land treated through specialized platforms. This will be accomplished by enhancing the efficiency of waste treatment processes and reducing the volume of waste sent to landfill, thereby supporting land recovery and circular resource use. Reduction of waste transport, through route optimization and limiting non-essential movements to reduce CO₂ emissions. 
• Promotion of the circular economy, with increased use of recycled materials and more sustainable product life-cycle management. 
• Optimization of corporate mobility by reducing business trips and implementing more efficient travel planning to minimize travel-related pollution. 
• Preparation of sustainability analyses of environmental remediation projects in terms of applied technologies. 
• Monitoring and reduction of water usage in industrial remediation processes. 

To ensure the achievement of these goals, Wolftank Group has implemented has implemented a monitoring and regular review process. 

5.4.2.11 E2 – 4 – Pollution of air, water and soil 

§ 26-31 

The environmental impact analysis identified the main sources of pollution: 

• Air: Gas and particulate emissions results mainly from transport, production processes, and the use of fossil fuels. Projects for energy efficiency and the reduction of harmful emissions have been initiated. 
• Water: Water pollution is linked to the discharge of chemicals in on-site and off-site treatment processes to decontaminate groundwater. The mitigation plan includes upgrading treatment systems and reusing water in industrial processes and services. 
• Soil: The risk of contamination arises mainly from the incorrect handling of industrial waste and the presence of chemicals in treatment processes. Soil remediation and microbiological treatment programs are being developed. 

5.4.2.12 E2 – 5 – Substances of concern and substances of very high concern 

§ 32-35 

The double materiality analysis revealed no material financial impact for E2 – 5 – Substances of concern and substances of very high concern. 

5.4.2.13 E2 – 6 – Anticipated financial effects from pollution-related impacts, risks and opportunities 

§ 36-41 

Pollution represents not only an environmental risk factor but also an economic one. Wolftank Group has identified key financial effects associated with environmental impacts, including: 

• Regulatory compliance costs, related to compliance with new environmental regulations. 
• Possible sanctions and legal liabilities in case of environmental violations or accidents. 
• Investments in mitigation technologies, which, although initially high, can generate operational savings in the long term. 
• Opportunities for funding and incentives through the adoption of sustainable solutions aligned with decarbonization targets. 
• Corporate reputation and market value, as environmental performance influences investor perception and competitiveness in the industry. 

Wolftank Group is developing financial analysis models to assess and quantify risks and opportunities related to pollution management, ensuring a data-driven approach that supports targeted mitigation strategies and informed decision-making. 

5.4.3 ESRS E4 – BIODIVERSITY – PHASE IN 

Although currently classified as a Phase-in topic under the gradual implementation of the ESRS framework, E4 – Biodiversity and Ecosystems represents an area of growing strategic relevance for Wolftank Group. Biodiversity is fundamentally linked to the balance of natural ecosystems, environmental resilience, and the long-term sustainability of industrial operations. During this transitional phase – where full reporting obligations are not yet in force – Wolftank Group has proactively decided to go beyond the Minimum Disclosure Requirements (MDR) and advance its reporting efforts. This approach reflects the company’s commitment to preparing responsibly and deliberately for the time when full disclosure will become mandatory.  

Our activities, processes and innovations are continuously designed to have a positive and beneficial impact on the environment. Measures are taken on a daily basis to mitigate potential negative impacts on the ecosystem and human well-being through actions that span the entire supply chain.

To this end, Wolftank Group presents not only the required indicators, but also additional data and assessments aimed at mapping the actual impacts of its business activities on biodiversity. These efforts support the identification of strategic opportunities and strengthen the Group’s capacity to contribute actively to ecosystem restoration and the protection of natural capital.  
This includes protecting ecosystems and biodiversity, minimizing negative impacts and promoting positive ones, such as restoring soil biodiversity through sustainable remediation techniques such as bioremediation.

Number of approved remediation projects	36
Remediation area (sqm)	578,513
Volumes of land disposed of in landfills (ton)	14,288
Volumes of soil reclaimed at treatment plant (ton)	57,480
Volumes of Fill Soil from MPS/End of Waste (ton)	0
Volume of water drawn from the aqueduct (m3)	1,070
Volumes of water treated on-site with P&T/other and discharged to the sewer (m3)	935,617
Volumes of pumped water discharged/discharged directly into the aquifer or onto soil or surface water from in-situ treatment systems (m3)	378,742
Total volumes of water pumped (ton)	1,340,205
Excavated soil volumes (ton)	71,768

5.4.3.1 Impacts 

Soil quality is improved through on-site treatments (directly in the soil), enabling the reuse of the land and enhancing the biodiversity conditions in the area. 

Wolftank Group company remediates contaminated soil by subjecting it to a microbiological bioremediation process. This way, contaminated areas can be restored through soil restoration, thereby improving their biodiversity conditions. 

5.4.3.2 Opportunities 

Increasingly strict regulatory requirements related to land use, soil sealing, and biodiversity, for which Wolftank Group’s services are required. This includes predictive measures for protection, such as the use of tanks to prevent environmental damage. 

Leveraging technological innovation to generate new ESG-related business opportunities – for example through the development of a digital twin of contaminated subsurface areas, which reduces the need for physical drilling and minimizes environmental disturbance. 

5.4.3.3 Impact materiality analysis for Biodiversity and Ecosystems  

The impact materiality analysis for ESRS E4 – Biodiversity and Ecosystems clearly underscores the pivotal role of Wolftank Group’s environmental recovery initiatives, particularly in the areas of soil remediation and treatment. These interventions serve as concrete responses to environmental degradation, making a meaningful contribution to biodiversity conservation and the regeneration of natural ecosystems. 

The company’s actions primarily target the restoration of soil quality, often impaired by legacy industrial activities. This leads to a positive and measurable environmental impact, not only by mitigating existing damage but also by laying the groundwork for the ecological revival of local habitats. In doing so, Wolftank Group actively supports the ecological resilience of the affected areas and advances the restoration of natural capital. 

Positive Impacts on Ecosystem Restoration 

The company’s contribution to ecosystem regeneration unfolds along two main strategic directions:  

1. Soil improvement through on-site treatment  

Direct land interventions aimed at restoring natural conditions: These efforts not only enable the reuse of remediated areas but also foster the return of native biodiversity. The practice has been evaluated with a score of 4 out of 5 on the impact scale, underscoring its effectiveness in contributing to environmental regeneration. However, the current scope of application remains primarily regional (score of 2), which limits the extent of the overall benefit at this stage. Nonetheless, the final aggregated score of 3.00 confirms that this activity constitutes a significant and material contribution within the company’s strategic sustainability framework. 

2. Soil remediation of contaminated land through off-site restoration. 

Application of bioremediation techniques for soil decontamination: The use of advanced bioremediation methods enables the restoration of previously polluted areas, enhancing soil quality and safeguarding adjacent ecosystems. Here too, the environmental impact is rated high (4 out of 5), with clearly visible and measurable outcomes. As with the previous initiative, however, the regional scale of implementation limits the breadth of benefits (scope rated 2), resulting in an overall impact score of 3.00. Despite these limitations, the initiative remains a material and strategically relevant component of Wolftank Group’s contribution to ecosystem regeneration. The set of activities analyzed in the impact assessment confirms that the topic of biodiversity and ecosystems is material for the company. It significantly influences environmental performance and represents a key element of the sustainability strategy. 

From a strategic standpoint, ecosystem restoration initiatives generate a range of positive outcomes for Wolftank Group. They enhance compliance with environmental regulations, thereby reducing the risk of sanctions and facilitating access to green financing instruments. At the same time, these efforts strengthen the company’s reputation among stakeholders, particularly those with a strong focus on ESG performance. Moreover, they open up new business opportunities by enabling collaborations with public and private entities engaged in environmental protection and ecosystem regeneration. To amplify the positive impact of its activities and strengthen its role as a responsible actor in environmental protection, Wolftank Group is intensifying its focus on expanding the scope of its remediation efforts.  

This strategic direction includes: 

• Adopting a broader, national-scale approach to remediation activities, extending beyond the current regional focus; 
• Enhancing stakeholder and investor engagement, particularly around ESG-driven initiatives and environmental performance; 
• Integrating advanced technological solutions to improve the efficiency, scalability, and replicability of remediation and treatment processes; 
• Developing strategic partnerships with both public and private entities to facilitate financing and co-design of regeneration interventions. 

These measures reflect the Group’s commitment to scaling its environmental contribution while aligning with long-term sustainability goals.  

5.4.3.4 Financial materiality analysis for Biodiversity and Ecosystems  

The analysis of the financial materiality related to topic ESRS E4 – Biodiversity and Ecosystems has highlighted two strategic directions that represent tangible development opportunities for Wolftank Group: on the one hand, the evolution of the environmental regulatory framework; on the other hand, the adoption of advanced technological solutions applied to sustainability. Both have been assessed as material, meaning they are capable of significantly influencing the company’s economic and financial prospects in the short, medium, and long term.  

One of the key opportunities for Wolftank Group lies in the progressive tightening of environmental regulations – particularly in the areas of waste management, land use, biodiversity protection, and soil sealing. This evolving regulatory landscape calls for increasingly sophisticated and preventive solutions – an area in which Wolftank Group has developed strong expertise, especially in tank safety and the prevention of environmental damage. The company’s proven capabilities position it well to meet future regulatory demands while creating value through compliance-driven innovation. The assessment of the financial impact associated with this opportunity indicates a positive growth trajectory: in the short term, the financial impact is limited (rated 2 out of 5), with a medium probability (40-60%) and a relevance index of 1.00; in the medium term (1-5 years), the impact becomes significant (4 out of 5), with a probability between 60% and 85%, leading to a rating of 2.90. In the long term (beyond 5 years), a maximum financial impact is estimated (5 out of 5) with a probability of above 85%, and a final rating of 4.625. 

This data suggests that, in the long term, increasing regulatory pressure will serve as a key strategic lever, driving the company to invest in advanced technologies and services that align with evolving environmental standards and market expectations. 

A second key opportunity lies in the use of technological innovation to develop high-value ESG solutions. A notable example is the creation of digital models that accurately represent contaminated subsurface environments. These tools significantly reduce the need for extensive geotechnical surveys and piezometers, while improving the efficiency of site characterization and subsequent remediation efforts. 

The financial impact analysis indicates a promising outlook: In the short term, the estimated impact is medium (3 out of 5) with a probability between 40% and 60%, resulting in a score of 1.50. In the medium and long term, the impact is expected to be high (4 out of 5) with a probability ranging from 60% to 85%, leading to a score of 2.90 for both timeframes. 

While this opportunity shows a slightly lower maximum financial impact compared to that of regulatory developments, it remains strategically significant – particularly if the company succeeds in effectively developing and commercializing advanced environmental technologies. This would not only reinforce Wolftank Group’s innovation leadership but also open new ESG-driven revenue streams.  

5.4.3.5 ESRS E4 MDR – PAT – Policies, Actions, Metrics, and Objectives related to Biodiversity and Ecosystems  

§ MDR-P, 65; § MDR-A, 68-69, § MDR-M, 75-77; § MDR-T, 80-81 

§ 13; § 23 – 24; § 28; § 32; § 35 – 38 

Although the remediation of contaminated sites and the management of waste for soil and water matrices are topics closely linked to E2 – Pollution, Wolftank Group’s approach allows for recognizing their direct impact on biodiversity and ecosystem regeneration. Environmental remediation activities and the treatment of soil and water not only mitigate existing forms of pollution but also restore contaminated lands to their original state, thus contributing to the conservation and restoration of natural habitats. 

In line with the requirements outlined by the MDR of ESRS E4, the company has established clear operational objectives, supported by specific actions and transparent measurement metrics. These actions, in addition to ensuring the sustainable management of soil and water resources, serve as strategic levers to promote environmental resilience and the continuous improvement of the Group’s ESG performance. 

Analyzing the Sustainability of Remediation Projects 

To assess the actual sustainability of environmental remediation projects, Wolftank Group has implemented a screening process during the design phase, which includes an estimate of CO₂ emissions and energy consumption (kWh) for each technology used. The goal is to provide comparative analyses to inform clients about the environmental impact of the various technological options available, raising their awareness of more environmentally responsible choices. 

Increase the share of land treated compared to that sent to landfill 

The second objective focuses on maximizing soil recovery by reducing reliance on landfill disposal. To achieve this, the company plans to increase the productivity of its recycling plants and invest in expanding treatment capacity at remediation sites. The effectiveness of this initiative is measured using a clear performance indicator: the total amount of soil remediated (in tons). 

Increase the share of water treated on-site compared to that transported for disposal 

Efficient water resource management is key element in the protection of ecosystems. In this context, Wolftank Group has implemented systematic monitoring of water consumption at its operational sites, with a particular focus on the ratio between water treated on-site and water transported off-site for disposal. This initiative pursues a dual strategic goal: on the one hand, to reduce CO₂ emissions associated with transportation of wastewater, and on the other hand, to promote a circular and localized approach to water treatment.  

In the coming years, Wolftank Group aims to strengthen its efforts across three key action areas: 

• The structural integration of technological and environmental sustainability analyses into the design of remediation projects. 
• The enhancement of soil treatment methods to increase the proportion of soil recovered versus that disposed of. 
• The strengthening of water monitoring systems to improve efficiency in water management and reduce the environmental footprint associated with wastewater transportation. 

These actions demonstrate the company’s tangible commitment to ecosystem regeneration, advancing a sustainable transition even within complex operational contexts such as environmental remediation. Furthermore, they establish a solid foundation for more comprehensive future reporting, in preparation for the transition of the E4 topic Phase-in to full disclosure status under the ESRS framework.  

5.4.4 ESRS E5 – CIRCULAR ECONOMY 

The circular economy is a strategic lever to drive the transition towards a sustainable development model that is efficient in its use of resources and resilient to market and environmental changes. For the Wolftank Group, integrating circularity principles is essential not only to reduce the Group’s own environmental impact, but also to strengthen its capacity for innovation and competitiveness, thereby contributing to long-term value creation for our customers.

In the context of the Group’s industrial activities – which include, among others, the sectors of industrial coatings, waste treatment for the production of secondary raw materials (end-of-waste), and environmental remediation – the adoption of circular practices reflects a concrete commitment to material reuse, waste reduction, and the optimisation of production cycles. This approach is becoming increasingly important within the European regulatory framework, which actively promotes the closing of production cycles and the valorization of secondary materials.

In light of the above, we report below the results of the dual materiality analysis, which examines both the impacts generated by the Group on the circular economy and the risks and opportunities that this area may generate on the organisation’s performance and economic-financial solidity.

5.4.4.1 Positive Impacts 

Saving resources by recycling and reselling oil. Contribution to resource conservation as less oil needs to be extracted. At the same time, CO₂ emissions and energy is saved. 

5.4.4.2 Risks 

Price increase for resources such as resin, which cannot be passed on to customers in the short term // shortage of resources. 

5.4.4.3 Materiality impact analysis for the Circular Economy 

The material impact analysis related to ESRS theme E5 – Circular Economy, highlighted the important role played by the recycling and resale of used oil in advancing more sustainable management of natural resources. This practice significantly contributes to reducing the exploitation of non-renewable resources and lowering climate-altering emissions, thereby positioning Wolftank Group as a key contributor to the transition toward a circular economy model. Through the recovery and regeneration of waste materials such as contaminated soil, water, and used oil Wolftank Group significantly reduces the need for raw material extraction, yielding clear benefits for both the environment and energy efficiency. By avoiding the production of new materials, this approach lowers energy consumption and effectively reduces associated CO₂ emissions, contributing to a more sustainable and resource-efficient industrial model. The treatment of waste to produce secondary raw materials or achieve end-of-waste status represents a high-impact environmental strategy, delivering measurable benefits for both the environment and the responsible management of natural resources. The effectiveness of this practice is supported by an environmental impact assessment, which confirms its value in terms of both scale and significance, highlighting its contribution to circularity, emissions reduction, and resource conservation.

• Effective and positive impact: the treatment and recovery system contribute to the conservation of natural resources by reducing reliance on virgin raw materials. 
• Impact scale: rated 4 out of 5, this score reflects the process’s strong potential to generate positive environmental outcomes and foster circular resource use. 
• Scope: estimated at 3 (medium range), indicating that while the effects are currently concentrated in specific geographical areas, there is clear potential for broader application and scalability. 
• Overall assessment: With a composite score of 3.50, this activity is considered highly material to the company’s sustainability strategy and long-term environmental objectives.

The decision to implement a circular economy model based on waste recycling represents a strategic lever for Wolftank Group, delivering benefits on both environmental and operational fronts. Beyond reducing pressure on natural resources, this approach also contributes to the reduction of climate-altering emissions, thereby supporting the company’s broader decarbonization objectives and enhancing long-term sustainability performance.

The valorization of waste for reuse further strengthens Wolftank Group’s positioning as a leader in sustainable waste management, contributing to enhanced ESG performance and improved compliance with environmental and social regulations. 

However, the current geographical scope of this practice remains limited, presenting a strategic opportunity for expansion at both national and international levels. Scaling up the model could significantly amplify the already observed benefits, making the company’s contribution even more impactful in the broader transition toward a climate-neutral and regenerative economy. 

5.4.4.4 Materiality financial analysis for the Circular Economy 

The financial materiality analysis conducted by the Group highlighted some critical issues related to the economic environment and the dynamics of raw material procurement. 

In particular, ESRS E5 – Circular Economy is significantly influenced by risks related to price volatility and the availability of essential resources, such as resin, which is widely used in the company’s production processes. If rising costs for these raw materials are not adequately reflected in final product pricing, this could negatively impact the company’s margins, placing pressure on both profitability and competitiveness within its target markets. Among the main risk factors identified were the rising prices of critical resources and the possibility of their structural shortage. In the short term, this scenario could lead to increased production costs and delivery delays. Even in the medium term, sustained high prices could jeopardize the Group’s competitiveness against competitors with greater resilience and a more elaborate supply chain diversification. In the long term, the risk is considered manageable, as it can be mitigated through alternative procurement strategies, the development of substitute materials, and the adoption of innovative solutions inspired by the principles of circularity. 

The probability of these risks materializing is estimated to be low (between 15% and 25%) across all time horizons considered. In the short term, the commodities market is already showing signs of volatility, but the impact is considered manageable. In the medium and long term, however, the trend appears uncertain but susceptible to stabilization, also thanks to the introduction of corrective measures by the Group. 

The overall significance of the risk is minimal across all time horizons, thanks to careful monitoring and the preparation of mitigation strategies. However, given the sensitivity of the supply chain and developments in the raw materials market, the issue has been assessed as material from a financial perspective, highlighting the strategic importance the Group places on proactive and sustainable resource management. 

5.4.4.5 ESRS E5 – MDR – PAT 

The analysis of the MDR (Mandatory Disclosure Requirements) related to ESRS E5 – Resource Use and Circular Economy provides an overview of the policies adopted to promote sustainable use of natural resources E5-1 (MDR-P), actions taken to prevent over-extraction of raw materials, encourage reduction, reuse, and recycling E5-2 (MDR-A), as well as concrete targets and metrics E2-3 (MDR-M, MDR-T) for the short, medium and long term related to circular economy and resource efficiency 

5.4.4.6 E5 MDR-P – E5-1 – Policies related to the Circular Economy 

§ MDR-P, 65 § 15 

Wolftank Group is implementing  a set of environmental and sustainability policies aimed at promoting the responsible and efficient use of natural resources by integrating circular economy principles into its operations and across the value chain. These policies are regularly communicated through the publication of the Sustainability Report, which also includes an analysis of relevant environmental risks, opportunities, and impacts. Their monitoring is overseen through the Group Sustainability Plan, which serves as the operational framework for implementation and periodic review. 

The policies apply to all Group employees, as well as partners in the value chain, both upstream (suppliers, subcontractors) and downstream (customers, industrial partners), and include clear expectations towards external parties involved in production or operational processes. Responsibility for implementing the policies rests with the Executive Board, the Boards of Directors of the subsidiaries, and the respective Heads of Functions across operational areas. 

As part of its policy implementation, Wolftank Group actively recognizes and integrates external standards and third-party initiatives, including specific requirements from industrial and institutional clients – particularly in the areas of environmental remediation, sustainable mobility, and energy infrastructure. 

Policies are developed with consideration for the interests of the main stakeholders, who are engaged through structured dialogue and communication processes. To ensure transparency and accessibility all policies are made publicly available on the Group’s website, allowing both stakeholders and implementation partners (e.g., suppliers and contractors) to consult them as needed. 

Wolftank Group is firmly committed to improving its environmental performance, by carefully managing its environmental impacts and promoting the transition from virgin to secondary (recycled) resources. This commitment is reflected in concrete actions such as: 

• Reducing the use of raw materials and energy. 
• Widespread adoption of recycling practices, both in offices and on construction sites. 
• Limiting plastic use. 
• Encouraging the use of materials from renewable sources. 
• Training employees on the environmental impact of their activities. 
• Collaborating with customers and stakeholders to promote virtuous environmental behavior. 

These commitments are formalized in the Wolftank Group Environmental Policy, which outlines strategic guidelines on sustainable procurement, stakeholder participation, and shared responsibility. 

5.4.4.7 E5 MDR-A – E5-2 – Circular Economy Actions and Resources 

§ MDR-A, 68-69; § 20 

Through its Sustainability Plan, Wolftank Group has outlined a series of operational and strategic actions aimed at promoting the circular economy and the efficient management of natural resources within its areas of activity. 

The planned actions are detailed in the Sustainability Plan and include: 

• Monitoring Biopile utilization times, with the aim of optimizing the rotation of treated materials in biological remediation processes. 
• Monitoring internal consumption, particularly related to water and energy, with the aim of reduction and optimization. 
• Installing separate waste bins in all offices, accompanied by an internal information campaign via the company intranet to promote waste separation and recycling among employees. 
• Monitoring the ratio of regenerated activated carbon to newly purchased virgin activated carbon with the aim of increasing the use of recycled materials in environmental remediation; 
• Monitoring the volumes of water treated on-site at reclamation sites versus the volumes of water to be disposed of off-site to improve efficiency and reduce environmental impact. 

The actions are structured across differentiated time horizons, based on their nature and complexity, and are developed and implemented over intervals of 1, 3 and 5 years, ensuring continuous and measurable improvement in the medium term. 

At present, no specific financial allocations (neither Capex nor Opex) are exclusively dedicated to these actions. However, their monitoring and implementation are embedded within the Group’s operational and organizational planning, and related expenditures are partially included in the general budget in an aggregated form. 

The detailed timeline of actions, along with their alignment with other environmental objectives, is outlined in the relevant section of the Group Sustainability Plan. 

Looking ahead, the company plans to introduce an internal system for tracking environmental KPIs, enabling structured and periodic reporting in future reporting cycles. 

5.4.4.8 E5 MDR-M – Metrics for Evaluation of the Circular Economy  

§ MDR-M, 75-77 

To effectively monitor its environmental performance and evaluate progress toward a more sustainable use of resources, Wolftank Group has identified a set of Key Performance Indicators (KPIs) aligned with the principles of the circular economy and efficient material management. These indicators form the backbone of the company’s reporting system, enabling a transparent assessment of environmental impacts and the effectiveness of actions taken. 

Wolftank Group is going to establish a set of baseline data to monitor and measure future progress in the area of waste circularity. These baselines will serve as the foundation for defining performance indicators and will enable the evaluation of the long-term effectiveness of implemented policies and actions. Among the key indicators, particular focus was placed on the office recycling rate, measured as the percentage of waste correctly sorted and sent for recycling. This metric reflects the Group’s commitment to fostering responsible behavior among employees, supported by specific measures such as the installation of separate waste bins and internal awareness campaigns. The initiative serves a dual purpose: 

• to reduce the Group’s internal environmental footprint, and 
• to strengthen a culture of sustainability across the organization. 

Another strategic area in which the Wolftank Group has developed performance indicators is the sustainable management of water resources, with particular focus to water treatment processes. The metrics adopted measure the ratio between the volume of water treated on site (on-site) and the volume of water transported and treated or disposed of externally at authorized facilities (off-site). 

This indicator enables the assessment of the efficiency and autonomy of treatment systems at various operational and reclamation sites, highlighting actions to reduce transport, associated emissions, and environmental costs. The objective is to progressively increase the share of on-site treatment, utilizing innovative technologies and plant solutions. 

As part of its environmental reclamation activities, Wolftank Group follows a circularity-oriented approach, with a focus on the use of regenerated materials. In this context, a dedicated KPI was introduced that measures the ratio of kilograms of purchased regenerated activated carbon to kilograms of virgin activated carbon. This indicator directly reflects the extent to which traditional raw materials are replaced by circular alternatives, contributing to the reduction of the environmental footprint of the treatments. 

In parallel, the on-site versus off-site water treatment ratio is continuously monitored.  Both indicators are essential for evaluating the operational effectiveness of remediation projects and for gauging the Group’s progress in managing processes more sustainably and efficiently.  

5.4.4.9 E5 MDR-T – E5-3 – Circular Economy Targets 

§ MDR-T, 80-81; § 24, 25 e 27 

Wolftank Group has defined a set of environmental objectives within its Sustainability Plan, with a focus on optimizing resource use, improving waste management, and promoting circular economy principles across its industrial operations. Particular attention is given to contaminated site remediation, plant management, and the efficient  handling of water flows. The main operational objectives outlined in the plan include: 

• Increasing the turnover of treated material in their plants, reducing dwell time, and maximizing material recovery. 
• Increasing the share of treated water compared to that designated for disposal. 
• Promoting recycling in offices by improving internal practices and raising employee awareness. 
• Strengthening circular economy activities in environmental remediation projects, aiming to return value to extracted or treated materials, especially waste oil and contaminated soil. 

These targets are directly linked to increasing the rate of circular material utilization, with a particular focus on the recovery rate of waste relative to the total volume managed. They also aim to reduce the use of virgin raw materials by minimizing the reliance  on new resources and promoting  the reuse and valorization of existing materials. 

The targets defined by Wolftank Group are embedded in its waste management strategy, especially concerning the recovery and treatment of oils and soils from contaminated sites. In this context, the Group’s activities are designed to reintegrate these materials into the production cycle as secondary raw materials, or to qualify them under ‘end-of-waste’ criteria, in compliance with applicable environmental quality standards and regulatory frameworks. 

These objectives are aligned with the upper levels of the European waste hierarchy, as they prioritize resource recovery over disposal. Their implementation is supported by investments in technological innovation, particularly in advanced treatment processes. 

Although a group-wide ecological threshold has not yet been formalized, all reclamation and waste treatment activities are subject to national and international regulatory limits, which act as operational thresholds for qualifying materials as Secondary Raw Materials/End of Waste. 

Responsibility for achieving these targets lies with the relevant technical and operational departments, in coordination with the Sustainability Department and management, who continuously monitor progress through quality control systems, internal reporting mechanisms, and audits. 

5.4.4.10 E5-4 – Resource Inflows 

§ 30, 31, 32 e 25 

Inflows of resources are disclosed through the Sustainability Report and the Sustainability Plan, with time horizons covering the short, medium, and long term. 

For each reporting period, the total weight of waste handled is recorded.

In the context of the circular economy, particular attention is given to the Secondary Raw Material (SRM) or End of Waste generated by waste treatment platforms. The Group measures both the absolute weight and their percentage share relative to the total volume of waste processed.

Data is collected and processed through Waste Management Systems, ensuring traceability and consistency of the monitored material flows. To ensure the accuracy of the results and prevent double counting, the data is verified by cross-referencing multiple sources and collection methods. This control process allows the reported values to be validated, and ensures that the underlying assumptions are transparently and robustly documented. 

5.4.4.11 E5-5 – Resource outflows 

§ 35, 36, 40, 37, 38 39 e 40 

Table E5-5 3

(in kg)	Offices	Operation	Total
Total waste generated	11,908	260,219,240	260,231,148
Hazardous waste	10	53,577,675	53,577,685
Hazardous waste prepared for reuse	0	0	0
Hazardous waste recycled	5	7,822,090	7,822,095
Hazardous waste which followed another recovery operation	0	31,753,636	31,753,636
Hazardous waste incinerated	0	1,013,058	1,013,058
Hazardous waste to landfills	0	7,838,704	7,838,704
Hazardous waste to other disposal operations	5	5,150,187	5,150,192
Non-hazardous waste	11,898	206,641,565	206,653,463
Non-hazardous waste prepared for reuse	5,500	10,647,882	10,653,382
Non-hazardous waste recycled	5,168	6,989,500	6,994,668
Non-hazardous waste which followed another recovery operation	50	126,033,253	126,033,303
Non-hazardous waste incinerated	281	130	411
Non-hazardous waste to landfills	0	45,973,800	45,973,800
Non-hazardous waste to other disposal operations	900	16,997,000	16,997,900

In addition to incoming flows, Wolftank Group also monitors outgoing flows resulting from its operational and production activities, with particular focus to the waste generated and its final destination. Information is collected, processed, and aggregated through an internal management system, ensuring traceability and data verification in accordance with applicable regulations. 

The total amount of waste produced is expressed in mass and final destination (e.g., recovery, disposal, incineration, etc.). 

The data is shown in Table E5-5-3 and allows the monitoring of performance in waste management and highlighting actions to be taken to reduce disposal and increase recovery. 

Information on the composition of waste and waste streams relevant to the sector is mainly derived from the environmental authorizations (AIA) of the waste platforms used by the Group and from MUD (Modello Unico di Dichiarazione ambientale – Single Environmental Declaration Form) records. The classification is also supported by waste data sheets and the relevant EWC codes. 

5.4.4.12 E5-6 – Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities 

§ 43 

Wolftank Group analyzes and communicates the financial effects potentially arising from material risks and opportunities related to the use of natural resources and impacts associated with the circular economy, both in quantitative and qualitative terms. 

This information is collected and presented in the Sustainability Report and the financial materiality analysis, which are the main tools for transparency and assessment of the environmental impacts on the business model. 

The risk categories associated to resource scarcity, waste management, and the transition to a circular economy are thoroughly assessed, alongside the opportunities arising from the adoption of low-impact technologies and the improvement of material efficiency. The analysis also highlights the main assumptions used to estimate financial impacts including factors such as evolving environmental regulations, raw material price volatility, and green market trends. This approach enables the Group to anticipate potential economic impacts, manage environmental risks with greater awareness and strategically steer future investments toward circular, resource-efficient solutions. 

5.4.5 ESRS S1 – OWN WORKFORCE – Phase in

Although the ESRS S1 – Own Workforce standard includes a “phase-in” mechanism that allows for the gradual application of reporting obligations, Wolftank Group has adopted a proactive approach by going beyond the minimum mandatory disclosure requirements (MDR). In line with our commitment to transparency and continuous improvement, we have voluntarily included additional qualitative and quantitative information on material workforce-related topics, such as training, organizational well-being, occupational health and safety, inclusion and equal opportunities policies. 

5.4.5.1 Negative Impacts 

• Damage to workers’ health, including serious or fatal injuries, due to accidents at work sites. The risks to workers’ health and safety are very high (e.g., risk of explosion). 

5.4.5.2 Risks 

• A serious accident could cause Wolftank Group to lose orders and significantly damage its reputation. 
• The competitiveness of the labor market presents a risk of losing skilled employees. In addition, there is a risk of losing know-how, as experienced staff members retire, and the transfer of knowledge to younger generation may not occur quickly or effectively enough. 
• Lack of qualified/needed labor and consequent increase in wage costs. Training of in-house personnel requires time and financial resources. Any delays in project management could result in penalties. 
• Potential risk of criminal and financial penalties for non-compliance with mandatory health and safety regulations. 

5.4.5.3 Opportunities 

• Adhering to a zero-harm policy and providing continuous safety training and awareness programs can enhance Wolftank Group’s reputation as a reliable and responsible business partner, making the company an attractive choice for clients and collaborators who prioritize occupational health and safety.  

5.4.5.4 Materiality impact analysis for Own Workforce (S1) 

The topic ESRS S1 – Own Workforce holds strategic importance for Wolftank Group, as it encompasses the protection of employee health and safety both at operational sites and within company facilities. In environments characterized by high-risk industrial activities, as is the case in Wolftank Group’s operations, the potential for accidents – including serious or fatal incidents – remains a key area of concern. Particularly, the presence of hazards such as explosion risks demands continuous vigilance and a strong focus on prevention and protection measures, positioning safety as a fundamental pillar of the company’s governance and operational framework. 

The analysis focuses on three fundamental dimensions: 

• Severity and likelihood of risks to workers. 
• Scope and extent of the impact generated. 
• Overall materiality assessment. 

Specific Impact: Health and Safety at Operational Sites 

Accidents on construction and remediation sites can result in serious or even fatal consequences for workers, endangering  their physical and psychological well-being. Due to the hazardous nature of the activities performed, the risk is considered extremely high, with a rating of 5 (absolute) on the risk scale. The likelihood of serious events occurring is real and requires continuous supervision through the implementation of effective preventive measures. 

From the perspective of the scope of impact, the issue primarily concerns workers directly employed at production sites, with no significant effects on external communities or other stakeholder groups. 

By combining the risk levels and the extent of the impact, the overall rating is significant (3.67). This value confirms the materiality of the issue in the ESG context, indicating occupational safety as one of Wolftank Group’s management and strategic priorities. 

Protecting the workforce is not only a regulatory or ethical obligation, but also a key factor in setting internal policies and maintaining the long-term sustainability of business operations. 

5.4.5.5 Materiality financial analysis for Own Workforce (S1) 

The management of the company’s own workforce is a central pillar of corporate strategy, as it is directly linked to operational safety, the availability of qualified personnel, and compliance with health and safety regulations. The analysis of financial materiality highlights tangible risks that can significantly affect the company’s profitability, operational efficiency, and reputation. At the same time, it identifies strategic opportunities that have the potential to enhance competitiveness and long-term financial resilience. 

Risk: Accidents at Work and Company Reputation 

The financial impact of a potential occupational accident is considered high across all time horizons – short, medium, and long term – with consequences that could include increased insurance premiums, the need for corrective investments, and the competitive positioning of the company. Although the probability of occurrence is estimated to be very low, it is important to realistically assess this risk, as the severity of the potential consequences is significant. For this reason, the risk is classified as material, with direct implications for both corporate reputation and operating costs. 

Opportunities: Zero Damage Policy and Continuous Training 

Investment in a safety-oriented corporate culture, supported by ongoing training programs, is a strategic lever capable of generating tangible returns. In fact, these initiatives not only help prevent workplace accidents, but also strengthen the image and reliability of the Wolftank brand. 

The financial impact of these actions is expected to be significant in the short and medium term due to the immediate benefits in terms of reputation and the reduction of potential liabilities related to accidents. The probability of achieving these results is very high – between 85% and 100% – in the short and medium term, and remains high in the long term, with an estimated likelihood of 60% to 85%. Given these projections, the topic is considered material, as it significantly contributes to operational stability and brand enhancement. The proactive adoption of preventive measures, therefore, not only protects personnel but also represents a distinctive and competitive advantage that can increase the company’s attractiveness to partners and investors. 

Risk: Labor Shortage and Loss of Know-How 

In an increasingly dynamic and competitive labor market, retaining qualified staff presents a real challenge for Wolftank Group. In fact, the loss of key skills, matured over time within the organization, can compromise operational efficiency and slow technological progress and innovation. From a financial perspective, the impact of this risk is estimated to be moderate in the short to medium term, as it entails additional costs related to recruitment, training, and the need to transfer knowledge. However, in the long term, the impact can be reduced to a low level through the introduction of structured knowledge transfer and internal professional development programs. The probability of this risk materializing is high, between 60% and 85% in the short and medium term, while it tends to decrease in the long run, with an estimated 15% to 40%. The risk is therefore considered material, due to its direct impact on productivity and business continuity. In this context, human capital management is seen as a real strategic investment, essential to ensure the company’s sustainability and competitiveness over time. 

Risk: Increased Salary Costs and Project Delays 

The increasing difficulty in finding skilled labor results in significant wage pressure and poses a real risk of delays in project execution. This directly affects business continuity and delivery timelines, increasing the complexity of managing business activities. The financial impact of this risk is considered high in the short and medium term due to rising personnel costs and the need for urgent measures to attract and retain qualified resources. In the long term, the impact is expected to decrease to a moderate level, provided that structured and sustainable policies are implemented to stabilize human capital.  

The probability of this scenario materializing is high, between 60% and 85% in the short to medium term, confirming a trend already underway in the sector. In the long term, this probability decreases to a moderate level (between 40% and 60%), depending on the effectiveness of the strategies adopted. This risk is therefore considered material, as it directly affects both the company’s financial performance and operational efficiency. The management of labor costs, combined with the enhancement of human resources, becomes a central factor in ensuring competitiveness and meeting project deadlines. 

Risk: Non-Compliance with Health and Safety Regulations 

Non-compliance with occupational health and safety regulations represents a significant risk for Wolftank Group, with potential consequences including both criminal and administrative sanctions, as well as damage to the company’s reputation. An incident of non-compliance can in fact trigger inspections, operational shutdowns and a loss of trust from customers and stakeholders. 

The financial impact associated with this risk is rated high across all time horizons, given the substantial and long-lasting economic, legal, and reputational implications. The probability of occurrence is also high – between 60% and 85% – due to increasing regulatory rigor and intensified controls in high-risk industries. As a result, the risk is classified as material, as it can significantly compromise economic stability and corporate image. Maintaining a high level of compliance is not only a regulatory obligation but an essential component in ensuring a safe, stable working environment aligned with the standards expected by both market and society. 

The financial materiality analysis of ESRS Theme S1 confirms that workforce management is a key factor for the economic sustainability of the Wolftank Group. Both risks and opportunities related to safety, skills availability, and regulatory compliance have a tangible impact on costs, reputation, and operational performance. Addressing these aspects means strengthening corporate resilience and consolidating Wolftank Group’s position in the industrial and environmental market. 

5.4.5.6 ESRS S1 MDR – PAT 

The analysis of the Mandatory Disclosure Requirements (MDR) related to ESRS S1 – Own Workforce provides an integrated view of the policies, practices, actions and monitoring tools adopted by the Wolftank Group to ensure the protection, development and well-being of its employees. This section outlines how the company addresses material impacts, risks and opportunities related to its own workforce through structured governance, active engagement, and measurable targets. 

The MDR table for ESRS S1 is structured into several core categories, including policy frameworks, stakeholder engagement mechanisms, remediation processes, mitigation measures, and performance indicators. Together, they offer transparency on how the company upholds social responsibility principles and aligns human capital management with its long-term sustainability strategy. 

The objective of these disclosure requirements is to give a complete and consistent picture of how the company ensures decent work, inclusiveness, safety and equal opportunities for all workers, while actively managing critical risks such as workplace accidents, labor shortages, and non-compliance with labor rights. 

5.4.5.7 MDR–P – S1-1 – Policies related to own workforce 

§ MDR-P; § 19, 20,21,22,23,24 

Wolftank Group has defined and implemented a set of policies and practices for the responsible management of its workforce, in line with the United Nations Guiding Principles on Business and Human Rights and the core of the international treaties promoted by the International Labour Organisation (ILO) conventions.  

In particular, the company is committed to ensuring: 

• A safe working environment, supported by a robust Health, Safety, and Environmental (HSE) management system and a specific Occupational Risk Prevention Policy; 
• Equal treatment and inclusion, as expressed in our Equal Opportunities and Diversity Policy; 
• The protection of human rights and the prevention of any form of discrimination, coercion, or exploitation, in line with our Human Rights Policy; 
• Promoting diversity and combating all forms of violence or harassment in the workplace; 
• Ethical conduct towards non-employee workers, as stipulated in the Code of Conduct for Suppliers. 

These policies are integrated into HR processes and monitoring mechanisms to ensure consistency with corporate values and regulatory compliance. 

5.4.5.8 MDR–A – S1-2 – Processes for engaging with own workers and workers’ representatives about impacts 

§ 27, 28 

Wolftank Group fosters an open and ongoing dialogue with its employees and their representatives, promoting collective bargaining and active participation in decisions that affect them. Company committees and formal consultation mechanisms are in place to discuss issues such as workplace safety, continuous training, and work-life balance. The company organizes regular meetings with workers’ representatives and promotes information initiatives to ensure transparency and participation. 

5.4.5.9 MDR–A – S1-3 – Processes to remediate negative impacts and channels for own workers to raise concerns 

§ 32,33. 34 

Wolftank Group has established dedicated internal channels to enable employees to report any critical issues, violations, or concerns in a confidential and secure manner. These tools include: 

• An internal whistleblowing mechanism managed in accordance with recognized best practices for the protection of whistleblowers. 
• The option to report concerns through trade union representatives. 
• A structured grievance process, which includes issue analysis, formal response procedures, and monitoring of corrective actions. 

The company policies explicitly prohibit any form of retaliation and are designed to foster a culture of openness, trust, and continuous improvement. 

5.4.5.10 MDR–A – S1-4 – Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions 

§ MDR-A; § 38, 39, 40, 41, 43 

Wolftank Group addresses material risks related to the workforce – such as accidents, loss of know-how, and regulatory non-compliance – through targeted actions, including: 

• The adoption of a ‘Zero Damage’ policy. 
• The implementation of security training courses. 
• The introduction of benefits, flexible working hours and support for family-work reconciliation. 
• Investments in digitalization of HSE management. 

To assess the effectiveness of these measures, the company uses specific KPIs and conducts periodic reviews of the results achieved, with the objective of driving continuous improvement. 

5.4.5.11 MDR-T –  S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities 

§ MDR-M; § MDR-T; § 47 

Wolftank Group has developed a detailed operational plan, which translates into concrete objectives, targeted actions, and measurable metrics to promote workforce well-being and reduce negative impacts. This approach is closely linked to the Group’s sustainability strategy and addresses environmental, social, and governance issues, with a particular focus on the S1 dimension. 

Key objectives include reducing pollution related to corporate mobility through the adoption of car sharing, carpooling, and remote work policies. Progress is monitored using indicators such as kilometers traveled per employee and the use of low-CO₂-impact vehicles. 

In the area of training, Wolftank Group is committed to strengthening internal competencies through targeted programs on both technical and administrative topics. Initiatives include courses for the tender office, the establishment of an internal technical academy, and the integration of e-learning platforms. The effectiveness of these efforts is tracked by monitoring training hours and participation in growth programs. 

The company has also embedded ethical and value-based principles into its onboarding process by integrating ESG policies into the induction phase. This aims to standardize organizational culture across the entire Group. 

To enhance quality of working life, Wolftank Group has introduced additional welfare incentives, aligned with the welfare policies of its individual subsidiaries. The utilization rate of these programs serves as an indicator of employee engagement and program success. 

Another strategic focus is the development and retention of talent, which is supported by competence mapping, structured training plans, and collaborative career development pathways. Participation is tracked using KPIs such as the number of training hours per employee per year. 

Wolftank Group has set a clear objective to increase diversity in management supported by the structured analysis of gender composition and other key diversity dimensions, including age, nationality, and disability status. An additional goal is to obtain gender equality certification. 

In the area Health, Safety, Environment, and Quality (HSEQ), the company actively promotes the ‘Zero Harm’ objective by monitoring workplace accidents, near misses, and safety training hours. To reinforce  HSE governance, regular review meetings are held at least four times per year, and a dedicated internal HSE committee is tasked with analyzing safety performance and defining corrective actions. 

5.4.5.12 S1-6 – Characteristics of the undertaking’s employees 

§ 50, 51 

	2024				2023
	Male	Female	Total	Male	Female	Divers	Total
Number of employees as of 31.12.	327	126	453	325	118	0	443
Average number of employees during the year	326	122	448	266	95.5	0	361.5
Number of permanent employees as of 31.12.	291	113	404	291	110	0	401
Average number of permanent employees during the year	291	111.5	402.5	241.5	90	0	331.5
Number of temporary employees as of 31.12.	36	13	49	34	8	0	42
Average number of temporary employees during the year	35	10.5	45.5	24.5	5.5	0	30
Number of full-time employees by head count as of 31.12.	318	86	404	314	86	0	400
Average number of full-time employees by head count during the year	316	86	402	255.5	70.5	0	326
Number of part-time employees by head count as of 31.12.	9	40	49	22	21	0	43
Average number of part-time employees by head count during the year	15.5	30.5	46	16	19.5	0	35.5
Number of employees with disabilities	13	7	20	12	4	0	16

Table S1, 6-2, 6-3, 6-4, 6-5, 6-6.

Employees per region	DACH	Italy	International**	Total
Number of employees as of 31.12.2024	23	417	13	453
Number of permanent employees as of 31.12.2024	23	368	13	404
Number of temporary employees as of 31.12.2024	0	49	0	49
Number of full-time employees by head count as of 31.12.2024	15	377	12	404
Number of part-time employees by head count as of 31.12.2024	8	40	1	49

**International = Brasil, China, Spain, USA

Table S1, 9-1.

Distribution of employees by personnel group
White collar including managerial & expert and executive	70%
Blue collar	30%

Wolftank Group employs 453 employees in 7 countries, with a high proportion of technicians and operational specialists. The male-female ratio shows a male dominance, which is typical in the industries we serve. 

However, the company is committed to improving gender equality, including through access to leadership and technical roles for women. 

5.4.5.13 S1-7 – Characteristics of non-employee workers in the undertaking’s own workforce 

§ 55, 57 

Non-employee workers (e.g., consultants and contractors) perform essential but non-continuous activities, mainly related to maintenance and engineering. The company ensures their safety and respects their rights through the Code of Conduct for Contractors and contracts that comply with European standards. 

5.4.5.14 S1-8 – Collective bargaining coverage and social dialogue 

§ 60, 63 

The vast majority of our employees are covered by collective labor agreement coverage. In some companies, there is a constructive social dialogue with workers unions.

5.4.5.15 S1-9 – Diversity metrics 

§ 66 

Table S1, 9-2.

Distribution of employees by age group as of 31.12.2024
< 30 years old	7.50%
30 – 50 years old	58%
> 50 years old	34.50%

Gender distribution at the top management level:
male	86%
female	14%

5.4.5.16 S1-10 – Adequate wages 

§ 69, 70 

All employees are paid an adequate wage, in line with applicable benchmarks.

5.4.5.17 S1-11 – Social protection 

§ 74, 75 

The vast majority of our employees are covered by social protection, through public programs or through benefits offered by the undertaking, against loss of income due to any of the following major life events: sickness, unemployment starting from when the own worker is working for the undertaking, employment injury and acquired disability, parental leave, and retirement.

5.4.5.18 S1-12– Persons with disabilities 

§ 79 

Table S1, 12-1.

Total number of employees with a disability	2024				2023
	Male	Female	Divers	Total	Male	Female	Divers	Total
Number of employees with disabilities	13	7	0	20	12	4	0	16

5.4.5.19 S-13 – Training and skills development metrics 

§ 83 

Table S1, 13.

Average hours of training that the organization’s employees have undertaken:

13.5 hrs

5.4.5.20 S1-14 – Health and safety metrics 

§ 88 

Table S1, 14.

Total number of fatalities as a result of work-related injuries in the own workforce	0
Total number of fatalities as a result of work-related ill health in the own workforce	0
Total number of fatalities as a result of work-related injuries for other workers working on undertaking’s sites	0
Total number of fatalities as a result of work-related ill health for other workers working on undertaking’s sites	0
Total number of recordable work-related accidents in the own workforce	2
Number of days lost to work-related injuries and fatalities related to non-employees	18
Number of days lost to work-related ill health and fatalities from ill health related to non-employees	0

Wolftank Group closely monitors HSE indicators, including: 

• Injury and serious accident rate. 
• Number of fatalities (reduced to zero in the last three years). 
• Lost workdays due to accidents. 
• Number of completed safety audits. 
  

These metrics are collected according to recognized standards (e.g. ISO 45001) and reported in the annual report. 

5.4.5.21 S1-15 – Work-life balance metrics 

Table S1, 15.

Number of entitled employees that took familiy-related leave
male	18
female	18

5.4.5.23 S1-17 – Incidents, complaints and severe human rights impacts 

During the reporting period, Wolftank Group did not record any significant incidents or serious impacts related to human rights. No complaints were filed by employees.

The company maintains a proactive approach to prevention, which includes: 

• A reporting system accessible to all employees, 
• Continuous monitoring of working conditions, and 
• Training programs on ethical conduct and compliance-related topics. 

These measures reflect Wolftank Group’s ongoing commitment to respecting and promoting human rights across all areas of its operations. 

5.4.6 ESRS S2 – WORKERS IN THE VALUE CHAIN – PHASE IN 

Although the full reporting requirement for topic S2 – Value Chain Workers is subject to a transition period (phase-in), Wolftank Group has chosen to partially anticipate the implementation of the standard. In addition to the disclosure required under MDR – PAT, the company has included additional  relevant elements in narrative and qualitative form, with the goal of enabling a gradual and robust integration of the reporting framework in line with ESRS requirements. 

5.4.6.1 Negative Impacts 

The health and safety risks for value chain workers are considered very high, particularly on operational sites where hazardous activities are carried out. This includes potential risks of serious incidents, such as explosions, which could result in significant harm to suppliers’ personnel and raise liability and reputational concerns for the company. 

5.4.6.2 Risks 

A serious incident in the value chain could lead to Wolftank Group being held liable, resulting in loss of orders and significant damage to its reputation. A serious incident involving a supplier or subcontractor – particularly one related to health, safety, or human rights violations – could result in Wolftank Group being held liable, either legally or in the eyes of stakeholders. Such an event could lead to loss of customer trust, cancellation of orders, and significant reputational damage, with direct implications for the company’s market position and financial performance. 

5.4.6.3 Impact materiality analysis for Workers in the Value Chain 

The topic S2 – Workers in the Value Chain – is of particular relevance for Wolftank Group, as it is closely linked to the working conditions of suppliers, with a specific focus on health and safety risks at construction and remediation sites. These operational environments are, by their very nature, high-risk and may be the scene of serious or even fatal accidents, which can affect not only the health and well-being of workers, but also have direct implications for the company’s reputation and social responsibility.  For this reason, the active and systemic management of these risks is essential to ensure compliance with safety standards and to promote an ethical, responsible, and sustainable supply chain. 

The analysis of the impact materiality was structured around three main dimensions: 

1. The severity of the risk to suppliers’ workers, 
2. The scope and extent of the impact, and 
3. The overall assessment of  materiality. 

The risk under consideration refers to the direct consequences of potential accidents occurring at construction or remediation sites, where supplier personnel are actively involved. Such incidents may result in serious injuries or worse, with significant repercussions for the affected individuals, as well as legal liabilities and reputational damage for Wolftank Group. 

The risk scale was rated at the highest level (5 – absolute), confirming the high level of hazard associated with activities carried out on construction sites. The risk encompasses serious accidents, including fatal events, resulting from factors such as exposure to hazardous substances, risk of explosion, or structural collapse. 

In contrast, the scope of impact was classified as limited (1 – local scale), as it is restricted suppliers’ workers and does not extend to external communities. Therefore, this is a specific operational risk, rather than a systemic territorial risk. 

The overall average impact assessment score was 3.33, indicating a significant level of risk. While  the effect is confined to a specific segment of the value chain, its severity for the individuals involved and the potential for broader consequences – if not properly managed – underscore its relevance. 

As a result, the impact is classified as material, taking into account both the potential severity of incidents and the economic, legal, and reputational consequences that may follow. 

Accordingly, workplace safety across the supply chain is confirmed as a material issue for Wolftank Group. Key strategic priorities include: 

• Improving preventive practices, 
• Enhancing targeted training for supplier personnel, and 
• Ongoing monitoring of compliance with safety standards at external worksites. 

In particular, the adoption of regular audits and the reinforcement of preventive control measures are considered effective tools to mitigate risk and ensure full compliance with applicable occupational health and safety regulations. 

5.4.6.4 Financial materiality analysis for Value Chain Workers 

The topic S2 – Workers in the Value Chain – is also of strategic financial importance for the Wolftank Group, as it is closely linked to working conditions and risks arising from the sustainability practices adopted by suppliers and business partners. Failure to comply with social and ethical standards along the supply chain can result in significant economic, operational, and reputational consequences, impacting business continuity and stakeholder trust. 

The analysis identified two main risk areas that, although characterized by a low probability of occurrence, could have potentially significant impacts: on the one hand, serious accidents within the value chain; on the other hand, potential exposure to non-compliant labor practices, such as child labor or conditions contrary to ESG standards. 

A serious workplace accident at a supplier could expose Wolftank to direct risks, both in terms of reputational liability and business continuity. While such events are rare, they could lead to financial compensation, legal disputes, and loss of customer confidence, with tangible consequences for the company’s financial stability. 

The financial impact was classified as high across all time horizons: 

• In the short term, Wolftank Group could face lawsuits, claims, and the loss of orders, leading to immediate cash flow impacts. 
• In the medium term, the company would be forced to review its supplier selection criteria, which could affect operational and organizational processes. 
• In the long term, reputational damage could result in the loss of strategic partnerships and reduced market attractiveness. 

Although the probability of occurrence is estimated to be very low (1-15%) across all periods, the risk is non-negligible. The controls currently in place help limit exposure, but do not fully eliminate it, requiring constant reinforcement of preventive strategies and surveillance mechanisms to ensure uniformity of security standards in the supply chain. 

Given these considerations, the risk was classified as material due to its potential to generate significant economic and reputational impacts. 

Another identified risk area concerns the potential presence of non-compliant labor practices within the supply chain, including child labor or non-compliance with minimum ESG standards. Although the exposure to this risk is low, its management is crucial to protect the brand’s ethical integrity and maintain the trust of partners and stakeholders. 

The financial impact was assessed as minimal across all time horizons: 

• In the short term, the strict selection of suppliers reduces the immediate risk, though it does not eliminate it entirely. 
• In the medium term, supervision of working conditions and adherence to ESG principles help to maintain low operational risk. 
• In the long term, the implementation of effective due diligence strategies, combined with continuous monitoring programs, ensures stable and proactive control. 

The probability of occurrence, consistent with the impact, was also estimated to be very low (1-15%), due to the effectiveness of company policies, audit systems and training activities aimed at the supply chain. 

The analysis showed that, although the likelihood is low, the risk of serious incidents in the supply chain is material for Wolftank Group. The potential economic and reputational repercussions require a structured and proactive approach to ensuring supplier compliance, as well as maintaining high standards of safety and working conditions. 

5.4.6.5 ESRS S2 – MDR – PAT – Policies, Action, Targets related to value chain workers 

§ MDR-P ; § MDR-A ; § MDR-M ; § MDR-T 

§ 17-19; § 32 – 38; § 42 

Wolftank Group has adopted a systemic approach to ensure the protection of workers across the entire value chain, integrating principles of social responsibility, respect for human rights, and the safeguarding of working conditions. The policies in place are based on key corporate policies such as the Supplier Code of Conduct, the Human Rights Policy, the Health and Safety Policy, and the company’s HSEQ standards. 

These regulatory instruments set strict criteria for business partners, requiring them to align their behavior with the Group’s ethical and sustainability values. Suppliers must respect workers’ fundamental rights, guarantee safe and healthy working environments, and adhere to principles of transparency, inclusion, and non-discrimination. 

At the operational level, Wolftank Group implemented a coordinated set of initiatives to bring its commitments into practice. Among these, the launch of a digital portal for ESG monitoring of suppliers is a strategic step to ensure supply chain traceability and quality. At the same time, a supplier qualification program was launched, which includes assessments of ESG performance, technical requirements, administrative aspects, and HSEQ criteria, with the aim of gradually extending it to all Group companies. 

Specific attention was also given to assessing the financial stability of key suppliers, establishing centralized HSEQ services to conduct safety audits of field activities, and directly engaging suppliers in stakeholder dialogue processes, thus enhancing transparency and cooperation throughout the value chain. 

To monitor the effectiveness of the actions taken, the Group has defined a set of key performance indicators (KPIs) that include: 

• The percentage of suppliers monitored through the ESG portal. 
• The number of Group companies that have activated the supplier qualification program. 
• The number of suppliers assessed for financial stability. 
• The number of suppliers involved in stakeholder engagement processes. 
• The number of shared HSEQ inspection visits. 

These metrics enable a quantitative and transparent assessment of progress over time, fostering continuous improvement in risk management and sustainability across the supply chain. 

Wolftank Group has established a structured roadmap for achieving its supply chain-related ESG targets, extending through 2031. 

By 2026, the company plans to: 

• Implement further formal policies and procedures within its Italian subsidiaries, 
• Utilize the ESG portal for supplier monitoring and assessment, 
• Define a minimum number of annual supplier audits, and 
• Achieve a 10% increase in the number of suppliers engaged in stakeholder dialogue, using 2024 as the baseline. 

During the 2027–2029 period, the objectives include: 

• Extending the implementation of procedures to all Group companies, 
• Setting performance improvement targets across all ESG areas, and 
• Expanding supplier participation in stakeholder engagement processes by an additional 30% per category. 

Between 2030 and 2031, the focus will shift to: 

• Consolidating all implemented measures, 
• Achieving an overall 50% increase in the number of suppliers involved in dialogue, feedback, and continuous improvement processes, and 
• Reviewing and strengthening both qualitative and quantitative targets to support the development of a responsible and resilient supply chain aligned with the company’s long-term ESG objectives. 

5.4.7 ESRS S3 – COMMUNITIES AFFECTED – phase in

As with other topics subject to a transition period (phase-in), Wolftank Group has chosen not to limit its efforts to the minimum requirements for ESRS S3 – Affected Communities. Instead, the company has adopted a progressive and forward-looking approach to the application of the standard, starting already in the current reporting period. Although full disclosure is not yet mandatory, Wolftank Group has voluntarily included an initial qualitative and narrative overview of its existing policies, processes, and actions, in line with the Minimum Disclosure Requirement – Policies, Actions, and Targets (MDR – PAT). This voluntary approach demonstrates the Group’s early-stage commitment to building a robust and ESRS-consistent reporting system, and to strengthening its accountability and engagement with affected communities. 

5.4.7.1 Negative Impacts 

• Damage to the health of people in the vicinity of work sites in the event of accidents, including the risk of explosion. 
• Leakage of confidential customer information due to cyber risks could lead to public controversy, stakeholder unrest, and reputational damage. 

5.4.7.2 Risks 

• A serious accident affecting people in the immediate vicinity could lead to Wolftank Group losing orders and seriously damaging its reputation. 

5.4.7.3 Opportunities 

• Acceptance of company sites and operations by local communities contributes to a positive image, enhances attractiveness as an employer and business partner, and prevents resistance from local communities. 

5.4.7.4 Impact materiality analysis  for Affected Communities 

Wolftank Group recognizes the crucial importance of the local communities living or operating near its sites, facilities, and infrastructure. The Group’s activities in the territories can have significant direct or indirect impacts on public health, safety, and information management. For this reason, Wolftank Group adopts an approach based on prevention, transparency, and continuous dialogue with affected communities and their institutions. 

Within the framework of the dual materiality analysis, the theme ‘S3 – Affected Communities’ was explored by considering the potential severity of the impacts that the company’s operations may have on areas inhabited by or frequented by people. This assessment was based on three key dimensions: the intensity and probability of the risks posed to the local population, the geographical and temporal scope of the potential effects, and the level of public attention and perception related to sensitive issues such as physical security and the integrity of environmental information. 

Health risk for people near construction sites 

One of the most significant risks identified is the possibility of accidents occurring at construction sites, such as explosions, fires, or the accidental release of hazardous substances. Although people living or passing through the vicinity of operational sites are not directly involved in the work activities, they could still be exposed to serious consequences in the event of a critical incident. The assessment revealed a high level of risk, as the effects on the health and safety of the surrounding population could be severe. Although the impacts are geographically confined – limited to areas near the construction sites – the consequences in terms of public welfare and safety are such that the overall impact is material. 

In response to this, the Wolftank Group has strengthened its prevention and response measures by adopting up-to-date operational protocols, utilizing advanced monitoring technologies, and preparing emergency plans tailored to the specific context of each site. In addition, the company actively collaborates with local authorities and ensures a constant flow of information to communities, promoting awareness and preparedness in case of need. Preventive management of environmental and industrial risks is considered an essential element in safeguarding public health and building a lasting relationship of trust with the territories. 

Computer security and protection of sensitive information 

A second area of impact relates to the management of sensitive data, particularly data concerning environmental issues or technical interventions in risk areas. The accidental loss or unauthorized disclosure of such information could lead to feelings of insecurity, suspicion, or mistrust among local communities. In some cases, perceptions of non-transparency in the management of environmental information may result in protests or tensions with residents. The assessment has shown that, although the impact is limited to the areas where Wolftank Group operates, the risk is considered high due to its potential to affect the company’s reputation and relations with stakeholders. 

To prevent such consequences, the company has invested in cybersecurity and strengthened its data protection policies. State-of-the-art cybersecurity systems and internal control mechanisms have been implemented to ensure the traceability and confidentiality of the processed information. At the same time, external communication efforts have been strengthened to promote proactive transparency, prevent misinformation, and foster constructive dialogue with communities. In an environment of growing focus on data governance, Wolftank Group considers responsible information management a fundamental component of its social license to operate.  

In its approach to dealing with affected communities, Wolftank Group integrates operational responsibility, active listening, and transparency. The potential impacts on the health, safety, and trust of people living in areas where the company operates are consistently monitored. In line with the requirements of the ESRS S3 standard, the organization is committed to consolidating tools and skills aimed at reducing risks, ensuring comprehensive prevention, and promoting a sustainable,  shared development model. 

5.4.7.5 Financial materiality analysis for Affected Communities 

The issue of affected communities also constitutes a key area of financial materiality for Wolftank Group. The company often operates in complex territorial contexts, where the quality of relationships with local communities can have a direct influence on operational efficiency, project acceptance, and the company’s overall reputation. Effectively managing community relations and maintaining a high level of transparency in operations can strengthen stakeholder trust and contribute to the social legitimacy of industrial activities. Conversely, critical incidents or public controversies may result in economic losses, project delays, and significant reputational damage underlining the importance of proactive engagement and responsible local presence. 

In assessing financial materiality, Wolftank Group identified three main drivers that influence the relationship between communities and the company’s economic performance. The first concerns the risk of serious incidents near operational sites and facilities, which could have significant reputational and commercial repercussions. The second is the potential loss or unauthorized disclosure of sensitive data, especially related to environmental issues, with consequent social tensions or calls for accountability. Finally, the proactive aspect of territorial engagement was considered, i.e. the opportunities arising from strengthening ties with local communities. 

The risk of major incidents occurring in the Group’s areas of activity has been assessed as highly material. Although such events are unlikely due to the strict controls implemented, they could provoke negative reactions from the population and local authorities, compromising business continuity and the company’s reputation. In the short term, this risk could result in compensation claims, work stoppages, or loss of customers, resulting in significant economic impacts. In the medium term, it may erode community trust in the company’s activities and limit local support for ongoing or future projects. However, in the long term, if the risk is managed effectively and proactively, its impact is expected to decrease substantially, reinforcing the company’s social license to operate and long-term resilience. The probability of such incidents occurring was considered very low, thanks to an established system of risk prevention, monitoring, and management. 

Another important area of focus is the protection of confidential information. The unauthorized disclosure of sensitive data, particularly information related to environmental interventions, could lead to misinformation, fueling public dissatisfaction and undermining the company’s perceived transparency and reliability with affected communities. This risk, however, has been assessed as not financially material, as its potential impact is low and can be effectively mitigated through the adoption of appropriate cybersecurity tools, information campaigns, and proactive communication with stakeholders. While the likelihood of such issues arising is considered low in the short to medium term, it may increase over the long term due to ongoing digitalization and growing public sensitivity to data protection and privacy concerns. 

In addition to the identified risks, Wolftank Group also recognized a major strategic opportunity: building positive and collaborative relationships with local communities. Active engagement, transparency in decision-making, and a genuine willingness to listen can generate tangible benefits, including social acceptance, reduced opposition to projects, and enhanced operational stability. From a financial perspective, this opportunity is considered material across all time horizons considered. In the short term, it strengthens brand reputation and facilitates consensus on project implementation. In the medium term, it helps reduce costs associated with managing disputes, delays, or administrative hurdles. Finally, in the long term, it fosters stable, trust-based relationships that support business expansion and reinforce the sustainability of the company’s operation model. 

In summary, the analysis of financial materiality for the S3 theme showed that the risk of incidents affecting the community is to be considered material, given its potential impact on reputation, operational continuity, and revenue streams. In contrast, while IT-related risk are present, they are not deemed  financially material, as they can be effectively mitigated through appropriate measures and protocols. A key strategic opportunity, however, lies in establishing strong, trust-based relationships with local communities – a factor that serves as both a competitive advantage and a long-term investment in the sustainability and resilience of Wolftank Group’s business model. 

5.4.7.6 MDR-P – S3-1 – Policies related to affected communities 

§ MDR-P ; § 15 – 17 

Wolftank Group promotes a responsible approach to local communities, based on respect, transparency, and cooperation. The company’s policies, including its Environmental Policy, Code of Ethics, Human Rights Policy, and Supplier Code of Conduct, establish clear principles for managing the impacts generated in the territory in which the company operates. These documents emphasize the health and safety of people, the management of environmental risks, and the need to foster the social and cultural development of communities, with a constant commitment to dialogue and sharing. 

5.4.7.7 S3-2 – Processes for engaging with affected communities about impacts 

§ 21 – 23 

Wolftank Group has implemented structured processes for community involvement through informative and participatory initiatives. The Sustainability Plan includes actions such as open days, safety days, and the presentation of the sustainability report to promote transparency and dialogue with local communities. Starting in 2026, specific awareness-raising events focused on health and safety issues will be organized, with active stakeholder participation. At the same time, educational partnerships with local schools are being developed to cultivate a shared environmental culture. Involvement also occurs through participation in local events and sponsored initiatives, further strengthening the connection between the company and the community. 

5.4.7.8 S3-3 – Processes to remediate negative impacts and channels for affected communities to raise concerns 

§ 27 – 28 

To manage potential negative impacts on communities, Wolftank Group has established internal risk management procedures that include prior assessment of environmental risks, the development of tailored emergency plans for each operational site, and the implementation of strict safety protocols. In addition, Wolftank Group provides accessible reporting channels via its corporate website, allowing stakeholders and community members to raise concerns or report non-compliant behavior. These channels include a whistleblowing platform, direct contact options with the Sustainability Department, and communication interfaces with local authorities. The entire system is embedded within the Group’s sustainability governance framework and is continuously monitored to ensure its effectiveness and responsiveness, and alignment with stakeholder expectations. 

5.4.7.9 MDR-A – 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 

§ MDR-A ; § 32 – 36 

The company has initiated a series of concrete actions aimed at mitigating material impacts on communities while seizing opportunities to create shared value. Key initiatives include strengthening environmental education programs in schools to raise awareness of sustainability issues among the younger generations. Starting from 2026, educational cycles focused on plastic pollution in the sea and the regenerative economy will be launched in collaboration with schools in the Rimini area. 

In parallel, Wolftank Group actively promotes and supports social and community initiatives through sponsorships, contributions to non-profit organizations, and – starting in 2026 – the funding of a dedicated social project to be developed in collaboration with employees. The theme of this project will be determined based on emerging societal needs, reflecting the company’s commitment to inclusive and responsive community engagement. These initiatives are effective tools for strengthening the company’s social legitimacy, preventing tensions, and creating a lasting positive impact. 

The effectiveness of these actions is monitored using both qualitative indicators, such as the degree of participation in events or stakeholder satisfaction, and through quantitative KPIs outlined in the Sustainability Plan, such as the number of projects implemented, the number of hours of environmental training provided or the number of events organized. 

5.4.7.10 MDR-T – S3-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities 

§ MDR-M; § MDR-T § 42 

To ensure systematic and continuous improvement-oriented management, Wolftank Group has established theme-specific operational targets and performance indicators (KPIs). In 2025-2026, the company will focus on analyzing existing data and developing a reporting methodology consistent with international standards. Looking ahead, the goal is to increase both the number and quality of territorial initiatives and measure their impact with clear and verifiable metrics. Targets include the number of events organized, the number of educational visits, hours of environmental training delivered, and the number of social projects or partnerships activated. 

5.4.8 ESRS G1 – BUSINESS CONDUCT – GOVERNANCE 

5.4.8.1 Positive Impacts 

• Prevention and the possibility of immediate action in the event of violations of the law or good business practices through a whistleblowing system, which is a legal requirement in key countries of Wolftank Group’s operations. 
• Prevention of corruption and conflicts of interest, etc., through the establishment of a legally required supervisory board, as required, amongst others, by Italian Law 231. 
• Ensuring compliance with ecological, economic, and social standards in the supply chain through a Code of Conduct. 

5.4.8.2 Negative Impacts 

• Leakage of confidential information (e.g. environmental measures) from customers due to cyber risks could lead to loss of customers. 

5.4.8.3 Risks 

• Leakage of confidential information (e.g. environmental measures) from customers due to cybercrime could lead to the loss of customers. 
• Suppliers may represent a risk in terms of general liability, particularly with regard to their financial capacity, stability, and sustainability performance. 

5.4.8.4 Impact material analysis for Governance 

The topic of G1 – Business Conduct holds strategic relevance for the Wolftank Group, as it encompasses core areas such as ethical business management, anti-corruption practices, whistleblower protection, and data security. Adherence to regulatory and ethical standards not only helps to mitigate legal and reputational risks but also plays a crucial role in reinforcing the trust of customers, investors, and stakeholders at large. 

In alignment with the materiality assessment methodology, the Group has evaluated this topic across three dimensions: the importance of prevention and protection measures, the scope and scale of the impacts, and the overall level of materiality. 

Impact 1: Whistleblower Protection and Whistleblowing System 

The whistleblowing system at Wolftank Group is a key governance mechanism, enabling the reporting of legal violations and breaches of business ethics in a secure and anonymous manner. It plays a vital role in safeguarding the integrity of the organization and ensuring full compliance with legal obligations, particularly under Austrian and Italian law where such a system is mandatory. The absence or inefficacy of this system is considered an absolute risk (rated 5), while its scope of impact is evaluated as average (3), mainly at the national regulatory level. With an overall materiality score of 4.00, the issue is classified as material and critical for the company’s ethical and legal accountability. 

Impact 2: Combating Corruption and Conflicts of Interest 

Wolftank Group embeds the fight against corruption and conflicts of interest at the core of its governance strategy. In alignment with the requirements of Italian Legislative Decree 231/01, the company has established a legally required supervisory body responsible for overseeing the enforcement of ethical conduct and compliance across all operations. The associated risk is rated as high (4), reflecting the crucial role that anti-corruption efforts play in ensuring legal compliance and preserving corporate reputation. The scope of impact is considered average (3), as these measures contribute to the stability and integrity of the broader national economic system. With an overall materiality score of 3.50, the issue is classified as material and significant within Wolftank’s sustainability framework. Comparable governance structures and anti-corruption compliance requirements are also established across the DACH region (Germany, Austria, Switzerland) and other countries, where Wolftank Group is active. Wolftank aligns its practices with national legal frameworks and corporate governance standards. 

Impact 3: Corporate Culture and Code of Conduct 

Wolftank Group acknowledges that promoting a responsible and ethical corporate culture throughout its supply chain, including employees of Group companies, is essential to ensuring long-term sustainability. The adoption of a dedicated Supplier Code of Conduct reinforces the Group’s commitment to environmental, social, and governance standards, fostering transparency and responsible business practices. This topic carries a high-risk rating (4), highlighting the importance of strict adherence to ethical principles to avoid reputational damage and operational setbacks. Although the scope of impact is rated as concentrated (2), primarily affecting local and regional operations, it remains critical to business continuity. With an overall materiality score of 3.00, this topic is considered material and important within Wolftank’s governance framework. 

Impact 4: Data Security and Information Protection 

In an increasingly digitalized operational landscape, cybersecurity and the protection of sensitive information have become central to Wolftank Group’s risk management and corporate security strategy. The potential for data leaks – particularly involving confidential environmental or customer information – poses a serious threat to the Group’s reputation and competitive position. This topic carries a high-risk rating (4), reflecting the essential role of data protection in maintaining stakeholder trust. Although the scope of impact is considered limited (1), primarily affecting internal systems or a restricted number of stakeholders, the implications remain significant. With an overall materiality score of 3.00, this issue is classified as material and important to Wolftank’s governance and operational resilience. 

The impact materiality analysis confirms that all four dimensions – whistleblower protection, anti-corruption, corporate culture, and data security – are material for the Wolftank Group. As part of its strategic governance approach, the company invests in robust compliance mechanisms, transparent business practices, and cybersecurity systems. These efforts are instrumental in enhancing stakeholder trust and supporting the Group’s long-term sustainable value creation. 

5.4.8.5 Financial material analysis for Governance 

Theme G1 – Corporate Conduct is essential for the Wolftank Group, as it includes critical aspects such as data security, supplier management, compliance with ESG standards and corruption risks. Effective corporate governance management is paramount to maintain stakeholder trust, preventing penalties, and ensuring operational sustainability. 

The analysis of financial materiality focuses on six main risks: 

1. Leakage of confidential information and impact on data security. 
2. Risk of contributing to corruption in the value chain. 
3. Increased insurance premiums for recurring accidents. 
4. Financial risks related to supplier management. 
5. Non-compliance with economic and ESG standards in the supply chain. 
6. Potential exposure to fraud, corruption and money laundering.  

Risk: Leakage of Confidential Information and Data Security 

The potential leakage of confidential information presents a significant concern for Wolftank Group, particularly in an increasingly digitalized environment. The loss of sensitive data could not only lead to the loss of customers but also seriously undermine stakeholder trust. In financial terms, the short- and medium-term impacts are considered low, mostly involving mitigation measures and strengthened cybersecurity systems, while the long-term impact is minimal due to the effectiveness of protective strategies already in place. Although the probability of short- and medium-term events remains low, the long-term risk could increase moderately as digitalization advances. Given its potential effect on reputation and client relationships, this risk is considered material. 

Risk: Contribution to Corruption in the Value Chain 

Wolftank Group acknowledges the risk of inadvertently contributing to corruption in its value chain, for example through the procurement of illegally sourced materials. Such events could expose the Group to financial penalties and reputational harm. In the short term, the financial impact is assessed as medium, with legal and image risks, though it is expected to decline in the medium and long term due to the adoption of enhanced supplier controls and due diligence processes. The probability of occurrence remains very low across all timeframes thanks to stringent compliance systems already in place. As a result, this risk is considered not material. 

Risk: Increase in Insurance Premiums for Accidents 

The frequency of accidents in the industry may lead to rising insurance premiums over time. However, Wolftank Group has thus far managed to keep insurance costs under control, and the financial impact is expected to remain minimal across short-, medium-, and long-term horizons. Although the probability of premium increases is very high in the short and medium term, and high in the long term, these are not anticipated to cause substantial disruptions thanks to proactive risk management strategies. Accordingly, this risk is classified as not material due to its limited financial consequences. 

Risk: Financial Instability of Suppliers 

The financial health of suppliers plays a key role in ensuring Wolftank Group’s operational continuity. Short-term disruptions could result in delays and cost increases, representing a medium financial impact. Over the medium and long term, this risk diminishes thanks to supplier monitoring and the strength of existing relationships. The probability of occurrence is moderate in the short term and drops to very low in the long term when supported by robust diversification strategies. However, due to its potential impact on the supply chain, this risk is considered material. 

Risk: ESG Non-Compliance in the Supply Chain 

Non-compliance with ESG standards by suppliers could have legal and reputational consequences for Wolftank Group. In the short term, the financial impact may be moderate, including customer dissatisfaction and potential penalties. However, this risk declines over time as contractual frameworks and supplier selection processes become more rigorous. While regulatory pressure keeps the short-term probability moderate, the long-term likelihood is very high, requiring ongoing attention. Despite this, the risk is assessed as not material due to the mitigation measures already in place and efficiently working. 

Risk: Fraud, Corruption and Money Laundering 

As with any organization, Wolftank Group remains potentially exposed to the risks of fraud, corruption, and money laundering. This could result in significant reputational damage and financial penalties, with high impact across all time horizons. Nonetheless, the likelihood of such events occurring is very low in all periods, owing to the implementation of a comprehensive set of internal controls, compliance systems, and monitoring mechanisms. Consequently, this risk is classified as not material. 

The financial materiality analysis for theme G1 – Corporate Conduct shows that supplier management and data security are material, while risks related to corruption, ESG, and insurance premiums are non-material due to the control measures already in place.  

5.4.8.6 MDR-P Governance Policies 

§ MDR-P, 65 

Wolftank Group implements centralized management through a central body responsible for the development and dissemination of management systems and corporate policies. This approach ensures a structured regulatory framework that guarantees legal compliance and upholds high ethical standards, while keeping corporate policies consistently updated to adapt to market developments and new regulations. 

The company incorporates international governance standards to ensure the transparency and effectiveness of its policies. By following industry and regulatory best practices, Wolftank strengthens corporate governance through continuous training and active employee involvement. 

Wolftank Group’s corporate policies serve as a guiding framework and code of conduct for all employees, ensuring consistency and uniformity in business practices. Key stakeholders are actively engaged in decision-making processes through regular consultations and feedback mechanisms. Additionally, policies are communicated transparently and accessibly, using official channels and corporate platforms for information dissemination. 

Wolftank Group is committed to effective and responsible corporate governance, based on a centralized policy management system. The adoption of international standards and the continuous updating of guidelines ensure an ethical and sustainable approach, fostering active stakeholder involvement and clear communication of company policies. 

During 2024, Wolftank Group strengthened its commitment to a robust, ethical, and transparency-oriented governance system through concrete actions that address the full range of standards under ESRS G1, and in particular the MDR-A, MDR-T and MDR-M indicators. 

5.4.8.7 MDR-A Action 

§ MDR-A, 68 – 69 

Wolftank Group has implemented a series of targeted actions to address material impacts related to governance, ensuring a strategic and integrated approach to business management. These measures are fully aligned with the organization’s overall strategy and aim to ensure security, transparency, and sustainability in decision-making and operational processes. 

A central element of this approach is the protection of corporate and customer data, with a strong focus on information security. To this end, Wolftank Group has launched a comprehensive program aimed at strengthening both technological and regulatory safeguards. This initiative includes: 

• Migration of data to secure cloud platforms to improve accessibility and reduce cyber risks. 
• Development of internal policies for data and information management, with detailed procedures to protect confidentiality and integrity. 
• Adoption of multiple levels of IT security, including advanced authentication systems and secure password-protected credentials. 
• Application of the AI-ACT provisions governing the use of sensitive data in artificial intelligence-based systems. 

To ensure the effectiveness of these actions, Wolftank Group has allocated dedicated financial resources, divided between investments in capital goods (Capex) and operating costs (Opex) related to the maintenance and protection of digital systems. The allocation of resources is monitored regularly to ensure consistency between strategic objectives and operational results. 

At the same time, the Group launched a process to revise and harmonize the Code of Ethics across all group companies, introducing specific sections on human rights, gender equality, and equal opportunities. This effort was complemented by strengthening the whistleblowing procedures, including the activation of secure and accessible reporting channels, the definition of protection measures for whistleblowers and the provision of trainings on the subject. 

The issue of legality has also assumed a strategic role: the implementation of a Management System for the Prevention of Corruption, in line with the international standard UNI EN ISO 37001:2016, is underway, with the aim of raising the Group’s level of integrity and accountability. 

Additionally, Wolftank Group continues to foster an inclusive and participatory decision-making process, actively involving stakeholders in setting priorities and evaluating actions taken. This approach not only strengthens internal governance, but also builds trust among employees, customers and partners. 

5.4.8.8 MDR-Targets 

§ MDR-T,- 80 

As part of its progressive alignment to the ESRS standards, Wolftank Group has established a set of clear and measurable operational objectives aimed at strengthening its culture of governance, integrity and transparency.  

A key commitment concerns the revision of the corporate policy structure, with the goal of integrating essential aspects related to human rights, gender equality, diversity and supplier evaluation into the existing Code of Ethics. This Code also includes specific sustainability and financial stability criteria, which are crucial for ensuring a responsible and resilient supply chain. The policy update seeks to strengthen the internal regulatory framework, promoting a corporate culture oriented towards social responsibility and transparency. 

To ensure broader dissemination and application of its policies, Wolftank Group has initiated a structured process of dissemination of its governance tools (including Whistleblower, Model 231, Code of Ethics) across all Group companies. This is supported by a system of implementation verification, flanked by internal training programs dedicated to ensuring in-depth knowledge of the policies by employees. 

At the same time, the harmonization of ethical policies in all Italian Group companies is scheduled for completion by the end of 2025. This process will also include the structured inclusion of company policies in the onboarding paths of new employees, as well as conducting internal surveys and interviews to monitor awareness, gather feedback, and identify opportunities for improvement. 

In terms of legality and corruption prevention, the process of implementing a Management System in accordance with UNI EN ISO 37001:2016 has begun, with the goal of achieving ISO 37001 certification by 2026. This initiative also aims to enhance the company’s legality rating, with a focus on ensuring compliance with the legal frameworks of the countries where Wolftank Group primarily operates. . 

Another key focus area is the protection of corporate and customer data. To this end, a plan has been defined for the migration of data to secure cloud systems, supported by updated IT security policies and training activities aimed at mitigating digital risks. 

Finally, in alignment with its commitment to sustainability, Wolftank Group is considering initiating a process to get an ESG rating by a globally recognized assessment platform, with the aim of enhancing its performance in supply chains and increasing transparency towards external stakeholders.

5.4.8.9 MDR-Metrics 

§ MDR-M, 75 – 77 

To ensure effective and transparent monitoring of actions taken in the area of corporate governance and ethical conduct, Wolftank Group has defined a set of metrics and KPIs (Key Performance Indicators) to assess the achievement of set objectives and the effectiveness of implemented policies. 

Specifically, dedicated indicators have been introduced for the main areas of intervention: 

• Ethics and whistleblowing: 
  The number of reports received through internal whistleblowing channels is monitored regularly to ensure that the system is fully operational and trusted by employees. The qualitative target is to maintain zero documented ethical violations, as an expression of the proper functioning of the prevention and control system. 
• ESG reporting: 
  The implementation of the new integrated IT system for ESG reporting will be measured through its initial activation in at least one Group company, with gradual extension planned for subsequent years. This indicator is linked to efficiency in the collection, management and reporting of non-financial data. 
• Training and awareness-raising: 
  KPIs were defined relating to the number of employees involved in training courses and the number of hours provided on key topics such as business ethics, IT security, data breaches, corruption prevention, and compliance with company policies. The integration of this content in onboarding processes and internal evaluation moments represents an additional qualitative parameter of effectiveness. 
• Legality and certification: 
  Obtaining UNI EN ISO 37001:2016 certification by 2026 is a key indicator to attest the maturity level of the corruption prevention system. Furthermore, an increase in the level of legality recognized to the company will be assessed, also through external parameters such as the AGCM legality rating. 
• ESG performance: 
  Obtain an ESG assessment score by a globally recognized assessment platform will provide a useful benchmark to compare Wolftank Group’s performance with other players in the industry. This indicator will make it possible to guide further improvement strategies in supply chains and sustainability management. 

These indicators not only make it possible to measure achievements but also provide an objective basis for dynamically adapting and optimizing corporate policies, ensuring that the governance evolution remains consistently aligned with international standards, stakeholder expectations, and the Group’s core values. 

5.4.8.10 GOV-1 The role of the administrative, supervisory and management bodies 

§ 5 

Wolftank Group adopts a Corporate Health and Safety Management System (HSMS) integrated with Quality and Environmental (QE) management. This system aims to promote a corporate culture centered on safety and prevention, raising employee awareness of risks and promoting responsible behavior, in line with the principles of the Code of Ethics. 

To enhance oversight of compliance with ethical and governance rules, the Group has established a monitoring mechanism specific to each country in which it operates. This body is responsible for monitoring compliance with the Organizational Model and the Code of Ethics, ensuring that they are applied and constantly updated. 

Responsibilities of the Governing Bodies on Corporate Conduct 

The Wolftank Group’s governance is structured according to high standards, such as the Austrian and German Corporate Governance Code, ensuring transparency and fairness in business decisions. The members of the Executive Board and Supervisory Board have specific expertise in matters of business conduct, including sustainability, ethics, and risk management. 

The company has implemented several corporate policies to strengthen its ethical and regulatory commitment, including: 

• Anticorruption Policy, which prohibits all forms of corruption and establishes whistleblowing procedures. 
• Code of Ethics, serving as a guide for the behavior of employees, suppliers, and stakeholders. 
• Supplier monitoring, with regular assessments based on ESG (environmental, social, and governance) criteria. 

Finally, the training and awareness-raising of governance members on matters of business conduct is ensured through the continuous updating of internal policies and procedures, guaranteeing compliance with both international standards and local regulatory frameworks.. 

5.4.8.11 G1-1 Corporate culture and Business conduct policies  

§ 7 – 11 

Wolftank Group has implemented a governance and business conduct system based on principles of integrity, safety, and compliance with applicable regulations. Its corporate culture is centered on fostering a safe working environment and promoting ethical practices, supported by whistleblowing mechanisms and policies. 

Managing Material Impacts, Risks and Opportunities 

To ensure effective management of business conduct and corporate culture, Wolftank Group has adopted key corporate policies, including the Code of Ethics and the Code of Conduct for Suppliers. These documents define the guiding principles for the behavior of employees, collaborators and business partners. 

Corporate culture is promoted through: 

• Safe and secure workplaces with a zero-accident strategy. 
• Strict safety protocols and continuous training sessions to minimize risks and prevent injuries. 
• Investment in state-of-the-art equipment to improve operational safety. 
• A proactive approach to security management, leading to increased efficiency and business productivity. 

Reporting and Investigation Mechanisms 

To ensure compliance with company policies, Wolftank has set up reporting channels for employees and business partners. Through the Group’s website, it is possible to securely report violations of the Code of Ethics or incidents of misconduct, including cases of non-compliance or human rights violations. 

Anti-Corruption Policies and Protection of Whistleblowers 

Currently, the Group does not have anti-corruption policies specifically aligned with the UN Convention against Corruption, but each subsidiary adheres to the Code of Ethics and Whistleblowing Policy, in accordance with the EU Directive 2019/1937 on the Protection of Whistleblowers. 

The whistleblowing process allows anyone aware of unlawful conduct to report it through dedicated channels, ensuring confidentiality and protection from retaliation. Reports may concern: 

• Violations of the Code of Ethics 
• Administrative responsibility of the company 
• Health, Safety, and Environmental Issues (HSSEQ) 
• Mobbing or disrespectful behavior 
• Security and anti-corruption 
• Breaches of business ethics 

Guarantees for Reporting Irregularities 

Wolftank safeguards the confidentiality and anonymity of whistleblowers and people involved in whistleblowing. The whistleblowing system guarantees protection against any form of discrimination or retaliation. 

Implementation of Whistleblowing Policies 

In Italy, the Group has adopted the Whistleblowing Operational Protocol in accordance with Legislative Decree 24/2023, implementing a software platform for managing reports. This measure is part of the Organizational Management Model (Legislative Decree 231/01) adopted by the company. While comparable legal frameworks exist in the DACH region (Germany, Austria, Switzerland) and other countries where Wolftank operates, mandatory internal whistleblowing systems typically apply only to companies with 50 or more employees. Nonetheless, Wolftank is committed to implementing a coherent whistleblowing policy and reporting system across the Group, as part of its broader commitment to good governance and alignment with European compliance standards. 

Investigation of Corporate Conduct Incidents 

A dedicated team is responsible for handling reports, initiating timely, independent, and objective investigations to determine the necessary corrective actions and monitor their implementation. 

Corporate Conduct Training 

Wolftank Group promotes awareness of the Code of Ethics through information and training procedures. Continuous training programs are planned for employees, including the involvement of legal experts to ensure compliance with current regulations. 

Functions at Risk of Corruption and Bribery 

The business areas most exposed to the risk of corruption and Bribery are: 

• Procurement 
• Sales 

Wolftank Group follows a zero-tolerance policy towards corruption and bribery, supported by a robust ethics system and specific policies designed to mitigate risks. 

Risk Management in the Supply Chain 

Wolftank monitors the sustainability and financial stability of suppliers, particularly for the procurement of critical materials. The strategy includes diversification and optimization of the inventory to manage price fluctuations and delivery times. 

5.4.8.12 G1-2 Management of relationships with suppliers 

§ 14 – 15 

Wolftank Group has implemented a structured system for supplier relationship management, focusing on supply chain risks and impacts on sustainability issues. The company policy establishes clear principles to ensure responsible sourcing that respects ethical, environmental, and regulatory compliance standards. 

Wolftank Group demonstrates a strong commitment to responsible supply chain management, promoting ethical practices, respect for human rights and environmental protection. The Supplier Code of Conduct is a key reference to ensure that business partners operate according to the same principles of sustainability and integrity. 

Policies for the Prevention of Late Payment 

Currently, there is no specific policy in place to prevent late payment, particularly with regard to small and medium-sized enterprises (SMEs). However, Wolftank Group is committed to maintaining transparent and sustainable relations with its suppliers, which may include a focus on responsible and timely payment practices. 

Principles for the Management of Relations with Suppliers 

The Code of Conduct for Suppliers outlines the basic criteria governing the relationship between Wolftank and its business partners. This code applies to all suppliers, contractors, and subcontractors who provide goods and services to the company. 

Suppliers are obliged to: 

• Comply with the regulations in force in the countries where they operate and refrain from conduct that, while not violating the law, may damage Wolftank’s reputation or have a negative impact on the environment. 
• Ensure respect for human rights and labor standards, conforming to the principles of the Universal Declaration of Human Rights and the recommendations of the International Labor Organization (ILO). 

Social and Environmental Criteria in Supplier Selection 

When selecting contractual partners, Wolftank Group adopts social and environmental criteria to ensure the sustainability of its supply chain. Suppliers must commit to: 

• Avoiding human rights abuse, ensuring safe working conditions, and respecting legal minimum wages. 
• Promoting equal opportunities and non-discrimination, prohibiting any form of discrimination based on ethnicity, gender, religion, age, or sexual orientation. 
• Avoiding child and forced labor by complying with international and local regulations on minimum age for employment and decent working conditions. 
• Respect freedom of association and the right to collective bargaining. 

Commitments to Sustainability and Environmental Protection 

Suppliers to Wolftank Group must comply with strict environmental standards, including: 

• Compliance with applicable environmental regulations in the countries where they operate. 
• Decarbonization and energy transition, with a preference for the use of renewable energy and low-impact technologies. 
• Protection of biodiversity, avoiding deforestation and alteration of natural ecosystems. 
• Reducing environmental impact, with strategies to limit air pollution, greenhouse gas emissions, and hazardous waste generation. 
• Responsible sourcing of raw materials, avoiding the use of resources that may be associated with violations of social and environmental standards. 

5.4.8.13 G1-3 Prevention and detection of corruption and bribery 

§ 18 – 21 

Wolftank Group is actively committed to the prevention and detection of corruption and bribery, implementing specific measures to ensure corporate integrity and compliance with applicable regulations. The policies adopted the aim of promoting an ethical and transparent working environment, based on principles of compliance and accountability. 

Wolftank Group’s commitment to the prevention of corruption and bribery is reflected in rigorous reporting and investigation policies, the protection of whistleblowers and the promotion of a corporate culture based on transparency and integrity. Ongoing training and the adoption of new procedures will ensure continuous improvement in anti-corruption governance. 

Wolftank Group has established a reporting procedure to enable employees to report suspected incidents of bribery and corruption. This procedure is based on the following principles: 

• Protection of corporate integrity: each report is intended to protect the core values of the company. 
• Good faith reports: the system is designed to monitor possible violations and take the necessary steps to correct them. 
• Confidentiality guaranteed: the reporter’s identity is protected. 
• Secure reporting channels: Wolftank has set up several reporting channels, including:  
• Dedicated email address: compliance@wolftank.com 
• Online form is available on the company website. 

Independence of Investigations and Reporting Process 

Investigators and the investigating committee are independent from the management chain involved in the prevention and detection of corruption, thus ensuring the impartiality of investigations. All reports are reviewed internally with anonymity and discretion, and by an independent and neutral body, which verifies violations and proposes possible disciplinary or corrective measures. 

The company expressly prohibits any form of retaliation or discrimination against whistleblowers who make reports in good faith. Additionally, sanctions are provided for those who violate the whistleblower protection measures or make unfounded reports with malice or negligence. 

Adoption of Procedures and Training 

Wolftank Group has already implemented a whistleblowing procedure and continues to strengthen the system for preventing and detecting corruption through: 

• Communication of company policies: Ensuring the disclosure of procedures to employees and relevant partners, ensuring that they are aware of the ethical behavior to be adopted. 
• Anti-bribery and corruption training: Targeted training programs will be implemented for corporate functions that are exposed to a higher risk of bribery and corruption, ensuring increased awareness and compliance within critical roles. 
• Monitoring training coverage: A system is being developed to collect data on the percentage of corporate functions involved in training programs. 

5.4.8.14 G1-4 Confirmed incidents of corruption or bribery 

§ 24 

There were no incidents of corruption or bribery. 

5.4.8.15 G1-5 Political Influence and Lobbying 

§ 29-30 

Wolftank Group does not pratice Political influence and lobbying activities. 

5.5 Sustainability Plan

Inspired by its Vision and Mission, Wolftank Group firmly believes that only a comprehensive, 360º approach can effectively address the challenges of the future. 

Accordingly, in line with our Vision and Mission, our Sustainability Plan places the highest priority on environmental stewardship by 

• Reducing resource consumption and emissions, 
• Promoting circular economy principles, 
• Enhancing the sustainability of regeneration and waste treatment processes to be implemented internally and offered to customers, and 
• Developing innovative infrastructure solutions to support the growth of the green economy. 

To fulfil these commitments, Wolftank’s Sustainability Plan defines clear objectives, sets out concrete actions to achieve them, and establishes targets and KPIs to monitor and track performance over time. 

In addition, reflecting our alignment with the United Nations Sustainable Development Goals (SDGs), the Group has identified its primary areas of action: 

Moreover, investing in innovation – recognized as a key driver of business improvement and operational efficiency – is essential to the success of Wolftank’s sustainability plans. Equally important is the protection and empowerment of people and communities, encompassing both Wolftank’s employees and all relevant external stakeholders. 

Wolftank Group is committed to maintaining high standards of governance, integrity, and transparency across all areas of its operations. To this end the company has implemented a structured process for managing economic, environmental, and social impacts, ensuring that sustainability is embedded into decision-making at every level. 

The table below presents the Sustainability Plan, detailing the  targets, KPIs, corresponding actions and the short-, medium- and long-term implementation timelines for each individual topic. 

Table Sustainability Plan.