CALCULATION OF KPIS ASSOCIATED WITH ENVIRONMENTALLY SUSTAINABLE ACTIVITIES

The charts show the share of aligned eligible and not eligible activities relative to turnover, CapEx and OpEx calculated for 2022. Appendix | Sustainable activities: the Taxonomy of the European Union provides detailed tables of these indicators as required by EU Delegated Regulation 2021/2178 (Annex II).

6 - Taxonomy Eligible Aligned: refers to an economic activity that simultaneously meets the following three conditions: it is included in the EU Taxonomy Regulation for its potential substantial contribution to climate change mitigation or adaptation; it meets the specific criteria developed by the EU Taxonomy Regulation for that specific environmental objective; and it meets all DNSH criteria and Minimum Safeguards.

- Taxonomy-Eligible not aligned: refers to an economic activity that: is included in the EU Taxonomy Regulation for its potential substantial contribution to climate change mitigation or adaptation; but does not meet the technical screening criteria developed by the EU Taxonomy Regulation for such activities and specific environmental objectives; or does not meet at least one of the DNSH and/or Minimum Safeguards. Not eligible: refers to an economic activity that has not yet been included among those that contribute substantially to climate change mitigation or adaptation.

7 - This activity is described in Section 3.1 of Annex I to EU Delegated Regulation 2021/2139 of June 4, 2021.

Note in this regard that Comer Industries has adopted a conservative approach in the process of screening and evaluation of eligibility of economic activities. The economic activities of manufacturing key components to serve economic activities falling under the categories described in Sections 3.2-3.6 of Annex I of EU Delegated Regulation 2021/2139 of June 4, 2021, including the activity of manufacturing key components for electric vehicles and equipment, were not considered eligible. Conversely, the activity of manufacturing planetary gearboxes was considered permissible because they are designed, manufactured, and sold to serve wind turbines, and likewise are an integral and essential part thereof.

8 - The assessment of compliance with DNSH criteria, i.e., that the activity does not cause significant harm to any of the environmental objectives in Article 9 of Reg. EU 2020/852, was performed in accordance with the criteria of EU Delegated Regulation 2021/2139 of June 4, 2021 based on documented activities and evidence already available within Integrated System management, to achieve risk reduction and compliance objectives.

9 - Comer Industries implemented a due diligence process inspired by the principles and criteria set forth in the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the relevant ILO principles. More information on this can be found in the "Human Rights” section.

Financial information was collected and extracted from the accounting system used by the Company for the preparation of the statutory financial statements, prepared in accordance with IFRS. The data used to calculate the indicators on turnover, OpEx and CapEx required by the regulations were therefore derived from the relevant administrative flows. Since this is the first report, the values of the KPIs represent the baseline for future reporting.

2022 Sales

4%

ELIGIBLE ALIGNED NOT ELIGIBLE

Capex 2022

98%

Opex 2022

47%

2%

ELIGIBLE ALIGNED NOT ELIGIBLE

53%

ELIGIBLE ALIGNED NOT ELIGIBLE