2. Environmental Management

Due to their nature, mining operations are related inevitably with environmental impact. As a result, we are committed to operate responsibly regarding the environment and minimize our environmental impact, as well as implement responsible environmental management initiatives and practices.

According to a quantitative survey conducted in August 2019 to 500 members in the Municipality of Aristotle, 34% has a negative opinion about Hellas Gold, with 81% of those being due to environmental impact concerns.

Our Environmental Policy dictates our commitment to ‘design, develop, operate and decommission facilities in an environmentally sound manner’.

Through the development of its Sustainability Integrated Management System (SIMS), Eldorado Gold reviews systematically the environmental management systems’ requirements at our operations and incorporates best practices into an internal set of performance standards (see Section 2.2).

As part of our systematic approach to environmental protection: • We have established environment teams at all sites to daily oversee, implement and manage our environmental policies, programs and activities • The teams report directly to the Environmental Manager and their Mine General Manager, who in turn report to our

Vice President & Managing Director • The Vice President & Managing Director reports to

Eldorado Gold’s Chief Operating Officer, who sets annual environmental objectives and targets and reviews weekly environmental performance • At Eldorado Gold Board level, the Sustainability

Committee oversees all environmental activities and

Eldorado Gold’s President & CEO is ultimately accountable for environmental performance • We operate an Environmental Management System independently certified to ISO 14001, whose scope

includes all project life cycle stages, including exploration for new deposits, construction of new mining facilities, mine operation and processing, material transportation and site reclamation • Our Kassandra Mines are the first mining operations in

Greece with an Energy Management System certified to ISO 50001, which defines the prerequisites to establish, implement, maintain and improve the energy management system • We are one of the few companies in Greece to validate

GHG emissions according to ISO 14064, which specifies principles and requirements to measure and report greenhouse gas (GHG) emissions.

Environmental Impact Assessments: We conduct Environmental Impact Assessments (EIAs) for our projects, which have developed through extensive consultation with local communities and input from technical and environmental experts, in order to evaluate their potential environmental impacts. Furthermore, we submit environmental impact mitigation plans to regulators as part of the permitting process and work with various Stakeholders to understand, assess and mitigate our impacts.

Independent Environmental Monitoring Committees: As part of our commitment towards transparency and accountability, independent environmental monitoring committees have been established for all our operating sites. The committees include government regulators, technical experts and representatives from local authorities, who visit our sites to oversee independently our activities and observe our environmental practices.

Contractor Environmental Management Handbook: We have included an Environmental Management Handbook as an integral part of contractual agreements with Contractors, who have to sign that they understand and accept its requirements, before starting their work. According to this Handbook, Contractors: • Receive induction training before starting work and are obliged to train their employees on environmental and energy management issues at least twice a year for each employee • Must assess their own environmental risk before starting work and submit a Written Environmental Risk

Assessment, if required • Must ensure that waste management is compatible with environmental regulations and applicable legislation, as well as our procedures • Are obliged to report any type and quantities of hazardous materials they will use • Are briefed and trained on dealing with fire incidents and use of firefighting equipment.

In May 2020, the new Environmental Law 4685/2020 was passed by the Greek Parliament, which modernizes Greek legislation to EU standards.

We closely monitor the regulatory and legal framework related to our activities, in order to apply its relevant provisions and transform our commitment towards environmental protection into action through our environmental programs. Within 2020, 2 fines imposed in 2016 for alleged environmental non-compliances with a total amount of €1,734,300, were reduced to €300,000 by Administrative Courts (see Section 2.4). During 2020, the following minor incidents occurred: • A case of foams observed in Kokkinolakkas creek for approximately 2 km, due to damage of an Intermediate

Bulk Container (IBC) tank with concrete accelerator during its transfer with a forklift. We reviewed the accelerator

IBCs unloading and transferring process, to minimize possibility of future accidents. • 3 cases of black sediment observed in Karvounoskala creek, due to gravel fines used to layer our mine road, which were washed away by rainfalls and dust control water. We immediately cleaned the creek and changed gravel used for road layering, as well as designed a surface runoff collection system along our mine road. • An engine oil leakage from a personnel transport vehicle due to damage. We trained employees on proper handling of relevant environmental incidents (as described within our emergency response plan) and proceeded with infrastructure works for underground movement of mobile equipment. • A coloring of one sedimentation pond and its exit to the

Mavrolakkas creek observed during the daily inspection of the mine water treatment system, due to a failure at a backfill dam, which resulted in higher than normal pH and TSS values from the water treatment system. 0 major environmental incidents 0

accidents with actual or potential negative environmental impacts during transportation

We comply with Greek legislation and consult with our Stakeholders regarding changes in operations. Moreover, we continuously inform our Stakeholders on social issues (e.g. economic issues, cultural heritage) and environmental issues (e.g. air quality, noise, vibrations, water) through various means, which include our environmental monitoring platform (see Section 4.1) and our open-door policy to inform everyone interested on our practices. Through these approaches, we seek to include community members in our Stakeholder consultations regardless of diversity factors (e.g. age, gender, educational level).