Galp Energia SGPS S A : IMR 2023 - Non-financial information (GRI, SASB, WEF)

1. Non-financial consolidated information

Pursuant to Article 66.º-B and Article 508-G of the Portuguese Code of Commercial Companies (in accordance with the provisions of Directive 2014/95/EU of the European Parliament and the European Council, relating to the disclosure of non-financial and another information, transposed to Portuguese law through Decree-Law No. 89/2017 of 28 July) and the model for reporting non-financial information by issuers of securities admitted to trading on a regulated market presented by CMVM.

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1. Non-financial consolidated information

2. Description of the methodology and reasons for its adoption in the reporting of non- financial information, as well as any changes that have occurred in relation to previous years and the reasons that motivated them.

Galp's non-financial information report is intended to provide a global, transparent, and rigorous view of the processes through which Galp creates environmental, social and economic value. The disclosure of non-financial information is in line with the applicable rules and globally recognised guidelines, namely:

• rules pertaining to the reporting of non-financial information introduced by Decree-Law No. 89/2017 of 28 July (this appendix), with the upcoming implementation of the Corporate Sustainability Reporting Directive (CSRD) in 2024
• the Value Reporting Foundation (VRF) guidelines for integrated reporting
• the Global Reporting Initiative (GRI) guidelines, GRI Standards version 2021, " in accordance with the GRI Standards for the period from 1 January 2023 to 31 December 2023", following the new Oil & Gas sector supplement guidelines (GRI 11) relating to the sustainability report
• the Sustainability Accounting Standards Board (SASB) for Oil and Gas (Exploration & Production, Midstream and Refining and Marketing Standards)
• the recommendations from the Task Force on Climate-related Financial Disclosure (TCFD) of the Financial Stability Board (FSB) concerning disclosure of climate- related financial risks
• the United Nations Global Compact (UNGC) principles on sustainability information
• the World Economic Forum, Measuring Stakeholder Capitalism metrics and disclosures
• the Sustainable Development Goals
• the inclusion, materiality, responsiveness and impact principles in the AA1000 Accountability Principles Standard (AA1000AP 2018) regarding sustainability information
• the Sustainable Finance Disclosure Regulation (SFDR) indicators, available athttps://www.galp.com/corp/en/sustainability/reporting/documents

Galp's material aspects are all those that can significantly interfere with the ability to generate value for the Company and its stakeholders. Its identification is a continuous, robust and mature process at Galp, which guides the Company in understanding the main challenges and opportunities it faces, ensuring strategic alignment and communication with the most important aspects. Galp's non-financial information is publicly presented, and subject to third-party verification, in the company's annual integrated report, on the Company's website and other relevant communication media. See our independent assurance report about sustainability information in section 7. Of Part V (Appendices) of this document.

Appendices

Part I - Information on adopted policies

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C. Main risk factors

1. Identification of the main risks associated with the matters subject to reporting and arising from the Company's activities, products, services or business relationships, including, if applicable and whenever possible, supply chains and subcontracting.
2. Indication of how these risks are identified and managed by the Company.
3. Explanation of the internal functional division of competencies, including corporate bodies, committees, commissions or departments responsible for risk identification and management/monitoring.
4. Express indication of the new risks identified by the Company compared to what was reported in previous years, as well as the risks that ceased to be.
5. Indication and brief description of the main opportunities that are identified by the Company in the context of the matters subject to reporting.

D. Implemented policies

6. Description of the policies: i. environmental, ii. social and tax, iii. regarding workers and gender equality and non-discrimination, iv. regarding human rights and v. regarding combating corruption and bribery in the Company, including the policies of due diligence and the results of their application, including related key non-financial performance indicators, and comparison with the previous year.

Information available for consultation in section 53 of Part III of this report - Corporate Governance Report - Identification and description of the major types of risks (economic, financial, and legal) to which the Company is exposed in the pursuit of its business activity and in Part I - 2.4 How we manage risk.

Galp is committed to efficiently and transparently manage all matters related to risk management and impacts of its activities (whether environmental, social, tax or governance). In this regard, Galp has developed a set of Policies that govern its performance and that enable the sustainable management of the business and the establishment and fulfilment of challenging objectives and goals.

Safety, Health and Environment Policy

Through the Safety, Health and Environment Policy, Galp undertakes to integrate synergistically aspects related to safety, health and the environment in its strategy and to ensure the proper management of these topics, with the clear goal of acting responsibly, and thereby reducing possible negative impacts and maximising the positive effects of its activities.

Specific Health, Safety and Environmental Requirements

This Regulation defines the requirements in health, safety and environment (HSE) that must be met in decision-making, throughout the life cycle of the projects, in order to ensure the protection of people, the environment and the assets. The Regulation presupposes the HSE risk assessment and is aligned with Galp's Safety, Health and Environment Policy and its commitments.

Climate Change Policy

Galp considers it is essential to promote and contribute to meeting the energy needs of the future, in strict cooperation with the goals proposed to combat climate change. In this regard, and aware that this is truly a challenge for the future, Galp updates its Climate Change Policy in line with its commitment to follow good market practices and trends in this regard.

Code of Ethics and Conduct

1. Non-financial consolidated

Appendices

Part I - Information on adopted policies

Policy for the Prevention of Money Laundering and Terrorist Financing

Galp considers it is essential to prevent, detect and respond to the risks of exposure of money laundering and terrorist financing within the scope of its transactions with third parties. In this regard, a Policy for the Prevention of Money Laundering and Terrorist Financing was implemented, which lists Galp's commitments to combat the transformation of funds from criminal origin into legal resources through the financing mechanisms of a money laundering organisation.

Prevention of Money Laundering and Terrorist Financing Standard

Galp's Money Laundering and Terrorism Financing Prevention Standard establishes rules aimed at preventing, detecting and responding to the risks of exposure to money laundering and terrorist financing, achieving that established in the Code of Ethics and the Prevention of Money Laundering and Terrorist Financing. Amongst the various duties instituted by the Standard is the general duty of employees of the Galp Group or third parties acting on its behalf not to enter transactions with counterparties whose intention may be to conceal or disguise the illicit origin, source, location, or disposal or movement of capital, goods or products, in violation of applicable money laundering prevention laws.

Sustainable Procurement Policy

In our Sustainable Procurement Policy, we reinforced the 4 principles to be applied across our value chain: Respect for human rights and working conditions, Acting with transparency and integrity, Assume quality as a critical success factor and the Protection of the environment, people, and assets. Our suppliers' qualification, selection and contracting of is governed not only by compliance with commercial and technical terms & conditions, but also by Galp's Sustainable Procurement Policy compliance, the provisions of its Code of Ethics and Conduct and normative documents, that make it up, among other Galp's relevant policies, as well in acquiescence with the current legislation in the countries where it operates, with the purpose of creating shared value, in a sustained manner, progressively in accordance with the European legislation.

Biodiversity Policy

In our Biodiversity Policy, we establish strategic guidelines and ambitions in the dimension of biodiversity, including it as an integral part of business management and throughout the value chain associated with the Group's projects.. This document is focused on 3 main principles: Respect exclusion zones; Identify, assess, and manage existing and new operated sites; Promote collaboration and spread knowledge. Galp shares the vision of recognising the importance of taking long-term sustainable actions to conserve and protect biodiversity, aiming to contribute to biodiversity restore.

Key Indicators and Results

See the following sections of this report - Integrated Management Report:

• Part I - 1.2. Value creation
• Part I - 2.2. Creating sustainable value
• Part I - 2.3. Approach to ESG
• Part II - Sustainability journey

i. Environmental policies

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1. Non-financial consolidated information

1. Description of the Company's strategic goals and the main actions to be undertaken for their implementation.

Galp provides, in its strategic plan, a set of environmental and climatic strategic goals. See the following sections of this report - Integrated Management Report:

• Part I - 2.2. Creating sustainable value
• Part I - 2.3. Approach to ESG
• Part II - Sustainability Journey - 1. Our decarbonisation journey
• Part II - Sustainability Journey - 2. Biodiversity, Water, Circular economy

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3. Indication, compared to the previous year, of the degree of achievement of those goals.

ii. Social and tax policies

1. Description of the Company's strategic goals and the main actions to be undertaken for their implementation.

See the following sections of this report - Integrated Management Report:

• Part I - 2.3. Approach to ESG
• Part II - Sustainability Journey - 1. Our decarbonisation journey
• Part II - Sustainability Journey - 2. Biodiversity, Water, Circular economy

In its strategic plan, Galp provides a set of strategic social objectives, aimed at creating value and its distribution, directly and indirectly, by the Company. See the following sections of this report - Integrated Management Report:

• Part I - 2.3. Approach to ESG
• Part II - Sustainability Journey - 3. People, Communities, Human Rights
• Part II - Sustainability Journey - 4. Protect and empower our people
• Part II - Sustainability Journey - 5. Promote a value-adding, conscious business See also:
• Galp'sTax Policy

1. Non-financial consolidated

3. Indication, compared to the previous year, of the degree of achievement of those goals

See the following sections of this report - Integrated Management Report:

• Part I - 2.3. Approach to ESG
• Part II - Sustainability Journey - 3. People, Communities, Human Rights
• Part II - Sustainability Journey - 4. Protect and empower our people
• Part II - Sustainability Journey - 5. Promote a value-adding, conscious business

iii. Employees and gender equality and non-discrimination

1. Description of the Company's strategic goals and the main actions to be undertaken Galp positions itself as a competitive and fair employer, its values guided by principles of diversity, equal opportunity and training. for their implementation.

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Part I - Information on adopted policies

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financial consolidated information

3. Indication, compared to the previous year, of the degree of achievement of those goals

iv. Human rights

1. Description of the Company's strategic goals and the main actions to be undertaken for their implementation.

See the following sections of this report - Integrated Management Report:

Part I - 2.3. Approach to ESG

Part II - Sustainability Journey - 3. People, Communities, Human Rights

Part II - Sustainability Journey - 4. Protect and empower our people

Part II - Sustainability Journey - 5. Promote a value-adding, conscious business

See in Galp website, the 2024 Equality Plandocument, which includes the measures implemented in 2023.

For more information, see Part III - Corporate Governance Report of this report and the Remuneration Policy.

Galp's commitments are established in the Human Rights Policy, which is aligned with Internationally recognised Human Rights standards, namely the 10 principles of the United Nations Global Compact, the Universal Declaration of Human Rights of the United Nations, as well as the Code of Conduct of the International Labour Organisation (ILO) and with regard to the Rights of Indigenous Peoples (ILO 169 and IFC PS7).

Additionally, Galp is a signatory of the CEO Guide on Human Rights of BCSD Portugal.

See the following sections of Part II - Sustainability Journey of this report - Integrated Management Report:

• 3. People, Communities, Human Rights
• 5. Promote a value-adding, conscious business

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Appendices

Part I - Information on adopted policies

For more information about the human rights assessments report, please consult the Operational Human Rights Assessment - 2023 Update available on the Galp website (link here).

v. Fighting corruption and bribery attempts

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1. Prevention of corruption: measures and instruments adopted to prevent corruption and bribery; policies implemented to dissuade these practices together with workers and suppliers; information about the compliance system indicating the respective responsible officials, if any; indication of legal proceedings involving the Company, its administrators or employees related to corruption or bribes; measures adopted at the public procurement site, if relevant.

As part of the assessment process of any new potential investment in a different region, Galp assesses the risks of corruption associated with the socio-economic context of the region in question.

Galp also performs due diligence procedures regarding its business and social partners, service providers and the most relevant suppliers before entering into transactions with them, to ensure that such entities also follow appropriate and effective policies and procedures related to the prevention of corruption and bribery.

In 2023, 4766 counterparties were assessed through the Company integrity process.

In 20 cases, significant risks were identified and, therefore, the interactions with the counterparties in question have been interrupted.

1006 assessments were also conducted prior to making and/or receiving offers involving Galp employees through Galp's electronic of fer registration platform.

consolidated information

2. Prevention of money laundering (for issuers subject to this regime): information about In 2020, Galp's Money Laundering and Terrorist Financing Prevention Standard was published, which establishes rules and procedures aimed at preventing, detecting

-financial

3. Codes of Ethics: indication of any code of ethics to which the Company has adhered or implemented; indication of the respective mechanisms for implementation and compliance monitoring of the same, if applicable.

Code of Ethics and Conduct

Galp's Code of Ethics and Conduct is a guide for the actions of the Company, its people and business partners, which outlines the fundamental ethical guidelines of Galp's actions and that establishes, for each of the principles listed therein, commitments, responsibilities and good practi ces. In 2023, a revision of the Galp's Code of Ethics and Conduct was approved.

Whistleblowing - Ethics Line Standard

Through the ethics line OpenTalk, Galp promotes the reporting, on a confidential basis, of any knowledge or substantiated suspicion of the occurrence of irregularities or circumstances of non-compliance in relation to the Code of Ethics and Conduct or other Galp Policies and Regulations.

Ethics and Conduct Committee

Galp's Ethics and Conduct Committee, an in-company and independent body that reports to the Audit Board, is responsible for monitoring the implementation of the aspects set out in the Code of Ethics and Conduct, for clarifying doubts about its application and for processing the information transmitted through the Ethics Line. For more information, see Part III - Corporate Governance Report (Information on the Company's shareholding structure, organisation and governance, Item 29 - Ethics and Conduct Committee) of this report.

Regulations of the Ethics and Conduct Committee

This Regulation establishes the competencies, duties, and rules of operation of the Galp Ethics and Conduct Committee. For more information, see Part III - Corporate Governance Report (Information on the Company's shareholding structure, organisation and governance, Item 29 - Ethics and Conduct Committee) of this report.

1. Non

4. Conflict of Interest Management: measures for managing and monitoring conflicts of interest, namely the requirement to subscribe to statements of interest, incompatibilities and impediments by managers and employees.

Conflict of Interest Management Standard

The Conflict of Interest Management Standard describes the set of in-company control rules and procedures adopted by Galp in order to prevent conflicts of interest.

Whistleblowing - Ethics Line Standard

If employees are in a situation where their personal interests conflict, or may conflict, with their professional duties at G alp, they must report such a situation through Galp's electronic conflict of interest registry.

If employees are aware of a conflict of interest that is a risk to Galp and they have substantiated suspicions that have not been reported to the Ethics and Consultation Committee, the employees must report the information through the ethics line OpenTalk.

Appendices