Content Indices

<IR>: Integrated Reporting Framework
GRI: Global Reporting Initiative Standards
SASB: Sustainability Accounting Standards Board - Infrastructure Sector – Electric Utilities & Power Generators
UNGP: United Nations’ Guiding Principles on Business and Human Rights
UN SDG: United Nations Sustainable Development Goals

FIRST GEN MATERIAL TOPIC	DEFINITION OF MATERIAL TOPIC	GRI TOPIC STANDARD	SASB (Electric Utilities)
ENVIRONMENT
Climate Action	Management of impacts, risks, and opportunities associated with climate change and the transition to a lower-carbon economy	GRI 102: Climate Change	IF-EU-110a
Emissions	Gross direct (Scope 1), energy indirect (Scope 2), and other indirect (Scope 3) emissions of the seven constituent greenhouse gases	GRI 102: Climate Change	IF-EU-110a
Biodiversity	Protection and restoration of habitats, species conservation, and managing significant impacts on natural ecosystems	GRI 304: Biodiversity	Implicit in Ecological Impacts
Water and Effluents	Managing water withdrawal, discharge, consumption, and compliance with water quality regulations	GRI 303: Water and Effluents	IF-EU-140a
Waste	Managing the total waste generated, diverted from disposal, and treated	GRI 306: Waste	IF-EU-150a
Energy	Managing energy consumption within the organization, generation efficiency, and customer electricity savings	GRI 103: Energy	IF-EU-110a IF-EU-420a
Materials	Inputs used to manufacture and package an organization's products and services can be non-renewable materials, such as minerals, metals, oil, gas, or coal; or renewable materials, such as wood or water. Both renewable and non-renewable materials can be composed of virgin or recycled input materials	GRI 101: Materials	N/A
Environmental Compliance	Refers to an organization's compliance with environmental laws and/or regulations. This includes compliance with international declarations, conventions and treaties, as well as national, sub-national, regional, and local regulations	GRI 2-27: Compliance with laws and regulations	N/A
SOCIAL
Occupational Health and Safety	Prevention of physical or mental harm to workers, safety audits, tracking incident rates, and COVID-19 mitigation	GRI 403: Occupational Health and Safety	IF-EU-320a
Training and Education	An organization's approach to training and upgrading employee skills, performance/career development reviews	GRI 404: Training and Education	N/A
Diversity and Equal Opportunity	An organization's approach to diversity and equal opportunity at work to promote social equality	GRI 405: Diversity and Equal Opportunity	N/A
Human Rights	Due diligence covering employee training on human rights policies, labor relations, and respecting stakeholder rights	GRI 2-23: Policy commitments GRI 408: Child Labor GRI 409: Forced or Compulsory Labor GRI 411: Rights of Indigenous Peoples	N/A
Local Communities	Engagement and impact assessments on individuals living or working in areas affected by the organization	GRI 413: Local Communities	N/A
Employment	An organization's approach to employment or job creation, including hiring, recruitment, retention, and the working conditions it provides	GRI 401: Employment	N/A
Labor/Management Relations	An organization's approach and practices with employees and their representatives, including its approach to communicating significant operational changes	GRI 402: Labor/ Management Relations	N/A
Supplier Social Assessment	Due diligence expected of an organization to prevent, mitigate, and address actual and potential negative social impacts (such as human rights or labor issues) within its supply chain	GRI 414: Supplier Social Assessment	N/A
Customer Health and Safety	An organization's systematic efforts to address health and safety across the life cycle of a product or service, and its adherence to customer health and safety regulations	GRI 416: Customer Health and Safety	N/A
Stakeholder Engagement	The ongoing process of understanding, taking into account, and responding to the legitimate needs and interests of key stakeholders	GRI 2-29	N/A
Power Supply Resilience	Managing the hours of planned/forced outages and ensuring the physical/cybersecurity protection of the grid	No specific GRI topic Standard	IF-EU-550a
GOVERNANCE / ECONOMIC
Market Presence	An organization's contribution to economic development in local areas (e.g., remuneration or local hiring)	GRI 202: Market Presence	N/A
Indirect Economic Impacts	The positive and negative impacts of an organization's infrastructure investments and services supported	GRI 203: Indirect Economic Impacts	N/A
Tax	Approach to regulatory compliance and how tax strategy ensures responsible tax payments for nation-building	GRI 207: Tax	N/A
Sustainable Finance	The process of taking ESG considerations into account when making investment decisions	No specific GRI topic Standard	N/A
Anti-corruption	Prevention of fraud/bribery and support for political advantage, and policymaker fair commercial transactions	GRI 205: Anti-corruption	N/A
Economic Performance	Generating direct economic value, revenues, and net income to sustain the business model and create wealth for stakeholder	GRI 201: Economic Performance	N/A
Innovation	Implementing new business processes, innovations, and digital transformation initiatives to benefit business units and improve sustainability	No specific GRI topic Standard	N/A
Corporate Governance	The oversight structure, policies, and expertise of the highest governance body that enables the organization to create value ethically	GRI 2-9 to 2-22	N/A
Risk Management	Preventing operational disruptions, mitigating critical enterprise risks, and managing systemic impacts on resources and processes	GRI 2-10 Role of the highest governance body in overseeing the management of impacts GRI 2-12 Role of the highest governance body in sustainability for overseeing impacts	N/A
Data Privacy	Managing incidents of non-compliance with physical and cybersecurity standards, and protecting the fundamental right to data protection	GRI 418: Customer Privacy	N/A

FIRST GEN
MATERIAL TOPIC

DEFINITION OF MATERIAL TOPIC

GRI TOPIC STANDARD

SASB
(Electric Utilities)

ENVIRONMENT

Climate Action

Management of impacts, risks, and opportunities associated with climate change and the transition to a lower-carbon economy

GRI 102: Climate Change

IF-EU-110a

Emissions

Gross direct (Scope 1), energy indirect (Scope 2), and other indirect (Scope 3) emissions of the seven constituent greenhouse gases

GRI 102: Climate Change

IF-EU-110a

Biodiversity

Protection and restoration of habitats, species conservation, and managing significant impacts on natural ecosystems

GRI 304: Biodiversity

Implicit in Ecological Impacts

Water and Effluents

Managing water withdrawal, discharge, consumption, and compliance with water quality regulations

GRI 303: Water and Effluents

IF-EU-140a

Waste

Managing the total waste generated, diverted from disposal, and treated

GRI 306: Waste

IF-EU-150a

Energy

Managing energy consumption within the organization, generation efficiency, and customer electricity savings

GRI 103: Energy

IF-EU-110a
IF-EU-420a

Materials

Inputs used to manufacture and package an organization's products and services can be non-renewable materials, such as minerals, metals, oil, gas, or coal; or renewable materials, such as wood or water. Both renewable and non-renewable materials can be composed of virgin or recycled input materials

GRI 101: Materials

N/A

Environmental Compliance

Refers to an organization's compliance with environmental laws and/or regulations. This includes compliance with international declarations, conventions and treaties, as well as national, sub-national, regional, and local regulations

GRI 2-27: Compliance with laws and regulations

N/A

SOCIAL

Occupational Health and Safety

Prevention of physical or mental harm to workers, safety audits, tracking incident rates, and COVID-19 mitigation

GRI 403: Occupational Health and Safety

IF-EU-320a

Training and Education

An organization's approach to training and upgrading employee skills, performance/career development reviews

GRI 404: Training and Education

N/A

Diversity and Equal Opportunity

An organization's approach to diversity and equal opportunity at work to promote social equality

GRI 405: Diversity and Equal Opportunity

N/A

Human Rights

Due diligence covering employee training on human rights policies, labor relations, and respecting stakeholder rights

GRI 2-23: Policy commitments
GRI 408: Child Labor
GRI 409: Forced or Compulsory Labor
GRI 411: Rights of Indigenous Peoples

N/A

Local Communities

Engagement and impact assessments on individuals living or working in areas affected by the organization

GRI 413: Local Communities

N/A

Employment

An organization's approach to employment or job creation, including hiring, recruitment, retention, and the working conditions it provides

GRI 401: Employment

N/A

Labor/Management Relations

An organization's approach and practices with employees and their representatives, including its approach to communicating significant operational changes

GRI 402: Labor/ Management Relations

N/A

Supplier Social Assessment

Due diligence expected of an organization to prevent, mitigate, and address actual and potential negative social impacts (such as human rights or labor issues) within its supply chain

GRI 414: Supplier Social Assessment

N/A

Customer Health and Safety

An organization's systematic efforts to address health and safety across the life cycle of a product or service, and its adherence to customer health and safety regulations

GRI 416: Customer Health and Safety

N/A

Stakeholder Engagement

The ongoing process of understanding, taking into account, and responding to the legitimate needs and interests of key stakeholders

GRI 2-29

N/A

Power Supply Resilience

Managing the hours of planned/forced outages and ensuring the physical/cybersecurity protection of the grid

No specific GRI topic Standard

IF-EU-550a

GOVERNANCE / ECONOMIC

Market Presence

An organization's contribution to economic development in local areas (e.g., remuneration or local hiring)

GRI 202: Market Presence

N/A

Indirect Economic Impacts

The positive and negative impacts of an organization's infrastructure investments and services supported

GRI 203: Indirect Economic Impacts

N/A

Tax

Approach to regulatory compliance and how tax strategy ensures responsible tax payments for nation-building

GRI 207: Tax

N/A

Sustainable Finance

The process of taking ESG considerations into account when making investment decisions

No specific GRI topic Standard

N/A

Anti-corruption

Prevention of fraud/bribery and support for political advantage, and policymaker fair commercial transactions

GRI 205: Anti-corruption

N/A

Economic Performance

Generating direct economic value, revenues, and net income to sustain the business model and create wealth for stakeholder

GRI 201: Economic Performance

N/A

Innovation

Implementing new business processes, innovations, and digital transformation initiatives to benefit business units and improve sustainability

No specific GRI topic Standard

N/A

Corporate Governance

The oversight structure, policies, and expertise of the highest governance body that enables the organization to create value ethically

GRI 2-9 to 2-22

N/A

Risk Management

Preventing operational disruptions, mitigating critical enterprise risks, and managing systemic impacts on resources and processes

GRI 2-10 Role of the highest governance body in overseeing the management of impacts
GRI 2-12 Role of the highest governance body in sustainability for overseeing impacts

N/A

Data Privacy

Managing incidents of non-compliance with physical and cybersecurity standards, and protecting the fundamental right to data protection

GRI 418: Customer Privacy

N/A

GRI Content Index

Statement of use	First Gen Corporation has reported the information cited in this GRI content index for the period January 1 to December 31, 2025 with reference to the GRI Standards.
GRI 1 used	GRI 1: Foundation 2021

GRI STANDARD	DISCLOSURE	LOCATION
GRI 2: General Disclosures 2021	2-1 Organizational details	6
2-2 Entities included in the organization's sustainability reporting	7, 46 to 47
2-3 Reporting period, frequency and contact point	6, 9, 11
2-4 Restatements of information	258
2-6 Activities, value chain, and other business relationships	36, 38 to 40, 42 to 45, 175
2-7 Employees	151
2-9 Governance structure and composition	69, 72 to 75, 232 to 237
2-10 Nomination and selection of the highest governance body	73
2-11 Chair of the highest governance body	11, 69, 232
2-12 Role of the highest governance body in overseeing the management of impacts	67 to 69, 75, 84
2-13 Delegation of responsibility for managing impacts	69, 86 to 89
2-14 Role of the highest governance body in sustainability reporting	7, 11
2-15 Conflicts of interest	70, 73
2-16 Communication of critical concerns	69, 86, 172, 218
2-17 Collective knowledge of the highest governance body	72
2-18 Evaluation of the performance of the highest governance body	67, 73
2-19 Remuneration policies	73, 158
2-20 Process to determine remuneration	73, 158
2-21 Statement on sustainable development strategy	20 to 25
2-22 Policy commitments	70 to 71, 127, 142, 208, 215
2-24 Embedding policy commitments	67, 167, 188
2-25 Processes to remediate negative impacts	157, 172, 208
2-26 Mechanisms for seeking advice and raising concerns	70, 157, 172
2-27 Compliance with laws and regulations	105, 127, 148, 160, 172
2-28 Membership associations	189
2-29 Approach to stakeholder engagement	58, 172 to 173
GRI 3: Material Topics 2021	3-1 Process to determine material topics	9, 54 to 57, 58, 60
3-2 List of material topics	54, 61 to 63, 248 to 251
3-3 Management of material topics	54, 61 to 63, 111, 115, 126 to 127, 150, 156, 161, 169
GRI 101: Climate Change 2025	102-1 Transition plan for climate change mitigation	77 to 78, 114, 127, 131, 224
102-2 Climate change adaptation plan	94 to 95, 211
102-3 Just transition	152 to 153, 155, 172 to 173
102-4 GHG emissions reduction targets and progress	104, 132, 224
102-5 Scope 1 GHG emissions	128 to 129, 195
102-6 Scope 2 GHG emissions	128 to 129, 195
102-7 Scope 3 GHG emissions	128 to 129, 195
102-8 GHG emissions intensity	129, 158
102-9 GHG removals in the value chain	132
102-10 Carbon credits	145
GRI 302: Energy 2016	103-1 Energy policies and commitments	127, 133
103-2 Energy consumption and self generation within the organization	134
103-3 Energy consumption from energy consumption	129
103-5 Reduction in energy consumption	131, 133, 210
GRI 201: Economic Performance 2016	201-1 Direct economic value generated and distributed	109
201-2 Financial implications and other risks and opportunities due to climate change	94 to 95, 103
201-3 Defined benefit plan obligations and other retirement plans	158, 203
GRI 202: Market Presence 2016	202-1 Ratios of standard entry-level wage by gender compared to local minimum wage	158
202-2 Proportion of senior management hired from the local community	151
GRI 203: Indirect Economic Impacts 2016	203-1 Infrastructure investments and services supported	171, 177 to 187
203-2 Significant indirect economic impacts	177 to 180
GRI 204: Procurement Practices 2016	204-1 Proportion of spending on local suppliers	188
GRI 205: Anti-corruption 2016	205-1 Operations assessed for risks related to corruption	70, 105, 218
205-2 Communication and training about anti-corruption policies and procedures	70, 218
205-3 Confirmed incidents of corruption and actions taken	105, 218
GRI 207: Tax 2019	207-1 Approach to tax	113
207-2 Tax governance, control, and risk management	113
207-3 Stakeholder engagement and management of concerns related to tax	113
207-4 Country-by-country reporting	113
GRI 301: Materials 2016	301-1 Materials used by weight or volume	77 to 78, 94 to 95, 114, 127, 131, 211, 224
GRI 303: Water and Effluents 2018	303-1 Interactions with sector as a shared resource	133, 148, 210
303-2 Management of water discharge-related impacts	133, 136 to 139
303-3 Water withdrawal	134 to 135
303-4 Water discharge	134 to 135
303-5 Water consumption	136
GRI 304: Biodiversity 2016	304-1 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas	143 to 144
304-2 Significant impacts of activities, products and services on biodiversity	143 to 146
304-3 Habitats protected or restored	146, 193
Disclosure 304-4 IUCN Red List species and national conservation list species with habitats in areas affected by operations	146 to 147
GRI 306: Waste 2020	306-1 Waste generation and significant waste-related impacts	140 to 142
306-2 Management of significant waste-related impacts	140 to 142, 200
306-3 Waste generated	140 to 142
306-4 Waste diverted from disposal	140 to 141
306-5 Waste directed to disposal	140 to 141
GRI 308: Supplier Environmental Assessment 2016	308-1 New suppliers that were screened using environmental criteria	188
308-2 Negative environmental impacts in the supply chain and actions taken	188
GRI 401: Employment 2016	401-1 New employee hires and employee turnover	152 to 153
401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees	156, 158, 204
401-3 Parental leave	156, 215
GRI 403: Occupational Health and Safety 2018	403-1 Occupational health and safety management system	158, 161
403-2 Hazard identification, risk assessment, and incident investigation	158
403-3 Occupational health services	159, 206
403-4 Worker participation, consultation, and communication on occupational health and safety	158 to 159
403-5 Worker training on occupational health and safety	159
403-6 Promotion of worker health	157, 159, 205 to 206
403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships	159, 188, 191
403-8 Workers covered by an occupational health and safety management system	158, 167
403-9 Work-related injuries	105, 160
403-10 Work-related ill health	160, 205
GRI 404: Training and Education 2016	404-1 Average hours of training per year per employee	155
404-2 Programs for upgrading employee skills and transition assistance programs	155, 161
404-3 Percentage of employees receiving regular performance and career development reviews	154 to 155, 158
GRI 405: Diversity and Equal Opportunities 2016	405-1 Diversity of governance bodies and employees	153
405-2 Ratio of basic salary and remuneration of women to men	158
GRI 406: Non-discrimination 2016	406-1 Incidents of discrimination and corrective actions taken	157, 208
GRI 408: Child Labour 2016	408-1 Operations and suppliers at significant risk for incidents of child labour	16, 105, 157
GRI 409: Forced or Compulsory Labour 2016	409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labour	105, 157
GRI 411: Rights of Indigenous Peoples 2016	411-1 Incidents of violations involving rights of indigenous peoples	70, 181, 183, 215
GRI 413: Local Communities 2016	413-1 Operations with local community engagement, impact assessments, and development programs	172, 177 to 180, 184 to 189
413-2 Operations with significant actual and potential negative impacts on local communities	173, 177 to 186
GRI 414: Supplier Social Assessment 2016	414-1 New suppliers that were screened using social criteria	188
414-2 Negative social impacts in the supply chain and actions taken	188
GRI 416: Customer Health and Safety 2016	416-1 Assessment of the health and safety impacts of product and service categories	59
416-2 Incidents of non-compliance concerning the health and safety impacts of products and services	59
GRI 418: Customer Privacy and Services 2016	418-1 Substantiated complaints concerning breaches of customer privacy and breaches of customer data	189, 218

GRI STANDARD

DISCLOSURE

LOCATION

GRI 2: General Disclosures 2021

2-1 Organizational details

2-2 Entities included in the organization's sustainability reporting

7, 46 to 47

2-3 Reporting period, frequency and contact point

6, 9, 11

2-4 Restatements of information

258

2-6 Activities, value chain, and other business relationships

36, 38 to 40, 42 to 45, 175

2-7 Employees

151

2-9 Governance structure and composition

69, 72 to 75, 232 to 237

2-10 Nomination and selection of the highest governance body

2-11 Chair of the highest governance body

11, 69, 232

2-12 Role of the highest governance body in overseeing the management of impacts

67 to 69, 75, 84

2-13 Delegation of responsibility for managing impacts

69, 86 to 89

2-14 Role of the highest governance body in sustainability reporting

7, 11

2-15 Conflicts of interest

70, 73

2-16 Communication of critical concerns

69, 86, 172, 218

2-17 Collective knowledge of the highest governance body

2-18 Evaluation of the performance of the highest governance body

67, 73

2-19 Remuneration policies

73, 158

2-20 Process to determine remuneration

73, 158

2-21 Statement on sustainable development strategy

20 to 25

2-22 Policy commitments

70 to 71, 127, 142, 208, 215

2-24 Embedding policy commitments

67, 167, 188

2-25 Processes to remediate negative impacts

157, 172, 208

2-26 Mechanisms for seeking advice and raising concerns

70, 157, 172

2-27 Compliance with laws and regulations

105, 127, 148, 160, 172

2-28 Membership associations

189

2-29 Approach to stakeholder engagement

58, 172 to 173

GRI 3: Material Topics 2021

3-1 Process to determine material topics

9, 54 to 57, 58, 60

3-2 List of material topics

54, 61 to 63, 248 to 251

3-3 Management of material topics

54, 61 to 63, 111, 115, 126 to 127, 150, 156, 161, 169

GRI 101: Climate Change 2025

102-1 Transition plan for climate change mitigation

77 to 78, 114, 127, 131, 224

102-2 Climate change adaptation plan

94 to 95, 211

102-3 Just transition

152 to 153, 155, 172 to 173

102-4 GHG emissions reduction targets and progress

104, 132, 224

102-5 Scope 1 GHG emissions

128 to 129, 195

102-6 Scope 2 GHG emissions

128 to 129, 195

102-7 Scope 3 GHG emissions

128 to 129, 195

102-8 GHG emissions intensity

129, 158

102-9 GHG removals in the value chain

132

102-10 Carbon credits

145

GRI 302: Energy 2016

103-1 Energy policies and commitments

127, 133

103-2 Energy consumption and self generation within the organization

134

103-3 Energy consumption from energy consumption

129

103-5 Reduction in energy consumption

131, 133, 210

GRI 201: Economic Performance 2016

201-1 Direct economic value generated and distributed

109

201-2 Financial implications and other risks and opportunities due to climate change

94 to 95, 103

201-3 Defined benefit plan obligations and other retirement plans

158, 203

GRI 202: Market Presence 2016

202-1 Ratios of standard entry-level wage by gender compared to local minimum wage

158

202-2 Proportion of senior management hired from the local community

151

GRI 203: Indirect Economic Impacts 2016

203-1 Infrastructure investments and services supported

171, 177 to 187

203-2 Significant indirect economic impacts

177 to 180

GRI 204: Procurement Practices 2016

204-1 Proportion of spending on local suppliers

188

GRI 205: Anti-corruption 2016

205-1 Operations assessed for risks related to corruption

70, 105, 218

205-2 Communication and training about anti-corruption policies and procedures

70, 218

205-3 Confirmed incidents of corruption and actions taken

105, 218

GRI 207: Tax 2019

207-1 Approach to tax

113

207-2 Tax governance, control, and risk management

113

207-3 Stakeholder engagement and management of concerns related to tax

113

207-4 Country-by-country reporting

113

GRI 301: Materials 2016

301-1 Materials used by weight or volume

77 to 78, 94 to 95, 114, 127, 131, 211, 224

GRI 303: Water and Effluents 2018

303-1 Interactions with sector as a shared resource

133, 148, 210

303-2 Management of water discharge-related impacts

133, 136 to 139

303-3 Water withdrawal

134 to 135

303-4 Water discharge

134 to 135

303-5 Water consumption

136

GRI 304: Biodiversity 2016

304-1 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas

143 to 144

304-2 Significant impacts of activities, products and services on biodiversity

143 to 146

304-3 Habitats protected or restored

146, 193

Disclosure 304-4 IUCN Red List species and national conservation list species with habitats in areas affected by operations

146 to 147

GRI 306: Waste 2020

306-1 Waste generation and significant waste-related impacts

140 to 142

306-2 Management of significant waste-related impacts

140 to 142, 200

306-3 Waste generated

140 to 142

306-4 Waste diverted from disposal

140 to 141

306-5 Waste directed to disposal

140 to 141

GRI 308: Supplier Environmental Assessment 2016

308-1 New suppliers that were screened using environmental criteria

188

308-2 Negative environmental impacts in the supply chain and actions taken

188

GRI 401: Employment 2016

401-1 New employee hires and employee turnover

152 to 153

401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees

156, 158, 204

401-3 Parental leave

156, 215

GRI 403: Occupational Health and Safety 2018

403-1 Occupational health and safety management system

158, 161

403-2 Hazard identification, risk assessment, and incident investigation

158

403-3 Occupational health services

159, 206

403-4 Worker participation, consultation, and communication on occupational health and safety

158 to 159

403-5 Worker training on occupational health and safety

159

403-6 Promotion of worker health

157, 159, 205 to 206

403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

159, 188, 191

403-8 Workers covered by an occupational health and safety management system

158, 167

403-9 Work-related injuries

105, 160

403-10 Work-related ill health

160, 205

GRI 404: Training and Education 2016

404-1 Average hours of training per year per employee

155

404-2 Programs for upgrading employee skills and transition assistance programs

155, 161

404-3 Percentage of employees receiving regular performance and career development reviews

154 to 155, 158

GRI 405: Diversity and Equal Opportunities 2016

405-1 Diversity of governance bodies and employees

153

405-2 Ratio of basic salary and remuneration of women to men

158

GRI 406: Non-discrimination 2016

406-1 Incidents of discrimination and corrective actions taken

157, 208

GRI 408: Child Labour 2016

408-1 Operations and suppliers at significant risk for incidents of child labour

16, 105, 157

GRI 409: Forced or Compulsory Labour 2016

409-1 Operations and suppliers at significant risk for incidents of forced or compulsory labour

105, 157

GRI 411: Rights of Indigenous Peoples 2016

411-1 Incidents of violations involving rights of indigenous peoples

70, 181, 183, 215

GRI 413: Local Communities 2016

413-1 Operations with local community engagement, impact assessments, and development programs

172, 177 to 180, 184 to 189

413-2 Operations with significant actual and potential negative impacts on local communities

173, 177 to 186

GRI 414: Supplier Social Assessment 2016

414-1 New suppliers that were screened using social criteria

188

414-2 Negative social impacts in the supply chain and actions taken

188

GRI 416: Customer Health and Safety 2016

416-1 Assessment of the health and safety impacts of product and service categories

416-2 Incidents of non-compliance concerning the health and safety impacts of products and services

GRI 418: Customer Privacy and Services 2016

418-1 Substantiated complaints concerning breaches of customer privacy and breaches of customer data

189, 218

SASB Content Index

The following table shows the main indicators required by the Value Reporting Foundation—SASB Standard for First Gen’s primary sector of reference: Infrastructure, specifically the Electric Utilities & Power Generators Sector. The table shows, where present, the reference to the GRI disclosure with which the disclosure required by SASB was covered as well as references to the pages of the 2025 First Gen Integrated Report.

CODE	ACCOUNTING METRIC	2025	2024	2023	GRI STANDARDS
GREENHOUSE GAS EMISSIONS AND ENERGY RESOURCE PLANNING
IF-EU-110a.1	(1) Gross global scope 1 emissions (MtCO2eq)	102	5.33	8.97	102-5
	(2) Percentage covered under emissions-limiting regulations (%)	Not applicable. The company is not operating under any emissions-limiting or reporting regulation.
	(3) Percentage covered under emissions-reporting regulations (%)
IF-EU-110a.2	Greenhouse gas (GHG) emissions associated with power deliveries	Not applicable. The company is not involved in the transmission business.			-
IF-EU-110a.3	Description of long-term and short-term strategy or plan to manage scope 1 emissions, emission reduction targets, and an analysis of performance v. those targets	Refer to pages 77 to 78, 123 to 124, 127 to 128, 224 of the 2025 IR	Refer to pages 82 to 101 and 129 to 131 of the 2024 IR	Refer to pages 76 to 77, 109 to 110, 89 to 90, 127 to 128 of the 2023 IR	201-2
AIR QUALITY
IF-EU-120a.1	Air emissions of the following pollutants: (1) NOx (excluding N₂O) [Mt]	0.0	2,524.82	3,476.49	305-7
	(2) SOx [Mt]	0.0	282.83	237.40
	(3) particulate matter (PM10) [Mt]	0.0	147.88	204.04
	(4) lead (Pb) [Mt]	0.0	0.00	0.00
	(5) mercury (Hg) [Mt]	0.0	0.00	0.00
	(6) Percentage of each in or near areas of dense population	0.00%	100.00%	100.00%
WATER MANAGEMENT
IF-EU-140a.1	(1) Total water withdrawn (Mm³)	3,482.24	3,290.27	2,553.39	303-3a
	(2) Total water consumed (Mm³)	4.74	20.84	2.15	303-5a
	(3) percentage of each in regions with High or Extremely High Baseline Water Stress (%)	0.00%	0.00%	0.00%	303-3b
IF-EU-140a.2	Number of incidents of non-compliance associated with water quantity and/or quality permits, standards and regulations	0	0	0	303-2 2-27
IF-EU-140a.3	Description of water management risks and discussion of strategies and practices to mitigate those risks	Refer to pages 94 to 95, 133 to 135, 137 to 138 of the 2025 IR	Refer to pages 138 to 140, 146 to 147, and 223 of the 2024 IR	Refer to pages 182 to 183 of the 2023 IR	303-1
COAL ASH MANAGEMENT
IF-EU-150a.1	(1) Amount of coal combustion residuals (CCR) generated (Mt)	Not applicable. The company does not own any coal plant.			306-3
IF-EU-150a.1	(2) Percentage recycled (%)				306-4
IF-EU-150a.2	Total number of coal combustion residual (CCR) impoundments, broken down by hazard potential				-
ENERGY AFFORDABILITY
IF-EU-240a.1	Average electric rate for customers	The retail electricity rate is subject to approval by the Energy Regulatory Commission.			-
IF-EU-240a.2	Typical monthly electric bill for residential customers for (1) 500 kWh and (2) 1000 kWh of electricity delivered per month				-
IF-EU-240a.3	(1) Number of residential customer electric disconnections for non-payment	Not applicable. The Company is not involved in the distribution business of residential customers.			EU27
IF-EU-240a.3	(2) percentage reconnected within 30 days
IF-EU-240a.4	Discussion of impact of external factors on customer affordability of electricity, including the economic conditions of the service territory				DMA-EU (former EU7) DMA-EU (former EU28)
WORKFORCE HEALTH AND SAFETY
IF-EU-320a.1	(1) Total recordable incident rate (TRIR)	0.35	0.38	0.18	403-9
	(2) Fatality rate	0.00	0.03	0.14
	(3) Near miss frequency rate (NMFR)	0.46	0.69	0.30
END-USE EFFICIENCY AND DEMAND
IF-EU-420a.1	Percentage of electric utility revenues from rate structures that (1) are decoupled and (2) contain a lost revenue adjustment mechanism (LRAM)	Not Applicable. The energy accounting mechanism implemented in the Philippines. We have, however, Renewable Energy and Conservation (RECON) Program mandated under Republic Act No 11285) which institutionalizes energy efficiency and conservation, the efficient use of energy, and grants incentives to energy efficiency, conservation, and sufficiency projects. Through PJ Energy Phils., supports the RECON by offering energy efficiency audit and energy efficiency advisory services by qualified technical staff. One output of this initiative is formulating Energy Management Plan which includes baseline assessments, estimated energy savings based on the efficiency measures that can be part of an energy management plan to be implemented by its customers to improve their energy performance.			-
IF-EU-420a.2	Percentage of electric load served by smart grid technology	Not Applicable. First Gen does not offer smart grid technology.			-
IF-EU-420a.3	Customer electricity savings from efficiency measures, by market (MWh)	Not Applicable. We can only determine the estimated total kWh savings of the customers.			-
NUCLEAR SAFETY AND EMERGENCY MANAGEMENT
IF-EU-540a.1	Total number of nuclear power units, broken down by results of most recent independent safety review	0	0	0	DMA-EU (former EU21)
IF-EU-540a.2	Description of efforts to manage nuclear safety and emergency preparedness	Not applicable. The Company does not own any nuclear plant.			-
GRID RESILIENCY
IF-EU-550a.1	Number of incidents of non-compliance with physical or cybersecurity standards or regulations	0	0	0	-
IF-EU-550a.2	(1) System Average Interruption Duration Index (SAIDI)	Not applicable. The company is not involved in the distribution business.			EU28
	(2) System Average Interruption Frequency Index (SAIFI)				EU29
	(3) Customer Average Interruption Duration Index (CAIDI), inclusive of major event days				-

CODE	ACTIVITY METRIC	2025	2024	2023	GRI STANDARDS
IF-EU-000.A	Number of customers served: (1) Residential	0	0	0	EU3
	(2) Commercial	0	0	0
	(3) Industrial	0	0	0
	(4) All other retail customers	245	199	182
	(5) Wholesale customers	23	26	23
IF-EU-000.B	Total electricity (MWh) delivered to: (1) Residential	0	0	0	-
	(2) Commercial	0	0	0	-
	(3) Industrial	0	0	0	-
	(4) All other retail customers	4,664,206.34	14,537,341.63	-	-
	(5) Wholesale customers	4,664,206.34	14,537,341.63	-	-
IF-EU-000.C	Length of transmission and distribution lines (km)	Not applicable. The Company is not involved in the transmission and distribution business.			EU 4
IF-EU-000.D	Total electricity generated (MWh)	8,319,870.00	18,293,360.00	21,570,800.00	EU2
	Energy Source	% of Total Energy Generated
	Natural Gas	0.00	58.28	64.45
	Hydro	12.92	3.51	1.21
	Geothermal	83.62	36.63	32.59
	Wind	3.33	1.50	1.69
	Solar	0.14	0.07	0.07
IF-EU-000.E	Total wholesale electricity purchased (MWh)	145,024.70	212,182.15	-	-