Environmental
review

SASB EM‑MM‑160a.1, RT‑CH‑410b.2

At PhosAgro Group, we attach much importance to environmental protection and safety, as well as climate risk management. Proper focus on all of these areas helps secure the Company’s sustainable development and well‑being of the regions across its geography. Our Strategy to 2025 and Environmental Policy incorporate provisions to ensure strict compliance with statutory environmental requirements and minimise the environmental impact of the Company’s operations across the entire fertilizer lifecycle, from ore mining to food production. We conducted a comprehensive assessment of our activities, identifying the main areas of environmental impact, both direct and indirect. We then correlated these findings with the UN SDGs and Russia's national development goals. Based on this analysis, we mapped out six strategic focus areas of environmental protection:

We believe that our requirements should be uniform both for us and our partners engaged in PhosAgro’s projects. Everything we require of ourselves equally applies to our counterparties and is enshrined in the Code of Conduct for Counterparties.

GRI 3‑3, 101‑1

Environmental stewardship has always been a core priority for PhosAgro Group. We operate in regions with fragile and unique ecosystems, and safeguarding their sustainable natural integrity is our unwavering commitment. Our operations undergo a stringent assessment for compliance with the Environmental Policy and the Company’s internal regulations.

Environmental management system

Our environmental management system is integrated in the Company’s overall management framework and is a key element in our approach to managing environmental responsibility.

In 2022, the environmental management system passed a recertification audit across the Company’s production sites and was found to be in full compliance with ISO 14001. In 2024, it successfully underwent an inspection audit under the same standard.

PhosAgro’s environmental management system embraces all management levels and all stages of the product’s life‑cycle, from R&D to manufacturing and finished product application by customers. This approach ensures uniform management requirements across all aspects of the Company’s operations.

The facilities have also put in place a procedure to manage internal audits. Every year, they develop internal audit programmes taking into account the environmental significance of the reviewed processes, changes affecting the facility and previous audit outcomes. The audits provide input data for the Company’s management to analyse environmental management efficiency.

Compliance with statutory and regulatory requirements

Environmental compliance is key to running a responsible business.

PhosAgro Group’s environmental management practices ensure our compliance with the applicable environmental and nature conservation regulations and regulators’ decrees. To that end, the Company has in place an internal and external control framework, which includes internal audit and external compliance reviews, a reporting system designed in accordance with legislative requirements, and a staff training system.

All our facilities that have an adverse environmental impact are included in dedicated state registers, with relevant categories assigned to them. PhosAgro has all necessary permits in place for each of these facilities.

None of PhosAgro’s enterprises uses ozone‑depleting substances in the production process. A small amount (not more than 250 kg/year) of carbon tetrachloride (CCl4) is used in laboratory testing.

We do not undertake cross‑border hazardous waste transportation and our production sites are not situated in protected areas. Hence, there are no significant restrictions on our operations.

The Company takes steps to remedy the harm caused by an emergency in 2019 by committing RUB 3,002,000 to the reproduction of aquatic biological resources in 2024.

In 2024, our environmental investments in fixed assets increased, driven among other things by the upgrade of absorption systems at the Balakovo branch and the establishment of dry phosphogypsum storage at the Cherepovets site, while current environmental protection expenditures also rose.

No audits of Apatit by local bodies of Rosprirodnadzor were held in 2024. There were no administrative proceedings involving the Company, and hence no fines.

The reduction in the Company's environmental impact payments was associated with decreased phosphogypsum disposal in waste facilities, achieved through its expanded application as a construction material at both the Cherepovets and Balakovo sites.

In 2024, over‑limit payments accounted for 0.036% of total environmental impact payments (vs 0.86% in 2023). They resulted from exceeding the permissible emission limit for nitrogen oxides by one of the emission sources at the Cherepovets facility.

Assessment, analysis, and monitoring

Continuous improvement is inherent in our environmental management. The Company identifies areas for improvement in its environmental management by reviewing its management system using an effective mechanism, which combines external and internal audits, and performance monitoring and evaluation, including those by a wide range of stakeholders, with the review findings analysed and assessed by the Company’s management. These efforts enable us to work out corrective action plans and proposals on how to develop and improve the system.

When assessing the Company’s performance, much attention is paid to the analysis of ESG ratings and investor feedback.

SASB RT‑CH‑110a.2 / EM‑MM‑110a.2

PhosAgro Group has LEAD status under the UN Global Compact and is a participant of the Climate Ambition initiative.

Starting 2021, the Company has been making annual climate disclosures in line with the TCFD logic and starting 2023, with key requirements of the new IFRS S2, which enables the most thorough disclosure of the climate‑related aspects of PhosAgro Group’s strategy, risks and opportunities, management approach, results, and indicators.

The Company’s representatives are members of climate change and sustainable development task and expert groups instituted by government authorities and non‑governmental organisations, and are actively engaged in discussions on current global challenges.

Strategy and management approach

GRI 3‑3

The Company focuses on climate change in line with the double materiality principle: on the one hand, it identifies and assesses the impact of its operations on climate all along the value chain from extraction of raw materials to consumption of finished products. On the other hand, it projects how climate change affects PhosAgro’s business, strategy, and financial planning.

Climate matters feature prominently in PhosAgro’s strategic and investment decisions, as well as in its day‑to‑day management. In our evaluation of investment projects, we use internal carbon price mechanisms. The Company has identified, assessed, and prioritised climate risks, establishing their short, medium and long term consequences for its production and business processes. We make our strategic plans and day‑to‑day management decisions with full awareness of the nature and extent of climate impact (both environmental and political) on the Company’s business, strategy, and financial planning. The Group develops and takes consistent steps to reduce its carbon footprint and closely interacts with partners across its value chain (suppliers and consumers) and other stakeholders domestically and worldwide.

PhosAgro’s Climate Strategy was adopted in 2020. It is a comprehensive document setting out the Company’s climate policy in the face of growing climate change and uncertainty.

Main principles of PhosAgro Group’s Climate Strategy:

• setting up targets to reduce GHG emissions in line with the Science Based Targets initiative; using climate scenario analysis;
• integrating climate risks into the comprehensive risk management framework for investment and day‑to‑day business activities;
• utilising technology‑related measures along with proper organisation and management, as well as sound social and personnel policy, to reduce GHG emissions;
• identifying not only risks, but also attractive climate‑related investment opportunities and making long‑term plans for them;
• promoting awareness of the Company’s climate initiatives and plans, as well as cooperation in specific areas;
• engaging stakeholders to reduce GHG emissions along the value chain.

The Climate Strategy has set the following goals:

• to minimise GHG emissions while increasing output;
• to improve energy efficiency and environmental performance of the key production processes;
• to reduce energy and carbon intensity per unit of output;
• to develop innovative fertilizers and efficient plant nutrition systems to reduce Scope 3 GHG emissions from the use of fertilizers by farmers;
• to enter into new emerging markets for green products;
• to retain and expand the existing market niches by ensuring PhosAgro Group’s competitive edge in terms of energy and carbon intensity.

The Company is currently focused on creating particular metrics reflecting the impact of climate action in production and management processes on financial indicators. To that end, we assessed the impact of the carbon border adjustment mechanism (CBAM) on PhosAgro’s operating expenses. The mechanism covers Russian industrial products, including, most likely, mineral fertilizers. In 2024, a cross‑functional working group refined and automated our product carbon footprint assessment mechanism, among other things to ensure alignment with the CBAM requirements. The mechanism underwent evaluation by international consultants, and its methodology was validated. The mechanism helps measure carbon footprint per each tonne of fertilizer based on a transparent calculation methodology for GHG emissions, which covers production processes and semi‑product flows fully in line with the CBAM guidelines.

Actions to deliver the Climate Strategy

In 2024, we continued to implement the Climate Agenda project aimed at creating the climate action management system and pushing forward the low‑carbon transition plan.

The Company’s experts continued to explore options for absorbing greenhouse gases in order to select the most suitable ones across Group facilities. In 2024, we also launched the Carbon Footprint Compensation project aimed at absorbing (compensating for) GHG emissions, with a carbon footprint compensation farm being set up in the Vologda region.

As a result of our efforts in 2024:

• Methods were developed to calculate the carbon pool of forest sites with a total absorption of 15.98 t of CO₂‑eq. / year, and 5.2 carbon units / ha / year using the CDM methodology. Total sequestration: 20,092 carbon units within 40 years.
• At two 100 ha sites (Rus LLC and the Plemzavod Mayskiy agricultural complex), we tested carbon dioxide sequestration in forage grasses using the Company’s fertilizers, including locally cultivated forage crop varieties.
• We achieved an additional average annual carbon sequestration of 2.6 carbon units / ha with a total accumulation of 13.69 t of CO₂‑eq. / year and an increase in total yield to 11.6%. We acquired experience in using the equipment to estimate carbon gain in ecosystems and the carbon footprint of products.

Risks and opportunities

GRI 201‑2

PhosAgro identifies its climate risks and opportunities based on climate change. The process is influenced by physical (changes in natural processes or phenomena) and transitional factors of various nature (changes in the policy and regulation with a view to fulfilling low‑carbon transition).

Risks

• R1 — disruptions in production processes and logistics operations due to increasing acute climatic effects and other climate‑related factors.
• R2 — flaws in supply chains, construction design, health and safety; negative environmental footprint and reduced flows of ecosystem services; lower resilience of infrastructure and communications due to increasing climatic effects.
• R3 — PhosAgro Group’s failure to comply with regulations reducing its negative environmental footprint (following the adoption of the carbon border adjustment mechanism).
• R4 — deterioration of the Company’s sustainability reputation.
• R5 — increased costs and losses (as a result of customers’ failure to meet their obligations, rising prices for feedstock, materials and services, higher borrowing rates) and shrinking revenues (as a result of a decline in sales, customers, countries and regions of operation).

Opportunities

• O1 — boosting PhosAgro Group’s appeal as an environmentally and climatically responsible supplier of products with a positive climate profile.
• O2 — improved logistics driven by the new export opportunities amid shortened seasonal freeze‑up of rivers and lakes due to climate change.
• O3 — new financial products that open up new sources of cheaper funding (such as green bonds) for companies that embraced environmental and climate sustainability.

As part of our comprehensive risk management framework, we identify, assess, and manage climate risks. Covered value chain stages – direct operations up and down the value chain. Climate risk management process is baked in the company‑wide risk management processes.

Climate scenario analysis

The Company views climate scenario analysis as a tool to make its climate strategy resilient to uncertainties and risks related to climate change. In line with that, we adopted climate scenarios and determined respective scenario parameters that are most probable and significant for the Company in the short, medium, and long term.

PhosAgro Group assessed the impact of climate‑related risks and opportunities on its operations under two climate change scenarios: global warming of 2°С and 4°С. The key features of the scenarios are:

• 2°С scenario is expected to result in stringent climate policy measures that will increase market volatility (goods, services, finances, etc.). This is projected to bring about low‑carbon transition, putting in place mechanisms of a low‑carbon economy that will slow down physical climate‑related impacts going forward;
• 4°С scenario is expected to result in less stringent climate policy measures as compared to the 2°С scenario, triggering faster physical climate‑related changes.

Experts assessed the 2°C scenario as the most probable, hence it was selected as the basis for setting targets, evaluating risks and opportunities, and developing plans under the low‑carbon transition.

PhosAgro identified projected changes in climate risks and opportunities under the adopted climate scenarios based on risks, opportunities, scenario parameters, and time frames. In doing so, the Company focused on its operations, strategy, and financial planning.

Processes to identify and assess climate change risks are being integrated throughout the value chain – from design, procurement and apatite‑nepheline ore mining to finished product delivery.

Key initiatives in 2024

The Company is implementing a set of initiatives designed to achieve the targets of its Climate Strategy.

The Company launched RECSOIL, a joint project aimed at recarbonisation (carbon accumulation in soil) of agricultural lands. The project will not only accumulate carbon but also increase soil resilience to climate change and improve its agrophysical and agronomic characteristics. The project is implemented jointly with UN FAO, Lomonosov Moscow State University, and Kept on the fields of the innovative partner AgroGard. It encompasses developing low‑carbon agricultural practices, conducting detailed agrochemical and soil research with expert organisations, formalising a climate project, and developing standardised (simplified) design documentation for agricultural climate projects.

A new parameter was introduced to refine calculations of our internal carbon price. To complement our existing approach to carbon balance assessment of investment projects, we incorporated the price per tonne of CO₂‑eq. as a parameter, aligned with the EU ETS.

The cost of carbon units was calculated at PhosAgro’s carbon farm in the Vologda region. The estimated cost of carbon units obtained from forest sites is RUB 658 per carbon unit.

The international certification body TÜV AUSTRIA Standards and Compliance conducted verification of our product carbon footprint calculation report.

Metrics and targets

PhosAgro’s climate metrics are aligned with the goals of the Climate Strategy approved by its Board of Directors.

The Company is working to expand and enhance the quality of climate‑related measurements, including both existing and prospective metrics. Most metrics are locked on targets which are aligned with the goals of the Climate Strategy and other commitments of the Company.

The metrics are monitored and reported annually to stakeholders.

The Company’s primary focus is on GHG emissions (carbon dioxide CO₂, methane CH₄ and nitrous oxide N₂O) in all three Scopes (1, 2, and 3). The Company calculates greenhouse gas emissions in accordance with the international guidelines:

• 2006 IPCC (Intergovernmental Panel on Climate Change) Guidelines for National Greenhouse Gas Inventories;
• The Greenhouse Gas Protocol: Scope 2 Guidance;
• The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (Revised Edition);
• ISO 14064‑1 – Specification with Guidance at the Organisation Level for Quantification and Reporting of Greenhouse Gas Emissions and Removals.

Calculations are based on global warming projections of the IPCC report “Climate Change 2021: The Physical Science Basis”.

The Company’s efforts include end‑to‑end monitoring of raw data (Scopes 1, 2, and 3) and analysis of supply chain participants’ data (Scopes 2 and 3).

The targets are set in line with minimum qualitative and quantitative criteria based on RCP 2.6, a representative concentration pathway for reduction of global anthropogenic GHG emissions, in order to keep global temperature rise below 2°C by 2100.

Note

Greenhouse gas emissions were calculated in line with the Guidelines for Climate Impact Management of PJSC PhosAgro and other Group Entities (using the IPCC methodology).

In 2022, we changed our approach to calculating Scope 2 GHG emissions related to electricity consumption. In 2020–2021, the methodology relied on emission factors defined by the International Energy Agency (IEA), while starting 2022, we use the energy indirect GHG emission factor for the First Synchronous Zone of the Russian Energy System defined by the Trading System Administrator of the Wholesale Electricity and Capacity Market.

In 2024, the Company purchased green attribute certificates and used them to fully offset the electricity purchased by the Balakovo and Volkhov branches of Apatit.

The results of the GHG assessment for purchased renewable electricity, using the market‑based method based on the certificate data, align with the results calculated using the location‑based method.

Scope 3 greenhouse gas emissions were calculated for four categories after an expert review identified them to be the most significant emission sources for the Company.

GRI 305‑5

We have chosen 2018 as the base year for calculations because it was the Company’s first GHG inventory year and we needed to set GHG reduction targets for all three scopes based on the available emission data. In 2018, GHG emissions were as follows:

• direct GHG emissions (Scope 1) – 4,624.6 kt of CO₂‑eq.;
• indirect GHG emissions (Scope 2) – 924.1 kt of CO₂‑eq.;
• and other indirect GHG emissions (Scope 3) – 12,634.4The data for comparable periods, including the base year, for the purchased goods and services category have been adjusted due to adjustments to the carbon footprint data for products that the supplier previously provided. kt of CO₂‑eq.

In 2024, per unit GHG emissions (Scope 1) declined by 29.3 kg/t or 19.5% compared to 2018, whereas gross GHG emissions (Scope 1) increased by 2% vs 2018 due to higher production volumes. With adjustments made for the output growth factor, gross emissions decreased by 1,141.1 kt compared to 2018. Improved production efficiency (primarily reduced per unit consumption of natural gas in production processes) and changes in the mix of semi‑finished products used in fertilizer production had the most significant impact on the reduction of emissions, as part of direct emissions related to manufacturing of semi‑finished products decreased due to replacing some of the Company’s own products (for example, ammonia) with third‑party feedstock.

Per unit GHG emissions (Scope 2) declined by 22.3% compared to the baseline year of 2018, while gross GHG emissions (Scope 2) (excluding the output growth factor) decreased by 261.0 kt vs 2018. The reduction was achieved thanks to procurement of green electricity, as well as energy efficiency initiatives.

Gross GHG emissions (Scope 3) increased by 22.5% relative to the baseline year, with per unit emissions down by 3.3%. The key factor affecting the growth in Scope 3 emissions was the increased production volume, which led to more purchases of feedstock and increased emissions from the application of sold products. Excluding the output growth factor, Scope 3 GHG emissions declined by 519,9 kt vs the baseline year due to higher volumes of purchased feedstock and energy and tolling arrangements.

In 2024, we modernised our product carbon footprint data collection process through substantial automation within our Cognos information system. This technical advancement enables plant‑specific carbon footprint calculations across the entire PhosAgro Group, supports more sophisticated factor analysis of changes, and generates required reporting data for the EU CBAM, with our calculation methodology validated during this reporting year.

Our enhanced data capabilities now support deeper analytics into factors driving year‑on‑year carbon footprint changes.

The analysis shows that, despite higher sales volumes, Scope 1 gross emissions in 2024 decreased by 34 kt of CO₂‑eq. (0.7%) y‑o‑y primarily due to the partial replacement of internally produced feedstock and energy with resources purchased from third parties. Production efficiency improvements also had a positive impact, as they helped reduce gas consumption rates and the associated GHG emissions.

In Scope 2, gross emissions grew by 92 kt of CO₂‑eq. (11.4%). Along with higher sales, the most considerable impact on Scope 2 GHG emissions came from increased purchases of energy (electricity) from third parties.

In 2024, Scope 3 gross GHG emissions in the product carbon footprint grew by 705 kt of CO₂‑eq. vs 2023. The main factors contributing to this increase in 2024 were higher sales volumes and associated GHG emissions from the use of products, as well as the rise in per unit GHG emissions from purchased goods, changes in the consumption mix and rates of purchased feedstock, and the sale of products manufactured under tolling arrangements.

In 2024, the share of self‑generated electricity covering the Company’s production facilities reached 37.4%, down slightly compared to 2023. However, with the re‑commissioning of a gas turbine power plant at the Cherepovets production site following repairs, the self‑sufficiency ratio is projected to exceed 40% in 2025.

Going forward, the Company will continue developing in‑house power generation. Construction and installation works have commenced in Balakovo for two gas‑piston power plants (2 MW each) and an 18 MW exhaust gas turbine.

Strategy and management approach

GRI 3‑3, 302‑4

In 2024, the Company continued to follow the Climate Strategy and the Energy Efficiency and Energy Saving Policy approved by the Board of Directors. We reviewed and updated the list of initiatives set out in the Energy Efficiency Programme, which is tightly integrated into the Company’s Strategy to 2025.

The Energy Efficiency and Energy Saving Policy sets out the following key goals:

• continuously improving energy efficiency;
• using energy resources in a sustainable and efficient manner;
• streamlining the energy management process for all types of operating activities.

Key initiatives in 2024

Initiatives planned for 2025

Metrics and highlights

The energy efficiency metrics are used to monitor the Company’s progress towards its energy efficiency improvement target and are set forth in PhosAgro’s Energy Efficiency Programme and Action Plan, which helps keep track of electricity generation and consumption, energy intensity, etc.

The energy efficiency metrics are based on PhosAgro’s raw data and are calculated in accordance with the approved statistical methodologies.

In 2024, self‑generated electricity coverage for the Company’s production assets stood at 37.4%, down from 2023 levels. In absolute terms, in‑house electricity generation decreased by 102.3 mln kWh y‑o‑y due to the unavailability of critical generating equipment from foreign manufacturers impacted by international sanctions against Russia. Total electricity consumption grew by 106.2 mln kWh (2.6%) y‑o‑y, which is attributable to the upgrade of the processing facilities.

In 2024, Apatit used 300 mln kWh of carbon‑free electricity at its production sites. This means that mineral fertilizers supplied by the Volkhov and Balakovo production sites in 2024 were manufactured using exclusively green power purchased from the hydroelectric power plants of TGC‑1.

PhosAgro Group’s energy consumption

GRI 302‑1, 302‑3, SASB RT‑CH‑130a.1 / EM‑MM‑130a.1, MED 22

Strategy and management approach

GRI 3‑3, 306‑1

Having developed a system for accumulating and analysing data on production and consumption waste from our operations, we are now implementing a range of projects aimed at minimising waste generation and increasing the share of recycled waste.

Metrics and highlights

SASB RT‑CH‑150a.1

The management system covers:

PhosAgro’s waste management is monitored on a regular basis and discussed by the Strategy and Sustainable Development Committee before being communicated to the Board of Directors.

Key initiatives in 2024

GRI 306‑2

PhosAgro is implementing consistent efforts to increase the share of recycled and decontaminated hazard class 1–4 waste. At each production site, regular initiatives are conducted to identify potential types of materials that can be diverted for recycling.

Promoting phosphogypsum utilisation

In 2024, PhosAgro expanded the use of phosphogypsum as a construction material at Apatit’s Cherepovets and Balakovo sites. This helped reduce the volume of phosphogypsum sent to waste disposal facilities.

A key focus is the use of phosphogypsum as a soil ameliorant in diverse agricultural landscapes across varying soil types and climatic zones. Under the guidance of Pryanishnikov All‑Russian Research Institute of Agricultural Chemistry, research was initiated in 2024 on applying Apagips (neutralised phosphogypsum compliant with GOST 58820‑2020) to combat soil desertification. Preliminary results have been promising.

A notable example of Apagips application is the chemical amelioration of acidic soils across 1,000 ha at Vozrozhdenie LLC in the Ulyanovsk region. Apagips demonstrated excellent efficacy as a soil ameliorant in pilot trials.

All contractors working at the Company’s sites undergo training and are informed of waste management requirements, which are explicitly outlined in work/service agreements. Compliance with safe and proper waste handling protocols is strictly enforced.

Disposal of beneficiation waste and overburden at Kirovsk branch

SASB EM‑MM‑150a.1, EM‑MM‑150a.2

Metrics and highlights

Strategy and management approach

GRI 3‑3

PhosAgro Group has developed and now maintains an emissions management process that includes assessment of planned activities, discussion of relevant matters with a wide range of stakeholders, as well as monitoring and disclosing pollutant emissions. To effectively reduce its environmental impact, PhosAgro is running a programme to re‑equip production facilities and cut pollutant emissions.

PhosAgro takes part in the government’s Clean Air initiative, which aims to drastically reduce air pollution in major industrial cities across Russia. As part of the initiative, the Company implemented a number of measures, which helped reduce gross pollutant emissions in 2024 by 24% vs the 2017 level (project launch).

Air quality in sanitary protection areas near the Company’s production sites complies with applicable hygienic requirements.

Key initiatives in 2024

Apatit’s Cherepovets site completed the fifth and final initiative as part of the Clean Air national project.

Modernisation of the SK‑600/1 and SK‑600/2 technological systems, along with the adoption of domestically developed energy efficient and environmentally safe sulphuric acid production technology, reduced atmospheric pollutant emissions and enhanced energy efficiency.

At the Volkhov branch, the key activities of 2021–2024 to mitigate the negative impact on the air quality were implemented as part of an investment project to develop the Volkhov site: technical solutions to reduce per unit emissions and pollutant concentrations at the sanitary protection zone boundaries near residential areas were initially integrated into the design of new production lines and existing facility upgrades. This approach achieved a 74% reduction in per unit pollutant emissions compared to 2020 levels.

Key initiatives to reduce negative air quality impacts at the Balakovo branch included:

• reconstruction of the SK‑20 sulphuric acid production unit, including installation of a five‑layer contact apparatus and adoption of a domestic energy efficient and environmentally safe sulphuric acid production technology;
• catalyst replacement at the SK‑17 and SK‑20 sulphuric acid production units;
• technical upgrades to absorption systems in the phosphate fertilizers workshop.

These measures reduced per unit atmospheric emissions at the Balakovo site by 25.7% in 2024 compared to 2023.

At the Kirovsk branch, the 2024 activities to minimise dust emissions from tailing dumps of beneficiation facilities included:

• chemical stabilisation using binding agents (PSKh‑18, bitumen emulsion) for dusty surfaces in the beach area of tailing dumps:
  • at ANBP‑2 across 325.7 ha,
  • at ANBP‑3 across 336 ha;
• chemical stabilisation for dusty surfaces on service roads of tailing dumps:
  • at ANBP‑2 across 121 ha,
  • at ANBP‑3 across 67 ha;
• biological stabilisation of the tailing dump’s dam slopes and decommissioning of the tailing dump’s beach area (via sowing of regionally specific plant species) across 7 ha;
• extra nutrition of crops planted in the past years on the dam slopes and in the beach area of tailing dumps across 36 ha;
• piloting four new anti‑dusting agent prototypes.

To stabilise dust‑emitting surfaces at the tailing dumps in the Kirovsk branch, the Company has been conducting multi‑year research in collaboration with scientific institutions to identify optimal surface stabilisation and dust control methods. Studies confirmed that specially selected plant communities, tailored to the substrate and regional climate, effectively stabilise dam slopes and inactive areas of the tailing dumps, preventing wind‑driven particle dispersal. This approach has been successfully applied across the Company’s operations.

Beach areas of the tailing dump, where fresh material is continuously deposited, as well as access roads, are treated with custom binding agents. Research into more efficient solutions remains ongoing.

In 2024, the implementation of biological and chemical measures successfully prevented the emission of over 25 t of particulate matter into the atmosphere.

These initiatives reduced particulate emissions from facility surfaces by 37%.

RT‑CH‑140a.2 / EM‑MM‑140a.2

Metrics and highlights

Strategy and management approach

GRI 3‑3, 303‑1

Water is an essential resource for the Company. There is no shortage of water sources in the regions where our facilities are based. According to the Water Risk Atlas and Water Risk Filter, all PhosAgro production sites are located in areas with low or moderate fresh water scarcity. However, access to clean water is a major issue facing the world.

In 2024, the Company reviewed its per unit targets for water withdrawal and waste water discharge. The new 2025 targets account for water flows excluding mining and pit waters, which are natural in origin and flow in and out without involvement in production processes. These new targets were discussed at a meeting of the Board of Directors' Strategy and Sustainable Development Committee and subsequently approved by the Board of Directors:

• reduction in water withdrawal, excluding mining and pit waters, to 2.6 m³ /t of products;
• reduction in waste water discharge into surface water bodies, excluding mining and pit waters, to 1.7 m³ /t of products.

Risks and opportunities

SASB RT‑CH‑140a.3

The main risks related to water consumption are water quality deterioration in water bodies across PhosAgro’s footprint and the Company’s non‑compliance with statutory requirements for limiting one’s negative impact on water bodies.

PhosAgro has implemented closed‑loop water recycling systems at its sites in Volkhov and Balakovo to reuse water in production processes.

Going forward, we plan to improve waste water management by focusing on maximum reuse of water through closed‑loop water recycling systems and better treatment of effluents discharged into water bodies in addition to ongoing monitoring of water bodies in the regions of operation.

The regulatory risks include tightened waste water quality requirements, as well as restrictions on the amount of water consumed and discharged into both water bodies and centralised waste water systems. There were no incidents of non‑compliance associated with water quality permits, standards, and regulations in 2024.

To mitigate these risks, in 2020 we adopted the Water Strategy that sought to reduce water consumption and discharge and improve waste water quality.

The strategy is implemented at all PhosAgro sites, and we regularly analyse these measures to determine whether they are sufficient and effective enough to achieve our targets.

To identify the impact of the Company’s operations on water bodies, we monitor these bodies in accordance with adopted programmes by engaging our own certified laboratory and external certified laboratories.

Key initiatives in 2024

Phosphate facility

Design and engineering documents were finalised for a waste water treatment unit with a source water capacity of at least 400 m3/h.

Engineering documents were finalised for the technical upgrade of an acidic waste water treatment station with production capacity increase.

Nitrogen facility

Basic design development for the industrial waste water treatment system is ongoing.

Engineering surveys were conducted for the waste water reception, accumulation, transportation, and treatment at the industrial waste water neutralisation and treatment unit. Engineering documents for the project are under development, with priority measures currently being implemented.

The Saami pit water is now utilised for process needs at the Kirovsky mine workings. In 2024, the volume of water substitution reached record high levels due to the integration of an additional pump into the system.

The reconstruction of the Rasvumchorrsky mine compressor station was completed, with the cooling tower removed from the circulation cycle.

The relative decrease in the share of reused water can be attributed to multiple factors, including the implementation of energy and resource efficiency enhancement programmes and the transition from calculation‑based monitoring methods to instrumentation metering. Additionally, 2024 saw arid conditions and lower precipitation levels, resulting in deteriorated water quality and an increased reliance on fresh water in production processes.

The rise in water consumption is driven by higher production volumes, including increased ore mining and processing, and higher output of concentrates and mineral fertilizers.

PhosAgro’s Environmental Policy sets forth the Company’s obligations to preserve biodiversity, natural landscapes and habitats across its footprint and prevent its projects from causing any harm to the same.

Metrics and highlights

Strategy and management approach

GRI 101‑1, 3‑3

PhosAgro’s strategy for managing the conservation of biodiversity, natural landscapes, and ecosystems in its regions of operation is anchored in the provisions of the Company’s Environmental Policy and is guided by legal requirements and internal documents of the environmental management system.

Key initiatives in 2024

GRI 304-2, 101-2

• The Company developed and implemented the Biodiversity Conservation and Monitoring Guidelines for Apatit to regulate biodiversity conservation and monitoring efforts across its operational regions. The guidelines define the scope, frequency, and methodology for biodiversity monitoring at production facilities.
• Compensatory afforestation was conducted on a 2.4346 ha site in the Volkhov Forestry District (Leningrad region), where 1,461 Norway spruce saplings were planted.
• The Company released young fish into water bodies across its regions of operation.
• The Company planted samplings of tree and shrub species.
• A comprehensive environmental survey was performed in the impact zone of the Vostochny mine (Kirovsk branch, Murmansk region) as part of the biodiversity protection programme development. The initiative was independently evaluated and received positive feedback from experts at the Forestry Research Institute of the Karelian Research Centre, the Russian Academy of Sciences

Comprehensive biodiversity protection programmes

GRI 304‑2, 101‑2, 101‑4

Comprehensive biodiversity protection programmes were developed for the Volkhov branch, three of the Kirovsk branch’s facilities and the Cherepovets production site.

The branch‑specific monitoring programmes outline the geographic scope of monitoring zones, the nature and extent of the Company’s operational impacts on ecosystems, indicator species, and metrics to assess their biodiversity status and its changes, as well as indicators to evaluate the effectiveness of biodiversity management measures.

Surveys conducted at the Volkhov branch, three Kirovsk branch facilities, and the Cherepovets production site revealed no significant adverse changes in biodiversity within the Company’s operational zones. Ecosystems in these areas often exhibited higher species diversity compared to baseline zones, likely due to restricted human access preserving ecosystem integrity.

Key factors influencing biodiversity include emissions of pollutants and greenhouse gases, water withdrawal and waste water discharge, and waste disposal.

Land disturbance resulting from the Company's operations occurs due to mineral extraction, construction of waste disposal facilities, and other construction activities. Mineral extraction is one of the Company’s core activities. The expansion of open‑pit and underground mining operations within permitted licence areas drives production growth and ensures stable product supply. Mining activities are conducted safely and with maximum efficiency. Reclamation for these sites is best to be implemented following resource depletion. The Company’s mining assets currently have operational lifespans extending beyond 2030.

Waste disposal is managed within pre‑approved designated areas at the Company’s facilities, with no involvement of additional territories. Increasing the share of waste diverted for recycling reduces pressure on these disposal sites and extends their operational lifespan.

In 2024, the increase in disturbed land area was attributed to the expansion of the phosphogypsum tailings disposal facility at the Balakovo branch of Apatit.

A comprehensive environmental study was conducted in the impact zone of the Vostochny mine (Kirovsk branch, Murmansk region) as part of a biodiversity conservation programme developed in collaboration with the Polar‑Alpine Botanical Garden‑Institute, a branch of the Kola Science Centre of the Russian Academy of Sciences.

The study revealed that the terrestrial ecosystems within the footprint of the Vostochny mine host over 800 species of fungi, liverworts, lichens, mosses, and vascular plants, as well as 65 bird and 16 mammal species.

The mammal species composition in the area is generally limited. However, the Vostochny mine demonstrates a less pronounced negative impact compared to the Kirovsky and Rasvumchorrsky mines, as it directly borders the forests of the Southern Khibiny region.

Four rivers and two lakes within the Vostochny mine’s impact zone were studied. All water bodies were found to be suitable for sustaining and developing relatively high populations of juvenile fish.

The Biodiversity Conservation Programme for the Vostochny mine of Apatit’s Kirovsk branch underwent comprehensive review by researchers from the Forestry Research Institute at the Karelian Research Centre of the Russian Academy of Sciences and received a positive assessment.

In 2024, we held research at the Volkhov branch as part of the programme for environmental monitoring of biota (flora and fauna) within the sanitary protection zone.

The study of the area within the footprint of the Volkhov branch revealed that the structure of animal species across the reviewed biotopes is typical for the region in question. A total of 59 bird species were found to live within the facility’s footprint and in adjacent areas.