THE MATERIALITY ANALYSIS

The reporting in the Sustainability Report focuses on material topics as well as the concept of impact and due diligence. As defined by the GRI Standards, material topics are those aspects that reflect the organization's most significant impacts on the economy, environment and people, including on human rights.

The materiality analysis process consists of the following stages:

1.

Context analysis

An analysis was performed to understand the context of the organization, delving into aspects such as the activities carried out by Comer Industries (in terms of mission, vision, business model, type of business, geographic area of interest, etc.), business relationships (customers, suppliers, contractors, etc.), sustainability context (mega trends, industry trends, competitors, regulatory environment, etc.), and relevant stakeholders (next section).

2. Identification of sustainability impacts

Key impacts of the organization on the economy, environment and people, including on human rights, were identified based on the outcomes of the context analysis and issues that emerged from the ongoing dialog with stakeholders and experts inside and outside the organization. A detailed analysis allowed each impact to be systematically associated with one or more relevant sustainability issues. The issues identified were listed and submitted for evaluation by management and stakeholders, described in the next section.

3. Evaluation of the significance of the impacts

Following identification, an assessment of the most relevant sustainability impacts and issues was performed through a "targeted" process that involved the direct involvement of key categories of internal stakeholders (employees) and external stakeholders (suppliers, investors) as well as top management, through the completion of an assessment questionnaire that assigned each impact or issue a priority for action by the organization using a scale from 1 ("Not important") to 4 ("Top priority").

4. Prioritization of the most significant impacts

The assessment led to determining the significance and priority of impacts, and subsequently establishing a significance threshold for the purpose of relating each significant impact to a "material" topic for reporting. The list of material topics was finally submitted to the Group's top management (CEO and Executives) for final approval.

The full list of current and potential positive and negative impacts and related material topics for 2022 can be found in Appendix | The materiality analysis