Annual Consolidated Management Report
Consolidated Corporate Governance Statement
Consolidated Non-Financial Information
Consolidated Report on Payments to Governments
Annual Consolidated Financial Statements
Independent Auditors’ Report
Bulgarian Energy Holding EAD
31 December 2024
Translation from Bulgarian

Bulgarian Energy Holding EAD
Contents
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
Annual Consolidated Management Report ................. i
Consolidated Corporate Governance Statement ......... ii
Consolidated Non-Financial Information ................. iii
Consolidated Report on Payments to
Governments ............................................................. iv
Annual Consolidated Financial Statements ................ v
Consolidated Statement of Profit or Loss ................... 1
Consolidated Statement of Comprehensive Income .. 2
Consolidated Statement of Financial Position ........... 3
Consolidated Statement of Changes in Equity ........... 5
Consolidated Statement of Cash Flows ..................... 7
Notes to the Consolidated Financial Statements ........ 8
1. Corporate information ..................................... 8
2. Statement of compliance with IFRS Accounting
Standards and application of the going concern
principle .................................................................... 10
3. Changes in the accounting policy .................. 12
3.1. New standards, amendments and interpretations
to IFRS effective from 1 January 2024 ..................... 12
3.2. Standards, amendments and clarifications that
have not yet entered into force and have not been
applied by the Group from an earlier date ................ 13
4. Material Accounting Policy Information ....... 14
5. Segment reporting ......................................... 48
6. Revenue from sales ....................................... 51
7. Other operating income ................................. 55
8. Cost of natural gas, electricity and other current
assets sold ................................................................. 57
9. Costs for acquisition of property, plant and
equipment in an economic way ................................ 57
10. Expenses for materials ................................... 58
11. Hired services expenses ................................. 58
12. Reversal of/(expenses for) impairment of
financial and non-financial assets, net ...................... 59
13. Personnel expenses ........................................ 59
14. Other operating expenses .............................. 59
15. Finance income.............................................. 62
16. Finance costs ................................................. 62
17. Income tax expenses ...................................... 62
18. Earnings per share and dividends .................. 63
19. Property, plant and equipment ....................... 65
20. Intangible assets ............................................ 73
21. Investments accounted for using the equity
method....................................................................... 74
22. Business combinations ................................... 79
23. Trade and other receivables ........................... 80
24. Deferred tax assets and liabilities .................. 85
25. Inventories ..................................................... 86
26. Financial assets at fair value through other
comprehensive income .............................................. 89
27. Cash and short-term deposits ......................... 90
28. Share capital and reserves .............................. 91
29. Loans and lease liabilities .............................. 92
30. Deferred financing ......................................... 97
31. Retirement employee benefit obligations ...... 99
32. Provisions .................................................... 101
33. Deferred income .......................................... 105
34. Related party disclosures ............................. 105
35. Trade and other payables ............................. 108
36. Categories of financial assets and liabilities 109
37. Financial Risk Management Objectives and
Policy 110
38. Fair value measurement ............................... 116
39. Capital management policies and procedures
118
40. Contingent assets, contingent liabilities, and
commitments ........................................................... 118
41. Balance of debt arising from financing activities
with the amounts disclosed in the consolidated
statement of cash flows ........................................... 130
42. Events after the reporting period .................. 130
43. Approval of the consolidated financial
statements ................................................................ 134
Independent Auditors’ Report .................................... vi

BULGARIAN ENERGY HOLDING EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
31 December 2024

This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
Board of Directors as of the date of issue of the consolidated financial statements
Valentin Aleksiev Nikolov
Ivo Ivanov Todorov
Kalin Boyanov Filipov
Diyan Atanasov Ivanov
Vasil Georgiev Stoynov
Address
Bulgaria
Sofia Region, Sofia Municipality, Sofia 1000
Oborishte District, 16 Veslets str.
Servicing banks
Allianz Bank Bulgaria AD
Bulgarian-American Credit Bank AD
Bulgarian Development Bank AD
D Commerce Bank AD
Central Cooperative Bank AD
Citibank Europe AD, Bulgaria Branch
Eurobank Bulgaria AD
European Investment Bank
First Investment Bank AD
ING Bank N.V. – Sofia Branch
Investbank AD
Municipal Bank AD
DSK Bank AD
United Bulgarian Bank AD
UniCredit Bulbank AD
International Investment Bank
National Bank of Greece
Auditor
DZZD Audit BEH with participants in the merger of auditing companies Grant Thornton OOD and
Zaharinova Nexia EOOD, registered respectively under Reg. No.032 and Reg. No.138 in the Register
of Registered Auditors

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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1. General
Company name BULGARIAN ENERGY HOLDING EAD (BEH EAD)
UIC 831373560
Address Bulgaria
Sofia Province, Sofia Municipality
City of Sofia 1000
Oborishte district
8 Veslets str.
Scope of Business Activity Acquisition, management, evaluation and sale of shares in
commercial companies, operating in the fields of production,
extraction, transmission, transit, storage, management,
distribution, sale and/or purchase of natural gas, electricity,
thermal energy, coal, as well as all kinds of energy and raw
materials for its production, participation in the management of
such companies, their financing, acquisition, evaluation,
issuance and sale of bonds, acquisition, evaluation and sale of
patents, sub-licensing for the use of patents to the above-
mentioned companies, as well as carrying out its own production
or commercial activity.
Directors As of 31 December 2024, the Company is managed by a
Board of Directors (BOD) with members:
Veselina Lachezarova Kanatova-Buchkova
Chairperson of the BD
Kalin Boyanov Filipov
Vice-Chairperson of the BD
Valentin Aleksiev Nikolov
Member of the BD and Executive Director
Galina Tsvetanova Todorova
Member of the BD and Executive Director
Ivo Ivanov Todorov
Member of the BD
The Company is represented by the Executive Directors.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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Bulgarian Energy Holding EAD (parent company) together with its subsidiaries form an
economic group. The holding structure is presented in the chart below:
Structure of Bulgarian Energy Holding EAD as of 31 December 2024
The Company is the sole owner of the capital of the following subsidiaries:
NPP Kozloduy EAD
Scope of Business Activity Use of nuclear energy for generation of electricity and thermal
power, which activity is performed in the presence and
maintenance of: valid license for generation of electric and
thermal power by an electric power generation facility specified

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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in the license, valid licenses for operation of nuclear facilities
pursuant to the Safe Use of Nuclear Energy Act (SUNEA),
issued by the Nuclear Regulatory Agency (a valid authorization
for production activities carried out by the power generation
facility specified in it, issued by the Inspectorate on the Safe Use
of Nuclear Energy for Peaceful Purposes);
Import and export of fresh and spent nuclear fuel;
Investment activity related to the activity of the company,
specified in the scope of activity;
Construction, assembly and repair activities in the field of
electric and thermal power generation;
Sale of high and medium voltage electric and thermal power.
Operation of radioactive waste management facilities according
to a valid license under the Safe Use of Nuclear Energy Act
(SUNEA).
Directors The company is managed by a Board of Directors and as of 31
December 2024 is represented by the Executive Director Ivan
Todorov Andreev.
Licenses The company holds the following licenses:
– License for operation of nuclear facility, series E,
registration No.5303 dated 03.11.2017, in force since
06.11.2017, for operation of Unit 5 of NPP Kozloduy, with
unlimited validity;
– Nuclear Installation Operation License, Series E -
Registration No.5535, dated 03 October 2019, for the operation
of the Unit 6 of NPP Kozloduy, with unlimited validity;
– Electricity and Heat Production License No.Л-049-
03/11.12.2000, for a period of 30 years;
– Heat Transmission License No.050-05/11.12.2000; for a
period of 30 years;
– Nuclear Facility Operation License - Series E, Reg.
No.6200/20.06.2024, effective from 26.06.2024, for operation
of the Spent Nuclear Fuel Storage Facility of NPP Kozloduy,
issued by the Nuclear Regulatory Agency, with unlimited
validity;
– License Series O, reg. No.6149/21.03.2024, effective from
01.04.2024 for the use of sources of ionizing radiation for
business purposes - performing non-destructive control with
radiation methods, issued by the Nuclear Regulatory Agency.
License term - 01.04.2034
– License Series O, reg. No.6147/20.03.2024, in force since
08.04.2024 for the use of sources of ionizing radiation for
business purposes - radiochemical control, radiation monitoring
of the environment and metrological control, issued by the
Nuclear Regulatory Agency. License term - 08.04.2034

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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– License, Series T, reg. No.6195/19.06.2024, effective from
12.07.2024 for transport of radioactive substances, issued by the
Nuclear Regulatory Agency. License term - 12.07.2034
– Electricity Trading License No.Л-216-15/18.12.2006, valid
until 18.12.2026;
– License Series SO, reg. No.5794, in force since 05.10.2021 for
carrying out specialized training for activities in nuclear
facilities and with sources of ionizing radiation that have an
impact on safety and for issuing certificates of competence to
persons professionally engaged in activities in nuclear facilities
and with sources of ionizing radiation, beyond those under
Article 64, paragraph 1, item 1 and item 2 of the Safe Use of
Nuclear Energy Act - issued by the Nuclear Regulatory Agency.
License term: until 05.10.2026;
– License for operation of Dry Storage Facility for Spent
Nuclear Fuel from VVER-440 Reactors, issued by the Nuclear
Regulatory Agency, Series E, reg. No.5016 of 28.01.2016, with
unlimited validity;
Investments in enterprises NPP Kozloduy EAD is the sole owner of the capital of NPP
Kozloduy EAD, NPP Kozloduy - New Builds EAD, NPP
Construction Supervision EOOD and NPP Service EOOD
and has a controlling interest of 63.96% in
Interpriborservice OOD, Kozloduy, holding 71 shares of its
equity. The Company has a minority share of 1.12% in ZAD
Energy AD.
Bulgargaz EAD
Scope of Business Activity Public supply of natural gas and related purchases and sales,
purchase of natural gas for storage in a gas storage facility,
market research and analyses of the natural gas market in the
country.
Directors The Company is managed by a Board of Directors and as of 31
December 2024 is represented by the Executive Director Veselin
Sashev Sinabov.
Licenses Individual license for public supply of natural gas on the
territory of the Republic of Bulgaria - License No.Л-214-14
dated 29 November 2006, issued by the Energy and Water
Regulatory Commission for a period of 35 years.
Pursuant to Art. 21, para. 1, item 1 and in connection with Art.
39, para. 1, item 5 of the Energy Act with a decision of the
Energy and Water Regulatory Commission dated 16.09.2021
Bulgargaz EAD acquired a license for trading in natural gas
No.А0435 for a period of 10 years.
The Company holds a license for trading in natural gas in the
territory of the Hellenic Republic - Decision No.247/2020, for

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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an indefinite term and Decision No.311/2022 for trading in
natural gas in the territory of the Hellenic Republic, for a term
of 20 years, issued by the Greek Energy Regulatory Authority -
RAE.
The Company holds a perpetual license for the supply of natural
gas No.2023P 0370 dated 20 June 2023 issued by the Regulatory
Authority for Network Industries of the Slovak Republic.
On 12.12.2024, by Decision No.H4955/2024, the Hungarian
Energy and Utilities Regulatory Office granted the Company a
license to trade in natural gas in Hungary, valid from the date of
notification for an indefinite period.
Bulgartransgaz EAD
Scope of Business Activity Storage and transmission of natural gas; maintenance,
operation, management and development of gas transmission
grids; maintenance, operation, management and development of
underground gas storage facilities; development of programs
and activities for ensuring the compliance of the natural gas
transmission and storage activities with the requirements of the
European energy legislation; development of pricing policy for
access to and transmission on the gas grids, storage of natural
gas and connection to gas transmission grids; administration of
natural gas transactions and arranging the balancing of the
natural gas market in compliance with the requirements of the
current legislation; engineering, investment, manufacturing and
service activity; import of goods, machinery and equipment
related to the company's operations; centralized operational
management, coordination and control on the operation of gas
transmission grids.
Directors The Company is managed and represented by a Board of
Directors and as of 31 December 2024 the CEO is Kiril
Dimchov Ravnachki.
Licenses The Company holds licenses issued by the Energy and Water
Regulatory Commission (EWRC) as follows:
− License No.L-214-09 dated 29 November 2006 for
transmission of natural gas on the territory of the Republic of
Bulgaria, for a period of 35 years;
− License No.L-214-06 dated 29 November 2006 for
transmission of natural gas on the territory of the Republic of
Bulgaria, for a period of 35 years;
− License No.L-214-10 dated 29 November 2006 for storage
of natural gas on the territory of the Republic of Bulgaria for a
period of 35 years.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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Investments in enterprises Bulgartransgaz EAD is the sole owner of the capital of
Balkan Gas Hub EAD and owns 50% of the shares of
Bulgartel AD, and 20% of the capital of Gastrade S.A.
Mini Maritsa Iztok EAD
Scope of Business Activity Coal extraction and marketing, industrial, commercial,
leasing, repair, external economic activities, training and
retraining of personnel for coal mining for the purpose of
income generation, carrying out preventive maintenance
and rehabilitation activities in rest stations owned by the
company, trading in electricity, carrying out rail freight
transport, as well as other activities not prohibited by law.
Directors The Company is managed by a Board of Directors and as of 31
December 2024 is represented by the Executive Director, Todor
Dimchev Todorov.
Licenses The Company holds the following Licenses:
− license for “electricity trading” No.L-480-15 dated 20
October 2016 issued by EWRC for a period of 10 years.
− license issued by the Ministry of Transport, Information
Technology and Communications for transportation “Rail
freight”, issued in 2016 for a period of 5 years. The license was
updated on 14.05.2021 and it is valid until 13.05.2026.
Investments in enterprises Mini Maritsa Iztok EAD holds a minority share of 3.68% in
ZAD Energy.
TPP Maritsa East 2 EAD
Scope of Business Activity Generation of electric and thermal power, transmission and
distribution of thermal power, construction and repair works in
the electric and thermal power sector, construction and repair
works in the field of electric and thermal power generation,
investments, acquisition and management of copyrights, rights
on inventions, trademarks and industrial designs, know-how and
other intellectual property, as well as any other activity not
prohibited by law or regulation, and when authorization or
license is required – after such an authorization or license is
obtained.
Directors The Company is managed by a Board of Directors and, as of 31
December 2024, is represented by the Executive Director, Diyan
Stanimirov Dimitrov.
Licenses The Company holds the following licenses issued by EWRC as
follows:
− Licence for generation of electric power L-091-01 dated 21
February 2001 valid for a period of 20 years; By Decision № I1-

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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L-091 dated 02 July 2020, the term of the license was extended
for a further 20 years from the expiry date of the license - 24
March 2021.
− License for trading with electric power No.L-498-15 dated 31
January 2018 valid for a period of 10 years;
Investments in enterprises The Company holds a minority share of 0.96% in ZAD Energy.
Natsionalna Elektricheska Kompania EAD (NEK EAD)
Scope of Business Activity Production of electricity, centralized purchase and sale of
electricity, supply of electricity to consumers connected to the
transmission grid, import and export of electricity, construction
and repair activities in the field of electricity production,
investment activities, implementation and promotion of energy
efficiency in energy production.
Directors The Company is managed by a Board of Directors and as
of 31 December 2024 is represented by the Executive
Director Martin Ivanov Georgiev.
Licenses The Company holds licenses issued by EWRC as follows:
− License No.L-147-13 dated 17 December 2004 for the
public supply of electricity for a term of 35 years, supplemented
by a special balancing group coordinator;
− License No.L-073-01 dated 14 February 2001 for power
generation from HPP and PSHPP, valid for a period of 35 years;
− License No.1-230-15 dated 4 June 2007, for trading in
electricity for a period of 10 years, supplemented by a standard
balancing group coordinator. By Decision No.I2-L-230 of
the Energy and Water Regulatory Commission (EWRC)
of 15 September 2016, the term of the license for the
trading in electricity activity including the rights and
obligations of the coordinator of the standard balancing
group was extended by 10 years - until 4 June 2027;
− License No.L-408-17 dated 1 July 2013 for supply of
electricity from a supplier of last resort, valid for a period
of 26 years. (Decision No.I1-L-408/29.01.2014 amending
/supplementing License No.L-408-17/01.07.2013, issued for
the activity “supply of electricity from a supplier of last resort”
with the rights and obligations of a coordinator of a special
balancing group).
Internal structural units NEK EAD, Hydro Power Plants Enterprise, Plovdiv – performs
electricity generation, construction and maintenance of hydro
power generation facilities, investment activity.
NEK EAD, Dams and Cascades Company, Sofia performs
technical operation and maintenance of dams and hydro power
facilities.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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Investments in enterprises NEK EAD holds 27% of the capital of ContourGlobal Maritsa
Iztok 3 AD, 27% of the capital of ContourGlobal Operations
Bulgaria AD, 42% of the capital of ZAD Energia, 34 % of
Allianz Bulgaria Pension Insurance Company AD, 24% of the
capital of HPC Gorna Arda AD.
Electricity System Operator EAD (ESO EAD)
Scope of Business Activity Transmission of electricity, unitary operational planning,
coordination and management of the electricity system of the
Republic of Bulgaria, provision and management of third party
access on a non-discriminatory basis to grid users or groups of
grid users, implementation of the joint operation of the
electricity system with the electricity systems of other
countries, coordinated development and interoperability of the
electricity transmission grid with interconnected electricity
transmission grids, expansion, reconstruction, modernization,
operation, maintenance and provision of the reliable operation
of the electricity transmission grid, including the availability of
all necessary ancillary services, maintenance and development
of auxiliary grids, repairs and services in the field of energy,
other commercial activities and services that are not prohibited
by law.
Directors The Company is managed and represented by a Board of
Directors and as of 31 December 2024 the CEO is Angelin
Nikolaev Tsachev.
Licenses The Company holds the following licenses issued by EWRC:
− License for transmission of electricity No.L-419-04 dated
18 December 2013, valid for a period of 35 years.
− License No.L-221-17 dated 28 December 2006 for the
activity “Management of the Electricity System” (amended by
Decision No.I1-L-221-17 dated 29 September 2008). The
validity of the license is until 17.12.2039.
Investments in enterprises Electricity System Operator EAD is the sole owner of the
capital of ESO Engineering EOOD, ESO Project EOOD, ESO
Charge EAD, owns 50% of the capital of Bulgartel AD and
33.33% of the capital of SEleNe CC.
National Energy Operator EAD (NEO EAD)
Scope of Business Activity Construction and operation of electric power facilities
Directors The Company is managed and represented by a Board of
Directors and as of 31 December 2024 the Executive Director
is Aleksandar Zdravkov Mihailov.
Minproekt EAD
Scope of Business Activity Design and construction, scientific research, engineering and
consulting activities related to coal mining in Bulgaria,

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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Basis for preparation of the consolidated financial statements
BEH EAD operates in compliance with the Bulgarian and the European legislation. The consolidated
financial statements of the Group are prepared in accordance with IFRS Accounting Standards
developed and published by the International Accounting Standards Board and adopted by the European
Union.
Responsibility of Management
The Management confirms that an adequate accounting policy has been applied in the preparation of the
consolidated financial statements for 2024 and they have been prepared on a going concern basis.
The management is responsible to keep proper accounting records, to carry out appropriate asset
management and to undertake the measures necessary to avoid and detect any possible frauds and other
irregularities.
The consolidated management report for 2024 is prepared in accordance with art. 45 of the Accountancy
Act and art. 247 of the Commercial Act and is approved by the Board of Directors of Bulgarian Energy
Holding EAD.
2. Incorporation, management and structure
Legal status
Parent company
BEH EAD is a sole owner joint-stock company, established in 2008, following the change of the
company's name, statute and subject of activity of Bulgargaz Holding EAD, and the capital of the
company was increased through par value distribution of all shares from the capital of Natsionalna
Elektricheska Kompania EAD, NPP Kozloduy EAD, TPP Maritsa East 2 EAD and Mini Maritsa Iztok
EAD. In this way, all state energy companies operating in the sphere of production, extraction,
transmission and trade with energy resources, have been integrated in the structure of BEH EAD.
The sole owner of the capital of BEH EAD is the Republic of Bulgaria and the rights of a sole owner
are exercised by the Minister of Energy who has the capacity of a principal and is empowered to make
all decisions within the competence of the sole owner of the capital according to the law and the Articles
of Association of the Company.
The company is managed through a one-tier management system. The management bodies are:
• Sole owner of the capital in its capacity of General Assembly - the Minister of Energy of the
Republic of Bulgaria;
• The Board of Directors.
notwithstanding whether by open or underground method.
Testing of blast protection equipment and explosives
Directors The Company is managed and represented by a Board of
Directors and as of 31 December 2024 the Executive Director
is Kostadin Hristov Hristov.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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At the date of preparation of these annual consolidated financial statements, there are no plans for
privatization of the company, it is included in the list of state companies not subject to privatization -
Appendix No.1 to art. 3, para. 1 of the Privatization and Post-Privatization Control Act.
Companies in the Bulgarian Energy Holding Group
NPP Kozloduy EAD was established on 28 April 2000 by Decision No.7 dated April 2000, company
case 582/2000 of Vratsa District Court. The Company has its headquarters and registered office at: City
of Kozloduy, Vratsa Province, NPP site, telephone code 0973, postal code 3320. The sole owner of the
capital of NPP Kozloduy EAD since 18 September 2008 is BEH EAD.
HPP Kozloduy EAD was registered in Vratsa District Court with company case No.495 dated 2004
with the purpose of building a hydroelectric plant, generation and distribution of electricity from small
hydroelectric power plant for utilization of the residual resource of the spent water from NPP Kozloduy
EAD. The sole owner of the capital of HPP Kozloduy EAD is NPP Kozloduy EAD.
NPP Kozloduy - New Builds EAD was established on 9 May 2012 by the issuance of 200,000 ordinary
registered shares with a nominal value of BGN 10. The company is engaged in the construction of power
units of a nuclear power plant. The Company's capital is BGN 1,816,800,000 divided into 181,680,000
ordinary registered shares with a par value of BGN 10 each. The sole owner of the capital of NPP
Kozloduy - New Builds EAD is NPP Kozloduy EAD.
NPP Construction Supervision EOOD was entered in the Commercial Register at the Registry Agency
with UIC 206736961, headquarters and registered office: Vratsa province, Kozloduy municipality, town
of Kozloduy, site of NPP Kozloduy on 25.11.2021 with capital BGN 5 thousand. NPP Kozloduy EAD
is the sole owner of the capital of NPP Construction Supervision EOOD, consisting of 50 (fifty) shares,
each with a nominal value of BGN 100.00.
NPP SERVICE EООD was entered in the Commercial Register and the Register of Non-Profit Legal
Entities with the Registry Agency with UIC: 206858488, headquarters and registered office Vratsa
province, Kozloduy municipality, town of Kozloduy, Kozloduy site on 11.03.2022 with capital BGN
750 thousand. NPP Kozloduy EAD is the sole owner of the capital (100%) consisting of 1000 (one
thousand) shares, each with a nominal value of BGN 750.
Interpriborservice OOD (in bankruptcy) was established by Decision № 55 of the Council of Ministers
of 13 April 1988 as a specialized enterprise for installation, adjustment, repair, technical service of
automated process control systems, supply of instruments, equipment and spare parts for NPP, TPP, etc.
Partners in the established company are Russian and Ukrainian companies working in the field of
energy. NPP Kosloduy EAD had a controlling interest of 63.96% in Interpriborservice OOD (in
bankruptcy), Kozloduy, representing 71 shares of its capital, which is in total 111 shares of BGN 100
each. On 11 September 2023, the company was declared bankrupt by a decision of the Vratsa District
Court.
Bulgargaz EAD was registered in Bulgaria in accordance with the Commercial Act. The Company was
entered in the Commercial Register under No.113068, volume 1534, page 35, company case №
16440/2006 and was registered on the basis of Decision № 1 dated 15 January 2007. The Company has

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
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headquarters and registered office at: Sofia municipality, Sofia 47 Petar Parchevich Str. The sole owner
of the capital of Bulgargaz EAD is BEH EAD.
Bulgartel EAD was registered under company case No.13115/2004 in accordance with the Commercial
Act by a decision of the Sofia City Court dated 30 November 2004. The Company's headquarters and
registered office is: Sofia, Lyulin Municipality, Residential Area Lyulin 2, 66 Pancho Vladigerov Blvd.
The owners of the capital of Bulgartel AD are Electricity System Operator EAD and Bulgartransgaz
EAD with a 50% share each.
Bulgartel Skopje DOOEL is a sole owner joint-stock company registered in the Central Registry of
the Republic of Macedonia on 3 December 2008 under No.643867. The company registered office and
address of management is in Macedonia, city of Skopje, Orce Nikolov Str. The sole owner of the capital
of Bulgartel Skopje DOOEL is Bulgartel EAD.
Bulgartransgaz EAD was registered in accordance with the Commercial Law by Decision No.1 dated
15 January 2007 by Sofia City Court under No.113067, Volume 1543, p. 32, company case
No.16439/2006. The Company's headquarters and registered office is: Sofia, Lyulin Municipality,
Residential Area Lyulin 2, 66 Pancho Vladigerov Blvd. The sole owner of the capital of Bulgartransgaz
EAD is BEH EAD.
Balkan Gas Hub EAD is a sole joint stock company with registered office in the Republic of Bulgaria,
incorporated in the Commercial Register and the Register of Non-Profit Organizations with the Registry
Agency under UIC 205478458 on 18 January 2019. The Company’s registered office is Bulgaria, Sofia,
Lyulin Municipality, Residential Area Lyulin 2, 66 Pancho Vladigerov Blvd. The sole owner of the
capital of Gas Hub Balkan EAD is Bulgartransgaz EAD.
Mini Maritsa Iztok EAD was registered under company case No.2444/1993, reg. 1, vol. 1, p. 12, lot 6
by Stara Zagora District Court in accordance with the Commercial Law by Decision No.2773 dated 7
July 1993. The Company headquarters and registered office: Radnevo, Stara Zagora district, 13 Georgi
Dimitrov str. The sole owner of the capital of Mini Maritsa-Iztok EAD is BEH EAD.
Natsionalna Elektricheska Kompania EAD was registered in accordance with the Commercial Act
by Sofia City Court under No.196, volume 5, p. 98, under company case No.29869/1991. The
Company's headquarters and registered office is: Sofia, 5 Veslets str. The sole owner of the capital of
NEK EAD is BEH EAD.
Electricity System Operator EAD (ESO EAD) was registered in accordance with the Commercial Act
by Sofia City Court by Decision No.1 of 4 January 2007, under company case No.16298/2006, lot
No.112765, volume 1528, register 1, page 53. The Company's registered office and address of
management is Sofia, Vitosha district, 201 Tsar Boris III Blvd. The sole owner of the capital of ESO
EAD is BEH EAD.
ESO Engineering EOOD was registered in the Commercial Register and the Register of Non-Profit
Legal Entities with the Registry Agency on 18 February 2021 with UIC/PIC 206401308. The registered
office of the company is. Sofia, 24 Petko Yu. Todorov blvd. The sole owner of the capital of the company
is Electricity System Operator EAD.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
13
ESO Proekt EOOD was registered in the Commercial Register and Register of Non-Profit Entities to
the Registry Agency on 26.04.2022. Its headquarters and registered office is: city of Sofia, postal code
1404, 24 Petko Yu. Todorov blvd. The sole owner of the capital of the company is Electricity System
Operator EAD. The company capital is BGN 250,000, divided into 2,500 (two thousand five hundred)
shares with a nominal value of BGN 100 (one hundred) each.
ESO Charge EAD is registered in the Commercial Register at the Registry Agency on 29.03.2024
under UIC 207774922, with registered office in Sofia, postal code 1404, 24 Petko Yu. Todorov blvd.
The company's capital is BGN 1,000,000 divided into 10,000 ordinary registered shares with a nominal
value of BGN 100 each. The sole owner of the capital of the company is Electricity System Operator
EAD.
TPP Maritsa Iztok 2 EAD was registered by decision No.2591 dated 30 June 2000 of Stara Zagora
Regional Court in accordance with the Commercial Act under company case 1338/2000, reg. 1, vol. 2,
p. 46, lot 23. The Company has its headquarters and registered office at: Kovachevo, Stara Zagora
province The sole owner of the capital of TPP Maritsa Iztok 2 EAD is BEH EAD.
National Energy Operator EAD is a joint-stock company established on 4 April 2023, as a sole
proprietorship with sole owner Bulgarian Energy Holding EAD. The Company has its headquarters and
registered office at: City of Sofia 1000, Oborishte district, 16 Veslets str. and the address for
correspondence is Sofia 1000, Oborishte district, 16 Stara planina str., office #3.
Minproekt EAD is a joint-stock company with sole owner Bulgarian Energy Holding EAD. The
company joined the BEH EAD group on 07.12.2023.
The company is based at: City of Sofia 1756 Studentski district, 14, Kliment Ohridski blvd.
No separate branches of the enterprise are set up in the structure of BEH EAD.
History of the parent company
BEH EAD is the successor of the State Oil and Gas Company, founded in 1973, renamed to
Gazosnabdyavane in December 1975. In accordance with the Decree on Business Activities, in the
beginning of 1990, the Company was renamed to Bulgargaz. Bulgargaz was transformed into a sole-
owner joint-stock company by order of the Council of Ministers of 12 May 1993.
With a transformation plan dated 27 October 2006 and its annexes, Bulgargaz EAD was transformed
into Bulgargaz Holding EAD by the separation of two separate sole joint-stock companies –
Bulgartransgaz EAD and Bulgargaz EAD pursuant to the provisions of Article 262 (d) of the
Commercial Act. Bulgartransgaz EAD and Bulgargaz EAD are legal successors of the respective portion
of the property (rights and obligations) of Bulgargaz Holding EAD. The transformation was registered
in the court by decision No.45 dated 15 January 2007 of the Sofia City Court.
With Protocol No.RD-21-305 of 18 September 2008, the Minister of Economy and Energy changes the
company name, the Articles of Association and the scope of activity of Bulgargaz Holding EAD and
establishes Bulgarian Energy Holding EAD, the capital is increased by in-kind contribution at par value
of all shares of the capital of Natsionalna Elektricheska Kompania EAD, NPP Kozloduy EAD, TPP
Maritsa East 2 EAD and Mini Maritsa Iztok EAD.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
14
Information under Art. 187e and Art. 247, para. 2 of the Commercial Act
Share capital
As of 31 December 2024, the share capital of the parent company BEH EAD is BGN 3,463,941,744,
distributed into 3,463,941,744 shares with a nominal value of BGN 1 each. The entire amount of the
Company capital is subscribed and paid in full. The company's shares are ordinary, registered, non-
preferred, with voting rights.
The Company does not possess any own shares. In 2024, the Company did not acquire or transfer its
own shares.
Information regarding the remuneration of the members of the Board of Directors of Bulgarian
Energy Holding EAD and its subsidiaries under management and control contracts
The remuneration of the members of the Board of Directors of Bulgarian Energy Holding EAD
and its subsidiaries is as follows:
Remuneration of key management personnel
thousand BGN 2024 2023
Remuneration 5,664 4,739
Social security 363 322
Social costs 892 832
Total 6,919 5,893
Information regarding the acquisition and holding of company shares by the members of the
Board of Directors
The members of the Board of Directors do not own shares of the companies. They do not have privileges
or exclusive rights to acquire shares and bonds of the companies. All shares of BEH EAD are owned by
the State, and the shares of NPP Kozloduy EAD, Bulgargaz EAD, Bulgartransgaz EAD, Mini Maritsa-
Iztok EAD, NEK EAD, TPP Maritsa East 2 EAD, Minproekt EAD, NEO EAD and ESO EAD are 100%
owned by BEH EAD.
Information on the participation of the members of the Board of Directors in companies as
unlimited partners, holding more than 25 per cent of the capital of another company, as well as
their participation in the management of other companies or cooperatives as procurators,
managers or members of boards for the period 01.01.2024 - 31.12.2024:
Veselina Lachezarova Kanatova-Buchkova – Chairman of the Board of Directors of Bulgarian
Energy Holding EAD as of 31.12.2024. She does not hold any interest as an unlimited shareholder, does
not own more than 25 per cent of the capital of any other company, and does not participate in the
management of any other company or cooperative as a procurator, manager or member of the board.
Kalin Boyanov Filipov – Vice Chairperson of the Board of Directors of Bulgarian Energy Holding
EAD as of 31.12.2024. He does not hold any interest as an unlimited partner, does not own more than
25 per cent of the capital of any other company, and does not participate in the management of any other
company or cooperative as a procurator, manager or member of the board.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
15
Valentin Aleksiev Nikolov – Executive Director of Bulgarian Energy Holding EAD and member of the
Board of Directors since 04.07.2024 and as of 31.12.2024 holds more than 25 percent of the capital of
the following companies: SUZVEZDIE LUV OOD, UIC: 202787168 – sole owner of the capital until
10.01.2024 and partner with 49% participation in the capital from 10.01.2024 until now; MDV
CONSULT Ltd, UIC: 203320833 – Partner with 50 percent participation in the capital until the present
moment. Until 04.07.2024, he participated in the management as Executive Director and member of the
Board of Directors of the following company: Kozloduy NPP EAD, UIC: 106513772.
Galina Tsvetanova Todorova – Executive Director of Bulgarian Energy Holding EAD and member of
the Board of Directors since 04.07.2024 and as of 31.12.2024 does not have any participation as an
unlimited partner, does not own more than 25 percent of the capital of another company, and does not
participate in the management of other companies or cooperatives as a procurator, manager or member
of the board.
Ivan Todorov Andreev – Executive Director of Bulgarian Energy Holding EAD and member of the
Board of Directors until 04.07.2024. Has participation as a member of the Supervisory Board in the
following company: ALLIANZ BULGARIA PENSION COMPANY AD, UIC: 121050885. Since
04.07.2024, he has participated in the management as Executive Director and member of the Board of
Directors of the following company: Kozloduy NPP EAD, UIC: 106513772.
Diyan Stanimirov Dimitrov – Member of the Board of Directors of Bulgarian Energy Holding EAD
until 04.07.2024. Since 04.07.2024 he has participated in the management as Executive Director and
Member of the Board of Directors of the following company: TPP Maritsa East 2 EAD, UIC:
123531939.
Ivo Ivanov Todorov – Member of the Board of Directors of Bulgarian Energy Holding EAD as of
31.12.2024, does not have any participation as an unlimited partner, does not own more than 25 percent
of the capital of another company, and does not participate in the management of other companies or
cooperatives as a procurator, manager or member of the board.
Information on contracts pursuant to Art. 240b of the Commercial Act
The Company has not entered into contracts with members of the Board of Directors, other than
management and control contracts, as well as with parties related to them.
Personnel
Number of personnel:
2024
reported
2023
reported
% of change
2024/2023
19,066 19,604 (2.74%)
Labor productivity - revenue/number of employees (in thousand BGN)
2024
reported
2023
reported
% of change
2024/2023
463.73 587.77 (21.10%)

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
16
Associated parties
As of 31 December 2024, BEH Economic Group has interests in the following joint ventures accounted
for using the equity method in the consolidated financial statements:
Company Country of
incorporation Core Business 2024 Amount of
investments
% thousand BGN
Joint ventures
ICGB AD Bulgaria construction and operation of
a gas transmission system 50.00% 76,392
South Stream Bulgaria
AD Bulgaria construction and operation of
a gas transmission system 50.00% 10,131
SEleNe CC Greece
coordinating the security of
the electricity network in
Southeast Europe
33.33% 4,571
Gastrade S.A. Greece construction of a liquefied
natural gas terminal 20.00% 33,503
Total joint ventures 124,597
As of 31 December 2024, BEH Economic Group has interests in the following associates accounted
for using the equity method in the consolidated financial statements:
Company Country of
incorporation Core Business 2024 Amount of
investments
% thousand BGN
Associates
ContourGlobal
Maritsa Iztok 3 AD Bulgaria generation of electricity 27.00% 52,490
Contour Global
Operations Bulgaria
AD
Bulgaria operation and maintenance of
a thermal power plant 27.00% 2,756
ZAD Energy Bulgaria Insurance company 48.08% 13,185
Allianz Bulgaria
Pension Company AD Bulgaria Pension insurance company 34.00% 32,873
Total associates 101,304
3. Main results for 2024
3.1. Financial result
The reported net financial result of the Group for 2024 is a profit of BGN 246,177 thousand, with an
annual decrease of BGN 864,255 thousand compared to the result in 2023. The change in the financial
result was mainly influenced by the recorded decrease in revenues in each of the Group's business
segments. An analysis of the financial performance of BEH Group by business segments, as well as the
main factors affecting the activities of the Holding companies, is presented below in this section.
The change for each of the main components forming the financial result is presented in the table below:

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
17
Financial results 2024 2023 Change 2024/2023
thousand
BGN
thousand
BGN
thousand
BGN (%)
Total revenue 8,841,436 11,522,622 (2,681,186) (23.27%)
Book value of natural gas, electricity
and other current assets sold (3,405,516) (5,340,727) 1,935,211 36.23%
Operating expenses (4,979,592) (4,853,185) (126,407) (2.60%)
Financial costs, net (103,751) (132,362) 28,611 21.62%
Profit from business combination - 14,446 (14,446) (100.00%)
Profit on sale of investment in joint
venture - 271 (271) (100.00%)
Share of profit from equity accounted
investments 3,716 44,496 (40,780) (91.65%)
Income tax expenses (110,116) (145,129) 35,013 24.13%
Net profit 246,177 1,110,432 (864,255) (77.83%)
BEH EAD was established as a corporate structure uniting the state energy companies. The main
revenues of the Group originate from transmission, storage and sale of natural gas, electricity generation,
transmission and sale of electricity, as well as coal mining and sale.
Taking into account the characteristics of the current market model, the activities of the companies and
their financial results depend on the influence of external factors related to the macroeconomic factors
and market trends, as well as to the market regulation models applied by the independent regulatory
authority – Energy and Water Regulatory Commission (EWRC/the Commission).
The current market model provides for the existence of companies carrying out the functions of a public
supplier of electricity and natural gas. As of 31.12.2024, these functions are performed by two
companies of the BEH Group structure – Natsionalna Elektricheska Kompania EAD – public electricity
supplier and Bulgargaz EAD - public natural gas supplier. In their capacity of public suppliers, both
companies are subject to regulation by EWRC, and the Commission determines the selling prices of
electricity and natural gas at which the companies sell their products to the end suppliers. Due to the
imperfections of the pricing models used on the regulated market existing in the past, especially on the
electricity market, significant price deficits have been generated in the past that have had an impact on
the financial performance and the position of the companies in the Group.
In 2024, BEH Group's earnings before interest, taxes, depreciation and amortization (EBITDA)
decreased by 37.68% on an annual basis and amounted to BGN 1,388,833 thousand compared to BGN
2,228,613 thousand reported in 2023. The Group's operating result at the level of earnings before interest
and taxes (EBIT) for 2024 is a profit of BGN 456,328 thousand, which is BGN 872,382 thousand less
than the operating profit reported a year earlier.
The total assets increased from BGN 27,709,085 thousand at the end of 2023 to BGN 30,091,566
thousand as of 31.12.2024. The reported increase is mainly due to a higher book value of property, plant
and equipment during the period under review, which at the end of 2024 amounted to BGN 21,083,539
thousand compared to BGN 19,084,434 thousand at the end of the previous year. The amount of assets
as of 31.12.2024 is also affected by the increase in trade and other receivables.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
18
Working capital remains positive at BGN 3,291,871 thousand as of 31.12.2024, which means that the
Group is able to cover its short-term liabilities with its current assets.
The table below sets out information on the key indicators of the Group's financial position as of 31
December 2024.
Key indicators 2024 2023 Change 2024/2023
thousand BGN thousand
BGN
thousand
BGN (%)
Total revenue 8,841,436 11,522,622 (2,681,186) (23.27%)
Total expenses (8,385,108) (10,193,912) 1,808,804 17.74%
EВIТDA 1) 1,388,833 2,228,613 (839,780) (37.68%)
EВIТ 2) 456,328 1,328,710 (872,382) (65.66%)
EВТ 3) 356,293 1,255,561 (899,268) (71.62%)
EВIТDA margin 15.71% 19.34% (3.63 p.p.) -
Total assets 30,091,566 27,709,085 2,382,481 8.60%
PPE 4) 21,083,539 19,084,434 1,999,105 10.48%
Working capital 5) 3,291,871 5,608,761 (2,316,890) (41.31%)
Cash 3,699,884 3,878,394 (178,510) (4.60%)
Equity 19,946,205 18,336,668 1,609,537 8.78%
1) EВIТDA – earnings before interest, taxes, depreciation, amortization and
profit in associated and jointly controlled entities;
2) EВIТ – earnings before interest, taxes and profit in associated and
jointly controlled entities;
3) EВТ – earnings before taxes;
4) PPE –property, plant and equipment;
5) Working capital – current assets minus current liabilities
The reported financial results by different types of segments are presented below:

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
19
• Electricity Segment
Electricity 2024 2023 Change 2024/2023
thousand
BGN
thousand
BGN
thousand
BGN (%)
Revenues from sales:
- external customers 6,267,236 7,876,206 (1,608,970) (20.43%)
- other segments 1,657,716 941,215 716,501 76.13%
Segment Revenue 7,924,952 8,817,421 (892,469) (10.12%)
Changes in production and WIP balances 14,089 4,928 9,161 185.90%
Costs for acquisition of property, plant and
equipment 61,858 46,872 14,986 31.97%
Costs of natural gas, electricity and other
current assets sold (3,431,763) (3,781,408) 349,645 9.25%
Expenses for materials (683,787) (1,024,452) 340,665 33.25%
Hired services expenses (430,287) (390,779) (39,508) (10.11%)
Depreciation, amortisation and impairment (521,841) (513,369) (8,472) (1.65%)
Personnel expenses (901,771) (843,943) (57,828) (6.85%)
Impairment of sales receivables, net 17,082 14,457 2,625 18.16%
Net impairment of property, plant and
equipment 2,173 - 2,173 100.00%
Costs for provisions (466,288) (78,249) (388,039) (495.90%)
Other operating expenses (946,502) (1,213,161) 266,659 21.98%
Operating profit from the segment 637,915 1,038,317 (400,402) (38.56%)
Within the Group, operations in the Electricity segment are carried out by the following companies:
NEK EAD, ESO EAD, NPP Kozloduy EAD, TPP Maritsa East 2 EAD and the National Energy
Operator EAD. In compliance with the legal regulations, the companies are holders of licenses for
generation, sale, transmission and trade of electricity. They carry out their operations in compliance with
the requirements of the EU directives and regulations in the field of energy, the Energy Act and the
Ordinance on regulating the prices of electricity. The regulation of their operations is carried out by the
independent specialized authority – EWRC.
The main changes in the operating environment that have affected the activities of the companies in the
Electricity segment are as follows:
• Regulatory interventions in the free electricity market, mainly in the form of revenue caps
for electricity generators and compensation for non-household end customers;
• Decline in prices in European electricity markets, compared to peak prices at the end of 2021 and in
2022;
• Increased construction of installations for the production and consumption of electricity from the sun
in 2024, reaching a share of 29% of the total generation capacity in the country, resulting in a decrease
in production from conventional sources in 2024 compared to the previous year 2023;
• The share of electricity produced by RES in the electricity mix of the Republic of Bulgaria in 2024
reached 25% (2023: 20%). The growth in supply from this type of generators has affected the
competitiveness and volumes of electricity generated by other types of generators;

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
20
• In 2024, the country still has regulated and free markets operating in parallel, with domestic
consumption subject to regulation. An annual decision of the regulator, the EWRC, in the middle of the
calendar year determines the quantities of electricity and the prices at which the Public Supplier (NEK
EAD) buys and sells to meet the needs of end suppliers.
In 2024, the country's total gross electricity generation recorded a decline of 4.9% from the previous
year and amounted to 38,227,519MWh, compared to 40,177,891 MWh a year earlier. The reason for
the reported annual decline is mainly lower electricity demand in 2024 in the region. As a result, the
country's net trade exports contracted significantly compared to the previous year - by 70.7%, reaching
986,984 MWh in 2024 compared to 3,367,785 MWh in 2023.
In 2024, the gross electricity production of the generating companies within the BEH Group amounts to
22,124,462 MWh and shows a marginal growth of 0.93% compared to the reported production in 2023.
In 2024, Kozloduy NPP EAD produced 15,777,075 MWh of electricity, with the share of electricity
from the plant in the electricity energy system (EES) of the Republic of Bulgaria at a record high (after
2020) of 41.6%. NPP Kozloduy EAD delivered 15,031,942 MWh of net active electricity, realized in
accordance with the current regulations. The amount of electricity realized is 2.0% less compared to
2023 due to the reduced production. In accordance with the monthly quotas set by the EWRC, 35% of
the net generation (5,195,990 MWh) was provided by NPP Kozloduy to the Public Supplier at regulated
prices. Regulated market electricity deliveries from the plant are 27% higher than in 2023, which has
had an impact in reduced free market sales.
In addition to the regulated market electricity quantities, in 2024 the plant realised a total of 9,835,953
MWh on the organised exchange market and balancing market, as well as sales under Article 119 of the
EA and supply to own sites under Article 119(1) of the EA. The average selling price of electricity
produced by NPP Kozloduy in all directions in 2024 is BGN 135.99/MWh and is down 17% compared
to 2023. In 2024 NPP Kozloduy EAD maintains its good financial position despite the reported decrease
in sales compared to 2023. The company ended 2024 with a profit of BGN 221,913 thousand (2023:
BGN 537,052 thousand) and cash in the amount of BGN 549,318 thousand . (2023: BGN 912,588
thousand). The main influence on the reported lower financial result was the drop in the prices of the
electricity traded on the stock market, where in 2024 65% of the electricity produced by the company
was sold.
In 2024, TPP Maritsa East 2 EAD reported gross electricity generation of 4,486,222 MWh, which is
15.2% more than its level a year earlier (3,894,419 MWh). In 2024, 3,916,805 MWh of electricity were
sold (2023: 3,269,529 MWh), or an increase of 19.8% compared to the previous year as a result of higher
quantities sold on the regulated market
Pursuant to Order No.E-RD-16-295 of 01.06.2023 of the Minister of Energy and Decision No.C - 14 of
30.06.2023 of the EWRC, a production quota for TPP Maritsa East 2 EAD in the amount of 2,200,000
MWh was determined for the price period from 01.07.2023 to 30.06.2024. By Order No.E-RD-16-310
of 31.05.2024 the Minister of Energy assigned to TPP Maritsa East 2 EAD a total annual quota of
2,628,000 MWh for the next price period from 01.07.2024 to 30.06.2025. Subsequently, by Order No.E-
RD-16-2729, dated December 13, 2024, the quantities were increased to 3,155,000 MWh due to the
increased demands of the public electricity supplier in the second half of 2024. As a result, in 2024 TPP

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
21
Maritsa East 2 EAD will sell 3,233,218 MWh on the regulated market, or more than 3 times more than
in the previous year (2023: 773,754 MWh), with the quantities sold on the regulated market accounting
for 82.5% of the company's total sales.
In 2024, TPP Maritsa East 2 EAD sold 604,617 MWh on the market segments of IBEX EAD, with a
significant decrease of 74.1% compared to the quantities sold in 2023 (2,335,339 MWh). The decrease
is a result of the clear trend in 2024 of decreasing exchange prices for traded electricity in the country
and the region combined with relatively high prices for greenhouse gas emission allowances, which
severely limits the ability of TPP Maritsa East 2 EAD to realize its production at prices that cover full
costs and provide a normal rate of return for the plant.
For participation in load and frequency regulation of the power system in 2024, TPP Maritsa East 2
EAD reports electricity from participation in upward secondary regulation - 54,845 MWh and electricity
from participation in downward secondary regulation - 25,806 MWh.
The reported net financial result of TPP Maritsa East 2 EAD in 2024 is a loss in the amount of BGN
101,595 thousand, compared to a profit of BGN 57,611 thousand in the previous year 2023, or a decrease
of BGN 159,206 thousand. The main reason for the reported negative financial result in 2024 is due to
the lower revenue generated from core business, despite an increase in sales volume, following the
recorded decrease in prices on the regulated and free market.
With the owned hydroelectric plants and PSHPP, NEK EAD is the largest producer of energy from
renewable energy sources in the country, which actively participates in the regulated and free market
and in the control and regulation of the electricity system. The production of electricity from the
company's own hydropower plants and PSHPPs in 2024 was characteristic of a very dry year, with the
hydropower plants in the NEK EAD structure producing 1,861,165 MWh, or 1,301 MWh less (0.1%)
than the quantities in 2023 (1,862,466 MWh). The reported decrease in generation is due to lower
inflows and stored water volumes in the reservoirs in 2024.
During the period under review NEK EAD fulfilled its obligations in accordance with its licensing
activities and provided the required amount of electricity to the end suppliers. The company sold a total
of 15,096,485 MWh of electricity on the regulated and free market in 2024, up 6.0% from the previous
year (2023): 14,238,701 MWh). The reported annual increase in electricity sales in quantity terms is due
to an increase in quantities sold on both the regulated and free markets. As a public supplier,
characteristic for NEK EAD in 2024, the highest relative share (87.7%) in the structure of electricity
sold to the company are the quantities for the needs of the regulated market - 13,241,050 MWh.
NEK EAD reported a positive net financial result for 2024 in the amount of BGN 139,090 thousand, or
an increase of BGN 44,070 thousand compared to 2023, when the company's profit was BGN 95,020
thousand. The increase is mainly the result of an increase in revenues from electricity sold to End
Suppliers and to the platforms of IBEX EAD, as well as an improved structure of purchased electricity
and optimization of trading activities.
For the period January-December 2024, the amount of electricity sold in the country for which the
transmission operator ESO EAD is charged an access price for final customers and transmission is
32,791,026 MWh, up by 706,923 MWh or 2.2% compared to 2023 (32,084,103 MWh). For 2024, the
amount of electricity for which an access price is payable to generators, excluding renewable generators

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
22
with dynamically varying generation - from solar and wind - is 28,225,746 MWh, up by 3,177,438
MWh, or by 10. 1% less compared to the same period in 2023 (31,403,184 MWh), and the amount for
which an access price is payable for solar and wind producers is 6,521,637 MWh, which is 1,643,757
MWh (33.7%) more compared to 2023 (4,877,880MWh).
In 2024, ESO EAD reported a profit of 265,184 thousand BGN, an increase of 5.9% compared to the
result a year earlier (2023: BGN 250,451 thousand). The Company's improved financial result for 2024
is mainly due to higher access revenues for generators and end customers as a result of the higher
reported weighted average price for 2024, as well as growth in market administration revenues. Further
impacting the Company's improved financial position in 2024 was an increase in financing revenue as
a result of compensation received under the Updated Program for Compensation of Non-Household End
Customers of Electricity. The Company also reported lower purchased power costs for transmission
technology expense compared to 2023 due to the decrease in market prices for electricity traded on
IBEX EAD.
• Natural Gas Segment
Natural gas 2024 2023 Change 2024/2023
thousand
BGN
thousand
BGN
thousand
BGN (%)
Revenues from sales:
- external customers 2,341,614 3,323,046 (981,432) (29.53%)
- other segments 242,327 206,123 36,204 17.75%
Segment Revenue 2,583,941 3,529,169 (945,228) (26.78%)
Changes in production and WIP balances 15 2 13 650.00%
Costs of natural gas, electricity and other
assets sold (1,654,435) (2,521,641) 867,206 34.39%
Expenses for materials (7,633) (6,482) (1,151) (17.76%)
Hired services expenses (44,805) (43,290) (1,515) (3.50%)
Depreciation, amortisation and
impairment (305,660) (304,469) (1,191) (0.39%)
Personnel expenses (87,290) (82,688) (4,602) (5.57%)
Impairment of sales receivables, net (71,895) (44,551) (27,344) (61.38%)
Impairment of property, plant and
equipment, net 431 - 431 100.00%
Other operating expenses (126,074) (94,949) (31,125) (32.78%)
Costs for provisions (34,351) (1,230) (33,121) (2692.76%)
Technological costs of natural gas (140,208) (133,835) (6,373) (4.76%)
Operating profit from the segment 112,036 296,036 (184,000) (62.15%)
The operations of transmission, transit, storage and public supply of natural gas are carried out based on
licenses issued to Bulgartransgaz EAD and Bulgargaz EAD in compliance with the Energy Act and the
secondary legislation which follows the European legislation in the field and the regulatory requirements
of EWRC.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
23
In 2024, the amount of natural gas transported by Bulgartransgaz EAD to consumers in the country is
27,850,701 MWh (2023: 26,302,903 MWh), an increase of 1,547,798 MWh (5.9%) compared to 2023.
Traditionally, seasonality in natural gas transport has been maintained in 2024, with the highest volumes
transported in January at 3,082,961 MWh and the lowest volumes transported in July at 1,588,515 MWh.
The change in natural gas transported on a monthly basis shows the most significant increase in
transported natural gas in May, June and November of 2024 compared to 2023.
The deviation in the transmitted quantities of natural gas to the exit points in the country has a direct
correlation with the climate, taking into account temperature changes in the direction of increase, which
in particular affects the consumption of natural gas in the country. The largest decrease was in July by
10.9%, or 195,116 MWh, and the smallest in March - by 1.5%, or 40,498 MWh.
In 2024, the total amount of transited natural gas is 174,925,007 MWh (2023: 145,572,930 MWh), with
a significant increase of 29,352,077 MWh, or 20.2% compared to 2023. The reported changes to
neighboring countries are as follows:
• in the direction of Greece, an increase of 58.9%, or 13,884,027 MWh more compared to 2023 is
reported;
• in the direction of Serbia, an increase of 21.8% is reported, or 19,567,395 MWh more compared
to 2023;
• in the direction of North Macedonia, an increase of 4.9% is reported, or 194,334 MWh more
compared to 2023;
• in the direction of Romania, a decrease of 15.1% is reported, or 4,293,679 MWh less compared
to 2023.
In the direction of Serbia, the quantities transported have the largest share in the total transit of natural
gas in 2024 – 62.4%, followed by the direction of Greece with a share of 21.4%. The least transited
quantities are to North Macedonia – only 2.4% of the total transit.
No cross-border transmission of natural gas to the Republic of Turkey took place during the period
2022-2024, as the commissioning of the Turkish Stream gas pipeline, through which Turkey supplies
its own natural gas, started in early January 2020.
The activity “Natural gas storage” is carried out in the only underground gas storage facility on the
territory of the country - Chiren, owned by Bulgartransgaz EAD. The technological process related to
the natural gas storage service is seasonal (cyclic) and is expressed in the extraction and injection of gas
from/into the underground gas storage. The natural gas produced in 2024 is 4,987,277MWh and is
2,383,454 MWh (91.5%) more than the quantities in 2023 (2,603,823 MWh). The reported injected
natural gas in the Chiren UGS in 2024 is 4,457,001 MWh and is 1,830,677 MWh (69.7%) more than
the injected in the same period of 2023 (2,626,324 MWh).
In connection with the military operations in Ukraine in 2022, the Minister of Energy issued an order
imposing an additional obligation on Bulgartransgaz EAD to serve the public, in order to ensure the
security and continuity of natural gas supplies on the territory of the Republic of Bulgaria. The order
was issued in accordance with the European measures to ensure security, and Chiren UGS reached the
target of 90% occupancy. In 2024, the trend of maximum filling of the gas storage capacity is
maintained. As of 31.12.2024, the natural gas stored by customers in the Chiren UGS is 4,079,062 MWh,
compared to 4,780,893 MWh stored in 2023.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
24
Gas Hub Balkan (GHB) EAD was established as an operator of a natural gas trading platform in
accordance with the Bulgarian Energy Law. In 2024, GHB offered the following services for access to
its e-commerce platform: i) Short-term (spot) segment, which offers short-term standardized products
"within the day", "day ahead", as well as time and local products for the needs of balancing the network
of the transmission system operator. Trade is carried out anonymously, according to the provisions of
Regulation (EU) No.312/2014; ii) Long term segment which offers products traded on medium and
long-term basis - weekly, monthly, quarterly and yearly. (iii) A brokerage service that enables the
conclusion of contracts for the purchase of gas by end customers/end suppliers directly connected to the
gas transmission system of Bulgaria, without incurring costs for membership of the trading platform and
without the need to receive access to access and transmission services through the network of the
transmission system operator Bulgartransgaz EAD.
In 2024, the quantities of transactions in the short-term segment increased compared to the same period
of the previous year by 25.8%, or by 3,307,225 MWh, reaching 16,118,475 MWh. compared to the
12,811,250 MWh reported in 2023. The quantities of transactions in the long-term segment in 2024
reached 26,614,856 MWh, which is 20.1% less compared to the same period of the previous year (2023:
33,323,850 MWh)
At the end of 2024, there were 108 registered participants on the GHB, of which three are transmission
network operators and one mining company.
The activity of Bulgargaz EAD (public supply of natural gas) is regulated by the Energy Act and the
bylaws. With the amendment of Art. 30 par. 1 item 7 of the Energy Act (EE) promulgated in SG No.79
of 2019, the circle of persons to whom Bulgargaz EAD sells natural gas at a regulated price is
significantly narrowed. The change enters into force as of 01.01.2020, as Bulgargaz EAD in its capacity
of Public supplier sells natural gas at regulated prices only to: i) end suppliers of natural gas; ii) persons
to whom a license for the production and transmission of thermal energy has been issued. All other
customers directly connected to the gas transmission network are excluded from the regulated market.
After the changes in the legislation, Bulgargaz EAD conducts its activities as follows: i) on a regulated
market under contracts at the exit point of the gas transmission system of Bulgaria - at prices regulated
by EWRC; ii) on the free market under contracts with customers directly connected to the gas
transmission system - at freely agreed prices; iii) on an organized stock market - at freely agreed prices;
iv) others, outside the organized stock market (in the domestic and international markets) - at freely
negotiated prices; v) sale of services (SWAP operations and others) and extraordinary sales.
For 2024, the reported quantities of natural gas sold amount to 17,806,287 MWh, and compared to those
for 2023 (24,629,913 MWh), they decrease by 6,823,626 MWh, or by 27.7%.
In 2024, the following trends were reported:
• the main consumers of natural gas remained enterprises in the energy sector, as well as
distribution companies;
• A decline in sales was reported in all sectors, with the most significant decrease being reported
in the exchange sales (83%) and chemistry (-77%) sectors compared to 2023.
In 2024, the largest relative share in the structure of natural gas sales were those on the regulated market
– 12,858,251 MWh, or about 72.2% of total sales. In second place in relative share are sales at free
prices on the local and regional market (BTT) – 4,239,451 MWh or 23.8% of total quantities,
respectively. With the lowest share are sales on the free market (outside those on the BTT) – 708,585
MWh, or 4.0% of total sales.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
25
To ensure the natural gas needs of its customers, as of 31.12.2024, Bulgargaz EAD has delivered
17,659,487 MWh of natural gas (for 2023: 25,593,678 MWh). In 2024, the company purchased pipeline
natural gas in the amount of 10,273,658 MWh, liquified natural gas in the amount of 6,960,611 MWh,
purchased quantities at a virtual trading point in the amount of 242,980 MWh and purchased natural
gas under balancing contracts in the amount of 182,238 MWh.
The main supplies of natural gas, guaranteeing the consumption of the company's customers, are
provided through:
• concluded contracts for the supply of liquefied natural gas for 2024 as a result of tender
procedures for liquefied gas supply terminals in Turkey, Revitusa and Alexandroupolis;
• long-term contract concluded with Azerbaijan Gaz Supply Company (AGSC), which is fully
implemented from 01.10.2022 with the launch of the IGB interconnection;
• natural gas purchase and sale agreement with Botas, ensuring regasification and transmission
capacity through the Strandzha 1 - Malkoçlar interconnection point;
• Alexandroupolis terminal, which was put into commercial operation on 01.10.2024, through
which supplies of liquefied natural gas (LNG) were made to the Bulgarian market. The capacity
reserved by Bulgargaz EAD for the next 10 years is 10,600,000 MWh per year.
To ensure the security and continuity of natural gas supplies and to cover the seasonality for its
customers, Bulgargaz EAD uses the capacity of the underground gas storage facility at Chiren UGS,
owned by the combined operator Bulgartransgaz EAD. The operation of the gas storage facility is
cyclical, with the natural gas injection period being May-October and the extraction period being
November-April.
In accordance with the Emergency Action Plan for storing natural gas quantities, in order to compensate
for the seasonal unevenness of its customers, Bulgargaz EAD is obliged to inject, store and extract
natural gas quantities by participating in a public procedure of Bulgartransgaz EAD for the allocation
of storage capacity at the Chiren UGS. The extracted natural gas quantities by Bulgargaz EAD as of
31.12.2024 are 2,199,675 MWh, which is 1,598,123 MWh or 265.7% more than in 2023 (601,552
MWh).
The injected quantities of natural gas by Bulgargaz EAD as of 31.12.2024 are 1,556,523 MWh, which
is 679,552 MWh more than on 31.12.2023, when they were 876,971 MWh. The company has 2,570,234
MWh of gas available in the Chiren UGS as of 31.12.2024, which is a decrease of 643,152 MWh, or
20.0% compared to 2023 (3,213,386 MWh).
The development of the natural gas market in 2024 continued the trend of increasing the share of LNG
deliveries started in 2022 and 2023, in view of the reduced pipeline gas deliveries from Russia to Europe.
On 29 June 2022, Regulation (EU) 2022/1032 of the European Parliament amending Regulations (EU)
2017/1938 and (EC) No 715/2009 as regards gas storage to meet the storage targets in the European
Union entered into force. In this regard, Bulgargaz EAD, as well as other users of the gas storage facility
in Chiren, injected quantities of natural gas above the planned ones at significantly increased prices. In
order to achieve the externally imposed requirements for 80% filling of the storages, it was necessary to
maintain large stocks of natural gas at high prices. Subsequently, market conditions limited the
production of these quantities of natural gas. According to the Regulation, Member States shall take all
necessary measures, including the provision of financial incentives or compensations for market
participants, in order to achieve the filling targets set under the Regulation. In this regard, in 2024, the
Ministry of Energy developed a compensation mechanism under the "Program for Compensation of

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
26
High Prices of Natural Gas Injected into the Chiren UGS for the Period 01.05.2022 - 11.10.2022", for
quantities of natural gas produced in the months of January-April 2024. The compensation was paid by
the Electricity System Security Fund of Bulgargaz EAD, covering up to BGN 150 per MWh, for
quantities of natural gas of 1,045,167 MWh produced by the Chiren UGS for the period 21.11.2022.
until 21.04.2024 and delivered to end customers and/or end suppliers in the European Economic Area.
On 05.09.2024, Bulgargaz EAD received compensation from the Electricity System Security Fund in
the amount of BGN 156,775 thousand. The quantities of natural gas that Bulgargaz EAD failed to extract
from the Chiren UGS by 15 April 2024, were transferred as fulfillment of the obligation under the
Emergency Action Plan for the 2024-2025 gas year.
On the basis of an agreement signed on 30.1.2022 with BOTAŞ BORU HATLARI İLE PETROL
TAŞIMA A.Ş, Bulgargaz EAD secures access to the regasification terminals of liquefied natural gas in
Turkey and its subsequent transfer to the territory of the Republic of Bulgaria, with provided flexibility
of supplies. The period of the Agreement between Bulgargaz EAD and BOTAŞ is 01.01.2023 -
31.12.2035. With Decision No.26 as of 12.01.2023 the Council of Ministers of the Republic of Bulgaria
approves the signed Agreement. The agreement provides capacity for regasification of up to 14 cargoes
(14,000,000 MWh) of liquefied natural gas per year and its subsequent transmission to the
interconnection point on the border of the Republic of Turkey and the Republic of Bulgaria –
Malkoçlar/Strandzha 1, in the amount of up to 19,000,000 MWh per year. The difference in the
quantities between the possibility of delivery of liquefied natural gas and its subsequent transmission is
intended to provide flexibility in obtaining the quantities of delivered liquefied natural gas (estimated as
28% of the total volume). It is management's judgment that during the summer, when demand is lower,
the quantities may not be taken in full, with the greater transfer capacity allowing these not taken
quantities to be taken up during the winter period, when demand is significantly higher. In addition to
this, the flexibility enjoyed by the Company when requesting and receiving quantities saves significant
financial losses from selling natural gas quantities below cost on the exchange and/or as a positive
imbalance to the operator of the gas transmission network, not only in the event of interruption as a
result of repair activities, but also in case of non-payment by the company's customers.
Also, the agreed price for the service provided under the Agreement is fixed for the entire period of the
agreement (with annual inflation indexation, starting from 01.01.2025), which eliminates the risk for the
Company of paying higher prices in the event of high demand for reserving storage and regasification
slots.
The term of the Agreement allows for the conclusion of a long-term contract (over 10 years) for the
supply of liquefied natural gas. In long-term contracts for liquefied natural gas, the prices of the goods
are not tied to the market, as is the case with short-term supplies, but are intended to cover the investment
in the development of a respective gas field and/or a terminal for loading liquefied natural gas.
The conclusion of the Agreement provided a third source of supply for the company, which in turn, in
addition to the above-mentioned advantages, brings security and independence in supplies to Bulgarian
consumers, since in this way Bulgargaz EAD has diversified the routes and sources of supplies,
providing three interchangeable sources of supply.
The management of Bulgargaz EAD believes that according to the currently available information, on
the basis of which forecasts for its future development have been made, as well as due to the continued
financial and operational support from the sole owner of the capital, the Company will continue to
function as a going concern and will settle its obligations according to the maturities and agreed terms.
Given the importance and strategic significance of the activities performed by Bulgargaz EAD,

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
27
Bulgarian Energy Holding EAD, as the parent company, has neither the intention nor is there a legal
need to cease the company's activities, regardless of its financial indicators as of 31 December 2024.
The sole owner of the capital is committed to continuing operational and financial support of Bulgargaz
EAD.
The Company's management has made its assessment of the events, facts and circumstances and, as a
result of the analysis performed, has concluded that the going concern principle has been adequately
applied in preparing the annual financial statements as of 31 December 2024.
• Coal Segment
Coal 2024 2023 Change 2024/2023
thousand
BGN
thousand
BGN
thousand
BGN (%)
Revenues from sales:
- external customers 227,996 319,610 (91,614) (28.66%)
- other segments 153,277 133,290 19,987 15.00%
Segment Revenue 381,273 452,900 (71,627) (15.82%)
Change in finished goods and work in
progress 38,236 55,313 (17,077) (30.87%)
Costs for acquisition of property, plant
and equipment 9,637 11,568 (1,931) (16.69%)
Costs of natural gas, electricity and other
assets sold (9,176) (14,648) 5,472 37.26%
Expenses for materials (96,051) (161,034) 64,983 40.35%
Hired services expenses (32,590) (37,600) 5,010 13.32%
Depreciation, amortisation and
impairment (86,597) (81,278) (5,319) (6.54%)
Personnel expenses (386,055) (356,186) (29,869) (8.39%)
Impairment of sales receivables, net (132) 5,301 (5,433) (102.49%)
Impairment of property, plant and
equipment, net (19,572) - (19,572) (100.00%)
Other operating expenses (6,166) (19,622) 13,456 68.58%
Provision expenses (70,575) 15,136 (85,711) (566.27%)
Operating profit\ (loss) for the
segment (277,768) (130,150) (147,618) (113.42%)
The lignite coal extracted by Mini Maritsa-Iztok EAD is intended for the supply of the thermal power
plants in the Maritsa East complex (TPP Maritsa East 2 EAD, ContourGlobal Maritsa East 3 AD, AES
Maritsa – 3C Maritsa East 1 EOOD and Brikel EAD), with which the subsidiary is linked in terms of
technology and market.
One of the priorities in the activity of Mini Maritsa-Iztok EAD is the implementation of the planned
overburden activities aimed at stabilization of the mining horizons and the increase of the land resistance
coefficient. Therefore, the production levels are consistent on one hand with the extraction opportunities
provided by the land, and on the other hand with the needs of the plants that the company supplies. The

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
28
coal mined and sold in 2024 amounted to 13,745 thousand tons, 5,720 thousand tons (29.39%) less than
the quantity in 2023 (19,465 thousand tons), due to the reported decline in demand from all thermal
power plants of the Maritsa East complex. The most significant decrease in lignite coal consumption
was reported at ContourGlobal Maritsa East 3 AD, respectively from 6,466 thousand tons in 2023 to
838 thousand tons in 2024, due to the expiration of the lignite coal supply agreement on 21.02.2024.
On 30.04.2024, the agreement to the coal export purchase and sale agreement between Mini Maritsa
Iztok EAD and Virom Group OOD Belgrade, Serbia expired, under which no sales were made in 2024,
and 1,063 thousand tons of lignite coal were sold in 2023.
The sales prices of the quantities of lignite coal sold by the company to counterparties throughout the
country during the reporting period were formed at a price of 87.35 BGN/TUG, maintaining the same
price levels from 2023.
• Administrative Activity Segment
Administration activity 2024 2023 Change 2024/2023
thousand
BGN
thousand
BGN
thousand
BGN (%)
Revenues from sales:
- external customers 4,590 3,760 830 22.07%
- other segments 625,342 857,245 (231,903) (27.05%)
Segment Revenue 629,932 861,005 (231,073) (26.84%)
Expenses for materials (237) (301) 64 21.26%
Hired services expenses (7,826) (4,326) (3,500) (80.91%)
Depreciation, amortisation and
impairment (1,490) (1,317) (173) (13.1%)
Personnel expenses (12,450) (10,845) (1,605) (14.80%)
Impairment of sales receivables, net (62,677) 119,670 (182,347) (152.37%)
Impairment of property, plant and
equipment, net (13) - (13) (100.00%)
Other operating expenses (1,315) (1,099) (216) (19.65%)
Costs for provisions - (615) 615 100.00%
Operating profit from the segment 543,924 962,172 (418,248) (43.47%)
Administrative activities are mainly carried out by the parent company BEH EAD, as this segment also
includes the activities of the newly joined company in BEH Group Minproekt EAD. The financial
situation of its subsidiaries is the primary factor that directly affects the revenue amount of BEH EAD.
This is because the dividend received by BEH EAD from its subsidiaries is determined based on the net
financial result reported by the subsidiaries from their operations. In 2024, the reported dividend and
participation income (including income from interest on arrears) amounts to BGN 632,297 thousand
compared to BGN 855,113 thousand of dividend and participation income received in 2023. The most
significant part of them is the dividend income from Bulgartransgaz EAD in the amount of BGN 257,251
thousand, followed by dividend income from NPP Kozloduy EAD and ESO EAD in the amount of BGN
241,673 thousand and BGN 123,503 thousand, respectively. The reported dividend income in 2024 is
lower on an annual basis, since in accordance with item 4 of Order No.1 of the Council of Ministers of
27 March 2024, NEK EAD does not distribute or pay a dividend in favor of BEH EAD in 2024 for the
company's profit for 2023. In comparison, in 2023 the reported dividend from NEK EAD was in the

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
29
amount of BGN 449,314 thousand.
In 2024, the dividend distribution rate from state-owned commercial companies was maintained in
accordance with Order No.1 of the Council of Ministers of 27 March 2024 on the establishment and
payment to the State of deductions from the profits of state-owned enterprises and state-owned
commercial companies, dividend deductions were set at 50% of the net profits of the companies, after
deduction of uncovered losses from previous years and deductions for the Reserve Fund.
At the level of profit before taxes, the result reported by BEH EAD in 2024 is BGN 673,878 thousand
and is BGN 431,894 thousand lower than the reported profit before taxes in 2023 in the amount of BGN
1,105,772 thousand. This result is influenced by the reported net financial income in 2024 of BGN
119,332 thousand. (compared to net financial income of BGN 143,403 thousand in 2023). A significant
part of the company’s financial income came from interest on loans granted to its subsidiaries. In 2024,
the company's reported financial expenses amount to BGN 73,623 thousand. (BGN 74,617 thousand in
2023) and mainly reflect accrued interest on BEH EAD's outstanding bond issues.
3.2. Information on the main intangible resources
The main intangible resources of BEH Group are related to the licenses held by the subsidiaries in the
field of production and trade of electricity and heat and transmission and trade of natural gas. The
licenses are described in detail in Section 1. "General information" of the consolidated activity report
for each company separately.
3.3. Ratios
• Profitability of revenue - net profit/operating income
2024
reported
2023
reported
% of change
2024/2023
0.028 0.096 (70.83%)
This indicator summarizes the overall efficiency of the operations of BEH-group.
• Return on Equity (ROE)
2024
reported
2023
reported
% of change
2024/2023
0.012 0.061 (80.33%)
The ratio indicates the efficiency of turning the equity into profit.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
30
• Return on Assets (ROA)
2024
reported
2023
reported
% of change
2024/2023
0.008 0.040 (80.00%)
The ratio provides information about the efficiency in turning the assets into profit.
3.4. Compliance with the covenants according to the terms and conditions of the bond issues
of BEH EAD
The values of the covenants that BEH EAD is obliged to observe on a consolidated basis according to
the terms of the bond issues placed are as follows:
Covenants as of 31.12.2024 as of 31.12.2023
EBITDA Coverage ratio > 4.0 8.44 12.18
Debt Coverage ratio < 4.5 (0.18) (0.15)
3.5. Commitments, contingent liabilities and other significant events
Litigation and claims arise during the normal course of business of the Company. The Company's
management is of the opinion that the costs necessary to resolve these disputes and claims will not have
a material effect on the financial status and cash flows in future financial periods.
Bulgarian Energy Holding EAD
Proceedings by the European Commission against Bulgarian Energy Holding EAD
Case COMP/B1/АТ.39849 – BEH gas
The case concerns a possible violation of Article 102 TFEU in relation to alleged actions by BEH EAD
and its subsidiaries Bulgargaz EAD and Bulgartransgaz EAD aimed at:
• preventing their competitors from gaining access to key gas infrastructure (gas transmission
network and natural gas storage facility) in Bulgaria, explicitly or implicitly denying access to
third parties or causing delays;
• preventing competitors from receiving access to a main gas import transmission network by
reserving a capacity, which remains unused.
The proceedings were instituted in 2013 with a view to adopting a decision under Chapter 3 (Articles 7
to 10) of Regulation 1/2003.
On 23 March 2015, the EC issued a Statement of Objections. Bulgarian Energy Holding EAD and its
gas subsidiaries submitted their respective responses to the European Commission on 9 July 2015
(Bulgargaz EAD), 10 July 2015 (Bulgarian Energy Holding EAD) and 17 July 2015 (Bulgartransgaz
EAD).
On 24 November 2017, the 44th National Assembly (NA) of the Republic of Bulgaria adopted a decision
to take the necessary action to bring Case COMP/B1/AT.39849 - BEH Gas to a close, whereby the NA

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
31
supports the closure of the case under Article 7 of Regulation (EC) No 1/2003 without admitting the
alleged infringements and without accepting liability for them, by fulfilling the obligations arising from
a possible prohibition order, including a possible financial penalty. Currently, the European Commission
has not made any official decision to close the case, including regarding the possible amount of the
financial sanction.
On 26 July 2018, the 44th National Assembly (NA) of the Republic of Bulgaria adopted a decision to
take action to close Case COMP/B1/AT.39849 - BEH Gas pursuant to Article 9 of Regulation (EC) No
1/2003 by entering into commitments on the Bulgarian side and reaching an agreement with the
European Commission. The second decision of the National Assembly is justified by the development
of case COMP/B1/AT.39816 between the EC and Gazprom, where on 24 May 2018 the Commission
announced that an agreement had been reached and it was terminated pursuant to Art. 9 of Regulation
(EC) No.1/2003 without a financial penalty.
On 17 December 2018, the European Commission notified the adoption of Decision C(2018)8806 under
Case AT.39849 BEH-Gas, whereby the European Commission imposed a fine on Bulgarian Energy
Holding EAD (BEH), its subsidiary for gas supply – Bulgargaz EAD – and its subsidiary –
Bulgartransgaz EAD (BEH Group) – in the amount of EUR 77,068,000 for preventing competitors from
accessing key gas infrastructure in Bulgaria in breach of EU antitrust rules. The decision was received
in the offices of the three companies on 19 December 2018, which set the start of the appeal period of
the EC Decision (two months and ten days after notification of the Decision to the parties), and for
payment of the fine (three months after the notification of the Decision to the parties) set therein.
Appealing the decision does not delay payment of the fine.
On 18 March 2019, ING Bank NV issued two unsecured bank guarantees in favor of the EU with a total
amount equal to the amount of the fine of EUR 77,068,000, as follows:
- a bank guarantee in the amount of EUR 51,379 thousand, covering 2/3 of the total amount of
the fine, securing the obligations of Bulgarian Energy Holding EAD and Bulgargaz EAD;
- bank guarantee in the amount of EUR 25,689 thousand, which guarantees the liability of
Bulgartransgaz EAD for the imposed sanction.
On 4 July 2019, the Bulgarian State, through the Ministry of Foreign Affairs, filed an application to
intervene in the case in support of BEH EAD and its gas subsidiaries.
On 26 August 2019, the European Commission presented before the General Court its Defense in
response to the complaint lodged by Bulgarian Energy Holding EAD, Bulgargaz EAD and
Bulgartransgaz EAD.
On 29 November 2019, Bulgarian Energy Holding EAD, Bulgargaz EAD and Bulgartransgaz EAD filed
an Opposition against the European Commission Defense.
On 20 February 2020, the Republic of Bulgaria filed through the Ministry of Foreign Affairs, within the
period specified by the General Court of the European Union, the official position of the Republic of
Bulgaria on Case Т-136/19, submitted by the Ministry of Energy and the Ministry Foreign Affairs,
whereby the State intervened in support of Bulgarian Energy Holding EAD, Bulgargaz EAD and
Bulgartransgaz EAD against the European Commission, before the General Court of the European
Union. The General Court examines additional documents and requested information in order to clarify
all the circumstances involved in the case. By letter of 14 March 2022, the Court requested the European
Commission to provide non-confidential versions of the documents listed by the Court.

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On 29 September 2022, the court session ended with oral hearings under the BEH Gas case, within
which the parties summarized their positions and the court asked questions that were addressed by the
parties.
On 25 October 2023, the court of first instance rendered a Decision in favor of Bulgarian Energy
Holding EAD, Bulgartransgaz EAD and Bulgargaz EAD, with which it completely annulled the fine
imposed by the European Commission on the three BEH-group companies in the amount of
EUR 77,068,000.
On 11 January 2024, the European Commission filed an appeal against the decision of the court of first
instance, requesting the annulment of the Decision of the General Court in its entirety. Based on the
appeal, case C-14/24 R was initiated before the Court of Justice of the European Union – European
Commission against BEH and others.
BEH Group filed a response to the complaint of the European Commission to the Court of Justice of the
European Union On 29 March 2024.
On 22 July 2024, the European Commission submitted a counter-answer to the Court of Justice of the
European Union.
On September 30, 2024, BEH Group provided a response.
On 25 October 2023, the General Court of the European Union annulled in full the Decision of the
European Commission in Case AT.39849 – BEH Gas, by which the Commission sanctioned, with a fine
of EUR 77,068,000, BEH EAD, Bulgargaz EAD and Bulgartransgaz EAD for abuse of a dominant
position, preventing access to the Bulgarian gas infrastructure in the period from 30 July 2010 to 1
January 2015.
The Bulgarian state is also an interested party in the case. On 11 January 2024, the European
Commission filed an appeal against the decision of the court of first instance. To date, replies have been
filed by BEH EAD, Bulgartransgaz EAD and Bulgargas EAD and the State against the European
Commission's appeal in Case C-14/24 before the Court of Justice of the European Union.
The Bulgarian side has also submitted a justification for the Court to allow oral hearings as at first
instance. Oral hearings in the case are expected in the second quarter of 2025.
4. Risk factors
The Group's risk management policies identify and analyse the risks affecting the Group, set risk limits
for individual types of risks, define rules for risk control and compliance with the established limits.
Risk management policies and systems are subject to regular review in order to identify the changes
occurred in the market and activities. By trainings and application of the established standards and
procedures, the Group aims to develop discipline and constructive control environment where all
employees understand their role and obligations. The main types of risks to which the Group is exposed
in the course of its business are as follows:
4.1. Interest rate risk
Interest rate risk is the risk of adverse change in interest rates leading to an increase in interest expenses
and/or a decrease in the company's interest income.
The Group is exposed to the risk of changes in market interest rates mainly in relation to the financial
assets and liabilities with a variable (floating) interest rate, as well as in relation to defined staff benefit

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plans, calculated on the basis of a discount factor which is determined at the basis of the market yield of
government securities.
The interest-bearing assets in the structure of the Group's assets are represented by cash, bank deposits
and loans, the majority of which have a fixed interest rate. The Group also has loans granted with a
combined structure of the borrowing rates, which contains two components – fixed and variable. The
borrowings of the Group are in the form of long-term and short-term loans and predominantly have a
fixed interest rate. This minimizes the likelihood of a change in the unfavorable direction of cash flows.
4.2. Currency risk
The Group carries out purchases, sales, lending and borrowing operations in foreign currencies – Euro,
US Dollars, Japanese Yen, British Pounds, Swiss Francs and Macedonian Denars. The main part of
these operations is carried out in EUR and USD.
As the BGN/EUR exchange rate is fixed at 1.95583, the currency risk arising from the Group’s euro
exposures is minimal.
The Group makes payments for construction and installation works, deliveries for assets under
construction and goods in US Dollars. In this regard, there is a risk of changes in exchange rates.
Consequently, the Group is exposed to the risk of changes in the exchange rate of the US dollar. In the
event of material fluctuations in the future, the Group may hedge its exposure through derivative
instruments such as foreign currency swaps.
4.3. Liquidity risk
Liquidity risk arises if the Group fails to meet its obligations when they become due. The group carries
out ongoing monitoring and control of cash outflows and applies an approach that ensures the necessary
liquidity resource to meet the obligations incurred under normal or stressful conditions without realizing
unacceptable losses.
One of the objectives of the parent company is to provide, if necessary, financial resources to its
subsidiaries in order to maintain their operations and to implement certain strategic projects.
The parent company finances the operating activities of the companies in the Group in two ways:
• Internal financing - within the economic group, by redistribution of the free cash resource.
Bulgarian Energy Holding EAD acts as an intermediary between the companies in the corporate
structure, coordinating the conditions between them and monitoring for the execution of
transactions at market levels. The interest rates on cash loans and foreign currency deposits are tied
to a rate that is the market rate for such transactions during the transaction period (floating or fixed).
• External financing – in case of shortage of funds in the economic group, Bulgarian Energy Holding
EAD may take actions for external financing. This is a preferred way to raise funds for investment
projects. The holding has successfully implemented 4 (four) bond issues since 2013. The funds
raised were used to implement investment projects, repay and refinance loans, as well as for general
corporate purposes, with the exception of coal-related activities.
4.4. Market risk
The manifestation of risk is expressed in changes in market conditions regarding prices, exchange rates,
interest rates or equity instruments and their impact on the Group's income from the investments made.
The purpose of market risk management is to exercise control over the exposure to market risk within
acceptable parameters by optimizing returns.

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The Group undertakes periodic analyses of the macroeconomic environment in the country and in-depth
analysis of specific macro-indicators, including information on interest rates, which are submitted to the
Board of Directors. The Board is responsible for assessing the future risks faced by the Group. In the
event of deteriorating market conditions, hedging instruments may be used.
4.5. Credit risk
In the course of its activities, the Group is exposed to credit risk, which is associated with the risk for
some of the counterparties not to be able to fulfill their obligations in full and within the usual deadlines.
IIn this regard, the credit quality of customers is assessed, taking into account financial condition, past
experience and other factors. Regular monitoring of the assessment results is carried out, on the basis of
which, if necessary, impairment is calculated, in accordance with applicable international accounting
standards.
The Group's receivables are presented in the consolidated statement of financial position in net amount
in net amount, after deducting the accrued impairment for the expected credit loss.
In relation to the credit risk of uncollectibility of receivables from counterparties, the Group takes the
following precautionary measures:
• for trade and other receivables that are overdue and were not secured upon their origination,
deferred payment arrangements are concluded and a collateral of not less than the initially
recognized amount of the claim is negotiated;
• for other contracts that are not secured, the following usual measures are taken in advance in
case of overdue payment by the debtor company – offsetting liabilities to the Group against
overdue receivables of the debtor, and if the amount of the liabilities is not big enough to cover
the receivables, then other out-of-court options for settling the claims are sought.
The Group is currently monitoring and analysing the servicing of the receivables, the reasons for the
defaults and the changes in the financial capacity of the debtor companies and the status and quality of
the collaterals received.
The group has a significant concentration of credit risk in respect of receivables from Toplofikatsia Sofia
EAD.
Credit risk arising from other financial assets of the Group, such as cash and other financial assets, is
the credit exposure of the Group arising from the likelihood that its contractors may fail to meet their
obligations.
The Group's maximum credit exposure in respect of financial assets amounts to their respective carrying
amount in the consolidated statement of financial position as of 31 December 2024.
4.6. Regulatory risk
Regulatory risk is determined by the specifics of the business activity. Pursuant to Art. 21, paragraph 1,
item 8a, item 8b, item 8c, 8d, 8g, 8h, 8i, Art. 30, para. 1 and Art. 33a of the Energy Act, the following
prices are subject to regulation by the EWRC:
o determines for each price period a limit value of the costs of the electricity transmission network
operator for the purchase of availability for additional services in accordance with Art. 105, para. 2;
o determines annually by June 30 premiums for electricity from renewable sources and from high-
efficiency combined production of electricity and heat, generated by power plants with a total
installed electrical capacity of 500 kW and over 500 kW

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o determines monthly compensation to cover part of the costs of household end customers for
purchased electricity from an end supplier at regulated prices;
o for the purposes of pricing, determines annually by June 30 an estimated market price of
electricity to cover the technological costs of the transmission system operator and the distribution
system operators;
o monitors market developments, assesses the risks that may arise from new products and services,
and takes measures against abuse;
o exercises control over the possibility for transmission system operators to impose limitations on
the capacity provided or operational restrictions, based on transparent and non-discriminatory
procedures that do not create barriers to market entry;
o may authorise the transmission system operator and distribution system operators to carry out
activities other than those provided for in this Act and in Regulation (EU) 2019/943 of the
European Parliament and of the Council of 5 June 2019 on the internal market in electricity (OJ
L 158/54 of 14 June 2019), hereinafter referred to as Regulation (EU) 2019/943, if such activities
are necessary for the performance of their obligations under this Act or Regulation (EU)
2019/943;
o at which the producers sell thermal energy to the heat transmission company and to directly
connected customers;
o at which the heat transmission company sells thermal energy to customers;
o at which the public supplier sells natural gas to the end suppliers of natural gas and to a person who has
been issued a license for production and transmission of heat energy; the prices are approved on monthly
basis and are applied from the first day of the month for which they are approved;
o at which end suppliers sell natural gas to customers connected to the respective gas distribution
networks;
o for access and/or transmission through the transmission grid;
o to connection to the grids;
o for access and transmission of natural gas through transmission and/or distribution networks,
except in the cases where the Commission at its discretion approves a methodology for setting a
price for access and transmission through the transmission grid;
o for access and/or transmission through the electricity distribution grids;
o for access and storage of natural gas in a storage facility;
o for distribution of traction electricity on the distribution grids of the railway transport;
o For the provision of services to customers, as determined by the Commission, related to the
licensing activity;
o including the price or the price component at which all end customers connected to the electricity
system, including the electricity transmission system operator and the electricity distribution
network operators, shall contribute for compensation of the costs under Art. 34 and Art. 35.
o The Commission sets premiums for power plants with a total installed electrical capacity of 500
kW and over 500 kW for the electricity produced from highly efficient combined heat and
electrical energy production;
o The premiums are determined annually by June 30 as the difference between the preferential
prices of producers and the estimated market price determined for this period for electricity
produced in a highly efficient combined cycle manner.
Price regulation has a significant impact on revenues, expenses, and hence on the overall economic and
financial condition of the Group.
4.7. Cash flow risk

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The cash flow risk depends on fluctuations in the amount of future cash flows associated with a
possessed financial instrument. The Group plans its cash flows and floating rate financial instruments
are of a short-term nature of less than 1 year.
Detailed information regarding the Group's financial risk management objectives and policy and the
main categories of financial assets and liabilities, is included in the consolidated financial statements of
BEH EAD for 2024.
5. Future development, investments, forthcoming significant transactions and other information
under Art. 247 of the Commercial Act
5.1. Future development of Bulgarian Energy Holding EAD
The objectives of BEH EAD are focused on the following main and priority areas:
Financial sustainability of BEH Group
• Improving corporate management practices
- Increasing the transparency and sustainability of BEH Group in accordance with OECD
principles and the Guidelines for Corporate Governance of State-Owned Enterprises.
• Providing funding for key activities and projects:
- Effective management of financial assets and instruments;
- Participation in the capital markets in order to attract external financing from international
financial institutions under competitive terms;
- Using the advantages that result from the scale of the holding structure (economy of scale);
- Support to independent transmission operators in the process of negotiating the necessary
credit resources to finance projects of particular importance to companies, in the context of
climate change mitigation and sustainable development of the low-carbon economy
• Cost optimization in BEH Group:
- Forecasting and planning the expenses of BEH Group;
- Transparency and predictability of expenses;
- Increasing the efficiency of the business activities.
• Elimination of deficits in BEH Group:
- Ongoing monitoring and control over the amount of the generated tariff deficit;
- Cooperation and support to the Ministry of Energy, EWRC and the Energy Commission in
the development of normative and regulatory changes related to the reformation of the sector
and the compensation of the generated tariff deficits in the system.
Ensuring the security of the energy system in the country
• Diversification of the sources and routes for supply of natural gas in the country through
projects for:
- Increasing the capacity for natural gas transmission from Greece to Bulgaria and from
Bulgaria to Romania (Vertical Gas Corridor);

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- Increasing the capacity for transmission of the Greece-Bulgaria gas interconnector to 5
billion cubic meters per year by conducting annual capacity auctions with neighboring
operators in case of interest in additional quantities;
- Shareholding in the liquefied natural gas terminal (LNG terminal) near Alexandroupolis,
Greece
- Research of the possibilities and expediency of possible participation in other new
investment intentions to build terminals for liquefied natural gas in the region;
- Participation in tenders for reserving capacities at terminals of liquefied natural gas in Turkey
and Greece;
• Security, reliability and continuity of gas supplies
- Expansion of the capacity of Chiren UGS and its transformation into a commercial storage
facility.
• Construction of new capacities, extending the life of existing facilities, guaranteeing the
security of the electricity system, combined with ensuring long-term profitability:
- Ensuring the long-term operation of the 5th and 6th nuclear power units above their design
until 2047 and 2051 respectively and the implementation of measures ensuring the operation
of the units at increased power;
- Diversification of supplies of fresh nuclear fuel while complying with nuclear safety
conditions and requirements;
- Taking actions for construction of the 7th and 8th units at site No.2 of the NPP Kozloduy
EAD with the AP1000 technology.
- Rehabilitation of hydropower capacities, expansion of the production capacity and
modernization of the capacities with the purpose of ensuring the long-term and effective
exploitation of the hydropower resources of our country;
- Construction of new PSHPP on existing dams (Batak and Dospat).
• Decarbonization:
- Ensuring a fair and smooth transition to a low-carbon energy sector;
- Generation and transmission of electricity with a low or zero carbon footprint through
projects to build new capacities and infrastructure.
- Integration of decarbonization goals with the strategic direction and development framework
of the energy sector in Bulgaria;

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• Development of transmission infrastructure and digitization of the activity management
systems:
- Comprehensive modernization of the planning, management and maintenance activities of
the electricity transmission network in the country through the introduction of state-of-the-
art digital tools and methods to ensure the necessary maneuverability and security in the
conditions of low-carbon production;
- Increasing the transmission capacity of the electric power system and construction of new
infrastructure for the rapid implementation of RES capacities.
• Liberalization of the gas market:
- Development of a competitive and integrated natural gas market and strengthening the
position of the Republic of Bulgaria as a regional gas trader.
5.2. Expected investments
Gas interconnector Greece-Bulgaria
The Greece-Bulgaria Gas Interconnector project (IGB project) was implemented in pursuance of the
policy of the Republic Bulgaria, aimed at increasing the security of natural gas supplies by providing
infrastructure for access to alternative sources and routes for supply of natural gas and ensuring the
country's physical connectivity with the Southern Gas Corridor. With the project, put into operation on
1 October 2022, the construction of a gas pipeline with a capacity of 3 billion cubic meters per year from
Komotini to Stara Zagora, with a length of 182 km, 151 km of which on Bulgarian territory, was carried
out.
With the commissioning of the IGB gas pipeline, Bulgaria and Greece are now able to respond
effectively to supply disruptions from external sources or seasonal peaks in the consumption of natural
gas. This is infrastructure that ensures transit transmission, and also ensures crisis supplies and covers
peak usage in the months of increased consumption.
Currently, the gas pipeline operates with a transmission capacity of 3 billion m3 per year, which, with
additional investment, can reach 5 billion m3 per year depending on the market interest.
Expansion of the capacity of Chiren underground gas storage
The only underground gas storage facility in the country Chiren is owned by Bulgartransgaz EAD. The
project for expansion of the capacity of Chiren UGS consists of step-by-step increasе of the capacity of
the only gas storage facility on the territory of Bulgaria with the purpose of achieving larger volumes of
stored gas, increased pressures in the gas tank and higher average withdrawal and injection capacity.
The project envisages an increase in the volume of working gas to 1 billion m3 and an increase in the
withdrawal and injection capacity to 8 - 10 million m3/day.
Grant funding of nearly 78 million euros has been allocated from the Connecting Europe Facility (CEF)
for the implementation of the project. In order to support the Chiren UGS expansion project, a State
guarantee in the amount of BGN 208 million for Bulgartransgaz EAD was included in the State Budget
Act for 2025.
On 22 June 2022, a grant agreement was signed with the European Executive Agency for Climate,
Infrastructure and Environment (CINEA) for the co-financing of the expansion of the Chiren UGS with

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the following identification number and name: Project 101069718 — 6.20.2-BG-WM-21-Extension of
the Chiren UGS. The total value of the costs, according to the decision of the EC to approve the
financing, is in the amount of EUR 155,820 thousand. The amount of the grant is 50% of the value of
the grant agreement - up to EUR 77,910 thousand. As of the date of preparation of the financial
statement, an advance payment of EUR 38,955 thousand, or 50% of the value of the financing, has been
received. In June 2024, an interim payment of EUR 271 thousand was received under the agreement. In
March 2025, Amendment No.1 to the grant agreement was signed, according to which the project
implementation period was extended until 07.12.2027.
Acquisition of a share of the rights and obligations under the Oil and Gas Exploration Contracts in
the area of Block 1-21 Han Asparuh
By Decision of the National Assembly of the Republic of Bulgaria of 21.07.2023 (prom. SG
No.63/2023) the Minister of Energy was instructed to negotiate the terms and conditions for BEH EAD
to acquire up to 20% of the rights and obligations under the Oil and Gas Exploration Contracts in the
area of Block 1-21 Han Asparuh.
The Decision under item 21 of Protocol No.25 of the meeting of the Council of Ministers on 5 June
2024 authorizes TotalEnergy EP Bulgaria B.V. to transfer its share of 57.14 percent of the rights and
obligations arising from the permit to OMV Offshore Bulgaria GMBH. The same decision extends the
term of the permit for oil and gas exploration in the area by 23 months as a result of a delay caused by
a force majeure event (the decision of TotalEnergies EP Bulgaria B.V. to withdraw from the permit and
the contract, as well as the continuation of the military actions of Russia against Ukraine, and the
consequences of the same on the security of the Black Sea while carrying out the operations), certified
by Force Majeure Certificate No.007/09.02.2024, issued by the Bulgarian Chamber of Commerce and
Industry.
Pursuant to Decision No.394/07.06.2024 of the Council of Ministers, Supplementary Agreement No.10
to the Exploration Contract was signed, whereby TotalEnergies EP Bulgaria B.V. transferred its 57.14%
interest in the rights and obligations under the permit to OMV Offshore Bulgaria GMBH, with the
company now holding a 100% interest in the project.
By Decision No.83 of 20 February 2025 of the Council of Ministers (prom. SG No.16/2025) OMV
Offshore Bulgaria GMBH was allowed to transfer 50 percent of the rights and obligations arising from
Decision No 649 of the Council of Ministers of 2012. For the grant of the oil and gas exploration permit
- underground resources, in the area of Block 1-21 Han Asparuh, located in the exclusive economic zone
of the Republic of Bulgaria in the Black Sea, to NewMed Energy Balkan Limited, operating through its
branch NewMed Energy Balkan Limited - Branch Bulgaria foreign trader branch (FTB).
Pursuant to an item in the above decision, on 12 March 2025, the Minster of Energy entered into a
supplemental agreement with the parties for a partial assignment of the rights and obligations under the
oil and gas exploration contract. The oil and gas exploration in Block 1-21 Han Asparuh has thus been
continued, with the two companies (OMV Offshore Bulgaria GMBH and NewMed Energy Balkan
Limited - Bulgaria Branch FTB) now each holding a 50 percent stake in the project, with OMV Petrom
(through OMV Offshore Bulgaria GMBH) as its operator. The block is located in the exclusive
economic zone of the Republic of Bulgaria in the deep Black Sea and, upon successful production and
future discovery of the block's gas potential, the country would have its own energy source that would

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provide it with natural gas at the most affordable prices possible, guaranteeing the country's energy
independence. Additionally, the development of the field is expected to stimulate investor interest in the
region and increase the competitiveness of the sector and of household and industrial consumers of
natural gas.
The parties are exploring the possibility of acquiring a share of BEH EAD for participation in the
exploration activities under the Oil and Gas Exploration Contract.
Building New Nuclear Capacity
In fulfillment of Bulgaria’s strategic goals to ensure its energy independence and security in 2023, steps
were taken to build two new nuclear units with a total installed capacity of 2300 MW. In early 2023, an
agreement was signed with Westinghouse Electric Company LLC for the provision of front-end
engineering design (FEED) services to support the construction of an AP1000 nuclear reactor facility at
the NPP Kozloduy site.
On 18 December 2023, a Decision of the National Assembly was adopted (prom. SG No.105/2023) to
take action on the construction of Units 7 and 8 at NPP Kozloduy Site No.2 with AP-1000 technology
with an indicative schedule of priority activities Annex No.1 to the Decision.
Pursuant to the decision, in the second half of December 2023 the Ministry of Energy and BEH EAD
started preliminary preparation of documentation for the pre-selection process of construction
companies, and on 28 December 2023 Bulgarian Energy Holding EAD increased the capital of NPP
Kozloduy - New Builds EAD by a cash contribution of BGN 1,500,000 thousand.
Following a procedure for the selection of a contractor for the project and in accordance with the
Decision of the National Assembly of 23 February 2024, negotiations have been launched with Hyundai
Engineering & Construction Co., which has been shortlisted as a potential construction company for the
engineering, construction, delivery and commissioning of a nuclear power plant at the approved site in
Kozloduy, with AP1000 technology. In November 2024, an engineering contract was signed between
NPP Kozloduy - New Builds EAD and a consortium between the Korean Hyundai Engineering and
Construction and the American Westinghouse Electric Company. In October 2024, an extension of the
Front End Engineering Design (FEED) contract was signed with Westinghouse Electric Company for
the construction of Units 7 and 8 with AP1000 type reactors at the NPP Kozloduy site.
Planned increase in the capital of BEH EAD in the Updated Medium-Term Budget Forecast for the
period 2025-2028
By Decision of the Council of Ministers No.88 of 24.02.2025, an Updated Medium-Term Budget
Forecast for the period 2025-2028 was approved. It is part of the explanatory memorandum to the draft
law of the State Budget of the Republic of Bulgaria for 2025 (prom. SG No.26 of 27.03.2025). In view
of the implementation of investment programs, as well as of assigned public policies for the
capitalization of commercial companies with state participation in the capital, a capital increase of BEH
EAD in the total amount of BGN 2.5 billion is envisaged. This is aimed at providing financing for
structurally decisive projects in the energy sector, such as the Chaira, Batak and Dospat pumped storage
hydropower plants, NPP Kozloduy Units 7 and 8, hydroelectric power plants, hydropower transmission
infrastructure, projects to increase the technical capacity for gas transmission, expansion of the gas
transmission network, reconstruction of power lines, etc. In addition, a BGN 250 million capital increase

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of BEH EAD is foreseen to provide funds to Mini Maritsa Iztok EAD for the implementation of technical
reclamation of the disturbed areas of the East Maritsa Coal Basin deposit.
Digital Transformation of the Power Grid Project
The aim of the project is a comprehensive modernization of the planning, management and maintenance
activities of the electricity transmission grid of the Republic of Bulgaria through the introduction of the
most modern digital tools and methods to ensure the necessary maneuverability, security and quick
response in the management of the power system in the conditions of low carbon production. ESO EAD
is implementing investment C4.I4 Digital Transformation of the Electricity Transmission Network, part
of the Recovery and Resilience Plan of the Republic of Bulgaria, with an approved budget of BGN 611
million (co-financing BGN 370 million from the Recovery and Resilience Mechanism and BGN 241
million from own funds). The investment is being implemented in accordance with an operational
agreement signed by the Ministry of Finance, the Ministry of Energy and ESO EAD.
The implementation of the activities started in early February 2020 and is scheduled to be completed by
the end of March 2026.
GREENABLER Project
The project "Sustainable adaptation of the national transmission network for full integration of the
potential for renewable energy production" (Bulgarian Grid REinforcement ENABLing Full-Fledged
Clean Energy Rollout - GREENABLER) is planned to be implemented through financing from
RePowerEU (EUR 225.5 million) and the Modernization Fund (EUR 631.4 million), with 90% (EUR
771.2 million), with a total indicative budget of EUR 856.9 million, to be financed free of charge. The
project includes (group 1) investments in the reconstruction of about 720 km of existing power lines to
increase their nominal voltage from 220 kV to 400 kV and (group 2) investments in the reconstruction
of the Hemus - Stara Planina power line from 220 kV to 400 kV, reconstruction of 888 km of 110 kV
power lines and doubling of 92 km of 110 kV power lines in order to increase the transmission capacity
of existing overhead power lines.
Following the published EC Decision on 12.06.2024 on allocating funds for the implementation of the
investments for 2024 from the first group with funds from the Modernization Fund, a grant agreement
was signed between the Ministry of Energy and ESO EAD on 23.12.2024. The deadline for
implementing investments under the Modernization Fund is the end of 2030, and under REPowerEU -
at the end of 2026.
5.3. Future developments in 2025 by segments
• Electricity Segment
Considerable dynamics and unpredictability of the market environment are expected in the current and
coming years as a result of significant external factors, such as ongoing military conflicts and a highly
volatile electricity market in terms of price. Internal factors such as measures to protect businesses from
high electricity prices and frequent changes in the regulatory framework also have an impact.
With amendments adopted at second reading on May 16, 2025 in the Energy Act of the fifty-first
National Assembly of the Republic of Bulgaria, which are expected to be promulgated in the State
Gazette the current model of parallel functioning of a regulated and free market is changing and a
transition to the next stage of the liberalization of the electricity market, which provides for full
liberalization of the wholesale electricity market from 01.07.2025, while maintaining household

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42
consumers on a regulated market. In this regard, in order to guarantee the security of electricity supplies
to households after 1 July 2025 and given the withdrawal of NEK EAD as a public supplier, the
amendments to the Energy Act aim to ensure the needs of end suppliers to cover the electricity
consumption of households in the country by creating a new mechanism (segment) on the exchange
market, which includes long-term products. This segment will be open to all sellers (i.e. producers and
traders of electricity) and will include a newly created non-standard product (traded on an organized
exchange market), which will be tailored to the specific consumption profile of end suppliers. The model
provides for NEK EAD to act as a coordinator of a balancing group, which will have the opportunity to
offer electricity to the specially created new market mechanism.
In line with the provisions set out in the approved by Decision of the Council of Ministers No.237 of 22
April 2025 draft amendment to the National Recovery and Resilience Plan of the Republic of Bulgaria,
the government's position on dropping the commitment to liberalize the retail market for household
consumers by 31 December 2025 at the latest, with the adopted changes to the Electricity Act, the
transitional period for the functioning of the electricity market is extended, with the introduction of the
liberalization of the retail market being postponed to a later stage, when adequate mechanisms for the
protection of Bulgarian consumers have been developed.
The strategic goals of NPP Kozloduy EAD are related to ensuring the highest level of safety, efficient
and competitive production, maintaining qualified, competent and motivated personnel and preserving
the financial stability of the company. In order to meet the requirements of EURATOM, an Agency for
diversification of fresh nuclear fuel (FNF) supplies, the activities under the contracts concluded with
Westinghouse for supply of fresh nuclear fuel cartridges for Unit 5 and with Framatom for supply of
FNF for Unit 6 will be carried out.
From the second half of 2025, NPP Kozloduy EAD will conclude transactions with electricity only on
an organized stock market, with the exception of the sales under Art. 119 of EA. A priority for a basic
nuclear producer such as NPP Kozloduy EAD, operating entirely in market conditions, is to ensure the
operation of the units with nominal power (base load) in the long term, in strict compliance with the
characteristic technological requirements and limitations. In this regard, the commercial activity of the
company in the future will be aimed at ensuring the full realization of the produced electricity. The
company's price policy for free supply will be oriented towards ensuring secure and rhythmic sales
revenue, in line with market conditions.
The main challenge for NPP Kozloduy EAD is the implementation of the Decision of the National
Assembly (NA) for undertaking specific steps on the construction of units 7 and 8 at site No.2 of NPP
Kozloduy EAD with AR1000 technology. The construction of a new nuclear capacity is related to the
need for the Bulgarian state to take actions to ensure long-term base capacity in connection with the
green deal and the ongoing energy transformation, given the advantages and the capabilities of nuclear
energy as a safe, reliable, sustainable and low-emission alternative. With the Decision of the National
Assembly (prom., SG No.105 of 19.12.2023) an indicative time schedule for the project implementation
was also approved. The first steps were taken with the increase of the capital of the project company
NPP Kozloduy - New Builds EAD by BGN 1,500 million, by increasing the capital of NPP Kozloduy
EAD. The purpose of this action was to provide the funding necessary for the starting the next stage of
the investment intention for construction of a new nuclear capacity, where a contract for execution of
the actual engineering, including also a technical design, will be awarded. By decision of Protocol
No.102-0224/23.10.2024 of the Board of Directors of BEH EAD, consent was given to decisions taken
by Protocol No.51/23.10.2024 of the Board of Directors of NPP Kozloduy EAD to increase the capital
of NPP New Builds EAD by BGN 300 million. At this stage, it is planned to start the activities on the

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43
structuring the project financing and the beginning of negotiations with banking institutions, with a view
to attracting the necessary funds.
The future development of NEK EAD will be in accordance with the licenses held by the company and
will be determined by the future model for full liberalization of the electricity market. The activity of
the company will be aimed at fulfilling the main obligations of NEK EAD as a Public Supplier to satisfy
the consumption of the End Suppliers until this activity ceases as a result of the legislative changes. In
parallel with this, the company's goal is not to allow a price deficit and to demand from the EWRC a
mechanism for recovery of the one accumulated to NEK EAD until now to be developed. In the field of
production, the company will strive to use the available water resources as efficiently as possible, as
well as to gradually refurbish the facilities to ensure their safe and reliable operation. On the free
electricity market, NEK EAD will strive to expand its market share through the hydro facilities at its
disposal providing vital services for balancing the electricity system of the country.
In line with the European requirements to achieve zero carbon neutrality, NEK EAD is actively
exploring possibilities for construction of renewable energy sources, electricity storage systems (through
batteries and PSHPP), modernization and expansion of the existing capacities and other projects in this
direction.
In order to ensure the adequacy of the energy sector in Bulgaria in the long-term perspective, it is of key
importance to preserve the power generation capacities, which have a key role on the one hand for
generation, and on the other for the regulation of the electricity system, as well as building new ones,
by using innovative, low-carbon and sustainable technologies.
The TPP Maritsa East 2 EAD strategy of includes the implementation of investment projects, the main
goal of which is the modernization of the Power Plant and limiting environmental pollution. The
completion of already started projects and the implementation of new ones is a prerequisite for TPP
Maritza East 2 EAD to maintain its key position as one of the main producers of electricity in the
country. A higher capacity utilization with a lower emergency rate, higher efficiency and environmental
friendliness of the plant, ensuring energy security in the country, is achieved as a result of the
implementation of the investment and repair programs.
To ensure the adequacy of the energy sector in Bulgaria in the long term, it is of key importance to
preserve electricity generation capacities, which play a key role on the one hand for generation and on
the other in the regulation of the electricity system, as well as to build new ones through the use of
innovative, low-carbon and sustainable technologies. In this regard, the role of the transmission system
operator in the process of transition to a low-carbon market model is of key importance and covers
directions such as the integration of new renewable capacities through implementation of innovations
contributing to the flexibility and development of the transmission network, increasing and efficient
distribution of intersystem capacity and last but not least - ensuring the necessary level of security of
supply.
• Natural Gas Segment
The market goals of Bulgargaz EAD are related to maintaining market positions in the country and
entering new regional gas markets. To achieve these goals, Bulgargaz EAD has obtained licenses for
natural gas trade in Greece and Hungary, as well as permits for natural gas supply to Slovakia and
Romania. The company is a registered user of the gas transmission networks of Bulgartransgaz EAD-
Bulgaria, DESFA SA-Greece, TRANSGAZ SA-Romania, ICGB Bulgaria, GASTRANS d.o.o. -Serbia.

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44
Diversification of supply sources
Bulgargaz EAD ensures the supply of natural gas through a long-term contract for supply of Azerbaijani
natural gas from the Shah Deniz field through the IGB (Greece-Bulgaria intersystem connection) gas
pipeline with Azerbaijan Gas Supply Company (AGSC), concluded in 2013, with validity period 25
years from the date of the first delivery - 31.12.2020. Bulgargaz EAD has reserved a long-term capacity
in the IGB gas pipeline, corresponding to the quantities of Azeri gas agreed for delivery.
Pursuant to the state strategy for diversification of natural gas supply routes and sources for the country
and Decision No.166 of 10 March 2020 of the Council of Ministers, Bulgargaz EAD has reserved
capacity at the liquefied natural gas terminal to Alexandroupolis for the supply of 5,300,000 MWh/year
for a period of 10 years. Pursuant to Decision No.661 of 15 September 2022 of the Council of Ministers
(CoM), Bulgargaz EAD has reserved an additional capacity at the liquefied natural gas terminal near
the town of Alexandroupolis, Republic of Greece - Gastrade S.A., for 5,300,000 MWh/year (≈ 500
million cubic meters per year) for a period of 10 years, starting from the year of commercial operation
of the terminal (from 2024), with which the total reserved capacity is 10,600,000 MWh/year.
In order to secure the delivery routes from the LNG terminals to the Bulgarian gas transmission network,
Bulgargaz EAD participates in tenders and reserves non-interruptible capacity products at entry-exit
points of the Bulgarian gas transmission network. For entry points where there is a risk of interruption
of capacity products (points where only interruptible products are offered), Bulgargaz EAD was able to
carry out the delivery through swap transactions, thus avoiding the risk of interruption of capacity
products.
At the end of 2022, an Agreement was signed between Bulgargaz EAD and the Turkish state gas
company BOTAŞ BORU HATLARI İLE PETROL TAŞIMA A.Ş, whereby Bulgargaz EAD is granted
access to the regasification terminals of liquefied natural gas in the Republic of Turkey for 1.5 billion
cubic meters per year and the subsequent transfer of quantities of natural gas to the interconnection point
between the Bulgarian and Turkish gas transmission networks - Strandzha/Malkoclar, for the period
2023 - 2035. The signing of the Agreement with Botash provides a strategic partnership and makes it
possible to balance the supply portfolio of Bulgargaz EAD, providing three entry points from LNG
terminals located in the Aegean Sea - Botash, Revitousa and Alexandroupolis. The agreement entered
into force after its approval by Decision No.26 of 12.01.2023 of the Council of Ministers of the Republic
of Bulgaria.
By a National Assembly Decision of 19.04.2024, the Minister of Energy was assigned to take the
necessary actions to renegotiate the Agreement between Bulgargaz EAD and Botas. Bulgargaz EAD
and Botas are in active negotiations to renegotiate the Agreement, with the Ministry of Energy providing
the necessary institutional and political support.
Diversification of delivery routes
The Republic of Bulgaria has a strategic geographical location, a well-developed gas infrastructure with
a high level of interconnection and significant capacity. With the implementation of new infrastructure
projects, the country is developing its potential of being an increasingly significant factor in ensuring
energy independence and diversification of sources and routes for the supply of natural gas for the
region.

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With the implementation of new gas infrastructure projects in the country and the region, a significant
increase in the quantities of natural gas from alternative sources is expected, which will be transported
through the gas transmission infrastructure of Bulgartransgaz EAD both for Bulgaria and for the
countries of the region.
On 1 October 2024, the LNG terminal near the city of Alexandroupolis was put into operation, equipped
with a state-of-the-art technology facility, allowing for regasification with a maximum capacity of 5.5
billion cubic meters per year. The terminal consists of a floating LNG storage and regasification facility,
an underwater and onshore gas pipeline, and a metering station, where the facility connects to the
national gas transmission system of the Republic of Greece. Thanks to the project, additional quantities
of natural gas will be provided for the gas markets in the region, offering access to various sources
(USA, Egypt and others). Through existing and planned gas pipelines in the region, natural gas from the
terminal will be supplied to consumers in Bulgaria as well as the Republic of North Macedonia, Serbia,
Romania, Hungary, Moldova and Ukraine, providing them with the opportunity to take advantage of
the dynamically developing LNG market and the benefits it offers - flexibility, competitiveness and
security of supply, as well as access to new gas suppliers for natural gas supplies. On 3 October 2024,
the first delivery of liquefied natural gas to the Republic of Bulgaria took place, with the regasification
of one million megawatt hours of liquefied natural gas.
The vertical gas corridor is a strategic project for ensuring security of supply and diversification of
natural gas supplies for Bulgaria and the countries of South-Eastern, Eastern and Central Europe. The
projects, developed by Bulgartransgaz EAD, to increase transmission capacities from Greece to Bulgaria
and from Bulgaria to Romania are a key part of the overall vision of the Vertical corridor, as their
implementation and the already available infrastructure in Bulgaria are the basis for achieving the set
goals for diversification and improving the security of supplies.
A project in the conceptual phase is the construction of a second gas interconnector between the
Republic of Bulgaria and the Republic of Northern Macedonia with Petrich - Strumica route. The
development of intersystem connectivity between the Republic of Bulgaria and the Republic of North
Macedonia will contribute to increasing the energy security and integration of the energy markets.
Natural gas storage
Strategic importance for the Republic of Bulgaria has the project to increase the capacity of Chiren UGS
facility and its turning into a commercial storage facility. Chiren USG plays a major role in
compensating for the seasonal irregularity in the consumption of natural gas in the country and providing
an emergency reserve in unforeseen and force majeure situations. The increased storage, extraction and
injection capacities will give the market an additional flexibility and will ensure the security of natural
gas supplies and will contribute to improving competition and access to natural gas from alternative
sources. In this way, the project will help increase the liquidity of the gas markets in Bulgaria and the
region.
The expansion of the Chiren UGS is in synergy with the LNG terminal project near Alexandroupolis, in
which Bulgaria participates through Bulgartransgaz EAD with a 20% shareholding. In this way gas
traders and users in the region will be enables to take full advantage of the dynamic development and
competitive advantages provided by the liquefied natural gas market. This will enable gas traders and
users in the region to take full advantage of the dynamic development and competitive advantages
provided by the liquefied natural gas market. The Bulgarian participation in the project is strategically

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important for the diversification and security of energy supply for Bulgaria and other countries in the
region.
Shrinking consumption and increasing the storage capacity
The escalation of the Russian military aggression against Ukraine since February 2022 has led to a
significant reduction in gas supplies, leading to a record high and volatile energy prices and it created
the risk of a further economic decline in Europe.
In order to ensure the security of gas supplies in the EU, Council Regulation (EU) 2022/1369 of 5 August
2022 lays down rules for dealing with a situation of serious difficulties in the field of gas supplies. In
order to ensure the security of gas supplies in the EU, Council Regulation (EU) 2022/1369 of 5 August
2022 lays down rules for dealing with a situation of serious difficulties in the field of gas supplies.
According to the Regulation, the member states should make every possible effort to reduce their gas
consumption in the period from 1 August 2022 to 31 March 2023 by at least 15% compared to their
average gas consumption in the period from 1 August until 31 March in the five consecutive years
preceding the entry into force of the Regulation. The continuing need to reduce gas demand in order to
ensure security of supply and limit price volatility has led the Council to extend the Regulation by 1
year - until 31 March 2024. According to the Council Recommendation of 27 February 2024 the validity
of the Regulation was extended for a new period from 1 April 2024 to 31 March 2025 ("reduction
period") by at least 15% compared to its average gas consumption in the reference period from 1 April
2017. until 31March 2022.
In addition to the reforms adopted in the internal gas market, on 29 June 2022, the EU adopted
Regulation (EU) 2022/1032, which obliges all EU members to fill their gas storage facilities to at least
80% of their capacity. The validity of the Regulation has been extended also in 2024, when by 1
November the storage facilities shall be 90% full. To achieve the goals of 80% gas storage capacity,
reduced customer consumption and the high cost of gas in the storage, production for the 2022-2023 gas
season was severely limited, which led to the presence of large natural gas stocks at the end of the season
- April 2023.
Bulgargaz EAD produced quantities during the period January-April 2024, with the set production price
being significantly below their acquisition cost. In this way, the company was able to reduce its stored
quantities and sell them on the market.
The quantities of natural gas that Bulgargaz EAD was unable to produce from the Chiren UGS by
15.04.2024 were transferred as fulfillment of the obligation under the Emergency Action Plan for the
2024/2025 gas year.
• Coal Segment
The climate neutrality road map of Bulgaria, adopted by decision No.59 of 26.01.2024 of the Council
of Ministers, considers both the risks associated with climate change and the changing realities regarding
the electricity industry in Bulgaria and the interacting economic, environmental and social factors.
Based on the conclusions in the Report of the Energy Transition Commission, the final date for the
gradual cessation of the use of coal is 31.12.2038, and subsequent implementation of measures to restore
the disturbed areas and preparation for new economic activities in the Company.
In response to the challenges faced by Mini Maritza - East EAD, actions are taken to preserve the energy
profile of the region, through investments in the field of clean technologies, low-emission productions

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and scientific research and development activities, using the potential of the available infrastructure,
human capital and land.
Mini Maritza - East EAD also plans actions aimed at developing projects and adapting financing
programs using sources such as:
➢ The Just Transition Fund, which is a financial instrument within the Cohesion Policy and aims
to provide support to territories facing serious socio-economic challenges arising from the
transition to climate neutrality;
➢ The Modernization Fund, which is funded by the from the emissions allowances auctions as per
the EU Emissions Trading Scheme, with the aim of supporting the transition to climate
neutrality;
➢ The Cohesion Fund, the purpose of which is to strengthen the economic, social and territorial
cohesion of the European Union to promote sustainable development;
➢ The Social Climate Fund, established by Regulation (EU) 2023/955 of the European Parliament.
By a decision of the National Assembly in 2024 (published in the SG № 38/30.04.2024), it was assigned
for all necessary actions to be taken in compliance with the applicable Bulgarian and EU legislation to
provide funds from the state budget to Mini Maritsa-Iztok EAD, in the amount of BGN 250,000
thousand per year for a period of four years, in order to ensure activities for technical reclamation of the
disturbed terrain of the East Maritsa Coal Basin deposit. The funds will be provided only and solely on
the condition that the reclamation activities are carried out solely by Mini Maritsa-Iztok EAD, and no
assignment or subcontracting of the activities to private companies and/or companies with state or
municipal participation is allowed.
• Corporate governance
BEH EAD will actively continue its activities on the implementation of effective management practices
within the Group. The aim of the management is to provide a long-term vision for the development of
the Group companies which is in line with the Energy Strategy of Bulgaria.
The management of BEH EAD works in close cooperation and takes advantage of the necessary support
from the State represented by the Minister of Energy. In the process of management of the holding and
its subsidiaries, all important decisions regarding the management strategy and their future development
are taken after being agreed and approved by the principal – the Minister of Energy.
6. Events after the reporting period
No adjusting events or significant non-adjusting events have occurred since the date of the reporting
period to the date of approval of the consolidated financial statements for publication, except for the
following non-adjusting events:
Changes in the Accounting Act
In February 2025, the National Assembly adopted amendments to the Accountancy Act aimed at
postponing the requirements for non-financial reporting by enterprises by one year. The changes were
published in the State Gazette, issue 17 of 28.02.2025. Initially, according to European Directive
2022/2464, companies with over 500 employees had to submit non-financial sustainability reports for
2024. With the new amendments, this deadline has been extended by one year, with the first submission

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48
of such reports being for 2025. The changes aim to facilitate the transition and adaptation of companies,
reducing the risk of inaccuracies and improving the quality of the reports.
Target contributions to the Security of the Electricity System Fund
With § 2, para. 1 of the Final Provisions of the Law on the Collection of Revenues and the Execution of
Expenditures in 2025, until the adoption of the Law on the State Budget of the Republic of Bulgaria for
2025, the mechanism for collecting targeted contributions to the "Security of the Electricity System"
fund has been extended. The target contribution represents the positive difference between market
revenues and the determined revenue ceiling for the relevant type of producer, with a delivery period
from 1 January 2025 to 31 December 2025.
Changes in the Energy Act
With amendments adopted at second reading on May 16, 2025 in the Energy Act of the fifty-first
National Assembly of the Republic of Bulgaria, which are expected to be promulgated in the State
Gazette, the current model of functioning of the electricity market in our country is changing. The
change provides for full liberalization of the wholesale electricity market from 01.07.2025, while
maintaining household consumers on a regulated market. It is envisaged that end suppliers will supply
end household customers, and a new mechanism (segment) of IBEX EAD is being created to ensure the
necessary quantities of electricity. This segment will be open to all sellers (i.e. producers and traders of
electricity) and will include a newly created non-standard product (traded on an organized exchange
market), which will be tailored to the specific consumption profile of end suppliers. The model provides
for NEK EAD to act as a coordinator of a balancing group, which will have the opportunity to offer
electricity to the specially created new market mechanism.
Determining a revenue ceiling for electricity producers for the period July 1 – December 31, 2025.
With a decision of the Council of Ministers No.380 of May 28, 2025 the values are determined (in BGN
per MWh) that serve to calculate the revenue ceiling for the respective type of electricity producer
under § 2, para. 1 of the Final Provisions of the Law on the Collection of Revenues and the Execution
of Expenditures in 2025 until the adoption of the Law on the State Budget of the Republic of Bulgaria
for 2025., The State Social Security Budget Act for 2025 and the National Health Insurance Fund Budget
Act for 2025 are determined for the period July 1, 2025 - December 31, 2025, as follows:
a) for electricity produced by nuclear power plant – 120 BGN per MWh;
b) for electricity produced by hydroelectric power plants owned by the National Electricity Company
EAD – 140 BGN per MWh;
c) for electricity produced by coal-fired condensing power plant, including lignite coal - 400 BGN,
increased by the average monthly price per ton of CO2 emission allowances multiplied by 1.32, per
MWh;
d) for electricity produced by coal with added biomass fuel (solid or gas biomass fuels) and/or waste,
and/or petroleum products, and/or a combination thereof - BGN 400, increased by the average monthly
price per ton of CO2 emission allowances multiplied by 0.9, per MWh;
e) for electricity produced by renewable sources without a contract for compensation with premiums –
300 BGN per MWh.

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49
Bulgarian Energy Holding EAD
Change in the Management Bodies of Bulgarian Energy Holding EAD
By a protocol decision of 7 February 2025 of the Minister of Energy Galina Tsvetanova Todorova was
released as a member of the Board of Directors of Bulgarian Energy Holding EAD and Diyan Atanasov
Ivanov was elected in her place until a new tender procedure is held. The change was entered in the
Commercial Register and the Register of Non-Profit Legal Entities on 13 February 2025.
By a protocol decision of 16 May 2025, the Minister of Energy released Veselina Lachezarova
Kanatova-Buchkova as Chairperson of the Board of Directors of Bulgarian Energy Holding EAD and
Vasil Georgiev Stoynov was elected in her place until a new competition procedure is conducted. The
change was entered in the Commercial Register and the Register of Non-Profit Legal Entities on 22 May
2025.
Credit rating of Bulgarian Energy Holding EAD
On 17 March 2025, Fitch Ratings revised the outlook on Bulgarian Energy Holding EAD's long-term
rating (BB+) to stable from positive and affirmed the rating on its unsubordinated and unsecured debt
at BB+. The outlook revision reflects the expected increase in leverage and high capital expenditure
associated with the construction of the new nuclear units.
Decisions on the establishment and payment to the state of profit deductions from state-owned
enterprises and commercial companies with state participation in capital
The Council of Ministers (CoM), by Order No.1 of 2 May 2025, has determined that state-owned
enterprises and commercial companies with state participation in the capital, with the exception of
hospitals, mental health centers and companies in the Water Supply and Sewerage sector, shall distribute
a dividend for the financial year 2024, in compliance with the requirements of Art. 247a of the
Commercial Act, after deducting the deductions for the Reserve fund, when this fund is not replenished,
in accordance with Art. 101 of the State Budget Act of the Republic of Bulgaria for 2025 - 100 percent.
Pursuant to the Order, Bulgarian Energy Holding EAD shall distribute and pay a 6-month (interim)
dividend based on the adopted 6-month financial statements as of 30 June 2025 in the amount of 100
percent of the reported profit, subject to the relevant application of Article 247a of the Commercial Law.
Natsionalna Elektricheska Kompania EAD
Change in the management of Natsionalna Elektricheska Kompania EAD
On 7 March 2025, Georgi Georgiev Dobrev was listed as a member of the Board of Directors and
Executive Director, replacing Martin Ivanov Georgiev.
On 20 March 2025, Nadya Georgieva Stefanova was listed as a member of the Board of Directors,
replacing Alexander Yulianov Rusanov.
TPP Maritsa Iztok 2 EAD
Determining the revenue ceiling for an electricity producer
With the Decision of the Council of Ministers No.121/05.03.2025 on determining the values used to
calculate the revenue ceiling for an electricity producer from a coal-fired condensing power plant,
including lignite, the amount of BGN 300, increased by the average monthly price per ton of CO2
emission allowances multiplied by 1.32, for one MWh, was determined.

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NPP Kozloduy EAD
Additional quantities of electricity from NPP Kozloduy EAD for purchase from the public supplier
By Decision No.Ts-3/01.01.2025 of the EWRC, the estimated monthly availability for electricity
production of the producers from whom the public supplier shall purchase electricity, and the quantities
of electricity that the public supplier shall provide to cover the consumption of the customers of the end
suppliers, as determined by Decision No.Ts-17/30.06.2024 for the period 01.07.2024 – 30.06.2025, has
been amended. As of 01.01.2025, additional quantities of electricity from NPP Kozloduy EAD in the
amount of 400,000 MWh have been determined, whereby the quota for the regulated market determined
for the period 01.07.2024 - 30.06.2025 changes from 5,431,200 MWh to 5,831,200 MWh, while
maintaining the current regulated price of 65.47 BGN/MWh.
Set a revenue ceiling for a producer type
By Decision of the Council of Ministers No.121/05.03.2025, a revenue ceiling for the type of producer
NPP was set at 150 BGN/MWh for the period from 01.01.2025 to 31.12.2025. The same, according to
item 2 of the decree, may be changed if necessary upon a proposal by the Minister of Energy.
Diversifying of fresh nuclear fuel
In accordance with the terms of Addendum 52 to the contract with AO TVEL, two deliveries of fresh
nuclear fuel were made. On 25 March 2025, the first delivery of 42 TVSA-12 cartridges and 12 pcs. of
PP SUS (absorbing rods for control and protection systems), and on 23 April 23 2025, the second
delivery of 42 TVSA-12 cartridges was made. On 10 April 2025, 42 RWFA nuclear fuel assemblies
manufactured by Westinghouse Electric Sweden AB were delivered.
Bulgargaz EAD
Extension of the term of a bank guarantee
Pursuant to a contract concluded in 2020 with a banking institution, the company was granted a credit
product in the form of an issued bank guarantee in favor of a supplier of natural gas. The term is renewed
periodically, every six months, and in the last reference - a term until 11 August 2025 and an amount of
USD 140,362 thousand.
Release of bank guarantee
On 28 January 2025, the LNG terminal near Alexandroupolis stopped operating due to a technical
failure. The operator of the terminal Gastrade S.A. was unable to set a date from which the terminal is
expected to resume operations. Therefore, Bulgargaz EAD requested the release of the bank guarantee
in the amount of EUR 48,679 thousand, which maintains credit protection in favor of Gastrade S.A.
Conclusion of overdraft agreements by banking institutions
To secure natural gas supplies in January and February 2025, Bulgargaz EAD withdrew overdrafts from
banking institutions, guaranteed by BEH EAD, with a total limit of BGN 220 million.
Mini Maritsa-Iztok EAD
Change in the Board of Directors of Mini Maritsa-Iztok EAD
According to minutes No.13-2025 of 20 February 2025, a decision was made at a meeting of the Board
of Directors of Mini Maritsa-Iztok EAD to change the composition of the Board of Directors Stelian
Koev was released as a member and Tihomir Tenev was elected in his place. The change was entered
in the Commercial Register and the Register of Non-Profit Legal Entities on 7 March 2025.

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
51
Bulgartransgaz EAD
Additional increase in the subordinated bond loan provided by each shareholder in the capital of
Gastrade S.A.
In accordance with decisions of the Management and Supervisory Boards, on 13.02.2025,
Bulgartransgaz EAD transferred from the Company's account at the National Bank of Greece, on which
a pledge was established, EUR 2,910 thousand for an additional increase in the subordinated bond loan
provided by each shareholder.
Change in the Management and Supervisory Board of Bulgartransgaz EAD
By its decision of 17 January 2025, the Supervisory Board of Bulgartransgaz EAD elected Vladimir
Malinov as a member of the Management Board of the gas transmission operator. The decision of the
Supervisory Board was approved by the Energy and Water Regulatory Commission on 23.01.2025. As
of 29.01.2025, Vladimir Malinov has been entered as the Executive Director of Bulgartransgaz EAD in
the Commercial Register and the Register of Non-Profit Legal Entities, replacing Kiril Ravnachki.
As of 25 March 2025, Ekaterina Mihaylova, who replaces Alexander Kanazirski, is entered in the
Commercial Register and the Register of Non-Profit Legal Entities as a member of the Supervisory
Board of Bulgartransgaz EAD.
Change in the Audit Committee of Bulgartransgaz EAD
By its decision of 3 April 2025, the Board of Directors of Bulgarian Energy Holding EAD released
Silvia Todorova as a member of the Audit Committee of Bulgartransgaz EAD and elected Lilyana
Dragieva as a member of the Audit Committee as of 3 April 2025, with the mandate of the remaining
members.
Change in the Board of Directors of Gas Hub Balkan EAD
According to the decision of the Board of Directors of Gas Hub Balkan EAD of 29 January 2025,
Vladimir Malinov was elected as a member of the Board of Directors, and Darina Koleva was released
as a member of the Board of Directors of Gas Hub Balkan EAD. These circumstances were entered in
the Commercial Register and the Register of Non-Profit Legal Entities on 4 February 2025.
Early repayment of loan agreements with banking institutions
On 8 April 2025, a loan agreement concluded in 2021 with UniCredit Bulbank AD in the amount of
EUR 20,000 thousand was repaid early.
On 11 April 2025, a loan agreement concluded in 2021 with Investbank AD in the amount of EUR
10,333 thousand was repaid early.
Conclusion of annexes to loan and collateral contracts
In accordance with decisions taken by the Management and Supervisory Boards of Bulgartransgaz EAD,
annexes to concluded loan and collateral agreements have been signed with:
United Bulgarian Bank AD - Annex No.3 dated 24.04.2025 to the 2020 loan agreement, which reduces
the loan interest rate from EURIBOR+1.75% to EURIBOR+1.40%
DSK Bank AD - Annex No.4 dated 17.04.2025 to the 2020 loan agreement, which reduces the loan
interest rate from 1M EURIBOR+1.65% to 1M EURIBOR+1.39%

Bulgarian Energy Holding EAD
ANNUAL CONSOLIDATED MANAGEMENT REPORT
For the year ending 31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
52
DSK Bank AD - Annex No.4 dated 17.04.2025 to the 2021 loan agreement, which reduces the loan
interest rate from 1M EURIBOR + 1.65% to 1M EURIBOR+1.39%
Citibank Europe AD - Annex No.1 dated 17.04.2025 to the 2021 loan agreement, which reduces the
loan interest rate from the APR+1.70% to the APR+1.40%
D Commerce Bank AD - Annex No.3 dated 24.04.2025 under a loan agreement from 2021, by which
the interest rate on the loan is reduced from 1M EURIBOR+1.75% to 1M EURIBOR+1.20% and a
change in the interest rate under the collateral agreement from 0.01% to SOFR - 0.40%.
Electricity System Operator EAD
Change in electricity prices by decision of the EWRC
EWRC opened a procedure for amending the electricity prices approved by Decision No.Ts-17 of
30.06.2024 and from 01.01.2025 by Decision No.Ts-3/01.01.2025 approved new prices for electricity.
With the new pricing decision, the Regulator changes the estimated market price for base load
determined by ESO EAD for the period 01.01.2025 - 30.06.2025 from 178.64 BGN/MWh to 219.01
BGN/MWh, or an increase of 22.6% The increased amount of the approved costs for the purchase of
technological losses leads to a change in the pricing elements forming the transmission price, which
changes from 12.70 BGN/MWh to 13.66 BGN/MWh according to Decision No.Ts-3/01.01.2025. The
remaining parameters and prices for ESO EAD, approved by Decision No.Ts-17/30.06.2024, remain
unchanged.
Memorandum of Support and Cooperation
On 20 March 2025, a Memorandum of Support and Cooperation was signed between ESO EAD,
Bulgarian Development Bank EAD, National Association of Municipalities in Bulgaria and the
Association of Bulgarian Employers' Organizations, with which the parties declare their readiness for
joint cooperation to promote a Mechanism for financing activities for optimizing electricity
consumption costs in municipal companies, public enterprises, private legal entities, etc. The
Mechanism will be implemented by ESO Charge EAD through several methods, including the
construction of production capacities from renewable sources on rooftops, storage facilities, energy
arbitrage, with financing from Bulgarian Development Bank EAD and their payment through contracts
for guaranteed results for clients.
National Energy Operator EAD
Change in the management of National Energy Operator EAD
By decisions of Minutes No.16-2025/28.02.2025 of the Board of Directors of Bulgarian Energy Holding
EAD, Georgi Georgiev Dobrev was released as a member of the Board of Directors of National Energy
Operator EAD and the management contract was terminated, without release from liability. Said Haisam
Hamameh was elected in his place for a period from the date of entry of the decision in the Commercial
Register and the Register of Non-Profit Legal Entities until a new competition procedure is conducted.
The change was entered in the Commercial Register and the Register of Non-Profit Legal Entities on 7
March 2025.
VALENTIN NIKOLOV Signed with electronic signature
EXECUTIVE DIRECTOR
BULGARIAN ENERGY HOLDING EAD
15.05.2025
City of Sofia

BULGARIAN ENERGY HOLDING EAD
CONSOLIDATED CORPORATE GOVERNANCE STATEMENT
31 December 2024

1. GENERAL PROVISIONS
This Corporate Governance Statement consisting of the parent company Bulgarian Energy Holding EAD (BEH EAD,
the Company) and its subsidiaries was prepared in compliance with the requirements of Art. 40 para. 1 of the
Accountancy Act and according to Art. 100n, para. 8 in relation to para. 7, item 1 of the Public Offering of Securities
Act (POSA).
Bulgarian Energy Holding EAD is a public interest entity under §1, item 22 of the additional provisions of the
Accountancy Act and Art. 2 of Directive 2013/34/EU of the European Parliament and of the Council whose
transferable securities are admitted to trading on a regulated market in a Member State of the European Union.
BEH EAD is a separate legal entity under the Bulgarian law, a sole-owner joint stock company acting in accordance
with the provisions of the Commercial Act, the Public Enterprises Act, the Rules on the application of the Public
Enterprises Act (the Rules) and the other legislative acts of the Republic of Bulgaria. The sole owner of the capital,
who has all the rights of a shareholder under the law and the Articles of Association, is the Bulgarian state through
the Minister of Energy.
The Company is managed by a one-tier management system. The Board of Directors has management, representative
and control functions.
The implementation of the Corporate Governance Code is both a statutory requirement and a result from the
willingness of the management for a constant improvement of the principles and practices for corporate governance
established within the Company. The efforts of the executive management are focused on the transparency of the
activity through presentation of due and complete information, stakeholder consideration, independence, and
prevention of conflict of interests.
The Group observes the established principles and norms of corporate governance provided for in the effective
legislative acts, applicable for its activity. Furthermore, the Company is involved in certain actions and policies with
regard to the subsidiaries’ sustainable development, including the disclosure of information, related to the climate and
social aspects of their activity. The Board of Directors of BEH EAD encourages the implementation and monitors the
observation on behalf of the subsidiaries of the established principles for sustainable development at a group level,
and it also contributes to the establishment of sustainable development culture.
The BEH Group places great importance on fostering effective relationships with various stakeholders. These
stakeholders include certain individuals or groups directly impacted by the Company’s operations and who also
possess the ability to influence its activities. This includes suppliers, clients, employees, creditors, advocacy groups,
and others. The Company identifies these stakeholders based on their significance, areas of influence, roles, and
commitment to sustainable development. The Board of Directors of BEH EAD complies with legal requirements when
engaging with stakeholders. The corporate management of the Holding and its subsidiaries guarantees respect for the
stakeholder rights as mandated by law or through mutual agreements with the companies. In accordance with the good
practice of corporate governance, the Holding takes the stakeholders interest in consideration in accordance with the
principles of transparency, accountability and business ethics.
The Consolidated Corporate Governance Statement of BEH Group is a separate report, which is published along with
the consolidated management report, and both documents are subject to publication on the parent company’s corporate
website: www.bgenh.com.

Bulgarian Energy Holding EAD
Consolidated corporate governance statement
31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
3
2. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 1 of POSA
BEH EAD adheres, as appropriate, to the National Corporate Governance Code, established by the Chairperson of the
Financial Supervision Commission within the meaning of art. 100n, para. 8, i. 1, letter “a” of POSA by Decision
No.850-ККУ of 25.11.2021 and adopted by the National Corporate Governance Committee. The Code is applied on
a “comply or explain” principle, i.e. in case of diversion the management clarifies the reasons for this.
The parent company protects the rights of the sole shareholder – the state, described in Chapter 3 of the National
Corporate Governance Code.
BEH EAD implements a Corporate Governance Policy, adopted by the Board of Directors of BEH EAD by a
Resolution under item I.2. of Protocol No.27-2018/17.05.2018. The main purpose of the Corporate Governance Policy
is maintaining and improving standards and management quality corresponding to the best world practices for
transparency, respect to the interested parties, independence, and avoidance of conflict of interests in implementing
the Company activity. As a public enterprise in the energy sector, BEH E AD plays a key role for the economy of
Bulgaria, which predetermines the significance of the good corporate governance. BEH EAD is aware of its
importance for maintaining the economic effectiveness and competitiveness of the Republic of Bulgaria. Its
implementation raises the efficiency, transparency, and responsibility of Bulgarian Energy Holding EAD in pursuing
its activity at levels, competitive to the private sector. It is mandatory for all companies within the holding, as their
executive managements develop and apply internal implementing rules, strategies, and policies in conformity with it.
The strategic goals of the Corporate Governance Policy are:
- Balancing the development of the Company with the interests of the owner, management, stakeholders, and
existing and potential investors.
- Ensuring a mechanism for an honest, responsible and effective management of the Company on behalf of
the management bodies;
- Providing for effective supervision on the management on behalf of the principal and the regulatory bodies;
- Ensuring information security and foreseeability of real and potential investors/bondholders in making
investment decisions.
- Achieving transparency and publicity of the processes for providing information on behalf of the Company
to employees, partners, and stakeholders.
- Raising the trust of the owner, existing and potential investors, and stakeholders and maintaining the good
name of BEH EAD to the public.
BEH EAD adheres to an Information Disclosure Policy of BEH EAD adopted by a Decision under item I.1.10 of
Protocol No.75-2022 of 13 October 2022 of the Board of Directors of BEH EAD. The Policy defines the scope of the
information subject to disclosure by BEH EAD in its capacity as a public enterprise, within the meaning of Art. 2,
para. 1 of the Public Enterprises Act. BEH EAD discloses and provides easy access to all essential information,
including the financial status of the holding and the companies in BEH Group, as well as its structure. BEH EAD
discloses any essential information regarding the operational activity of the Company, regardless of its nature, in
compliance with the principle of equal treatment of the addressees. As soon as possible, the Company discloses
publicly internal information in accordance with Regulation (EU) No.596/2014 of the European Parliament. The
Policy is publicly accessible on the corporate webpage of the Company at: www.bgenh.com.
The Group strictly complies with the requirements for disclosure of information in terms of time and completeness
according to the Bulgarian legislation and instructions of the Minister of Energy. The timely disclosure of information
on the annual, half-yearly, and quarterly reports, as well as management reports related to BEH EAD, is properly
communicated to the public. This is done through the Company’s website, the Ministry of Finance’s website, and a
web-based electronic information system for public enterprises overseen by the Public Enterprises and Control
Agency.
BEH Group publishes consolidated non-financial information in accordance with Art. 29, para. 4 of the Public
Enterprises Act. The consolidated non-financial information provides details on the degree and manner in which the
Company’s operations qualify as environmentally sustainable, namely: what part of their turnover is the result of
products and services, related to economic activities qualified as environmentally sustainable; the share of capital and
operational expenses, if applicable, allocated to assets or processes linked to sustainable activities.
3. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 2 of POSA
The number of the companies in which the members of the Board of Directors can hold managerial positions and the
number of successive mandates of the independent members of the Board of Directors is not defined in the regulatory
acts of BEH EAD. However, the Company complies with the good practices, without a formal regulatory requirement
for prevention of high concentration of control functions in individual companies by one single person.

Bulgarian Energy Holding EAD
Consolidated corporate governance statement
31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
4
The remuneration of the members of the executive bodies of BEH Group is determined in accordance with the terms
and conditions of the Rules on the application of the Public Enterprises Act. No remuneration other than that specified
in the Rules is allowed.
The parent company is a public enterprise, which complies with the provisions of the Public Enterprises Act and its
bylaws, and does not apply a deliberate Remuneration Policy.
4. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 3 of POSA
By a decision of the Board of Directors of 28 February 2017, an Internal Audit Unit was established at BEH EAD,
which is a separate department of direct subordination to the Executive Director. The internal audit activities comply
with the requirements of the Public Sector Internal Audit Act. By a decision of the Board of Directors of BEH EAD
under item I.2.1. of Protocol No.68-2017/31.10.2017, as amended by a decision under item I.4.1. of Protocol No.
43/2023 of 29.06.2023, the Statute of the Internal Audit Department was approved. By a decision of the Board of
Directors of BEH EAD under item I.1.1. of Protocol No.47-2023/12.07.2023, a Methodology for the implementation
of internal audit activities by the Internal Audit Department was approved. The scope of audit engagements for
assurance and consultation covers BEH EAD and its subsidiaries, excluding the independent transmission operators.
The internal audit supports the Group's management in achieving its goals by:
- Identifying and assessing the risks in the Group with a view to allocating audit resources to maximize
coverage of the audit environment;
- Assessing the adequacy and effectiveness of the financial management and control system with regard to:
a) identifying, assessing and managing the risk by the Group management;
b) compliance with the legislation, internal acts and contracts;
c) reliability and the comprehensiveness of the financial and operational information;
d) effectiveness, efficiency and economy of the activities;
e) protecting assets and information;
f) performing tasks and achieving goals.
- Providing recommendations to the management of BEH EAD for improvement of the activities in the Group.
On 2 April 2014, a Financial Management and Control System was approved in BEH EAD, which entered into force
on 14 April 2014. In 2024, the Financial Management and Control System was updated and adopted by the Decision
of the Board of Directors of BEH EAD under item I.2.1 of Protocol No.111-2024/15.11.2024 and is effective as of 29
November 2024.
The purpose of the system is to provide reasonable assurance that the objectives of the Company are achieved through:
- compliance with the legislation, the internal acts of the Company and the contracts concluded,
- reliability and comprehensiveness of financial and operational information;
- economy, efficiency and effectiveness of the activities;
- storage and protection of assets and information;
- preventing and detecting fraud and irregularities and taking follow-up action.
Financial management and control are implemented through the following interrelated elements:
- control environment;
- risk management;
- control activities;
- information and communication;
- monitoring.
The control environment includes:
- personal integrity and professional ethics of the employees of the holding,
- management philosophy and work style;
- an organizational structure ensuring separation of responsibilities, hierarchy and clear rules, rights,
obligations and reporting levels,
- human resource management policies and procedures;
- competence of staff.
With a Decision under item I.3. of Protocol No.21-2022/06.04.2022 of the Board of Directors of BEH EAD, an
Updated Risk Management Policy has been adopted at BEH EAD in accordance with the Guidelines of the Ministry

Bulgarian Energy Holding EAD
Consolidated corporate governance statement
31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
5
of Finance for risk management in public sector organizations. The rules and procedures for risk management in BEH
EAD are an integral part thereof.
The management of BEH EAD undertakes constant commitment to the processes of identification, assessment,
analysis and management of risks within the holding, as well as commitment to these processes at all management
and expert levels.
The following are determined in the Risk Management Strategy
- the stages of the risk management process and their content;
- the participants in the implementation of the risk management process.
The implementation of the Strategy aims to:
- Identify, analyze and assess risks with a view to ensuring the possibility of fulfilling the Company’s goals;
- Determine the level of risk appetite and risk response actions (restriction, transfer, acceptance or termination);
- Establish and implement adequate and effective control mechanisms;
- Identify the roles and responsibilities of participants in the risk management process;
- Protect the Company’s reputation.
The Risk Management process in the Company comprises the following:
- Defining the main objectives of the Company;
- Identifying the risks;
- Risk control;
- Risk assessment;
- Documenting the risk;
- Defining the level of risk – risk appetite;
- Review and reporting on risk.
The Executive Director shall implement controls designed to provide reasonable assurance that risks are contained
within tolerable limits and shall include, at a minimum:
- authorization and approval procedures;
- separation of responsibilities in a manner that prevents a single employee from having concurrent approval,
execution, and control responsibilities;
- a dual signature system that does not permit a financial commitment or payment to be made without the
signatures of the Executive Director and the Chief Accountant and Head of the Accounting Department;
- rules for access to assets and information;
- prior control for legality;
- ongoing control over the performance of financial commitments and contracts entered into;
- ex-post performance evaluations;
- policies and procedures for objective, accurate, complete, reliable and timely accounting of all business
transactions in accordance with the accounting policies adopted at BEH EAD;
- policies and procedures for human resource management;
- policies and procedures for maintaining personal integrity and professional ethics.
The information and communication systems in the company shall ensure:
- identification, collection and dissemination in appropriate form and timing of reliable and credible
information to enable each employee to assume specific responsibility;
- effective communication flowing horizontally and vertically to all hierarchical levels of the company;
- establishing an appropriate management information system for the company to make all employees aware
of clear and precise instructions and orders regarding their roles and responsibilities in relation to financial
management and control;
- implementing a documentation and document management system containing rules for the compilation,
formatting, circulation, use and archiving of documents;
- establishing an effective and timely reporting system, including levels and timelines for reporting, types of
reports, forms of reporting when errors, irregularities, misuse, fraud or abuse are detected.
The Executive Director of BEH EAD shall ensure monitoring of the financial management and control system in order
to assess its functioning and to identify weaknesses and deficiencies in a timely manner and ensure its timely updating.
The system includes ongoing monitoring, self-assessment and internal audit
5. INFORMATION PURSUANT TO ART. 100n, paragraph 8, item 4 of POSA
5.1. Information under Art. 10, paragraph 1 (c) of Directive 2004/25/ЕC of the European Parliament and
the Council of 21 April 2004.

Bulgarian Energy Holding EAD
Consolidated corporate governance statement
31 December 2024
This document is a translation of the original Bulgarian text, in case of divergence the Bulgarian text shall prevail.
6
Bulgarian Energy Holding EAD is the owner of an economically related group, which includes the following
companies as of 31 December 2024:
Company Country of
incorporation Core Business
31 December
2024
31 December
2023
% %
Subsidiaries
Natsionalna Elektricheska
Kompania (NEK) EAD
Bulgaria electricity generation and public
electricity supplier
100% 100%
Bulgargaz EAD Bulgaria public supply of natural gas 100% 100%
Bulgartransgaz EAD Bulgaria storage and transmission of
natural gas 100% 100%
Bulgartel EAD Bulgaria implementation of
telecommunications 100% 100%
Bulgartel Skopje DOOEL Macedonia implementation of
telecommunications 100% 100%
Balkan Gas Hub EAD Bulgaria
construction and operation of an
electronic platform for trade with
natural gas, energy products,
green and white certificates,
carbon-gas emissions
100% 100%
Kozloduy NPP EAD Bulgaria generation of electricity and
thermal energy 100% 100%
HPP Kozloduy EAD Bulgaria
production and distribution of
electricity from a hydroelectric
power plant
100% 100%
NPP Kozloduy – New Builds EAD Bulgaria construction of energy units of a
nuclear power plant 100% 100%
NPP Construction Supervision
EOOD Bulgaria
assessing the compliance of
investment projects and
exercising construction
supervision in design and
construction
100% 100%
NPP Service LTD Bulgaria repair of general and special
purpose machines and equipment 100% 100%
Interpriborservice OOD
(in bankruptcy) Bulgaria installation and maintenance of
automated systems 63.96% 63.96%
TPP Maritsa East 2 EAD Bulgaria generation of electricity and
thermal energy 100% 100%
Mini Maritsa – Iztok EAD Bulgaria coal extraction and sale 100% 100%
Electricity System Operator EAD Bulgaria transmission of electricity 100% 100%
ESO Engineering EOOD Bulgaria
construction of technologies and
projects for energy facilities and
project management
100% 100%
ESO Proekt EOOD Bulgaria
conceptual projects in
accordance with the Spatial
Development Act, consulting
activity
100% 100%
ESO Charge EAD Bulgaria
construction and operation of
electric and hydrogen refueling
systems
100% -
National Energy Operator EAD Bulgaria
Construction and operation of
systems for storage and
utilization of electricity from
RES
100% 100%
Minproekt EAD Bulgaria Design, research and
development engineering 100% 100%