Żabka Group

Governance roles

Reference: pages 43-45, 80-81. Composition and skills datapoints are incorporated by reference to the management report (index row: MR, pages 43-45).

Board of Directors of Zabka Group SA: seven Directors, one Executive and six Non-Executive, of whom three meet the independence criteria. "The gender balance on the Board of Directors is 57% men and 43% women" (page 43). Directors are appointed by the General Shareholders' Meeting for up to six years, the current term being one year. The Board determines overall strategy and "has delegated its management powers to a Management Committee", which it supervises.

Anna Pawlak-Kuliga was appointed Independent Non-Executive Director on 17 June 2025, expanding the Board to seven; otherwise composition did not change. The Board met on seven dates in 2025 (19 Feb, 23 Mar, 12 May, 22 Jul, 24 Sep, 28 Oct, 9 Dec).

Audit Committee: Olga Grygier-Siddons (Chair), Giulia Fitzpatrick, Krzysztof Krawczyk. She "was appointed by the Company's Board of Directors to oversee the sustainability area, including climate matters in particular" (page 80).

The Management Committee is also 43% women, 3 of 7 (page 71). Board experience is mapped as finance 7, retail 7, risk 4 (page 45).

Information provided to and matters addressed by the governance bodies

Reference: pages 80-81.

Governance runs on four levels: supervision by the Board of Directors, strategic leadership by the Management Committee, strategic management by the ESG Centre of Excellence, and operational management by Group entities (page 80).

• Tomasz Blicharski, Group Chief Strategy & Development Officer, "sponsors the Group-wide sustainability agenda including climate matters".
• Marta Wrochna-Lastowska, Group CFO, "sponsors ESG and climate-related reporting. She supervises the sustainability reporting process and manages sustainability-related risks, including those related to climate change."
• Responsibility for sustainability reporting is assigned to the CFO of each entity.

The ESG Business Forum, established at the end of 2024, in 2025 approved 2025 and 2026 ESG KPIs, evaluated ESG performance and ratings, and handled "decisions related to approval of the 2024 Sustainability statement, and 2025 DMA update, and approving generic direction of a long-term decarbonisation pathway" (page 81).

The report does not state how often the Board itself addressed each material IRO.

Sustainability-related performance in incentive schemes

Reference: page 81.

Directors and key managers may receive variable remuneration as an annual cash bonus and/or a Long Term Incentive Plan (LTIP), regulated by the Żabka Group SA Remuneration Policy, which is adopted at the General Meeting.

"The LTIP is based on the condition of agreed levels of EBITDA Growth, Sales to End Customers Growth and the ESG LTIP Index. The ESG Index included in the LTIP scheme determines 15% of the value of bonus payments made to top management."

Sustainability is also built into the annual bonus for eligible employees and co-workers at Żabka Polska, Żabka Automatic Logistics and Żabka Property Fund, through an ESG Index of five equally weighted KPIs:

1. sales of own-brand products promoting a sustainable lifestyle
2. percentage of business partners familiarised with the Code of Conduct
3. employee and co-worker engagement via the Gallup Q12 survey
4. reduction of virgin plastic in own-brand plastic packaging
5. reduction of Scope 1 and 2 GHG emissions in own operations

At Froo "the annual bonus system emphasises social responsibility through team integration and cultural training for managers". The share of total Executive remuneration tied to sustainability targets is not disclosed.

Statement on sustainability due diligence

Reference: page 155.

The statement maps the five core elements of due diligence to named sections of the sustainability statement, in two columns (PEOPLE and ENVIRONMENT):

GOV-4 paragraph 30 is also flagged as an SFDR datapoint (Indicator 10, Table #3 of Annex 1) at page 155 (page 147).

Risk management and internal controls over sustainability reporting

Reference: page 81.

Reporting is governed by the ESG Data Collection Procedure, adopted "to mitigate risks of incompleteness, inaccuracy and lack of integrity of sustainability data". It "designates the Group CFO as the person responsible for overseeing the sustainability reporting process across the Żabka Group".

The ESG Reporting Department prepares and organises data collection, identifies data providers and business owners, and "ensures the integration of the sustainability reporting process with the risk assessment results reporting process, as well as all relevant internal controls".

• Data providers obtain, verify and enter data and are "tasked with providing evidence to confirm all reported values and information".
• Business owners supervise data providers and confirm accuracy and timely delivery.
• Two named control activities: "selective checking of evidence supporting reported non-financial data" and "conducting on-site inspections to verify the correctness of the non-financial data reporting process".

In 2025 the Group "deployed an ESG reporting platform to enhance the sustainability reporting process across the entire Żabka Group" (page 129). No risk-and-control matrix or residual-risk assessment for reporting is published.

Strategy, business model and value chain

Reference: pages 12, 79, 85.

Żabka Group SA is "a public limited liability company (societe anonyme) incorporated and existing under the laws of the Grand Duchy of Luxembourg" and "an issuer and holding company that does not conduct business operations". Operations sit in the Ultimate Convenience segment, "in which business operations generating approx. 90% of Group revenues are carried out" (page 79).

Scale in 2025 (page 12): 12,339 stores; 10,585 franchisees and agents; 10m digital active shoppers; 71,300 jobs retained in the economy; franchisee margin CAGR 2023-2025 of 17.0%; free cash flow of PLN 1,740m; total energy consumption 137,548 MWh; total GHG emissions (location-based) 3,592,616 tCO2e.

"Żabka controls: location selection, store design and equipment, sourcing and delivery, lease ownership and training. Franchisees and agents focus on delivering great customer service and running their stores efficiently."

Value chain (page 85) is mapped in five stages: sourcing; procurement and production; logistics, distribution and marketing; store operations and sales; end of life. All 22 material IROs are placed across upstream, own operations and downstream. Consolidation covers the same companies as the Consolidated Financial Statements.

Interests and views of stakeholders

Reference: page 82.

Seven stakeholder groups are tabulated with engagement purpose, mechanism and examples of outcomes: suppliers, sub-suppliers, food producers and processors; own workforce; investors and institutions; local communities; franchisees and agents; customers and end-users; and the environment, which "we treat as a 'silent' stakeholder and consider its needs when making decisions".

Mechanisms named: ongoing supplier discussions and bilateral meetings, the Fair Business Platform, Żabka Polska's annual suppliers meeting, town halls, NPS surveys and the Gallup engagement survey, investor days and periodic reporting, community engagement and charity work, the Franchisee Council, the Entrepreneurship Academy, and the "Your Opinion" customer satisfaction survey in the Żappka app.

Outcomes disclosed include "increasing seasonal and transport benefits to address pay discrepancies between different distribution centres", "increased Group focus on ESG remediation plans and due diligence in the supply chain", "cascading sustainability policies and governance from Żabka Group to other entities", the OptiPlan tool for franchisees, the "Good life" grant programme and in-store food waste reduction initiatives.

How stakeholder views changed the strategy itself is not separately described.

Material impacts, risks and opportunities

Reference: pages 84, 86; topic detail at pages 90-92 (E1), 98-99 (E4), 102 (E5), 114 (S1), 120 (S2), 125 (S4), 130 (G1).

"We have identified 22 material impacts, seven risks and five opportunities. The great majority of these are relevant from all timeframe perspectives" (page 86).

The materiality matrix (page 84) colour-codes the topical standards against the four ESG Framework pillars. Material: E1, E4, E5, S1, S2, S4, G1 and ESRS 2. Immaterial: E2, E3 and S3.

The 22 numbered matters (page 86):

• Environmental: 1 changing climate and extreme weather events (E1, risk); 2 GHG emissions in operations (Scope 1 & 2); 3 GHG emissions in value chain (Scope 3); 4 energy use; 5 energy efficiency (E1, opportunity); 6 ecosystem conversion and land use change (E4, risk); 7 dependencies on water and soil ecosystem services (E4); 8 virgin plastic use; 9 customer habits related to circular economy; 10 food waste (E5)
• Social: 11 job opportunities creation; 12 health & safety requirements; 13 pay equity; 14 training and development; 15 equity, diversity and inclusion (S1); 16 upstream and 17 downstream value chain working conditions (S2); 18 customer data privacy; 19 consumer communication; 20 good nutrition (S4)
• Governance: 21 corporate culture; 22 anti-corruption practices (G1)

Climate risk identification and scenario analysis is also presented under E1-2, and resilience under E1-3 (2025 ESRS numbering).

Process to identify and assess material impacts, risks and opportunities

Reference: pages 83-84, 98.

"In 2025, we updated our 2024 double materiality assessment (DMA) according to the criteria defined in ESRS 1 and implementation guidance from EFRAG." The long list drew on "relevant matters in AR 16 ESRS 1 Appendix A, those reported by our peers, and ESG trends specific to the food retail sector".

Four steps (page 83): understanding Group context and value chain mapping; identifying IROs from stakeholder insight, internal analysis (policies, ERM risk book) and external analysis (peers, media, EcoVadis); workshops and interviews; prioritisation and "validation by the Management Committee, Audit Committee and Board of Directors".

Impact materiality: scale (0 to 5), scope, irremediability and likelihood. "Negative actual impacts - three parameters were assessed: scale, scope and irremediability. A topic was considered material if at least two of the three parameters were rated 4 or higher." Impacts were assessed gross.

Financial materiality: each topic scored 0 to 1 against revenue growth, EBITDA margin and WACC separately, then multiplied by likelihood (1 to 5); "any sustainability risk or opportunity that scored 3.5 or above was deemed material".

Nature-related impacts used ISIC sector data and the ENCORE tool with TNFD guidance; that assessment "did not include analysis of ecosystem services that are disrupted or likely to be disrupted" (page 98).

Disclosure requirements covered by the sustainability statement

Reference: pages 143-146; EU-legislation datapoint tables at pages 147-156.

A full ESRS content index is printed. "The following tables list all of the ESRS disclosure requirements in ESRS 2 and the six topical standards material to Żabka Group... We have omitted all the disclosure requirements in the topical standards E2, E3 and S3 as these are below our materiality thresholds." The tables also show where information "lies outside of the sustainability statement and is 'incorporated by reference'", using the keys SUS, MR, REM and FIN.

What the index records: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2; E1-1 to E1-9; E4-1 to E4-6; E5-1 to E5-6; S1-1 to S1-7, S1-9, S1-10, S1-13, S1-14, S1-16, S1-17; S2-1 to S2-5; S4-1 to S4-5; G1-1 to G1-6, plus topic-level GOV-1, GOV-3, SBM-2, SBM-3 and IRO-1 rows.

• S1-8 and S1-15 carry no page and the note "Below materiality threshold". S1-11 and S1-12 do not appear in the index at all.
• E1-7 and E1-8 carry no page but a nil-return note.
• E1-9 is annotated "Qualitative information."; E4-6 and E5-6 are annotated "Not reported for 2025."

Reader note: the index itself covers seven topical standards (E1, E4, E5, S1, S2, S4, G1), so the narrative reference to "six" does not match the tables. S2 is newly material in FY2025.

Transition plan for climate change mitigation

Reference: pages 93-94.

"We are aware the ways in which regulators and businesses define a transition plan is evolving. Żabka Polska's strategy and decarbonisation plan, with goals set until 2026, meets some of the ESRS E1-1 transition plan criteria. We also recognise that some aspects, particularly those covering subsidiaries and our long-term transition roadmap with milestones, are yet to be fully defined."

The Group "will strive to... eventually become climate neutral by 2050", "in line with the ESG Framework our Board of Directors approved in 2024". Priority is the 2026 commitments for Żabka Polska and entities under full operational control, "responsible for about 90% of total GHG emissions of the Group".

Levers: fleet electrification; lower-emission new logistics centres; dedicated transport cutting dry-ice reliance; logistics modernisation; loading dock insulation; heat pumps; fuel limits; supply-chain decarbonisation.

Assumptions: "We are making the assumption that 100% zero emissions-energy can be acquired at close to parity with grid power."

Other E1-1 datapoints (page 94): locked-in emissions are acknowledged, "however, no detailed analysis has been conducted on this matter"; no coal-fired assets intended for operation exceeding 30 years; not excluded from the EU Paris-aligned benchmarks; "no significant CAPEX invested relating to coal, oil or gas-related economic activities in 2025".

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 and E1.IRO-1, disclosed in the FY2025 report at pages 90-92. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 79, 90-92.

Classification (page 92). Risks are tabulated as physical or transition: Physical/Acute and Physical/Chronic for changing climate and extreme weather events; Transition/Market for energy use; Transition/Policy and Legal for Scope 1 and 2 emissions, Scope 3 emissions and ESG regulation. "The climate risk assessment conducted encompasses both physical risks and transition risks."

Methodology (pages 90-91). Geospatial coordinates gave "location-specific climate projections and... distances to hazard-affected areas". "All hazards prescribed by the ESRS E1 were analysed", 28 in total, on magnitude, duration, likelihood and extent. Physical risk covered six logistics centres, Park Logistics City and stores in eight clusters.

Scenarios (page 90). IPCC AR6: SSP5-8.5, high emissions, at +4.4 degrees C by 2100, and SSP2-4.5 at +2.7 degrees C by 2100. "A 1.5 degrees C-aligned scenario was also considered on a general level."

Scope. The analysis "specifically focused on the operations of Żabka Polska, which generate over 90% of the Group's revenues". Horizons: one year, to 2030, and 2030 to 2050 (page 79).

Gap: no named 1.5 degrees C transition scenario.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 climate chapter, disclosed in the FY2025 report at pages 91-92. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 91-92.

Result (page 91). "In terms of resilience, climate risks and opportunities do not materially affect the Group's Consolidated Financial Statements in the short term, but they might be significant in the medium and long terms. Our strategy is linked to these material climate risks and opportunities through the Responsibility Strategy of Żabka Polska and the Group's framework policies including those on environment and climate."

Where the effects bite. "The biggest potential losses for our business are expected to come from disruptions in operations, rather than direct damage, especially over the long term in the middle-of-the-road scenario." For stores the largest losses are business interruptions over the long term under SSP5-8.5; for logistics centres, over the medium term under SSP2-4.5. Exposed Polish sites named are Pruszcz Gdanski, Komorniki, Plewiska, Radzymin and Nadarzyn.

Capacity to adapt. Responses named are infrastructure upgrades, emergency protocols, insurance optimisation, site diversification, resilient technologies and long-term energy contracts (page 92).

Gaps: no areas of uncertainty and nothing on financial flexibility to redeploy assets.

Policies related to climate change mitigation and adaptation

Reference: pages 88-89.

Environmental policies are presented jointly for climate, biodiversity and circularity, tagged [E1-2] [E4-2] [E5-1] [MDR-P]. "The Environmental, Social and Governance (ESG) Framework and the Environmental and Climate Framework Policy outline the Żabka Group's directional ambitions relating to environmental and climate matters", owned by the Group Sustainability Director and the Quality Standards & Climate Protection Director, covering climate protection, energy, biodiversity, circularity, water, mineral sourcing and business-partner engagement.

Climate-specific instruments:

• Decarbonisation Policy "defines the general principles of limiting GHG emissions within Żabka Polska sp. z o.o. and its value chain".
• Energy Policy regulates electricity management at Żabka Polska from 2021 to 2026 and "outlines a strategic plan to enhance energy efficiency and increase the use of renewable energy sources within Żabka Polska's operations (Scope 2) and throughout its value chain (Scope 3)". An Energy Management System to PN-EN ISO 50001 is in use.
• Transport and Mobility Policies set goods-transport principles and fleet directives "that support Żabka Polska's decarbonisation objectives".

Żabka Polska "monitors the implementation of its ESG-related policies through the achievement of strategic KPIs defined under the Responsibility Strategy" (page 88).

Actions and resources in relation to climate change policies

Reference: pages 94-96. The table gives achieved reductions, expected next-year reductions and resources allocated per lever.

Scope 1

• Own fleet (EV chargers at logistics centres, parking lots and users' residences; driving-style dashboards; carpooling pilots): 72 tCO2e, about 274 tCO2e expected, PLN 13.1m.
• Logistics efficiency (Plewiska refrigeration modernisation; dedicated transport extended by 1,840 stores, cutting reliance on dry ice): 1,373 tCO2e, PLN 1.6m plus PLN 0.02m.
• Heating (heat pumps at Pruszcz Gdanski; heat recovery at Katy Wroclawskie): about 42 tCO2e, PLN 1.1m.
• Other (low-carbon warehouse concept for Lodz, construction begun Q4 2025; "Excellent" BREEAM In-Use at Radzymin): 21 tCO2e.

Scope 2

• Renewable energy (PPAs; guarantees of origin covering 95% of electricity in own operations and 41% in franchisee operations): 17,413 tCO2e own operations and 155,535 tCO2e franchisee operations, PLN 1.6m.

Scope 3

• Supplier engagement (product carbon footprint tool): PLN 0.2m.
• Stores and franchises (air conditioning control in 2,300 stores; automatic lighting in 900 locations; glycol refrigeration in 36 stores): 3,918 tCO2e, about 4,000 tCO2e expected, PLN 14.2m.

"Funding for all major decarbonisation projects is secured during Żabka Polska's annual budgeting process."

Targets related to climate change mitigation and adaptation

Reference: pages 76, 78, 93-94.

"Since 2021 Żabka Polska has set SBTi-validated GHG reduction targets until 2026... The baseline year for these targets is 2020... Annual targets are aligned with the reduction pathway validated by SBTi" (page 94).

Commitments as stated (page 93): reduce "absolute Scope 1 and Scope 2 GHG emissions 25% by 2026 from a 2020 base year"; reduce "Scope 3 GHG emissions from franchisees 70% per PLN of revenue over the same timeframe"; and "75% of its suppliers by spend... will have science-based targets by 2026".

Gap stated by the company: "No targets have yet been officially disclosed for the period from 2027 onwards. However, it is planned to establish measurable science-based GHG reduction targets for all Group entities" (page 94). In 2025 the Group "set a consolidated Scope 1-3 baseline for 2025 and prepared to submit Group targets for SBTi validation in 2026" (page 78).

Energy consumption and mix

Reference: pages 134-135.

Energy production: non-renewable 16,970 MWh (2024: 18,104), renewable 1,478 MWh (2024: 359).

Intensity (page 135): energy consumption from activities in high climate-impact sectors per net revenue was 5.07 MWh per million PLN (2024: 5.19). "It is assumed that all activities of Żabka Group entities are in a high climate-impact sector (mostly NACE sector G - Wholesale and retail trade)."

Data was collected on forms from Group entities, based on meters and supplier invoices, converted using DEFRA calorific values, reported as final energy consumption with double counting of self-generated energy avoided.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 97, 136. "Compared with 2024, overall emissions increased from an estimated 3,345,411 tCO2e to 3,419,667 tCO2e" (page 97).

Żabka Group 2025

Żabka Polska is reported separately: Scope 1 14,316 tCO2e (2024: 15,236); Scope 2 location-based 18,894 and market-based 1,481; Scope 3 3,101,600 (2,957,249).

Method (page 136): GHG Protocol. Scope 3 categories 1, 2, 3, 4 and 14 are material; "the remaining categories 5-13 and 15 were excluded from calculation as they are not relevant or not material for Żabka Polska".

GHG removals and mitigation projects financed through carbon credits

Reference: page 137; index row at page 144.

A nil return, disclosed in the appendix under the heading "GHG credits and internal carbon pricing" and tagged [E1-7] [E1-8]:

"In 2025, the Żabka Group did not carry out projects to remove greenhouse gases or reduce GHG emissions using carbon credits."

The ESRS content index carries the same answer: the E1-7 row gives no page reference and the Additional information column reads "In 2025 the Group did not use carbon credits" (page 144). The EU-legislation datapoint table lists ESRS E1-7 "GHG removals and carbon credits paragraph 56" against Regulation (EU) 2021/1119 Article 2(1) with no page (page 149).

Consistent with this, the Żabka Polska target is expressed as a reduction in "Scope 1 & 2 GHG emissions (without offset)" (page 94), so no removals or credits count towards the 2026 target.

Internal carbon pricing

Reference: page 137; index row at page 144.

A nil return, disclosed in the appendix under the heading "GHG credits and internal carbon pricing" and tagged [E1-7] [E1-8]:

"In 2025, the Group did not use internal carbon-pricing schemes."

The ESRS content index records the same: the E1-8 row gives no page reference and the Additional information column reads "In 2025 the Group did not use internal carbon pricing schemes" (page 144).

No shadow price or internal carbon fee is applied in investment decisions anywhere in the decarbonisation chapter. The levers described instead are fleet electrification and hybridisation, renewable sourcing through PPAs and guarantees of origin, heat pumps and heat recovery, logistics modernisation, energy-efficient stores and supplier engagement (pages 93, 95-96).

Anticipated financial effects from physical and transition risks and climate opportunities

Reference: pages 91, 137. The index annotates this row "Qualitative information." (page 144).

Qualitative outcome (page 91). "We conducted a physical climate risk analysis... The analysis included an estimation of the anticipated annual average financial loss resulting from property damage and business interruptions for those assets and operations identified as vulnerable to physical risks." Hazards named for stores, logistics centres and the supply chain are storms, water stress, drought, floods and rising sea levels, with the largest potential losses from operational disruption rather than direct damage.

On transition: "In terms of the transitional challenges in the short term, EBITDA is not envisaged to be materially negatively affected by transition risk. However, over the medium and long term, market and technological shifts, particularly those influencing fuel pricing, are anticipated to pose significant challenges."

No quantification (page 137). "The Żabka Group has not yet quantitatively calculated the anticipated financial risks and opportunities related to climate change, biodiversity and ecosystems, or circularity. It plans to in years to come, if the regulatory environment around these requirements stabilises."

No monetary amounts, no share of assets at material physical risk and no share of net revenue from activities at transition risk are given.

Biodiversity and ecosystems in strategy and business model

Reference: page 98.

No biodiversity transition plan is disclosed. Under [E4-1] the Group states: "As a food retailer, Żabka Group depends on healthy ecosystems for the products our suppliers and brands source from operators in the upstream value chain. Changes in the health of these ecosystems can result in both acute and chronic impacts to the food supply chains. Żabka and Froo stores and Group operations are spread over Poland and Romania, with stores mainly located in cities. Our robust supply chain and ongoing risk-management activities underpin the resilience of our strategy and business model."

The DMA conclusion is that the Group "has an impact on biodiversity through sourcing of agricultural raw materials in the upstream value chain, which drives a negative impact on biodiversity through the conversion and change of land use. While detailed information on the specific agricultural practices of all suppliers in the value chain is not easily available, this impact is inherent to the food retail sector."

It also records a dual relationship with ecosystem services: operations rely on provisioning services such as stable water supply for food production (Maczfit) and logistics, and on regulating services including soil retention and water purification, while "our ongoing demand for new retail and logistics locations leads to the construction of buildings that can negatively affect these ecosystem services".

Policies related to biodiversity and ecosystems

Reference: pages 88-89.

Biodiversity policies sit in the joint environmental policy section tagged [E1-2] [E4-2] [E5-1] [MDR-P]. The ESG Framework and the Environmental and Climate Framework Policy cover "biodiversity and ecosystems" and "water" among their subject areas.

• Biodiversity Policy "sets out the general principles of conduct to protect biodiversity. It also defines the main directions of Żabka Polska's activities in this area, aimed at ensuring the protection of ecosystems and preventing loss of biodiversity."
• Water Resources Policy "outlines guidelines designed to reduce water usage and protect water resources. As water is a vital ecosystem service, we consider this Policy to be part of our approach to managing biodiversity-related impacts."
• A Sustainable Food System Framework Policy and an Animal Welfare Policy sit alongside these (pages 89, 126).

A footnote records alignment: actions "align with the implementation of tasks from the COP15 summit, specifically the Kunming-Montreal Global Biodiversity Framework (targets 15, 18, and 19), and adhere to the EU Climate Change Adaptation Strategy, EU Farm to Fork Strategy, EU Biodiversity Strategy for 2030, and the new EU Forest Strategy for 2030" (page 89).

Actions and resources related to biodiversity and ecosystems

Reference: pages 100-101.

Sourcing (page 100). Żabka Polska continued policies on commodities "including coffee, soy and palm oil - identified as critical raw materials associated with deforestation risk":

• Coffee, and since 2025 tea and cocoa, certified by the Rainforest Alliance, "with nearly PLN 330 million sales in 2025".
• Palm oil: a 2019 phase-out policy means "20 out of 21 of own-brands do not contain palm oil"; branded products containing palm oil are accepted only under RSPO certification.
• "All Żabka Polska's own-brand products containing fish or seafood hold Marine Stewardship Council (MSC) certification." Cage-laid eggs have been eliminated.
• Work continued on implementing the EU Deforestation Regulation, including ensuring franchisees can meet the requirements on schedule.

Own operations (pages 100-101). A project with UNEP/GRID Warsaw funded renovation of tourist trail infrastructure in the Karkonosze National Park, protecting 44.5 hectares of habitat. An audit confirmed two logistics centres' full compliance with the Alliance for Water Stewardship standard "with no non-conformities identified". The new Katy Wroclawskie centre underwent a Life Cycle Assessment under BREEAM International New Construction v6.0. At Radzymin a Sustainable Water Use Plan was developed and biodiversity measures installed, including pollinator-friendly plants and an insect house.

Targets related to biodiversity and ecosystems

Reference: page 101, tagged [E4-4] [MDR-T].

"In 2025, Żabka Polska continued to fulfil the general objectives outlined in its Biodiversity Policy, which was put in place in 2023. To further minimise its impact on nature and better track the effects of the completed actions from various deployment roadmaps, for 2026 Żabka Polska set an ambition to maintain measures preventing biodiversity losses in own operation at no direct losses set at the target level."

For indirect impacts the target is not yet set: "As for the indirect impacts related to sourcing products and/or materials, Żabka Polska and the Group is in the final stage of defining measurable targets in this area to take into account final versions of the relevant EU regulations, mitigate risks assessed in this domain and leverage on measures which will be introduced jointly with a future introduction on the GHG reduction targets resulting from forest, land and agriculture activities (FLAG)."

In the meantime "Żabka Group shall continue to adhere to its current Environmental and Climate Framework and Sustainable Food System Framework Policies".

No quantified, dated biodiversity target with a baseline is therefore disclosed for the upstream value chain, where the Group locates its material biodiversity impact. The own-operations ambition is expressed as maintaining no direct losses rather than as a measurable reduction.

Impact metrics related to biodiversity and ecosystems change

Reference: page 101.

The single site is described in a footnote: "The site is a warehouse located 600m from a landscape park (Chojnowski Park Krajobrazowy) and a protected landscape area (Warszawski Obszar Chronionego Krajobrazu). The area of the site presented in the table is the area of the warehouse."

A wider screening is reported under E4.SBM-3 (page 99): "None of the 29 locations evaluated were found to have a significant impact on biodiversity. In the case of four sites, the impact on key biodiversity areas may be considered as moderate." The assessment covered proximity to protected areas and to Natura 2000 species and habitat areas, hydrology, land cover, and noise and light. "The results of the analysis confirmed that no direct impact on endangered species was found."

The four moderate-impact sites are named at page 137: Nadarzyn Logistics Centre (permeable soils, aquifer area), the Maczfit ready-meal warehouse at Lubna, the Maczfit main production site at Szymanow and Maczfit fruit and vegetable processing at Jozefoslaw.

Policies related to resource use and circular economy

Reference: pages 88-89.

Circularity policies sit in the joint environmental policy section tagged [E1-2] [E4-2] [E5-1] [MDR-P], under the ESG Framework and the Environmental and Climate Framework Policy, which cover "resource use and circularity".

• Plastic Circularity Policy "defines Żabka Polska's activities in the area of the circular economy, guided by the 'Green Loop'. This model... highlights those areas of business targeted by the Company's actions that involve the comprehensive management of resources, from eco-design to environmental recovery and regeneration."
• Eco-design Policy "outlines the principles which Żabka Polska follows in the areas of recommended packaging materials for Żabka Polska's own brands, the composition of packaging plastics, and the principles of eco-design and their implementation for... suppliers."
• Waste Management Policy "sets out recommended waste-management methods for reducing waste at various stages of a product's lifecycle", on a hierarchy of "prevention, reuse, recycling, recovery and disposal".
• Food Waste Prevention Policy "sets standards and goals for reducing food waste in Żabka Polska's own operations, throughout the store network and in the operations of... suppliers."
• Paper and Wood Policy covers paper and wood in packaging.

Many of these policies are owned by the Director of Quality Standards and Climate Protection (page 89).

Actions and resources related to resource use and circular economy

Reference: pages 102-104, tagged [E5-2] [MDR-A].

Eco-design and packaging (pages 102-103). Eco-design principles are applied "in alignment with the waste hierarchy, in accordance with the EU New Circular Economy Action Plan": rPET in bottles, trays and bowls; removal of black ink; reduced packaging size and weight; laminated films switched to mono-materials. "At year end, 97.6% of Żabka Polska's own-brand PET bottles were 100% made from recycled material" (bottle only, excluding cap and label). The brands contributing most to cutting virgin plastic were Dobra Karma (324 tons of recycled content), Szammam (292 tons) and Wycisk (163 tons).

Deposit return and collection (page 103). Poland's deposit system started on 1 October 2025; Żabka voluntarily refunds deposits and collects packaging even though most of its 12,000-plus stores are under 200 square metres and could join only voluntarily. "As of year-end 2025, nearly 100% of Żabka stores were already accepting PET bottles and cans from customers. In 2025, we collected almost 11 million beverage containers through the system." Under "Naturally Together" franchisees separate cardboard and foil; the reusable-cup discount covered "over 485,000 discounted hot drinks"; and a six-month cup-collection pilot ran in Torun under the Retail ReLooped project.

No monetary resources are attributed to these circularity actions.

Targets related to resource use and circular economy

Reference: pages 75, 78, 104.

Under [E5-3] the Group states: "We plan to establish measurable targets for Group entities from 2027 onwards. The targets related to this area, defined by Żabka Polska's Responsibility Strategy, are presented in the ESG Framework section" (page 104).

The Żabka Polska targets, with 2026 commitments and 2025 results, are set out in the ESG Framework pillars (pages 75, 78). Under 04 Green planet, tagged [E1-4] [E5-3] [MDR-T]:

Under 01 Sustainable lifestyle, tagged [S4-5] [E5-3] [MDR-T]: "Reduce food waste intensity in own operations by 25%" returned -24.9%, and "50% of unsold food in internal operations managed" returned 87%.

A footnote limits the scope: "The targets shown apply to Żabka Polska and were selected to track the Company's progress in realising its Responsibility Strategy for the years 2021-2026." The virgin plastic KPI is also one of two indicators under the Sustainability-Linked Bond Framework, with a 2019 baseline of 0% (page 156).

Resource inflows

Reference: page 105.

"Resource inflows cover own-brand packaging, imported materials introduced to the market and logistics materials used for transportation."

Accounting policies: the total weight "refers to packaging of our-own brand products, imported materials introduced to the market and logistics materials used for transportation. Biological materials from sustainable sources are packaging that have either FSC or PEFC certifications. The total weight of materials used in 2025 is the denominator for those indicators expressed in percentages."

Materials the report actually names on the inflow side are plastic (including rPET and CPET with post-consumer recycled content, and mono-material films), paper and cardboard, wood, glass and metal (pages 103, 105). No weight is given per individual material, and there is no breakdown between own-brand packaging, imported materials and logistics materials.

Resource outflows

Reference: page 105.

"Resource outflows are materials and products that come out of our production processes and that are then put on the market (including packaging). Group entities do not have production processes per se, except for Maczfit (for the manufacture of meals). As a Group, we introduce materials such as glass, plastic, paper, wood and metal into the market, which are used in packaging forms such as trays, bowls, cups, bottles, cans, soft films for sandwich packaging, top films, labels and more."

Own brands named as introducing these materials from the upstream value chain are Foodini, Wycisk, Dobra Karma and S!, "which are designed in line with circular principles".

Accounting policies: "we used as denominator the overall total weight of the materials (packaging) used during the reporting period. Data on these includes own-brand packaging, imported materials introduced to the market and logistics materials used for transport. The numerator is recyclable content in products packaging. The year-on-year change results from improved accuracy and completeness of data related to the packaging of imported products."

Only one outflow rate is disclosed. There is no figure for expected durability or repairability, and no breakdown of outflows by material. Waste is reported separately.

Waste

Reference: page 105.

"Waste we generate primarily covers waste generated at logistics centres (Żabka Polska), production facilities (Maczfit) and offices. The Group's largest waste streams are paper and plastic packaging waste." Data was compiled from waste-collection invoices and internal systems, with Romanian entities also using environmental compliance reports.

Food waste (page 104): 2,981 Mg generated in own operations (2024: 2,061), with 83% diverted from the waste stream (2024: 68%). 2025 data extends to darkstores (Lite e-commerce) and Romanian operations; downstream food waste in stores and households is excluded.

Policies related to own workforce

Reference: pages 114-115.

"The Żabka Group has implemented a comprehensive range of policies to manage the material impacts on our own workforce." Three key policies were adopted by the Board of Directors of Zabka Group SA in 2024:

• Code of Conduct and Ethics for Employees, which "defines the Group's expectations regarding ethical behaviour" and the conduct expected in the workplace.
• Human Rights Policy, which "presents the Group's commitment to responsible business conduct and outlines internationally recognised human rights principles".
• Diversity, Equity and Inclusion Policy, which "defines the essential terms of diversity, equity and inclusion within the Group" and which all employees and co-workers must comply with. Żabka Polska adopted its own Equity Policy in 2021.

Labour and anti-mobbing: the Labour Charter defines rights and obligations including equal pay and treatment, prevention of mobbing and discrimination, working hours, leave, wage payments and health and safety. Maczfit has an Anti-Mobbing and Anti-Discrimination Procedure.

Health and safety: Żabka Polska's Occupational Health and Safety Policy "forms an integral part of the Integrated Management System and complies with the ISO 45001 international standard", owned by the Health and Safety Director. At Group level, responsibility for workforce policies "lies with, and is overseen by, the Group Chief People Officer".

Processes for engaging with own workforce and workers' representatives

Reference: pages 115-116.

• In 2025 "Maczfit, Dietly, Froo and DRIM carried out employee Net Promoter Score (eNPS) surveys", after which local managers worked on corrective action plans.
• Żabka Polska runs the Gallup employee engagement survey annually for all employees and co-workers, plus "Pulse Check" satisfaction surveys "usually conducted more than once a year". After the annual survey "all managers, supported by a dedicated HR team, analyse the results from individual teams".
• "At Żabka Polska, regular elections are conducted for employee representatives who engage the employer on matters mandated by local labour regulations, such as health and safety measures and the use of workplace monitoring. Any Company employee is eligible to run for this position."
• A Health and Safety Committee functions at Żabka Polska, Żabka Property Fund, Żabka Automatic Logistics and Żabka Nano, reviewing working conditions and convening "at least once a quarter".

"There is no predefined Group-level method for assessing the effectiveness of engagement with our workforce or related actions"; each entity evaluates its own approach. The Group Chief People Officer oversees engagement, with the Organisational Culture Manager overseeing survey findings.

Processes to remediate negative impacts and channels to raise concerns

Reference: pages 116-117.

"We are committed to effective processes that address any negative impacts to our workforce we cause or contribute to."

Mobbing, harassment and discrimination (page 116). "Any Żabka Polska employee who considers that they have experienced bullying, harassment or discrimination is entitled to submit a complaint to the Anti-Mobbing Committee. The investigation into a complaint is carried out by the Committee, whose task is to determine whether the complaint is justified." The Committee operates on four stated principles: "promptness; confidentiality; impartiality; and a focus on thoroughly clarifying the facts and resolving the problem." A similar arrangement exists at Maczfit.

Health and safety (page 117). Concerns can be raised "through the following mechanisms: a special intranet form (accessible 24/7 at bhp.zabka.pl); contacting employee health and safety representatives at each major location; or by contacting an OHS specialists". Concerns are recorded in an electronic register, corrective or preventative actions are "defined, implemented and communicated back to the worker(s) concerned", and the process is overseen by the OHS department "ensuring independence and accountability". Examples of 2025 remediation given are "improved forklift safety measures after concerns were raised and improved warehouse signage".

Taking action on material impacts on own workforce

Reference: pages 115-116, 118-119.

Key actions taken in 2025 (page 118):

• Opened the new semi-automated logistics centre at Katy Wroclawskie, which "will ultimately employ more than 200 people, providing them with modern facilities and tested health and safety measures and benefits including a monthly transportation allowance and a relocation allowance".
• "We introduced a new system of monthly bonuses in all logistic centres and terminals, applicable to employees across operational warehouse and logistics functions to introduce a more transparent pay structure", followed by a satisfaction survey and an action plan.
• EQUAL-SALARY recertification by the Swiss EQUAL-SALARY Foundation after "a detailed audit conducted by PwC, covering 2,800 employees". "The results confirmed an adjusted gender pay gap of below 5%."
• "In partnership with an external expert, we conducted a living wage analysis (for a total of 3,260 employees) across all of our locations in Poland, Luxembourg and Romania", against basic, decent and comfortable living wage levels.

Health and safety (page 119): OHS teams and the Health and Safety Committee reviewed incident reports and implemented corrective actions, including "a project aimed at improving the safety of those working with forklifts and racking in our logistics centres, improved warehouse signage, and testing new protective workwear".

Targets related to own workforce

Reference: pages 77, 119.

Under [S1-5] the Group states: "We plan to establish measurable targets for Group entities. We outline our targets and supporting metrics focused on enhancing positive impacts for our workforce in alignment with Żabka Polska's strategy under the Responsible Organisation pillar, which is described on page 77" (page 119).

The Responsible organisation pillar, tagged [S1-5] [S4-5] [MDR-T], sets out Żabka Polska commitments for 2026 with 2025 results (page 77):

A footnote limits the scope: "The targets shown apply to Żabka Polska and were selected to track the Company's progress in realising its Responsibility Strategy for the years 2021-2026."

So no Group-wide measurable workforce target exists yet, and the Żabka Polska targets cover engagement and training rather than the health and safety, pay equity or diversity impacts identified as material.

Characteristics of the undertaking's employees

Reference: pages 137-138.

2024 comparatives: 4,058 total, 3,527 permanent, 531 temporary, 3,971 full-time, 87 part-time.

By country (page 138): Poland 3,193 (2024: 3,069) and Romania 1,064 (989). "The table above shows employee headcount in countries where we have at least 50 employees representing at least 10% of the total number of our employees as per ESRS requirements. This is why we do not report Luxembourg data."

Turnover (page 138): 825 employees left in 2025 (2024: 953), a turnover rate of 19.4% (24.4%). "In 2025, the Group introduced a revised methodology for calculating employee turnover. Number of departures was divided by the average number of employees during the year." More than a third of departures were in operational and logistics roles, "where turnover levels are structurally higher", and "a further 266 terminations were involuntary". "No large-scale redundancies or significant job cuts occurred in 2025."

All figures are headcount as at 31 December, collected on forms from Group entities. "In all our own workforce-related metrics, the category of 'Other gender' was not applicable."

Characteristics of non-employees in own workforce

Reference: pages 138-139.

"People in own workforce cooperating with Żabka Group on the basis of contracts other than an employment contract":

2024 comparatives: 3,170 non-employees in total, of which 1,442 self-employed, 338 on mandate or service contracts and 1,390 agency workers. The non-employee population therefore grew by about 29% year on year, faster than the employee base.

Accounting policies: the data covers "those workers who are bound to an entity within the Group by a civil-law contract, such as interns; individual contractors providing services to the Group entities (i.e. self-employed people); and temporary workers - those who are provided to an entity within the Group by businesses engaged in employment activities (temporary employment agencies)". Data was collected on forms from Group entities, in headcount as at 31 December 2025.

Context: non-employees are 49% of the Group's own workforce and include "field staff who support franchisees in their day-to-day work, or pickers in Lite e-commerce who are responsible for retrieving ordered items in dark stores" (pages 114, 118).

Diversity metrics

Reference: page 139.

2024 comparatives: 113 people at top management level (46 female, 67 male) and 4,058 employees. Female representation in top management therefore fell from 40.7% to 33.0% year on year, while the overall female share of employees was broadly unchanged at 40.3%.

Accounting policy: "Top management is defined as members of the management boards of Żabka Group companies and individuals who directly report to them."

Governance-body diversity is reported separately: the Board of Directors is 43% women (3 of 7) and the Management Committee likewise 43% (3 of 7), both disclosed under GOV-1 (pages 43, 71). The Diversity, Equity and Inclusion Policy adopted by the Board in 2024 underpins these metrics, and in 2025 the Group became "the first company on the Warsaw Stock Exchange to receive EQUAL SALARY certification twice" (page 77).

Adequate wages

Reference: page 118.

Accounting policy, given as a footnote: "all employees receive at least the respective minimum wage in Poland and Romania. We did not include people on long-term leave in the calculations."

The Group goes beyond the benchmark test with a living wage study, reported under S1-4 on the same page: "In partnership with an external expert, we conducted a living wage analysis (for a total of 3,260 employees) across all of our locations in Poland, Luxembourg and Romania to determine if our Group's current pay is below the local living wage level anywhere. As 'living wage' is not a one-size-fits-all concept, the analysis focused around three levels of living wage: basic living wage; decent living wage; and comfortable living wage."

The results of that living wage analysis are not disclosed, so the statement confirms compliance with minimum wage benchmarks but does not say how pay compares with the three living wage thresholds it tested. The figure covers employees; no adequate wage figure is given for the 4,100 non-employees in the Group's own workforce.

Training and skills development metrics

Reference: pages 139-140.

Performance and career development reviews (page 139):

Same result in 2024. Accounting policy: "A regular performance review is defined as a review based on criteria known to the employee and his or her superior, undertaken with the knowledge of the employee at least once a year. In most Group entities, this is a review connected to the annual bonus." People on long-term leave and those on non-annual review cycles were excluded, and participation was calculated only for individuals employed as at 31 December 2025.

Training hours (page 140):

The Group average is unchanged year on year, with the gap between women and men widening. Accounting policy: hours cover training conducted during 2025 for people employed at 31 December 2025, excluding long-term leave; "the total number of training hours offered to and completed by employees for the Romanian entities and Cool Logistics was estimated based on the management's knowledge of the type of training conducted and the number of employees participating".

Health and safety metrics

Reference: pages 140-141.

Management system coverage (page 140):

2024: 100% / 63% / 84% and 70% / 17% / 47%. Both audited-or-certified measures therefore fell year on year.

Fatalities (page 141): zero in 2025 and 2024 for employees, non-employees and other workers on the organisation's sites, from work-related injuries and from work-related ill health.

Accidents (page 141):

Employee accidents fell by more than two thirds; the non-employee rate rose. Cases of recordable work-related ill health were 0 in both years. Days lost to work-related injuries were 343 (2024: 617), with no days lost to ill health or fatalities. Data was gathered manually from accident registers held by OHS units and from personnel and payroll systems.

Compensation metrics (pay gap and total compensation)

Reference: page 142.

Accounting policy: the gap is "calculated as the difference between the average gross hourly pay for men and women divided by the average gross hourly pay for men and expressed as the percentage of the average gross hourly pay for men. The calculation is based on a cash approach and includes both fixed and variable remuneration actually paid. It covers employees with a full 12 months of service." The company explains the swing from a negative to a positive gap: "Methodological refinements and improved data completeness influenced the 2025 results. The data indicates that, on average, men earned approximately 3% more than women."

Annual total remuneration ratio: "The annual total remuneration ratio of the highest-paid individual to the median annual total remuneration for all Żabka Group employees (excluding the highest paying individual) amounted to 1:51. In 2024, this ratio amounted to 1:48 in the Group's largest entity, Żabka Polska." The two years are therefore not on the same basis, the 2024 figure covering one entity and the 2025 figure the Group. The calculation "include[s] the main components of compensation, covering both basic and variable remuneration", excluding individuals not employed for the full year and severance or settlement components.

Incidents, complaints and severe human rights impacts

Reference: page 117.

"Data was compiled from Group entities' internal registries. In 2025, we received 5 employee-related complaints filed through channels for people in own workforce to raise concerns. None of these have been classified as discrimination, harassment or 'severe human rights issues'."

The statement adds that as of 2025 the Group "identified no operations at significant risk of incidents of forced labour or compulsory labour, or operations at significant risk of incidents of child labour" (page 114). The outcome of the five complaints is not described.

Policies related to value chain workers

Reference: page 121, tagged [S2-1, MDR-P].

Upstream. "Żabka Group has implemented our Code of Conduct for Business Partners and Human Rights Policy for Business Partners, which outline the most important principles we expect our business partners to acknowledge and comply with across all their supply chains throughout the course of our business relationship. The Code is aligned with OECD standards, UN and ILO frameworks and conventions, and relates to the upstream element of our value chain."

"Under the Human Rights Policy for Business Partners, we reaffirm a zero-tolerance rule for all forms of human trafficking throughout our partners' operations and supply chains, as well as child labour, forced or compulsory labour." The owner is the Group Sustainability Director. "These policies are intended to cover all workers of our business partners in the upstream value chain, including at-risk persons and vulnerable groups, such as children and migrant workers."

Downstream. Commitments sit in Żabka Polska's Franchisee Code of Ethics and Conduct, which "outlines our expectations regarding ethical behaviour, fair employment practices, timely payment of wages and social insurance, non-discrimination and respect for diversity." Since 2022 all new franchisees sign a declaration of familiarity; a legal compliance project for earlier franchisees produced "a network-wide familiarisation rate of 98.3% as of 31 December 2025".

Processes for engaging with value chain workers

Reference: pages 121-122.

Upstream (page 121). "In 2025, our focus was on indirect engagement with workers through ongoing contact with suppliers to familiarise them with Żabka Polska's Business Partner Code of Conduct." Each agreement includes a standard compliance clause, and partners sign a formal statement of adherence forming part of the contract. "We reserve the right to verify our business partners' compliance with standards, including labour standards for their workers. This verification may be carried out in accordance with SMETA standards, BSCI, or SAI SA8000, by independent third-party entities."

Through Sedex, the Group implemented supplier self-assessment questionnaires and audits: "Currently, we are connected to 84 supplier sites on Sedex and we will engage additional suppliers in 2026." "Due to the heightened human rights risks associated with them, transport, cleaning and security service providers are prioritised for additional due digilence" (page 122).

Downstream (page 122). Engagement runs through day-to-day contact via field contractors, onboarding for new franchisees, the Franchisee Council (elected representatives from all 12 sales regions, two-year terms, established 2011), the Razem magazine, and NPS surveys. The Group Sustainability Director "is responsible for assessing the overall effectiveness of engagement of suppliers with relation to ESG".

Processes to remediate negative impacts and channels for value chain workers

Reference: page 123.

Upstream. "Remediation of negative impacts on value chain workers is handled through the engagement mechanisms mentioned on pages 121-122. Anyone may raise concerns through the whistleblowing channels that are available offline, and online through the Whistle B platform and/or other dedicated whistleblowing channels in Group entities."

Obligations are passed down the chain: "Under Żabka Polska's Code of Conduct for Business Partners, the Company's business partners must enable employees to report violations of the law and the Code. Żabka Polska's business partners are required to provide their employees with an independent external system for making anonymous complaints and anonymously reporting violations, and for providing feedback."

Downstream. The franchisee satisfaction survey is the main channel: "The results of the franchisee-satisfaction survey are an important source of insight for Żabka Polska, which the Company uses to make decisions about whether changes should be implemented." Franchisees rate satisfaction with the settlement system, their sales partner, the logistics service, handling of failure reports and product range, and can contact Franchisee Council representatives by phone, email and in the field.

No figures are given on grievances received from value chain workers or their outcomes.

Taking action on material impacts on value chain workers

Reference: pages 120, 123-124.

Upstream actions in 2025 (page 123):

• "We continued to familiarise suppliers with Żabka Polska Suppliers' Code of Conduct, with 91.8% confirming their acquaintance with the document at the end of 2025 and 87.7% confirming their compliance with the Code provisions."
• "At Żabka Polska we continued the process of supplier 'passportisation'. This process enables the collection and verification of supplier data, including compliance with legal, tax and ethical standards."

Downstream actions in 2025 (page 124): Cyberstore, "an AI-driven app for franchisees for automating stock replenishment", and Żabka Assistant within OptiPlan; coordination of the deposit system "with aim of minimising additional workload for the store workers", including semi-automated collection in selected stores and compensation for franchisees; the Too Good To Go and Foodsi collaboration to cut franchisee food-waste losses; and a franchisee technology survey in which "86.5% of respondents recognised their positive impact on work efficiency", up 6.5 percentage points, from over 2,200 responses.

The Group states the upstream problem is systemic: it "can only be addressed through unprecedented levels of collaboration across the value chain, including at government level" (page 120). No remediation spend is disclosed.

Targets related to value chain workers

Reference: page 124.

The Group states the measurement difficulty first: "Labour and human rights present a complex area for measurement and tracking, and we recognise the limitations of reducing such issues to simple KPIs. Our focus is on increasing suppliers' awareness of our standards and providing support to franchisees and their employees in their daily work. This ambition supports our broader policy objective of ensuring ethical sourcing and sustainable supply chain practices, as well as aligning with the 10 Principles of UN Global Compact - in this context, principles 1-6 relating to human rights and labour."

By 2026, Żabka Polska aims to:

• "Maximise the percentage of business partners familiarised with the Code of Conduct" (2025 result: 91.8%, against a 100% commitment shown in the ESG Framework, page 76)
• "Increase franchisees' NPS scores as a result of cooperation with Żabka" (2025 result: 4 pts)
• "Retain total franchisees' voluntary churn rate at same level as in the base year (2020)" (2025 result: 15.3%)

On how targets were set: "Target-setting was guided by industry benchmarks, international standards and peer practices, and was reviewed collaboratively by our teams including compliance, procurement, sustainability and senior management. While direct input from value chain workers has not yet been integrated into this process, the Group is actively exploring ways to incorporate worker perspectives."

Policies related to consumers and end-users

Reference: pages 125-126, tagged [S4-1, MDR-P].

• Sustainable Food System Framework Policy "defines the directional ambitions of the Żabka Group relating to the creation and maintenance of a sustainable food system across our modern convenience offerings... the Group commits to clear labelling and transparent communication about the products offered, including their quality and nutrition profiles". The Group Sustainability Director owns it. It was adopted by Zabka Group S.A. and cascaded to the Romanian subsidiaries.
• The Code of Conduct makes "the concealment of information that may adversely affect the product, service levels or the health of our customers" an unacceptable employee behaviour, and requires that "marketing messages or external communications are clear, honest, fair and accurate."
• Responsible Communication, Sponsorship and Public Engagement Policy: the Group commits "to ensuring full compliance with relevant communications and marketing laws, adopted self-regulations and good practices", owned by the Corporate Affairs Director.
• GDPR policies owned by the GDPR Coordinator, plus a Personal Data Protection Standard Policy implemented in 2025. It "establishes mandatory minimum standards for personal data processing across all Żabka Group entities... and covers areas such as documentation, risk assessment, data subject rights, supplier management, training, monitoring and audits."

Processes for engaging with consumers and end-users

Reference: page 126.

"Żabka Group actively engages with consumers in connection to promoting healthier dietary choices through transparent product information and initiatives like Porcja Dobrego!. The Group personnel responsible for leading consumer engagement in nutrition awareness are the Quality Standards and Climate Protection Director and the Sustainable Food Manager. At Żabka Polska, this area is managed by the Quality and Environmental Management Department, as well as New Product Development and marketing functions."

NPS. "The NPS survey serves as a vital tool for Żabka Polska and Maczfit for actively engaging with consumers and gaining a deeper understanding of their needs and expectations, supporting ongoing improvements in customer satisfaction and loyalty." Customers are asked how likely they are to recommend products or services, typically on a 0 to 10 scale. "Responses are carefully analysed to identify trends and recurring issues, enabling both companies to make targeted improvements to their offerings and customer support. The NPS is also used as a benchmark for service quality, with results regularly reported to management and used to inform strategic decisions."

Privacy. "The Group takes steps to clearly communicate privacy policies, complying with GDPR, and providing channels for consumers to manage their data processing consent and raise concerns."

Processes to remediate negative impacts and channels for consumers

Reference: page 127.

"Customers can share any nutritional or health concerns, as well as issues related to labelling transparency, through our customer service channels. In 2025 Group companies received a total of 510,296 complaints from consumers and end-users. Consumers contact us regarding a wide range of issues, such as customer care, issues with deliveries, labelling, quality and refunds."

Channels, all "monitored daily to track both the current number of pending complaints and those resolved as of the previous day": a phone line available 6am to 11pm; email, where "enquiries are resolved with 24 hours"; a form in the Żappka application; and a Messenger chatbot, where "emphasis is placed on real-time responses for immediate concerns". "Complaints are processed on a first-in, first-out (FIFO) basis using the Jira and Freshworks platforms." For complex issues, complaints are reviewed with other departments such as Quality.

A footnote sets the scale: the figure covers "all complaints received, regardless of their confirmed nature, severity or topics raised", and "with Żabka Polska's over 4 million daily customers... Such cases are infrequent as only 1 per 3,200 clients contacts us through the above-mentioned channels". Franchisees and their employees are obliged under the Franchisee Code "to treat customers with respect, courtesy and non-discrimination".

Taking action on material impacts on consumers and end-users

Reference: pages 127-128.

Porcja Dobrego! (page 128). "a nutritionist-led programme created through strong partnerships with trusted suppliers, where we develop new recipes to ensure meals and snacks marked with the special Porcja Dobrego! sticker contain only the highest-quality ingredients and maintain a balanced nutritional profile." Products are "free from artificial additives, plant-based and/or with a Nutri-Score of A, B or C". "In 2025, we introduced 65 new products meeting the Porcja Dobrego! criteria with a promising sales potential. This brought the total number of these products to 140."

Other actions. "Maczfit manufactures meal options tailored to the needs of consumers with different dietary preferences and health conditions", including glucose and lactose intolerance and diabetes; it "hires a team of six permanent dietitians" and "delivered meals to over 5,000 towns across Poland". Lite e-commerce, which has no own brands, "requires labelling from their suppliers that is in line with applicable Polish and EU regulations" and contacts suppliers where information such as country of origin or quality class is missing.

For 2026: "we intend to maintain the proportion of own-brand products meeting our Porcja Dobrego! programme criteria at around 62%", with communication targeted at students, people doing sports and senior citizens.

Targets related to consumers and end-users

Reference: pages 75, 78, 128.

Under [S4-5] the Group states: "We plan to establish measurable targets for Group entities from 2027 onwards. We outline our targets and supporting metrics focused on enhancing positive impacts for consumers and end-users, as aligned with Żabka Polska's strategy under the Sustainable lifestyle pillar on page 75" (page 128).

The 01 Sustainable lifestyle pillar, tagged [S4-5] [E5-3] [MDR-T], gives Żabka Polska commitments for 2026 with 2025 results (page 75):

On the NPS commitment the report notes: "Recent market dynamics have amplified customers price sensitivity and value-seeking behaviour. As a result, NPS and customer-sentiment scores are under pressure across the whole retail industry."

"The targets shown apply to Żabka Polska... for the years 2021-2026." No target addresses customer data privacy or consumer communication, the two material S4 risks.

Business conduct policies and corporate culture

Reference: pages 130-132.

Culture: the Code of Conduct and Ethics for Employees; the Code of Conduct and Human Rights Policy for Business Partners; the Policy of Responsible Communication, Sponsorship and Public Involvement, which "affirms our commitment to neutrality by explicitly excluding any form of political involvement from our sponsorship activities"; the Public Engagement Policy, which "introduces a complete ban on offering, giving, accepting or requesting any benefits when working or engaging with the public sector"; and the Procedure for Payment Terms.

Compliance and anti-corruption: the Compliance Strategy, owned by the Group Compliance & Privacy Officer; the Compliance Policy and Procedure, "based on ISO 37301"; the Whistleblowing Investigation Procedure, covering "the violation of provisions on corruption, money laundering and the financing of terrorism" and "the rules for... protecting whistleblowers"; the Internal Notification Procedure and Follow-up Instruction; the Conflict of Interest Management Policy; the Anti-fraud Policy, which "introduces a simple and clear message of zero tolerance for abuse, including corruption"; and Żabka Polska's Procedure for Giving and Accepting Gifts and Samples.

Management of relationships with suppliers

Reference: page 133.

"Social and environmental criteria are currently taken into consideration when business partners are onboarded at Żabka Polska. Depending on the nature of the business conducted by the business partner and the level of risk associated with our work together, assessed on the basis of turnover, strategic importance for the Company and type of activity, the supplier-verification process covers a wide range of non-financial themes. Its execution is based on well-defined processes."

"Żabka Group maintains an ongoing dialogue with its business partners and suppliers. In September 2025, Żabka Polska hosted the annual Suppliers Meeting in Poznan, attended by our suppliers' representatives. This event constituted a forum where the Company presented its development vision and strategic goals also in the sustainability area... All the invited suppliers were reminded of existing ESG and sustainability provisions dedicated to business partners as well as having a chance to access and review all respective documents."

The Fair Business Platform, in use since 2022, "primarily serves to facilitate the efficient exchange of information" and acts as a hub for sharing practices on decarbonisation, ethical business, sustainable food systems and circularity, complemented by Fair Business Brunches and Workshops (pages 76, 133).

Prevention and detection of corruption and bribery

Reference: pages 131-132.

Compliance management system (page 131). "The Żabka Group has instituted a comprehensive compliance-management system that is operational across our Group and its subsidiaries." Responsibilities are split: "Management responsibilities: Management is responsible for establishing, developing and maintaining the compliance system, overseeing its operation and communicating compliance issues within our Group"; "Management Committee oversight: the Management Committee ensures that our Group's activities are in compliance with applicable laws and internal standards"; and "Audit Committee evaluation: the Audit Committee is tasked with reviewing the system's effectiveness." The Compliance Officer reports to the Management Committee.

Training (page 132). Training is annual e-learning with a final test all participants must pass, plus face-to-face compliance training at onboarding. "At Żabka Polska, we take a cautionary approach, and all employees, regardless of role, are deemed 'functions that are most at risk in respect of corruption and bribery'." In other Group companies the compliance function and management boards identified at-risk functions, including management board members, directors, purchasing and sales, and finance.

Targets related to business conduct

Back-filled from the business conduct chapter and the ESG Framework, where targets are addressed as MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Reference: pages 76, 131-132.

A stated target exists. The 02 Mindful business impact pillar, tagged [MDR-T, E1-4], carries the 2026 commitment "100% of business partners familiarised with the Code of Conduct", with a 2025 result of 91.8% (2024: 82%) (page 76). The Code of Conduct for Business Partners and the Human Rights Policy for Business Partners cover "human rights, plastic circularity, decarbonisation and animal welfare". The same commitment is restated as a Żabka Polska 2026 aim to "maximise the percentage of business partners familiarised with the Code of Conduct" (page 124).

Effectiveness tracking, the other MDR-T limb. Anti-corruption training coverage of functions at risk is tracked at 100% for 2025 and 2024, with annual mandatory e-learning and a compulsory final test (page 132). The Audit Committee "is tasked with reviewing the system's effectiveness" (page 131), and whistleblowing outcomes are "reported to the Ethics Committee quarterly and yearly", which reports to the Board (page 132). Incident metrics are reported at zero across all five G1-4 categories, and payment practices are tracked with three metrics (pages 132-133).

Incidents of corruption or bribery

Reference: page 132.

"We did not identify any confirmed incidents of corruption or bribery during 2025."

A complete nil return across all five datapoints, for both years.

Context for the zero result: all Żabka Polska employees are treated as functions most at risk of corruption and bribery, training coverage of at-risk functions was 100%, and three whistleblowing routes exist at Żabka Polska, two of them anonymous, including the WhistleB platform accessible 24/7 (page 132). Under S1-17 the Group also reports 5 workforce complaints in 2025, none of which was classified as discrimination, harassment or a severe human rights issue (page 117). The report does not disclose the number of corruption-related reports received through the whistleblowing channels, only confirmed incidents.

Political influence and lobbying activities

Reference: page 142.

A restatement is disclosed for the prior year: "In 2024, the amount of PLN 10,183,698 was initially presented as political contributions; however, this figure relates to charity donations. The correct amount for financial and in-kind political contributions for 2024 is PLN 0."

"The Żabka Group works closely with leading industry and business organisations whose statutory activities include, among other matters, influencing the shape of public policy in areas that are key to the functioning of the trade sector... In 2025, dialogue was conducted with stakeholders primarily relating to the introduction of a deposit system on the Polish market, as well as potential regulatory changes in the area of Sunday trading."

Memberships listed: Polish Chamber of Trade, Polska Organizacja Handlu i Dystrybucji, Polish Economic Society, Polish Confederation Lewiatan, Employers of Poland, The Polish Franchisor Organization, Consumer Goods Forum, IMS Luxembourg, Friends of EFRAG and UN Global Compact. Membership amounts "relate to TUV NORD Polska and others listed".

Payment practices

Reference: page 133.

The Polish entities have implemented the Procedure for Payment Terms, with "a rigorous invoice processing procedure... to ensure that invoices progress smoothly through the approval path. Payments are executed on a daily basis."

Standard terms and SMEs. "Our standard payment terms under the Procedure are dependent on the buying category involved. Under the Procedure, payment to small and medium enterprises (SMEs) should be made within 30-60 days after receipt of the invoice, dependent on the presence of contractual advantage and on the products' shelf life being less than 30 days. All organisational units in Poland are obliged annually to verify contracts and classify contractors in terms of product category and contractual advantage."

Accounting policy: "We provide information on the Group's payment practices based on Group entities' accounting systems. It was not feasible to generate this information for two Group entities (Cool Logistics and Maczfit were excluded from the calculation)." The scope limitation is disclosed but not quantified by value of payments.