74Software

The role of the administrative, management and supervisory bodies

Composition of the Board of Directors

The Company's Board of Directors comprises ten directors (including four independent directors). It is chaired by Pierre Pasquier and assisted by a Board observer.

In 2024, the Board comprises eleven non-executive members, including four women, representing 36.4% of the Board, and four independent members, also accounting for 36.4%. There are no employee representatives on the Board.

Board Composition Table:

Board Expertise:

• 82% Knowledge of the software publishing business
• 36% Entrepreneurial experience
• 55% Finance, control & risk management expertise
• 45% Finance, control & risk management knowledge
• 73% Human resources & employee relations
• 36% Environmental & societal challenges
• 91% International dimension

Board Committees

The Board has three specialized committees:

1. Audit Committee: 5 members, 6 meetings, 100% attendance
2. Appointments, Governance and Corporate Responsibility Committee: 5 members, 5 meetings, 100% attendance
3. Compensation Committee: 5 members, 6 meetings, 100% attendance

Executive Committee

The Executive Committee consists of eight members, all men, reflecting 0% female representation. The Company recognises this and is committed to fostering a more inclusive leadership structure and increasing female representation in executive roles.

Executive Committee Members:

• PATRICK DONOVAN - CEO (United States - France)
• ERIC BIERRY - Deputy CEO, CEO SBS (France)
• ROLAND ROYER - CEO Axway (France)
• TOBIAS UNGER - CFO (Switzerland)
• XAVIER REBEUF - R&D Operations (France)
• PAUL FRENCH - Chief of Staff (United States)
• PHILIPPE BUISSON - Secretary, Digital Engagement SBS (France)
• YANN METZ-PASQUIER - Strategy & Ventures (France)

Executive Committee Characteristics:

• 8 members
• 3 nationalities

Sustainability-Related Expertise

CSR Competencies Represented on the Board of Directors:

CSR Competencies represented in Executive Committee:

The skills and expertise represented on the Board of Directors and the Executive Committee are essential in addressing 74Software's material impacts, risks, and opportunities. The diverse backgrounds of its members - including software publishing, financial services, entrepreneurship, finance, risk management, and corporate social responsibility - enable a comprehensive approach to sustainability challenges. Their expertise in human resources, social relations, environmental and societal issues, and international business ensures the Company can effectively identify and mitigate environmental impacts, anticipate regulatory changes, and develop products with a lower environmental footprint.

Frequency of Sustainability Discussions

Main Topics Covered by the Board of Directors in 2024:

• Strategy and the corporate project
• Acquisition and disposal operations
• 2024 budget and major guidelines
• Approval of financial statements
• Workplace and wage equality
• Social and environmental responsibility objectives
• Composition of the Board and its Committees
• Assessment of the Board of Directors' activities
• Share capital increase
• More in-depth implementation of the ethics and anti-corruption internal systems
• Qualification of directors as independent
• Company officer compensation
• Members of the Board compensation
• Grant of free shares to Company employees
• Analysis of the minority shareholders vote at the 2024 General Meeting
• Monitoring of legal and regulatory developments: Rixain Law, CSRD Directive, DORA Regulation, Attractiveness Law

CSR is included on the agenda of the Appointments, Governance and Corporate Responsibility Committee and the Audit Committee.

The administrative, management, and supervisory bodies, along with their respective committees, are typically updated on a quarterly basis by the CEO, who represents the Executive Committee. In addition, they receive a comprehensive presentation at least twice a year from both the CEO and the Head of CSR. Material topics are given particular focus in the implementation of the Company's strategy, with some of them incorporated into the variable remuneration framework for the CEO and certain operational managers.

Key performance metrics related to customer experience and success are presented annually to the Board of Directors and the Appointments, Governance, and Corporate Responsibility Committee, as well as internally to employees during dedicated sessions.

Specific Roles Assigned

Chief Executive Officer (CEO):

• Leads the CSR policy and defines the roadmap in quarterly Committee meetings with the Human Resources Director, the Head of CSR and, if necessary, the heads of the functional departments concerned
• The main social, societal and environmental indicators are included and measured as part of the Company's performance monitoring

EVP of People and Culture:

• Supports the CEO in CSR strategy implementation

Head of Corporate Social Responsibility:

• Supports the CEO in CSR strategy implementation
• Coordinates the CSR team and work with relevant Functional Departments (Human Resources, Purchasing, IT, Legal Affairs, etc.)
• Reports directly to the CEO on a weekly basis and delivers regular presentations to the Board or its committees

Digital Sustainability Officer:

• Part of the CSR team
• Drives the digital sustainability strategy

Network of Local Officers:

• A network of local officers in 74Software's subsidiaries is responsible for gathering social, societal and environmental data in line with the CSR roadmap

Board Committees:

• The Appointments, Governance and Corporate Responsibility Committee provides ongoing oversight, regularly reviewing progress and sustainability initiatives
• The Audit Committee oversees sustainability reporting, including matters related to audits and the sustainability report

Sustainability Integration and Oversight

The Board of Directors and the Executive Committee play a pivotal role in overseeing sustainability impacts, risks, and opportunities. They continuously assess and refine sustainability-related aspects of the Company's strategy and business model, ensuring that material risks and opportunities are identified and addressed through well-defined policies and targets.

At the operational level, the CEO, supported by the Deputy CEO, the EVP of People and Culture, and the Head of Corporate Social Responsibility, drives the implementation of sustainability initiatives. Together, they translate strategy into action, oversee the execution of key initiatives, and provide regular progress updates to the Board, reinforcing the Company's commitment to responsible and sustainable growth.

Progress on sustainability targets is regularly reviewed by the Nomination, Governance, and Corporate Responsibility Committee, along with senior management. The Committee meets quarterly to assess reports, track progress, and discuss key developments. The Board conducts an annual review of the sustainability strategy to ensure alignment with the Company's long-term objectives.

Regular internal audits reinforce compliance with policies and procedures, while the Audit Committee oversees sustainability reporting, including matters related to audits and the sustainability report.

Controls and Procedures

The Company has established dedicated controls and procedures to manage impacts, risks, and opportunities, integrating these mechanisms with other internal functions to ensure a cohesive and effective approach. The Nomination, Governance, and Corporate Responsibility Committee provides ongoing oversight, regularly reviewing progress and sustainability initiatives.

To reinforce compliance and awareness, the Company conducts internal audits and training sessions, ensuring that all employees across the Group understand and adhere to the established policies and procedures.

To ensure accuracy and accountability, CSR regulatory reporting is reviewed by independent third-party auditors.

Independence and Effectiveness

The Board of Directors comprises 36.4% independent members.

The organisation and functioning of the Board are governed by Articles L. 225-17 and subsequent provisions of the Commercial Code, as well as Articles 14 to 21 and 23 of the Company's bylaws and internal regulations.

Diversity is a key focus in the composition of the Board, ensuring a balance between independent and non-independent members while striving for gender equality. The Board also promotes multicultural diversity and a broad range of competencies to strengthen its governance and decision-making.

In 2024, the Board held 8 meetings with 97% attendance.

The Board of Directors is responsible for the regular oversight of accounting and financial information. It reviews and approves the half-year and annual financial statements, taking account of the Statutory Auditors' opinion.

Board Observer: The Board is assisted by a Board observer.

Audit Committee Activities: The Audit Committee conducts assignments on behalf of the Board of Directors and reports to the Board on:

• Internal control and risk management: monitors the smooth running of the internal control and risk management system and the preparation and processing of accounting and financial information; assesses the effectiveness of the processes set up by management to identify, evaluate, manage and verify financial and non-financial risks
• Financial reporting: critically reviews management's decisions and assessments involving financial statements, performance analyses and half-yearly reports
• Internal audit: ensures the smooth running of the internal audit function, validates the audit universe and risk mapping, approves the annual internal audit plan, and reviews assignment results as well as the implementation of recommendations
• External audit: ensures the quality of the Company's relations with the Statutory Auditors and monitors the performance of their engagement

Integration of sustainability-related performance in incentive schemes

Roles covered

The remuneration scheme covers the CEO and the Deputy CEO.

Sustainability KPIs tied to remuneration

The remuneration of the CEO and the Deputy CEO is partially based on qualitative and quantitative, social and/or environmental non-financial criteria. These criteria include:

• 5% based on the employee engagement indicator, which can be increased to 10% in case of notable over performance
• 5% based on the customer satisfaction indicator (Net Promoter Score)
• 5% based on an environmental performance indicator

Additionally, 5% of executive remuneration is tied to the reduction of 74Software's carbon footprint.

Weighting

A total of 15% of the CEO and Deputy CEO's variable remuneration is linked to sustainability criteria:

• Employee engagement: 5% (up to 10% for over-performance)
• Customer satisfaction (NPS): 5%
• Environmental performance (carbon footprint reduction): 5%

Performance period and target structure

The achievement of these quantitative and qualitative criteria is reviewed by the Board of Directors when approving the annual financial statements for the past fiscal year, based on the recommendation of the Remuneration Committee.

Link to STI or LTI

The disclosure indicates that these criteria are part of variable remuneration reviewed annually, suggesting a link to short-term incentives (STI), though this is not explicitly stated.

Strategic rationale

By linking these incentives to CSR goals, the Company encourages its leaders to prioritise and achieve these targets, thereby promoting sustainable practices throughout the organisation. The Company reinforces its commitment to sustainability, encouraging its leaders to prioritise and achieve these targets while promoting sustainable practices throughout the organisation.

Strategy, business model and value chain

Company overview and mission

74Software is a global portfolio company that provides a platform for enterprise software businesses to thrive in their chosen markets by applying their differentiated business strategies and leveraging scale benefits from being part of a larger group. 74Software has its registered office in Annecy, France, where it took root back in 1968. 74Software was created in 2024 through the strategic combination of Axway and SBS, with the Group's corporate name changing from Axway Software SA to 74Software SA on 6 December 2024.

Through its portfolio companies, 74Software is positioned as a major player in enterprise software, thanks to a diversified and globally distributed product portfolio. Thousands of companies and organisations around the world rely on 74Software's portfolio companies' software solutions to manage their critical data and business processes daily. The Group has unique strengths in the banking and financial services industry.

As of 31 December 2024, 74Software owned two portfolio companies (Axway and SBS) and had a total of 4,787 employees across 26 countries around the world.

74Software is listed in compartment B of the Paris Stock Exchange under the mnemonic code 74SW.PA. As of 31 December 2024, the Group's capitalisation was €821 million and it was included in the CAC Technology, Euronext Tech Croissance and Euronext PEA-PME 150 indices.

Corporate purpose and vision

Purpose: "A trusted, independent software provider that sustainably grows enduring value by delivering successful outcomes for its customers, opportunities for its employees and returns for its shareholders through a portfolio of market-leading products".

Vision: 74Software's vision is to become a major global company with a diversified portfolio of enterprise software businesses, delivering mission-critical software for a data-driven world. Supporting the world's leading companies and organisations in making the best use of their data and business processes, which are crucial to their success. 74Software provides software solutions that enable businesses to maximize the value of their data—enhancing processing capabilities, AI, integration, and exposition—in support of their critical business flows and seamless operations.

Key values

• Long-term focus: whether through engaging with employees, the relationships maintained with existing or prospective portfolio companies, or through long-standing shareholder base and financing partners;
• Authenticity: honesty, transparency and the highest level of ethics are at the heart of the way we interact with stakeholders;
• Secure foundation: our people, entrepreneurial spirit and decades of experience give our customers, employees, and investors a place to build a bold future.

Business model

74Software's business model can be presented as follows:

Platform services provided to portfolio companies:

• People and Culture
• Information Technology and Systems
• Cash Management and Financing
• Accounting, Tax and FP&A
• Facilities
• Legal Services
• R&D Operations

Group functions to support strategic goals:

• Investor Relations
• Banks and Financing Partners Relations
• M&A Strategy and Execution
• Consolidation, Tax and Corporate Structuring

By providing these services, 74Software believes its operating portfolio companies can focus fully on their value proposition to their customers and achieve higher revenue growth and profit margins than on a standalone basis.

Portfolio company operations:

The portfolio companies assist their customers in identifying their needs and developing robust, secure, and innovative digital solutions through software and services that optimize business processes and enhance competitiveness. A significant portion of their revenue comes from product and service subscriptions, sold directly or through partners, to large companies and organisations. Additionally, software licenses, on-site support, consulting, development, training, and other services contribute to their revenue.

Products and services

At the end of 2024, 74Software's product portfolio was based on two brands: Axway and SBS, two leading publishers, both specialists in their markets and recognised internationally.

Axway: Infrastructure software and data flow management

Axway targets several application infrastructure and middleware sub-segments, standing out in five specific markets:

• Managed File Transfer (MFT): secure and reliable managed file transfer, essential for businesses that handle sensitive data;
• B2B Gateway Software (B2B Integration - Electronic Data Interchange): electronic data exchange between companies, optimising business and logistics processes;
• API Management (Application Programming Interface Management): management tools that enable organisations to securely and efficiently create, deploy, and manage their Application Programming Interface;
• Integration Platform as a Service (iPaaS): flexible and scalable integration solutions that enable organisations to easily connect their applications and data.

Axway also offers several specialized products such as Axway Financial Accounting Hub (AFAH) for the integration, transformation, and control of financial data, supporting multiple entity accounting and reporting, intercompany processing and reconciliation, and connection to any data source or target. Other products include Axway Automator for cross-silo automation and orchestration, Axway Track & Trace for healthcare supply chain integrity, and Axway Validation Authority for real-time validation of digital certificates and access permissions within PKI environments.

SBS: Banking and financial applications

SBS, formerly Sopra Banking Software, is a major player in banking and financing software, serving over 1,500 financial institutions. The brand's software solutions cater to retail banks, corporate banks, microfinance institutions, payment or credit factories, and specialised finance institutions (e.g., auto captive). The SBS portfolio includes:

• Financing products: products to support the full lending lifecycle from origination to servicing in niche markets such as wholesale auto financing or UK mortgages;
• Integrated banking products: fully integrated core banking processing platforms that are market leaders in their chosen markets, most notably Middle East and African retail banking, French mid-market banks and retail banks in the Benelux region;
• Modular banking products: innovative and composable SaaS banking platform to address the needs of Tier 2 to Tier 4 banks with modular solutions covering front-to-back functionality in retail banking;
• Banking components: Various components to address the needs of discerning bank customers with point solutions across the payments, lending and processing space.

Key markets and geographical presence

With 74Software revenue of €690 million in 2024 (pro forma), the Company operates globally across multiple regions:

Revenue by Portfolio Company:

• Axway Scope (12 months): 48% (€329.8m)
• SBS Scope (12 months): 52% (€362.0m)

Geographic distribution:

• Europe: 3,090 employees (65%)
• Americas: 378 employees (8%)
• Middle East - Africa: 437 employees (9%)
• Asia/Pacific: 882 employees (18%)
• Total: 4,787 employees across 26 locations in over 100 countries
• Over 12,000 customers

Revenue breakdown by type (pro forma 2024):

• Recurring Revenue: 72% (including Maintenance & Support 28%, Customer-managed Subscription 27%, Own-managed Subscription 17%)
• Services: 21%
• Licenses: 7%

Product revenue breakdown by product line:

• Managed File Transfer: 42%
• B2B Integration: 25%
• API Management: 18%
• Specialised Products: 15%
• Integrated Products: 47%
• Financing Products: 25%
• Banking Components: 18%
• Modular Products: 10%

Significant groups of products/services

As outlined above, 74Software's revenue streams are diversified across:

1. Product revenue (79% of total revenue in 2024):

   • Recurring revenue (91% of product revenue)
   • License revenue

2. Services revenue (21% of total revenue in 2024):

   • While Axway's service revenue represents 11% of Axway's revenues, SBS's service revenue stands at 30% of SBS's revenues, reflecting the difference in business models and the more complex implementation projects required for banking applications.

Annual Recurring Revenue (ARR):

• Axway ARR: €246 million (grew by 7.4% in 2024)
• SBS ARR: €225 million (grew by 11.8% in 2024)

Value chain description

Upstream value chain:

74Software's upstream stakeholders include:

• Second-level suppliers of raw materials
• Energy providers
• Service vendors
• Suppliers of hardware, software, cloud services
• Third-party applications and cybersecurity providers

Key inputs:

1. Skilled professionals: Acquired through rigorous recruitment processes and continuously developed through training and development programmes.

2. Advanced technology infrastructure: Sourced through strategic partnerships with technology providers and ongoing research and development efforts. The Company integrates cutting-edge tools and methodologies, with data security as a top priority.

3. Supplier and partner network: 74Software collaborates with a trusted network of suppliers and partners to source high-quality materials and services, fostering long-term relationships built on mutual trust and sustainability. The Company takes proactive steps to minimise the environmental impact of its supply chain by adopting more sustainable practices and working with suppliers who utilise renewable energy sources.

Own operations:

The Company operates primarily through software development, secure data management, and cloud services. As of 2024, 74Software had 20 patents (issued and/or published) relating to its technologies and solutions, filed mainly in the United States in the security and data exchange integrity market segment.

Research & Development commitment:

• 2,057 employees (43% of total workforce) dedicated to R&D
• Spread across 10 main R&D centres worldwide
• Over 25% of 2024 pro forma revenue invested in R&D

Downstream value chain:

Downstream stakeholders comprise:

• Enterprise and institutional customers
• Distribution channels
• Technology innovation partners
• Original equipment manufacturers (OEMs)
• Endpoints such as systems, devices, and individual end-users

Key outputs and customer value:

74Software's products drive significant operational efficiencies and cost reductions for customers while actively supporting their sustainability objectives:

• Axway solutions contribute to sustainable IT practices by optimising resource usage and facilitating cloud migration, reducing the environmental impact of traditional infrastructure. Products such as Amplify and Managed File Transfer (MFT) enhance data transfers and system integration, minimising redundancy and reducing reliance on manual processes. By promoting cloud adoption, Axway enables companies to utilise data centres incorporating partially renewable energy sources and efficient cooling technologies.

• SBS solutions are designed with sustainability at their core, prioritising carbon footprint reduction, resource efficiency, and the integration of sustainable practices into product development. SBS ensures that its software solutions are energy-efficient and fully compliant with environmental regulations.

Both Axway and SBS products are engineered for long-term use, reducing the need for frequent reinvestment and thereby minimising electronic waste.

Customer engagement and partnerships

74Software has a worldwide network of partners, not only providing services and support but also delivering innovations that enrich and extend 74Software's solutions. With a global reach supported by an extensive network of technological partners and distributors, 74Software distributes its software products in over 100 countries, positioning itself as preferred partner for some of the world's largest companies and organizations.

Innovation and market position

74Software is committed to keeping its companies' products at the forefront of their markets through significant and continuous investment in innovation. The Company constantly invests to develop new innovative offerings and solutions for its customers, focusing on delivering the agility and functionalities expected by customers.

Market recognition (2024):

Axway:

• Positioned as a Leader in The Forrester Wave™: API Management Software, Q3 2024
• Named as Leader in API Management, B2B integration and MFT categories in Winter 2024 G2 reports
• Recognised for the 9th time as a Leader in the 2024 Gartner® Magic Quadrant™ for API Management
• Positioned as a Leader in the IDC MarketScape: Worldwide Business-to-Business Middleware 2024 Vendor Assessment

SBS:

• Designated as a Leader in Quadrant Knowledge Solutions' SPARK Matrix™: Digital Banking Platform, 2024
• "One to Watch" in the Chartis RiskTech100 2025
• One of 12 providers that matter most in The Forrester Wave™: Digital Banking Processing Platforms, Q4 2024
• A Leader in Quadrant Knowledge Solutions' SPARK Matrix™: Global Retail Core Banking, 2024
• A Leader in Quadrant Knowledge Solutions' SPARK Matrix™: Card Management System, 2024
• A Leader in Quadrant Knowledge Solutions' SPARK Matrix™: Open Banking Intermediaries, 2024

Sustainability-related goals embedded in the business model

74Software is a responsible and committed company, attentive to its social, societal and environmental impacts. The Group commits annually to the United Nations fundamental principles and the Middlenext Corporate Governance Code. Corporate responsibility policies are regularly assessed by independent third parties.

The Company's sustainability objectives are centred on:

• Maximising its social and societal impact
• Minimising its environmental impact
• Adhering to the principles of the UN Global Compact

74Software undergoes regular independent assessments by third-party organisations, including CDP, EcoVadis, EthiFinance ESG Ratings, ISS ESG, and others.

Customer experience is at the core of the business model, measured through Net Promoter Score (NPS):

• Axway NPS 2024: 52
• SBS NPS: From 2025

Employee engagement is also tracked:

• Axway employee engagement score 2024: 70%
• SBS: From 2025

Mergers and acquisitions strategy

Mergers and acquisitions play a major role in 74Software's history and strategy. Since 2001, the Group has carried out more than 25 external growth transactions under both Axway and SBS. The Group is a long-term investor in its portfolio companies, which aim to position themselves as consolidators in their respective markets.

74Software employs a proprietary M&A framework to evaluate potential acquisitions, aiming to support its long-term goals. The criteria assessed include:

• Revenue diversification
• Return on investment
• EPS accretion
• Cash generation
• Strategic fit
• Market position
• Innovation potential
• Make versus buy analysis

The acquisition of SBS in September 2024 was the most significant transaction, valued at €330 million, and was partially financed by a €131 million share capital increase.

Strategic objectives and financial targets

2025 Guidance:

• Revenue: 2-4% organic growth (around €700 million)
• Profit on operating activities: 14-16% of revenue
• Unlevered free cash flow: Around 10% of revenue

Medium-term ambitions (by 2027):

• Revenue above €750 million (same scope)
• Margin on operating activities of more than 17%

Long-term ambitions (by 2028):

• Margin on operating activities of around 20% of revenue
• Beyond 2028: aspiration to exceed €1 billion in revenue

Key non-financial KPIs

Interests and views of stakeholders

Identified stakeholder groups

74Software engages with a wide range of stakeholders, actively integrating their interests and views into its strategy and business model. Upstream stakeholders include key suppliers, providers, and partners, such as second-level suppliers of raw materials, energy providers, and service vendors. These stakeholders significantly influence the company's approach to sustainability and responsible sourcing. More directly, stakeholders include suppliers of hardware, software, cloud services, third-party applications, and cybersecurity providers. Downstream stakeholders comprise enterprise and institutional customers, distribution channels, technology innovation partners, original equipment manufacturers (OEMs), and endpoints such as systems, devices, and individual end-users.

Additionally, 74Software engages with civil society, including media, NGOs, academic institutions, individuals, and local communities. The Company also maintains active relationships within the economic sphere, collaborating with customers, suppliers, employees and their representatives, investors, shareholders, auditors, rating agencies, business partners, and public and regulatory authorities.

Engagement methods by stakeholder group

The table below lists 74Software's main stakeholders:

74Software engages with a wide range of stakeholders through proactive dialogue, actively incorporating their insights into its strategy and business model. Stakeholder engagement includes regular interaction and the integration of their interests into the company's ongoing strategic development. Stakeholder relationships are systematically managed, with interests monitored through various structured methods. For example, employee engagement is measured through an annual survey, the results of which inform specific action plans implemented throughout the year, while customer satisfaction is tracked through systematic NPS surveys with clients and partners.

Key concerns and views raised by stakeholders

The growing awareness and expectations of stakeholders, including investors, customers, and communities, further emphasises the need for comprehensive environmental strategies.

74Software is committed to meeting stakeholder expectations by participating in annual CSR evaluations and adhering to recognised standards. The Company actively engages with EcoVadis to assess its CSR performance and responsible purchasing practices, while also taking part in EthiFinance ESG Ratings to respond to our investors' evaluations.

Additionally, 74Software contributes to the Climate Disclosure Project (CDP) and submits Communication on Progress (COP) reports as part of its commitment to the UN Global Compact. The Company's adherence to the GHG Protocol ensures compliance with an internationally recognised framework for measuring and reducing greenhouse gas (GHG) emissions. Furthermore, the United Nations' Sustainable Development Goals (SDGs) serve as a guiding framework for 74Software's CSR initiatives.

Integration of stakeholder views into strategy and business model

In response to stakeholder interests and views, 74Software has significantly adapted its strategy and business model. The Group has integrated stakeholder feedback into its approach, leading to concrete enhancements in key areas. This includes adjustments based on insights from stakeholders, such as integrating feedback on sustainability priorities into strategic planning processes. As a result, the Group has committed to developing and implementing initiatives, including science-based targets for decarbonisation and enhancements to its social programmes. These initiatives are scheduled to be rolled out over the next two years, aiming to strengthen the Company's relationships with stakeholders by demonstrating a clear commitment to transparency, sustainability, and continuous improvement, ultimately fostering increased trust, collaboration, and mutual benefit.

74Software integrates stakeholder interests and perspectives into its strategy and business model through active engagement. The Company analyses these insights as part of its due diligence and materiality assessment processes, ensuring that its actions align with stakeholder expectations and sustainability objectives. The administrative, management, and supervisory bodies are regularly updated on stakeholder views regarding the Company's sustainability-related impacts. This is facilitated through structured reporting and discussions, as detailed in Section 3.1.3.1 The role of the administrative, management, and supervisory bodies (ESRS2 GOV-1).

Affected stakeholders versus users of sustainability information

The Company maintains active relationships within the economic sphere, collaborating with customers, suppliers, employees and their representatives, investors, shareholders, auditors, rating agencies, business partners, and public and regulatory authorities. By maintaining collaborative and transparent relationships with these stakeholders, 74Software ensures that its sustainability practices are both relevant and impactful across the entire value chain.

Material impacts, risks and opportunities and their interaction with strategy and business model

Material Impacts, Risks, and Opportunities

Through its materiality assessment, 74Software has identified 37 key impacts, risks, and opportunities (IROs), categorised under environmental, social & societal, and governance aspects. These IROs are detailed in the subsequent sections of this report, specifically in ESRS E1, E5, S1, S4, and G1.

Material impacts, risks, and opportunities per ESRS standards:

I-: negative impact(s); I+: positive impact(s); R: risk(s); O: opportunitie(s)

Nature and Classification of Material IROs

The material environmental impacts identified are both actual and negative, primarily arising from the operational strain on the environment, particularly in relation to carbon emissions, energy consumption, and electronic waste generation. The social impacts identified are predominantly potential and negative, reflecting inherent challenges in the software sector, such as privacy concerns, high workload, and gaps in diversity and inclusion. However, mitigation measures, including policies and initiatives, are either already in place or scheduled for implementation in the coming years. Without such actions, these negative impacts could affect both employees and end-users.

Beyond risk mitigation, 74Software also generates positive impacts. The Company creates value for employees through training and skills development while supporting digitalisation for citizens, businesses, and public institutions. The anticipated timeframes for these impacts are classified into short-term, medium-term, and long-term categories.

Value Chain Location and Time Horizons

Climate Change and Energy (ESRS E1):

Resource Use and Circular Economy (ESRS E5):

Own Workforce (ESRS S1):

Interaction with Strategy and Business Model

These material IROs are closely linked to 74Software's core business activities, primarily concentrated within its own operations. They relate to the Company's ability to develop and deliver software solutions, products, and projects, influencing and being influenced by key stakeholders such as clients, end-users, employees, data centre operations, and hardware management. Given their integration with the business model, most IROs are managed through ongoing operational processes, enabling direct intervention when necessary.

For environmental IROs within the upstream and downstream value chain, 74Software exerts direct influence by setting science-based targets to reduce greenhouse gas (GHG) emissions, implementing a low-carbon trajectory at the Group level, and strengthening procurement and waste management policies. However, the Company recognises that negative environmental impacts extend beyond its operational footprint, as climate change and electronic waste present global challenges.

Affected Stakeholder Groups

74Software's strategy and business model have a direct impact on its workforce, particularly in areas such as well-being, diversity, and work-life balance. These factors are critical to talent retention and employee engagement. The IRO analysis has identified several key workforce segments that are significantly affected by material impacts, ensuring that targeted measures are in place to address their specific needs:

• Employees on short-term contracts or in roles with limited long-term stability: These employees are significantly affected by insecure employment, leading to concerns about job security and long-term career prospects.

• Employees in roles with high turnover and team instability: These employees face challenges related to business continuity and workforce engagement, as frequent changes may disrupt team cohesion and productivity.

• Employees in roles with demanding workloads and long working hours: These employees are at risk of experiencing detrimental effects on their well-being and productivity, including stress-related illnesses and burnout.

Management and Resilience

Efforts to enhance opportunities and mitigate risks are embedded within the Company's governance structures, ensuring an integrated and proactive approach. As a result, 74Software demonstrates high resilience across the time horizons defined in the 2024 Due Diligence and Materiality Assessment. This resilience analysis relies on qualitative insights from internal subject-matter experts, providing a comprehensive evaluation of mitigating factors across all IROs.

Following the integration of Axway and SBS in September 2024, 74Software is actively developing a fully aligned workforce strategy. In 2025, efforts will be directed towards further merging teams across business functions to establish a unified approach to workforce policies and disclosures. As part of this transition, specific workforce stability and development targets will be set to mitigate identified risks, ensuring alignment with the Company's broader strategy and IRO findings. These initiatives will ensure that all employees and non-employees materially impacted by the Company's operations are fully included. Additionally, material risks, such as employment stability and workload intensity, will be systematically addressed through targeted workforce initiatives.

Financial Effects

At present, 74Software is unable to quantify the financial effects of its material risks and opportunities. However, ongoing assessments and enhancements to the DMA process will continue to refine the Company's understanding of these financial implications over time.

Description of the process to identify and assess material impacts, risks and opportunities

Overall Methodology

In 2024, 74Software conducted a Double Materiality Analysis (DMA) in line with the Corporate Sustainability Reporting Directive (CSRD), guided by European Sustainability Reporting Standards (ESRS) 1 & 2 and informed by the Company's due diligence activities. The process, overseen by the CSR team with support from an external consulting firm, followed a structured six-step methodology, engaging internal experts from various departments and validated by the executive leadership team.

The DMA unfolded in two key stages. The first stage involved mapping the interconnections between impacts, dependencies, and potential risks and opportunities, ensuring a holistic understanding of their financial and operational significance.

This was followed by an assessment of likelihood and magnitude, using both qualitative and quantitative thresholds in line with ESRS 1 Section 3.5: Financial Materiality. The evaluation accounted for direct business implications, including effects on financial performance, reputation, and operational resilience.

Step-by-Step Methodology

The process followed a structured six-step methodology:

1. Topic Identification: The first phase focused on identifying material sustainability topics, considering the Company's business model, value chain, SASB standards, and peer benchmarks. This exercise resulted in the definition of twenty-eight key topics.

2. IRO Mapping: Each topic was assessed for impacts, dependencies, risks, and opportunities across the value chain - spanning the Company's own operations, upstream suppliers, and downstream activities - as well as across short, medium, and long-term horizons. In total, 158 IROs were evaluated, with ongoing refinement expected as the Company further integrates SBS and enhances its understanding of the value chain.

3. Dependency Analysis: A key outcome of this analysis was the identification of critical dependencies, highlighting reliance on technology suppliers, a skilled workforce, third-party partnerships, customer engagement, and regulatory compliance.

4. Materiality Assessment: To assess materiality, the methodology incorporated standardised rating scales, evaluating each factor based on its severity, likelihood, magnitude, and time horizon. These criteria ensured a consistent, data-driven approach to measuring both the financial impact of sustainability risks and their broader implications for stakeholders.

5. Stakeholder Engagement: Stakeholder engagement was central to the refinement of the DMA, with internal subject matter experts and employees contributing insights through surveys, interviews, and workshops.

6. Governance Validation: Regular updates were provided to the Board of Directors and the Audit Committee, ensuring alignment with corporate governance and decision-making structures.

Inputs to the Assessment

The DMA process incorporated the following inputs:

• Sector benchmarks: SASB standards and peer benchmarks
• ESRS guidance: European Sustainability Reporting Standards (ESRS) 1 & 2
• Internal experts: Internal subject matter experts from various departments and employees
• External consultants: Support from an external consulting firm
• Stakeholder consultation: Surveys, interviews, and workshops with internal stakeholders
• Business model and value chain analysis: Consideration of the Company's business model and value chain

Scoring Criteria for Impact Materiality

The methodology incorporated standardised rating scales, evaluating each factor based on:

• Severity
• Likelihood
• Magnitude
• Time horizon (short, medium, and long-term)

These criteria ensured a consistent, data-driven approach to measuring the broader implications for stakeholders.

Scoring Criteria for Financial Materiality

The assessment used qualitative and quantitative thresholds in line with ESRS 1 Section 3.5: Financial Materiality. The evaluation accounted for:

• Direct business implications
• Effects on financial performance
• Reputation
• Operational resilience

Frequency and Last Review

The Double Materiality Analysis was conducted in 2024. In 2024, there was no specific risk assessment for ESG reporting, as it was the first exercise.

Value Chain Mapping

The assessment evaluated IROs across the value chain, spanning:

• The Company's own operations
• Upstream suppliers
• Downstream activities

Most IROs are concentrated within the Company's own operations, primarily relating to the Company's ability to develop and deliver software solutions, products, and projects, influencing and being influenced by key stakeholders such as clients, end-users, employees, data centre operations, and hardware management.

For environmental IROs within the upstream and downstream value chain, 74Software exerts direct influence by setting science-based targets to reduce greenhouse gas (GHG) emissions, implementing a low-carbon trajectory at the Group level, and strengthening procurement and waste management policies.

Material IROs Identified

Through its materiality assessment, 74Software has identified 37 key impacts, risks, and opportunities (IROs), categorised under environmental, social & societal, and governance aspects. In total, 158 IROs were evaluated.

Material impacts, risks, and opportunities per ESRS standards:

I-: negative impact(s); I+: positive impact(s); R: risk(s); O: opportunitie(s)

Integration with Risk Management

The broader risk assessment framework integrates sustainability-related risks alongside other business risks, leveraging a structured approach to prioritisation and mitigation. This process, supported by a range of risk assessment tools, ensures that the most critical sustainability risks are effectively addressed and aligned with the Company's long-term strategic objectives. By embedding sustainability considerations within its risk management framework, 74Software maintains continuous oversight of emerging risks and opportunities, reinforcing its commitment to responsible and adaptive business practices.

Nature of Material Impacts

The material environmental impacts identified are both actual and negative, primarily arising from the operational strain on the environment, particularly in relation to carbon emissions, energy consumption, and electronic waste generation. The social impacts identified are predominantly potential and negative, reflecting inherent challenges in the software sector, such as privacy concerns, high workload, and gaps in diversity and inclusion. However, mitigation measures, including policies and initiatives, are either already in place or scheduled for implementation in the coming years.

Beyond risk mitigation, 74Software also generates positive impacts. The Company creates value for employees through training and skills development while supporting digitalisation for citizens, businesses, and public institutions.

Resilience Analysis

74Software demonstrates high resilience across the time horizons defined in the 2024 Due Diligence and Materiality Assessment. This resilience analysis relies on qualitative insights from internal subject-matter experts, providing a comprehensive evaluation of mitigating factors across all IROs.

Financial Effects

At present, 74Software is unable to quantify the financial effects of its material risks and opportunities. However, ongoing assessments and enhancements to the DMA process will continue to refine the Company's understanding of these financial implications over time.

Transition plan for climate change mitigation

Given the recent acquisition of SBS by Axway in September 2024, the new Group 74Software has a long way to go to align all practices and build a new common sustainability strategy with ambitious targets and a roadmap. However, both SBS and Axway have a strong track record of monitoring greenhouse gas (GHG) emissions and remain committed to reducing their carbon footprint through the implementation of targeted emissions reduction initiatives.

Current status

Although 74Software does not yet have a formal transition plan for climate change mitigation, it is actively working to align with the transition to a sustainable economy and the goal of limiting global warming to 1.5°C, in accordance with the Paris Agreement.

The Company is also committed to supporting the objective of achieving climate neutrality by 2050, with no or limited overshoot, as established in Regulation (EU) 2021/1119 (European Climate Law).

Key focus areas

To achieve this, 74Software is focusing on:

• improving the measurement of the Company's carbon footprint, particularly the carbon footprint of the Group's products;
• defining the SBTi targets and a low-carbon trajectory;
• implementing initiatives to reduce carbon emissions;
• elevating the industry in terms of environmental standards by working with our partners, suppliers, and clients and promoting the best standards in low-carbon solutions.

Target timeline

Our objective is to have a climate change mitigation transition plan approved by our administrative, management, and supervisory bodies by the end of 2026. This plan will be fully integrated into and aligned with 74Software's overall business strategy and financial planning.

Policies related to climate change mitigation and adaptation

74Software does not have a formal environmental policy specifically dedicated to climate change mitigation and adaptation. However, the Company's actions are guided by its commitment to the United Nations Global Compact and its Supplier and Partner Charter.

United Nations Global Compact

• Policy name: United Nations Global Compact (signatory commitment)
• Scope: Through Axway, 74Software is a signatory of the Global Compact, demonstrating its dedication to sustainable and responsible business practices. Historically, SBS was also a signatory via Sopra Steria Group. In 2025, this commitment will be made at the 74Software level.
• Key content: Regarding climate change, the Global Compact encourages companies to support the transition to a low-carbon economy, reduce greenhouse gas emissions, and promote sustainable environmental practices.

Supplier and Partner Charter

• Policy name: Supplier and Partner Charter
• Scope: Suppliers and partners
• Key content: 74Software has established a Supplier and Partner Charter, incorporating its commitments to suppliers. These include reducing the environmental impact of their activities, sites, products, and services, measuring and reducing greenhouse gas emissions, and preserving natural resources by controlling energy consumption.

Digital Sustainability Policy (SBS Division)

• Policy name: Digital Sustainability Strategy
• Scope: Digital technologies and infrastructure within the SBS division, extended to Axway as of September 2024 and being adapted for 74Software
• Governance: Sponsored by Executive Committee member Xavier Rebeuf, in his role as Head of Research and Development Operations. Driven by the Digital Sustainability Officer, who is part of the CSR team, and overseen by the Executive Committee.
• Key content: The policy includes using the French eco-design referential (RGESN) to assess the global maturity score of services and conducting Life Cycle Analyses (LCA) of flagship products hosted on AWS Cloud. The Company is committed to training employees in eco-design and impact measurement, establishing a network of digital sustainability referents, and holding monthly steering committee meetings.
• Implementation and monitoring: The CSR team, particularly the Digital Sustainability Officer, leads regular communication campaigns to promote awareness of this policy. Each business unit has a digital sustainability referent responsible for disseminating relevant information within their teams. Dedicated intranet pages on SBS provide employees with updates on the deployment of the Digital Sustainability Strategy.
• Targets: Key objectives include training 30% of programming teams in eco-design and incorporating SBS products into the calculation of GHG emissions from the use of sold products by the end of 2025.

Transition Plan Status

Although 74Software does not yet have a formal transition plan for climate change mitigation, it is actively working to align with the transition to a sustainable economy and the goal of limiting global warming to 1.5°C, in accordance with the Paris Agreement. The Company is also committed to supporting the objective of achieving climate neutrality by 2050, with no or limited overshoot, as established in Regulation (EU) 2021/1119 (European Climate Law). The objective is to have a climate change mitigation transition plan approved by administrative, management, and supervisory bodies by the end of 2026.

Actions and resources in relation to climate change policies

Overview

In 2024, 74Software implemented a series of initiatives aimed at reducing emissions and energy consumption across Axway's operations. As a newly formed Group at the end of 2024, 74Software remains firmly committed to decarbonisation. However, at this stage, it has not yet been possible to quantify the emissions reductions associated with future initiatives. Additionally, the Company is currently unable to calculate the financial impact of these measures in terms of capital expenditures (CapEx) and operational expenditures (OpEx). Future reporting will provide further clarity on these aspects as sustainability efforts continue to evolve.

Action 1: Agile working methods and remote work

Description: Continued adoption of agile working methods, originally introduced several years earlier, enabling employees to work 60% remotely and 40% on-site.

Scope: Own operations

Expected outcomes:

• Significantly reduced commuting-related emissions
• Lowered office energy consumption

Action 2: Office space optimisation

Description: Implementation of flexible work arrangements and office downsizing, minimising the energy required for heating, cooling, and lighting by reducing unused office areas. Throughout 2024, several offices successfully downsized.

Scope: Own operations (France and Germany offices)

Expected outcomes/Results:

• Scope 1 and 2 CO₂ emissions from Axway's offices in France and Germany decreased by 179.8 tCO₂, representing a 51.7% reduction in these locations
• The Paris headquarters and Berlin office played a pivotal role in this reduction

Action 3: Vehicle fleet transition to hybrid and electric models

Description: Transition of vehicle fleet to hybrid and electric models, starting with Axway's fleet, as part of broader efforts to reduce greenhouse gas emissions and advance sustainable mobility solutions.

Scope: Own operations

Expected outcomes/Results:

• GHG emissions from Axway's company vehicles (reported under scope 1) decreased by 28.7 tCO₂, representing a 24.5% reduction in 2024

Action 4: Suppliers and Ethics Charter engagement

Description: Engagement with suppliers through the Suppliers and Ethics Charter, encouraging suppliers and partners to measure and reduce their environmental impact, fostering the adoption of sustainable practices across the supply chain.

Scope: Upstream value chain

Action 5: Digital sustainability strategy deployment

Description: Comprehensive digital sustainability program focused on reducing the environmental footprint of software products and digital infrastructure. Key components include:

• Evaluation of core services maturity using the French eco-design framework Référentiel Général d'Éco-Conception des Services Numériques (RGESN), with particular focus on services hosted on AWS Cloud
• Life cycle analyses of flagship products within the 74Software SBS division
• Development of an impact measurement tool to assess environmental impact of software
• Annual eco-design audits and environmental impact assessments
• Establishment of non-functional eco-design requirements
• Eco-design and impact measurement training for employees across both SBS and Axway
• Establishment of a network of digital sustainability representatives for flagship products

Scope: Own operations and downstream value chain (products sold to customers)

Time horizon: Ongoing; as of 2024, audits and measurements done on part of SBS portfolio; in 2025 aim to expand to Axway portfolio

Resources allocated:

• Non-financial: 220 developers trained in eco-design
• Financial: CAPEX and OPEX currently integrated within existing operational budgets; specific isolated figures not available as of 2024 due to recent formation

2024 Key Results:

• 220 developers trained in eco-design
• 10 best practices added to software architecture guidelines
• 5 eco-design audits conducted
• 4 environmental impact assessments completed
• Emissions related to the use of sold Axway products calculated for the first time

Note on GHG removal projects: In 2024, 74Software did not finance any greenhouse gas (GHG) removal or mitigation projects through carbon credits.

Targets related to climate change mitigation and adaptation

Publication status: Not published this year (first reporting year following 2024 creation through Axway acquisition of SBS)

Digital Sustainability Objectives for 2028

While 74Software has not yet defined GHG emission reduction targets for the Group, the following digital sustainability objectives have been established:

Progress measurement indicators:

• Total number of trained employees
• Total number of audits
• Number of non-functional requirements included in product definition framework
• Architectural principles included in software architectural guidelines
• Improvement of product life-cycle process
• INR (Institut national de la recherche) Certification

Resources allocated: 2 full-time employees to oversee progress and roadmap execution

Future Climate Targets

74Software is committed to:

• Engaging in the Science-Based Targets (SBT) initiative in 2025
• Setting ambitious, science-driven goals aligned with the transition to a sustainable economy
• Reducing GHG emissions to limit warming to 1.5°C in accordance with the Paris Agreement
• Achieving climate neutrality by 2050 with no or limited overshoot (EU Climate Law)

Transition plan objective: Approved climate change mitigation transition plan by end of 2026, fully integrated with overall business strategy and financial planning.

Energy consumption and mix

Not disclosed.

74Software states in section 3.2.6 (page 89) that while the company has successfully finalised its overall carbon footprint for 2024, time constraints related to the merger between Axway and SBS and ongoing updates to data collection processes have prevented comprehensive reporting of detailed energy consumption and mix data for this initial period. The company commits to incorporating this information into future reports as data collection systems are refined and standardised.

The company's ESRS compliance table (page 73) explicitly marks Disclosure Requirement E1-5 (Energy consumption and mix) as 'Not published this year', despite the topic being deemed Material.

Scope 1 and Scope 2 emissions data are reported (see section 3.2.7), but the underlying energy consumption data disaggregated by source (coal, oil, natural gas, renewable sources, etc.) as required under E1-5 / new E1-7 is not provided.

Gross Scopes 1, 2, 3 and Total GHG emissions (E1-6 / ESRS E1-8)

Reporting scope and methodology

The greenhouse gas (GHG) emissions assessment follows the GHG Protocol framework. Scope 1 and Scope 2 emissions data for this report covers the twelve-month period from Q4 2023 to Q3 2024, representing the most complete and verifiable dataset available within reporting deadlines. As a result, Q4 2024 emissions were estimated based on Q4 2023 data.

The assessment is based solely on Axway's historical activities. Due to the recent acquisition of SBS (September 2024), the 2024 green taxonomy reporting was conducted on a constant scope basis, excluding SBS's activities from the analysis. However, the carbon footprint was calculated over a 12-month period for both companies (Axway and SBS) to form the consolidated 74Software GHG inventory.

Methodology by scope:

Scope 1 (Direct emissions): Calculated using energy consumption data per site and fuel type. Emission factors sourced from Base Carbone databases. Includes stationary combustion (natural gas, fuel oil, biofuel, biomass), mobile combustion (company vehicles based on fuel card data), and fugitive emissions (refrigerants, assuming 2.5% leakage rate per EPA guidelines where recharged weight data unavailable).

Scope 2 (Indirect emissions from purchased energy): Calculated using electricity bills with consumption measured in kWh, aggregated by country. Where billing data unavailable, consumption extrapolated based on surface area (124 kWh/m² mean). Heating consumption for district heating calculated using Ademe emission factors. Market-based Scope 2 figures not available (NA).

Scope 3 (Value chain emissions): Categories calculated using various data sources:

• Category 1 (Purchased goods and services): Estimated using monetary data from company reporting tools, excluding rents, donations. Dell purchases used specific Dell emission factors.
• Category 3 (Fuel and energy-related activities): Computed using Ademe calculator based on energy consumption data.
• Category 5 (Waste): Data from recycling certificates and national averages, including Axway e-waste reports from Hewlett Packard Enterprise.
• Category 6 (Business travel): Based on CO₂ estimates and distance data from travel agencies. Base Carbone and Ademe factors applied.
• Category 7 (Employee commuting): Derived from employee survey (2023 survey for Axway, 2024 survey for SBS). Base Carbone factors applied.
• Category 8 (Upstream leased assets): Based on Axway's external data centre consumption data (Noida, Phoenix, Paris) assuming 24/7 usage.
• Category 11 (Use of sold products): Only Axway products calculated in 2024. Estimated based on IT architecture requirements and extrapolated to product line emissions using Annual Recurring Revenue (ARR) data. Customers categorised into size buckets by entitled purchase metrics. Server consumption calculated using Datavizta. Location-based emission factors from ADEME database applied. Axway Managed extrapolated based on revenue from customer-managed products. SBS products to be assessed in 2025.
• Category 16 (Other upstream): €406k tCO2eq for Axway.

Other Scope 3 categories (2, 4, 9, 10, 12, 13, 14, 15) deemed not applicable due to business nature.

Total GHG emissions disaggregated by Scopes 1, 2, 3 and significant Scope 3 categories

GHG intensity per net revenue

*Despite SBS joining the group in September 2024, carbon footprint calculated over 12-month period for both companies. Pro forma revenue used (Chapter 5 Note 3: 3.1 Revenue by business line) instead of actual group revenue (12 months Axway + 4 months SBS).

Scope 1 sub-breakdown (if disclosed)

The report mentions stationary combustion (natural gas, fuel oil, biofuel, biomass/wood plaquettes), mobile combustion (company vehicles), and fugitive emissions (refrigerants R-13a, R-410a, R-32) but does not provide a detailed numerical sub-breakdown by combustion type.

Biogenic CO₂ emissions

Not separately disclosed.

Regulated emissions (e.g. EU ETS)

74Software is not subject to regulated emission trading schemes.

GHG removals and carbon credits

In 2024, 74Software did not finance any GHG removal or GHG mitigation projects through carbon credits.

Internal carbon pricing

74Software did not implement an internal carbon pricing mechanism in 2024.

---

Additional context: Categories 2, 4, 9, 10, 12, 13, 14, 15 are not applicable to 74Software's business model (no capital goods, no physical products, no franchises, no investments in scope). Category 11 (Use of sold products) calculated for Axway only in 2024; SBS products to be included from 2025. Emissions from the use of sold products use ARR data (contracts signed as of 31 December 2024), potentially overestimated vs. actual annual revenue.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

This disclosure requirement has been assessed as not material by 74Software.

According to the materiality assessment table, Disclosure Requirement E1-9 – Anticipated financial effects from material physical and transition risks and potential climate-related opportunities is classified as "Not material".

No quantified financial effects, time horizons, methodologies, or specific assets flagged for climate-related risks and opportunities are disclosed.

Policies related to resource use and circular economy

74Software does not have a formal global waste management policy in place. However, the company has stated commitments and objectives related to responsible resource use and circular economy.

Stated Commitments on E-Waste Management

74Software is committed to responsible e-waste management, aiming to minimise environmental impact through regulatory compliance and employee awareness.

Key objectives:

• Reducing e-waste through reuse, refurbishment, and increased recycling
• Donating equipment to employees or charitable organisations (prioritised by Axway)
• Promoting the circular economy and limiting waste production
• Optimising recycling through the supply chain

Implementation approach:

• All electronic waste at 74Software is collected and recycled through certified e-waste recycling partners
• Obsolete equipment is sent to certified facilities to support the circular economy by enabling reuse, refurbishment, and recycling
• Axway donates equipment to employees and charitable organisations

Supply chain integration:

• The Supplier and Partner Charter promotes the circular economy, limits waste production, and optimises recycling through the supply chain
• Supplier selection prioritises those who incorporate recycled materials and minimise the use of critical and scarce minerals

Digital Sustainability Strategy

The Digital Sustainability Strategy addresses e-waste reduction and was initially developed by SBS in 2024. It is now being extended to Axway, with the objective of establishing an aligned strategy by early 2026.

Key principles:

• Software and hardware are designed for durability, repairability, and upgradability
• Extending product lifespans and minimising the need for premature hardware replacements
• Ensuring compatibility with older equipment whenever possible
• Developing partnerships with responsible e-waste recyclers
• Educating employees on responsible e-waste disposal and the environmental impact of their technology choices

Oversight: Further details on this policy can be found in Section E1 of the sustainability statement.

Actions and resources related to circular economy

74Software has disclosed circular economy actions primarily focused on the end-of-life management of IT equipment and software maintainability. Due to the company's recent establishment in 2024 following the Axway-SBS merger, specific financial allocations are integrated into broader operational budgets and not yet separately tracked.

End-of-life management of IT hardware

Partnerships with recycling companies

74Software collaborates with recycling companies to ensure responsible processing and recycling of electronic equipment, extending the lifecycle of IT assets and maximising recovery of valuable materials.

• Hewlett Packard Enterprise partnership (2024): Collected IT equipment while optimising data centres in Paris and Bucharest
  • Outcome: Avoided environmental impact of 42,245.56 kg CO₂ emissions compared to landfill disposal (based on Consequential Life Cycle Analysis Method)
  • Scope: Own operations (Axway + SBS)
  • Time horizon: Objective to have a common policy by end of 2025, with yearly follow-up

Donation of obsolete IT equipment

74Software donates obsolete IT equipment through a structured process involving equipment release requests, accounting verification for tax compliance, IT condition assessment, and secure data erasure.

• Lebanon donation (July 2024): Over 200 obsolete IT items (desktops, servers, screens, printers, scanners) donated to Live Love Recycle, a non-profit organisation dedicated to environmental preservation
  • Scope: Own operations (Axway + SBS)
  • Time horizon: Ongoing initiative with periodic reviews of donation processes and impact
  • Progress: Yearly assessments of donation impact and environmental benefits planned

Software maintainability

Design for durability and upgradability

Ensuring that software is designed for durability, repairability, and upgradability.

• Scope: Own operations (Axway + SBS)
• Time horizon: Objective set yearly
• Progress: Reviewed yearly as part of the Digital Sustainability strategy

Resources allocated

Currently, capital expenditures (CAPEX) and operational expenditures (OPEX) associated with resource-use and circular economy initiatives are integrated into the Company's broader operational budgets. As 74Software was only recently established in 2024, specific financial figures are not yet available. The Company is committed to developing a structured financial tracking approach in 2025 to provide a clear breakdown of CAPEX and OPEX related to these initiatives in future disclosures.

Actions summary table

Targets related to circular economy

74Software has not developed specific targets related to e-waste.

The company has not published quantified targets for resource use and circular economy in 2024. According to the disclosure table, E5-3 (Targets related to resource use and circular economy) is marked as "Not published this year".

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

74Software has not been able to calculate the financial effects of the negative impacts related to e-waste for the year 2024.

Waste

E-waste Management

74Software has identified electronic waste (e-waste) as the most significant waste stream for the company. All electronic waste at 74Software is collected and recycled through certified e-waste recycling partners, ensuring responsible processing.

Obsolete equipment is sent to certified facilities to support the circular economy by enabling reuse, refurbishment, and recycling. Additionally, Axway donates equipment to employees and charitable organisations.

The Company promotes the circular economy, limits waste production, and optimises recycling through its supply chain via the Supplier and Partner Charter.

2024 E-waste Data

As a software company, electronic waste (e-waste) is the most significant waste stream for 74Software. Hazardous and non-hazardous waste are not considered material to the Group. Due to the SBS acquisition in Q3 2024, comprehensive e-waste reporting across all 74Software Group sites was not possible. The only available data is presented in the table below. Additionally, information on incineration and landfill disposal could not be obtained.

*Covers Axway's headquarters in Paris and the e-waste collected during the relocation of Axway's data centres in France and Romania in 2024.

Partnership Initiatives

74Software collaborates with recycling companies to ensure the responsible processing and recycling of electronic equipment. This partnership extends the lifecycle of IT assets, maximises the recovery of valuable materials, reduces the environmental impact of electronic waste, and promotes sustainable practices within the industry.

In 2024, 74Software partnered with Hewlett Packard Enterprise to collect IT equipment while optimising data centres in Paris and Bucharest. This initiative resulted in an avoided environmental impact of 42,245.56 kg CO₂ emissions compared to landfill disposal, based on the Consequential Life Cycle Analysis Method.

In July 2024, the Lebanese team successfully donated over 200 obsolete IT items, including desktops, servers, screens, printers, and scanners, to Live Love Recycle, a non-profit organisation dedicated to environmental preservation in Beirut.

Waste Management Approach

74Software is committed to responsible e-waste management, aiming to minimise environmental impact through regulatory compliance and employee awareness. While no formal global waste management policy is in place, objectives focus on reducing e-waste through reuse, refurbishment, and increased recycling. Axway prioritises donating equipment to employees or charitable organisations.

Equipment release requests are initiated by relevant stakeholders, and the Accounting Department verifies the purchase date to ensure compliance with tax regulations. The IT Department assesses the equipment's condition and determines if repairs are required. Once all personal data has been securely erased, final compliance checks are conducted before equipment is donated either to solidarity partners for educational purposes or to eco-organisations for responsible recycling.

Policies related to own workforce

74Software has established comprehensive policies to manage the material impacts, risks, and opportunities related to its workforce, in accordance with ESRS 2 MDR-P. These policies are designed to promote fair working conditions, enhance employee well-being, and support professional development across the Group's entities, including SBS and Axway.

Workforce management policies applicable to all companies worldwide

Following the acquisition of SBS by Axway in September 2024, 74Software began standardising the Group's social policies at the end of 2024. At this stage, the following policies are applicable to the companies' own workforces worldwide:

Code of Ethics

• Scope: Covers the handling of personal and organisational data. It outlines the processes for collecting, storing, and protecting this data in compliance with applicable laws and the rules established by the Group.
• Content: Establishes rules for ethical handling of personal and organizational data.

Whistleblowing Procedure

• Scope: Applicable to employees of the portfolio companies.
• Content: Establishes a confidential mechanism for employees to report ethical concerns, misconduct, and workplace risks.
• Implementation: A dedicated, secured and confidential email reporting system (74software.ethics.notification@74software.com) is accessible to all employees and managed exclusively by the Ethics Committee.
• Governance: The Ethics Committee oversees the whistleblowing system, comprised of the EVP, People & Culture, the VP, Global Legal, and the Head of Internal Audit.
• Process: All reports submitted through the whistleblowing system are acknowledged within seven working days. The Ethics Committee ensures that employees receive updates on any follow-up actions within three months of the initial report.
• Link to international standards: Aligns with the United Nations Guiding Principles on Business and Human Rights.

Integration of workforce policies at SBS and Axway

Although no single policy currently addresses all aspects of workforce management at a unified Group level, SBS and Axway implement policies and guidelines aligned with national labour regulations and corporate sustainability goals wherever they operate. These include:

Social Protection & Working Conditions

• Scope: All European countries where the company operates.
• Content: National labour laws provide comprehensive protections, including minimum wage policies, parental leave, and health benefits.

Work-Life Balance & Working Time

• Scope: Axway employees globally; SBS employees in Belgium, Spain, France, and the UK.
• Content:
  • Axway has implemented its 'Future of Work' policy, allowing all employees to work remotely for 60% of the time in a fully flexible manner. Employees can choose their in-office days. Additionally, a portion of the workforce works entirely remotely.
  • SBS applies flexible working arrangements in countries such as Belgium, Spain, France, and the UK to enhance employee well-being and significantly reduce burnout risks.

Health & Safety Standards

• Scope: All countries of operation.
• Content: Compliance with local occupational health and safety regulations ensures a safe working environment.
• Implementation: In France, Axway and SBS comply with stringent occupational health and safety regulations, including mandatory risk assessments and employee safety training. The Document Unique d'Évaluation des Risques Professionnels (DUERP) is updated annually to identify and assess workplace risks.

Diversity & Inclusion Commitments

• Scope: Embedded within local HR strategies.
• Content: Programmes supporting gender diversity, equal pay, and workplace anti-discrimination policies.

Human Rights policy commitments

74Software is fully committed to upholding and promoting human rights across all its operations and throughout its value chain.

• Link to international standards: As a signatory of the UN Global Compact, 74Software is committed to aligning its practices with:
  • United Nations Guiding Principles on Business and Human Rights
  • OECD Guidelines for Multinational Enterprises
  • Fundamental conventions of the International Labour Organisation (ILO)
  • United Nations Global Compact (ten universal principles covering human rights, labour standards, environmental protection, and anti-corruption)
• Scope: All employees, partners, and suppliers. The Company requires its partners and suppliers to uphold the same standards by signing the Partner and Supplier Charter.
• Monitoring: Regular progress reports are published to ensure transparency. Regular reporting on these commitments, including submissions to the UN Global Compact, is publicly accessible on the UN Global Compact website.
• Remediation: Where adverse human rights impacts are identified, 74Software ensures the provision of effective remedies through the whistleblowing system and grievance mechanisms.

Future commitments & continuous improvement

To further enhance alignment with ESRS S1 requirements, 74Software is assessing opportunities to harmonise workforce policies across its portfolio companies over the next three years. As part of this effort, the Company will strengthen its workforce governance framework, enhance policy transparency, and ensure the equitable application of sustainability principles across all subsidiaries and geographies.

Taking action on material impacts on own workforce

74Software recognises that Impact, Risk, and Opportunity (IRO) indicators described do not currently have measurable, outcome-oriented targets. As the Company was established in September 2024, uniting the SBS and Axway brands under a single entity, the harmonisation of policies, data collection processes, and governance structures remains an ongoing process. A collaborative target-setting initiative will be launched in 2025.

Working Conditions – Secure Employment

Impact & Risk

Policy: 74Software aligns with local labour laws and collective agreements to provide social protection benefits and mitigate job insecurity risks. In France, Belgium, and Spain, employment regulations ensure that all workers receive fair treatment and legal protections. These provisions apply to all employees within 74Software. Responsibility for implementation rests with local HR teams within each entity, under the leadership of the Heads of HR for Axway and SBS.

Programmes:

• Internal mobility programs and career development initiatives, including Pluralsight and University-led training that enhance long-term employability
• Workforce stability monitoring through turnover analysis (HRIS & PowerBI) to identify trends and reduce reliance on short-term contracts
• Structured workforce planning and succession strategies to mitigate employment risks and ensure long-term job security

Effectiveness: Assessed through workforce metrics including turnover rates, employee retention rates, and promotion rates, reviewed periodically by HR teams at Axway and SBS.

Working Conditions – Adequate Wages

Impact & Opportunity

Policy: 74Software is committed to providing fair and competitive wages to all employees. In the European Economic Area (EEA), salaries are structured in compliance with Directive (EU) 2022/2041 on adequate minimum wages. Outside the EEA, 74Software references benchmark data from reputable sources, such as the Anker Research Institute. Annual salary reviews are conducted to ensure wage equity. In France, collective agreements define specific salary equity indicators. This policy applies to all employees directly employed by 74Software. Implementation and oversight are managed by local HR teams, operating under the strategic guidance of the Heads of HR for Axway and SBS. The Global Compensation and Benefits team provides overarching guidance.

Programmes:

• Comprehensive compensation programme with annual salary increases, ensuring employee compensation remains aligned with market standards while reflecting individual performance
• Career development programmes and training initiatives, enabling employees to enhance their skills and progress into higher-paying roles

Effectiveness: Monitored through:

• Regular salary benchmarking against industry standards and competitor compensation data
• Internal pay equity analyses to identify and address disparities
• Annual compensation reviews assessing performance-based salary adjustments
• Employee participation and advancement within career development programmes
• Employee retention rates in relation to compensation and career progression

Prevention measures: Strict compliance with national labour laws, regular internal wage equity analyses, adherence to collective bargaining agreements, transparent compensation policies, confidential grievance mechanisms for compensation concerns, annual salary policy reviews, and market benchmarking conducted at least every two years.

Working Conditions – Data Privacy

Impact

Policy: 74Software is dedicated to safeguarding the privacy and security of all employee personal data, upholding the highest standards of data protection. The policy applies to all employee personal data processed by 74Software across its global operations. Implementation and oversight are the responsibility of the Data Protection Officers (DPOs) for Axway and SBS, operating under the strategic guidance of the Legal and Compliance teams, with support from the Global Information Security team.

Programmes:

• Strict enforcement of data privacy regulations, including GDPR
• Implementation of advanced cybersecurity measures
• Regular Data Protection Impact Assessments (DPIAs)
• Employee training on data handling best practices

Effectiveness: Measured through:

• Number of reported data breaches and security incidents involving employee data
• Completion rates and effectiveness of data protection and cybersecurity training programmes
• Results of DPIAs and vulnerability scans
• Employee feedback from surveys and reporting mechanisms regarding data privacy concerns
• Audit results assessing compliance with GDPR and other regulations
• Time taken to detect, respond to, and resolve data security incidents

Prevention measures: Strict data encryption, access controls, and security monitoring protocols; regular DPIAs to identify and mitigate privacy risks; robust incident response and breach notification procedures; clear channels for reporting data privacy concerns including whistleblowing mechanisms; ongoing training on data privacy and security best practices; regular audits and compliance assessments; enforcement of data minimisation policy.

Diversity and Equal Opportunities – Gender Diversity

Impact (positive)

Policy: 74Software is committed to fostering a workplace culture where gender diversity and equal opportunities are actively promoted. The Company adheres to the United Nations' Sustainable Development Goals (SDGs) and maintains a zero-tolerance policy on harassment and discrimination, ensuring strict adherence to ethical principles on non-discrimination. The Company actively implements diversity programmes across the 26 countries in which it operates. Local policies within SBS and Axway include targeted inclusion measures and positive action initiatives for underrepresented groups. Responsibility for implementing these policies rests with the local HR teams of each entity, under the oversight of the EVP of People & Culture.

Programmes:

• Axway target: Achieving 33% female representation across its workforce
• Targeted programmes aimed at promoting gender balance in recruitment and career advancement
• In 2024, SBS launched a feminisation programme to enhance female representation in the workforce, addressing recruitment, retention, promotion, and pay equity, with action measures at the local level, including mentoring programmes, diversity awareness initiatives, and internal events highlighting female talent
• Awareness training on anti-discrimination, ethics, and diversity across the entire 74Software Group

Effectiveness: From 2025 onwards, key performance indicators such as female representation in leadership and promotion rates of diverse talent will be tracked annually. Oversight will be led by the Head of HR, with regular progress reviews reported to the Executive Committee.

Additional measures: In France, employees over the age of 45 benefit from career transition support and medical check-ups, reinforcing the Company's commitment to age inclusivity.

Diversity and Equal Opportunities – Measures Against Violence and Harassment

Impact (positive)

Policy: 74Software is committed to maintaining a safe, respectful, and inclusive work environment. The Company enforces a zero-tolerance policy against all forms of violence, harassment, and discrimination, including physical, verbal, psychological, and sexual harassment. Employees have access to a confidential whistleblowing procedure, which guarantees protection against retaliation. This policy applies to all employees across 74Software and extends to all work-related settings, including virtual and off-site interactions. Responsibility for implementing and enforcing this policy lies with the local HR teams within each entity, operating under the leadership of the Heads of HR for Axway and SBS and the Head of Legal.

Programmes:

• SBS and Axway local-level workplace conduct measures, including designation of persons of trust in Belgium and enforcement of a Bullying & Harassment policy in the UK, with clear monitoring and escalation protocols for handling reported cases

Effectiveness: Tracked through:

• Number of reported harassment cases
• Resolution times
• Employee satisfaction with the resolution process
• Employee feedback gathered through regular engagement surveys

HR teams at Axway and SBS monitor trends and adjust workplace safety measures as necessary.

Prevention measures: Adherence to national labour laws, enforcement of clear reporting and response mechanisms, regular training on prevention and reporting, investigations conducted by trained and impartial individuals, formal mechanisms for reporting discrimination or bias through the 74Software Ethics Charter and Whistleblowing Policy, with protection against retaliation.

Diversity and Equal Opportunities – Diversity

Opportunity

Policy: 74Software is committed to building a diverse and inclusive workforce and has established comprehensive recruitment policies that ensure equal opportunities for all candidates, regardless of gender, ethnicity, age, disability, sexual orientation, religion, or any other protected characteristic. The responsibility for implementing this policy lies with the local HR teams within each entity, operating under the strategic guidance and oversight of the Heads of HR for Axway and SBS.

Programmes:

• Active implementation of diversity programmes across the 26 countries in which 74Software operates
• Targeted inclusion measures and positive action initiatives for underrepresented groups at local SBS and Axway levels, including mentoring programmes, diversity awareness initiatives, and internal events highlighting female talent
• Training and awareness programmes on anti-discrimination, ethics, and diversity across the entire 74Software Group

Effectiveness: Diversity principles are actively promoted and embedded within the organisational culture, supporting equal opportunities and professional development for all employees.

Talent Recruitment, Development, and Retention – Talent Attraction

Risk

Policy: 74Software is committed to strategic talent attraction through robust and inclusive recruitment policies. The Company emphasises a proactive and data-driven approach to talent acquisition, prioritising equal opportunities, non-discrimination, and the creation of an inclusive work environment. This policy applies to all recruitment activities across 74Software. The responsibility for implementing this policy lies with the local HR teams within each entity, operating under the strategic guidance and oversight of the Heads of HR for Axway and SBS.

Programmes:

• Diverse recruitment channels, including online job portals, social media, and professional networks, to reach a broad and diverse range of candidates with varied skills and experiences
• Employee referral programmes to tap into existing networks, fostering community engagement while enhancing recruitment effectiveness

Effectiveness: Tracked through:

• Workforce demographics
• Time-to-fill positions
• Candidate satisfaction surveys
• Employee feedback on the recruitment experience

Metrics are regularly analysed to assess efficiency and impact of recruitment strategies.

Prevention measures: Fair and transparent hiring processes, comprehensive training for hiring managers on inclusive recruitment and bias mitigation, structured and accessible onboarding programmes for all new hires, and regular reviews of recruitment strategies.

Talent Recruitment, Development, and Retention – Training and Skills Development

Impact (positive), Risk, and Opportunity

Policy: 74Software recognises that investing in continuous learning and skills development is essential to empowering its workforce and fostering social mobility. The Company has implemented comprehensive training policies designed to enhance employees' knowledge, boost their confidence, and equip them with necessary tools for career advancement. These policies create a learning culture where employees are encouraged to pursue professional growth. 74Software provides accessible and relevant training opportunities, including mandatory training, professional development programmes, and role-specific learning. The Company promotes a culture of continuous feedback and personal review. User evaluations are collected after each training session. This policy applies to all employees across 74Software. The responsibility for implementing this policy lies with the University departments of Axway and SBS, working in close collaboration with local HR teams and line managers.

Programmes:

• Access to diverse training platforms and comprehensive development programmes supporting continuous learning and career progression
• Programmes covering technical skills, leadership development, and diversity and inclusion, tailored to meet specific needs of different departments and roles
• Regular personal reviews conducted between managers and employees to provide feedback, discuss career goals, and identify development opportunities
• Axway University (one of 74Software's corporate universities) providing comprehensive training programmes throughout the year to enhance employee skills and digital proficiency
• SBS University (one of 74Software's corporate universities) providing comprehensive training programmes throughout the year to enhance employee skills and digital proficiency

Effectiveness: Tracked through:

• Training completion rates
• Employee feedback surveys conducted after each training session
• Long-term performance assessments
• Employee turnover rates
• Innovation metrics (for opportunity): number of employee-driven initiatives and patents

University teams at Axway and SBS analyse these indicators to refine training programmes.

Prevention measures: Equal access to learning opportunities, regularly updated training content aligned with evolving business needs and regulatory requirements, integration of employee feedback into programme design, fair and transparent personal reviews.

Employee Engagement and Open Dialogue

Policy: 74Software actively engages with the workforce and workers' representatives across its portfolio companies to ensure that employee perspectives are incorporated into decision-making processes. In countries such as France, Belgium, and Germany, Axway and SBS employees are represented by works councils and employee representatives, who regularly meet with management. To gather direct workforce feedback, SBS and Axway conduct regular employee engagement surveys to assess workplace well-being, job satisfaction, and inclusion.

Programmes:

• Axway's 2025 Engagement Survey: With an 85% participation rate, the survey recorded an all-time high engagement score of 70%
• SBS new engagement survey to launch in March 2025, fully aligned with Axway's approach, creating a unified process
• SBS women's network to launch in March 2025 to foster community, representation, and support for women within the organisation
• CEO Office Hours for Axway employees: Launched in 2022, these digital meetings are open to all employees and provide a direct platform for interaction with the Chief Executive Officer and members of the Executive Committee
• All Hands meetings facilitated by various members of the Executive Committee
• SBS CEO Catch-ups: Providing employees with direct opportunities to engage with leadership

Effectiveness: Insights from surveys inform policy improvements, work-life balance initiatives, and diversity efforts. The 2025 Engagement Survey results highlighted improvements in resource allocation, career development opportunities, and leadership communication.

Grievance Mechanisms and Remediation

Policy: 74Software maintains comprehensive grievance mechanisms to enable employees to report concerns related to discrimination, harassment, unethical behaviour, or privacy violations without fear of retaliation. Multiple channels are provided for employees to report concerns, ensuring accessibility and confidentiality.

Programmes and Channels:

• HR Business Partners: Employees can directly raise concerns with their local HR representatives
• Whistleblowing System: A dedicated, secured and confidential email reporting system (74software.ethics.notification@74software.com) accessible to all employees and managed exclusively by the Ethics Committee
• Ethics Committee: The EVP, People & Culture, the VP, Global Legal, and the Head of Internal Audit oversee the whistleblowing system, compliance processes, and employee grievance mechanisms
• Work Councils and Employee Representatives: In countries where applicable, employees can escalate concerns through formal employee representation structures
• Data Protection Office: Employees have access to an internal ticketing system to report concerns related to data and/or privacy

Process: All reports submitted through the whistleblowing system are acknowledged within seven working days. The Ethics Committee ensures that employees receive updates on any follow-up actions within three months of the initial report. If an issue is substantiated, corrective measures may include internal investigations and appropriate disciplinary actions, engagement with relevant stakeholders to remediate the impact, and escalation to legal authorities if required.

Effectiveness: 74Software ensures that all grievance reports remain confidential. The Ethics Committee tracks and monitors all reported concerns to ensure timely and effective resolution. From 2025 onwards, remediation actions will be systematically tracked at both the Group and entity levels. The Ethics Committee will compile annual reports to assess the effectiveness of these measures.

Training and awareness: Training programmes are conducted to educate employees on data protection laws and privacy policies. Measures are in place to safeguard individuals using these channels, ensuring confidentiality and protection against retaliation.

Future initiatives: 74Software will explore initiatives to further raise awareness, ensuring that all employees are informed about their rights and equipped with the knowledge to utilise grievance mechanisms effectively.

2024 Targets and 2025 Roadmap

Axway 2024 achievements:

• Maintaining an Engagement Score of ≥65: Achieved with an engagement score of 70%, based on 85% employee survey participation
• Strengthening recruitment and retention strategies: Progress towards the 33% female representation target by 2026, with representation reaching 32% in 2024
• Performance of these KPIs directly influenced executive compensation policies

SBS 2024 focus:

• Gender equality through a collective agreement in France incorporating specific salary equity indicators
• Feminisation programme overseen by the CEO of SBS to increase female representation in management roles through targeted recruitment and development efforts
• New performance-based compensation models for executives to be introduced in 2025, incorporating employee satisfaction survey participation rates as a key performance indicator

74Software 2025 journey:

• Collaborative target setting process involving direct engagement with the workforce and their representatives
• Establishing ambitious yet achievable targets
• Diligently tracking progress
• Continuously refining approach through structured governance, robust feedback mechanisms, and strategic initiatives

Targets related to own workforce

Process and Integration Context

Following Axway's acquisition of SBS in 2024, a structured process was initiated to harmonise and unify methods for monitoring negative impacts, advancing positive impacts, and managing risks. While both companies retain a degree of independence, the Group is developing a roadmap to establish common processes in 2025.

Axway Targets (2024)

SBS Targets (2024)

Gender Equality Focus:

• A collective agreement in France incorporating specific salary equity indicators was established
• A dedicated feminisation programme overseen by the CEO of SBS aimed to increase female representation in management roles through targeted recruitment and development efforts
• No quantified targets or timelines disclosed for SBS

Performance-based compensation:

• New performance-based compensation models for executives will be introduced in 2025, incorporating employee satisfaction survey participation rates as a key performance indicator

Future Target Setting (2025)

In 2025, 74Software will embark on a new journey of collaborative target setting involving direct engagement with the workforce and their representatives to establish ambitious yet achievable targets.

Characteristics of the undertaking's employees

Total headcount and FTE

The headcount figures represent the number of employees as of December 31, 2024 (end of the reporting period).

Total employees: 4,787

Headcount by gender

Headcount by region

Headcount by country

Headcount by employment contract type

The sustainability highlights note that 99% of contracts are permanent contracts, indicating strong job stability.

Other information

Following the acquisition of SBS by Axway on 2 September 2024, the newly formed Group 74Software doubled in size. The four-month period together in 2024 did not permit sufficient time to fully align all policies, processes, programmes, and indicators. Where information is available for only one company (Axway or SBS), it is clearly stated in the report. By default, published information relates to the entire Group's scope.

The entire group's headcount is covered by employee engagement initiatives including town hall meetings, employee engagement surveys, and sustainability trainings and programs.

Characteristics of non-employees in the undertaking's own workforce

Total non-employee workers

In 2024, 74Software engaged non-employees (subcontractors) to support its operations, classified into productive contractors and structure contractors.

Productive contractors are directly involved in operational, revenue-generating activities across Professional Services, R&D, SaaS & Cloud Support, and Engineering. These contractors contribute directly to revenue by working on client-facing projects and are re-invoiced to customers.

Structure contractors support indirect, margin-enhancing functions, including business unit management, sales, administrative, and functional roles. While they do not generate revenue directly, they play a strategic role in maintaining operational efficiency and ensuring business continuity.

Methodology

The data is presented in an administrative framework, where each agency corresponds to a country for budgetary tracking purposes. This methodology aligns with 74Software's reporting practices, ensuring consistency across the Group.

Counting methodology: Headcount

74Software's strategic use of non-employees in both productive and structural roles reflects its ability to flexibly support revenue-generating operations while sustaining long-term strategic initiatives.

Collective bargaining coverage and social dialogue

At 74Software, we are committed to fostering fair and transparent working conditions for all employees. Collective bargaining agreements cover 42% of our workforce, ensuring structured representation and negotiated employment terms.

Within the European Economic Area (EEA), collective bargaining agreements are in place across several countries, covering 39.5% of employees. Outside the EEA, 2.5% of employees benefit from similar agreements.

For employees not covered by collective bargaining agreements, working conditions and employment terms are determined by local laws or industry-specific collective agreements, ensuring compliance with national labour standards.

Social dialogue remains a key focus, with 40% of employees globally represented by workers' representatives. Specific representation rates vary across EEA countries where 74Software has a significant presence. The company does not currently have an agreement for employee representation through a European Works Council (EWC), a Societas Europaea (SE) Works Council, or a Societas Cooperativa Europaea (SCE) Works Council.

Coverage and representation breakdown

Methodology note: Coverage rates are reported for countries with more than 50 employees representing more than 10% of total employees.

Diversity metrics

Gender diversity at top management level

74Software reports gender distribution at the top management level using the Executive Committee (ExCom) as the reference point, which serves as the highest operational decision-making body.

Executive Committee composition: The Executive Committee consists of eight members, all men except one, reflecting 0% female representation (noting one female member represents 13% as stated). The Company recognises this and is committed to fostering a more inclusive leadership structure and increasing female representation in executive roles.

Board of Directors gender composition

While specific numerical breakdown is not provided in a consolidated metric format, the document indicates the Board includes both male and female directors, with notable female representation including:

• Kathleen Clark (Vice-Chairwoman)
• Marie-Hélène Rigal (Director)

Age band distribution of total workforce

Overall gender split of employees

Multi-year context

Axway targets: Axway established a target of achieving 33% female representation across its workforce by 2026, with representation reaching 32% in 2024.

SBS initiatives: In 2024, SBS launched a feminisation programme to increase female representation in management roles.

Methodology note

The Executive Committee is used as the reference point for top management diversity metrics, as ExCom members serve as the highest operational decision-makers directly shaping strategic direction and corporate policies.

Adequate wages

Benchmark used

74Software applies a living wage benchmark for all employees:

• Within the European Economic Area (EEA): wages comply with Directive (EU) 2022/2041 on adequate minimum wages and align with Anker Research Institute's living wage data. The Company guarantees that wages meet or exceed the national minimum wage in every EEA country.

• Outside the EEA: 74Software relies on external benchmarks, including the Anker Research Institute's living wage data, to assess wage adequacy. In all non-EEA locations, wages are above or aligned with both the applicable national minimum wage and the living wage standards set by Anker Research Institute.

Policy statement

74Software is committed to providing fair and competitive wages to all employees, ensuring alignment with relevant legal frameworks and industry benchmarks. Annual salary reviews are conducted to ensure wage equity, taking into account market trends, job responsibilities, and individual performance. In France, collective agreements define specific salary equity indicators, which are rigorously applied to maintain fair and transparent pay structures.

Through this policy, 74Software seeks to promote a living wage and uphold equitable compensation practices across all operations.

Coverage and scope

This policy applies to all employees directly employed by 74Software, regardless of location. However, it does not extend to contractors or subcontractors, whose compensation is determined by their respective contractual agreements and applicable local labour regulations.

74Software operates in: Australia, Belgium, Bulgaria, Brazil, France, Germany, Hong Kong, India, Ireland, Italy, Luxembourg, the Netherlands, Morocco, Romania, Spain, Sweden, Switzerland, the UK, the US, Singapore, Tunisia, Ivory Coast, Senegal, Cameroon, Lebanon, and the United Arab Emirates.

Monitoring and assessment

The effectiveness of compensation initiatives is closely monitored through multiple assessment methods:

• Regular salary benchmarking conducted against industry standards and competitor compensation data
• Internal pay equity analyses performed to identify and address any disparities
• Annual compensation reviews assess performance-based salary adjustments and ensure alignment with market conditions
• Employee participation and advancement within career development programmes are actively tracked, along with employee retention rates, particularly in relation to compensation and career progression

74Software maintains strict compliance with national labour laws and regulations, conducting regular and thorough internal wage equity analyses. Salary policies and wage adjustments are reviewed annually, with market benchmarking conducted at least every two years.

Governance

The implementation and oversight of this policy are managed by local Human Resources (HR) teams within each 74Software entity, operating under the strategic guidance and supervision of the Heads of HR for Axway and SBS. The Global Compensation and Benefits team provides overarching guidance and ensures consistency in the policy's application across all regions.

Social protection

74Software has established comprehensive social protection measures for employees across Australia, Belgium, Bulgaria, Brazil, France, Germany, Hong Kong, India, Ireland, Italy, Luxembourg, the Netherlands, Morocco, Romania, Spain, Sweden, Switzerland, the UK, and the US. These protections cover sickness, unemployment, employment injury or ill-health, parental leave, and retirement.

Coverage exclusions

Unemployment: Employees are not covered by a mandatory public unemployment protection scheme in Singapore, Tunisia, Ivory Coast, Senegal, Cameroon and Lebanon as these countries' labour systems do not provide state-funded unemployment benefits. As a result, employees in these countries rely on end-of-service gratuity payments and personal savings in case of job loss.

In the United Arab Emirates (UAE), a mandatory unemployment insurance scheme exists; however, enrolment and contributions are the individual responsibility of employees, rather than the employer. This scheme is not state-funded but operates as a private insurance system mandated by the government. Employees must personally subscribe and pay the premium to receive financial support in the event of unemployment.

Retirement: In The United Arab Emirates employees are not covered for retirement benefits due to the absence of a mandatory state pension system for expatriate workers. The UAE does not require private-sector employers to provide retirement or pension schemes for foreign employees.

Social protection framework

Social protection is provided through compliance with local labour laws and collective agreements in all EEA countries where 74Software operates. The Company guarantees that wages meet or exceed the national minimum wage in every EEA country where it operates.

Training and skills development metrics

Overall training metrics (2024)

• Total training hours: 124,243 hours
• Average training hours per employee: 26 hours

Training hours by entity and gender (2024)

Performance and career development review coverage (2024)

*The participation rate is calculated based on the agreed number of employees scheduled for a Talent Review in 2024. This agreed number excludes employees who were not planned for a Talent Review due to specific circumstances, such as recent hires, employees approaching retirement, or other predefined exceptions. Therefore, the participation rate reflects the proportion of employees who completed the Talent Review out of those who were required to undergo the process in 2024.

**KPI's such as the definition and achievement of objectives, are tracked by operational managers to monitor progress and ensure alignment with Company goals. For this question, we have reported employees who did have an objectives interview launched at the beginning of the year 2024.

Non-discrimination training (2024)

Additional workforce context

• Total employees: 4,787
• Information security training coverage: 51% of employees trained in information security in 2024
• Non-discrimination practices training: 13% of employees trained in non-discrimination practices in 2024

Health and safety metrics

74Software does not operate under a formal health and safety management system but ensures compliance with local health and safety regulations across its operating countries. This approach guarantees that the majority of the workforce is protected within a robust regulatory framework designed to prevent work-related injuries and occupational health risks.

At this stage, 74Software cannot report the exact percentage of its workforce covered by a health and safety management system, as data collection is still being harmonised following the merger of Axway and SBS in September 2024. However, given the Company's role as a software publisher, the risk of work-related accidents and occupational health hazards remains extremely low. Employees primarily work in office-based environments, with minimal exposure to high-risk conditions.

Despite the absence of a Company-wide formalised health and safety management system, all employees remain covered by local legal health and safety requirements applicable in their respective countries of operation.

No specific health and safety metrics (fatalities, recordable work-related accidents, injury rates, or days lost) are disclosed for the 2024 reporting period.

Work-life balance metrics

Family-related leave entitlement and take-up

74Software is committed to fostering work-life balance by ensuring that employees have access to family-related leave, including maternity, paternity, parental, and carers' leave. The Company upholds equitable access to these benefits across its workforce, aligning with local legal requirements in each operating country.

SBS 2024:

In 2024, SBS provided family-related leave to 94.3% of its employees in all countries where legal frameworks mandate such entitlements. Among those eligible, 10.79% of employees utilised family-related leave, with 8.22% being male and 2.57% female.

Percentage of SBS employees who took family-related leave in 2024 by country:

Axway 2024:

Axway employees are also entitled to family-related leave in accordance with national policies and labour laws; however, consolidated data is not yet available for reporting.

Overall coverage:

All 74Software employees are granted family-related leave in compliance with applicable national social policies and labour regulations. Where relevant, collective bargaining agreements further reinforce these entitlements, ensuring that employees across all SBS and Axway locations have access to maternity, paternity, parental, and carers' leave.

Return-to-work rates after parental leave

Not disclosed for 2024.

Methodology notes

Data is based on SBS entities only. Family-related leave includes maternity, paternity, parental, and carers' leave as mandated by local legal frameworks in each operating country. The percentage entitled reflects compliance with local legal frameworks. Axway data collection and harmonisation with SBS was ongoing in 2024 following the merger that created 74Software.

Compensation metrics

Pay gap

74Software is committed to fair and equitable compensation practices across all operating countries. While the Company upholds the principle of equal pay for equal work, reporting a standardised gender pay gap metric is not currently feasible due to the varied remuneration structures within the workforce. Employees are compensated through different payment models, including monthly salaries, daily rates, and hourly wages, making it challenging to apply a uniform calculation method.

Given these structural differences, publishing a gender pay gap figure using a standardised formula would not accurately reflect the Company's compensation practices and could lead to misleading conclusions. However, 74Software recognises the importance of transparency in pay equity and is actively working towards harmonising remuneration data to facilitate a more standardised reporting approach in the future. The Company aims to develop a methodology that ensures accurate and representative gender pay reporting, with the objective of publishing its first gender pay gap report in 2026.

Phase-in notice: The gender pay gap disclosure is phased in for the first year of reporting under CSRD/ESRS S1-16.

Remuneration ratio

74Software has calculated the annual total remuneration ratio, which compares the earnings of the highest-paid individual to the median annual total remuneration of all employees, excluding the highest-paid individual. This calculation was based on fixed annual compensation and theoretical variable compensation for all employees contractually present as of 31 December 2024.

To ensure accuracy and comparability, remuneration figures have been restated to a full-time and full-year equivalent basis and adjusted for currency conversion at the official exchange rate of €1 = $1.08238 (as of 31 December 2024).

Based on this calculation, the remuneration ratio is:

• 21.0:1 for the CEO of 74Software
• 13.6:1 for the Deputy CEO (also CEO of SBS)

These figures reflect structural and regional variations across the Company's international operations, where salary levels are influenced by local market conditions, job functions, and economic factors. As 74Software was officially established in 2024 following the merger of Axway and SBS, this represents the first consolidated remuneration disclosure under the new Group structure.

Moving forward, 74Software remains committed to responsible remuneration practices, ensuring that compensation structures remain competitive, transparent, and aligned with both business objectives and industry benchmarks.

Methodology

The methodology applied for the remuneration ratio is the one historically used by the Company. It does not take into account the fair value of the shares. The 74Software Group will comply with the CSRD definition for the 2026 reporting.

The calculation was based on employees contractually present as of 31 December 2024, with remuneration restated to full-time and full-year equivalent basis and adjusted for currency conversion.

Incidents, complaints and severe human rights impacts (S1-17)

74Software has identified S1-17 as material but is unable to report the required indicators for 2024.

Disclosure status

For 2024, 74Software is unable to report the number of work-related incidents, complaints, and severe human rights impacts within its workforce. While these indicators are considered material to the Company's reporting, the necessary data collection and reporting systems were still being consolidated and aligned following the acquisition of SBS by Axway and the subsequent formation of 74Software.

As the integration of HR data and the establishment of unified reporting processes across the newly formed organisation remain ongoing, accurate and comprehensive data for these indicators are not available for the 2024 reporting year.

Future commitments

74Software is actively working to implement robust data collection and reporting mechanisms to ensure these indicators are fully reported in future periods. This includes the establishment of clear reporting channels, employee training on incident reporting, and the integration of data systems to provide a consolidated and transparent view of work-related incidents and human rights impacts.

Policies related to consumers and end-users

74Software has established a comprehensive framework of policies to protect consumers and end-users, particularly focusing on data protection and cybersecurity. The company addresses material impacts and risks related to data transaction security, cyberattacks, data leakage, and service availability.

Governance Model for Data Protection

74Software has established a robust Governance Model for data protection, encompassing a comprehensive framework of policies and procedures designed to safeguard data processing activities, data breach management, and cross-border data transfers.

Key content and principles:

• Ensures the highest standards of security and compliance across operations
• Addresses data processing activities, breach management, and cross-border data transfers
• Safeguards 74Software, its customers, information assets, and information systems from unauthorised access, use, disclosure, alteration, or destruction
• Ensures compliance with legal and regulatory requirements
• Enforces stringent security measures, proactive risk management and rigorous security standards

Scope: Applies to 74Software, its customers, and all associated information assets and systems across global operations (both Axway and SBS entities)

Governance and oversight:

• Data Protection Officers (DPOs) for Axway and SBS
• Legal and Compliance teams provide strategic guidance and supervision
• Global Information Security team provides technical expertise
• Local HR teams ensure awareness of data privacy policies

Monitoring and implementation:

• Data Protection Compliance Programmes implemented at both Axway and SBS
• Centralised data processing register for transparent oversight
• Streamlined data breach response procedures
• Mandatory employee training on data protection principles
• Regular assessments of data processing activities
• Periodic audits and monitoring to evaluate effectiveness
• Robust contractual measures for third-party vendors and subcontractors
• Annual reviews of policies and initiatives

Information Security Policy

The Information Security Policy serves as the cornerstone of 74Software's data protection framework.

Key content and principles:

• Protects 74Software, its customers, information assets, and information systems from unauthorised access, use, disclosure, alteration, or destruction
• Ensures compliance with legal and regulatory requirements
• Supports the Information Security Management System (ISMS) based on ISO/IEC 27001:2022
• Preserves the Confidentiality, Integrity, and Availability (CIA) of the company's and its customers' information systems and assets
• Implements cybersecurity controls aligned with business strategies
• Assigns clear accountability for cybersecurity risks
• Regular review and enhancement of policies and procedures to adapt to emerging threats and regulatory developments

Link to international standards:

• ISO/IEC 27001:2022 (Information Security Management System)

Monitoring and implementation:

• Regular reviews and enhancements to adapt to emerging threats
• Continuous monitoring of cybersecurity controls
• Clear accountability mechanisms for cybersecurity risks

Privacy Statement

74Software enforces strict data privacy policies through its comprehensive Privacy Statement.

Key content and principles:

• Ensures compliance with the General Data Protection Regulation (GDPR)
• Ensures compliance with the EU-U.S. Data Privacy Framework
• Ensures compliance with other relevant international and regional regulations
• Establishes clear guidelines for lawful and transparent collection, storage, processing, and secure disposal of personal data
• Defines individuals' rights regarding their data, including access, rectification, erasure, and portability
• Provides accessible mechanisms for exercising these rights

Scope: Applies to all personal data processed by 74Software across its global operations

Link to international standards:

• General Data Protection Regulation (GDPR)
• EU-U.S. Data Privacy Framework

Monitoring:

• Number of reported data breaches and security incidents
• Completion rates and effectiveness of data protection and cybersecurity training programmes
• Results of Data Protection Impact Assessments (DPIAs) and vulnerability scans
• Employee feedback from surveys and reporting mechanisms
• Audit results assessing compliance with GDPR and other regulations
• Time taken to detect, respond to, and resolve data security incidents

Ethics Charter and Whistleblowing Policy

The 74Software Ethics Charter and Whistleblowing Policy provide mechanisms for reporting and addressing discrimination or bias, contributing to data protection governance.

Key content and principles:

• Provides mechanisms for reporting concerns
• Addresses discrimination or bias
• Clear and accessible channels for employees to report data privacy concerns

Monitoring:

• Continuous monitoring and improvement of policies
• Regular reviews with updates in response to regulatory changes, emerging cybersecurity threats, and feedback

Preventive Measures

To prevent material negative impacts on consumers and end-users, 74Software implements:

• Strict data encryption, access controls, and security monitoring protocols
• Regular Data Protection Impact Assessments (DPIAs) to identify and mitigate privacy risks
• Robust incident response and breach notification procedures
• Ongoing training and awareness programmes on data privacy and security best practices
• Regular audits and compliance assessments
• Data minimisation policy to limit collection and retention of personal data to what is strictly necessary

Link to International Frameworks

As a signatory to the UN Global Compact, 74Software reaffirms its dedication to advancing responsible business practices, contributing to the Sustainable Development Goals.

Taking action on material impacts on consumers

74Software addresses material impacts on consumers and end-users through actions across three main subsidiaries: corporate-level security measures, Axway customer engagement initiatives, and SBS financial inclusion and accessibility programmes.

Corporate-level Data Security & Privacy Actions

Scope: Own operations

Actions implemented:

• Established global framework including Chief Information Security Officer (CISO) and Data Protection Officer (DPO)
• Implemented incident reporting procedures for employees and third parties
• Developed comprehensive data breach response plan covering containment, investigation, remediation, and notification
• Provided comprehensive security awareness training to all employees and contractors
• Established dedicated data protection contact point, online data subject request forms, and complaint channels

Time horizon: Short-term (2024 implementation, ongoing)

Resources allocated:

• Human: CISO, DPO, security teams, auditors
• Training: 100% employee training completion target by end of each year
• Financial: CAPEX and OPEX integrated within existing operational budget; specific isolated figures not available for 2024 (first year). Committed to establishing clear CAPEX/OPEX breakdown in 2025 development strategy for future transparent reporting

Expected outcomes/KPIs:

• 100% employee training completion rate (annual target)
• KPIs tracked: incident count, response time, vulnerability remediation, compliance rates (reviewed annually)
• Risk assessments based on data sensitivity, potential breach impact, and system vulnerabilities

Effectiveness: First year of implementation (2024); no prior action plans to report. Future reports will include incident analysis, training completion rates, and data breach response plan effectiveness assessments.

---

Axway Customer Engagement & Support Initiatives

Scope: Downstream value chain (customer-facing)

Actions implemented:

1. Customer engagement expansion:

   • Increasing customer engagement opportunities
   • Customer Advisory Boards (CABs), User Groups, and customer community forums
   • Introduced Axway Managed Cloud onboarding survey
   • "Idea" portal for customer-driven product improvements

2. Internal collaboration improvements:

   • Enhanced knowledge transfer between customer-facing teams and Support, R&D, and Finance
   • Investment in new internal tools to enhance employee efficiency

3. Buying process simplification:

   • Streamlining contracts
   • Automating tasks within legal review process

4. Customer learning experience:

   • Simplifying and adapting content for accessibility
   • Axway University platform providing structured, on-demand training

Time horizon: Short to medium-term (ongoing implementation)

Resources allocated:

• Human: Customer experience teams, product development teams, compliance and risk management specialists, account managers, support teams
• Financial: Financial resources allocated to customer engagement programmes, security and data protection measures, continuous platform improvements (specific amounts not disclosed)
• Training: Employee training programmes to engage customers effectively

Expected outcomes/KPIs:

• Expanded customer engagement: 56 Customer Engagement events, 17 CABs, 39 User Groups engaging over 1,300 customers (achieved)
• 1,000+ suggestions gathered via "Idea" portal, leading to 115 customer-driven product improvements
• Enhanced compliance controls and regular product security assessments

---

SBS Financial Inclusion Actions

Scope: Downstream value chain (rural and remote areas)

Actions implemented:

1. Digital banking and mobile money expansion:

   • Collaboration with telecommunications operators to improve network coverage
   • Partnerships with financial technology firms for tailored digital solutions for local populations
   • Financial literacy programmes to mitigate over-indebtedness risks

2. Risk management measures:

   • Proactive risk assessments
   • Rigorous testing protocols
   • Continuous monitoring of user feedback and market conditions
   • Strict data privacy and security measures
   • Responsible lending practices
   • Transparent communication channels and robust whistleblower policy

Time horizon: Ongoing (no specific timeframe disclosed)

Resources allocated:

• Human: Existing teams actively monitor and implement action plans; partnerships with telecom operators and fintech firms
• Financial: CAPEX and OPEX integrated within existing operational budgets; specific isolated figures not available for 2024. Committed to establishing clear CAPEX/OPEX breakdown in 2025 development strategy for future transparent reporting

Expected outcomes: Expanded access to financial services in underserved areas; removal of barriers to financial inclusion; economic growth and empowerment opportunities.

Effectiveness: Enhanced compliance controls and regular product security assessments implemented (Axway heritage); SBS has not previously reported on this topic.

---

Digital Accessibility Actions

Scope: Own operations and downstream value chain

Objective: Achieve full digital accessibility compliance across entire product portfolio by 31 December 2030, through bringing all existing products into WCAG 2.2 Level AA compliance or replacing non-compliant products with accessible alternatives.

Axway accessibility actions:

1. Multi-year accessibility plan:

   • Regular audits generating Conformance Reports using VPAT 2.4 template
   • Assessment of WCAG 2.1 compliance
   • Prioritised action plans integrated into product backlog
   • Adopting VPAT 2.5 to align with WCAG 2.2 Level AA criteria

2. Automated accessibility testing:

   • Automating accessibility testing within CI/CD process for continuous monitoring

SBS accessibility actions:

1. European Accessibility Act (EAA) alignment:

   • All new web and mobile applications launched after June 2025 must comply with WCAG 2.1 AA
   • All existing applications must achieve full compliance by June 2030
   • Prioritised focus on bank customer-facing components
   • 100% WCAG 2.1 AA compliance target for new end-user cloud components (web and mobile banking)
   • Comprehensive audits and multi-year action plans for existing components
   • Legacy components with <50% accessibility scheduled for replacement within 3 years

2. Accessibility assessment infrastructure (starting 2025):

   • Integration of Axe DevTool and NVDA tools in development processes
   • Automated CI/CD controls
   • Dedicated independent audit team conducting RGAA audits on new web pages before customer delivery
   • Cross-audits across product lines for impartiality and consistency

3. User feedback integration:

   • Customer support channels
   • User groups
   • Dedicated accessibility feedback forms
   • Risk assessments during design and development phases

Time horizon:

• Short-term: New applications post-June 2025 (WCAG 2.1 AA)
• Long-term: Full compliance by 31 December 2030 (WCAG 2.2 Level AA)

Resources allocated:

• Human: Digital Sustainability Officer (CSR department), product digital sustainability referents, accessibility auditors
• Auditors: 3 dedicated accessibility auditors by end of 2024, plan to train 2 additional auditors
• Training: Auditors trained April 2024 by Ethic First
• Financial: Not separately disclosed; integrated in development budgets

Expected outcomes/KPIs:

• 10 accessibility audits per year initially
• 100% WCAG 2.1 AA compliance for new customer-facing components
• Full portfolio compliance by 2030
• Detailed accessibility reports before product delivery

Policy linkage: Aligns with European Accessibility Act requirements and W3C accessibility guidelines.

Targets related to consumers

Customer Satisfaction (NPS)

Target for 2025:

• Metric: Net Promoter Score (NPS)
• Target value: 53
• Target year: 2025
• Baseline year: 2024
• Baseline value: 52 (achieved, exceeding the 2024 target of 46)
• Scope: Axway operations
• Type: Absolute score
• Validation: Internal methodology
• Progress: Axway achieved an NPS of 52 in 2024, exceeding the target of 46. The company has reached 'CX leader' level in the B2B software industry.

Digital Accessibility Targets

Compliance targets (Axway):

• 2025 targets:
  • Remediate identified accessibility issues
  • Enforce mandatory accessibility training for all R&D personnel
• 2026 target:
  • Achieve compliance with at least WCAG 2.0, Level AA for all products
  • Implement automated accessibility testing process
• 2027 and beyond:
  • Reach higher levels of compliance by modernising interfaces
  • Introduce fully accessible components
• Scope: All Axway products
• Type: Qualitative compliance objectives
• Validation: Internal analysis based on existing and upcoming regulations

Training targets (SBS):

• 2025 target:
  • Train 150 UX/UI developers
  • Train UX/UI designers and two accessibility auditors
  • Priority given to teams working on consumer-facing components
• 2026-2030 target:
  • Train 150 UX/UI developers annually
• Scope: SBS product development personnel
• Type: Absolute number of personnel trained
• Validation: Internal multi-year training programme

Audit targets (SBS):

• 2025: Begin auditing key strategic components (Digital Core, Digital Lending, SFP, RR, Digital Engagement, SAB Your Portal, SAB Mobile Portal, EPE)
• 2026 onwards: Conduct annual audits across all components
• Scope: All SBS components
• Type: Process/compliance targets
• Validation: Internal

Financial Inclusion (SBS Microfinance)

Status: No specific targets have been defined for SBS's microfinance solutions as of 2024. Future developments may include defining measurable objectives to enhance the impact of financial inclusion initiatives.

Business conduct policies and corporate culture

74Software has established comprehensive guidelines to address impacts, risks, and opportunities associated with business conduct and corporate culture. The company implements several key policies across its operations.

Code of Ethics

Policy name: Code of Ethics

Scope: The Code of Ethics applies to the entire Company, including both SBS and Axway, across all geographies. It governs all business activities and operations, including interactions with employees, suppliers, customers, and other stakeholders throughout the value chain. The policy is binding for all internal employees, management, and board members, as well as external stakeholders, including suppliers and business partners, where applicable.

Key content and principles: The Code defines the rules that the Company and any associated stakeholder must observe in their internal behaviour and vis-a-vis persons and companies in their business relations. It covers:

• Ethical training, including anti-corruption measures and data protection
• Strict compliance with international laws and regulations
• Fair and sustainable purchasing practices
• Anti-corruption measures
• A whistleblowing system accessible to all stakeholders
• Professional alert procedures for reporting violations
• Securities Trading Code of Conduct to prevent insider trading
• Data protection compliance

Approval and oversight: The Chairman of the Board signs the Code and is responsible for overseeing its implementation across all levels of the organisation. An Ethics Committee has been set up to regularly analyse potential cases of fraud, measures undertaken, and changes in procedures and controls. The Ethics Committee comprises the EVP, People & Culture, the VP, Global Legal, and the Head of Internal Audit.

Public availability: The Code of Ethics is publicly disclosed and accessible on 74Software's website at https://www.74software.com/ethics-and-anti-corruption. It is also distributed internally to relevant employees and teams, ensuring full accessibility for all stakeholders involved in its implementation.

Links to international standards: The Code aligns with internationally recognised guidelines and conventions, including:

• OECD Guidelines for Multinational Enterprises
• UN Guiding Principles on Business and Human Rights
• UN Declaration of Human Rights
• United Nations Global Compact (74Software is a signatory)
• United Nations Convention against Corruption

Monitoring and implementation: Mechanisms are in place for identifying, reporting, and investigating concerns about unlawful behavior or actions that contradict the Code of Ethics. Both internal and external stakeholders can report concerns via a dedicated email address (74software.ethics.notification@74software.com), accessible only by the Ethics Committee. All reports are acknowledged within seven working days, and employees receive updates on follow-up actions within three months. Management may conduct periodic audits to verify compliance with ethical practices. The Company tracks and monitors all reported concerns to ensure timely and effective resolution.

Whistleblowing Procedure

Policy name: Whistleblowing Procedure

Scope: Applies to all employees of the portfolio companies worldwide.

Key content: Establishes a confidential mechanism for employees to report ethical concerns, misconduct, and workplace risks. The procedure explicitly prohibits retaliation against whistleblowers and guarantees protection for individuals who report concerns in good faith.

Public availability: The whistleblowing policy is publicly available on the 74Software website.

Supplier & Partner Charter

Policy name: Supplier & Partner Charter

Scope: Currently in deployment phase, will progressively extend to all suppliers and partners.

Key content: Requires suppliers and partners to adhere to 74Software's Code of Ethics and sustainability standards.

Approval and oversight: The CEO, Patrick Donovan, has formally validated the Supplier & Partner Charter. The future Group Procurement Department will lead the implementation and oversight of procurement policies.

Public availability: The policy is publicly available on the 74Software website and is distributed internally to relevant employees and teams.

Training and awareness

74Software provides mandatory training on business conduct topics to all employees, including:

• Anti-corruption training: 261 employees trained across different functions (46 in Finance & Sales, 83 managers, 178 other workers). Training is delivered online with duration of 30 minutes for Axway and 10 minutes for SBS, required once during onboarding.
• Data protection and GDPR awareness
• Security awareness
• Ethics and anti-fraud training
• Insider trading prevention

The Company has achieved 74% of employees trained in ethical practices as of 2024, with a target of 100% completion.

Governance and oversight

The remuneration of the CEO and Deputy CEO is partially linked to environmental criteria, with 5% tied to the reduction of 74Software's carbon footprint. This integration reinforces the Company's commitment to sustainability and encourages leaders to prioritise CSR objectives.

A specific mapping of corruption risks is maintained and considered when establishing risk factors. The Internal Audit Department maintains an annual corruption risk map to proactively identify and mitigate potential risks.

Performance in 2024

• 0 incidents of corruption or fraud reported in 2024
• 74% of employees trained in ethical practices
• Zero-tolerance policy for fraudulent behaviour actively enforced

Incidents of corruption or bribery

Confirmed incidents

74Software reported zero incidents of corruption or fraud in 2024. The company explicitly states: "0 incidents of corruption or fraud reported in 2024" in its business conduct disclosure.

Convictions and fines

No convictions or fines related to violations of anti-corruption and anti-bribery laws were reported for the 2024 reporting period.

Disciplinary actions

No employees were dismissed or disciplined due to corruption or bribery during 2024.

Contracts terminated

No contracts with business partners were terminated or not renewed due to corruption or bribery issues during the reporting period.

Investigation procedures and speak-up mechanisms

74Software has established comprehensive procedures for reporting, investigating, and responding to allegations of corruption and bribery:

• Whistleblowing system: A dedicated, secured and confidential email reporting system (74software.ethics.notification@74software.com) is accessible to all employees and managed exclusively by the Ethics Committee
• Ethics Committee: Composed of the EVP People & Culture, VP Global Legal, and Head of Internal Audit, operates independently of the management chain to ensure objective investigations
• Response timeframe: All reports are acknowledged within seven working days, with updates provided within three months
• Protection measures: Whistleblowers are protected against retaliation, with strict confidentiality maintained throughout the reporting process
• Training: Mandatory anti-corruption training is provided to all employees (74% of employees trained in ethical practices in 2024), with particular focus on high-risk functions (Finance and Sales)
• Risk management: Internal Audit Department maintains an annual corruption risk map to proactively identify and mitigate potential risks

Reporting context

As 74Software was formally established in 2024 following Axway's acquisition of SBS in September, the company notes that while the framework for identifying, reporting, and managing corruption and bribery incidents is fully defined and published, this represents the first reporting year under CSRD requirements. The company demonstrates its commitment to transparency by outlining comprehensive reporting mechanisms and achieving zero incidents during the reporting period.

Political influence and lobbying activities

Political engagement approach

74Software does not engage in political influence or lobbying activities. The Company maintains a strict policy of neutrality in political matters and focuses on its core business operations without attempting to influence political decisions or policies.

Political contributions

No political contributions were made during the 2024 reporting period.

Lobbying expenditure

No lobbying expenditure was incurred during the 2024 reporting period.

Trade association memberships

The Company referenced engagement with Numeum (the trade union for digital companies in France) specifically for technical analysis related to EU Taxonomy eligibility interpretation. However, no disclosure was made regarding membership fees, dues, or formal lobbying activities through trade associations.

EU Transparency Register

Not disclosed.

Payment practices

74Software's procurement processes strictly adhere to the specific payment terms set by each supplier, ensuring that payments are made in accordance with the original contractual agreements. In cases where payment terms are not explicitly determined by the supplier or otherwise codified, the Company aims to process all invoices within 60 days, or within the equivalent local standard where applicable. As of 2024, 74Software does not have specific payment practices concerning small and medium enterprises (SMEs).

Average time to pay invoices

For the 2024 reporting period, the average time taken to pay an invoice, calculated from the date when the contractual or statutory payment term begins, is 46 days - with an average of 43 days for Axway and 47 days for SBS.

Contractual payment terms breakdown

The table below presents the percentage of invoices paid within the contractual terms, without distinction by supplier category. These percentages reflect the proportion of payments made within the agreed timeframe, rather than indicating delays beyond the contractual terms.

Legal proceedings for late payment

There are no outstanding legal proceedings related to late payments within the scope of 74Software's operations.

Statutory payment terms (France)

Additional detail is provided for French entities under Article D. 441-6 of the French Commercial Code:

Trade payables (invoices received) past due at fiscal year-end:

Invoices excluded from above (disputed or unrecognised debts): NIL

Reference payment terms: Statutory period of 30 days from the invoice date

Trade receivables (invoices issued) past due at fiscal year-end:

Invoices excluded from above (disputed or unrecognised debts): NIL

Reference payment terms: Statutory period of 30 days from the invoice date

Invoices issued and past due more than 91 days mainly concern inter-company receivables.