74Software

Reference: page 64.

Sustainability governance is anchored in the Board of Directors and the Executive Committee, following the Middlenext Code of Corporate Governance. The CEO is accountable for CSR strategy and results and reports on CSR quarterly, presenting progress to the Board at least twice a year through the Nomination, Governance and Corporate Responsibility Committee or the Audit Committee. The Audit Committee oversees sustainability reporting; internal audit periodically reviews compliance with policies and controls.

In 2025 the CSR function was reorganised at Group level under the Group Chief Legal Officer, acting as Head of CSR, "to centralise CSR governance, strengthen regulatory compliance, and better integrate CSR considerations into 74Software's core business activities."

The Board comprises ten directors, including four women (40%) and four independent members (40%); there are no employee representatives. The Executive Committee has nine members, one woman (11% female representation), each carrying a named CSR competency area (Social, Environment, Business Conduct, Product Sustainability).

Reference: page 65.

The administrative, management and supervisory bodies receive quarterly updates from the CEO on behalf of the Executive Committee, and at least twice-yearly updates from the CEO or Head of CSR. Information covers material sustainability topics and IROs, corresponding policies and targets, KPI performance against target pathways, and planned remediation measures. Where relevant, sustainability objectives are integrated into variable remuneration for the CEO, Deputy CEO and certain operational managers.

In 2025, key topics discussed by the Board included professional and salary equality, social and environmental responsibility objectives, the strengthening of internal ethics and anti-corruption systems, and compliance with the CSRD directive, including the Double Materiality Assessment and all material IROs. Full detail on Board discussions is cross-referenced to Chapter 4, Section 4.1.2.3.b of the Universal Registration Document.

Reference: page 65.

74Software links executive incentives to CSR objectives "to ensure that its leaders remain focused on achieving these targets." The remuneration of the CEO and Deputy CEO is partially determined by non-financial criteria, both qualitative and quantitative, covering social and/or environmental aspects, with further detail cross-referenced to Chapter 4, Section 4.4 "Compensation and Benefits."

Elsewhere in the Sustainability Statement (Section 3.2, page 79), 5% of the variable remuneration of the CEO and Deputy CEO is specifically linked to the reduction of 74Software's carbon footprint, with achievement assessed annually by the Board based on the Remuneration Committee's recommendation at the time the financial statements are approved.

Reference: page 65.

The sustainability data was verified by the Company's statutory auditors, Mazars and ACA Nexia, appointed by the General Shareholders' Meeting. Throughout preparation, 74Software teams worked with the auditors to ensure CSRD compliance; quantitative and qualitative data underwent multiple checks and verification procedures, with particular focus on defining material IROs and meeting CSRD publication standards. The audit included interviews and surveys with senior management and stakeholders, and findings were presented to and discussed with the Board and its committees.

A due diligence core-elements table (page 66) maps each stage - embedding due diligence in governance and strategy, engaging affected stakeholders, identifying and assessing adverse impacts, taking actions, and tracking effectiveness - to the corresponding ESRS 2 and topical disclosure requirements (GOV-2, GOV-3, SBM-2, SBM-3, IRO-1, MDR-P, MDR-A, MDR-M, MDR-T).

Reference: page 66.

The central CSR team collects ESG data from all levels of the Company - central operations, country offices and suppliers - extracted from HR systems and other internal tools or submitted directly by subsidiaries, then verifies it through consistency checks, supporting documentation requests, and period adjustments before consolidation. The CEO and Board of Directors oversee this process, with the Nomination, Governance, and Corporate Responsibility Committee playing a monitoring role; risk-assessment findings, control weaknesses and remediation actions are reported at least annually to the Executive Committee and then to the Board.

In 2025 the CSR team conducted a comprehensive reassessment of ESG reporting, including a comparative analysis of key indicators against the prior year and strengthened consistency checks. Risks related to digital accessibility, data privacy and whistleblower protection were reassessed at a higher level following renewed internal consultation; "the assessment confirmed that no additional material risks emerged beyond those already monitored."

Reference: page 61.

74Software is a global portfolio company, registered in Annecy and headquartered in Paris, with a consolidated workforce of 4,571 across 26 countries. It serves large enterprises and financial institutions worldwide across managed file transfer (MFT), B2B integration, API management, integration platform as a service (iPaaS), financial accounting hubs, and specialised banking and financial software, generating revenue through subscriptions, licences, support, consulting, development and training.

Value creation relies on skilled professionals and technology infrastructure; the supply chain is managed through a "trusted network of suppliers and partners selected for quality, reliability, and sustainability performance," with preference for suppliers using renewable energy. 74Software states it "does not operate in the fossil fuel, chemical production, controversial weapons, or tobacco industries," and is externally assessed via CDP, EcoVadis, EthiFinance ESG Ratings and ISS ESG among others.

Reference: pages 62-63.

74Software engages a broad stakeholder universe across the value chain: upstream suppliers of raw materials, energy, hardware, software, cloud services and cybersecurity; downstream enterprise and institutional customers, distribution and technology partners, OEMs and end-users; civil society stakeholders (media, NGOs, academia, communities); and economic stakeholders including employees, investors, auditors, rating agencies and regulators.

A stakeholder table (page 63) sets out engagement type by group - town halls and engagement surveys for employees, NPS and satisfaction surveys for customers, contracts and ESG questionnaires for suppliers and partners, annual general meetings and roadshows for investors, compliance audits and reporting for regulators, and community outreach for local communities. Stakeholder insights are analysed through the double materiality assessment and embedded in due-diligence and risk-management processes, with the administrative and supervisory bodies updated through structured reporting per Section 3.1.3.1 (GOV-1).

Reference: page 67.

Through its 2025 double materiality assessment, 74Software identifies 41 key impacts, risks, and opportunities (IROs) across environmental, social/societal and governance aspects, detailed in the ESRS E1, E5, S1, S4 and G1 sections. Compared with the prior year, the impact materiality of business conduct increased (corruption, corporate culture, and whistleblower protection - the latter newly recognised as material), the financial materiality of employee data privacy rose given higher potential fines, and digital accessibility risk was reassessed as more significant given a tightening regulatory landscape. Conversely, the assessed severity of certain working-conditions impacts was reduced after the population concerned was found to be more limited than previously estimated.

A separate per-topic table (page 68) maps material IROs to standard: E1 (climate change mitigation and energy), E5 (e-waste management), S1 (working conditions, health and safety, talent, diversity, open dialogue, data privacy), S4 (financial inclusion, digital accessibility, data/transaction security, customer experience) and G1 (business conduct, strategic partners and suppliers).

Reference: page 67.

The double materiality analysis (DMA) is led by the CSR team and validated by the Executive Committee, with periodic updates to the Board and Audit Committee, following a "structured six-step methodology that combines document review, expert interviews, workshops, and surveys with internal specialists and selected value-chain participants." The process runs in two stages: mapping and screening to identify potential IROs and value-chain touchpoints, then scoring and prioritisation against calibrated criteria for impacts (severity, probability, scope, irremediability, time horizon) and for risks/opportunities (financial performance, reputation, legal/regulatory, business continuity), consistent with ESRS 1 Section 3.5.

Sustainability risks are integrated into the Company's enterprise-wide risk-management system and evaluated using the same criteria as other corporate risks. In 2025 the DMA was refined for greater granularity (for example splitting "financial and digital inclusion" into separate topics), recalibrated legal/financial thresholds, and strengthened scoring for digital accessibility risk, without altering the core methodology.

Reference: pages 70-78.

Section 3.1.5 sets out 74Software's ESRS 2 IRO-2 concordance table, mapping each disclosure requirement to the report section addressing it and to a materiality status (Material / Not material / Not published this year). The table covers ESRS E1 (E1-2 through E1-9), E5 (E5-1 through E5-6), S1 (S1-1 through S1-17), S4 (S4-1 through S4-5) and G1 (G1-1 through G1-6), together with a separate cross-cutting table of EU-legislation-derived data points (SFDR, Pillar 3, EU Benchmark Regulation, Climate Law) spanning ESRS 2 GOV-1/GOV-4/SBM-1 and the E1 through S4 topical standards, each likewise flagged Material or Not material with a section reference where applicable.

74Software states it "conducted a mapping exercise to align the material IROs with the applicable Disclosure Requirements... ensuring that all relevant ESRS topics and information are appropriately covered."

Reference: page 80.

74Software states plainly that it "does not yet have a formal climate change mitigation transition plan ensuring full compatibility with the transition to a sustainable economy and the limitation of global warming to 1.5°C," but has taken "significant structuring steps." It has submitted company-wide near-term targets to the Science Based Targets initiative (SBTi): a 42% reduction in Scope 1 and 2 (market-based) GHG emissions by 2030 from a 2024 base year, and a 25% reduction in Scope 3 emissions by 2030 from the same base, with SBTi submission expected in 2026. Emissions from the use of sold products are excluded from the SBTi targets given "material methodological uncertainty."

Planned levers include responsible mobility/fleet electrification, energy efficiency and renewable electricity procurement (Scope 1/2), and procurement, eco-design, low-emission travel and circular-economy initiatives (Scope 3), though their combined abatement potential "has not yet [been] quantitatively assessed." No carbon lock-in analysis has been conducted. A formally approved transition plan, embedded in business strategy and financial planning, is targeted for the 2027 financial year.

Reference: page 79 (back-filled from ESRS 2 IRO-1 / the E1 climate-DMA subsection). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

74Software's Impact, Risk and Opportunities analysis was conducted "with a comprehensive scope, considering 74Software's business activities and geographical footprint," in collaboration with an external consulting firm, including "a high-level evaluation of physical and transition risks and opportunities." This assessment concluded that "adaptation to climate change is not considered a material matter," so the two identified climate IROs (climate change mitigation; energy) are both classified as negative impacts rather than physical risks.

No formal scenario analysis using named climate scenarios (for example an SSP/RCP physical-risk pathway or an IEA 1.5°C transition scenario) has yet been performed: the report states that "a more detailed analysis, including scenario-based evaluations and transition event assessments, is planned to further examine exposure and impacts along the value chain." The only forward-looking modelling disclosed is a "business-as-usual scenario reflecting expected growth by 2030" used to project the GHG emissions trajectory against the SBTi targets (E1-1, page 80), not a climate-hazard scenario analysis.

Reference: page 69 (back-filled from ESRS 2 SBM-3 / IRO-1 continuation). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

74Software states that, "as a result" of embedding risk and opportunity management within its governance structures, it "demonstrates high resilience across the time horizons defined in the 2024 Due Diligence and Materiality Assessment." This resilience analysis is qualitative, "relying on qualitative insights from internal subject-matter experts, providing a comprehensive evaluation of mitigating factors across all IROs" - it is not climate-specific but spans the full IRO register, including the two material E1 items (climate change mitigation and energy).

The same section discloses a limit on the analysis: "at present, 74Software is unable to quantify the financial effects of its material risks and opportunities," though it states that "ongoing assessments and enhancements to the DMA process will continue to refine the Company's understanding of these financial implications over time." The E1-1 transition plan's decarbonisation levers (renewable energy sourcing, fleet electrification, real-estate consolidation) are the closest analogue to an adaptive-capacity discussion, but are not framed by the company as a resilience assessment.

Reference: page 81.

Climate change mitigation commitments are embedded in the Environmental and Digital Sustainability Policy, the Group Supplier and Partner Charter, and the Code of Ethics; in 2025 the Company signed the Global Compact commitment at Group level. Through the Environmental and Digital Sustainability Policy, 74Software commits to "supporting the global objective of limiting global warming to 1.5°C, in line with the Paris Agreement, and contributing to achieving climate neutrality in Europe by 2050," to reducing GHG emissions through continuous improvement prioritising avoidance and reduction, and to integrating sustainability into decision-making, product design and stakeholder relationships.

The Supplier and Partner Charter extends these commitments to suppliers (reducing environmental impact, measuring and reducing GHG emissions, controlling energy consumption). Coordinated programmes include an annual Scope 1-3 carbon inventory, renewable electricity sourcing, gradual vehicle electrification, and Scope 3 initiatives on business travel, procurement criteria, and waste/e-waste management, all under the SBTi submission's 1.5°C ambition.

Reference: pages 82-83.

In 2025, the agile working model (60% remote/40% on-site) continued to limit commuting and office-energy emissions, and office consolidation cut Scope 1 and 2 emissions by 425.6 tCO2eq (44.5%) at Axway's Belgium, Bulgaria, France, Germany, India and USA offices, and by 391.0 tCO2eq (39.8%) at SBS's Belgium, France and Lebanon offices; two office locations now run on 100% renewable electricity. The vehicle fleet continued transitioning to hybrid and electric models, and the Supplier and Partner Charter engaged suppliers on environmental impact reduction. No GHG removal or mitigation projects were financed through carbon credits in 2025, and financial impacts of these actions are "not yet available, in line with applicable phase-in provisions."

The digital sustainability strategy addresses Scope 3 product-use emissions through eco-design, using RGESN, ISO 14040/14044, GHG Protocol ICT Sector Guidance and BOAVIZTA methodologies. In 2025 this delivered environmental-impact measurement tools deployed across two SBS products (five assessments), seven RGESN-based eco-design audits, life-cycle assessments for AWS-hosted flagship products, and eco-design training reaching 316 employees (30-minute webinar) and 84 employees (full-day programme).

Reference: page 84.

Section 3.2.5 (Target related to climate change mitigation and adaption) cross-refers in full to Section 3.2.2: the GHG reduction targets submitted to SBTi are a 42% reduction in Scope 1 and 2 (market-based) emissions by 2030 from a 2024 base year, and a 25% reduction in Scope 3 emissions by 2030 from the same base, with SBTi submission of the targets expected in 2026 and no separate target-specific disclosure provided beyond the transition-plan section.

Reference: page 84.

74Software applies "the most recent country-specific electricity and energy mix data available on the website of the International Energy Agency (IEA)" for all sites except those covered by green certificates, with mobile combustion energy from company vehicles calculated in low heating value. The disclosed 2025 energy mix is 70% fossil fuels, 20% renewable sources and 10% nuclear sources.

Reference: pages 84-89.

74Software's 2025 GHG assessment follows the GHG Protocol across two 12-month reporting periods (Q4 2024-Q3 2025 for offices/data-centre energy, fugitive emissions and waste; calendar-year January-December 2025 for other data points). In 2025 total market-based GHG emissions were 54,722 tCO2eq (Scope 1: 1,761; Scope 2 market-based: 2,722; Scope 3 market-based: 50,238), against a 2024-recalculated market-based total of 58,920 tCO2eq. Scope 1 emissions fell 8.1% year on year and Scope 2 location-based emissions fell 23.4%, reflecting office-space optimisation; market-based carbon intensity was 0.0774 tCO2eq/k€ of net revenue.

Emissions were recalculated for 2024 following ADEME's update of emission factors, also incorporating updated office and company-car energy consumption data for several countries; the recalculated 2024 figures form the SBTi base year. Purchased goods and services (spend-based) and use of sold products (estimated from IT architecture models) are the largest Scope 3 categories; only 6% of Scope 3 emissions were calculated using primary data in 2025. 74Software confirms it is "not subject to regulated emission trading schemes."

Reference: page 91.

E-waste management is governed primarily by the Group's Code of Ethics and Environmental & Digital Sustainability Policy, which "emphasise systematic collection, reuse and donation, refurbishment and recycling of electronic equipment through certified e-waste management partners." The Supplier & Partner Charter extends circular-economy expectations to suppliers, promoting responsible sourcing, use of recycled materials, minimised use of critical/scarce minerals, and compliance with conflict-minerals standards.

The policies are informed by the UN Global Compact, the GHG Protocol, the Science Based Targets initiative, conflict-minerals sourcing standards, EU WEEE regulation where relevant, and the French RGESN eco-design framework. The Board of Directors oversees the Group's sustainability strategy including resource-use and circular-economy matters, with the Executive Committee responsible for implementation.

Reference: page 92.

In 2025, as part of data-centre optimisation in France, Ireland and Romania, 74Software partnered with Hewlett Packard Enterprise on decommissioned electronic equipment: 93.67 kg was refurbished for continued use and 2,095.26 kg was recycled through certified treatment, "resulted in an estimated avoidance of 58,161.5 kg CO2eq." A further 3,146.94 kg of office-level e-waste was recycled through certified local providers, and more than 500 obsolete laptops (855.44 kg) were donated to employees after data-erasure and compliance checks.

Financial impacts of these circular-economy initiatives are "not yet available, in line with applicable phase-in provisions." A 2025 progress table (page 93) confirms 77.5% of total collected e-waste was recycled across both the data-centre and office equipment streams.

Reference: page 94.

Among available data, the proportion of recycled e-waste rose from 63% in 2024 to 77.5% in 2025; non-recycled e-waste totalled 552.0 kg (8.2% of the total). Overall, 91.8% (6,213.4 kg) of electronic equipment was valorised through reuse, recycling and refurbishment in 2025, up from 992.3 kg diverted from disposal in 2024 (of which 877.5 kg reused and 5,242.2 kg recycled in 2025, versus negligible reuse and 992.3 kg recycled in 2024). Total e-waste generated rose from 1,573.3 kg in 2024 to 6,765.4 kg in 2025, reflecting a broadened data-collection scope: "in 2025, data collection efforts focused on electronic waste generated by office equipment and IT hardware across all 74Software sites... [representing] a significant improvement compared to 2024, when the scope was more limited."

The company notes that full completeness still cannot be guaranteed for several sites (including Cameroon, Germany, Hong Kong, Italy, Ivory Coast, Lebanon, Morocco, the Netherlands, Senegal, Sweden, Tunisia, UAE and the USA), and that it "does not have this level of information" for incinerated or landfilled e-waste volumes.

Reference: pages 105-107.

Policies are structured around a Group Code of Ethics (including a "People" chapter on respect, social dialogue, health/safety, diversity and privacy) and a Whistleblowing Procedure, complemented by SBS- and Axway-level policies aligned with local labour regulations (for example SBS's Right to Disconnect Charter). Human-rights commitments flow from 74Software's UN Global Compact participation and alignment with the UN Guiding Principles on Business and Human Rights, OECD Guidelines and ILO fundamental conventions, extended to suppliers through the Code of Ethics and Supplier & Partner Charter.

74Software does "not have a centralised workplace accident prevention policy"; SBS and Axway instead follow country-specific health and safety regulations, with S1-14 metrics reported "for the first time" this year. Following the 2024 SBS acquisition, 74Software strengthened workforce governance in 2025 through a new Group Chief Human Resources Officer and a renewed Group-wide HR organisation.

Reference: pages 107-108.

Employee engagement runs through direct communication and structured representation: works councils and employee representatives operate in France, Belgium and Germany, and a Group-wide annual "Voice Survey" assesses workplace well-being, job satisfaction and inclusion. In 2026, 74Software launched its first fully harmonised Group-level survey covering the 2025 period, replacing separate SBS/Axway formats; participation reached 88%, with an overall engagement score of 66%, and results highlighted strengths in role clarity and manager dialogue.

Central and local HR teams are jointly responsible for embedding survey feedback into decision-making, and grievance mechanisms including the whistleblowing system provide a confidential channel for concerns. The report notes 74Software does "not have a centralised global framework agreement" for engagement, relying instead on national labour laws and collective agreements.

Reference: page 109.

Employees can raise concerns through HR Business Partners, a dedicated confidential Whistleblowing System email (managed exclusively by the Ethics Committee), the Ethics Committee itself (CHRO, VP Legal and Head of Internal Audit), Work Councils/Employee Representatives where applicable, and the Data Protection Office for privacy issues. Reports through the whistleblowing system are acknowledged within seven working days, with follow-up on any action within three months; substantiated issues can lead to internal investigation, disciplinary action or escalation to legal authorities, with confidentiality protected throughout.

74Software states it does "not have a formal process to assess whether employees are fully aware of and trust the grievance mechanisms available to them," and plans to explore initiatives to raise awareness of these channels going forward.

Reference: pages 110-127.

74Software discloses 19 distinct workforce impacts, risks and opportunities across working conditions (secure employment, working time, work-life balance - all risks; adequate wages - an opportunity), open dialogue (social dialogue and freedom of association/collective bargaining - both negative impacts), health and safety (negative impact), data privacy (a negative impact and a separate financial risk), diversity and equal opportunities (gender diversity, diversity, and anti-violence/harassment measures - three positive impacts), and talent acquisition/development (talent attraction, appearing as a positive impact, a risk and an opportunity; training and skills development, appearing as a negative impact, a positive impact, a risk and an opportunity).

The report states plainly that "the IRO indicators described below do not currently have measurable, outcome-oriented targets," attributing this to the ongoing 2024 SBS/Axway integration; in 2025 74Software strengthened Group-level governance (a new Global HR organisation and Group Code of Ethics) while continuing to rely on local policies and processes, with progress tracked through qualitative assessment, employee feedback and the harmonised Voice Survey pending formal targets.

Reference: page 128.

74Software states that, "as of the reporting period, 74Software has not yet defined a harmonised set of Group-wide quantitative targets under ESRS S1-5"; target-setting and monitoring remain primarily managed at entity level, in line with local legal requirements, collective agreements and HR frameworks, while the Group's stated priority is to progressively harmonise workforce governance and disclosures across SBS and Axway through the HR Chapter.

A notable entity-level example is SBS's gender-equality focus: a French collective agreement incorporating salary-equity indicators, and a dedicated feminisation programme overseen by the SBS CEO aiming to increase female representation in management through targeted recruitment and development. Going forward, 74Software intends to structure target-setting using the Group-wide engagement survey, social dialogue mechanisms and HR governance.

Reference: page 129.

At 31 December 2025, 74Software employed 4,571 people (2024: 4,787), comprising 3,184 male, 1,384 female and 3 not-declared. By region: Europe 2,962, Asia-Pacific 824, Americas 360 and Middle East-Africa 422 (2024: Europe 3,090, Asia-Pacific 882, Americas 378, Middle East-Africa 437). France is the largest single country (1,481 employees), followed by India (785) and the United Kingdom (468).

Of the 2025 total, 4,512 were permanent and 59 temporary employees (no non-guaranteed-hours employees). Average monthly headcount ranged from 4,538 (January) to 4,631 (November) in 2025. Employee turnover for 2025 was 8.9% (409 departures from SBS and Axway combined), calculated on a headcount basis and attributed to "continued integration of SBS and Axway... and the progressive alignment of the Group operating model."

Reference: page 130.

74Software engaged 671 non-employee contractors in 2025, up from 594 in 2024. Contractors support two main areas: revenue-generating, client-facing work across Professional Services, R&D, and SaaS & Cloud Support/Engineering (re-invoiced to customers), and indirect internal functions such as business-unit management, sales, administrative and functional roles. The report frames this as reflecting 74Software's "ability to flexibly support revenue-generating operations while sustaining long-term strategic initiatives."

Reference: page 131.

Collective bargaining agreements cover 46% of 74Software's global workforce - 40% within the European Economic Area (EEA) and 6% outside it. Social dialogue reaches 40% of employees globally via workers' representatives. A coverage-band table (page 131) shows 40-59% collective-bargaining coverage in Belgium, France and Spain, and 50-79% in Tunisia, Ivory Coast, Senegal, Cameroon and Morocco, against 0-19% coverage in most other EEA and non-EEA countries listed. 74Software has no European Works Council, Societas Europaea Works Council or Societas Cooperativa Europaea Works Council agreement in place.

Reference: page 131.

Women held 1 of 9 Executive Committee seats in 2025 (11%), down from 0% representation reported for 2024, and 30% of the total workforce in both 2024 and 2025 (1,384 of 4,568 in 2025). By age, 15% of the 2025 workforce is under 30 (669 employees), 64% is 30-50 (2,913) and 21% is over 50 (986), against 16%/63%/20% respectively in 2024. 74Software uses the Executive Committee as its reference point for top-management gender diversity, "as ExCom members serve as the highest operational decision-makers, directly shaping strategic direction and corporate policies."

Reference: page 132.

Within the EEA, wages comply with Directive (EU) 2022/2041 on adequate minimum wages and are benchmarked against the Anker Research Institute's living-wage data, with the Company guaranteeing wages meet or exceed the applicable national minimum wage in every EEA country of operation. Outside the EEA, 74Software relies on the Anker Research Institute's living-wage benchmarks where available, supplemented by WageIndicator data otherwise; "in all non-EEA locations, wages are above or aligned with both the applicable national minimum wage and the living wage standards set by the selected benchmark source."

Reference: page 132.

Social protection combines public schemes and employer benefits depending on jurisdiction, covering sickness, unemployment, employment injury, parental leave and retirement. Employees lack a mandatory public unemployment protection scheme in Singapore, Tunisia, Ivory Coast, Senegal, Cameroon and Lebanon, relying instead on end-of-service gratuity and personal savings; in the UAE, unemployment insurance exists but enrolment is an individual rather than employer responsibility. Retirement-coverage limitations were identified for expatriate employees in Lebanon and the UAE given the absence of a state pension system for expatriates, while the US offers Federal Social Security plus an optional company retirement plan. Parental leave is provided across the Group, "except that no paid paternity leave was identified in Lebanon."

Reference: pages 132-133.

Talent-review participation rates for 2025 were 100% (men) and 100% (women) at SBS, and 98% (men, "based on the agreed number of employees scheduled") and 97% (women) at Axway; 2024 rates were considerably lower for SBS (51% men, 54% women) but already high for Axway (99%/99%). Total 2025 training hours reached 50,285, averaging 11 hours per employee (11.2 for men, 10.7 for women); 22 managers and 215 non-managers completed non-discrimination training. No comparable 2024 training-hours data is available ("N/A").

Performance management runs on a continuous Conversation/Feedback/Recognition model; Axway conducts a global talent review jointly managed by managers and HR, while SBS uses an operational-manager/mentor structure. In 2025, 74Software launched a Group-wide Talent & Development governance function under a newly appointed Global Leader for Talent & Development.

Reference: page 133.

74Software reports S1-14 health and safety metrics "for the first time" in 2025. 100% of employees are covered by a health and safety management system. The Group recorded zero fatalities from work-related injuries or ill health (own workforce and other workers on-site), 14 recordable work-related accidents (a rate of 1.5), 2 cases of recordable work-related ill health, and 304 days lost to work-related injuries, fatalities and ill health combined. No comparable 2024 figures are available ("N/A"), reflecting the metric's first-year status.

Reference: page 134.

In 2025, SBS provided family-related leave to 97% of employees, of whom 13.5% took such leave (10.4% male, 3.1% female). Axway provided family-related leave to 100% of employees, of whom 8.8% took leave (6.9% male, 1.9% female). All 74Software employees are entitled to family-related leave (maternity, paternity, parental and carers') in compliance with applicable national social policies, reinforced where relevant by collective bargaining agreements.

Reference: page 134.

74Software reports a gender pay gap of 23% for the 2025 period, calculated using target total cash compensation (base salary and target bonus) on a full-time-equivalent basis - described as "an improvement compared to 2024, as it reflects increased data consolidation and transparency at Group level," though not yet a fully CSRD-aligned calculation given "heterogeneous" remuneration data across entities following the SBS acquisition and the phased rollout of Workday as the Group HRIS.

The annual total remuneration ratio, comparing the highest-paid individual's earnings to the median of all other employees on a full-time, full-year-equivalent basis, is 20.7:1 for the CEO of 74Software and 13.4:1 for the Deputy CEO (also CEO of SBS). The methodology "does not take into account the fair value of the shares," and the Company states it "will continue strengthening alignment with the CSRD definition for future reporting periods."

Reference: page 135.

In 2025, 74Software recorded zero severe human rights issues or incidents, zero related fines/penalties/compensation, and zero incidents of discrimination. Two complaints were filed through channels for the own workforce to raise concerns, and no complaints were filed to National Contact Points for OECD Multinational Enterprises. USD 24,532.60 was paid in fines, penalties and compensation for damages "as result of incidents of discrimination, including harassment and complaints filed." The Group states that "in the reporting period, 74Software did not identify any severe human rights incidents connected to its own workforce," with figures compiled from Ethics Committee case reviews fed by the whistleblowing channel and HR/other internal escalations. No comparable 2024 figures are available ("N/A").

Reference: page 137.

74Software's approach to consumers and end-users is anchored in its Code of Ethics, which sets expectations for responsible business conduct, personal-data protection, information security, and ethical use of technology in dealings with customers, partners and other external stakeholders, applying across all entities including Axway and SBS. The Code defines mechanisms to report non-compliant behaviour, including a whistleblowing procedure open to employees and external stakeholders for breaches of ethical principles, legal requirements or fundamental rights, with more detailed policies for each material S4 sub-topic (data and transaction security, customer experience, financial inclusion, digital accessibility) set out in the corresponding sections.

Reference: pages 137, 146, 149-150.

Engagement mechanisms are tailored to each material sub-topic. On data and transaction security, 74Software communicates through email, in-app notifications and social media, backed by Axway's Responsible Disclosure programme and SBS's bug bounty programme, with the CISO and DPO jointly responsible for engagement outcomes. On customer experience, Axway runs an Engage-Listen-Analyse-Act model (Voice of the Customer programme, 86 customer engagement events, 15 Advisory Council meetings and 71 User Groups involving 1,644+ customers in 2025) while SBS follows Listen-Understand-Act (SBS Summit, five regional Connect events, Customer Groups, CEO Round Tables).

On financial inclusion, SBS engages African communities through market research, needs assessments, interviews and focus groups, co-led by the Clients & Growth Department and the Core Amplitude General Manager, exemplified by its partnership with Scolaris Finance SA in Mali and Burkina Faso. On digital accessibility, 74Software gathers feedback via user surveys, support tickets and dedicated customer-service teams, tracked through NPS and satisfaction surveys.

Reference: pages 143-144, 147, 149-150.

For data and transaction security, the Data Protection Compliance Programme structures breach reporting and remediation, with dedicated support portals, email and in-app channels, plus whistleblowing protection for those reporting suspected corruption or bribery. For customer experience, escalation paths are communicated during contract negotiations and monitored through surveys and user-group sessions, backed by the same whistleblowing policy publicly available on the 74Software website.

For financial inclusion, SBS applies debt-management frameworks, vulnerable-group support and data-privacy protocols, with concerns reviewed against defined response timelines and corrective measures such as loan restructuring; the whistleblower policy covers unfair-lending or data-privacy reports. For digital accessibility, regular audits generate Conformance Reports (VPAT, RGAA or RAAM templates) against WCAG 2.1 Level AA, feeding prioritised remediation into the product backlog, alongside mandatory employee accessibility training and whistleblower coverage of accessibility barriers.

Reference: pages 144-145, 147-148, 149, 151.

In 2025, 74Software established a Group-level Security Office - organised around governance/risk/compliance, enterprise infrastructure security, software security, and cloud/SaaS security - to coordinate data and transaction security risk management across Axway and SBS, targeting 100% annual security-training completion; no severe human-rights-related incidents involving consumers or end-users were reported. On customer experience, Axway expanded engagement (86 events, 15 Advisory Council meetings, 71 User Groups) and streamlined contracts, while SBS strengthened account-manager relationships and touchpoint surveys across the customer journey.

On financial inclusion, SBS partners with telecommunications operators to expand network coverage and deploys tailored digital solutions for underserved populations, alongside data-privacy safeguards and financial-literacy programmes. On digital accessibility, the Group is aligning with the European Accessibility Act (WCAG 2.1 AA compliance for new web/mobile applications launched after June 2025; full compliance for existing applications by June 2030), running independent RGAA audits ahead of customer delivery via three dedicated accessibility auditors trained in 2024, with ten more planned in 2026.

Reference: pages 144-145, 148, 150, 152.

Data and transaction security targets are structured by time horizon: short-term maintenance of ISO 27001/SOC 2 Type 2 certifications and 100% mandatory security-training completion; medium-term improvements to vulnerability remediation, incident response and the bug bounty programme; long-term alignment with evolving cybersecurity regulation. Customer experience is tracked via Net Promoter Score: Axway achieved +55 in 2025 (against a +53 target, with +56 set for the next cycle) and SBS achieved +38.2 (up from +7, with +42 targeted next), complemented by Axway's Customer Engagement Score.

Financial inclusion has "no formal, time-bound targets... yet defined," monitored instead through the number of microfinance institutions using Core Amplitude, customer-portfolio growth and geographic expansion. Digital accessibility targets a WCAG 2.0 Level AA standard for all Axway products by 2027 and a Group-wide ambition of full accessibility compliance across the product portfolio by 31 December 2030; in 2025, 24 UX/UI designers, 14 mobile developers, 105 web developers and 10 UI testers received accessibility training, with roughly 150 planned annually from 2026 to 2030.

Reference: page 154.

74Software's Code of Ethics sets principles for business conduct, anti-corruption, gifts and hospitality, conflicts of interest, data protection, intellectual property, fair competition and whistleblowing, endorsed by the Chairman of the Board and implemented by the Ethics Committee across all entities and, where relevant, partners and suppliers. The Code was shaped through stakeholder input - employee surveys, all-hands meetings and workers'-council consultation; customer NPS surveys and direct meetings; and supplier/partner engagement during contract negotiations.

Effectiveness is monitored through annual governance reviews and periodic audits; ethics training is mandatory for all employees, supported by the whistleblowing channel, internal audit risk-mapping, and a Gifts & Invitations declaration workflow. Anti-corruption and ethics expectations reach suppliers and partners through contractual clauses, onboarding sessions and dedicated supplier portals.

Reference: page 154.

Supplier management is governed by the Supplier & Partner Charter (validated by CEO Patrick Donovan) and the Code of Ethics, covering fair competition, transparency, confidentiality, intellectual property protection, payment terms, ESG criteria and anti-corruption, implemented by the Group Procurement Department with a dedicated ethics contact for suppliers and partners. 74Software addresses concentration risk with strategic suppliers, particularly public cloud providers, "by selecting alternative suppliers, defining contingency processes, and diversifying its vendor base," with Procurement maintaining and regularly updating contingency plans.

Supplier onboarding includes KYC, export-control, sanctions-screening and legal checks; periodic supplier audits generate corrective action plans where needed, and late payments are tracked. 74Software also states it uses its purchasing influence to encourage greener cloud infrastructure and more energy-efficient technologies among strategic technology partners.

Reference: page 155.

74Software applies a zero-tolerance approach to corruption and bribery anchored in its Code of Ethics, Gifts & Invitations Policy and Alert Procedure, aligned with ISO 37001:2016 and France's Waserman Act (Sapin II successor provisions). Internal Audit updates the corruption risk map annually; the Ethics Committee conducts independent investigations and reports to senior management, the Audit Committee and the Board. Mandatory anti-corruption training is provided to all employees, with enhanced focus on Finance and Sales as the only functions identified as high-risk.

Training reach fell from 261 employees in 2024 to 244 in 2025 (at-risk functions: 46 in 2024 versus 20 in 2025; managers: 83 versus 6; other employees: 178 versus 218), delivered online (Axway 25 minutes/SBS 26 minutes in 2025) once at onboarding. The Company states it "is assessing the introduction of formal performance targets to strengthen compliance."

Reference: pages 154-155 (back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement; G1-3 became a standalone DR only in the 2025/2026 ESRS).

74Software does not disclose a measurable, outcome-oriented business conduct target. Consistent with MDR-T, effectiveness is instead tracked in the absence of one: the G1-1 corporate-culture policy states its "effectiveness... is monitored through annual governance reviews and periodic audits," and mandatory anti-corruption training completion is tracked by function and year (G1-3, page 155 - 244 employees trained in 2025 across at-risk functions, managers and other employees, against 261 in 2024), with 74Software stating it "is assessing the introduction of formal performance targets to strengthen compliance."

No blanket MDR-T statement equivalent to Bavarian Nordic's "not all identified material IROs have associated targets" was located in the extracted text; the tracking mechanisms above are the only effectiveness-in-lieu-of-targets evidence found in the G1 chapter.

Reference: page 155.

74Software operates a whistleblowing procedure enabling any employee or external party to confidentially report, in good faith, suspected or actual breaches of anti-corruption law, ethical standards or internal procedures; reports go directly to the Ethics Committee for independent, impartial investigation, with confidentiality and anti-retaliation protection for whistleblowers and implicated individuals alike. Substantiated breaches can trigger disciplinary action up to dismissal and referral to authorities, under procedures the Company states are compliant with ISO 37001:2016 and French legislation including the Waserman Act.

"For the 2025 reporting period, no whistleblower alerts were received, whether or not they led to investigations and it has not been subject to any convictions or fines for anti-corruption or anti-bribery violations."

Reference: page 156.

74Software targets processing invoices within 60 days (or the local equivalent) where terms are not otherwise specified contractually, with close monitoring by the Finance Department and an enhanced validation procedure for individual suppliers; the Company states it "does not have specific payment practices concerning small and medium enterprises (SMEs)."

The average payment period per invoice fell from 46 days in 2024 to 40 days in 2025, and the share of invoices paid beyond 60 days fell from 12% to 10%. The full payment-terms distribution for 2025 was 47% within 0-30 days, 24% within 31-45 days, 19% within 46-60 days and 10% beyond 60 days (2024: 44%/25%/18%/12%). No outstanding legal proceedings relating to late payment were reported.