The Board of Directors and its Committees play a key role in corporate governance and the governance structure. The Group has established specialized committees including Board of Directors & Specialized Committees with Executive Management oversight. Risk management is embedded in the control environment with dedicated risk factors consideration.

Integration of sustainability-related performance in incentive schemes

Roles covered

Accor has integrated sustainability performance into the variable compensation of:

• Managers and some employees (established since 2022)
• All Talent (bonuses tied to sustainability goals)
• Executive Committee members (through monthly review of extra-financial performance)
• Headquarters employees and hotels Management (GM and HOD)

As stated in the report: "Tying part of all Talent's bonuses to sustainability goals and reviewing extra-financial performance monthly at the Executive Committee level reinforce the idea that sustainability is a driver of success."

Sustainability KPIs tied to remuneration

Climate and carbon reduction

For fiscal years 2023 and 2024, the Group set up share-based payment plans for some employees and managers, with performance criteria including:

• Carbon footprint reduction targets by the end of 2024
• The achievement of these criteria was considered when assessing the expenses relating to these plans

Revolving Credit Facility (RCF) indicator

One of the indicators linked to Accor's RCF relates to the diversity of management teams, demonstrating sustainability integration into strategic financing.

Water consumption baseline (2024)

The main objective for 2024 was to establish a robust baseline for water withdrawals, with importance demonstrated by its inclusion as a target in the Compensation Policy (as indicated in Section 3.1.3.1.9 "Compensation and benefits").

Climate Policy and governance

The Climate Policy was "published in December 2024, validated by the Chief Sustainability Officer and presented to the Climate Steering Committee."

As stated: "Embedding sustainability into performance metrics ensures that environmental and social factors are fully integrated into business operations."

Weighting and structure

The report does not disclose specific percentage weightings of STI or LTI tied to sustainability KPIs.

Performance period and targets

Share-based payment plans established for 2023 and 2024 fiscal years included carbon footprint reduction targets by the end of 2024.

The Group committed in 2020 to:

• Reduce CO2 emissions by 46.2% for Scopes 1 and 2 by 2030 (compared to 2019)
• Reduce CO2 emissions by 27.5% for Scope 3 by 2030 (compared to 2019)

Disclosure of payout against sustainability KPIs

The report states that "the achievement of these criteria was considered when assessing the expenses relating to these plans" for the 2023 and 2024 share-based payment plans, but does not provide specific payout figures or achievement rates for the reporting period.

The Group has established a control environment and risk factors framework (section 2). Risk management is integrated into the business model with identification and management of material risks.

Business Model and Strategy: A world-leading hospitality group, Accor offers stays and experiences in more than 110 countries with over 5,600 hotels & resorts and 10,000 bars & restaurants, as well as wellness facilities and flexible workspaces. With more than 45 brands ranging from luxury and lifestyle to economy, the Group operates one of the most diversified ecosystems in the industry.

Strategic Priorities: Accor's three strategic priorities aim to boost growth, increase profitability and make the Group a recognized driver of innovative and responsible hospitality:

1. DRIVE TRAFFIC by attracting, converting and fostering loyalty among guests, Talent and partners
2. ACCELERATE SUSTAINABLE GROWTH by allocating resources to ensure rapid and responsible growth
3. INNOVATE CONSTANTLY by putting in place favorable conditions with an asset-light model

Value Chain: The Group operates through two strategic divisions:

• Premium, Midscale & Economy division: 5,116 hotels and 723,145 rooms worldwide, including brands such as Pullman, Mövenpick, Swissôtel, Mercure, Novotel and ibis
• Luxury & Lifestyle division: 566 hotels and 127,140 rooms worldwide, organized around brands—Orient Express/Raffles and Fairmont/Sofitel, MGallery and Emblems/Ennismore

Stakeholder Engagement: Accor engages with each of the different stakeholders in its value chain, affirming a rapport based on exchange, dialogue and trust.

Key Stakeholder Groups:

• CUSTOMERS AND END USERS: Individuals, Companies, Work councils, Distributors, Hotel owners
• INTERNAL STAKEHOLDERS: Employees, Social partners, Brand managers, Board of Directors and Specialized Committees, Group Management Board, Executive Committees
• SUPPLIERS: Third-party providers, Subcontractors who must comply with the Group Responsible Procurement Charter
• FINANCIAL AND EXTRA-FINANCIAL STAKEHOLDERS: Shareholders, Investors, Banks and credit organizations, Financial rating agencies, Extra-financial rating agencies
• PUBLIC AUTHORITIES AND REGULATORY BODIES: Financial market authorities, States, Public authorities, Multilateral bodies and organizations, Local and regional authorities
• INDUSTRY ORGANIZATIONS: Associations, Coalitions and industry partners, Business networks and cross-functional economic networks, Professional associations
• CIVIL SOCIETY: Local communities, Residents' associations, Think-tanks, Research centers, Multilateral agencies, Schools and universities, NGOs and international organizations, Foundations, Opinion leaders: media, experts, Sponsors

Material Impacts and Opportunities: The Group has identified three societal trends driving the hospitality sector that inform its strategy:

1. The rise of international tourism: With more than a billion travelers in 2024, international tourism almost returned to pre-pandemic levels. This dynamism is driven by expansion of middle classes, rebound in business tourism, growth in leisure stays and surge in bleisure travel.

2. A desire for tailor-made experiences: Travelers aspire to rediscover charm and magic of travel, seeking new, authentic and memorable experiences with ultra-personalized stays.

3. The quest for ever more sustainable hotels: Protection of ecosystems, reduction of plastic waste and use of renewable energies are increasingly important to travelers, as are respect for local cultures and tourism and responsible consumption choices.

Integration with Strategy: These trends are integrated into the Group's strategic priorities and business model transformation from a generalist model to a multi-specialist one through its two divisions.

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

The excerpts provided indicate that IRO-1 content is located on pages 132-136, 143-144, 166, 169-170, 172, and 241. However, the specific methodology, step-by-step process, inputs, scoring criteria, thresholds, frequency, and value chain mapping details for the double materiality assessment are not included in the provided excerpts.

The document references indicate that:

• ESRS 2 IRO-1 is addressed on pages 132-136, 143-144, 166, 169-170, 172, 241
• Topic-specific IRO-1 disclosures are referenced for:
  • Climate change (E1): pages 143-144
  • Water and marine resources (E3): page 166
  • Biodiversity and ecosystems (E4): page 171
  • Resource use and circular economy (E5): page 172
  • Business conduct (G1): page 241

The excerpts confirm that Pollution (E2) is assessed as non-material for Accor.

Without access to the referenced pages containing the actual IRO-1 disclosure, the detailed double materiality assessment methodology cannot be extracted from the provided excerpts.

Climate Transition Plan: Accor is committed to planetary carbon neutrality by 2050. The defined trajectory includes an initial target to reduce its emissions by 46% out to 2030. The Group launched its first bond issue linked to sustainable development goals for an amount of €700 million in 2021.

Science-Based Targets: Accor is committed to reducing its Scope 1 and 2 greenhouse gas emissions by 46% and its Scope 3 emissions by 27.5% by 2030.

Policies related to climate change mitigation and adaptation

Climate Policy

Accor developed a Climate Policy in 2024 that presents its position on the climate challenge.

Approval and oversight:

• Validated by the Chief Sustainability Officer
• Presented to the Climate Steering Committee
• The Climate Steering Committee, under the aegis of the Sustainability Department, steers the deployment of the Policy

Scope:

• Covers all the Group's activities, i.e. scopes A, B and C, across all of Scopes 1, 2 and 3
• Scope A: Subsidiaries (sites owned or leased by Accor)
• Scope B: Managed (hotels under management contract)
• Scope C: Franchised (hotels under franchise contract)

Key content:

• Based on the double materiality analysis, specifically on the identification of risks, impacts and opportunities related to climate change
• Includes a description of the scope, a reminder of the objectives (the main one being to achieve the greenhouse gas emission reduction objectives) and commitments of Accor
• Presents the Group Policy in this area
• Concludes with an initial analysis of Accor's resilience to climate risks and describes the governance and commitments in relation to stakeholders

Main objective:

• To achieve the greenhouse gas emission reduction objectives: reduce Scope 1 and 2 emissions by 46.2% between 2019 and 2030, and reduce Scope 3.1, 3.3 and 3.14 emissions by 27.5% between 2019 and 2030

Public availability:

• The Climate Policy can be consulted on the Group website (published in December 2024)

Link to international standards:

• Aligned with the Paris Agreement goal of achieving global carbon neutrality by 2050 and limiting global warming to +1.5°C
• Commitment validated by the Science-Based Targets Initiative (SBTi) in 2020
• Accor is included in the EU Paris-Alignment Benchmark
• Member of the World Sustainable Hospitality Alliance (WSHA), Glasgow Declaration on Climate Action in Tourism (UN Tourism), Global Sustainable Tourism Council (GSTC), and Cornell Hotel Sustainability Benchmarking (CHSB) Index

Monitoring implementation:

• Climate-related criteria are included in both short-term and long-term variable compensation plans for members of the Executive Committee and hotel managers
• The Sustainability Department is responsible for reporting and measuring climate-related indicators and coordinates the Climate Steering Committee
• The Operations team collects data at the hotel level and deploys solutions made available to owners
• Carbon roadmaps validated at Climate Steering Committee and presented to Executive Committee

Actions and resources in relation to climate change policies

Supplier engagement and decarbonization program

Scope: Upstream value chain (nominated suppliers)

Description: More than 1,000 suppliers across five continents, representing 75% of the total volume of nominated purchases, participated through one-on-one meetings to:

• Present Accor's decarbonization program
• Assess suppliers' climate actions and carbon maturity using the ACME (Accor Carbon Maturity Evaluation) questionnaire
• Engage suppliers on an emissions reduction trajectory in line with Accor's objectives

Resources allocated (non-financial):

• All of the Group's buyers were mobilized
• Buyers' contribution to achieving climate objectives incorporated into their variable compensation
• Dedicated digital tool with real-time dashboard for monitoring suppliers' climate performance, allowing procurement community to access carbon reporting of nominated suppliers

Since June 2022: EcoVadis questionnaire strengthened with dedicated carbon module, enabling assessment of carbon performance of over 1,100 suppliers

Guest awareness and information initiatives

Scope: Downstream value chain (guests and corporate clients)

Actions:

1. Carbon impact information on restaurant menus

   • Procurement and Sustainability departments identified three service providers to assess carbon impact of recipes for hotels and chefs
   • Carbon impact indicated on menus to inform guests and guide them toward low-carbon meal choices

2. Carbon Tracker calculator for corporate clients

   • Developed by Accor teams
   • Accurately assesses impact of events or overnight stays
   • Incorporates carbon data from hotel reports and information on precise event components (meal type, customer origin)

Governance and organizational structure

Resources allocated (non-financial):

• ESG Committee: Ensures level of ambition of targets and monitors execution of sustainability strategy, particularly the climate roadmap
• Audit, Compliance & Risks Committee: Monitors process for preparing sustainability information
• Executive Committee: Defines strategy and means to achieve the Group's climate objectives
• Climate Steering Committee: Proposes roadmap for achieving climate objectives; steered by Environment team in Sustainability Department
  • Climate Steering Committee No. 13 on September 3, 2024 validated decarbonization roadmaps
  • Executive Committee meetings on November 8 and 28, 2024 reviewed roadmaps presented by Chief Sustainability Officer and CEOs
• Sustainability Department: Responsible for reporting and measuring climate-related indicators; coordinates Climate Steering Committee
• Operations team: Collects data at hotel level and deploys solutions to owners

Process: Carbon workshops enabled development of decarbonization roadmaps at entity level. ESG Committee approved transition plan publication.

Advocacy and industry partnerships

Scope: Industry-wide collaboration

Memberships and initiatives:

• World Sustainable Hospitality Alliance (WSHA) (joined 2021): Active member participating in working groups to review Hotel Carbon Measurement Initiative (HCMI) methodology on Scope 3 calculation
• Glasgow Declaration on Climate Action in Tourism (signed 2021): Commitment alongside 300 public and private tourism organizations to halve emissions by 2030 and contribute to global carbon neutrality by 2050
• Global Sustainable Tourism Council (GSTC) (joined August 2022): Benchmark organization for sustainability in hotel industry
• Cornell Hotel Sustainability Benchmarking (CHSB) Index: Advisory group providing international energy and carbon dataset, supporting development and dissemination of sustainability benchmarks
• Global Business Travel Association (GBTA) Board of Directors: Contributes to ESG standards and solutions in travel and tourism sectors
• WWF partnership: Science-based advocacy with World Wide Fund for Nature
• HARP (Hospitality Alliance for Responsible Procurement) (co-founded October 2023): Partnership with four global hotel groups (Marriott, Hilton, IHG, Radisson) and three procurement organizations (Avendra, Entegra, Foodbuy) to improve social and environmental performance of hospitality supply chain, with decarbonization defined as priority

Non-nominated procurement guidance

Scope: Own operations (hotels)

Action: Purchasing guide communicated to all hotels to assist in responsible procurement from compliant suppliers. Includes Responsible Procurement Charter describing risks and providing guidelines for supply chain control.

Targets related to climate change mitigation and adaptation

SBTi-validated Climate Targets

Target 1: Scope 1 and 2 GHG emissions reduction

• Metric: Absolute greenhouse gas emissions (Scopes 1 and 2)
• Target value: Reduce by 46.2% (market-based methodology)
• Target year: 2030
• Baseline year: 2019 (updated reference year)
• Baseline value: 3,306 ktCO2eq (Scopes 1 and 2 combined, SBTi scope)
• Scope: Own operations (Scope 1: direct emissions from stationary and mobile combustion sources, fugitive emissions from air conditioning; Scope 2: purchased electricity, urban heating and cooling networks)
• Type: Absolute reduction target
• Validation: Science-Based Targets initiative (SBTi) validated, aligned with +1.5°C trajectory
• Progress to date (2024):
  • Scope 1: 612 ktCO2eq (2024) vs 604 ktCO2eq (2019 baseline)
  • Scope 2 (market-based): 2,811 ktCO2eq (2024) vs 2,702 ktCO2eq (2019 baseline)
  • Total Scopes 1&2: 3,423 ktCO2eq (2024) vs 3,306 ktCO2eq (2019 baseline)
  • 2030 target: 1,776 ktCO2eq

Target 2: Scope 3 GHG emissions reduction

• Metric: Absolute greenhouse gas emissions (Scope 3.1, 3.3, and 3.14)
• Target value: Reduce by 27.5%
• Target year: 2030
• Baseline year: 2019 (updated reference year)
• Baseline value: 3,630 ktCO2eq (Scope 3.1, 3.3, 3.14 combined)
• Scope: Value chain emissions including:
  • 3.1: Purchases of goods and services (food & beverages, laundry, cleaning)
  • 3.3: Fuel and energy-related activities not in Scopes 1 & 2
  • 3.14: Hotels under franchise agreements (direct and indirect energy emissions)
• Type: Absolute reduction target
• Validation: Science-Based Targets initiative (SBTi) validated, aligned with +1.5°C trajectory
• Progress to date (2024):
  • Scope 3 (3.1, 3.3, 3.14): 3,868 ktCO2eq (2024) vs 3,630 ktCO2eq (2019 baseline)
  • 2030 target: 2,629 ktCO2eq

Target 3: Total SBTi scope emissions reduction

• Metric: Combined Scopes 1, 2, and 3 (3.1, 3.3, 3.14)
• Target value: Reduce by 36%
• Target year: 2030
• Baseline year: 2019
• Baseline value: 6,936 ktCO2eq
• Type: Absolute reduction target
• Validation: SBTi-validated
• Progress to date (2024): 7,291 ktCO2eq vs 6,936 ktCO2eq baseline; 2030 target: 4,406 ktCO2eq

Renewable Energy Target

Target 4: Low-carbon electricity supply for owned/leased hotels

• Metric: Percentage of electricity from low-carbon energy sources
• Target value: 80%
• Target year: 2025
• Scope: Owned and leased hotels (Scope A)
• Method: Via energy origin certificates

Food-Related Targets

Target 5: Vegetarian menu options

• Metric: Percentage of vegetarian options on menus
• Target value: 50%
• Target year: 2030
• Scope: Restaurants across hotel network (10,000+ bars and restaurants worldwide)

Target 6: Food waste reduction

• Metric: Food waste (absolute reduction)
• Target value: Reduce by 60%
• Target year: 2030
• Baseline year: 2023
• Scope: Hotels with restaurant operations (approximately 70% of portfolio, excluding hotels with no restaurant or minor offerings)
• Type: Absolute reduction
• Progress to date (2024): 862 hotels reduced food waste by at least 10% compared to 2023
• Note: Interim target of 10% reduction achieved in 2024; linked to €1 billion revolving credit facility sustainability criteria

Target 7: Responsible sourcing (coffee, tea, chocolate)

• Metric: 100% certified or verified sourcing
• Target value: 100% responsible
• Target year: 2030
• Certification: Rainforest or FairTrade certified; organic farming; or verified agroecological practices by recognized third party

Waste Targets

Target 8: Single-use plastics elimination

• Metric: Number of hotels compliant with single-use plastic elimination (66 guest experience products; 7 back office products)
• Scope: All Group hotels
• Progress to date (2024):
  • Guest experience: 88% of hotels compliant for 57+ products out of 66
  • Back office: 70% of hotels compliant for all 7 products

Water Target

Target 9: Water withdrawal reduction

• Metric: Water withdrawal reduction
• Target value: 45% reduction (based on SBTN desired states of Nature framework)
• Target year: 2030
• Scope: Hotel portfolio
• Note: Group will define future reduction targets in light of this reference framework

Financial Alignment

• Sustainability-Linked Bond issued November 2021 with coupons linked to GHG emission reduction targets
• Sustainability-linked RCF (€1 billion revolving credit facility, 2023) with sustainability criteria including:
  • Hotels measuring waste: increase from 800 (2023) to 3,900 (2030)
  • Food waste reduction: 60% reduction from 290g per cover (2023) to 116g per cover (2030)
• Carbon footprint reduction criterion included in long-term variable compensation for Chairman & CEO and top management

Energy consumption and mix

Total energy consumption and mix (2024)

Percentage breakdown (2024)

Scope and methodology:

• Scope covers all hotels under the Accor brand (scopes A, B, C), plus Other Activities and headquarters.
• Data for Momense energy breakdown not available; scope is immaterial (<0.5% of GHG emissions).
• Energy consumption based on reported data in GAIA 2.0 tool. In 2024, 79% of hotels transmitted consumption data; remaining consumption extrapolated.
• Electricity breakdown by origin (fossil/nuclear/renewable) based on data from https://ourworldindata.org/electricity-mix.
• Heat and cold networks: 90% attributed to fossil fuels based on IEA global data (https://www.iea.org/energy-system/buildings/district-heating).
• All renewable energy produced at Accor sites is non-fuel (mainly photovoltaic panels). Volume of self-generated renewable energy not tracked in 2024; will be included in 2025 reporting.
• Renewable energy certificates include bundled and unbundled instruments: Guarantees of Origin (GO), REGOs, RECs, I-RECs, TIGRs, GECs, LGCs, N-ZECs.
• Uncertainty about energy consumption of hotel portfolio: 0.49%.

Energy intensity:

No energy intensity per revenue disclosed under ESRS E1-7 (E1-5) requirements. The report states that "none of Accor's activities are considered to be in a sector with a high climate impact. Therefore, Accor does not present any related data."

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope and methodology

Reporting scope:

• Scope A (Subsidiaries): Sites owned or leased by Accor; full operational and financial control
• Scope B (Managed): Hotels under management contracts; partial operational control (OpEx influence only)
• Scope C (Franchised): Hotels under franchise agreements; no operational control but brand standards apply
• Full scope (A+B+C): All sites operating under the Accor brand

Organizational boundary: Operational control criterion applied. Accor does not have operational control over franchised hotels (Scope C) or hotels under management contracts (Scope B) for CapEx decisions.

Baseline year: 2019 (updated retrospectively in 2024 to account for changes in activity scope, reporting scope, and methodology)

Exclusions:

• Certain Other Activities (John Paul, Gekko, Lido, Onefinestay, Verychic, Our Habitas, Rikas) are excluded from 2024 reporting; gradual integration planned from 2025.
• Joint ventures and minority investments without management contracts are excluded except where noted.
• Category 3.15 Investments (Other Activities >50% owned) are outside SBTi commitment scope.
• Guest transport emissions (downstream Category 9 equivalent) not yet published; planned for 2026.

Scope 2 methodology: Market-based method used for SBTi targets; location-based also reported.

Scope 3 categories covered: 3.1 (Purchased goods and services, including F&B, laundry, cleaning), 3.2 (Capital goods), 3.3 (Fuel- and energy-related activities not in Scope 1 or 2), 3.4 (Upstream transportation), 3.5 (Waste), 3.6 (Business travel), 3.7 (Employee commuting), 3.14 (Franchises), 3.15 (Investments – Other Activities, outside SBTi scope).

Estimation and extrapolation: Energy-related emissions (Scopes 1, 2, 3.3, 3.14) use GAIA 2.0 data (79% of hotels reporting >75% of annual invoices in 2024); extrapolations applied where data incomplete. Non energy-related emissions (Scope 3.1 F&B, 3.5 waste, etc.) based on hotel surveys (54% response rate in 2024) and extrapolations.

Uncertainty: Acknowledged for emission factors (source variability), input data quality (third-party reliance), and Scope 3 breadth. Group applies GHG Protocol methodologies, sensitivity analyses, and normal distribution assumptions. Food waste data presents high uncertainty due to decentralized production and contextual factors.

2024 GHG emissions declaration (in ktCO₂eq)

Breakdown by organizational scope and GHG Protocol category (operational control)

Notes:

• "incl. 3.15" indicates emissions from Other Activities (Paris Society, D-Edge, Momense) consolidated via Category 3.15.
• SBTi scope excludes Category 3.2 (Capital goods), 3.4, 3.5, 3.6, 3.7, and 3.15.
• Categories 3.8–3.13 not applicable to Accor's business model.

2023 GHG emissions (in ktCO₂eq)

(Detailed category breakdown identical to 2024 table structure; figures shown are 2023 actuals.)

2019 baseline year (updated) GHG emissions (in ktCO₂eq)

Baseline year update notes:

• Reference year 2019 updated retrospectively in 2024 to reflect: (i) scope changes (546 hotels removed, 328 pre-2019 hotels added), (ii) reporting scope additions (fugitive emissions in Scope 1; Category 3.15 for Other Activities), (iii) methodological changes (GAIA 2.0 deployment, shift from spend-based to activity-based Scope 3).
• Updated 2019 total for SBTi scope: 6,936 ktCO₂eq (previously declared 6,726 ktCO₂eq in original SBTi submission).
• Impact of updates: Activity scope (–204 ktCO₂eq), Reporting scope (–214 ktCO₂eq), Methodology (+628 ktCO₂eq).

GHG intensity

Not explicitly disclosed in tabular form. The report notes:

• Average Accor hotel consumes 281 kWh/m² of energy and ~500 liters of water per occupied room (2024 estimate).
• Energy intensity reduced by 4% (kWh/m²) in 2024 vs. 2023.
• Intensity metrics per revenue or per room-night not provided for GHG emissions.

Biogenic CO₂ emissions

Not disclosed.

Regulated emissions (EU ETS or similar)

Not disclosed.

Total GHG emissions summary

Note: 2024 and 2023 figures are identical in the summary tables provided; detailed category-level data for 2024 not separately tabulated in excerpts. SBTi scope excludes Categories 3.2, 3.4, 3.5, 3.6, 3.7, and 3.15.

Change vs. baseline (2024 vs. 2019)

Notes:

• Actual performance diverges from 2024 targets (Scope 1+2: –21%, Scope 3: –12.6%).
• Growth in hotel portfolio (surface area) contributed +3,337 ktCO₂eq projected for 2030 trajectory modeling.
• Report attributes variance to growth in portfolio and activity; decarbonization levers not yet fully deployed.

Methodology notes

Emission factors:

• Energy: Country-specific grid factors for location-based; supplier-specific or residual mix for market-based.
• Scope 3.3: Upstream energy losses and infrastructure emissions per WSHA/HCMI methodology.
• F&B (3.1): Meal-type emission factors (e.g. vegan 1.66 kgCO₂eq/meal, red meat 6.57 kgCO₂eq/meal, average 2.85–3.14 kgCO₂eq/meal for 2023).
• Laundry, cleaning: Activity-based factors per kg washed or service unit.
• Refrigerants: GWP of specific gases (fugitive emissions).

Data collection:

• GAIA 2.0 tool (Schneider Electric Resource Advisor) used for energy data (Scopes 1, 2, 3.3, 3.14 energy components); 79% of hotels reported >75% of invoices in 2024; 93% adopted tool by end-2024.
• Non-energy Scope 3: Hotel-level survey (54% response rate 2024); extrapolations based on statistical methods (normal distribution, law of large numbers).
• Scope C (franchised): Encouraged but not mandated to use GAIA 2.0; extrapolations applied.

Consolidation: Operational control approach. Accor does not control franchised hotels (Scope C) or CapEx at managed hotels (Scope B), but influences OpEx via management contracts and brand standards.

Exclusions and phase-in:

• Certain Other Activities (John Paul, Gekko, Lido, Onefinestay, Verychic, Our Habitas, Rikas) excluded in 2024; gradual integration from 2025.
• Guest transport (downstream Category 9 equivalent) not yet calculated; planned publication 2026.
• Categories 3.8–3.13 not applicable.

Uncertainty:

• Acknowledged for emission factors, input data quality (third-party reliance, incomplete invoices), and Scope 3 breadth.
• Extrapolations sized to limit uncertainty; sensitivity analyses applied per GHG Protocol guidance.
• Food waste and F&B data subject to high contextual variability (decentralized kitchens, guest behavior).

Alignment:

• GHG Protocol Corporate Accounting and Reporting Standard (January 2025 revised edition).
• SBTi Corporate Net-Zero Standard Criteria.
• WSHA Hotel Carbon Measurement Initiative (HCMI) methodology for Scope 3 laundry outsourcing.

Baseline recalculation:

• 2019 baseline updated in 2024 per GHG Protocol Appendix E to reflect structural changes (hotels added/removed), reporting scope additions (fugitive emissions, Category 3.15), and methodology improvements (GAIA 2.0, activity-based Scope 3).
• Recalculated baseline submitted to SBTi during 2025 (not yet validated as of report date).

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

Phase-in Exemption

Accor uses the phase-in exemption allowed for the first 3 reporting years for ESRS E1-9.

As stated in the ESRS disclosure table on page 246:

E1-9 – Anticipated financial effects from material physical and transition risks and potential climate-related opportunities: Page 165 - Omitted in 2024 due to phase-in provisions

Forward-Looking Statement on Scenario Analysis

As mentioned in the excerpts, Accor states:

"Climate risk is identified as a major issue in the Group's risk analysis. As mentioned in Chapter 2 'Control environment and risk factors', a scenario analysis in accordance with the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD) will be conducted during 2025. This analysis will enable a more detailed assessment of the physical and transition risks, as well as their impact on the Group's activities in the short, medium and long term."

Qualitative Assessment of Material Risks and Opportunities

While quantified financial effects are not disclosed for 2024, the double materiality analysis process identified material climate-related risks and opportunities based on previous studies (TCFD 2022, AXA Altitude 2023 physical risk analysis):

Physical Risk:

• Risk linked to an increase in weather hazards that could cause damage to the sites, an inability to ensure business continuity in the affected areas or a decline in the attractiveness of these sites for customers
• Supported by AXA Altitude study results showing that a significant proportion of the Group's hotels could be highly exposed to risks of extreme heat, flooding or landslides
• Probability of occurrence assessed as high and increasing over time
• Estimated financial cost would be significant, although it would not fall directly to Accor, but to the owners of the sites concerned, due to the Group's asset-light model

Transition Risk:

• Risk linked to the evolution of business travel by air and its potential substitution
• Supported by 2022 TCFD analysis revealing that a significant share of the Group's revenues could be exposed to a decline in business travel by 2030
• Risk particularly high for hotels located near airports or not accessible by alternative modes of transport such as train
• Scale and likelihood of this risk assessed as higher over the long term: constraints on air traffic and decrease in air travel could increase over time

Climate-Related Opportunity:

• By improving carbon performance of hotels compared to competitors, the Group could gain market share
• By adapting development strategy to climate considerations, the Group's revenues could grow
• The 2022 TCFD analysis showed that business travelers are increasingly focusing on hotel carbon data, with revenue growth projected for the most sustainable hotels

CapEx/OpEx Implications and Control Model

Accor's asset-light model significantly impacts its control over capital and operational expenditure:

Scope A: Accor has operational control. The Group decides on OpEx and CapEx for sites it owns and operates.

Scope B: Accor has operational control but no control over capital expenditure (CapEx). In cases where Accor manages the hotel under a hotel management contract, the Group proposes a budget (OpEx) to the owner. The approval of the budget is the responsibility of the owner. Once the budget has been approved, Accor ensures it is implemented on behalf of the owner.

Scope C: Accor has no direct or operational or financial control. Thus, in the case of a site under a franchise contract, Accor has no control over the OpEx or CapEx.

Full scope: A + B + C.

Policies related to pollution

Accor has assessed pollution (ESRS E2) as non-material. According to the disclosure index, ESRS E2-3 (Targets related to pollution) is explicitly marked as "Non-material for Accor".

No specific policies related to pollution under ESRS E2-1 are disclosed in the provided excerpts. The company's materiality assessment determined that pollution-related impacts, risks and opportunities do not meet the threshold for detailed disclosure under this standard.

Pollution of air, water and soil

Accor has assessed E2-4 (Pollution of air, water and soil) as non-material.

According to the cross-reference table, ESRS E2-4 regarding the amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil (paragraph 28) is indicated as non-material.

No quantified emissions data to air (NOx, SOx, SO2, PM, VOC, heavy metals), water (heavy metals, nutrients, BOD/COD), or soil (heavy metals, microplastics) are disclosed in the provided excerpts.

Anticipated financial effects from pollution-related impacts, risks and opportunities

E2-6 is listed in the disclosure index for ESRS E2 Pollution but no specific content or page reference is provided for this disclosure requirement in the excerpts. The disclosure index indicates that E2-3 (Targets related to pollution) is assessed as non-material for Accor, but does not explicitly state whether E2-6 is omitted, non-material, or disclosed elsewhere in the document.

Policies related to water and marine resources

Water Policy

Accor has implemented a Water Policy that emphasizes the importance of responsible water management in its own operations and its value chain.

Key content and principles:

• Outlines approaches to reduce water withdrawals through both global and local commitments
• Highlights the challenges posed by the water crisis and related to climate change
• Details Accor's footprint and its dependence on water resources, in its hotel operations and across the food value chain
• Outlines Accor's commitments to sustainable water management
• Includes the identification of priority river basins based on hotel water withdrawals and water stress through a global analysis conducted in 2024
• Accor's commitment to limit the impact of chemicals in wastewater by controlling the use of detergents, pesticides, and other cleaning products in its hotels
• Raising the awareness of hotel staff about the main points of water consumption through an operational guide on water efficiency and various protocols (maintenance and cleaning, irrigation, etc.)
• Implementation of a program to raise guest awareness of sustainable water consumption via the "Skip the Clean" program for guests staying more than one night

Scope:

• Covers the entire Group hotel portfolio
• Designed to address issues specific to water withdrawals generated in the hospitality sector
• Restaurant activities are covered in more detail in the Sustainable Food Policy (water footprint of restaurant activities is mainly attributed to the upstream value chain through the procurement of food)
• Other Activities operating in the restaurant sector (Momense, Paris Society) will be taken into account in the Sustainable Food Policy when it is revised in 2025
• Other Activities operating in the service sector (D-Edge) and the headquarters account for a negligible share of water withdrawals and are not included in the Group's Water Policy

Approval and oversight:

• Reviewed and approved by the Sustainability Leaders of each region and brand
• Shared with the members of the Water Steering Committee
• Approved by Accor's Chief Sustainability Officer

Public availability:

• Accessible to all Group employees on the intranet
• Can be viewed on the Group's website
• Communicated by email to the Sustainability Leaders of the regions and brands in February 2024, who are responsible for relaying it to General Managers

Timeline:

• Published in 2023 and updated in 2024

Linkage to international standards:

• Based on external benchmarks such as the Taskforce on Nature-Related Financial Disclosures (TNFD) and the Science Based Targets Network (SBTN)
• Based on international initiatives such as CDP Water or the CEO Water Mandate of the United Nations
• Aims to meet the UN's sustainable development goals related to water (SDG 6 – Ensure availability and sustainable management of water and sanitation for all)

Monitoring implementation:

• Application of the Water Policy is regularly discussed with the network of Sustainability Leaders in each region and brand
• Monitoring through large collection of water-related data such as the level of deployment of technical standards, irrigation practices, swimming pool management methods, etc.
• Implementation of variable compensation criteria (STIP) related to the input of water consumption data in GAIA 2.0
• Monthly reporting by each hotel using the GAIA 2.0 tool
• Planned monitoring of the deployment of technical standards related to water flow to assess the application of the water policy

CEO Water Mandate

At the 2024 ChangeNow Summit, Accor's Chairman and CEO, Sébastien Bazin, announced the signing of the CEO Water Mandate, an initiative created by the United Nations that gathers 256 committed companies on water issues.

Key content and principles:

By joining this coalition, Accor commits to continual progress along six areas of water stewardship:

• Direct operations
• Supply chain & watershed
• Collective action
• Public policy
• Community engagement
• Transparency

Water Stewardship: Accor Chairman and CEO, Sébastien Bazin announced the signing of the CEO Water Mandate, an initiative created by the United Nations that gathers 256 committed companies on water issues. By joining this coalition, Accor commits to continual progress along six areas of water stewardship: direct operations, supply chain & watershed, collective action, public policy, community engagement and transparency.

Water Consumption: 62 million m3 of water withdrawn (Owned and leased sites and management hotels). On average, an Accor hotel consumes ~500 liters of water per occupied room. 78% of branded hotels have established their water consumption baseline.

Anticipated financial effects from material water and marine resources-related impacts, risks and opportunities

This disclosure requirement has been omitted in 2024 due to phase-in provisions under CSRD.

No quantified anticipated financial effects, methodology, or other substantive information is provided for this disclosure requirement in the 2024 reporting period.

Biodiversity Policies: Accor supports the Kunming-Montreal Global Biodiversity Framework, signed in December 2022, and is actively working to define science-based targets for nature. Protecting natural ecosystems and biodiversity is crucial for the resilience and appeal of destinations, especially in the face of climate change.

Ocean Conservation: As part of its commitment to ocean conservation, and in partnership with the World Wide Fund for Nature (WWF), Accor's Novotel brand is taking steps to reduce its direct impact and support innovations that protect marine biodiversity.

Biodiversity Actions: In June, Novotel announced a three-year partnership with the World Wide Fund for Nature (WWF). Under the agreement, from 2024 to 2027, WWF France will provide technical expertise to Novotel, helping its 580 hotels worldwide to have a positive impact on the ocean. Novotel will build a three-year science-based action plan, rooted in three of the United Nations' priority ocean-related actions and sponsor several critical WWF ocean-related conservation projects across the world.

Policies related to resource use and circular economy

Circular Economy Policy

Overview and scope: The Circular Economy Policy was shared on Accor's intranet (Accor Live) in November 2024 and published on the accor.com website in December 2024. The Policy is currently applicable to headquarters and owned and leased, managed and franchised sites. It will be extended to the Group's Other Activities in 2026.

Given Accor's asset-light business model based mainly on management and franchise arrangements and little on ownership of premises, the Policy focuses primarily on hotels' restaurant and accommodation activities. Issues relating to construction and renovation of sites will be incorporated in a second phase.

Key content and principles: The Policy emphasizes the importance of responsible management of resources both in Accor's own activities and across its entire value chain, and aims to foster collective momentum around the subject. The entire product life cycle is taken into consideration through reflections focused on the 5Rs principle: "Refuse, Reduce, Reuse, Repair, Recycle".

The Circular Economy Policy highlights the major challenges around resource consumption (gradual exceeding of planetary boundaries, United Nations Sustainable Development Goals) and identifies two negative impacts of Accor's activity:

• Intensive consumption of resources in the upstream value chain for site construction and maintenance
• Poor on-site or off-site waste management resulting in over-consumption of resources and environmental damage

Specific commitments:

• Decrease in the use of primary raw materials: Highlighting the importance of reducing the impact of operations on the entire product life cycle and consumption of virgin natural resources. This relies on a review of internal processes to be deployed within hotels (reduction of single-use plastics, reduction of food waste, intensification of product use, waste management, increased recycling) as well as a (re)definition of standards (technical, brand, etc.) to fully integrate the circular economy. These commitments also include the involvement and accountability of suppliers through integration of sustainability criteria in calls for tenders or commitments by suppliers to improve product traceability.

• Sustainable supply of products and materials: Specifying in particular the commitment to eco-label the entire hotel portfolio by 2026. This will ensure that most of the products used through hotels' operations are labeled and/or sourced sustainably.

• Inclusion of more environmental criteria in calls for tenders: Through mobilization of the Accor Procurement Department. Through the Group's Responsible Procurement Charter, signed by all nominated suppliers, they have undertaken to adopt ambitious policies to reduce their environmental footprint.

Waste management priorities: With regard to waste management, the Group aims (in order of priority) to:

• Reduce the volume of waste produced
• Improve sorting practices
• Increase reuse and recycling rates for waste that cannot be avoided

The Group's priorities in terms of waste management concern:

• Rethinking the way hotels are operated and systematizing circularity (including promotion of recycling) in operations while improving the guest experience
• Promoting innovation throughout the value chain by systematically including the consideration of environmental and eco-design criteria by suppliers

Governance: The Policy has been validated by the Group Chief Sustainability Officer. The Environment team of the Sustainability Department works with other departments such as Marketing, Procurement, and Design & Technical Services to define and propose circular products.

Accessibility: The Policy is accessible to all Group employees on the intranet and can be consulted directly by external stakeholders on the Group website.

Link to international standards: The Policy references United Nations Sustainable Development Goals and highlights the gradual exceeding of planetary boundaries.

Monitoring: The Policy sets out the governance put in place by Accor to steer its actions in this domain, both at Group and local level, as well as the frameworks and initiatives in which it is involved. Progress on waste management is monitored via monthly reporting in the GAIA 2.0 tool.

Responsible Procurement Charter

Overview and scope: The Responsible Procurement Charter is signed by all nominated suppliers.

Key content: Through the Charter, nominated suppliers have undertaken to adopt ambitious policies to reduce their environmental footprint. The Charter sets out the following main objectives:

• Significantly reduce carbon emissions
• Promote the use of certified and sustainable materials
• Preserve water resources
• Limit polluting and environmental emissions
• Protect biodiversity
• Reduce waste and eliminate single-use plastic products

Monitoring: The signing of the Responsible Procurement Charter by nominated suppliers constitutes a contractual obligation of the control plan developed by the Procurement Department. It lists all the Group's requirements in terms of social, environmental and ethical objectives with which the nominated supplier must comply.

Technical Standards (Design & Technical Services)

Overview and scope: The Design & Technical Services (D&TS) Department ensures the implementation of technical standards for the construction and renovation of hotels.

Key content: Accor's technical standards incorporate in particular standards related to:

• Implementation of infrastructures for the management of waste and recycling, such as appropriate storage areas within each new hotel
• Alignment with best practices in building design to reduce waste production

Implementation: During a construction or renovation project, the owner may call on the services of the D&TS Department and sign a technical assistance contract. The D&TS project manager then ensures that these standards are implemented. If the owner does not call on the D&TS Department for support during the performance of its works, the technical standards are subsequently communicated during the contractual phase and the owner must comply with them.

Limitations: Accor does not control the effective implementation of these technical standards. In the coming years, Accor plans to look at implementing a global monitoring plan around the management of resources and waste during construction to steer and measure results at Group level.

Sustainable Food Policy (2024)

Overview: To follow up on the Healthy and Sustainable Food Charter, in 2024 Accor adopted a Sustainable Food Policy comprising seven commitments monitored at regional and hotel level.

Governance: Each region and brand has formulated a specific roadmap that is steered by dedicated Operational Committees.

Key commitments: Accor is committed to promoting and offering healthy and responsible food in its restaurants, which translates to:

• Procurement of sustainable products, including organically farmed foods
• Banning endangered fish species from menus

These commitments are followed by the Group's hotels and restaurants.

Targets related to circular economy

Food Waste Reduction Target

Target metric: Food waste reduction

Target value: 60% reduction

Baseline measurement: 283 grams per cover (validated across 2,340 hotels by end of 2024)

Target year: 2030

Scope: Hotels with restaurant offering (excluding hotel F1, ibis Budget and Adagio as they do not have a restaurant offering). Portfolio at 12/31/2024: 4,677 hotels.

Type: Intensity-based (grams per cover)

Validation: Higher than the overall food waste reduction target in France for commercial catering (which is 50% between 2015 and 2030). No mention of external validation (e.g., SBTi).

Baseline establishment progress:

• Annual target: 40% of hotels with a baseline measurement (1,871 hotels)
• Result at 12/31/2024: 2,340 hotels with defined baseline measurement
• Baseline measurements validated only within range of 10 grams per cover to 2,500 grams per cover
• Scope expanded from 862 hotels to more than 2,300 sites in 2024

Progress to date (2024):

• 837 hotels monitored for food waste reduction during 2024 (following closure of certain restaurants from the original 862 hotels with 2023 baseline)
• Hotels implemented local action plans including replacing buffets with "à la carte" services, changing menus and recipes, and adapting quantities produced
• Food waste data regularly measured and input into GAIA 2.0 environmental reporting tool
• Estimated reduction in food waste in 2024 compared to baseline measurement reported (specific percentage not disclosed in excerpt)

Eco-certification Target

Target metric: All hotels obtaining eco-certification (Green Key and Green Globe eco-labels)

Target year: End of 2026

Scope: All Accor hotels

Note: These eco-labels include criteria relating to construction, renovation, and material resources. Audits required for certification.

Material resources note: Due to Accor's asset-light business model, construction and renovation of hotels does not come under the Group's direct responsibility. The Design & Technical Services Department has developed technical standards including environmental criteria such as eco-design, though these have not been subject to specific controls to date.

ESRS E5-4 Resource Inflows

Overview

Accor's resource inflow disclosure focuses on the hotel portfolio and headquarters, distinguishing between resources related to construction/renovation and hotel operations.

Construction and Renovation Resources

The main materials used for construction and renovation of hotels are:

• Concrete
• Wood
• Steel
• Stone
• Brick

Due to Accor's asset-light business model, construction and renovation does not come under the Group's direct responsibility. The Design & Technical Services Department has developed technical standards for building construction and renovation that include environmental criteria such as eco-design, though these have not been subject to specific controls to date.

Operational Resources

The main purchases in respect of hotel operations concern:

• Layout of rooms and common areas (furniture, household linen, electronic equipment) and associated packaging
• Consumer goods related to guest reception (food and beverages, hygiene products) and associated packaging
• Consumer goods related to room cleaning (cleaning products) and associated packaging

Total Weight of Resources

Accor's 2024 assessment of total weight of products used was based on carbon reporting of "Capital Goods" categories through a survey of hotels covering furniture, food products, household linen, and electronic equipment.

Data methodology: Data derived from extrapolations based on information reported by hotels (all brands and geographical locations), the Sequana Corporate headquarters, D-Edge, Momense and Paris Society. Only the following flows are considered for the hotel scope and headquarters: plastic, paper, cardboard, glass, food waste, used cooking oils and fats, and residual waste. Household linen was extrapolated differently - carbon reporting focuses on weight of laundry washed over a year, while figures presented relate to weight of laundry purchased over the year.

Product Categories Covered

The main product categories included in the assessment:

• Food products: representing a significant portion of operational purchases
• Furniture: bedroom and office furniture
• Household linen: sheets and towels (may be composed of cotton, recycled cotton, polyester, etc.)
• Electronic equipment: screens, computers, and other IT equipment

Other Activities

The Group's Other Activities (Momense, Paris Society) use similar resources to hotels for their Food and Beverage activities. Accor's headquarters mainly purchase electronic equipment, interior fittings, food for company restaurants, and consumables such as paper. Some products (printers, company cars) are leased long-term.

Data Limitations

Accor acknowledges that information on materials used in the supply chain is not yet fully available, including:

• Total weight by material type
• Proportion of sustainable organic materials
• Proportion of components recycled or reused

The Procurement Department is currently exploring different ways of structuring this data collection in the coming years, potentially through new approaches to suppliers and changes to contract and tender monitoring tools.

Waste Generation: 220K tonnes of waste generated (Owned and leased sites and management hotels).

Food Waste Reduction: Accor is committed to decreasing its food waste by 60% by 2030, relative to 2023. 2,340 branded hotels have defined their food waste baseline, of which 380 pioneers use artificial intelligence to measure and reduce their food waste. In 2024, 862 hotels reduced their food waste by at least 10% compared to 2023.

Food Waste Prevention: In 2024, a partnership with Too Good To Go enabled the prevention of over 810 tonnes of CO2 by saving and redistributing more than 300,000 food packages from 1,050 hotels worldwide.

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

Phase-in exemption applied

E5-6 – Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities: Omitted in 2024 due to phase-in provisions.

Waste

Waste generation and management approach

Waste management is a key priority for Accor under its Circular Economy Policy. The Group aims to reduce the volume of waste produced, improve sorting practices, and increase reuse and recycling rates for waste that cannot be avoided.

Accor's technical standards incorporate standards related to the implementation of infrastructures for waste management and recycling, such as appropriate storage areas within each new hotel. These technical standards are aligned with best practices in building design to reduce waste production.

Quantitative waste data

The following table presents Accor's waste generation data:

Waste measurement and reporting

Waste data is estimated based on a survey carried out at all sites in Scopes A, B and C. The methodological details are presented in the appendices and are linked to the methodology presented for determining Scope 3 carbon emissions.

As part of its Revolving Credit Facility (RCF) commitments, the Group has set a target that the number of hotels measuring their waste must increase from 800 in 2023 to 3,900 in 2030.

Scope and methodology

Information relating to waste production is estimated based on a survey carried out at all sites in Scopes A, B and C (owned and leased sites, management hotels, and franchise hotels). The extrapolation methodology, including the assumptions used, is detailed in Section 3.1.2.4.

Circular economy priorities

The Group's priorities in waste management concern:

• Rethinking the way hotels are operated and systematizing circularity (including the promotion of recycling) in operations while improving the guest experience
• Promoting innovation throughout the value chain by systematically including environmental and eco-design criteria by suppliers

Single-use plastic elimination

Accor has an action plan to reduce single-use plastic, launched in 2020, to limit both resource consumption and waste generated by hotel operations. As of 2024, 88% of branded hotels have eliminated at least 57 single-use plastic items.

Own Workforce Policies: Accor's values are based on its Purpose: 'Pioneering the art of responsible hospitality, connecting cultures, with heartfelt care.' Accor cultivates a curious, open-minded and authentic environment, making sure that everyone can come as they are and feel part of the Heartist® community.

Human Rights Policy: The Group has a global Diversity, Equity and Inclusion approach and Human Rights Policy. Accor is profoundly inclusive, leading the way for more DEI in the hospitality sector and in society.

Gender Equality: The Group has initiatives including RiiSE, a gender diversity network fully committed to promoting gender equality & diversity, eliminating all forms of discrimination and harassment, and empowering women within the company. Accor enshrined its first Gender Equality at Work Charter in 1970.

Talent Development: The Group is committed to supporting its Heartists® grow and give them the spark to thrive, so they can find meaning and enjoyment in their work. Accor empowers growth and develops Talent knowledge, skills, and capabilities to drive better performance and leadership.

Learning & Development: Through the Accor Academy, Heartists® can upskill and acquire new knowledge through robust training opportunities across various skills and expertise. The Accor Academy includes development programs designed for Heartists® in hotels who have not benefited from higher education through the Reveal Talent program.

Employee Characteristics: 360,000+ Talent under the Accor brand, with more than 300 professions. 110,590 new hires in 2024 (Owned and leased sites and management hotels). More than 120 nationalities represented in the workforce.

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

Disclosure Status

Accor has omitted the disclosure of ESRS S1-7 (Characteristics of non-employees in the undertaking's own workforce) in 2024 due to phase-in provisions.

This is explicitly stated in the ESRS Index table:

Contextual Information on Workforce Categories

While quantitative metrics for non-employees are not disclosed under S1-7, Accor provides contextual information about its workforce structure:

Non-employee workers are mentioned in Accor's scope definitions. The company states: "Non-employee workers are all other workers associated with Accor and not considered employees. They include, for example, temporary workers or self-employed workers. Whenever this population is covered by Accor's commitments, it will be explicitly specified."

Workers under the Accor brand is defined as encompassing "all the above-mentioned groups, including employees under the Accor brand and non-employee workers associated with Accor."

Exclusion noted: Accor explicitly excludes "extras" from consolidated reporting. These are "non-permanent employees with employment contracts lasting only a few hours or consecutive days." The company states: "Accor does not yet have the ability to include this population in the presentation of the consolidated information required in the related section (scopes A and B). However, certain Accor policies and commitments may apply to this population, as they are integrated into the workers under the Accor brand."

Suppliers and Third-Party Providers

The excerpts reference suppliers, subcontractors, and third-party providers working on behalf of the Group, but these are described in the context of supply chain management rather than as part of the own workforce for S1-7 purposes.

Collective bargaining coverage and social dialogue

Collective bargaining coverage

In 2024, the following percentages of employees were covered by collective agreements:

No breakdown by EEA vs non-EEA or overall percentage across all employee categories is disclosed.

Social dialogue arrangements

European Works Council

Accor has established a European Works Council (EWC), co-chaired with the IUF (International Union of Food, Agriculture, Hospitality, Tobacco and Allied Workers). The EWC:

• Meets at least twice a year
• Was established in 1996 by a memorandum of agreements
• Deals with the Group's organization, strategy and results, as well as subjects of a transnational nature
• Receives annual presentations on the HR Policy and progress of its deployment
• Was consulted during the development of the Human Rights Policy

Employee representative bodies

Accor has employee representative structures including:

• Works Council in France
• European Works Council at Group level
• Two directors representing employees on the Board of Directors
• Employee representative bodies at local level in compliance with national laws

Employee representative bodies are regularly informed or consulted when organizational, strategic or technological changes have a significant impact on employees.

Trade union engagement

Accor collaborates with the IUF through a comprehensive framework agreement on trade union rights. This agreement:

• Confirms the Group's commitment to preserving employees' rights and freedom to organize and participate in union activities
• Is currently being renegotiated (as of 2024)
• Will result in an amended version in 2025 reaffirming principles of trade union non-discrimination

An agreement on trade union non-discrimination was signed in 2024 in France, covering both male and female employees worldwide, reiterating the concept of non-discrimination in professional development and prospects of employees with a staff representative mandate.

Direct dialogue mechanisms

• Information sessions (townhalls) with management, held every three months, including Q&A sessions
• Periodic engagement surveys to assess employee opinions on working conditions, compensation and diversity
• Local initiatives including newsletters, intranet, and internal social network
• Diversity, Equity and Inclusion Champions community established in 2016
• Dedicated Diversity, Equity and Inclusion email address accessible to all employees

Governance

The Policy and progress of deployment are presented annually to the European Works Council. The Chairman and CEO and a representative of the IUF co-chair the European Works Council.

Diversity Metrics: More than 42% women on the Management Committees worldwide and 39% in positions of high responsibility (in a role equivalent to or higher than Vice President). More than 120 nationalities represented across the Group.

Adequate wages

Benchmark Used

Accor explicitly states it has not yet implemented a living wage benchmark. The company acknowledges: "Accor is aware that its Compensation Policy does not specifically cover the themes of adequate wages and social protection" and "Accor has not yet set out a definition of an adequate wage for its activities."

For 2024 reporting, Accor considers adequate wages to be "wages that comply with the legal and regulatory minimum levels or, where applicable, the living wage published by the Wage Indicator Foundation" (database recognized by the IDH Sustainable Trade Initiative). However, the company primarily compared fixed compensation to "the applicable minimum wage set by law."

Accor states: "the Group has chosen to refer to the regulatory minimal levels for now" and plans to "carry out discussions on the concept of an adequate wage, which it currently deems equivalent to regulatory minimum levels (legal and contractual)."

Coverage and Results

The September 30, 2024 survey revealed that 100% of assessed employees received a wage at or above the applicable benchmarks (primarily legal minimum wage).

This includes:

• Scope A: 100% of Accor headquarters employees and General Managers of leased sites received adequate wages
• Scope B: 100% of General Managers employed by owners of managed sites received adequate wages

Geographic Scope and Significant Exclusions

The assessment covered 41 countries for Scope A and 54 countries for Scope B. However, the scope is severely limited:

Included:

• Permanent employees (or fixed-term contracts >2 years) at headquarters
• General Managers (GM) and Heads of Department (HOD) at owned, leased, and managed hotels
• Represents less than 5% of total workforce

Explicitly Excluded:

• All hotel and restaurant operational employees (except GMs)
• Fixed-term contract employees <2 years
• "Extra" contracts for hospitality workers
• Employees of managed sites below GM level (63.6% of total employees)

Accor acknowledges: "the limited scope of the study excludes the most vulnerable populations, such as temporary employees and those in first-level positions at the sites, who are more exposed to the risk of low wages and precariousness."

The headquarters employees represent only 3% of total workforce (Scopes A and B combined) but comprised 80% of the survey results.

Targets and Commitments

Living Wage Commitment: Accor commits to define a living wage methodology but has not yet set specific targets. The company states: "Accor has not yet defined specific targets for adequate wages and social protection but plans to do so in the coming years."

Timeline commitments:

• 2025: Will "carry out discussions on the concept of an adequate wage" and "may adjust its Compensation Policy, in particular when international clarifications are made on the methodology to be adopted"
• 2025: Extend scope to include all leased and owned site employees (hospitality professions)
• 2025: Include fixed-term contract headquarters employees
• Future: "Accor undertakes to follow the future recommendations of the International Labour Organization (ILO) concerning a method for calculating an adequate wage that would be common to all organizations"
• If ILO recommendations not formalized by end of 2025, Accor will "consult the Talent & Culture teams in each region to define internally what an adequate wage should be"

Stated objective: "improve the quality of life of its employees by increasing the number of those who receive an adequate wage" with 2024 as reference year, ensuring results "do not deteriorate thereafter."

Methodology Details

Current Approach:

• Compares target "cash compensation" (base salary + target variable) to market median (80-120% range)
• Annual compensation surveys in 30 countries (multi-sectoral and hospitality-specific)
• Comparison to legal minimum wage as primary benchmark
• For EEA countries, will align with Directive (EU) 2022/2041 once transposed

Calculation: Fixed monthly compensation compared to benchmark index (monthly, daily, or hourly as applicable), recalculated to full-time equivalent.

Acknowledged Methodological Deviations from ESRS S1-10:

• Uses annual base salary instead of hourly wages
• Excludes vast majority of operational workforce
• Excludes temporary workers
• Primarily references minimum wage, not living wage
• No living wage gap analysis conducted

Frequency: Annual reassessment through compensation reviews.

Value Chain

Not currently covered. Accor identifies "Negative impact on workers in case of non-respect of fair and decent employment conditions" in upstream and downstream value chain but provides no adequate wage assessment or targets for suppliers or franchisees.

Gender Pay Gap (Related Disclosure)

Overall gender pay gap (not adjusted for role):

• Scope A: 22.7% in favor of men (41 countries)
• Scope B: 14.8% in favor of men (54 countries)

Pay gap for comparable responsibilities:

• Scope A: 2.7% in favor of men (39 countries)
• Scope B: 2.4% in favor of men (32 countries)

Same methodological limitations apply (permanent employees and GMs only, annual base salary).

Social protection

Disclosure statement

Accor acknowledges that detailed quantitative disclosure on social protection coverage (S1-11) has been omitted in 2024 due to phase-in provisions under ESRS.

The company states in its cross-reference table (page 248):

"S1-11 – Social protection: Omitted in 2024 due to phase-in provisions"

Policies and commitments

Positive impact identified: Benefits of social protection for all workers including in countries where state-provided benefits are minimal (page 190, 202).

Accor's Compensation and Benefits Policy (pages 203-204) commits to:

• Offer attractive and competitive compensation packages in each market
• Ensure fair treatment of employees
• Improve quality of life through adequate wages and favorable social protection

Specific social protection measures mentioned (page 201):

• Minimum maternity leave of 14 weeks
• Minimum of three days of parental leave to welcome a new child
• 100% paid paternity leave without seniority conditions (France headquarters)
• 100% paid maternity leave without seniority conditions (France headquarters)
• Parental leave for same-sex parents (France headquarters)
• 10-week parental leave for same-sex families in France (since January 2022)

Supplementary pension benefits

For executives (pages 320-321, 328-330):

Accor operates two supplementary pension plans for headquarters employees and senior executives:

1. Defined contribution plan (PERO)

• Coverage: Executives with >1 year service and compensation >4× annual social security ceiling (PASS)
• Company contribution: 8% of gross annual compensation, capped at 8× PASS
• Benefits: Pension annuity on retirement with survivor benefits option
• Rights: Retained if employee leaves before retirement

2. Defined benefit plan ("L. 137-11-2" plan)

• Coverage: Executives with >6 months service and compensation >8× PASS
• Rights vesting: Between 1.6% and 2.4% of annual reference compensation depending on brackets:
  • 8-12× PASS: 1.6%
  • 12-24× PASS: 2.4%
  • 24-60× PASS: 1.6%
• Annual cap: 3% of reference compensation
• Performance conditions: Recurring EBITDA (50%) and free cash flow (50%)
• Benefits: Pension annuity with survivor benefits option

Historical frozen plan (pre-2020) (page 329):

• Rights built gradually until December 31, 2019
• Annual vesting rates by compensation bracket:
  • 4-8× PASS: 1%
  • 8-12× PASS: 2%
  • 12-24× PASS: 3%
  • 24-60× PASS: 2%
• Overall cap: 30% of last annual reference compensation
• Replacement rate cap: 35% of average best 3 years in last 10 years (for compensation >12× PASS)

Other benefits (pages 201, 321):

• Medical services and infirmary at headquarters in France
• Unemployment insurance for Chairman and CEO (maximum 24 months, capped at €471,000)
• Meal and transport cost contributions (country-dependent)
• Heartist fund for employees impacted by climate/geopolitical events

Scope limitations

Current coverage (pages 202-203):

• Permanent employees of Accor's historical headquarters
• General Managers (GMs) at leased and managed sites
• Heads of Department (HODs) at leased and managed sites

Not covered in current disclosure:

• Hotel and restaurant operational employees (except GM/HOD)
• Employees on fixed-term contracts <2 years
• Non-historical headquarters entities

Planned expansion (page 203): From 2025, Accor plans to:

• Extend scope to permanent employees of owned and leased sites (scope A)
• Integrate non-permanent headquarter employees
• Cannot collect data for managed sites (scope B) as compensation data is confidential

Methodology notes

Accor conducted an assessment of local health and protection initiatives in 2019 across 15+ countries using an external firm. An update questionnaire was distributed to headquarters employees in 2024, with analysis planned for 2025 (page 206).

The company has not yet defined a formal Social Protection Policy but plans to do so following this inventory update (page 206).

Persons with disabilities

Materiality: Non-material for Accor

Status: The disclosure requirement S1-12 (Persons with disabilities) is listed in Accor's ESRS index as "Non-material for Accor" with a reference to page 213.

Data collection scope: The company indicates that "% of disabled employees" is one of the indicators concerned in their reporting (alongside headcount by gender, status, age group, turnover, absences, and work-related injuries).

No quantitative metrics for percentage of employees with disabilities are disclosed in the provided excerpts. The company has deemed this disclosure requirement as non-material, which typically means no detailed metrics, methodology, or country-specific exclusions are reported.

Training and Skills Development: 32% of hotel managers and department heads have no qualifications beyond a high school degree (or equivalent), demonstrating the Group's social elevator ambition. The Accor Academy provides training opportunities with 4 regional Academies. In November 2024, Accor launched a new global learning management system (LMS) called Learn Your Way.

Health and safety metrics

Workplace accidents and fatalities

¹ 662 accidents recorded in real terms as at November 30, 2024, before extrapolation for December.

² 8,244 accidents recorded in real terms at November 30, 2024, before extrapolation for December.

Methodology notes

Accor acknowledges that the health and safety indicators monitored are published on a voluntary basis and show discrepancies with ESRS S1-14 requirements:

• Coverage by H&S management system: Not currently monitored for the Group.
• Work-related illness cases: Not included in the fatality indicator.
• Accident rate methodology: The percentage of accidents presented relates to the number of accidents per employee, not per million hours worked as requested by the standard. Taking these methodological differences into account, the accident rate presented may differ significantly from a rate calculated according to standard requirements.
• Number of days lost: Not disclosed.

Accor undertakes to upgrade its accident reporting system in order to remove this gap.

Work-life balance metrics

Disclosure Status

ESRS S1-15 (Work-life balance metrics) has been omitted in 2024 due to phase-in provisions according to the ESRS cross-reference table (page 248).

Policy Context

Accor's Human Rights Policy includes commitments related to work-life balance:

• Parental leave: The Group has set a goal to offer employees a minimum of three days of parental leave to welcome a new child. This type of measure promotes work-life balance and has a positive impact on employees.
• Rest time standards: A minimum standard of rest time, guaranteeing employees the benefit of at least one day of leave for seven working days.
• Major life stages: Accor undertakes to respect the major stages of life, to minimize situations of uncertain working hours in short-term schedules in order to reduce constraints linked to atypical working hours in the sites.

Specific Initiatives (France - Corporate Headquarters)

The following benefits are provided at the Corporate Headquarters level:

• Cover of 100% paid paternity leave without seniority conditions
• Cover of 100% paid maternity leave without seniority conditions
• Implementation of parental leave for same-sex parents
• Implementation of additional leave days (for a sick child)
• 10-week parental leave available for same-sex families since January 2022

Quantitative Metrics

No quantitative metrics on family-related leave entitlement, take-up rates by gender, or return-to-work rates are disclosed for 2024.

Compensation metrics

Pay gap

Accor reports both an overall gender pay gap and a gap based on comparable responsibilities (like-for-like) using an internal methodology maintained since 2017 (HeForShe campaign). The calculation changed in 2024 to align with CSRD recommendations.

Overall gender pay gap (unadjusted):

• Scope A (Accor employees in headquarters and General Managers of leased sites): 22.7% in favor of men, across 41 countries
• Scope B (General Managers employed by owners of managed sites): 14.8% in favor of men, across 54 countries

Gender pay gap based on comparable responsibilities (like-for-like/adjusted):

• Scope A (headquarters employees and General Managers of leased sites, excluding employees hierarchically lower than GM): 2.7% in favor of men, in 39 countries
• Scope B (General Managers employed by owners of managed sites, excluding employees hierarchically lower than GM): 2.4% in favor of men, in 32 countries

Accor acknowledges that the methodology differs from the standard recommended methodology. The study only covers employees with permanent employment contracts (or fixed-term contracts of more than two years). Temporary employees and hospitality employees except General Managers are excluded from the study. The results are based on gross annual contractual base salary and full-time equivalent, not hourly wages as recommended by the standard.

The survey was conducted on September 30, 2024 and covered permanent employees (or those with fixed-term contracts of more than two years) at headquarters and General Managers (GM or equivalents in Other Activities), representing less than 5% of the total workforce sample.

Accor states that from 2025, it will extend the scope to all permanent employees in headquarters and all employees of owned and leased sites working in hospitality to present a result representative of the entire S1 scope, including site employees.

Remuneration ratio

Not disclosed. While Accor provides equity ratios for its Chairman and Chief Executive Officer Sébastien Bazin pursuant to Article L. 22-10-9 of the French Commercial Code, these ratios are specific to French legal requirements and cover different scopes than ESRS S1-16 requirements.

For fiscal 2024, the following ratios are reported for French legal purposes:

Accor SA scope:

• Ratio relative to average employee compensation: 43
• Ratio relative to median employee compensation: 67 (11% increase versus 2023)

Broader scope (headquarters + leased hotels in France):

• Ratio relative to average employee compensation: 66 (29% increase versus 2023)
• Ratio relative to median employee compensation: Not specified

The company notes that more companies, including Noctis Event and Potel et Chabot, were integrated in fiscal year 2024. On a like-for-like basis compared to 2023, the ratio of average employee compensation in the broader scope would be 55.

These ratios reflect French legal requirements and do not appear to be presented as meeting ESRS S1-16 requirements for annual total remuneration ratio.

Methodology

Gender pay gap methodology:

The gender pay gap is calculated using an internal methodology from the HeForShe study, originally defined in 2017. The calculation formula changed in 2024 to align with CSRD recommendations.

Compensation data relates to gross contractual base salary prorated to working time, including monthly fixed allowances if applicable. The comparison corresponds to a recalculation of the base salary in full-time equivalent.

The gap is calculated for each Hay grade (Accor's internal classification system common to all countries). The result is weighted by the number of employees for each Hay grade to obtain an average overall gap by country. Differences by category (headquarters or General Managers) and by country are consolidated by the Corporate Compensation & Benefits department to calculate the Group average compensation gap, weighted by the number of employees in each country.

New formula used in 2024:

[Average annual income of men (by Hay grade) - Average annual income of women (by Hay grade)] / [Average annual income of men (by Hay grade)] × 100

Scope and exclusions:

The study includes employees with permanent contracts or fixed-term contracts of more than two years who were on the payroll in September 2024 (after the 2024 annual compensation review).

Employees with expatriation contracts and countries where both sexes are not represented in headquarters positions or General Manager positions are excluded. The analysis of the gap based on comparable responsibilities covers a more limited scope than the overall pay gap due to incomplete assessment of headquarters positions and mapping of responsibility levels for General Managers in 2024.

Material gap threshold:

Accor deems the pay gap to be material if it is greater than 5%, aligned with the European Pay Transparency Directive threshold.

Acknowledged limitations:

Accor acknowledges several methodological deviations from the standard:

1. Exclusion of temporary employees and fixed-term contracts under 2 years
2. Exclusion of all hotel and restaurant employees except General Managers (less than 5% of sample)
3. Use of annual base salary rather than hourly wages
4. Limited scope focused on headquarters employees (47% of scope A employees, 3% of scopes A and B combined, but 98% and 80% of survey results respectively)

The limited scope excludes the most vulnerable populations, such as temporary employees and first-level positions at sites who are more exposed to risk of low wages. The data should be viewed in light of the types of positions studied.

Accor states it will take necessary technical measures to extend scope from 2025 to all permanent Accor employees and temporary headquarters employees, and include all employees of owned and leased sites working in hospitality professions.

Incidents, complaints and severe human rights impacts

Discrimination

The current handling of discrimination cases and workers' alerts remain decentralized. These matters are primarily managed by local management and Talent & Culture teams. At present, there is no centralized system to comprehensively track and manage all reported cases and incidents.

The Accor Integrity Line offers a solution for reporting concerns; however, it lacks the functionality to provide detailed data on alerts categorized by specific populations or types of discrimination. Similarly, the Group's engagement surveys facilitate the development of targeted action plans, but these surveys do not systematically record or calibrate incidents to ensure comprehensive tracking and resolution.

Grievance mechanisms

There is no single formalized approach to reporting via the manager, the Talent & Culture Department or employee representatives. An alert procedure outlining the whistleblower's rights is in place. Employees are encouraged via a message on the platform or other communications to: "Express yourself freely, securely and confidentially on the Accor Integrity Line platform".

Regarding the other channels, there is no global policy but rather references to local legislation on the protection of whistleblowers.

OECD contact points

Accor is not currently aware of any national contact point for complaints at the OECD level for multinational companies.

Methodology note

These matters are not centralized in relation to the reporting of incidents. The objective is to remedy these issues as quickly as possible and at local level.

Community Policies: Accor is committed to enabling positive change through ethical business practices, responsible tourism, sustainable development, community engagement, and diversity and inclusion. The Group has established a Social Care & Impact department to strengthen the human dimension of its initiatives.

Cultural Heritage: Accor signed a three-year partnership with the World Monuments Fund, becoming the organization's first Sustainable Tourism partner. This collaboration aims to support historic restoration, preservation, and promotion of culturally significant sites, ensuring their long-term sustainability while combating overtourism.

Community Impact: More than 480 projects supported by Accor Solidarity since its creation. In 2024, more than 15,000 people benefited from solidarity projects initiated by Accor. Social elevator programs have enabled more than 5,000 individuals to develop their skills, learn trades and access job opportunities. Shelter projects provided sanctuary to more than 10,000 people.

Business Conduct and Corporate Culture: Accor's Purpose states: 'Pioneering the art of responsible hospitality, connecting cultures, with heartfelt care.' The Group has fostered a corporate culture that embraces the principles of responsibility, combining enthusiasm and audacity with a sense of sustainability.

Values and Ethics: Accor's values are based on cultivating a curious, open-minded and authentic environment. The Group is committed to ethical business practices, responsible tourism, sustainable development, community engagement, and diversity and inclusion.

Supplier Management: The Group works with an extensive network of carefully selected partners and approximately 4,500 listed suppliers. Suppliers must comply with the principles of the Group Responsible Procurement Charter. ASTORE (the Group's procurement offering) provides €3 billion in purchases via Central Procurement contracts with 30 procurement offices around the world.

Prevention and detection of corruption and bribery

Ethics and CSR Charter

• Scope: All permanent and non-permanent employees, headquarters, subsidiaries and sites operated under the Accor brand
• Key content: Updated in 2024 to better reflect Accor's Purpose: "Pioneering the art of responsible hospitality, connecting cultures, with heartfelt care". The Charter includes commitments to use its voice with public authorities on topics affecting its business, defend legitimate interests, refrain from seeking preferential political or regulatory treatment, and demonstrate integrity in dealings with government agencies
• Availability: Accessible to employees on AccorLive
• Oversight: Chairman and Chief Executive Officer (member of Board of Directors), Executive Committee members, and Public Affairs Department oversee lobbying activities

Prevention of Corruption and Bribery Policy (also referred to as Corruption and Bribery Prevention Policy)

• Scope: Accor employees at headquarters and subsidiaries worldwide. May also benefit sites operated under the Accor brand. Does not cover the Board of Directors and its members. Also applies to Accor partners
• Key content: Specifies that any breach could result in severe penalties for Group employees, including disciplinary proceedings up to and including termination of employment for employees who knowingly or due to negligence violate the policy or conceal information. Non-compliance by Accor partners may lead to termination of commercial relations. Includes Third Party Due Diligence Policy
• Availability: Accessible to employees on AccorLive
• Oversight: Ethics Committee reviews at each meeting; Legal and Compliance Department reports on monitoring of alerts to the Audit, Compliance & Risks Committee annually; relevant governance bodies monitor legal disputes
• Monitoring: Corruption and bribery risk mapping last updated in 2022 and updated in 2024. Policies and procedures updated in connection with risk mapping updates. In 2024, none of the Group's companies were the target of a final conviction for violating anti-corruption legislation or of a financial conviction

Training Policy to prevent Corruption and Bribery risks

• Scope: Accor employees at headquarters and subsidiaries worldwide. May also benefit sites operated under the Accor brand. Does not cover the Board of Directors and its members. 100% of functions most exposed to corruption risks are identified in the training program
• Key content: Two types of training: (1) online training module that each employee must complete and validate once every three years; (2) training module for employees most exposed to corruption risks (identified based on corruption and bribery risk mapping), which they must follow and validate once every two years. All new employees included in the list of exposed employees must comply within six months of onboarding

Gifts and Entertainment Policy

• Scope: All permanent and non-permanent employees, headquarters, subsidiaries and sites operated under the Accor brand
• Key content: Updated in 2024 to better prevent risks and ethical problems and better align practices with Group standards. Changes increase transparency and guide employees in managing situations related to offering and acceptance of gifts and invitations, while respecting Accor's high ethical standards
• Monitoring: Digitization of disclosures related to business ethics issues, including gifts and invitations disclosures and conflicts of interest disclosures, in 2024

Incidents of corruption or bribery

Confirmed incidents and convictions

Accor discloses that in 2024, none of the Group's companies were the target of a final conviction for violating anti-corruption legislation, or of a financial conviction.

The statement covers final convictions handed down during 2024 against an entity controlled by Accor at the time of the alleged acts. This statement covers final judgments, i.e. those that are no longer subject to appeal or whose appeal periods have expired.

Fines paid

No fines for violations of anti-corruption or anti-bribery laws were paid in 2024.

Disciplinary actions and contract terminations

Accor does not provide specific quantitative data on the number of employees dismissed or disciplined, or contracts with business partners terminated or not renewed, due to corruption or bribery incidents during the reporting period.

Investigation and speak-up procedures

Whistleblowing system (Accor Integrity Line):

Accor operates a secure worldwide whistleblowing line called the Accor Integrity Line, which is:

• Available 24/7 in 29 languages
• Hosted by an independent external service provider
• Accessible to all stakeholders (employees, suppliers, workers in the value chain, guests, local communities)
• Available via intranet and publicly at accor-integrity.com
• Confidential, with guaranteed anonymity if desired by the whistleblower

Alert categories include compliance issues such as corruption or bribery, money laundering, competition law, and conflicts of interest.

Alert processing:

• Alerts are processed by dedicated contacts from the Internal Audit, Talent & Culture, and Legal & Compliance departments
• All contact persons are trained on the whistleblowing system
• An Alert Monitoring Committee, led by the Group General Counsel and Board Secretary, oversees all alerts
• The Committee met eight times in 2024 to monitor alerts
• Alerts may be investigated independently by Regional Compliance Officers or the Legal and Compliance Department

Volume trends: In 2024, the number of alerts submitted through the Accor Integrity Line increased by more than 37% compared to 2023, demonstrating the accessibility and effectiveness of the system.

Investigation protocols: Accor has procedures in place allowing the company to objectively investigate incidents related to business conduct, including allegations of corruption and payment of bribes. The company emphasizes that dedicated contacts must demonstrate objectivity, remain neutral in assessing facts, take precautions to preserve data security, guarantee confidentiality of whistleblower identity, and inform whistleblowers of follow-up within a reasonable period.

Sanctions policy: The Corruption and Bribery Prevention Policy specifies that any employee who knowingly or due to negligence violates the policy or conceals information about a potential violation will be subject to disciplinary proceedings up to and including termination of employment. Non-compliance by Accor partners may lead to termination of commercial relations.

Political influence and lobbying activities

Political engagement approach

Accor has made the following commitments, which are included in its Ethics and CSR Charter:

• To use its voice to ensure that its position on topics of general interest affecting its business is made known to public authorities and institutions, either on an individual basis or through associations
• To take action to defend its legitimate interests in the knowledge that its action is justified
• To refrain from seeking preferential political or regulatory treatment
• To demonstrate integrity and intellectual probity in all its dealings with government agencies and public bodies, regardless of the situation or the interest it is defending

Oversight of lobbying activities is the responsibility of the Chairman and Chief Executive Officer, member of the Board of Directors, as well as members of the Executive Committee and the Public Affairs Department.

No member of the Board of Directors has held a comparable position in the public administration in the two years preceding their appointment.

The Group's positions are stated by the Chairman and Chief Executive Officer, the members of the Executive Committee and the Public Affairs Department. Accor also uses an external agency as part of its institutional relations at European level.

In France, under the law of December 9, 2016 on transparency, fighting bribery and economic modernization, Accor entered the names of its authorized spokespersons in the transparency register managed by the Haute Autorité pour la Transparence de la Vie Publique (the French authority for transparency in public life).

Lobbying activities and focus areas

In 2024, Accor participated in the growth of the tourism sector at the national level and worked with public authorities and professional organizations in implementing an ambitious public policy. The activities of the Group's Public Affairs Department cover all the Group's businesses and entities worldwide.

The policy covers four main areas:

Energy transition: The Group launched an initiative with the hospitality industry and the government to monitor water consumption and energy efficiency as well as supporting its different sites in dealing with the energy crisis. The implementation of the tertiary decree led to regulatory changes and structural changes in the company's activity.

Appeal of sector professions: These are structurally under pressure and require adaptations to regulations to reflect the profound changes in working habits. The Group, through its professional organizations, has worked at the national and European levels to ensure that the specific nature of its business lines is taken into account by the public authorities, in order to reduce recruitment pressures.

Fair competition with digital platforms: The hospitality industry is increasingly intermediated. The implementation of the Digital Markets Act, a European regulation initially intended to establish fairer competition in digital markets, threatens in particular the Group's distribution model. Its implementation by major online platforms is at the expense of the hotel sector: it offers more visibility to online agencies and price comparators.

Engagement, inclusion and diversity policy: The pursuit of an ambitious policy based on the deployment of numerous solidarity initiatives to benefit vulnerable groups; this was accelerated in the context of the 2024 Olympic and Paralympic Games, and the Group's public affairs teams are working to make the legacy of the Paris Olympic Games an opportunity to promote these actions with the public authorities.

At a European level, through the European Hotel Forum and the professional bodies for the hotel sector (HOTREC and national federations), Accor helped to promote the interests of the hotel industry among the European institutions, particularly in relation to online sales and intermediaries.

At the international level, the Group was involved in the governance of world tourism through its commitment to the World Travel & Tourism Council (WTTC), an association of the main companies and institutions in the global tourism sector, and strengthened its joint work with public authorities in the countries in which it operates, thanks in particular to support for the French diplomatic network.

Political contributions

The Group does not make any financial payments to political parties.

Trade association memberships and lobbying expenditure

The main cash contributions paid by Accor to industry organizations or professional federations (which represent external lobbying expenses) are presented in the table below. These concern centralized lobbying expenses and represent all contributions. Internal lobbying expenses (e.g. personnel expenses) are not specified.

Payment practices

Materiality statement

G1-6 Payment practices is identified as non-material for Accor in the ESRS disclosure requirements table.

Supplier payment periods

The following data relates to Accor SA (parent company) invoices received and past due at December 31, 2024:

Contractual payment terms used: 60 days after invoice date

Customer payment periods

The following data relates to Accor SA (parent company) invoices issued and past due at December 31, 2024:

Payment terms used: Statutory terms: 30 days after invoice date

Scope note

The payment practices data disclosed relates to the parent company Accor SA only, as required under French Commercial Code Article L. 441-6 or L. 441-10. No information is provided on legal proceedings for late payment or participation in prompt payment codes.