Accor

Reference: page 149

Accor's Board of Directors comprises thirteen members, including two employee representatives, as of December 31, 2025, with the Chairman also serving as Chief Executive Officer. The Board is 46% independent and 69% women, with eight nationalities represented and a women-to-men ratio of 2.25. Five specialized Committees support the Board; the Audit, Compliance & Risks Committee and the ESG Committee carry the sustainability remit, the former monitoring the process for preparing and controlling sustainability information, including the double materiality analysis, and the latter assisting the Board in defining and monitoring the Group's sustainability strategy and extra-financial performance indicators. Both Committees jointly review the Sustainability Report before Board review. The Group Management Board is regularly informed on sustainability matters via the Chief Sustainability Officer, who sits on the Management Board.

Reference: page 150

In 2025 the ESG Committee met four times to address sustainability issues, and the Audit, Compliance & Risks Committee met four times, discussing sustainability at one of those meetings. Topics covered material matters identified in the double materiality analysis, notably climate change, including greenhouse gas emissions from sites' energy use for heating and cooling buildings. On the basis of the two Committees' work, the Board of Directors determines the Group's sustainability strategy and main related performance indicators at least once a year, and assesses achievement of these indicators annually. The materiality analysis and its results were discussed and approved by the ESG Committee, and the Board has incorporated ESG criteria into the compensation structure of the Company's executives.

Reference: page 150

The Chairman and CEO's long-term variable compensation includes a carbon footprint reduction criterion tied to the Group's public commitments. Short-term 2025 quantitative extra-financial targets for the CEO included a 4% reduction in water intensity (achieved -5.2%), 55% of hotels eco-certified (achieved 56.7%), and 40% of positions at VP level or above held by women (achieved 41.2%); long-term 2023-2025 targets on Scope 1+2 and Scope 3 carbon footprint reduction versus 2019 were both marked "Not achieved." Accor also links extra-financial performance to financing instruments: its sustainability-linked bond and revolving credit facility carry targets on Scope 1+2 and Scope 3 emissions, food waste, and the share of women on the Management Committee, the last of which reached 42.2% against a 45% target.

Reference: page 151

Accor maps its reasonable due diligence process against the corresponding sections of the Sustainability Report. Due diligence is embedded in governance, strategy and the business model through the incentive mechanisms linked to sustainable performance and the double materiality analysis. The Group engages affected stakeholders throughout its water, biodiversity, circular economy and human rights policy sections. Adverse impacts are identified through the double materiality analysis, and action to address them runs through the transition plan and topic-specific action plans across climate, water, biodiversity, resources and waste, working conditions, gender-based violence, forced labor and workers in the supply chain, local communities and consumers. Effectiveness of these actions is tracked and communicated through the corresponding "Targets and results" sections for each topic throughout the Report.

Reference: pages 152-153

Accor's sustainability-reporting internal control system builds on the double materiality analysis, which in 2024 informed four internal control books for the ESRS most material to the Group (E1, E3, S1, G1); two further books (E5 and S2) were drawn up in 2025, alongside updates to the earlier four. Four main risks were identified: completeness and integrity of data, accuracy of estimated data, availability of upstream/downstream value-chain data, and availability of information within publication deadlines. Controls include automated data-collection tools, a centrally defined reporting scope, documented estimation methodologies, and defined roles including a sustainability reporting manager and an ESRS owner per standard. The Audit, Compliance & Risks Committee oversees internal control, and the ESG Committee reviewed the governance of the Sustainability Report and the double materiality analysis.

Reference: page 142

Accor is a world-leading hospitality group operating 5,720 hotels (5,836 including joint-venture sites), more than 10,000 restaurants and bars, and wellness and co-working spaces, through more than 45 brands across two divisions: Premium, Midscale & Economy and Luxury & Lifestyle. The Group's asset-light model comprises 2.8% owned and leased sites (perimeter A), 35.9% managed (perimeter B) and 59.3% franchised (perimeter C), with 2.0% owned by joint ventures. Revenue from all Group activities totaled EUR 5.6 billion in 2025. Accor operates mainly in Europe, North Africa and Asia-Pacific (76.8% of activity) and generates no revenue from fossil fuels, chemical production, defense, or tobacco cultivation or production. In 2025, 303 new hotels joined the CSRD scope and 149 left it.

Reference: page 147

Accor structures stakeholder engagement around three priority categories: public authorities and regulatory bodies, the economic and financial sphere, and civil society, alongside internal stakeholders, suppliers and industry organizations. Engagement channels include the European Works Council, which meets twice a year and is co-chaired with the international trade union IUF, sectoral coalitions such as the World Sustainable Hospitality Alliance and the Hospitality Alliance for Responsible Procurement, and partnerships with NGOs including WWF, ADEME and CIWF. In June 2025, Accor convened WSHA, Travalyst and the World Travel & Tourism Council around the Ocean Tourism Pact at the United Nations Ocean Conference. Sectoral coalitions' action plans are shared with the Chairman and CEO and presented annually to the Shareholders' Meeting.

Reference: pages 158-164

Accor's double materiality analysis identified 118 impacts, risks and opportunities (IROs) in 2025, versus 115 in 2024, of which 32 were assessed as material (33 in 2024) using a materiality threshold of 16, half of the maximum possible score of 32. Six IROs changed classification between years: for example, water-withdrawal wording was refined, the waste impact description was linked to the Group's most material waste streams, and displacement of local communities was reassessed as no longer material. The 32 material IROs span climate change, water, biodiversity, circular economy, own workforce, workers in the value chain, local communities, consumers and business conduct; pollution (E2) carries no material IRO and is therefore excluded from the double materiality matrix and the report. The materiality matrix plots each theme's impact and financial materiality scores.

Reference: pages 153-157

Accor applies a five-step double materiality methodology aligned with ESRS 1: understanding the context, identifying IROs, assessing IROs, reviewing and validating the analysis, and identifying information to report. More than 30 internal experts across Sustainability, People & Culture, Finance, Procurement, Risk, Development and Strategy contributed, alongside external experts and a survey of nearly 50 external stakeholders. Impact materiality is scored on scale, scope and, for negative impacts, remediability, each rated 1-4; financial materiality is scored on financial, reputational, operational and legal cost dimensions. Probability of occurrence and severity scores are multiplied and summed across short/medium- and long-term horizons, against a materiality threshold of 16 out of 32. The CSRD Committee and CSRD Steering Committee reviewed the analysis, which the Board of Directors validated after ESG Committee review.

Reference: page 271

Appendix 1 of the Sustainability Report, "ESRS Disclosure Requirements included in the Sustainability Report," presents a topic-by-topic concordance table listing every ESRS 2 and topical disclosure requirement Accor addresses, together with reference pages in the report or a note that the requirement is "Not material for Accor," "Does not concern Accor," or "Omitted in 2025 due to phasing-in provisions." The table spans ESRS 2 general disclosures and each of the E1-E5, S1-S4 and G1 topical standards, and is the source used throughout this dataset to classify each disclosure requirement's status. Note: Accor's own table entry for IRO-2 itself cites pages 246-249, which appears to be a transcription mismatch, since the concordance table is actually presented on pages 271-274.

Reference: pages 168-183

Accor's first climate change mitigation Transition Plan, published in 2024, targets planetary carbon neutrality by 2050 and reductions of 46.2% in Scope 1 and 2 emissions and 27.5% in Scope 3.1, 3.3 and 3.14 emissions by 2030 versus 2019, validated by the Science Based Targets initiative in 2020. The Group states the Plan is "incomplete within the meaning of the CSRD standard": Scope 3 2030 targets follow a below-2°C rather than a 1.5°C trajectory, no long-term targets beyond 2030 are set, and 9% of total emissions are not covered. The 2019 base year was retrospectively updated in 2024 to 6,936 ktCO2eq. The Plan was approved for publication by the ESG Committee and built through Climate Steering Committee-facilitated carbon workshops spanning corporate, entity and operational levels.

Reference: page 166

Back-filled from ESRS 2 IRO-1 and the E1 climate risk section, where this content is disclosed in the FY2025 report (pages 153-157, 166-167). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

In 2025 Accor updated its climate risk mapping, last refreshed in 2022 on IPCC RCP8.5 (+4°C by 2100) and RCP2.6 (+1.5°C) scenarios, with a new TCFD-aligned analysis based on a single median scenario, IPCC SSP2-4.5, projecting +2.1°C by 2050 and +2.7°C by 2100. The analysis, led by the Risk Management, Strategy and Sustainability Departments with expert consultants, covered two time horizons (2030 and 2050) and the same scope as prior studies: owned/leased, managed and franchised sites, excluding Other activities and headquarters, baselined on Accor's business plan to 2030 and extrapolated to 2050. It identified a physical risk from weather hazards and two transition risks (reduced air travel, tightening sustainability regulation), and quantified their financial impact on Group revenue; a separate named 1.5°C-aligned transition scenario is not disclosed.

Climate-specific risk identification and scenario analysis is also presented under IRO-1 and SBM-3 (2023 ESRS numbering).

Reference: pages 163-164

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 163-164). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Accor's 2025 climate scenario analysis found that the Group's international presence and diversified geographic footprint support resilience: the Group could offset transition risks in the median +2.7°C scenario by capturing additional market share in domestic markets that carry lower physical climate risk and a more decarbonized energy mix. Financial effects arising from material climate risks and opportunities were estimated as part of the scale assessment and are described in Note 1.4 "Climate risks" to the consolidated financial statements. Strategic recommendations to mitigate risks and capitalize on opportunities were being developed following the analysis. The report states plainly that "Accor's resilience to other risks and opportunities has not been the subject of a specific overall analysis" beyond climate.

Reference: page 168

Accor's Climate Policy, developed in 2024 and published in December 2024, was validated by the Chief Sustainability Officer and presented to the Climate Steering Committee, which reports to the Sustainability Department and steers its deployment. It covers all Group activities across scopes A, B and C and Scopes 1, 2 and 3, and is based on the double materiality analysis. Its main objective is to reduce Scope 1 and 2 emissions 46.2% and Scope 3.1/3.3/3.14 emissions 27.5% by 2030 versus 2019, aligned with the Paris Agreement's 1.5°C goal and validated by the Science Based Targets initiative in 2020. Climate-related criteria are included in short- and long-term variable compensation for Executive Committee members and hotel managers, and the Sustainability Department reports and measures the associated indicators.

Reference: pages 177-183

Accor's climate actions span the value chain: more than 1,000 suppliers across five continents, representing 75% of nominated purchase volume, took part in the "Achieving Net Zero Together" decarbonization program using the ACME carbon-maturity questionnaire, which won the Leading Climate Action Initiative award at the 2025 World Sustainable Travel & Hospitality Awards. On the demand side, Accor rolled out carbon-impact labelling on restaurant menus and a Carbon Tracker calculator for corporate events, available since November 2025. Internally, an Environmental Performance Scorecard and the Engineering Property Management Services program support hotel energy efficiency, and green-electricity procurement was extended to Turkiye in 2025. Roadmaps were validated by the Climate Steering Committee and reviewed by the Executive Committee and Chief Sustainability Officer in late 2024, with the ESG Committee approving publication of the Transition Plan.

Reference: page 170

Accor's SBTi-validated 2030 targets, set in 2020, are to reduce Scope 1 and 2 emissions 46.2% and Scope 3.1, 3.3 and 3.14 emissions 27.5% versus a retrospectively updated 2019 baseline of 6,936 ktCO2eq. The commitment is expressed in absolute terms and covers more than 90% of Accor's total carbon footprint; the Group has not yet set a 2050 net-zero target but is assessing submitting one to SBTi during 2026, and aims to renew validation of its 2030 targets by March 2026. The waterfall trajectory to the 2030 target of 4,406 ktCO2eq breaks projected reductions down across Scope 1, Scope 2 and Scope 3 levers, including hotel energy decarbonization, electrification, renewable energy sourcing, and supplier and transport decarbonization, alongside projected emissions growth from portfolio expansion.

Reference: pages 183-184

Total 2025 Group energy consumption was 13,959,270 MWh across perimeters A, B and C, of which 93.7% came from fossil-fuel sources, 3.6% from nuclear electricity, and 2.7% from renewable sources. Fossil-fuel energy consumption was 13,072,144 MWh, up from 12,876,028 MWh in 2024; renewable energy consumption rose to 379,090 MWh from 307,652 MWh, the largest renewable component being electricity from contractual renewable instruments (328,352 MWh). Managed hotels (perimeter B) accounted for the largest share of consumption at 9,418,852 MWh. Accor states that none of its activities are in a high climate-impact sector and that biogenic emissions do not arise in its operations, so neither is separately disclosed. In 2025, 34% of perimeter A's electricity supply came from low-carbon sources via energy origin certificates.

Reference: pages 184-187

Accor's 2025 gross GHG emissions under operational control (perimeters A+B+C) totaled 7,498 ktCO2eq: Scope 1 was 690, Scope 2 market-based was 2,767 (location-based 2,714), and Scope 3 was 4,042, of which 6,849 ktCO2eq fell within the SBTi commitment scope (Scope 1+2: 3,457; Scope 3.1/3.3/3.14: 3,392). Emissions rose from 2024's SBTi-scope total of 6,777 ktCO2eq mainly due to portfolio shifts toward higher-carbon-intensity Luxury and Premium segments, though a like-for-like comparison shows a 5% reduction in energy-related emissions from efficiency gains and grid decarbonization. GHG intensity was 1.2 tCO2eq per EUR thousand of revenue on both a location- and market-based basis, broadly unchanged year on year. Hotels under franchise (Scope 3.14) contributed 1,418 ktCO2eq, the largest single Scope 3 category after purchases of goods and services.

Reference: pages 188-189

Accor's Water Policy, published in 2023 and updated in 2024, addresses water withdrawals across the Group's hospitality portfolio (perimeters A, B, C) and covers priority river basins identified through the AXA Altitude and SBTN State of Nature Water Layers tools; nearly half of the hotel portfolio was found to sit in areas of high water stress, with five priority basins named, including the Arabian Peninsula and Greater China's Yellow Sea/East China Sea basin. The Policy draws on the TNFD, SBTN, CDP Water and the UN CEO Water Mandate, and targets reduced withdrawals, improved resource efficiency and locally adapted mitigation. It was approved by the Chief Sustainability Officer and shared with the Water Steering Committee before distribution to regional and brand Sustainability Leaders in 2025.

Reference: pages 189-191

Accor's 2025 water action plan covered five workstreams: strengthening hotel reporting through a dedicated data-quality team; rolling out water-efficient showerheads and taps via the June 2025 "Blue Friday" operation offering up to 55% discounts; a change-management roadmap including an AXA Climate training course completed by 3,658 employees; testing four innovative solutions, including a shower "nudge" that cut room-level withdrawal by 41% in pilots; and expanding the "Skip the Clean" no-daily-cleaning program to over 600 hotels across five regions and brands, each participating room saving 4-12% of direct water use. A planned 2025 local water-stress analysis could not be completed due to internal reorganization, and consolidated dependence assessment was deferred to 2026.

Reference: pages 190-191

Accor targeted a 4% reduction in water withdrawal intensity (m3 per occupied room) in 2025 versus the 2024 reference year, across the hotel portfolio open on December 31, 2024 (perimeters A, B, C, excluding conflict zones); the result was a 5.2% reduction, from 0.55 to 0.52 m3 per occupied room. This target is included in short-term variable compensation (STIP) criteria introduced in 2025 and in the Chairman and CEO's compensation. It is a voluntary Group target, not adapted locally for water-stressed areas in 2025, though water-stress criteria were shared with regional Sustainability Leaders for defining 2026 targets. Separately, Accor references a non-binding "desired state of nature" trajectory implying a 45% reduction by 2030 versus 2023, not yet the Group's formal target.

Reference: pages 191-192

Group water withdrawals totaled 73 million m3 in 2025 (2 million from own operations, perimeter A; 71 million from managed sites, perimeter B), of which 38 million m3 was withdrawn in water-stressed areas, based on the 1,021 priority hotels identified via the SBTN State of Nature Water Layers indicator. Water intensity across the hotel portfolio (perimeters A+B) was 0.677 m3 per occupied room in 2025, down slightly from 0.683 in 2024. Data completeness reached 92.8% of actual, non-extrapolated, withdrawal volume in 2025, up from 90.7% in 2024, collected monthly through the GAIA 2.0 reporting tool with outlier and extrapolation methodologies benchmarked against Cornell University research. Water storage data is not monitored, as the Group considers its impact immaterial.

Reference: page 194

Two Group policies address biodiversity: the Biodiversity Policy and the Sustainable Food Policy, both validated in 2024 by the Chief Sustainability Officer. The Biodiversity Policy, drawing on the TNFD and SBTN and aligned with SDG 15, follows the "Avoid, Reduce and Restore" sequence across three levers: favoring renovation over new construction in sensitive areas, partnering with AXA Altitude to map construction risk (with mapping planned for every project from 2026), and habitat restoration at existing hotels. The Sustainable Food Policy addresses deforestation and land-use change from agricultural sourcing, given that 80% of the Group's land-use-change footprint stems from restaurant food activities versus 13% from hotel operations, through certification requirements (Rainforest Alliance, ASC, MSC) and a shift toward non-meat menu options.

Reference: page 195

To address natural habitat fragmentation, Accor used the ENCORE tool in 2025 to assess site-level pressures, finding "medium" materiality for solid-waste disposal and the spread of invasive species linked to tourism movement between hotels. For 191 at-risk sites located in key biodiversity or protected areas, action levers based on GSTC, IUCN, UNEP and CBD guidelines were identified, including guest awareness messaging, cleaning-equipment provision at sensitive natural areas, restrictions on collecting natural elements, and habitat-maintenance and ecological-corridor programs; mandatory pesticide/herbicide-free green-space management for at-risk sites will be discussed in 2026. On sustainable food, 324 hotels deployed carbon-footprint-per-dish calculation tools in 2025, and Accor has worked since 2016 with WWF to eliminate endangered seafood species from menus.

Reference: pages 195-196

Accor's Sustainable Food Policy sets seven commitments to be implemented by end-2030, to be reviewed in 2026, the first being 50% vegetarian dishes across restaurants. Measurement began in 2025 with a target that 13% of sites offer at least 25% vegetarian meals by year end; the actual result was 36.0% of hotels meeting the 25% threshold, covering all 10,000 hotel restaurants and bars plus Paris Society and Potel & Chabot Group, with starters, mains and sides equally weighted. On biodiversity risk exposure, Accor identified 139 sites overlapping Protected Areas and 83 sites overlapping Key Biodiversity Areas at end-2025, versus 129 and 78 respectively in 2024, using the WWF Biodiversity Risk Filter across perimeter A and managed sites.

Reference: page 193

Using the WWF Biodiversity Risk Filter, Accor assessed its perimeter A and managed sites, over which it has operational control, and identified 139 sites at risk from overlap with Protected Areas (at least 5% overlap) and 83 sites at risk from overlap with Key Biodiversity Areas (0-10% overlap) as of December 31, 2025, up from 129 and 78 respectively in 2024. In 2025 the analysis was extended to cover Other activities and headquarters. The report states plainly that "the Biodiversity Risk Filter tool only allows the identification of risks and not impacts," and that a full impact assessment would require more than 190 individual site-level analyses by a consulting firm, which the Group considers impractical at this stage.

Reference: page 197

Accor's Circular Economy Policy, available on the Group intranet and public website, is built around the "5Rs" principle: Refuse, Reduce, Reuse, Repair, Recycle, and addresses the two material negative impacts identified in the double materiality analysis: intensive upstream resource consumption for site construction and maintenance, and improper waste disposal, prioritizing food waste and plastic. It covers headquarters, owned and leased hotels (perimeter A), managed hotels (perimeter B) and franchised hotels (perimeter C), with extension to Other activities (Paris Society, Potel & Chabot Group, Rikas) planned for 2026. The Policy sets out sustainable-procurement commitments, including eco-label criteria mandatory for cleaning products, paper products and food, and is validated by the Chief Sustainability Officer.

Reference: pages 198-199; 201-202

Accor's resource and waste actions target construction/renovation and site operation separately. For construction, Design & Technical Services technical standards embed eco-design and waste-management infrastructure requirements, with 180 people trained on BREEAM, EDGE, Green Globe and LEED standards in 2025 and a target of 65% eco-certified hotels by end-2026. For operations, food-waste reduction now covers more than 2,700 hotels, using AI measurement tools (Winnow, Orbisk, Lumitics) deployed at over 400 hotels, developed with the WRAP coalition, formerly IFWC. The single-use plastics program, aligned with the UN Global Tourism Plastics Initiative since 2020, covers all Group hotels and both guest-facing and back-office products, with alternatives assessed for FSC certification, OK Compost Home labelling, and reusable-container design.

Reference: pages 200-203

Accor's food-waste target is a 60% reduction per cover by 2030 versus a 2023 baseline of 290 grams per cover, established across 862 hotels, against an EU sector target of 50%; the 2025 result was 150 grams per cover across 2,706 hotels with valid baseline and measurement data, and 2,803 hotels had defined a baseline by year end against a 2030 goal of 3,900 hotels. The plastics target was 90% of hotels compliant for 90% of the 57-product single-use plastics list by end-2025; the actual 2025 result was 80.8% Group-wide (96.2% for owned/leased, 90.4% for managed, 74.5% for franchised hotels), up from 81.3% in 2024. Both targets are linked to executive variable compensation and an external EUR 1 billion sustainability-linked revolving credit facility.

Reference: page 198; 203-204

The total weight of products used by Accor's hotel portfolio, perimeter A own operations plus perimeter B managed sites, was 322,530 tonnes in 2025, down from 332,149 tonnes in 2024, comprising furniture, household linen, electronic equipment and food and beverage-related purchases estimated using the Group's carbon-reporting methodology. Data on the proportion of recycled, reused or sustainable-organic materials in the supply chain is not yet available; the Procurement Department is exploring ways to structure this data collection, potentially through added supplier database fields or tender requirements. Resource inflow figures are derived from an annual survey of hotels covering furniture, food products, household linen and electronic equipment categories, cross-checked against carbon-reporting average weights per category.

Reference: pages 204-205

Accor's total weight of waste generated, own operations plus managed sites, was 410,097 tonnes in 2025, up from 219,650 tonnes in 2024, reflecting an expanded reporting scope: 2,423 hotels and eight headquarters covering 63% of employees reported in 2025 versus 1,091 hotels and one headquarters in 2024, and hotels' tracked waste streams expanded from five categories to an extensive list including green waste, metal, WEEE, furniture, textiles, batteries, light bulbs and pallets. The non-recycled share of total waste fell to 49.0% in 2025 from 69.2% in 2024. A new waste reporting tool and methodology, deployed in 2024, lets hotels track up to 27 waste streams via the GAIA 2.0 platform; different extrapolation methodologies are applied across regions and detailed in the report's methodology appendix.

Reference: pages 204-205

Of the 410,097 tonnes of total waste generated in 2025, 200,792 tonnes (49.0%) were eliminated (disposed of) and 209,305 tonnes were non-eliminated (diverted). Non-eliminated non-hazardous waste of 209,028 tonnes split into 198,538 tonnes recycled and 10,491 tonnes reused; non-eliminated hazardous waste totaled 277 tonnes, with 265 tonnes recycled and 11 tonnes reused. Of eliminated non-hazardous waste (200,271 tonnes), 31,934 tonnes went to incineration, 150,770 tonnes to landfill and 17,567 tonnes to other disposal methods; eliminated hazardous waste (521 tonnes) split into 37 tonnes incinerated, 209 tonnes landfilled and 274 tonnes disposed of by other methods. Total hazardous waste for 2025 was 792 tonnes. No radioactive waste is generated, given the nature of Accor's hospitality activities.

Reference: pages 215-216

Accor's Human Rights Policy, published in 2023 and derived from the Ethics and CSR Charter, commits the Group to freedom of association and collective bargaining, rejection of child and forced labor, respect for fundamental labor rights, fighting human trafficking and child sexual exploitation, rejecting harassment and discrimination, and upholding health and safety and privacy, in line with the Universal Declaration of Human Rights, ILO core conventions and the UN Guiding Principles on Business and Human Rights. It applies to all workers under the Accor brand and sets expectations for franchised hotels and business partners. A Group-wide human rights risk mapping, carried out in 2024 with an external firm, prioritized the Middle East, Asia-Pacific and Latin America for mitigation actions, and governance runs through a Vigilance Committee spanning Procurement, Risk, People & Culture, Human Rights, Internal Audit, Sustainability and Safety-Security.

Reference: pages 215-216

Accor engages Heartists through indirect internal dialogue (employee representative bodies), external indirect dialogue (a comprehensive 1995 trade-union-rights agreement with the IUF, currently being renegotiated, plus a twice-yearly European Works Council co-chaired with the IUF and a Group Works Council), and direct dialogue (town halls, management calls, and a periodic engagement survey). The survey, conducted twice in 2025 for headquarters and General Managers and once for sites, recorded a 7.9/10 engagement rate at headquarters, 85% participation, unchanged from 2024, and 8.8/10 at owned/leased and managed hotels, 90% participation. The Group does not set an engagement-score target, valuing instead the culture of feedback the survey generates; results are shared with Heartists and inform action plans.

Reference: pages 238-239

Employees can raise questions, needs or alerts through four channels: reporting to managers, to People & Culture, to employee representative bodies, or to the Accor Integrity Line, an external platform run by a specialized service provider that accepts anonymous or identified reports. Remedial options vary by issue, from schedule and workload adjustments to individual pay increases and gender-based-violence victim support. The report states plainly that "the reporting of incidents is not centralized" and there is "no single formalized approach" across managers, People & Culture or employee representatives, with resolution sought "as quickly as possible and at local level." A whistleblowing procedure specifies whistleblower rights, and the engagement survey separately measures employees' confidence that management takes their suggestions into account.

Reference: pages 221-222; 224-225; 229-231; 236-238

Accor's action plans addressing working-conditions, compensation, and health-and-safety impacts include a human rights risk mapping (2024), monthly monitoring of Accor Integrity Line alerts, responsible-recruitment principles disseminated from late 2025, shift-rotation systems for the most difficult time slots, a minimum 14-week maternity leave and three days' parental leave, an internal audit program covering roughly 500 hotels a year, about one audit per hotel every four years on average, and the Accor Heartist Solidarity Fund for employees severely affected by climate or geopolitical events. The Group monitors turnover, absenteeism and engagement rates to gauge effectiveness but has chosen not to set specific targets for these indicators, preferring to track them through committees involving senior management and the Executive Committee.

Reference: pages 223; 231-235

Accor states plainly that it "does not yet set targets" for most working-conditions and compensation indicators, instead actively monitoring survey results, turnover, absenteeism, alerts, adequate-wage coverage and the gender pay gap. Concrete targets do exist for specific items: in France, a budget equal to 0.1% of total payroll was allocated to correct identified gender pay disparities at Accor France, renewed annually. Adequate-wage results for 2025, the reference year, covering all employees except non-guaranteed-hour "extras", showed 100% of perimeter A employees and 99.6% of perimeter B employees paid at or above benchmark levels, with the Group committing only to ensure these results "do not deteriorate subsequently" rather than setting a numeric improvement target.

Reference: pages 216-218

Accor's total workforce, "Heartists," was 250,490 at end-2025, up from 249,091 in 2024, split 21,180 in own operations (perimeter A) and 229,310 at managed sites (perimeter B). By gender, 148,546 employees were male, 101,887 female and 57 other. Since 2025 Accor also reports contract type: perimeter A comprised 17,337 permanent, 1,237 temporary and 2,606 non-guaranteed-hour staff; perimeter B comprised 144,424 permanent, 75,839 temporary and 9,047 non-guaranteed-hour staff. Turnover was 33.5% for perimeter A and 28.1% for perimeter B, 28.6% combined, up from 25.6% combined in 2024, partly reflecting a scope change including "extras" in the total headcount for the first time. Departures totaled 91,092 in 2025 versus 76,509 in 2024.

Reference: page 223

Since 2025, Accor has collected adequate-wage data for all Heartists at headquarters, owned/leased and managed sites, excluding non-guaranteed-hour "extras," comparing fixed monthly compensation to legal and regulatory minimum benchmarks by country. The 2025 survey found 100% of perimeter A employees and 99.6% of perimeter B employees paid at or above the reference level; the 0.4% of below-benchmark managed-site employees were concentrated in Saudi Arabia (1.1%), Bahrain (7.7%), Cambodia (0.4%), the UAE (5.5%), Ireland (1.5%), Namibia (1.3%) and the UK (0.3%), several reflecting countries without a universal legal minimum wage where compensation includes accommodation, meals and transport valued outside the calculation. Accor has not yet defined its own concept of "adequate wage" beyond regulatory minimums and plans internal audits on a hotel sample from 2026.

Reference: pages 225-226

In 2025, Accor recorded 6,138 workplace accidents leading to at least one day off work (261 perimeter A, 5,877 perimeter B), up from 5,741 in 2024, and 1,167 commuting accidents with at least one day off. The workplace accident frequency rate, newly reported in 2025, was 8.3 per million hours worked for perimeter A and 21.5 for perimeter B, 20.1 combined. There were two deaths from workplace accidents or occupational illness and five from commuting accidents, all in perimeter B; Accor plans to improve documentation of cause of death from 2026. Occupational health and safety is managed locally per site, guided by ILO Conventions 155 and 187, without a centralized management system, given the Group's decentralized asset-light structure.

Reference: pages 233-235

Accor calculated its global gender pay gap for the first time in 2025 to meet ESRS requirements, covering total gross hourly pay, base salary, target variable component, bonuses and benefits in kind, for all perimeter A employees on permanent and fixed-term contracts, excluding non-guaranteed-hour "extras": the result was an 11.6% overall pay gap in favor of men. This is not comparable to 2024 due to expanded scope. Separately, the voluntary "HeForShe" survey, limited to permanent employees at Accor's historical headquarters and comparing pay for comparable responsibilities, has run annually since 2017; France additionally allocates 0.1% of total payroll to correct identified individual pay disparities, renewed through annual compensation reviews under the mandatory annual negotiation agreement.

Reference: pages 239-240

In 2025 Accor expanded its Accor Integrity Line whistleblowing categorization to include a new "workplace complaints" category, distinguishing discrimination cases from other social issues; use of the platform grew steadily, and case managers will receive dedicated harmonization training from early 2026 using an updated alert-management guide. The report states plainly that "data relating to complaints and reports are not centrally consolidated" and are "managed locally by the entities," and that Accor "does not aim for an exhaustive centralization of all discrimination situations" given local-context complexity. Accor states it is not aware of any complaints filed with OECD National Contact Points for Multinational Enterprises, and does not centralize information on fines or compensation related to discrimination or harassment, which are handled locally.

Reference: pages 242-243; 246-248

Accor's Responsible Procurement Charter, appended to nomination contracts as a contractual obligation, requires nominated suppliers to comply with local and ILO labor standards, never resort to forced labor, refuse to work with any supplier employing a child under 15, and cascade these commitments to their own subcontractors; it also covers environment, waste and biodiversity commitments. The separate Hotel Purchasing Guide governs non-nominated purchases, covering legal compliance, responsible sourcing and food safety. Around 4,500 nominated suppliers, representing roughly 50% of Accor sites' purchasing volume, are covered, sourced across "tier 1" nominated suppliers and their own "tier 2" suppliers; only tier 1 nominated-supplier workers are within the current reporting scope. Both the Charter and Hotel Purchasing Guide were updated in 2025 for deployment from 2026.

Reference: pages 241-242

Accor engages franchised-hotel and supplier workers primarily through owners and nominated suppliers as intermediaries, since it has no direct control over franchised-site or external workers: the Group's engagement survey is offered to franchised-hotel owners, and the Accor Integrity Line is available to all workers in the value chain. Heads of franchised operations maintain close contact with franchise owners to monitor contractual compliance. For nominated suppliers, dialogue runs through the supplier control plan, including EcoVadis assessments and on-site audits, and 2025 webinars on Accor's responsible procurement roadmap and EcoVadis process drew more than 1,200 participants. The Procurement Department has not yet established formal mechanisms for supply-chain workers to participate directly in decisions about procurement process design, deferring this to the next control plan.

Reference: page 253

Measures to remedy proven non-compliance with value-chain workers' human rights use the same Accor Integrity Line alert platform described for own-workforce issues, open to franchisees, suppliers and their employees. The platform is referenced in the Responsible Procurement Charter signed by all nominated suppliers and in the Hotel Purchasing Guide for non-nominated suppliers, and covers any illegal or unethical behavior a supplier experiences or witnesses in its dealings with Accor. Suppliers who identify inappropriate behavior are directed to report it to the Procurement Department for correction. Franchised-hotel employees can also report concerns directly to their manager or to People & Culture correspondents, in addition to the platform, which is available 24/7 in 29 languages via an independent external service provider.

Reference: pages 243-245; 248-251

Accor's supplier control plan, covering 2022-2025, classifies purchase categories into three risk levels across 16 risks in five domains: environment, human rights, working conditions, health and safety, ethics. At end-2025, 100% of nominated suppliers had signed the Responsible Procurement Charter, about 4,500 suppliers, 98% of high/very-high-risk suppliers by revenue had a valid EcoVadis assessment, up from 63% in 2024, average score up 17 points since 2022, and 83% of very-high-risk suppliers scoring below 43/100 had been or were being audited on-site by Bureau Veritas or Intertek, up from 48% in 2024. Suppliers scoring below 30/100 (EcoVadis) or 70/100 (on-site audit) must implement a corrective action plan or face removal after a second failed assessment.

Reference: page 246

Accor's stated goal for the 2022-2025 supplier control plan was 100% deployment of the control plan among nominated suppliers, measured through three sub-indicators: Charter commitment, achieved 100% at end-2025; a valid EcoVadis or equivalent assessment for high/very-high-risk suppliers, achieved 98%, up from 63% in 2024; and external audit of very-high-risk suppliers scoring below 43/100, achieved 83%, up from 48%. Separately, 99% of Procurement Department buyers had completed mandatory source-to-contract training by end-2025, against a 100% target. The Procurement Department is designing the next control plan, effective from 2026, and has not yet set targets specifically for value-chain workers' direct participation in procurement decision-making, an area it flags as still in planning.

Reference: pages 255; 257

Accor's Human Rights Policy and Ethics and CSR Charter extend to local communities, recognizing the rights of indigenous peoples and the situation of the most vulnerable communities, including minors exposed to poverty, neglect or weak legal protection. The Charter, given to new employees and published on accor.com, sets out the Group's commitments as "a player committed to civil society and the planet," and is proactively shared with partner NGOs and associations through partnership agreements. Since 2008, the Accor Heartist Solidarity Endowment Fund has been the primary vehicle for community commitments, operating under its own articles of association and the Group's Sponsorship Policy; project support decisions run through the Endowment Fund's Board or the Group Sponsorship Committee, which includes Finance, Legal, Audit, Procurement and Sustainability representatives.

Reference: pages 254-255

Local communities' needs and perspectives are identified through partner associations and Solidarity Champions in each region, who submit project applications to Accor's Solidarity team for review, including Know Your Counterparty checks. Consultations with NGOs such as ECPAT, child sexual exploitation prevention, and participation in the UN Global Compact inform Accor's understanding of community-displacement and related impacts. Affected communities and other stakeholders can confidentially use the Accor Integrity Line to report violations of the Ethics and CSR Charter, Human Rights Policy or applicable law. Each Regional Director is operationally responsible for ensuring commitments are met locally, while the Chief Sustainability Officer holds overall responsibility; associations funded by Accor must report regularly on project progress to demonstrate effective engagement.

Reference: page 259

Local communities can raise concerns through the Accor Integrity Line, open to all internal and external stakeholders including local communities, available 24/7 in 29 languages via an independent external provider, and accepts anonymous reports. The same channel handles reports related to sexual violence and sexual exploitation of children, a priority theme identified in the double materiality analysis. Reports are examined by relevant departments including Safety and Security, with remediation individualized case by case; Accor states it addresses human rights incidents affecting local communities "on a case-by-case basis" rather than through a single centralized remediation process, reflecting the decentralized nature of its owned, managed and franchised site network.

Reference: pages 255-256; 258-259

Since 2008, the Accor Heartist Solidarity Endowment Fund has supported more than 495 projects in 40 countries; in 2024, the last year with full results, it reached nearly 17,400 beneficiaries, 76% women, including 5,700 through social-elevator training and professional-integration projects and 11,700 through shelter and protection, comprising over 7,000 overnight stays and more than 31,000 instances of assistance. In March 2025 Accor launched the "Heartist Volunteering Program" to encourage employee volunteering, and the ALL Accor x Dift platform lets loyalty members convert points into donations, raising over EUR 500,000 since launch. On child sexual exploitation, the WATCH 2.0 program raises awareness among Accor-brand workers, supported by videos and materials developed with partner NGOs such as ECPAT.

Reference: pages 256; 259

The Accor Heartist Solidarity Endowment Fund's stated 2025 target is that at least 40% of project beneficiaries achieve a "sustainable positive outcome" by project end, in further training or employment, monitored project by project with partner associations through interim and final reporting. As 2025-supported projects only started during the year, results will only be compiled and reported in 2026. On gender-based violence and sexual exploitation of children, targets remain project-level rather than Group-wide, though training content and follow-up have been shared with the European Works Council; the Group acknowledges that "monitoring the progress of this e-learning remains difficult given the high number of Accor staff worldwide."

Reference: pages 263; 264

Accor's commitments to consumers rest on the Ethics and CSR Charter and Human Rights Policy, covering non-discrimination, privacy, health and safety, and, since 2025, an extended Group Diversity, Equity & Inclusion engagement addressing gender-based violence against guests, with a dedicated cross-functional working group spanning Social Care & Impact, Security, Communication and Operations. Personal data protection is governed by the Accor Customer Personal Data Protection Charter, aligned with GDPR, UK GDPR, the California Consumer Privacy Act, China's PIPL, Brazil's LGPD and Australia's Privacy Act, and covers processing under Accor SA's responsibility; Other activities maintain separate documentation given their distinct processing purposes. Accor has not identified consumers as falling within regulatory "vulnerable persons" categories and applies no special procedures for them.

Reference: pages 261-262

Guests and other data subjects can exercise personal-data rights, access, erasure, rectification, objection, via contact forms on the ALL.com support area, dedicated customer-service email addresses, or the Group Data Protection Officer, appointed since 2018 and registered with France's CNIL; requests are processed within regulatory timeframes, averaging 2.18 days in Q1 2025. On gender-based violence, guests can report incidents through Customer Care, the all.accor.com website, online forms, telephone agents or the Accor Integrity Line; a cross-functional working group meeting several times a year coordinates the Group's response. Regional data-protection coordinators support owned/leased hotels and a dedicated platform assists managed and franchised hotels, which Accor plans to enhance with a data-subject-information feature in 2026.

Reference: pages 264-265

Complaints and reports concerning consumers are channeled through Customer Care, which processes gender-violence-related complaints reported via the all.com website, online forms, telephone agents or other Group departments, categorizing them, currently mostly under "Safety & Security," as no dedicated gender-violence category exists yet, and collaborating with Legal, Compliance, Safety and Security and People & Culture as needed. Certain brands and regions redirect customer reports to central or local contact points or hotel management directly rather than through Customer Care. On personal data, data subjects can also contact their national data protection authority, such as France's CNIL, or use an agent. The report notes reporting mechanisms "have not yet made it possible to systematically monitor the number or precise nature of reported cases" of gender violence.

Reference: pages 263-264; 264-267

Accor's response to gender-based violence against guests includes a 2025 toolkit for hotel-level action, the "universal gesture of distress" discreet signal, and a gradually introduced "Angel Drink" alert code for restaurants and bars; targeted guest communications are planned for 2026. The Safety and Security Department's incident reporting tool, in development since 2024, lets hotels report abuse of minors, prostitution and sexual assault by category and is live in Premium, Midscale & Economy and Luxury & Lifestyle hotels across most regions, with full global rollout expected in the first half of 2026. Local initiatives include SHe Travel Club-certified hotels, France's 3919 helpline, 1,500 hotels displaying posters, and a gender-based-violence reporting program launched in Brazil in 2024 and rolled out globally in 2025.

Reference: pages 264; 267

On data protection, Accor's target is that by end-2026, 40% of General Managers at owned and leased hotels, plus headquarters and Other-activities employees, complete online personal-data-protection training. On gender-based violence, the Group states it is "committed to continuously evaluating its current practices" but frames this as a systemic, difficult-to-measure phenomenon given decentralized reporting across countries, brands and hotels, rather than setting a numeric target; efforts focus on extending awareness-raising and training materials to hotels and broadening reporting-channel accessibility for guests, following the 2025 extension of the Group's gender-based-violence commitment beyond employees and local communities to consumers and end-users.

Reference: pages 268-270

Accor's Ethics and CSR Charter, applying to all permanent and non-permanent employees and sites operated under the Accor brand worldwide, underpins a compliance program covering third-party due diligence, Know Your Counterparty, donations, sponsorship, responsible procurement, conflict-of-interest management, professional alerts, and gifts and entertainment. The Anti-Bribery & Corruption Policy specifies prohibited behaviors under the corruption and influence-peddling prevention framework, updated by the Head of Legal and Compliance in coordination with relevant departments. A dedicated risk mapping, last updated in 2025, identifies Hospitality Development and Operations, M&A, Procurement, Commercial and Digital, Senior Management, Public Affairs, and Communications and Marketing as the functions most exposed to corruption and influence-peddling risk, driving mandatory training frequency: general online training every two years, in-depth training for exposed roles every three years.

Reference: pages 270-271

Accor identifies employees most exposed to corruption and influence-peddling risk through a Group risk mapping last updated in 2025, and requires all identified exposed functions to complete mandatory training, 100% of the most exposed functions are covered by the training program. Alerts are handled through the Accor Integrity Line, monitored by a dedicated Alert Monitoring Committee, Legal and Compliance, Social Affairs, Audit, Compliance and Human Rights leads, that met six times in 2025 and reports to the Ethics Committee at each meeting and to the Audit, Compliance & Risks Committee annually. Accor Integrity Line submissions rose more than 28% year on year in 2025. In 2025, no Group company was subject to a definitive conviction or financial penalty for anti-corruption legislation violations.

Reference: pages 270-271

Accor's FY2025 statement was prepared under the 2023 ESRS, which had no standalone business-conduct targets DR; business-conduct effectiveness tracking instead falls to MDR-T. Accor discloses no numeric corruption-reduction target, but tracks effectiveness through: 100% of the functions identified as most exposed to corruption risk covered by the mandatory training program, general training renewable every two years, an in-depth module for exposed roles every three years; the volume of Accor Integrity Line alerts, which rose more than 28% year on year in 2025, read as a sign of growing platform trust; and the absence of definitive anti-corruption convictions or financial penalties against Group companies in 2025. The Alert Monitoring Committee reports to the Ethics Committee at each meeting and to the Audit, Compliance & Risks Committee annually.

Reference: page 271

In 2025, "the Group's companies were not subject to any definitive conviction for violation of an anti-corruption legislation, nor were they subject to a financial conviction." The statement covers final judgments handed down during 2025 against an entity controlled by Accor at the time of the alleged facts, where all appeals have been exhausted or appeal periods have expired. The Anti-Bribery & Corruption Policy specifies that breaches can result in severe penalties for employees, up to and including termination, and that non-compliance by Accor partners may lead to termination of the commercial relationship. In 2025 Accor updated its corruption and influence-peddling risk mapping and strengthened second-level control procedures within the prevention program.