ACS Group

The role of the administrative, management and supervisory bodies

Reference: pages 39-45.

Board at 31 December 2025 (pages 40-41): 14 members - 3 executive (21.43%), 3 shareholder-nominated (21.43%), 7 independent (50%), 1 other external (7.14%). Six directors were women, 42.86%. "employees and other workers, in accordance with the applicable legislation, are not represented on the administrative, management and supervisory bodies of ACS" (page 41).

Committees: the Audit and Sustainability Committee (5 members, 4 independent, 3 women) "supervises the implementation of ACS's strategy in relation to due diligence on the environment and human rights, social issues, bribery, anti-corruption" and supervises "the effectiveness of the Company's Internal Control over Sustainability Reporting (ICSR)" (pages 40-41). The Nominations Committee (5 members, 4 women) maintains the board skills matrix; the Remuneration Committee (5 members, 3 women) proposes sustainability metrics in variable pay (pages 42).

After the 2025 board evaluation run with an external consultant, "ACS directors are considered to have the necessary skills and knowledge to supervise the material IROs" (page 44).

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: pages 45-46.

Specific matters taken to the Committee in 2025 (page 45):

• Environment: the Climate Change Mitigation Transition Plan, "which was approved by the Sustainability Department in December 2024", the approved GHG protocol, adoption of the LEAP methodology for biodiversity risks, the launch of two Group task forces (water and biodiversity), and the sectoral taxonomy benchmark.
• Social: health and safety (accident rates) and human capital (talent attraction and retention).
• Governance: "an analysis, identification and assessment of human rights risks in the ACS Corporation's own operations", and training on CSDDD due diligence.

"The Audit and Sustainability Committee unanimously approved the updated Double Materiality Analysis prepared by the company in 2025" (page 45). The Risk Management Report and updated Risk Map were presented on 27 February and 18 December (page 45). The Committee was also briefed on the Independent Expert's Report on the Global Compliance Management System objectives (27 February) and the half-yearly Compliance Report (30 July) (page 46).

Integration of sustainability-related performance in incentive schemes

Reference: pages 46-48; also restated for climate at pages 68-69.

Under the 2023-26 Director Remuneration Policy, 20% of the executive directors' annual variable remuneration for 2025 was linked to non-financial targets (page 46):

1. the S&P assessment for inclusion in the Dow Jones Sustainability Indices - ACS had to rank above the 92nd percentile, with a base target of the 96th percentile and "If the Company is above the 98th percentile, a 50% bonus will be applied" (page 47);
2. compliance with the 2025 Sustainability Master Plan, weighted first on the 17 priority targets, "in particular as regard reducing direct emissions and improving the incident rate of own employees" (page 47).

Outcome: "In 2025, the non-financial targets were met" - the Group ranked in the 98th percentile and 100% of the 17 priority targets were achieved, along with the remaining 21 non-priority targets (page 47). The compliance scale runs from 0% to 150% (page 47).

Executives: under the 2023 Stock Option Plan, 20% of the award depended on an average DJSI percentile above 85% for 2023-25; "the average percentile score on the DJSI was 98%, thus meeting the targets set" (page 69).

Statement on due diligence

Reference: page 48.

ACS maps the five core elements of due diligence to sections of the statement (page 48):

The Group states that it "has a Protocol for Due Diligence on Sustainability based on the 'protect, respect and remedy' pillars of the UN Guiding Principles and the six steps defined by the Organisation for Economic Co-operation and Development's Due Diligence Guidance for Responsible Business Conduct" (page 48). Supporting instruments named are the Human Rights Policy, the Environmental Policy, the Sustainable Procurement Policy, the Code of Conduct for Business Partners and the General Sustainability Policy, the last approved at the proposal of the Audit and Sustainability Committee (page 48).

"Within the framework of the preparation of the Double Materiality Matrix and after considering the risks related to the Group's sectors of activity, its geographical locations and its specific risk factors, ACS has identified certain priority areas for sustainability due diligence" (page 48).

Risk management and internal controls over sustainability reporting

Reference: pages 49-52.

"During this year, the ACS Group developed and implemented an Internal Control System over Sustainability Reporting (ICSR) for sustainability indicators, focusing specifically on environmental (ESRS E1) and social (ESRS S1) indicators" (page 49). It is designed against "the COSO Integrated Framework for Internal Control and the Guide to the Internal Control System for Sustainability Information published by the Spanish Institute of Internal Auditors (IAIE)" (page 49).

Scope: a hybrid model prioritising "The heads of the Group's main business areas (tier-1 subsidiaries)" and "A selection of tier-2 subsidiaries, considered critical due to their significant contribution to the consolidated sustainability indicators" (page 49). Supporting documents are the ICSR Management Manual, a Scoping Matrix, per-process Risk and Control Matrices and process flowcharts (page 49).

"any control deficiencies identified lead to the implementation of an action plan with designated responsible parties and deadlines" monitored by the Sustainability Department until resolved (page 50). Information is collected through an internal digital system with separate roles for entry, review and approval, reviewed first by the parent companies and then by ACS's Sustainability Department (pages 51-52).

Strategy, business model and value chain

Reference: pages 7-16.

ACS is "a global infrastructure provider and operator comprising companies across the entire value chain", with 167,803 employees at 31 December 2025 and activity in North America, Asia-Pacific and Europe (page 7).

Sales by country (page 7): United States 59.2%, Australia 17.9%, Spain 8.2%, Canada 3.4%, Germany 2.3%, United Kingdom 2.1%, and 6.9% across 33 other countries.

Segments and 2025 turnover (pages 7-8): Turner EUR 25,786 million; Cimic EUR 10,637 million (including Thiess mining services); Engineering and Construction (Dragados, Flatiron Dragados, Hochtief) EUR 10,604 million combined; Infrastructure (Iridium, ACS Digital & Energy, 50% of Abertis) EUR 250 million; Other EUR 2,570 million.

Fossil fuel exposure (page 14): Thiess "has committed to reduce its revenues from services rendered to thermal coal mining to 25% of its total revenues by 2027 and to less than 20% by the end of 2030"; in 2025 it was 26% of Thiess revenue, "representing 1.8% of the ACS Group's consolidated turnover".

The 2025 Sustainability Master Plan, approved by the Board in 2021, set 26 strategic priorities and 38 targets, 17 of them priorities (page 15); all 38 were met in 2025 (page 16).

Interests and views of stakeholders

Reference: pages 16-19; consultation method at pages 30-31.

The Group maps stakeholders into five groups with named channels and actions: clients, shareholders and investors, people (anyone working for an ACS Group company), partners and suppliers, community and environment, and governments and regulatory authorities (pages 17-18). Channels include group websites and public reports, the Ethical Channel, satisfaction surveys, labour climate surveys, health and safety committees, the General Shareholders' Meeting and the shareholder service office.

2025 consultation for the double materiality analysis (page 30): internal - surveys of 110 employees plus executive interviews and surveys; external - surveys of 25 suppliers, 9 shareholders and analysts, 17 customers, external analysis of 4 ESG ratings and 4 comparable companies. Indirect stakeholders (regulators, banks, media, civil society, NGOs, sectoral associations, universities) were considered for context (page 31).

"In 2025, the Group strengthened its consultations with stakeholders by using surveys to assess IROs directly" (page 19), with stakeholder input weighted into the Scale parameter at 70% internal / 30% consultation (page 32). "The Double Materiality Analysis is approved by the ACS Group's Audit and Sustainability Committee" (page 19).

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

Reference: pages 19-29.

Material impacts (pages 21-27) cover climate change adaptation and mitigation, energy, pollution of air, water and soil, water, direct impact drivers of biodiversity loss, impacts on the extent and condition of ecosystems, resource inflows and outflows, waste, own workforce working conditions and equal treatment, value chain workers, affected communities and indigenous peoples, consumers and end-users, and business conduct. Counting the rows gives 56 material impacts.

Material risks and opportunities (pages 28-29): 16 rows - climate transition and physical risks (including "Decrease in revenue due to the decline in contract coal mining services activities"), water access, circular economy opportunities, own workforce health and safety, and governance risks from corruption and whistleblower systems.

Three entity-specific topics are added beyond the ESRS: Donations and the ACS Foundation, Innovation and Digitalisation, and Responsible Taxation (pages 20-21).

"The analysis of the current financial effects of the company's material Risks and Opportunities indicates that there is no significant risk of a material adjustment to the carrying amounts of assets and liabilities in the next reporting period" (page 29).

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

Reference: pages 30-34; climate-specific process at pages 73-76; biodiversity at pages 102-105 and 107-108.

The process runs in four phases - context analysis, establishment of the methodology, identification of IROs, assessment - taking "the European Financial Reporting Advisory Group (EFRAG) implementation guide 'IG1 Materiality Assessment'" as a reference, with identification "based on the full list contained in ESRS 1, AR16" (pages 30-31).

Thresholds (pages 32-33):

• Impact materiality scored out of 15; "an impact is considered significant if it is >=8". Actual negative impacts score Scale + Scope + Remediability; potential impacts multiply by probability. Stakeholder consultation is weighted into Scale at 70% internal / 30% consultation, then 60% internal / 40% external.
• Financial materiality scored out of 5 (Financial Impact x Probability); "a risk or opportunity is considered material if it scores >=3". Financial impact bands are set against 2023 profit before tax of EUR 1,127 million, from "Very low (0%-0.5%) (EUR 0-6 million)" to "Very high (>5%) (>EUR 56 million)".
• "A topic is considered material when at least one IRO exceeds the established threshold" and "The score for the topic is determined by the IRO with the highest result" (page 33).

Time horizons: short under five years, medium five to fifteen, long from fifteen years to 2045 (page 5).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 34-38 (content index); pages 218-221 (Appendix B datapoints).

Listed: BP-1, BP-2, SBM-1 to SBM-3, IRO-1, IRO-2, GOV-1 to GOV-5, MDR-P, MDR-T; E1-1 to E1-8; E2-1 to E2-4; E3-1 to E3-4; E4-1 to E4-5; E5-1 to E5-5; S1-1 to S1-6, S1-8 to S1-10, S1-12 to S1-14, S1-16, S1-17; S2-1 to S2-5; S3-1 to S3-5; S4-1 to S4-5; G1-1 to G1-4 and G1-6. The EU Taxonomy and the three entity-specific topics (Innovation and Digitalisation, Donations and Foundations, Responsible Taxation) carry their own rows.

Stated deferrals: "the ACS Group has taken advantage of the regulatory measures set out in the 'Quick Fix' adopted by the European Commission on 11 July 2025 as part of the 'Omnibus Package', thereby deferring the reporting of certain disclosure requirements contained in it" (page 4). The report does not list which ones. Appendix B (page 219) marks every E1-9 datapoint "Not reported, the Group relies on the transitional provision, see section IRO-1", and marks E3-1 sustainable oceans and seas "No Material" and the two E4-2 sustainable land and oceans datapoints "Not Material" (pages 219-220).

"The ACS Group makes use of the transitional provision set out in ESRS 1, which exempts it from reporting information on upstream and downstream stages of the value chain for the first three years" (page 5).

Transition plan for climate change mitigation

Reference: pages 69-71.

"the ACS Group Climate Change Mitigation Transition Plan was developed and approved by the Group's Sustainability Department in 2024", built on the transition plans of HOCHTIEF (including Turner, CIMIC and Flatiron, 2023), Clece and Dragados (2024) (page 69). "In 2025, the Climate Change Mitigation Transition Plan was updated to include the full 2024 footprint"; a further update is planned for 2026 once the impact of Thiess is analysed, when "the targets will be analysed and revised, where and as appropriate, with a view to ensuring their compatibility with the Paris Agreement and the ACS Group's Net Zero ambition" (page 69).

Targets are "consistent with limiting global warming to 1.5C in line with the Paris Agreement", with net zero by 2045 (page 69).

Levers (page 71): Scope 1 and 2 - efficiency, fuel transition, green energy; Scope 3 - design, planning and efficiency improvements; general - training and awareness. "These levers are translated into over 30 specific measures that are implemented in hierarchical order in accordance with a set of hypotheses and scenarios based on expert judgement."

Dependencies (page 71): "compliance with these targets does not depend exclusively on these levers and actions, but also on the global context" - geopolitical developments, regulatory policies, availability of clean technologies, sectoral trends and market conditions.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 as disclosed in the E1 chapter of the FY2025 report (pages 73-76) and from ESRS 2 SBM-3 (pages 71-72). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Scenarios (pages 71-72, 75). Physical: SSP2-RCP4.5 ("representative of current trends") and SSP5-RCP8.5 ("the worst-case scenario"), with high-resolution CORDEX data from AR5, over historical (1986-2023), short (<5 years), medium (<15 years) and long term (to 2050). Transition: IEA Stated Policies (STEPS) and Net Zero Emissions by 2050 (NZE), "in line with the Paris Agreement, given that it does not exceed the 1.5C threshold", over 2022-2035 and 2035-2050.

Assumptions (page 75): "the assumptions associated with the evolution of energy consumption, emerging technologies and changes in the energy mix and the resulting opportunities for new markets, has been designed to ensure proper alignment with the macroeconomic assumptions underlying the financial statements, such as revenue and margin growth". The analysis is run annually on new projects (page 78). No global average temperature projection is given for either scenario.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (pages 71-73), with supporting material at pages 75-76. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The resilience analysis "extends to the entire value chain, considering both upstream and downstream operations" (page 71).

Results (page 72). "in certain regions, some extreme events could, in exceptional circumstances, give rise to gross risks", but adaptability factors - "passing risk on to customers, specific insurance, contractual clauses covering climate risk, specific health and safety measures, using early warning systems or physical measures against climate impacts" - "contribute to the ACS Group's lack of material net risk in the short and medium term". On transition risk, the Group "has a variety of measures... that enable it to face the possible risks of transition with guarantees in all the scenarios and time horizons analysed".

Business model (pages 72-73). Thiess is moving from thermal coal (1.8% of Group revenue) to critical minerals; 2025 sales from sustainably certified projects were EUR 19,843 million, 19.1% up on 2024, and of the EUR 92,858 million portfolio 10% came from sustainable mobility and 3% from energy infrastructure.

Uncertainty (page 73): the Group "plans to continue improving its data and information collection and updating, as well as the methodologies it uses to reduce any uncertainties".

Policies related to climate change mitigation and adaptation

Reference: page 76 (section 1.3.2, printed as "E1-2 Topics related to climate change"); policy detail at pages 52-66 (MDR-P).

The policies relied on for climate, named in the E1 actions and targets tables, are the Environmental Policy, the General Sustainability Policy and, for the risk limb, the General Risk Control and Management Policy (pages 76, 78-79, 82).

MDR-P sets out the common framework: the General Sustainability Policy "stands out for its cross-cutting nature, serving as the overarching framework for all other policies in this area", alongside the Protocol on Due Diligence on Sustainability (page 52). "Except where indicated otherwise, the policies generally apply to all of ACS's activities, and are therefore mandatory for members of ACS's governing bodies and its executives, employees, workers, temporary employees and employees under collaboration agreements, and its interns and volunteers", and Group companies "must ensure that the principles of the Policy are extended, where appropriate and to the extent necessary, to Business Partners" (page 52). "ACS's Board is the highest level responsible for supervising the implementation, development and application of the General Sustainability Policy through the Audit and Sustainability Committee", and the policies are published on the corporate website (page 52).

Actions and resources in relation to climate change policies

Reference: pages 76-81.

Five actions are described, each with linked policy, scope, horizon and progress: implementing the decarbonisation levers, risk and opportunity analysis, climate change adaptation, the transition from coal mining services to low-carbon alternatives, and reducing embodied carbon. Two are summarised here.

1. Implementing the decarbonisation levers of the transition plan (pages 76-78). Scope: the entire value chain. "In 2025 ACS Group achieved a 22.0% reduction in Scope 1 and 2 compared to the baseline year (2019) (excluding Thiess and Dornan, as they were outside the scope of the plan)." Named Scope 1 and 2 measures include awareness campaigns, monitoring in offices and on sites, offsite manufacturing, vehicle and equipment efficiency, electric and hydrogen machinery, replacement of fossil heating and cooling, own renewable generation and purchase of green energy. Scope 3 measures are mapped to GHG Protocol categories 3.1 to 3.8, 3.13 and 3.15 - embedded carbon in design, transport optimisation, business travel, commuting, low-carbon procurement, recycled and bio-based materials, and decarbonisation of investments.

2. Risk and opportunity analysis (pages 78-79). Physical climate risk is analysed annually on new activities: 81 projects in 2023, 56 in 2024 and 23 over EUR 200 million in 2025.

No monetary CapEx or OpEx amount is attached to any of the five actions.

Targets related to climate change mitigation and adaptation

Reference: pages 81-84; progress table at page 213.

Intermediate Scope 1 and 2 reductions by 2025 (page 82): ACS Group Scope 1 at least -15%, Scope 2 at least -30%; Hochtief Scope 1 -20%, Scope 2 -35%. "In 2025, total Scope 1 and 2 emissions were reduced by 22.0% compared to the base year."

Scope 1 and 2 reductions by 2030 (page 82): Scope 1 at least -35%, Scope 2 at least -60%. Absolute target values charted at page 83: Scope 1 from 541,105.90 tCO2eq (2019) to 459,940.00 (2025) and 351,718.80 (2030); Scope 2 location-based from 117,287.20 to 82,101.00 and 46,914.90.

45% of Infrastructure sales in sustainably certified projects by 2025 (page 84): baseline 34.38% in 2019; "In 2025, 45.8% of the infrastructure sales were in sustainably certified projects or equivalent requirement."

Reported progress against the 2019 reference (page 213): Scope 1 358,559 tCO2eq, -15.1%; Scope 2 100,820 tCO2eq, -39.6%; Scope 1+2 459,379 tCO2eq, -22.0%.

A 2030 waterfall chart at page 83 decomposes the pathway from 2019 and 2022 emissions through business-as-usual growth and each named lever to residual 2030 emissions. "once it has been implemented in 2026, this trajectory will be updated based on the ACS Group's carbon footprint calculated in accordance with its GHG Protocol" (page 84). No absolute Scope 3 reduction target is disclosed beyond the 2045 net-zero commitment.

Energy consumption and mix

Reference: pages 84-86.

Renewable breakdown (page 85), MWh: fuel consumption from renewable sources 75,768; renewable energy consumption 62,181; self-generated renewable energy 36,819. "Of the renewable energy consumption in 2025, 35.58% was certified (38.82% in 2024), and 21.07% was self-generated (7.10% in 2024). Furthermore, 43.35% came from biofuel consumption in 2025."

High climate impact sectors (pages 85-86). Construction: total fossil 3,213,440 MWh, energy intensity 73.6 MWh per million EUR of revenue (88.6 in 2024). Mining: total fossil 7,040,015 MWh, intensity 2,079.9 (2,185.0 in 2024). Combined 10,253,455 MWh. "Some of the ACS Group's activities are included in Sections A to H and Section L of the NACE classification, considered as high-climate impact sectors."

Renewable energy production (page 86): 791,680 MWh in 2025 (754,929 MWh restated for 2024).

The Group notes its consumption "continues to rise, in line with the growth in its operations and the expansion of its business portfolio", and that 2024 covers only eight months of Thiess against twelve in 2025 (page 85).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 86-89.

Emissions (page 86), tCO2eq; 2024 restated:

Scope 3 by category (page 86): 3.1 purchased goods and services 4,299,670; 3.2 capital goods 141,953; 3.3 fuel and energy 535,637; 3.4 upstream transport 262,260; 3.5 waste 127,024; 3.6 business travel 57,008; 3.7 commuting 164,720; 3.8 upstream leased assets 272,174; 3.13 downstream leased assets 21,120; 3.15 investments 255,612.8.

By segment, location-based (page 87): Turner & Cimic 5,443,483; E&C 2,312,330; Infra 4,543; Corporation & Others 731,797.

Method (pages 87-89): emission factors mainly Defra and the IEA, with Spanish factors from the Ministry for the Ecological Transition; a three-tier data hierarchy of primary (direct measurement, including IoT meters for concrete), secondary and estimated data. Scope 3.1 records quantities of asphalt, concrete, glass, timber, steel, cement and aggregates, and "Emissions from subcontractor works and services are assumed to be equivalent to Scope 1 and Scope 2 emissions". Spain-specific figures under RD 214/2025: 42,327.2 tCO2e Scope 1 and 4,336.6 tCO2e Scope 2 market-based (page 86).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 89-90.

The Group works in three directions (pages 89-90): natural capture through reforestation and restoration, where "the Group has a limited number of its own projects executed by Dragados based on tree planting that are certified by the Ministry for Ecological Transition" and "most of the effort the Group dedicates to this type of activity is done for customers"; carbon storage in materials, since concrete "during the curing process, absorbs CO2 through a process called carbonation, storing it throughout the lifetime of the built infrastructure"; and exploration of "various carbon capture technologies and their potential application, or carbon credits, to help meet its emissions reduction targets if the reduction measures prove insufficient".

Quantified removals (page 90): "In 2025, Dragados funded several CO2 absorption projects entailing the reforestation of forests as carbon sinks, resulting in a total of 389.5 tCO2 eq absorbed (587.79 tCO2 in 2024)."

No carbon credits cancelled in the reporting year are reported, and no breakdown of credits by quality standard or removal type is given. The figure is immaterial against total emissions of 8,492,153 tCO2eq (page 86).

Internal carbon pricing

Reference: page 90.

The Group reports that it does not yet operate an internal carbon price, and describes work in progress instead. "The ACS Group continues to make progress on developing an approach that will integrate price signals and incentives into its decision-making, to promote practices and solutions with a lower environmental footprint throughout the project lifecycle. This tool is intended as an additional fulcrum for promoting the selection of lower-emission alternatives and fostering shared responsibility across the value chain, in line with the Group's Transition Plan" (page 90).

"In 2025, through Hochtief and building on the methodological work carried out in the previous year, progress was made on designing an initial approach to domestic carbon sequestration, which is currently undergoing testing, analysis and validation through pilot initiatives" (page 90).

No carbon price per tonne, scheme type, volume of emissions covered or share of the business covered is disclosed. A separate shadow-cost methodology for abatement (EUR/tCO2e, based on structured expert judgement) is described under the transition plan at page 70, but it is presented as a lever-prioritisation tool rather than an internal carbon price.

Policies related to pollution

Reference: page 91; policy detail at pages 52-66 (MDR-P).

The pollution policy section is a cross-reference: "To implement its strategy, the ACS Group has a number of policies in place that aim at reducing the pollution from its activities, as described in section 0.5.1. MDR - P: Policies adopted to manage material sustainability matters, through which material IROs are managed" (page 91).

The policies named against each pollution action and target are the ACS Group Environmental Policy and the General Sustainability Policy (pages 91-94). The Environmental Policy is the instrument linked to every E2 target, including the ISO 14001 coverage target, the Scope 1 reduction target, the zero-severe-incident target and the landfill minimisation target (pages 93-94).

MDR-P (page 52) sets the shared scope: the policies apply to all ACS activities and bind governing bodies, executives, employees, temporary employees, interns and volunteers, with principles extended to Business Partners, and are published on the corporate website. Policy coverage of pollution is also visible in the IRO-1 cross-reference at page 91, which routes the identification process back to section 0.3.1.

Actions and resources related to pollution

Reference: pages 91-93.

"All the actions described below are linked to the targets of the 2025 Sustainability Master Plan and are carried out on an ongoing basis... All the locations and regions in which the ACS Group operates are taken into account" (p.91). Four actions are described: fuel and air-pollutant reduction, renewable electricity, waste management, and risk analysis with preventive maintenance (the last recording "0 severe environmental incidents" in 2025, page 93). Two are summarised here.

1. Reducing fuel consumption and air pollutant emissions by using modern, efficient and low- or zero-emission equipment, vehicles and construction methods (pages 91-92). Scope: own operations. Progress: "In 2025, Scope 1 emissions, excluding Thiess and Dornan, were reduced by 15.1% compared to 2019." Measures include fleet and machinery renewal, BIM-driven process optimisation and prefabricated components.

2. Use of electricity from renewable energy sources (page 92). Scope: the entire value chain. Progress: "In 2025, Scope 2 emissions, excluding Thiess and Dornan, were reduced by 39.6% compared to 2019." Combustion of petrol, diesel and natural gas "generates emissions of compounds such as sulphur oxides (SOx), nitrogen oxides (NOx) and particulate matter (PM10)".

No monetary amount of resources allocated to the pollution actions is disclosed.

Targets related to pollution

Reference: pages 93-94; progress table at page 213.

All targets are consolidated for the Group excluding Thiess and Dornan, and the value chain link is own operations (page 93).

Increase ISO 14001 certified environmental management systems (page 93). Relative target on the percentage of operations certified. Baseline 73.9% in 2019. "This rate continues to rise steadily, starting at 73.9% in 2019 and continuing to rise to 90.9% in 2025, exceeding the initially defined target."

Reduce Scope 1 emissions by 35% in 2030, with an intermediate reduction of at least 15% by 2025 (page 94). Absolute. Baseline 422,347 tCO2eq in 2019. "This target is based on science-based criteria." Performance: "In 2025, 358,559 tCO2eq were emitted, a reduction of 15.1% compared to the baseline year."

Zero environmental incidents with severe environmental damage (page 94). Absolute, no comparative baseline. "In 2025, the number of environmental incidents with severe damage was 0."

Progressively minimise non-hazardous waste sent to landfill (page 94). Baseline 21.2% in 2019. "This measurement represented in percentage was 11.3% in 2025, having decreased compared to the base year 2019."

No target is set on NOx, SOx or PM10 tonnages directly; the air-pollution target is carried through the Scope 1 fuel-combustion reduction target.

Pollution of air, water and soil

Reference: pages 95-96.

Air pollutants (page 95), tonnes; 2024 recalculated on the 2025 methodology:

Water and soil (pages 95-96). "The ACS Group's business model does not directly generate water and soil pollution in its ordinary activities. However, there is the possibility of contamination from accidental spills of fossil fuels used in operations." The potential soil contaminants are named as BTEX compounds - benzene, toluene, ethylbenzene and xylenes.

E-PRTR nil return (pages 95-96): "In accordance with the thresholds set out in the European Pollutant Release and Transfer Register (E-PRTR), no quantitative data are reported, as the applicable reporting thresholds were not exceeded during the year. Accordingly, the data for 2024, which were initially reported without taking these regulatory thresholds into account, have been restated in line with the criteria currently applied, and it has been determined that emissions were also below the established reporting thresholds." The Group adds that it still regards the matter as material "not so much because of the current impacts identified, but because of the importance the Group attaches to protecting the environment" (page 96). Appendix B lists the E2-4 E-PRTR datapoint against pages 95-96 (page 219).

Policies related to water and marine resources

Reference: pages 97-98; policy detail at pages 52-66 (MDR-P).

"To implement its strategy, the ACS Group has put a range of policies in place that directly address water management, as well as the implementation of the various strategic priorities established in relation to this issue, as described in section 0.5.1. MDR - P" (page 97). The policy named against every water action and target is the Environmental Policy (pages 98-99).

Screening support was added during the year: "the ACS Group made progress on implementing a geospatial analysis tool based on geographic information systems, which enables environmental screening of projects from the early stages. This tool integrates water stress and water risk indicators alongside other environmental factors, including biodiversity" (page 97).

Marine resources: Appendix B marks the E3-1 "Sustainable oceans and seas" datapoint (paragraph 14) as "No Material", while the E3-1 water and marine resources and dedicated policy datapoints (paragraphs 9 and 13) are referenced to pages 97-98 (page 219).

Actions and resources related to water and marine resources

Reference: pages 98-99.

"in those areas of high water stress where the Group's operations may have a significant impact, ACS pays special attention to reducing water consumption, both in its own activities and in those related to its value chain. All the actions described here are linked to the targets of the 2025 Sustainability Master Plan and are carried out on an ongoing basis" (page 98). Two actions are described.

2. Reducing water consumption through recycling and reuse (page 99). Progress: "In 2025, 2,086,986 cubic metres of water were recycled and reused (including Thiess and Dornan)." Examples given are "Reusing wastewater, such as using neutralised drilling water for compaction or dust control", recycling systems for sanitation facilities and use of stored rainwater. "Water reuse represents the greatest potential for limiting demand to the level of consumption needed, promoting recurrent uses in a circular way. This includes applications such as using water to make concrete or in processes such as cleaning and operation of sanitation facilities."

Hochtief has set out specific courses of action "aimed at, among other things, strengthening water protection in projects, monitoring water consumption, implementing protection plans in areas experiencing water stress, and promoting recycling and reuse" (page 98). No monetary amount of resources is disclosed.

Targets related to water and marine resources

Reference: pages 99-100.

Monitoring the water extracted from water-stressed areas to minimise its share (page 100). "The water abstractions in water-stressed areas are monitored annually." Again no quantified level. The underlying metric fell from 8,047,371 m3 in 2024 to 7,818,316 m3 in 2025 (page 101).

Establishing a method for calculating the water footprint (page 100). In the 2019 baseline year "there was not yet a common, agreed corporate methodology (standardised scope criteria, definitions, allocation to river basins, quality controls and comparable calculation criteria)". Performance: the Water Task Force was created in 2025 and "in 2025 the ACS Group's Corporate Protocol for Calculating the Water Footprint was drawn up, providing a common methodology for quantifying and consolidating the Group's main water flows (abstraction, consumption, discharge and recycling/reuse)". "Ahead of its rollout, the Protocol will be circulated among and reviewed with members of the Water Task Force, and will begin to be implemented in 2026."

Two of the three water targets are therefore directional rather than measurable outcome levels, and the third is a process milestone.

Water consumption

Reference: pages 100-101.

Water flows (page 101), m3; 2024 includes eight months of Thiess against twelve in 2025:

Excluding Thiess and Dornan, withdrawal was 14,195,330 m3, discharge 10,505,748 m3 and consumption 3,689,583 m3 (page 101). Water recycled and reused: 2,086,986 m3 (2,261,766 m3 in 2024).

A footnote records a material non-consumptive flow: at "Dragados's Lima Metro project (Peru), 3,130,954.66 m3 and 2,253,473.73 m3 of groundwater table water emerged in 2024 and 2025 respectively during excavation works. Practically all of it... has been returned to it in similar or better conditions" (page 101). Appendix B references the total water recycled and reused and water consumption per net revenue datapoints to page 101 (page 219).

Transition plan on biodiversity and ecosystems

Reference: pages 102-105.

"Biodiversity therefore plays an important role in its strategy and business model", with objectives "aligned with the Kunming-Montreal Global Framework and with SDG 6 and SDG 15, primarily" (page 102).

Governance and method. "the ACS Group Biodiversity Task Force was established in 2025. This task force brings together managers and experts from the Group's leading companies and serves as a technical forum for aligning concepts, methodologies and courses of action" (page 102). Following a WWF Biodiversity Risk Filter assessment in 2023, the Group "adopted the Locate, Assess, Analyse, Prepare (LEAP) methodology proposed by the TNFD in 2024", piloted it in 2024 and rolled out a screening process in 2025 (page 104).

Frameworks in development (page 103): a Biodiversity Target Framework defining common definitions and criteria, and first steps on a Certified Wood and Deforestation-Free Framework "designed to strengthen deforestation risk management and supply chain due diligence, in line with applicable EU regulatory requirements".

The plan is a methodology and governance roadmap rather than a quantified, time-bound plan: no dated biodiversity milestone, budget or no-net-loss commitment is disclosed.

Policies related to biodiversity and ecosystems

Reference: page 108; policy detail at pages 52-66 (MDR-P).

"To implement its strategy, the ACS Group has a range of policies setting out appropriate measures to mitigate the impact of its various activities on ecosystems through prevention, reduction, restoration and offsetting initiatives, particularly in the areas sensitive to biodiversity described in section 0.5.1. MDR - P" (page 108). The policies named against the biodiversity actions and targets are the Environmental Policy and the General Sustainability Policy (pages 108-113).

In projects in sensitive areas "ACS Group companies adhere to the Directives on the conservation of wild birds (2009/147/EC), the conservation of natural habitats and of wild fauna and flora (92/43/EEC) and the environmental impact assessment (EIA) of Directive 2011/92/EU", and work to comply with equivalent national or regional legislation outside the EU (pages 107-108).

Appendix B (page 220): the E4-2 deforestation policy datapoint (paragraph 24(d)) is referenced to page 108, while "Sustainable land / agriculture practices or policies" (24(b)) and "Sustainable oceans / seas practices or policies" (24(c)) are both marked "Not Material".

Actions and resources related to biodiversity and ecosystems

Reference: pages 108-112.

Four actions are described, all linked to the 2025 Sustainability Master Plan and ongoing (page 108): awareness-raising, TNFD/LEAP project-level assessment, responsible management of biodiversity on projects ("applied to 100% of the Group's projects", page 110), and preventing deforestation. Two are summarised here.

1. Promoting awareness-raising on protecting and conserving ecosystems (pages 108-109). Scope: all Group companies and the rest of the value chain. Activities range from training for ACS personnel to "early interactions with customers to analyse the implementation of measures to mitigate impacts on biodiversity". "Hochtief has published a plan entitled 'Biodiversity and Ecosystems Impacts Approach' to refine its materiality assessment", with specialists drawing up ecology reports and species conservation plans.

4. Preventing deforestation (pages 111-112). Scope: all Group companies in own operations and business partners whose contracted activity is critical for non-deforestation. Customers are encouraged to use certified wood, and business partners are monitored for compliance with the Environmental Policy and must monitor their own supply chain. A gap is disclosed: "In 2025, it was decided not to report the aggregate figure for reforested and restored hectares, as the methodology is currently under review and being improved."

Targets related to biodiversity and ecosystems

Reference: pages 112-113.

Strengthening the measures to preserve/restore biodiversity in 100% of projects in environmentally sensitive areas (page 113). Base year 2021 (the 2025 Sustainability Plan), absolute. "Hochtief and its partner companies have reached this target of having a biodiversity management plan implemented in all their projects in sensitive areas since 2023. Specifically, in 2025 the percentage of projects was 100%."

Increase the environmental management systems certified under ISO 14001 (page 113). Relative, baseline 73.9% in 2019. "This rate continues to rise steadily, starting at 73.9% in 2019 and continuing to rise to 90.9% in 2025, exceeding the initially defined target."

Zero environmental incidents with severe environmental damage (page 113). Absolute, no comparative baseline. "In 2025, the number of environmental incidents with severe damage was 0."

The Group states that no scientific basis was needed for setting the targets (page 67, MDR-T). Two of the three biodiversity targets are shared with the pollution chapter (ISO 14001 coverage and zero severe incidents), and none is an ecological state or no-net-loss target; the Biodiversity Target Framework introduced in 2025 is described as "a starting point for consistently identifying where to focus efforts and how to move towards more comparable targets and indicators" (page 103).

Impact metrics related to biodiversity and ecosystems change

Reference: pages 113-115.

Change in land use (page 114): "Hectares with land use change due to implementation of own projects (direct responsibility)" - 1.29 ha in 2025 (15.94 ha in 2024 restated). For indirect land use change "in projects executed on behalf of customers, the data are based on estimates... often made on the basis of whether the land use change is classified as greenfield or brownfield (determined by the customer)"; no indirect figure is reported.

Severe environmental incidents (page 115): 0 in both 2024 and 2025.

Sensitive areas are identified from "Protected Planet, the IUCN Red List, BirdLife International, the UNESCO World Heritage Sites, Natura 2000 protected areas, and other national legislation" (page 114), with identification the responsibility of the operational units. Restoration measures are disclosed without a figure: responsibility for the EIA "lies with the customer, who is usually responsible for its preparation and finances the restoration measures resulting from it", and work in 2026 will "standardise a common methodology for calculation and reporting" (page 115).

Policies related to resource use and circular economy

Reference: page 116; policy detail at pages 52-66 (MDR-P).

"To carry out its strategy, the ACS Group has various policies aimed at the efficient use of resources and the promotion of the circular economy, described in section 0.5.1. MDR - P: Policies adopted to manage material sustainability matters, through which material IROs are managed" (page 116). The policies named against the E5 actions and targets are the Environmental Policy, the General Sustainability Policy and, for supply chain engagement, the Sustainable Procurement Policy (pages 117-122).

The policy intent is stated at the head of the chapter: "ACS prioritises the optimisation of the resources used in its activities, minimising the associated environmental impacts and promoting practices that encourage the durability, recyclability and reuse of materials. The circular economy is positioned as an essential pillar within the ACS Group's strategy for the long-term sustainability of the infrastructures and services it offers, contributing to reducing waste, the preservation of natural resources and the generation of added value throughout the value chain" (page 116).

The IRO-1 cross-reference for this topic routes back to the SBM-3 section rather than to IRO-1: "All the information concerning IRO-1 related to this topic is provided in section 0.2.3. SBM-3" (page 116).

Actions and resources related to resource use and circular economy

Reference: pages 116-119.

1. Digitalisation of processes to optimise the resources used (pages 117-118). Scope: the entire value chain. Two tools are named. BIM creates a "Digital Twin" giving "up-to-date data on resources during construction (facilitating control over personnel, material and machinery)" and allowing simulation "from design and construction to operation, maintenance and eventual dismantling (and reuse)". Digital material passports are "digital documents that provide quantitative information on the environmental impact of a product throughout its life cycle". Progress: "in 2025, Hochtief digitally registered key construction materials in 257 active projects, representing a year-on-year increase of 67 projects (35%) compared with the previous year."

3. Promoting the use of recycled and recyclable materials (page 118). "The average proportion of recycled materials used in 2025 was 20.44% (including Thiess and Dornan)."

5. Fostering the circular economy through waste management (page 119). "In 2025, the ACS Group achieved the recovery of 86.8% of the 14,313,024 tons of waste generated by its infrastructure and services projects (including Thiess and Dornan)."

No monetary CapEx or OpEx amount is attached to the E5 actions.

Targets related to resource use and circular economy

Reference: pages 120-122; progress table at page 213.

All targets are consolidated for the Group excluding Thiess and Dornan, and the value chain link is own operations (page 120). Six targets are disclosed; the two not summarised here are minimising non-hazardous waste sent to landfill (11.3% in 2025 against a 21.2% baseline) and increasing the rate of recycled building materials (20.44% against 15.35%), at pages 120-121.

Maintain a rate of waste destined for reuse / recycling / recovery of 80% (page 120). Baseline 77.8% in 2019. The rate rose "to 87.0% in 2025, exceeding the initially defined target".

Achieve 45% of Infrastructure sales in sustainably certified projects by 2025 (page 121). Baseline 34.38% in 2019. "In 2025, 45.8% of the infrastructure sales were in sustainably certified projects or equivalent requirements."

Assessing 100% of significant direct suppliers in terms of sustainability during the Master Plan period (page 121). Baseline 93% in 2019. "In 2025, 100% of significant suppliers were assessed."

Promoting life cycle analysis in infrastructure and building projects, exceeding 200 analysed projects in 2025 (page 122). Absolute; baseline 9 projects in 2019. "In 2025, 260 life cycle analyses were carried out."

Every target was met or exceeded. None sets a level beyond 2025 (page 67), and no absolute reduction target on primary material consumption is set.

Resource inflows

Reference: pages 122-123.

Materials consumed, 2025 (page 123):

The 2024 comparatives are restated "as a result of improvements in the quality and consistency of the reported information": concrete 29,957,357 t, steel 741,594 t, aggregates 7,797,405 t, asphalt 3,034,827 t, cement 402,900 t, wood 153,750 t, glass 19,454 t (page 123).

Method (page 122): data come from "the companies' purchasing and procurement management systems, which let it identify the quantities of materials purchased for the projects. Where the information cannot be obtained through direct methods, estimation methods are applied based on the project's procurement costs and average prices of the materials used."

The certified-sustainable share is reported only for wood; for the six technical materials it is marked "n.d." (not available).

Resource outflows

Reference: pages 123-125.

Products and durability (page 124): "the products developed by the ACS Group consist of infrastructures of various types, designed under principles of circularity that promote their durability and recyclability at the end of their useful life, after they are dismantled." No quantified share of recyclable or recycled content in outputs is given, and no rate of recyclable content in products and packaging is reported.

Method (page 124): "the Group carried out an exhaustive control of the weighing of the waste generated, classifying it by type into hazardous or non-hazardous waste. In addition, the final destination of the waste is specified, differentiating between waste that has been recovered (and the type of recovery applied) and waste that has been sent to disposal processes."

Management follows the waste hierarchy: "(a) prevention; (b) preparation for reuse; (c) recycling; (d) recovery, including energy recovery; and (e) disposal", with the Group prioritising prevention and reuse and promoting recovery over disposal, "reducing not only the waste load in landfills but also the emissions from transport" (page 123).

The corresponding quantities are reported at pages 124-125 and are set out under the Waste disclosure. The resource-outflow reporting is therefore complete on waste and silent on product-level circularity metrics.

Waste

Reference: pages 124-125; Appendix B references at page 220.

Total waste (page 124), tonnes; 2024 recalculated and covering eight months of Thiess:

By operation, 2025 (page 125), tonnes. Hazardous waste diverted from disposal 47,995 (18.4%): reuse 43,754, recycling 3,715, incineration with energy recovery 180, other recovery 346. Hazardous waste to disposal 213,142 (81.6%): incineration without energy recovery 18, landfill 207,860, other disposal 5,263. Non-hazardous diverted from disposal 12,378,147 (88.1%): reuse 3,793,759, recycling 7,294,501, incineration with energy recovery 5,732, other recovery 1,284,155. Non-hazardous to disposal 1,673,740 (11.9%): incineration without energy recovery 1,039, landfill 1,613,884, other disposal 58,816.

The non-hazardous landfill rate is the tracked Master Plan metric, 11.3% in 2025 against a 21.2% 2019 baseline (pages 94, 213), and the recovery rate target of 80% was exceeded at 87.0% (page 120). Waste also drives Scope 3.5 emissions of 127,024 tCO2eq (page 86). No radioactive waste figure is reported.

Policies related to own workforce

Reference: page 146; policy detail at pages 52-66 (MDR-P); Appendix B references at page 220.

"Among the most relevant are ACS's Code of Conduct, Sustainability Policy, Occupational Health and Safety Policy, Human Rights Policy, Sustainability Due Diligence Protocol, and the Policy on Operation of the Ethical Channel detailed in section 0.5.1. MDR - P" (page 146).

The Occupational Health and Safety Policy principles are quoted in full at pages 145-146: compliance with occupational risk prevention law "and adoption of other more stringent measures in accordance with the requirements voluntarily agreed upon"; integration of prevention "into all activities and at all levels"; ongoing improvement of management systems covering employees and third parties; awareness and training for "workers, contractors and suppliers"; identification of the material resources needed; promotion of consultation and active involvement of staff and their representatives; and cooperation with customers, contractors, suppliers and specialised organisations.

Appendix B maps the EU-legislation datapoints to this section: human rights policy commitments (paragraph 20), ILO Conventions 1 to 8 due diligence (21), workplace accident prevention policy or management system (23) all at page 146, and processes for preventing trafficking in human beings (22) at page 155 (page 220). SBM-3 forced labour and child labour risk datapoints are also referenced to page 146.

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 147-148.

"The consultations are conducted in accordance with EU legislation, national legislation and collective bargaining agreements, with guarantees of confidentiality, anonymity where appropriate, and protection against reprisals" (page 147).

Quantified engagement in 2025 (page 147):

• Health and safety committees: "83.4% of the Group's employees were represented in 2025, and 98.2% of health and safety topics were covered in the 3,455 meetings held during the year", under ISO 45001.
• Workplace satisfaction surveys: "24,947 employees took part in these surveys in 2025".
• "at Hochtief, the European Works Council acts as the workers' representative in the various European countries. This body is consulted at least once a year on issues that may affect employees at the European level. Hochtief Aktiengesellschaft's Labour Director actively participates in these meetings."

Direct dialogue between employees and managers is promoted "through regular interviews, providing a space for expressing concerns and proposing improvements", and "Each ACS Group company has its own processes and departments that manage relations with the Group's employees" (page 147). No single global operational owner of the engagement function is named for own workforce.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: pages 147-148; channel mechanics at pages 189-191.

Remediation steps when a proven negative material impact is identified (page 148):

1. "Determination of the impact's origin and responsibility", collaborating in judicial or extrajudicial proceedings where necessary.
2. "Restitution and reparation: Whenever possible and legally enforceable, the aim is to restore the affected parties to the state they were in before the impact, guaranteeing reparation proportional to the severity of the damage. The measures may include apologies, rehabilitation, financial or non-financial compensation, and preventive actions."
3. "Corrective action plans: If the impact cannot be eliminated, specific action plans are implemented with defined timelines and clear metrics."
4. "Management of impacts associated with business partners", adjusted to the level of influence and control.

The channel allows anonymous reports, is operated through external provider Whistleblower Software, and guarantees "that there will be no reprisals and/or prejudicial conduct against the whistleblower" (page 190). Appendix B references the S1-3 grievance and complaints mechanisms datapoint (paragraph 32(c)) to pages 147-148 (page 220).

Taking action on material impacts on own workforce

Reference: pages 148-155.

Health and safety (pages 149-151): "In 2025, the ACS Group companies' investment in Health and Safety amounted to EUR 221.2 million (including Thiess and Dornan)." Certified systems cover 100% of employees externally certified and ISO 45001 reaches 97.9%; internal audits cover 99% of employees. Hazard reporting tools include Dragados' "Blue Cards", CIMIC's Safety Leadership Score and the new "One Voice" tool. "In 2025, 100% of the employees had received training in Health and Safety during their career."

Wellbeing (page 152): Clece Wellbeing, the Take Care project, "Networked Care" free psycho-emotional support, Sonder and Telus Health at Sedgman, and UGL's Peer Support Programme.

Equal opportunities and inclusion (pages 152-153): "the number of women in management positions in the Group represented 21.8% of the total and the number of women in management positions was 207"; "99% of the Group's employees come from the local community"; "the number of employees from vulnerable groups was 12,991". Clece "contributed to 1,191 organisations: 831 social organisations, 266 local authorities and 94 training centres".

Human rights due diligence (page 155): "100% of the Group's own operations have been assessed in relation to human rights (excluding Thiess and Dornan, as they fell outside the scope of the Plan, although 100% of Thiess's operations have been assessed)."

Targets related to own workforce

Reference: pages 155-157; progress table at page 213.

Exceed 97% of employees subject to certified health and safety management systems by 2025 (page 156). Absolute; baseline 90.6% in 2019. "This rate started at 90.6% in 2019 and continued to rise to 97.7% in 2025."

Decrease the lost time injury frequency rate for own workers by 15% compared to 2019 (page 156). Baseline LTIFR 14.36 consolidated (2.65 infrastructure development, 27.04 Clece). "The figure for 2025 was 11.07, excluding Thiess and Dornan, compared with 14.36 in 2019, which implies a reduction of 22.9%... By segments, in infrastructure development the figure for 2025 is 1.71, and for Clece it is 20.23." The Group explains the split: Clece employees "have many musculoskeletal incidents with a lower severity" (page 156).

Increasing the number of employees from vulnerable groups by 7% compared to 2020 (page 157). Baseline 9,819 in 2020. "The number of workers from vulnerable groups was 2025 in 12,476, an increase of 27.1% compared to 2020." (The sentence is garbled in the translation; the annex at page 213 gives 12,476 for 2025 against 12,419 in 2024.)

Evaluating 100% of own HR operations by 2025 (page 157). Baseline 58% in 2019. "This rate continues to rise steadily, starting at 58% in 2019 and continuing to rise to 100% in 2025."

All five were met. None extends beyond 2025; new targets were still being assessed at the reporting date (page 67).

Characteristics of the undertaking's employees

Reference: pages 158-161.

"At the close of 2025, the ACS Group had 167,803 employees. The ACS Group's workforce increased by 6% to 9,998 employees, 1,342 of whom come from the 2025 consolidation of Dornan by global integration." Infrastructure development accounted for 78,744 people and Clece for 89,059 (page 158).

By gender (page 158): male 83,437; female 84,365; other 1; total 167,803 (2024: 75,693 / 82,102 / 9).

By country (page 158): Spain 86,216; Australia 21,776; United States 19,391; India 11,724; United Kingdom 6,983; Indonesia 4,630; Germany 3,654; rest of world 13,429.

By contract type at 31 December 2025 (page 159): fixed 126,758 (61,035 male / 65,722 female); temporary 32,880 (19,644 / 13,236); non-guaranteed hours 8,165 (2,758 / 5,407). Full-time 112,566 (75,209 / 37,356); part-time 55,237 (8,228 / 47,009). Breakdowns by age band and by professional category are also given.

Absenteeism (page 161): 21,311,393 hours lost (19,393,775 restated for 2024).

Scope is "100% of the consolidation perimeter in line with the financial information disclosed in the annual financial statements", with headcount at year end and data drawn from HR and payroll systems via standardised questionnaires (page 158). The 2024 comparatives are restated to include joint venture and joint operation employees pro rata, and to add Turner trade union employees (page 158).

Collective bargaining coverage and social dialogue

Reference: page 161; related action at page 148.

"By country, in companies headquartered in Spain, the number of employees covered by collective agreements or by an independent trade union was 100% in 2025 (100% in 2024)" (page 161).

The supporting action adds the social dialogue limb: "in accordance with current legislation and where relevant, companies in the ACS Group maintain regular dialogue with employee representatives regarding working conditions, with a view to fostering communication, consultation and the search for mutually agreed solutions on matters of common interest" (page 149). Representation is also evidenced through health and safety bodies - "83.4% of the Group's employees were represented in 2025, and 98.2% of health and safety topics were covered in the 3,455 meetings held during the year" - and through Hochtief's European Works Council, which "is consulted at least once a year on issues that may affect employees at the European level" (page 147).

Coverage is reported as a single Group percentage plus the Spanish figure; the disclosure does not give a full country-by-country or EEA-region breakdown of collective bargaining coverage, nor a separate percentage of employees represented by works councils. A material positive impact is recorded for this sub-topic: "High proportion of workers covered by collective agreements" (page 23). Coverage fell 2.6 percentage points year on year.

Diversity metrics

Reference: page 161; supporting figures at pages 152-153, 157-158.

Wider management: women held 200 management positions two levels below the CEO in 2025, 22.8% of the total, up 115.1% from 93 in 2019 (page 157); including Thiess and Dornan the figures are 207 positions and 21.8% (page 152).

Workforce age distribution (page 159), total employees: under 30 - 27,790; 30 to 50 - 79,950; over 50 - 60,063 (derived from the fixed, temporary and non-guaranteed-hours contract tables). Gender split of the whole workforce (page 158): 83,437 male, 84,365 female, 1 other.

Board diversity (pages 40-41): 6 of 14 directors were women, 42.86%, "amply complying with the recommendations of good governance in this respect and with the requirements of section 529 bis of the Spanish Corporate Enterprises Act... as amended by the Equal Representation Act 2/2024 of 1 August, even though that law will not apply to the Company until 30 June 2026". Appendix B references the GOV-1 gender diversity datapoint to pages 40-45 (page 218).

The S1-9 section itself is brief - a single paragraph of policy language plus the senior management figure - with the age distribution of employees disclosed under S1-6 rather than here.

Adequate wages

Reference: page 161; supporting action at page 148.

The analysis is described as a 2025 action: "In 2025, the ACS Group analysed whether its employees receive adequate pay in accordance with the criteria described in Annex I on the European Sustainability Reporting Standards (ESRS) of Delegated Regulation (EU) 2023/2772. As specified in section 7.3.5 of this report, following this analysis, it has been determined that all Group employees receive adequate wages. Compliance with this requirement will continue to be monitored" (page 148). The linked policy is the Human Rights Policy, and progress is recorded as "In 2025, the existence of adequate wages in all ACS Group companies was assessed" (page 148).

This is a full positive return rather than a partial one: because all employees are paid at or above the applicable adequate wage benchmark, no percentage of employees paid below it is disclosed, and no country is identified as an exception. The disclosure does not name the specific benchmarks used per country, nor give the reference wage levels against which the comparison was made.

A corresponding material positive impact is recorded in the double materiality analysis - "Adequate wage policies for own employees", an actual positive impact in own operations under the Working conditions sub-topic (page 23) - and the equivalent commitment for value chain workers appears as "Adequate salary policies including value chain workers" (page 24).

Persons with disabilities

Reference: pages 161-162.

"The ACS Group is committed to the employment integration of people with disabilities and other vulnerable groups, and uses employment as an instrument for social inclusion. At year-end, the ACS Group had 9,749 disabled employees (8,830 in 2024) and 3,242 employees from other vulnerable groups" (page 161).

"Furthermore, companies accounting for 100% (100% in 2024) of the Group's workforce have universal accessibility systems in place" (page 162).

The supporting action sits under S1-4: Clece "has worked in coordination on this project since 2012, employing people with disabilities, victims of gender violence, people at risk of social exclusion and young people in high unemployment", and "companies that represent most of the Group's employees have implemented systems that guarantee universal accessibility for people with disabilities, with infrastructure adapted to remove physical barriers for all people" (page 153). The total for all vulnerable groups was 12,991 including Thiess and Dornan (page 152) and 12,476 on the Master Plan basis, a 27.1% increase on the 2020 baseline of 9,819 (page 157).

A material positive impact underpins the disclosure: "Increase in the labor inclusion of people with disabilities through the removal of barriers and the creation of accessible employment opportunities" (page 23). The figure is not broken down by gender.

Training and skills development metrics

Reference: page 162; training actions at pages 153-154.

Average hours per employee (page 162): "the average number of training hours per employee was 13.6 hours (19.3 average hours for all employees and 8.0 average hours for all female employees), while in 2024 the figures were: 12.9 hours on average for all employees (an average of 19.0 hours per male employee and 7.2 per female employee)". By segment: Infrastructure 22.1 hours (21.8 male, 22.3 female); Services 6.1 hours (9.2 male, 5.3 female).

Hours by professional category (page 162): graduates with intermediate and university degrees 745,832; non-qualified technicians and administrative staff 329,431; other staff 1,207,854; total 2,283,115.

The Group attributes the gender gap in hours to "differences in the type of work, specialisation or the requirements needed to develop the individuals' skills" and adds that "When the figures are restated on an aggregate basis, as required, the results are not representative" (page 162). "Standardised measures for the Group-wide periodic performance and professional development reviews are currently being assessed through the ACS University platform" (page 162). The average-hours figures for male and female employees are labelled inconsistently in the translation, so the male figure should be read as the 19.3 hours quoted.

Health and safety metrics

Reference: pages 162-165; Appendix B references at page 220.

Metrics (pages 163-165), 2024 then 2025:

• Recordable work-related injuries: 4,869 / 5,206 (male 1,583, female 3,623; Infrastructure 502, Clece 4,704)
• Cases of work-related ill health: 1,953 / 1,855
• Fatal work-related injuries, own employees: 1 / 0
• Fatal work-related ill health, own employees: 0 / 0
• Fatal work-related injuries, own contractors: 3.35 / 3.00
• Total hours worked: 252,292,393 / 265,804,786
• Days lost to work-related injuries: 67,535 / 78,187
• Days lost to work-related ill health: 33,094 / 32,684
• Injury frequency rate per million hours: 19.30 / 19.59 (Infrastructure 3.09, Clece 45.60)
• Injury severity rate: 0.27 / 0.29
• Ill health frequency rate: 7.74 / 6.98

A footnote explains the fatality basis: "Since 2024, we have begun using CSRD criteria for reporting, under which both our own employees and contractors who are part of a joint operation are accounted for at the same percentage as our stake in the joint operation. If we had continued to use the reporting criteria from previous years (counting the number of people), there would have been 4 fatalities in 2024 and 3 in 2025" (page 165). The Group attributes Clece's higher rates to constant travel between work sites and the nature of the work (page 163).

Compensation metrics (pay gap and total compensation)

Reference: pages 165-168; Appendix B references at page 220.

ESRS pay gap (page 167). "for 2025, the pay gap was calculated in accordance with the requirements of the ESRS: i.e., by including in a single figure the difference between the average hourly pay level of male employees and the average hourly pay level of female employees... in 2025, the wage gap in infrastructure development activities stands at 2.4% (compared with -1.1% in 2024) and at -16.4% at Clece (versus -13.7% in 2024)." The Group declines to give a consolidated figure: "it is not meaningful to analyse the consolidated data because of the differentiation of activities and the resulting average wages."

Average annual remuneration by category (page 166), EUR, male / female / gap: senior management and graduates 115,479.4 / 89,986.9 / -22.1%; non-qualified technicians and administration 73,482.4 / 52,009.4 / -29.2%; operators in Construction and Concessions 39,830.5 / 49,520.4 / +24.3%; in Services 23,155.3 / 20,184.1 / -12.8%. New for 2025, pay is also broken down for Spain, the United States and Australia, "more than 75.9% of the Group's employees" (pages 166-167).

No total compensation ratio (CEO pay ratio) is disclosed. Appendix B references the excessive CEO pay ratio datapoint to pages 165-168 without giving a figure (page 220). "The Executive Directors of the ACS Group are all men" (page 168).

Incidents, complaints and severe human rights impacts

Reference: page 169; Appendix B references at page 220.

• "448 discrimination complaints, including harassment cases, which were received through the Group's ethical channels and through other means (directly through human resources or specific channels for this purpose)."
• "In addition, 562 reports on other issues were received through the Group's ethical channels and by other means."

"In 2025, there were no serious human rights incidents. No sanctions were imposed in connection with these complaints and reports" (page 169).

The handling route is described under S1-3: complaints reach the Ethical Channel operated through external provider Whistleblower Software, are triaged and investigated under the direction of the Governance and Compliance Committee in four phases aligned to ISO 37002:2021, with anonymity, confidentiality and protection against reprisals (pages 189-190). Where a proven material adverse impact is identified, restitution "may include apologies, rehabilitation, financial or non-financial compensation, and preventive actions to avoid future incidents" (page 148). Related material impacts recorded in the DMA are "Vulnerability in the working environment due to insufficient measures against violence and harassment" (page 24) and the opportunity of "Greater attractiveness as an employer by implementing effective measures against inequality and harassment" (page 29).

Policies related to value chain workers

Reference: page 171; policy detail at pages 52-66 (MDR-P); Appendix B references at pages 220-221.

The Code of Conduct for Business Partners, "updated in latest version on 19 December 2024", "outlines the basic principles that must govern the relationship between the Business Partners and the ACS Group" (page 193). The Sustainable Procurement Policy, approved in 2024, "establishes ACS's basic principles of action and guidelines for behaviour, applicable to the entire Group, in the processes of purchasing goods and services" and "establishes measures to avoid delays in payments to suppliers" (page 193).

Appendix B maps the EU-legislation datapoints to this page: S2-1 human rights policy commitments (paragraph 17), policies related to value chain workers (18), non-respect of UNGPs on Business and Human Rights and OECD guidelines (19) and ILO Conventions 1 to 8 due diligence (19), all at page 171, with the SBM-3 significant risk of child or forced labour in the value chain datapoint at page 170 (pages 220-221).

Policies are extended downward: "Business partners must, in turn, align themselves with the ACS Group's Corporate Due Diligence approach, and comply with its Sustainability, Human Rights and Environmental policies" (page 172).

Processes for engaging with value chain workers about impacts

Reference: pages 171-172.

"The Corporate Due Diligence Protocol, updated on 19 December 2024, established procedures to identify and address human rights and environmental impacts that may affect both the ACS Group and the workers in its value chain, including vulnerable groups" (page 171).

Operational responsibility is named. "The Group's Sustainability Department is the department with operational responsibility for ensuring that this collaboration takes place and that its outcomes form the basis for the Group's due diligence approach, including prioritising areas of greatest exposure, defining action plans, and implementing monitoring and management measures with business partners. The Board, through the Audit and Sustainability Committee, is also responsible for generally supervising the approach" (page 171).

Pre-project safety induction is the one direct channel described: "the ACS Group establishes a training system before the start of its projects, where they are informed about the safety, health risks and operating procedures related to the project" (page 173).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: pages 171-172.

"ACS tracks the reports received from value chain workers on an individual basis, monitoring their progress until their resolution, and incorporates performance indicators (such as the number of cases closed, response times and recurrence rates) to assess the effectiveness of the channels and the corrective measures taken, reviewing these results periodically within the framework of the Global Compliance Management System and the Sustainability Department" (page 171).

Contractual leverage (page 172): "the contracts with the Group's business partners include clauses that allow for the monitoring of their due diligence approach. These clauses provide for the possibility of temporarily suspending or terminating the business relationship if any adverse impacts are not adequately managed, always assessing the impact of those decisions and giving reasonable notice to the business partner." Business partners are obliged to make workers aware of the channels: "Workers in the value chain are required to understand and avail themselves of the available reporting channels" (page 172).

No count of reports received from value chain workers in 2025 is disclosed, and no figure is given for the performance indicators the Group says it tracks.

Taking action on material impacts on value chain workers

Reference: pages 172-173; supplier process detail at pages 193-195.

1. Processes for selecting, assessing, approving and auditing value chain partners (page 172). "During 2025, 99.0% of the Group's significant suppliers (including Thiess and Dornan) and 46% of its new suppliers were assessed for their sustainability... 100% of the significant suppliers were assessed during the period of the Sustainability Master Plan, excluding Thiess and Dornan." The processes "are designed to ensure their compliance with the ACS Group's minimum standards in terms of health and safety, diversity and equality, considering the workers in the value chain with the same level of stringency as for its own employees". "the audits identify possible deviations and assess the effective implementation of responsible practices and necessary corrective actions, establishing improvement plans in collaboration with the supplier."

Appendix B references the S2-4 datapoint on "Human rights issues and incidents connected to its upstream and downstream value chain" (paragraph 36) to pages 172-173 (page 221); no incident count is given there. No monetary amount of resources is disclosed.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: pages 173-174; progress table at page 214.

75% of significant suppliers trained in the Business Partner Code of Conduct by 2025 (page 174). "The base year is 2019, when this indicator was not tracked." Performance: "By 2025, 81.6% of the Group's significant suppliers had been trained." The annex records the progression as 6.0% reference, 66.8% in 2024 and 81.6% in 2025 (page 214).

Assessing 100% of significant suppliers in terms of sustainability during the period of the Plan (page 174). Baseline "93% of the critical suppliers were assessed" in 2019. "This figure reached 100% in 2025." The annex shows 85.6% in 2024 rising to 100% in 2025, measured as the percentage of significant direct suppliers evaluated in the last three years (page 214).

Improving the accident rates of subcontractors by training them (page 174). "The base year is 2019, when the contractor frequency rate, considered as the number of lost-time accidents of subcontractors per million hours worked, was 3.56." Performance: "The 2025 frequency rate (excluding Thiess and Dornan) was 31.1% lower than in 2019."

None of the three targets addresses wages, working hours or freedom of association in the value chain, and none extends beyond 2025; new targets were still being assessed at the reporting date (page 67).

Policies related to affected communities

Reference: pages 175-176; policy detail at pages 52-66 (MDR-P); Appendix B references at page 221.

"To carry out its strategy, the ACS Group has various policies aimed at promoting respect for human rights and access to information for local communities, and at preventing and managing impacts on indigenous peoples, through which material IROs are managed. Among the most significant are the Code of Conduct, the General Sustainability Policy, the Human Rights Policy, and the Sustainability Due Diligence Protocol" (page 175).

Free, prior and informed consent (page 176): "If indigenous communities hold rights over the land on which a project's activities are to be carried out, that indigenous community's right to free, prior and informed consultation and consent must be honoured. The application of this commitment will follow the guidance offered by the United Nations Office of the Commissioner of Human Rights."

Grievance outcome (page 175): "In 2025, no firm convictions were reported in relation to violations of the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises involving affected communities." Appendix B maps the S3-1 human rights policy commitments datapoint (paragraph 16) and the non-respect of UNGPs, ILO principles or OECD guidelines datapoint (17) to pages 175-176 (page 221).

Processes for engaging with affected communities about impacts

Reference: page 176.

"ACS works closely with the customer at this stage, proposing alternative solutions to minimise the environmental and social impacts, favouring a positive resolution of the EIA and providing added value to local communities" (page 176).

Operational responsibility: "The Group's Sustainability Department is responsible for overseeing these processes and coordinating with the various Group companies to manage the identified impacts and implement preventive and corrective measures" (page 176).

Indigenous peoples (page 176): "Where any of our Group entities are the direct owner of applicable land or where it is asked to assist with the FPIC processes by our clients, it will be encouraged and supported that appropriate consultation processes are followed. In all other cases, appropriate actions will be taken to support client-led efforts for free, prior and informed consent... For Indigenous communities, consultation will be conducted in good faith, with the goal of cooperative development as an indication of consent."

The disclosure is candid about the limit on ACS's own agency - the EIA and consent process usually belong to the client - and does not report how often engagement took place or how many communities were consulted in 2025.

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 176.

"During the construction phase, local communities, including indigenous peoples and other stakeholders, can voice their concerns through the ACS Group's Ethical Channel, as explained in section 11.2.2. G1-1... The submissions received are assessed in detail and, where necessary, specific measures are taken to address and remedy any negative impacts. If a proven current material negative impact is identified, the ACS Group takes the measures set out in its Corporate Sustainability Due Diligence Protocol" (page 176).

"The information gathered through these mechanisms is analysed to identify areas for improvement and assess the effectiveness of the measures taken, and is incorporated into the internal processes on impact management and continuous improvement" (page 176).

"In short, the ACS Group promotes active collaboration, attentive listening and effective restitution of negative impacts, consolidating its commitment to sustainable development and respect for the rights of the communities affected by its activities" (page 176).

No count of community complaints received or resolved in 2025 is reported, and the statement does not say whether affected communities are aware of and trust the channel, which the DR asks about. The nil return on convictions is given instead (page 175).

Taking action on material impacts on affected communities

Reference: pages 177-178; Appendix B reference at page 221.

1. Generating value through active listening to local communities (page 177). "In 2025, the ACS Group's funds allocated to Social Action amounted to EUR 15.9 million (including Thiess and Dornan)." ACS "collaborates with local associations, NGOs, public and private organisations, as well as companies that promote social action", using direct and indirect sources to identify community needs and feed them into the social action strategy.

2. Encouraging companies to buy local (page 177). "In 2025 the percentage of local workers was 98.5%, with 82.9% local suppliers (including Thiess and Dornan)." "in using building materials, one of the Group's main inputs, the use of local suppliers or suppliers whose facilities are located in the immediate vicinity of the projects is actively encouraged. This not only creates shared value in the community, but also helps reduce transport costs and emissions."

Appendix B references the S3-4 "Human rights issues and incidents" datapoint (paragraph 36) to pages 177-178 (page 221). Social action funds fell from EUR 16.2 million in 2024 to EUR 15.9 million in 2025 against a EUR 12.1 million reference value (page 213).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: pages 178-179.

Keep local suppliers above 75% (page 179). Linked to the Code of Conduct for Business Partners. No baseline, implemented in 2021. Performance: "By 2025, 88.2% of the suppliers were local suppliers (excluding Thiess and Dornan)." The figure including Thiess and Dornan is 82.9% (page 177).

Increasing the number of employees from vulnerable groups by 7% compared to 2020 (page 179). Baseline 9,819 in 2020. Performance: "In 2025, the number of employees from vulnerable groups, including people with disabilities (which in Clece includes people at risk of social exclusion, women victims of gender-based violence and the long-term unemployed; and in Cimic includes employees from Cimic's indigenous communities) was 12,476: a 27.1% increase versus 2020 (excluding Thiess and Dornan)."

None of the three addresses the two material negative impacts on communities recorded in the DMA - "Community safety concerns due to construction in urban areas" and "Disprotection of the rights of indigenous peoples due to the lack of participation and information about the projects" (page 25). The targets measure local hiring, local procurement and vulnerable-group employment, which map to the positive impacts rather than to the negative ones.

Policies related to consumers and end-users

Reference: pages 180-181; policy detail at pages 52-66 (MDR-P); Appendix B references at page 221.

"The ACS Group has, among others, a Code of Conduct, a General Sustainability Policy, a Human Rights Policy, a Data Protection Policy and the Information Security Policy, which promote the protection of consumers and end-users, including the protection of their data, respect for their human rights and ensures the quality of the services the ACS Group offers" (page 180).

The Information Security Policy, "effective from 19 December 2024", was approved by the Board and "forms the 'cornerstone' of the Information Security Management System (ISMS)", setting out principles "to safeguard the confidentiality, integrity, availability, authenticity and traceability of information and of the networks and systems that support critical processes" (page 192).

Appendix B maps the S4-1 datapoints - policies related to consumers and end-users (paragraph 16) and non-respect of UNGPs on Business and Human Rights and OECD guidelines (17) - to pages 180-181 (page 221). The two material IROs underpinning the chapter are the negative "Vulnerability in data security due to unauthorized access to confidential information resulting from security breaches" and the positive "Improved well-being, safety, and equal treatment of customers and end users thanks to the high quality of the services provided by Clece" (page 25).

Processes for engaging with consumers and end-users about impacts

Reference: pages 181-182.

"The Sustainability Due Diligence Protocol sets out the procedure for engaging with stakeholders, including customers and end-users, and defines the functioning of the Sustainability and Compliance Department" (page 181).

The mechanisms are structured around two subgroups (pages 181-182):

"To address any concerns during the provision of its services, the Group offers its Ethical Channel, which is accessible and confidential, allowing direct communication between customers and the ACS Group" (page 181).

At Group level, satisfaction measurement is the principal listening instrument: "most of its companies have a defined system for measuring customer satisfaction, while those with a more direct relationship with end users, such as Clece, have established formal systems for measuring customer complaints and claims... these systems are mainly managed using personalised tracking systems" (page 183).

"In line with its social commitment, the ACS Group pays special attention to the needs of customers and end users in vulnerable situations, guaranteeing they have equitable, safe and respectful access to the services provided by the Group" (page 182). No frequency of engagement or count of users consulted is reported.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: pages 181-182.

"The Ethical Channel is a cornerstone of communication with customers and end users. Details of how this channel operates, along with an explanation of how complaints are handled and the channel's effectiveness, are set out in section G-1 of this report" (page 182).

Volume and resolution (page 183): "In 2025, throughout the ACS Group, 3,061 complaints were received: 97.3% of which were resolved in the reporting year. In 2024, 2,540 complaints were received, 95.0% of which were resolved." This is the one quantified measure of channel effectiveness for this stakeholder group, and both volume and resolution rate rose year on year.

The Ethical Channel mechanics are set out at pages 189-191: external operation through Whistleblower Software, anonymous reporting with traceable two-way contact, alignment with Spanish Whistleblower Protection Act 2/2023 and Directive (EU) 2019/1937 and with ISO 37002:2021, a four-phase process of receipt, triage, handling and resolution, and a guarantee of no reprisals.

"During the reporting period, there were no serious incidences regarding the human rights of consumers and end-users" (page 182). The statement does not report whether consumers and end-users are aware of and trust the channel, nor break the 3,061 complaints down by subject or business.

Taking action on material impacts on consumers and end-users

Reference: pages 182-183.

Two actions are described, both ongoing (page 182).

1. Cybersecurity and data protection (pages 182-183). Linked to the Data Protection and Information Security Policy and to the S4-5 cybersecurity targets; scope: the entire value chain. "an Information Security Master Plan has been developed with strategic targets to anticipate, detect and respond to potential threats" (page 183). The underlying measures (pages 192-193) cover network redesign, isolating critical infrastructure from the internet, mobile device management, security event monitoring, internal audits and tested disaster recovery plans, with preparation for ISO 27001 certification under way.

2. Social Innovation Projects at Clece (page 183). Scope: downstream in the value chain. "Clece has completed an in-depth study on unwanted loneliness among elderly people who are dependent", producing "the AURORA Questionnaire, a specific tool for identifying instances of unwanted loneliness among the care-dependent". Separately, "Throughout 2025, Clece provided its Home Help Service assistants specific training sessions on gender-based violence against elderly women".

"During the reporting period, there were no serious incidences regarding the human rights of consumers and end-users" (page 182). No monetary resources figure and no count of people reached is given.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: pages 183-184.

Cybersecurity Recovery Plan (page 184). Target level "Business critical infrastructure"; scope "100% of services considered business critical"; period 2024-2025. The baseline row reads "2025 final dividend", which appears to be a translation or template error; no performance figure is given against this target.

Promoting Information Security awareness initiatives and increasing the number of trained employees (page 184). "There is no target level. The aim is to increase the number of trained employees annually." Scope: "all employees of the Group with responsibility for cyber security". Baseline 13,868 employees trained in 2019. Performance: "In 2025, the number of employees trained in the reporting year was 41,036 (excluding Thiess and Dornan), compared to 13,868 in the base year. It is important to consider that although cybersecurity is an important subject for the ACS Group, not all of the Group's employees need this type of training due to their functions."

Two of the three targets have no measurable level, and none addresses the positive impact recorded for service quality and the wellbeing of Clece's end users (page 25). Customer complaint resolution, at 97.3% of 3,061 complaints (page 183), is reported as a metric rather than as a target.

Business conduct policies and corporate culture

Reference: pages 186-193; Appendix B references at page 221.

Double Risk Control Model (pages 187-188). A homogeneous standards system aims to ensure "that all Group subsidiaries have a certified compliance management system or, at least, one that can be understood as certifiable", supported by half-yearly monitoring. The Global Compliance Report, designed in 2019, had 17 sections in its December 2025 version, from criminal compliance and anti-bribery through competition, cybersecurity, data protection, environmental and human rights due diligence to tax compliance and corporate governance, and "allows for an annual risk score card in all reported compliance areas".

Ethical Channel (pages 189-191). Aligned with Spanish Whistleblower Protection Act 2/2023, Directive (EU) 2019/1937 and ISO 37002:2021, with "a broader protection regime than the laws cited above". It permits anonymous reporting via external provider Whistleblower Software, runs a four-phase process, and guarantees no reprisals. Whistleblowers may also request a face-to-face meeting with the Governance and Compliance Committee "within seven (7) days" (page 191).

Appendix B maps the UN Convention against Corruption datapoint (paragraph 10(b)) and the protection of whistleblowers datapoint (10(d)) to pages 186-193 (page 221).

Management of relationships with suppliers

Reference: pages 193-195.

"Supply chain management is one of the main material issues for the ACS Group" (page 193). The governing instruments are the Code of Conduct for Business Partners, updated on 19 December 2024, and the Sustainable Procurement Policy, approved in 2024, which "establishes measures to avoid delays in payments to suppliers, complying with the payment deadlines under each applicable law, and to resolve disputes or claims related to payments" (page 193).

Consequences (page 195): where deficiencies are found "corrective measures will be agreed with them to address these deficiencies within a set period of time. If these are not remedied, the Organisation will consider suspending or terminating the business relationship, after considering the adverse impacts that could result." "Serious breaches can lead to the immediate termination of contracts." Audits are "occasionally... random audits by internal auditors or independent third parties"; the number carried out in 2025 is not reported. "The ACS Group has a decentralised structure... each one manages its own procurement with its own independent management systems" (page 193).

Prevention and detection of corruption and bribery

Reference: pages 195-197.

The Code of Conduct and General Compliance Policy "are supplemented by the Criminal and Anti-Bribery Compliance Policy, the Policy on Compliance with International Sanctions imposed on third parties, the Policy on Gifts and Hospitality as well as the Policy on Relations with Public Officials and Equivalents, revised by the Board on 19 December 2024" (page 195). The set "is aligned with national standard UNE 19601:2017 on criminal compliance management systems, and international standard ISO 37001:2021 on anti-bribery management systems", with AENOR certificates on the website (pages 195-196). "the specific risk matrices... were updated and reassessed in 2025" (page 196).

Independence (page 196). Reports reach the Ethical Channel and "will be processed and investigated at the direction of the Governance and Compliance Committee, in accordance with criteria of impartiality, specialisation and knowledge of the matter", escalating to Senior Management or, depending on type, to the Board.

Training (pages 196-197). Training is differentiated by role for those "exposed to Compliance Risks rated higher than low", with documentary records kept. Coverage: "100% of employees with responsibility for compliance, including those in positions that entail risks of corruption and bribery, are covered by training programmes" (page 197). No breakdown by employee category is given.

Targets related to business conduct

Back-filled from the business conduct chapter and the Sustainability Master Plan monitoring annex, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Business conduct targets are disclosed. MDR-T at page 67 states that "All the targets are set out in the relevant thematic chapters of this report, together with all the requirements specified in the MDR-T Data Requirements", that the targets "are set out in the Sustainability Master Plan", that "The base year considered for these objectives is 2019, and their time horizon extends to 2025", and that "no scientific evidence was used to identify the targets, as they do not require a scientific basis for their establishment or interpretation".

All 17 priority targets were met, and the Group states that "100% of the 17 priority targets set out in the 2025 Sustainability Master Plan were met... as well as the remaining 21 non-priority targets" (page 47).

No target is set on corruption incidents themselves, and none extends beyond 2025: "With the completion of the 2025 Plan, the Group is now working on assessing new sustainability targets" (page 67).

Incidents of corruption or bribery

Reference: page 197; Appendix B references at page 221.

Supporting context on detection sits in G1-1 and G1-3. The Ethical Channel received reports in 2025 that are counted under the own-workforce disclosure - "448 discrimination complaints, including harassment cases" and "562 reports on other issues" - with the statement that "No sanctions were imposed in connection with these complaints and reports" (page 169). The Audit and Sustainability Committee monitors "the activity of the Ethical Channel" and the main compliance risks, and was briefed on 27 February 2025 on "the Independent Expert's Report on compliance with all the objectives of the Global Compliance Management System approved by the Governance and Compliance Committee for 2024", and on 30 July 2025 on the half-yearly Compliance Report (pages 46, 188).

The Group also notes that it "was informed of the measures taken to manage risk through the criminal compliance and anti-bribery management model implemented across all the divisions worldwide, as well as the corrective actions undertaken in this regard and the identification of new risks" (page 46). The disclosure does not separate legal proceedings outstanding at the year end from incidents confirmed during the year, because there were none of either.

Payment practices

Reference: page 197.

"Since the ACS Group operates in various legal jurisdictions and in various business segments, there are no standard payment terms across the ACS Group. However, as reflected in the commitments of the Sustainable Procurement Policy, with regard to payments to suppliers, regardless of the type of supplier, the payment deadlines established in the applicable legislation will be complied with as applicable in each country" (page 197).

By region (page 197): "the average payment period was 14 days in North America (17 days in 2024), 32 days in Asia Pacific (35 days in 2024), and 31 days in Europe (32 days in 2024)." Every region improved year on year.

Legal proceedings (page 197): "As at 31 December 2025, there are no legal proceedings pending for late payments."

The disclosure does not give the percentage of payments made in line with standard terms, nor a description of standard terms by supplier category, because the Group states it has no standard terms across the organisation. A material negative impact underpins the topic: "Long payment periods can result in suppliers not being able to make their own payments to their suppliers or employees", a potential negative impact under the sub-topic "Management of relationships with suppliers including payment practices" (page 26).