Aeroporto Guglielmo Marconi di Bologna S.p.A.

The role of the administrative, management and supervisory bodies

Reference: pages 62-66.

AdB uses a traditional governance model: Shareholders' Meeting, Board of Directors and Board of Statutory Auditors (page 62). The Shareholders' Meeting appointed a new Board on April 29, 2025, serving until approval of the 2027 financial statements. At December 31, 2025 the Board had 9 members including the Chair and CEO, 56% male / 44% female, with 56% independent; the CEO "is the only member with executive powers on the Board of Directors. The other eight members are non-executive" (page 63). "There are no Board members elected to represent employees and other workers" (page 63).

The Board of Statutory Auditors has three statutory and two alternate auditors, is 40% female, and is appointed in part by the Ministry of Infrastructure and Transport and the Ministry for the Economy and Finance (page 63).

The Control, Risks and Sustainability Committee (CRSC), renewed on May 15, 2025, "comprises 3 female members (all in non-executive roles, two of whom independent)" and is "entrusted with assessing governance processes, controls and procedures to monitor, manage and control material impacts, risks and opportunities following the double materiality assessment" (pages 64-65). Sustainability governance also includes an Executive Officer for Sustainability Reporting appointed on March 3, 2025, an ESG Steering Committee of five executives, and a seven-member Sustainability Team Core (page 66). Board expertise is disclosed by area: institutional relations 33%, strategy and investment 22%, finance and control 33%, legal 11% (page 64).

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

Reference: pages 64-65; page 57.

In 2025 the Board "discussed the following topics relating to sustainability matters that are material for the Group: the implementation of the NIS2 Directive, regulatory matters and the MAR Directive, the Investment Plan and Enterprise Risk Management (ERM), the impairment testing mechanism and regulatory model, the Sustainability Plan and the Innovation Plan, the airport decarbonisation plan and the Scope 3 emissions reduction plan, the Noise Reduction Plan (PCAR_BAR), the Code of Conduct for Suppliers and Business Partners, the Climate Change Adaptation Plan, and the Airport Infrastructure Development Plan" (page 64).

Three Board members hold sustainability responsibilities as members of the CRSC, and "The corporate bodies are usually updated twice a year on sustainability matters" (page 64). The Board approves the sustainability plan, the DMA results and the consolidated sustainability reporting (page 64). The DMA outcome was "approved by the Control, Risks and Sustainability Committee in a joint session with the Board of Statutory Auditors on December 11, 2025, and by the Board of Directors of Aeroporto di Bologna on December 15, 2025" (page 57). Stakeholder views gathered in the DMA "are shared with the Control, Risks and Sustainability Committee... and subsequently presented to the Board of Directors at the next available meeting" (page 53).

Integration of sustainability-related performance in incentive schemes

Reference: page 65 (also tagged E1 GOV-3 13).

The Remuneration Committee, renewed on May 15, 2025, comprises "3 female members (all in non-executive roles, two of whom independent)" and covers the CEO and General Manager (page 65).

LTI plans. "In the 9th LTI plan (2023-2025), 10% of variable remuneration is dependent on the target related to progress with the Sustainability Plan (divided into two sub-targets). These two sub-targets relate to completion of the Woodland Area and the impact on waste sorted and generated or not generated by the airport" (page 65).

Climate link. "With regard to the climate-related objectives, the results in terms of quantifying AdB's GHG emissions and developing the Plan for the progressive reduction of these emissions are evaluated. Against the achievement of these results, 10% of the remuneration paid to the CEO is linked to emissions reduction targets and another 10% is tied to noise-related targets" (page 65).

Wider population. A sustainability target was confirmed for 2025 "for the entire company population covered by the MBO... variable incentive plan, with an average target weighting of 10% but with potential for overperformance up to 20%", and a "Quality and Sustainability" parameter "accounting for 30%, where one of the factors is the reduction of CO2 emissions related to home-to-work commuting" entered the 2025-2027 Performance Bonus agreement (page 65).

Statement on due diligence

Reference: pages 68-69.

The statement presents a mapping table of "how and where the application of the main aspects and steps of the due diligence process is covered in the Sustainability Statement" (GOV-4 30, 32, page 68), with each of the five core components cross-referenced to named paragraphs:

• (a) Integrating due diligence into governance, strategy and business model - GOV-2 (4.1), GOV-3 (4.1) and SBM-3 (6.3, 9.1, 11.1, 12.1, 15.1).
• (b) Engaging stakeholders in all key phases - GOV-2 (4.1), SBM-2 (2.3 and 6.1), S1-2, S1-3, S2-2, S2-3, S3-2, S3-3, S4-2, S4-3.
• (c) Identifying and assessing actual and potential negative impacts - MDR-P (4.4, 6.4, 7.2, 8.2, 9.3, 10.2, 11.4, 12.4, 13.4, 14.4, 15.2) and IRO-1 (3.1, 6.1, 7.1, 8.1, 9.1, 10.1, 15.1).
• (d) Taking action to address negative impacts - E1-3, E2-2, E3-2, E4-3, E5-2, S1-4, S2-4, S3-4, S4-4, each with MDR-A.
• (e) Tracking the effectiveness of actions and reporting - MDR-T (6.6, 7.4, 8.4, 9.5, 10.4, 11.6, 12.6, 13.6, 14.6) and MDR-M (6.7, 7.5, 8.5, 9.6, 10.5, 11.7, 13.7) (pages 68-69).

The statement on due diligence is also listed in the Appendix B datapoint table against SFDR Annex I, table 3, indicator no. 10 (page 180).

Risk management and internal controls over sustainability reporting

Reference: page 67 (paragraph 4.2.1).

"Governance and control activities dedicated to the process of identifying and managing IROs and, more generally, on the sustainability reporting process were strengthened during 2025" (page 67).

AdB developed the "SCIIS" (Internal Control System on Sustainability Reporting) framework and operational model "in close cooperation with internal data managers". "The definition of the internal control system is based on the 'Internal Control over Sustainability Reporting' (ICSR) guidelines issued by the CoSO framework. At the date of this Statement, the roll-out phase of the operational model for a panel of qualitative-quantitative KPIs pertaining to ESRS datapoints has been completed. Specifically, these KPIs were included in a 'risk control matrix', where the controls were formalised and monitored" (page 67).

A stated caveat: the reporting process and control system "are governed by specific procedures currently awaiting approval" (page 67).

Risks identified: "potential errors in reporting due to processing or consolidation of data from primary sources, compromising the completeness, truthfulness, and accuracy of the representation of AdB", plus risks "related to value chain data, as they are not extracted nor is there operational control over them" (page 67). Controls are classified as detective or preventive, and the ESG Reporting Manager supports the Executive Officer on SCIIS design and maintenance (page 67).

Strategy, business model and value chain

Reference: pages 46-52.

AdB manages Bologna airport, "ranked as Italy's seventh-largest airport by number of passengers in 2025", is listed on Euronext STAR Milan, and is parent of Fast Freight Marconi S.p.A. (cargo handling) and Tag Bologna S.r.l. (General Aviation) (page 46). At December 31, 2025 the Group "employed a total of 649 staff, all of whom are based within the Bologna Airport area"; the catchment area covers "approximately 11 million inhabitants and around 47,000 businesses" (page 47).

The business is run through two Strategic Business Units - Aviation (infrastructure, aviation services, PRM assistance, infrastructure development) and Non-Aviation (car parks, retail sub-concessions, advertising, passenger services, real estate). "Each of the two strategic business units corresponds to a group of services offered, which together represent the entirety of the Group's revenues. Both are connected to actual and potential material negative impacts" (page 47).

Strategy rests on four pillars - CONNECT, DEVELOP, EXPERIENCE, CARE (pages 48-49). The Sustainability Plan is organised under PLANET, PEOPLE and PROSPERITY (page 49).

The value chain table (page 51) splits upstream suppliers (service providers, construction and plant engineering, IT, consumables) from downstream customers (passengers, airlines, handlers, retail sub-concessionaires, couriers, rent a car, taxi firms). "No quantitative data were collected regarding the value chain, except for the information required to estimate Scope 3 emissions" (page 51).

Interests and views of stakeholders

Reference: pages 52-53.

AdB maps eight stakeholder categories against listening and engagement tools (pages 52-53): passengers (ASQ interviews, customer satisfaction and process-time questionnaires, Disability Council, PRM interviews, CRM and Happy or Not); sub-concessionaires; airlines and handlers; local communities (Airport Noise Commission, sustainable mobility technical tables); employees and trade unions (meetings with the CEO, RSU and regional union meetings, Home-Work Travel Plan and harassment questionnaires, mobility days, safety meetings); shareholders and investors; institutions and partner companies; airport community workers.

"For all intents and purposes, the Group considers 'Nature' to be one of its stakeholders, as a 'silent' bearer of interests" (page 53).

Topic-specific statements are given for S1 SBM-2 12, S2 SBM-2 9, S3 SBM-2 7 and S4 SBM-2 8, each tying the group to strategy pillars (page 53). Five categories were consulted in the 2025 materiality assessment: passengers (in-person interview), employees and trade unions (email survey), airport community workers (email survey), local authorities and business clients (online interviews) (page 57).

A clear negative statement closes the disclosure: "no changes were made to the AdB Group's strategy and business model in 2025 as a result of engaging with and listening to the stakeholders" (SBM-2 45 c, page 53).

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

Reference: pages 57-62 (consolidated IRO tables); topic tables at pages 82, 96, 99, 102, 105, 112-113, 134-135, 145, 152-153, 166.

"As a result of the double materiality assessment, all ESRS topics were found to be material for the Group. For clarification, it should be noted that the topics 'Water' and 'Pollution' appear to be relevant only from the perspective of impact materiality" (page 57).

The consolidated tables list 29 impacts (pages 58-60), each typed positive or negative, actual or potential, with impacted factor, strategy pillar, value-chain scope and time horizon, and 14 risks (pages 61-62). No opportunities are reported at all: every topical chapter states that none were identified (pages 83, 96, 99, 102, 105, 113, 136, 146, 154, 166).

Separate prioritised lists are given for impact materiality (own workforce first, then affected communities, pollution, climate change) and financial materiality (workers in the value chain first, then affected communities, circular economy, own workforce), with biodiversity, pollution and water below the financial threshold (page 57).

Changes versus FY2024: "Compared to FY 2024, the IROs have been merged in order to ensure smoother document flow", some positive impacts were dropped "as they were considered to be mitigation actions of existing negative impacts", and some 2024 negative impacts "were assessed as insignificant for 2025 as in the previous year they were included from a prudential perspective" (page 57). On financial effects, "no material risks and opportunities were highlighted for which there is a material risk of significant corrections to the asset and liability book values reported in the relevant financial statements for the next financial year" (page 56).

Climate-specific risk identification and resilience are also presented under E1-2 and E1-3 (2025 ESRS numbering).

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

Reference: pages 54-57; topic-level IRO-1 at pages 83, 96, 99, 102, 105, 166.

"For the purpose of the 2025 reporting, in the absence of significant changes in the internal and external environment compared to the analysis conducted in 2024, the report was refined by simplifying and summarising a number of IROs, while eliminating others. The double materiality assessment is an annual process, and as such AdB plans to review it also for FY 2026" (page 54).

Six methodological steps are described (pages 54-57): understanding the reference context (macroeconomic and geopolitical landscape, sector, regulation, peers, WEF Global Risk Report, ACI Europe guidance, AR 16 of ESRS 1, EFRAG Implementation Guidance, management interviews); identification of IROs (impact and financial long lists, each impact tagged upstream, own operations or downstream, aligned with the internal ERM); assessment; threshold setting; stakeholder engagement; formalisation.

Scales. "two separate magnitude scales were used, one for assessing impacts and one for assessing risks and opportunities, in addition to a shared likelihood scale". Impact magnitude used scale, scope and irremediable character on an "and/or" basis; risk and opportunity magnitude used economic/financial and reputational drivers; likelihood was assessed "within a five-year time horizon" (page 55).

Thresholds. "for Impact Materiality, impacts classified as 'very high', 'high' and 'medium' were, as a precautionary measure, considered above the threshold; For Financial Materiality, only risks and opportunities rated 'High' or 'Very High' were considered above-threshold, to better align with the identification of Top Risks mapped in the ERM system" (page 56).

Stated choices. A "residual" method was used, net of existing controls, but human rights impacts were given "maximum magnitude, regardless of the likelihood of occurrence"; and "the Group identified no dependencies on natural resources, but did identify and account for dependencies on human resources" (page 56).

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

Reference: pages 174-179 (Section 16, ESRS Content Index); pages 180-181 (Section 17, ESRS 2 Appendix B); page 57.

The report prints a full ESRS Content Index mapping each disclosure requirement to a chapter or paragraph rather than a page number (pages 174-179). It covers ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2 and the four MDRs, then 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 S1-17, S2-1 to S2-5, S3-1 to S3-5, S4-1 to S4-5, G1-1 to G1-4 and G1-6, plus topic-level GOV-1, GOV-3, SBM-2, SBM-3 and IRO-1 rows and entity-specific metrics (noise monitoring stations, economic impact, Services Charter metrics).

Phase-in omissions are declared explicitly. AdB "decided to make use of the phase-in option provided by the Transitional Provision '10.4 - List of disclosure requirements that are phased-in', set out in Appendix C of ESRS 1" for E1-9, E2-6, E3-5, E4-6 and E5-6 - the five anticipated-financial-effects requirements (page 174).

Two sub-topics are declared immaterial. "The list provided below does not include references to disclosure requirements E2-5 'Substances of concern and substances of very high concern' and G1-5 'Political influence and lobbying activities', as the related sustainability sub-topics were not deemed material following the double materiality assessment" (page 174).

The index is headed by the declaration of use ("ESRS 1 - General requirements - July 31, 2023") and "Relevant ESRS sector standards: Not applicable" (page 174). Appendix B lists the datapoints derived from other EU legislation against SFDR, Pillar 3, Benchmark Regulation and EU Climate Law references (pages 180-181).

Transition plan for climate change mitigation

Reference: pages 83-84 (paragraph 6.2 Transition plan).

Two board-approved plans, both "approved by AdB's BoD on a voluntary basis in 2024" (page 83):

Net-Zero Carbon 2030 Plan. AdB aims "to achieve Net Zero by 31/12/2030 in accordance with the ACA standard. The target concerns the reduction of Scope 1 and 2 greenhouse gas emissions by at least 90% compared to the base year (2010), while offsetting the remainder. The stated target is consistent with limiting global warming to 1.5°C, as stipulated in the Paris Agreement, and this compliance has been confirmed in 2024 with the achievement of level 4+ (transition level) under the Airport Carbon Accreditation framework" (page 83). The Net-Zero Roadmap is published on the ACI Europe portal (page 83). "As a result of the progressive implementation of the actions contained in the Net Zero Carbon 2030 Plan, in 2025 the reduction in Scope 1 and Scope 2 emissions was 56% compared to 2010" (page 84). The Plan "was approved by AdB's Board of Directors in December 2024, and includes actions defined in technical terms, quantifying the potential for CO2 reductions, and in economic-financial terms" (page 84). Levers: "plant electrification and efficiency, renewable energy production and purchase and e-mobility and Carbon Removal actions" (page 84).

Locked-in emissions. "The Net-Zero Plan does not include a point-in-time qualitative assessment of 'locked-in' GHG emissions... 'Locked-in' emissions are estimated to be qualitatively residual or about 10% of base year emissions and are attributable to emergency systems, refrigerant gases, high-temperature heat generation, and airport operations (e.g. de-icing activities)" (page 84).

Taxonomy alignment plans. "AdB has not formalised any specific targets or plans to date to increase the alignment of its economic activities with the criteria set out in Delegated Regulation (EU) 2021/2139" (page 84). The Group "is not among the categories of companies to be excluded from EU benchmark indices aligned with the Paris Agreement" (page 84).

Scope 3 Emissions Reduction Plan. Commits "to promoting actions to reduce these emissions by 27% by 2030 compared to 2019 levels", excluding GHG Category 11 aircraft full flight because those emissions are "extremely significant compared to all the others" and reduction actions "were not economically viable" (page 84).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3, where this content is disclosed in the FY2025 report (pages 82-83, 85). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical versus transition classification is explicit. The E1 IRO table sorts IROs by sub-topic: under climate change adaptation, "Discontinuity in airport operations and/or damage to infrastructure due to the occurrence of extreme weather events"; under energy, "Major change in market prices for electricity and gas supply (commodity price risk, foreign exchange risk, etc.)" (page 82). The narrative labels the first as "material physical climate risks" and the second under "transition risks" (page 83).

Methodology. In 2024 a climate vulnerability analysis was concluded with the Euro-Mediterranean Center on Climate Change (CMCC), considering "the climate risks to which the Group is exposed, based on the relevant business and geographic area; exposure of airport elements potentially threatened by climate hazards; vulnerability of each exposed element" (page 83). "In 2025, no significant changes occurred in the corporate assets to which these risks relate."

Scenarios. Climate indicator changes "over the future period 2032-2061 were calculated based on an group of climate models available under the EURO-CORDEX programme considering the three IPCC scenarios: RCP2.6 'Aggressive Mitigation,' RCP4.5 'Strong Mitigation,' and RCP8.5 'High Emission Scenario'" (page 85). A high-emission scenario is therefore covered; no 1.5°C-aligned transition scenario is named and no global average temperature projection is given per scenario.

Stated gap. "Unlike the preparations for physical climate risks, no similar analysis has so far been carried out for transition risks, to measure their likelihood, magnitude and duration within specific climate scenarios" (page 83). "No material opportunities related to climate change were identified" (page 83).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (paragraph 6.3, page 85; see also page 62). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The resilience analysis is the 2024 CMCC climate vulnerability study, which "represented a first exercise to understand the resilience of the Group's business model in addressing physical climate-related risks". "The 2024 analysis is still valid as there have been no significant changes in the activities and assets held by the Company" (page 62).

Results by hazard, stated as risk levels per infrastructure component (page 85):

• Hot: "Some substructures present a High or Medium risk."
• Cold: "Only a few substructures have Medium risk, while all others were found to have Low risk."
• Rainfall: "all facilities are at Low risk except parking areas, which have Medium risk."
• Snowfall: "all substructures are at Low risk, except for parking areas, which are at Medium risk."
• Wind: "all substructures are at Low risk."

"In summary, of all the climate-related factors analysed, extreme heat events pose the greatest risks to most infrastructure subsystems" (page 85).

Capacity to adapt. "In 2025, the Climate Adaptation Plan began to be prepared, carrying out specific design review activities on major new infrastructure projects within the multi-year Investment Plan... including the optimal sizing of airport works and infrastructure based on the long-term evolution of these profiles." Implementation "will continue in 2026 with further analysis, extended to the existing infrastructure", covering "the terminal expansion project, the entire airport plant package and the water drainage systems, in addition to the building facades". "In addition to the Climate Adaptation Plan, specific insurance coverage is in place for catastrophic events" (page 85).

The resilience analysis covers physical risk only; no transition-risk resilience assessment is reported (page 83).

Policies related to climate change mitigation and adaptation

Reference: page 85 (paragraph 6.4 Policies); page 70 (policy register).

"The main policy document to manage relevant climate-related impacts and risks is the Integrated Quality, Environment, Energy and Safety Policy" (E1-2 22, 25 a-d, page 85). Its stated content:

• "the commitment to maintaining and improving an integrated management system based on compliance with applicable regulations, while implementing monitoring and measurement of impacts to ensure continuous improvement in environmental and energy performance";
• "adopting climate adaptation solutions, based on specific vulnerability analyses";
• "contributing to the fight against climate change by improving energy efficiency and using renewable sources";
• "in the development or renovation of infrastructure and facilities, and when purchasing energy-relevant products or services, criteria and requirements must be adopted to ensure continuous improvement in overall energy performance" (page 85).

The policy register (page 70) shows the Integrated Policy applies at AdB level (not the whole Group) and covers all ten material ESRS topics. Responsibility for implementing the Integrated Policy sits with the Chief Executive Officer (page 99).

The climate policy disclosure rests on this single cross-cutting policy; no separate, dedicated climate policy document is reported.

Actions and resources in relation to climate change policies

Reference: pages 86-89 (paragraph 6.5 Actions).

Scope 1 and 2 levers, each with quantified CO2 savings against a business-as-usual scenario to 2030 (page 87):

Scope 3 levers (page 88) cover Fuel and Energy-Related Activities (839 t), tenants' green electricity (4,178 t), People Mover renewable energy (to zero), sustainable commuting (122 t), ground access modal shift (956 t), couriers and visitor vehicles (3,224 t), airport partners (204 t), low-emission buses and shuttles and hydrogen supply chain (1,061 t) and waste protocols (122 t), mostly via Memoranda of Understanding since "these are Scope 3 emissions, thus emissions that are not under the direct control of AdB" (page 84).

Adaptation. "No specific climate change adaptation actions were implemented in 2025" beyond the design review of new infrastructure projects (page 88).

Resources. Climate actions "involved the use in 2025 of approximately Euro 444 thousand in terms of OpEx and approximately Euro 4 million in capital expenditure (CapEx)". For 2026-2030, "Euro 669 thousand in OpEx and nearly Euro 26 million in CapEx had been allocated" (pages 88-89). AdB holds ISO 50001 certification, reconfirmed in 2025 (page 86).

Targets related to climate change mitigation and adaptation

Reference: page 90 (paragraph 6.6 Targets).

Scope 1 and 2: "Intersectoral reduction pathway (ACA), base year 2010", target -90% on 2010 by 31/12/2030 (page 90). Baseline 8,899 tCO2e (2010); actual 2025 3,914 tCO2e; target value 890 tCO2e (page 90).

Scope 3: set under the Scope 3 Emission Reduction Plan approved by the Board in 2024, base year 2019, target year 2030. Baseline 39,852 tCO2e; actual 2025 30,923 tCO2e; target 29,146 tCO2e (-27%). Category-level targets (page 90):

"The target does not include emissions associated with air operations (GHG Category 11 - use of sold products - Aircraft full flight)" (page 90) - although a Category 11 line does appear in the table above, covering the non-full-flight element.

Targets are tied to the Integrated Policy and the ACA programme, "which uses the principles of the GHG protocol" (page 90). "In order to achieve the targets set, the decarbonisation levers outlined in paragraph 6.5 Actions were planned and introduced" (page 90). No separate adaptation target is disclosed, and no SBTi validation is claimed.

Energy consumption and mix

Reference: pages 91-92 (paragraph 6.7 Metrics).

Fossil energy (MWh): total 19,370 in 2025 (14,028 in 2024), +38%. Natural gas 18,459 (13,099), +41%; crude oil and petroleum products 911 (929), of which non-automotive diesel 29, corporate-fleet diesel 643, corporate-fleet petrol 239. Coal and other fossil sources are zero, as is purchased electricity, heat, steam or cooling from fossil sources (page 91).

"In line with the previous reporting period, the Group did not use energy from nuclear sources in 2025" (page 91).

Renewable energy (MWh): total 7,556 (8,310 in 2024), -9%. Purchased renewable electricity, heat, steam or cooling 7,111 (8,230), -14%; self-generated non-fuel renewable energy 445 (80), +456% - "The figure is significantly higher due to the commissioning of the largest photovoltaic plant in mid-2025". Renewable fuel including biomass is zero (page 91).

Total energy consumption: 26,926 MWh (22,338), +21% (page 91). Renewable energy production from photovoltaic systems was 452 MWh (103), +339% (page 92).

Energy intensity. AdB "operates in a sector classified as high climate impact in accordance with Delegated Regulation (EU) 2023/137", NACE 52.23. Net revenue from high-impact activities was Euro 181,411 thousand (166,053), and intensity was 0.148 MWh per thousand euro (0.134), +10% (page 92).

Data sources are disclosed per stream - invoices for natural gas and purchased electricity, manual physical surveys for non-automotive diesel, manual meter readings for photovoltaic output, and estimates provided by management control for sub-concessionaire electricity (page 91, footnote 32).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 93-94.

The Scope 1 rise is attributed to "higher natural gas consumption during 2025", owed to "business growth (higher passenger numbers and infrastructure expansion works) and to greater use of the trigeneration plant" (page 93). Scope 2 market-based is zero "since electricity is purchased from renewable sources" (page 93). "Certain 2024 data were restated following calculation changes. These relate specifically to aircraft, fuels and waste generated" (page 93).

Scope 3 by category (page 94): Cat 1 purchased goods and services 84 (+79%); Cat 2 capital goods 316 (+259%); Cat 3 fuel and energy-related 294; Cat 5 waste 261; Cat 6 business travel 88 (-32%); Cat 7 home-work commute 1,676; Cat 11 use of sold products 606,400 (+3%) - 99.4% of Scope 3; Cat 13 downstream leased assets 1,127 (-50%).

Intensity: 3.395 tCO2eq per thousand euro of net revenue location-based (3.619 in 2024), 3.385 market-based (3.604), both -6% (page 94).

"there are no scope 1 emissions subject to regulated emissions trading schemes (EU ETS - domestic ETS - non-EU ETS)", and "the Group does not generate biogenic CO2 emissions" (page 93). Scope 1 composition is given: natural gas 94%, fleet diesel 4%, fleet petrol 1%, refrigerant gas 0.2%, non-automotive diesel 0.2%, de-icing glycol 0.1% (page 93). Emission factors cited include DEFRA 2025, ISPRA National Inventory Report 2025, IEA 2025, Eurocontrol SET v5.14 and ACI ACERT v7.52 (page 93).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 94-95.

Removals. "As part of the environmental offset works under the EIA Decree of the Airport Masterplan, the creation of the woodland strip north of the airport was completed in 2025. The degree to which the woodland absorbs CO2 is specifically analysed as part of the Ecosystem Service 'carbon capture and storage' assessment. This assessment concluded that once the woodland reaches maturity, the total carbon stock, considering both the tree and shrub components and the soil-related contribution, will be 30,520 tonnes CO2eq" (page 94). No tonnage of removals recognised in 2025 is reported - the figure given is a future carbon stock at maturity.

Carbon credits cancelled in the reporting year (page 95):

"Given that the latter target consists of an absolute reduction (net of offsets) of at least 90% of direct and indirect Scope 1 and Scope 2 emissions, any remaining emissions are and will continue to be offset through the purchase of carbon credits" (page 94).

Forward plan. "Also for 2026, AdB plans to purchase carbon credits to offset 100% of scope 1 and scope 2 emissions and 100% of emissions related to business travelling (category 6)" (page 95).

Quality criteria. "The selected credits comply with the internationally recognised Verified Carbon Standard (VCS), and meet quality and traceability criteria" (page 95). No breakdown of credit vintages, project types or geographies is given.

Internal carbon pricing

Reference: page 95 (paragraph 6.7 Metrics).

A complete nil return: "E1-8 Finally, the AdB Group does not apply internal carbon pricing systems" (page 95).

E1-8 is nonetheless listed in the ESRS Content Index against paragraph 6.7 Metrics (page 176), so the absence of a scheme is a reported answer rather than an omission. No shadow price, internal carbon fee, implicit price or carbon price applied in investment decisions is disclosed anywhere in the E1 chapter, and the statement gives no plan to introduce one.

For context within the same chapter, climate costs do enter decision-making through other routes: the transition plan quantifies lever-level CO2 savings and their economic and financial terms (page 84), the EU Taxonomy assessment is applied to 2025 CapEx (pages 88-89, 79), and "Major change in market prices for electricity and gas supply (commodity price risk, foreign exchange risk, etc.)" is carried as a material transition risk (pages 82-83). None of these is presented as an internal carbon price.

Policies related to pollution

Reference: page 96 (paragraph 7.2 Policies); page 70.

"The main policy document for the management of significant impacts related to pollution is the Integrated Quality, Environment, Energy and Safety Policy, which is published on the AdB website" (E2-1 12, 14, 15 a, c, page 96).

Its stated content for pollution: "the commitment to maintaining and improving an integrated management system based on compliance with all applicable environmental regulations and standards, while establishing monitoring and measurement activities to ensure continuous improvement in environmental performance. The policy explicitly mentions AdB's commitment to assessing, preventing and minimising environmental impacts, including those related to atmospheric emissions, and finally promoting an emergency response system that allows for rapid and effective interventions" (page 96).

The policy register shows the Integrated Policy at AdB scope, covering E2 Pollution among the ten ESRS topics, with further detail on purpose, scope, responsibilities, circulation and interaction with IROs in paragraph 4.4 (page 70). The Chief Executive Officer is responsible for implementing the Integrated Policy (page 99).

The E2 policy disclosure rests on this single cross-cutting document. No policy addressing substances of concern is reported, consistent with that sub-topic being assessed immaterial (page 174).

Actions and resources related to pollution

Reference: pages 96-97 (paragraph 7.3 Actions).

Three actions are tabulated against the material negative impact (page 97):

• UNI EN ISO 14001. "AdB has had an ISO 14001-certified Environmental Management System in place since 2004... In 2025, the System's certification was reconfirmed by passing the annual third-party audit."
• Environmental risk register. "In 2025 AdB continued, as part of the Environmental Management System, the monitoring of environmental aspects, related to its activities through a dedicated risk register. The registry includes the matrices of air, water, waste, soil and subsoil, light pollution, biodiversity and airport noise, for which periodic or ad hoc reviews are conducted. In the presence of particularly significant environmental impacts, in-depth risk sheets are prepared and closely monitored by corporate governance functions."
• Fixed air-quality monitoring network. "In 2025, AdB continued with the detection and monitoring of atmospheric pollutant concentrations in urban areas outside the airport, through two fixed stations installed in 2018", sited by agreement with ARPAE and the Municipalities of Bologna and Calderara di Reno. "Data analysis and validation of the monitoring stations is carried out by ARPAE, which produces monthly reports published on the AdB website. To date, ARPAE has not found specific correlations between air traffic and the data recorded by the measurement stations."

AdB also "maintains an up-to-date register/calendar of applicable environmental legislation, with periodic checks on any regulatory updates" (page 96).

Resources. "In 2025, these activities led to approximately Euro 272 thousand in OpEx costs... The future resources allocated in the Sustainability Plan for the period 2026-2030, for the activities planned on the topic of environmental pollution are approximately Euro 143 thousand in terms of OpEx" (page 96). No CapEx is reported for pollution.

Targets related to pollution

Reference: page 97 (paragraph 7.4 Targets).

A reasoned nil return under MDR-T 81 a), b): "With regard to the issue of air pollution, no measurable targets have been set or are planned for the reduction of the impact on air quality, as monitoring carried out so far has not detected any correlation between the concentration values recorded by the measuring stations and air traffic. The processes through which the Group carries out monitoring and the actions taken to manage the impacts associated with air pollution are described in paragraph 7.3 Actions" (page 97).

E2-3 is listed in the ESRS Content Index against paragraph 7.4 Targets (page 176), so the absence of a target is the disclosed answer rather than an omission.

Effectiveness is instead tracked through the monitoring described under E2-2: the two fixed stations whose data ARPAE analyses and validates under a specific operating agreement, with monthly reports published on the AdB website, and the environmental risk register maintained within the ISO 14001 system (page 97). The company states that should critical issues emerge, "the information collected will allow AdB to evaluate the implementation of any corrective measures aimed at improving air quality" (page 97).

Pollution of air, water and soil

Reference: pages 97-98 (paragraph 7.5 Metrics).

AdB reports ambient air-quality concentrations rather than emission loads. "Air pollutant emission data derives from the air quality monitoring network owned by AdB, which includes two fixed measurement stations located in urban areas outside the airport grounds. These stations detect air pollutants from all sources in the area where the stations are located. Data are analysed and validated by the Regional Environment and Energy Agency (ARPAE) under a specific operating agreement. Analyses and verifications conducted by ARPAE have so far not shown a direct correlation between the values detected and the company's activities. However, for the purposes of the Sustainability Statement, these data are still considered useful, as they represent material environmental information derived from the monitoring systems available to the company" (page 97).

Monthly values for 2025 and 2024 are given for both stations, Lippo and Agucchi (page 98):

• NO2 (µg/m³) - Lippo ranged 13 in June to August up to 27 in January; Agucchi ranged 12 in August up to 33 in February and November. 2024 carried "N/A" for Lippo in September and October.
• PM10 (µg/m³) - Lippo ranged 13 in May to 34 in February, with December marked "N/A"; Agucchi ranged 14 in May to 39 in February.

"Fields marked 'N/A' indicate that a measurement is not available for that specific month" (page 97).

No tonnage of pollutants emitted to air, water or soil is disclosed, and the E-PRTR Annex II pollutant amounts are not given. Water discharge volumes appear separately under E3-4 (page 101).

Policies related to water and marine resources

Reference: page 99 (paragraph 8.2 Policies).

Two documents are disclosed (E3-1 9, 11, 12 a, c):

Integrated Quality, Environment, Energy and Safety Policy - "sets out the commitment to maintaining and improving an integrated management system based on compliance with all applicable environmental regulations, while establishing monitoring and measurement activities to ensure continuous improvement in environmental performance. The policy explicitly mentions AdB's commitment to assessing, preventing and minimising environmental impacts, with specific reference to the quality and quantity of water resources" (page 99).

Wastewater and water supply procedure - "in line with the principles of the Integrated Policy, AdB has implemented a procedure for the management of wastewater from the airport facilities belonging to the Company and water supplied for water consumption. The procedure defines methods and responsibilities to ensure that management complies with environmental regulations, in order to ensure that withdrawals and discharges are controlled. It provides for monitoring of wastewater quality, maintenance of the sewerage and drainage network, and the correct management of concessions and permits, including fulfilling the requirements for the Single Environmental Authorization (AUA)" (page 99).

"The officers responsible for the implementation of the procedure are the Airport Operations Director, the Infrastructures Director, and the Chief Executive Officer, who is also responsible for implementing the Integrated Policy. It can be accessed through the Bologna Airport intranet" (page 99).

No policy on water use in operations, product design or marine resources is reported; the airport has no marine-resource activities.

Actions and resources related to water and marine resources

Reference: page 100 (paragraph 8.3 Actions).

A framing statement opens the disclosure: "Despite operating in a water-stressed area, no water withdrawal restrictions have been identified to date, as the withdrawals and uses themselves are considered insignificant. However, recognising that water scarcity represents one of the main environmental challenges, particularly in more vulnerable contexts, AdB is committed to assessing potential initiatives and solutions to optimise water use in its operational activities" (page 100).

Five actions are tabulated (page 100):

• UNI EN ISO 14001 - the environmental management system certified since 2004, covering "impacts on water resources", recertified in 2025 by third-party audit.
• Environmental risk register - continued in 2025, with water among the indicators monitored.
• Water Pledge - "Since 2023 Adb has adhered to the Pledge Dell'Acqua (Water Pledge) programme, promoted by Impronta Etica, to develop among member companies in the area common qualitative and quantitative water resource protection goals. Such goals have not yet been set."
• Wells for non-potable uses - "In 2025, water for non-potable uses, such as irrigation, firefighting tests and operation of air conditioning systems, continued to be withdrawn from wells constructed in 2022."
• Rainwater recovery - "Recovery and use of rainwater continued in 2025 through a system installed in 2023 at one of the airport's operational buildings."

No CapEx or OpEx figure is given for water actions, in contrast with the climate, pollution, circular economy, own workforce, affected communities and consumers chapters, each of which quantifies Sustainability Plan resources.

Targets related to water and marine resources

Reference: page 100 (paragraph 8.4 Targets).

A reasoned nil return under MDR-T 81 a), b): "Currently, there are no formal, measurable targets related to reducing impacts on water resources, either in terms of improving water quality or reducing water consumption. However, as described in the previous paragraph, the Company participates in the Water Pledge programme, which seeks to coordinate various activities among local organisations to identify shared qualitative and quantitative targets relating to the local protection of water resources. As a participating company, AdB will be able to incorporate these targets into its sustainable development plans" (page 100).

E3-3 is listed in the ESRS Content Index against paragraph 8.4 Targets (page 176), so the absence of a target is the reported answer.

Effectiveness tracking in place of a target is set out explicitly: "The company also assesses the effectiveness of its policies and actions related to impacts on water by monitoring: the quality of water leaving the airport on a regular basis, in line with the wastewater management procedure and applicable environmental regulations; annually, data on water withdrawals and consumption, as reported in the following paragraph 8.5 Metrics" (page 100).

The Water Pledge goals remain unset as at the reporting date (page 100).

Water consumption

Reference: pages 100-101 (paragraph 8.5 Metrics).

A definitional caveat governs the figures: "it can be reasonably assumed that the entire amount of water withdrawn is used for these purposes and subsequently discharged (to the ground and/or into the sewer system). Therefore, it should be specified that the 'consumption' of water reported in the tables below must be understood as 'Use', meaning water that is withdrawn and subsequently discharged. Instead, in the definition of 'consumption' as per the water balance, the difference between water withdrawn and water discharged is 0, as there is no dispersion of the resource" (page 100).

Withdrawal (cubic metres, page 101): groundwater 110,753 (2024: 121,136), -7%; third-party water from the aqueduct 60,645 (65,202), -8%; total withdrawal 171,398 (186,338), -8.5%. Every "areas of high water stress" column is reported as 0.

Discharge: third-party water into the public sewer system 171,398 (186,338), -8%; total discharge the same.

Total water consumption: 171,398 m³ (186,338), -8%, on the "use" basis above.

Intensity: "considering water consumption to be 0, the water intensity in 2025, calculated as the ratio of total water consumption to net revenues (Euro 181,411 thousand), would be 0 m3/€k, otherwise it would be 0.94 m3/€k (1.12 m3/€k in 2024). The water intensity calculated on the total number of passengers, which in 2025 amounts to 11,138,013 (10,775,972 in 2024), is 0.015 (0.017 in 2024)" (page 101).

"It is noted that there are no quantities of water stored, recycled and reused. Data on the amount of water withdrawn derived from meters installed on wells and from the adduction network" (page 101). All volumes are freshwater, at or below 1,000 mg/L total dissolved solids.

A tension worth noting: the airport is described as sitting in a water-stressed area (pages 99, 100), yet the high-water-stress columns are zero throughout.

Transition plan on biodiversity and ecosystems

Reference: page 103 (paragraph 9.2).

A plain negative statement: "The AdB Group has not yet carried out a resilience analysis of its strategy and business model in relation to biodiversity and ecosystems. This absence is justified by that reported in the previous paragraph, namely the lack of evidence of a direct impact generated on local biodiversity in connection with Group transactions" (E4-1 13, page 103).

"In any case, consistent with its strategic goals (Care Pillar), AdB has activated the mapping of the level of biodiversity with the objective of investigating its impacts and, in the case of their materiality, taking mitigation measures" (page 103).

E4-1 appears in the ESRS Content Index against paragraph 9.2, described as "Transition plan and consideration of biodiversity and ecosystems in strategy and business model" (page 176), so this is a reported nil answer rather than an omission.

The basis for the "no direct impact" conclusion is the 2025 Bird Control Italy study of biodiversity within the airport grounds, which "showed a good degree of biodiversity in the areas inside the airport grounds and that the prevailing conditions did not encourage the presence of birdlife that could potentially endanger flight safety"; "based on the results obtained, we consider that no potential/real negative impacts of airport activities on biodiversity were found" (page 102). The topic remains material for three stated reasons: proximity to the Natura 2000 "Golena San Vitale and Golena del Lippo" site, the new woodland north of the airport, and "growing interest and sensitivity on the part of local authorities in the Bologna metropolitan area" (page 102).

No transition plan aligned to biodiversity targets, and no 2030 deforestation or land-use commitment, is reported.

Policies related to biodiversity and ecosystems

Reference: page 103 (paragraph 9.3 Policies); page 70.

A single cross-cutting document: "Within the Integrated Quality, Environment, Energy and Safety Policy for Sustainable Development, AdB's commitment to maintain and improve an integrated Environmental Management System based on the assessment, prevention and minimisation of environmental impacts is mentioned, with specific reference to the Group's significant impacts related to biodiversity" (E4-2 23 b, 24 a, page 103).

"Further details regarding the purpose, scope, circulation, responsibilities and interaction with impacts of the Integrated policy are provided in paragraph 4.4 Policies" (page 103), where the register confirms the Integrated Policy is at AdB scope and covers E4 Biodiversity and ecosystems among the ten material ESRS topics (page 70).

What is not claimed is as informative as what is. No biodiversity-specific policy document is reported; no reference to the Kunming-Montreal Global Biodiversity Framework, no no-deforestation commitment and no biodiversity offset policy appear in the chapter. On offsets the statement is explicit in the actions paragraph: "among the implemented actions, no biodiversity offsets were used" (page 103). The related IRO-1 disclosure records that "No dependencies on biodiversity, ecosystems and related ecosystem services were identified" and "No material risks or opportunities have been identified for the Group regarding biodiversity" (page 102).

Actions and resources related to biodiversity and ecosystems

Reference: page 103 (paragraph 9.4 Actions).

"While there is no evidence to date of any direct impact generated by the Company on local biodiversity, the Group has introduced a number of initiatives to manage and monitor the impacts identified in the double materiality assessment. It is specified that, among the implemented actions, no biodiversity offsets were used" (MDR-A 68, E4-3 25, 28 b, page 103).

Biodiversity monitoring within the airport area. "Since 2023, AdB has monitored the species of fauna and flora in the area surrounding the airport to assess the trend in the degree of biodiversity over time (expressed in terms of the Shannon-Wiener index). The initiative also involves identifying further natural areas around the airport to propose regeneration projects... at the end of 2025, AdB signed a partnership agreement with the municipalities in the metropolitan area of Bologna that are members of GIAPP (Integrated Management of the Protected Areas of the Plain). The agreement establishes AdB's active participation in financing work to enhance the natural surroundings" (page 103).

Wooded strip. "In 2025, the wooded strip between the runway and the industrial areas north of the airport was completed. The value of this work rests not only in CO2 absorption but also in connecting the complex ecological nodes present in the area surrounding the airport (Olmi Quarry and the Golena San Vitale and Golena del Lippo sites)... In order to ensure the effectiveness of the renaturation process, the areas are not freely accessible to the public. The project involved planting tree and shrub species on a total area of 39 hectares, with approximately 28,000 native plants overall, including 15 tree and 12 shrub species. Additional features will also be evaluated to enhance the work completed, such as the installation of beehives for the development of a pollinator insect presence" (page 103).

No CapEx or OpEx figure is disclosed for biodiversity actions.

Targets related to biodiversity and ecosystems

Reference: page 104 (paragraph 9.5 Targets).

"No specific quantitative biodiversity targets have yet been set. Based on the future results of biodiversity surveys and subsequent updates of the related mapping of impacts, risks and opportunities, any specific quantitative targets on the topic will be assessed" (MDR-T 81 a, b, page 104).

Effectiveness tracking is disclosed in place of a formal target, together with one measurable threshold: "AdB assesses the effectiveness of policies and actions related to impacts on local biodiversity by monitoring the degree of biodiversity within the airport area based on the Shannon-Wiener index, as described in the previous paragraph. The Company aims to increase the biodiversity of floristic species and to maintain, in the short, medium and long term, a Shannon-Wiener diversity index above 1" (page 104).

E4-4 is listed in the ESRS Content Index against paragraph 9.5 Targets (page 176).

No baseline value of the index, no target year and no intermediate milestones are given, so the ">1" threshold is stated without a measured starting point. The monitoring programme it rests on has run since 2023 (page 103), and AdB states it "will continue the biodiversity monitoring process in the airport surroundings, which will provide insight into the effects of the wooded strip on the local ecosystem" (page 103). No target aligned to the Kunming-Montreal framework or to any biodiversity-related regulatory instrument is reported.

Impact metrics related to biodiversity and ecosystems change

Reference: page 104 (paragraph 9.6 Metrics); page 102.

The metrics disclosure is a site-extent and proximity statement rather than a set of species or condition indicators: "The airport site covers approx. 244 hectares and, as described in paragraph 9.1 is adjacent to the 'Golena San vitale' site (which is a ZSC [special conservation] and ZPS [special protection] area). This area covers around 69 hectares on the northern outskirts of the Bologna conurbation, encompassing a stretch of about 2 km of the Reno River and its floodplains" (E4-5 35, page 104).

The Natura 2000 designation is identified by code in the IRO-1 narrative: "in the immediate vicinity of the airport grounds is located the 'Golena San Vitale and Golena del Lippo' site, included in the Natura 2000 network as a Special Conservation Area (SCA) and Special Protection Area (SPA) with code IT4050018" (page 102).

Related quantitative figures appear in the actions paragraph rather than under E4-5: the new wooded strip covers 39 hectares with about 28,000 native plants, 15 tree and 12 shrub species (page 103).

What is absent: no Shannon-Wiener index value is reported for 2025 despite the monitoring programme and the ">1" aim (pages 103-104), no land-use change figure, no invasive-species metric and no species-population or ecosystem-condition indicator. E4-5 is listed in the ESRS Content Index against paragraph 9.6 Metrics (page 176).

Policies related to resource use and circular economy

Reference: page 106 (paragraph 10.2 Policies).

"The main policy document to manage material impacts and risks related to resource use and the circular economy in the Company's own operations is the Integrated Quality, Environment, Energy and Safety Policy. This defines the Group's commitment to maintain and improve an integrated management system based on compliance with all applicable environmental regulations and to assess, prevent and minimise environmental impacts, particularly those related to waste generation and materials circularity" (E5-1 12, 14, 15 a, 16, page 106).

A stated gap: "The Policy, updated in 2025, does not explicitly refer to issues of sustainable supply or the use of renewable resources in relation to circular economy topics" (E5-1 15 b, page 106).

Two design protocols supplement the policy: "As part of the management of impacts related to resource use and circular economy for airport design, Aeroporto di Bologna uses the CAM and LEED Protocols, which provide guidelines and requirements to ensure that buildings are also designed, constructed and operated according to certain circularity principles. Specifically, CAM guides the choice of materials and construction solutions toward recycled, recyclable and reduced-impact components through the entire life cycle. The LEED protocol, meanwhile, assesses a building's sustainability using a credit system, rewarding the use of recycled-content materials, for example, along with efficient resource management and reduced site waste" (page 106). CAM is identified as "Criteri Ambientali Minimi (Minimum Environmental Criteria), these set mandatory requirements for public procurement in Italy" (page 106).

Actions and resources related to resource use and circular economy

Reference: pages 106-108 (paragraph 10.3 Actions).

Actions cover "increasing separate waste collection, reducing the total generation of municipal waste, recovering and reusing food scraps and materials, and eliminating single-use plastics at points of sale open to the public. Actions are carried out in collaboration with HERA" (page 106). A candid trade-off is flagged: reducing separable fractions "could - in the future - make it more difficult to maintain the percentage of separate collection achieved at the airport, in favour of an overall and general reduction in the amount of waste produced" (page 106).

Quantified 2025 results by action (pages 106-108):

• Unsorted municipal waste - "a decrease in unsorted waste generation (unsorted fraction -26%) was reported, alongside a moderate increase in total waste volumes (5%)", against passenger growth of about +3.4%.
• Single-use plastic (with Plastic Free) - "the amount of plastic produced per 1,000 passengers was 17.73 kg, a decrease of 14% compared to 2024 and a reduction of 9.5% compared to the 2022 baseline".
• Aliplast partnership (plus Heinemann supply chain) - "4,160 kilograms of packaging were collected, a 51% decrease compared to 8,550 kilograms in 2024"; "18,438 kilograms of polyethylene film were purchased, produced from 97% recycled material... resulted in 83% in CO2 savings compared to production using virgin raw materials, which over the four years of the project saw a 53,000-kilogram reduction in the use of plastic".
• ReVending - cups and stirrers from vending machines recycled with HERA and Corepla.
• Separate collection training - "separate waste collection at the airport, which reached 560 tonnes in 2025, or 49.8% of the waste collected".
• Last Minute Market - "8,000 kg of food products were recovered... CO2eq savings of 20,300 kg and water savings of approximately 30 million litres".
• UCO and food waste - "1,650 kilograms of waste were collected, producing 1,700 litres of biodiesel, +83% compared to 2024"; "81 tonnes of such waste were produced and sent to the anaerobic digestion plant in Sant'Agata Bolognese... transformed into 81,100 cubic meters of biomethane and compost".
• Recycled materials in the P6 car park - "ArcelorMittal's XCarb steel was used"; "more than 90% of the waste generated in construction activities could be sent for recycling", supported by "an LCA analysis... conducted on the building as a whole".

Resources: "approximately Euro 14 million in capital expenditures (CapEx) in 2025", referring exclusively to the multi-storey car park, and "approximately Euro 14 million in terms of CapEx" allocated for 2026-2030 (page 108).

Targets related to resource use and circular economy

Reference: page 109 (paragraph 10.4 Targets).

"In terms of circular economy, AdB has introduced targets related to municipal waste management within its operations, which relate to the commitments established on the topic within the Integrated Policy... These targets are set by AdB on a voluntary basis in order to achieve the strategic goals of the Sustainability Plan" (MDR-T 80, E5-3 27, page 109).

A replaced indicator is disclosed with its reasoning: "The KPI 'Maintain the percentage of separated waste equal to or greater than 50%' has been replaced as it is not representative of the impact of the actions put in place. Focusing on the reduction of separated waste fractions, such as plastics and organics, has the effect of reducing the ratio of the amount of sorted waste to the total amount waste. However, these reduction measures are more beneficial than starting recycling and recovery according to the waste hierarchy indications as defined by EU regulations" (page 109).

All three targets address waste and plastic outflows. No target is set for resource inflows, recycled-content share of materials purchased, or absolute reduction in virgin material use, despite resource inflows being one of the two material E5 sub-topics (page 105).

Resource inflows

Reference: page 109 (paragraph 10.5 Metrics).

Scoping statement: "AdB, as a service company and not a production company, mainly handles materials related to infrastructure construction and maintenance. With regard to the reporting of resource inflows, specific categories of relevant materials have been identified, the quantities of which, in line with the required standards, are reportable through the information contained in the documents related to the implementation phase of the interventions" (E5-4 28, 30, 32, AR 21, page 109).

Total weight of products and materials used (tonnes, AdB scope):

The year-on-year jump, more than fourfold, is not explained in the metrics paragraph, though the chapter elsewhere attributes construction volumes to the new P6 multi-storey car park and terminal expansion works (pages 88, 108).

Declared gap on secondary materials: "There is currently no process in place to collect information on the absolute and percentage weight of reused or recycled secondary components and secondary intermediate products and materials used by the Group for its services, although CAM/LEED protocols are used as part of infrastructure design. Opportunities to systematise the collection of information related to the use of recycled materials in infrastructure maintenance and development will be assessed in the future" (E5-4 31 a, b, c, page 109).

No biological-materials share and no sustainably-sourced share is reported.

Resource outflows

Reference: pages 110-111 (paragraph 10.5 Metrics).

The E5-5 disclosure is built entirely on waste datapoints. The paragraph tags are E5-5 37 a), 38 a), b), 37 b), 39, 37 c) and 40 (pages 110-111) - the waste limbs of E5-5. No products-and-materials outflow datapoints are tagged: the statement gives no information on durability, recyclability, recycled content or repairability of outputs, which is consistent with AdB describing itself as "a service company and not a production company" (page 109).

Special waste composition (page 110): "aqueous waste, from the cleaning of run-off water drainage systems, equal to 30% of waste generated; unused materials, resulting from aircraft cabin cleaning, equal to 19%; end-of-life vehicles (rubber-tyred towing vehicle equipped with motorised snow plough blades) equal to 26%; residues from de-icing operators, contributing 10%; other residual categories, including waste mineral oils, fuel mixtures, packaging of various materials containing hazardous and non-hazardous substances".

Special waste generated: 734 tonnes in 2025 (532 in 2024), of which recovered 59% (43%) (page 110).

Non-recoverable outflow explained: "The sewage collected in the storage tank of the water discharge treatment plant from the aircraft de-icing apron is classified as non-recoverable waste. This is due to the specific features of the waste and the related disposal approval, which prevents it being reused" (page 110).

"Regarding the hazardous waste in the following tables relating to the AdB Group, no radioactive waste was generated" (page 110). Data derive from the electronic waste register and Waste Identification Forms (FIR) to January/February 2025, then from the SOGER Waste Management System for March to December 2025 (page 110).

Full recovery and disposal tables by EU R- and D-code are reproduced under the Waste disclosure.

Waste

Reference: pages 110-111.

Special waste recovered (tonnes, AdB Group scope, page 110):

Special waste disposed of (tonnes, page 110): hazardous 0.47 (2024: 0.13), all incineration (D10-D11), with landfill and other disposal at zero; non-hazardous 301.74 (301.59), all "other disposal operations"; total 302.21 (301.72).

Municipal solid waste: "In 2025, AdB generated approximately 1,125 tonnes of municipal solid waste, of which 88% was sent for recovery" (1,156 tonnes at 87% in 2024) (pages 110-111). Composition: "unsorted waste, equal to 50% of total MSW, organic waste (7%), paper and cardboard (15%), plastic (18%), glass (8%) and bulky waste (2%)" (page 111).

"The share of waste directed to disposal represents a limited portion of total waste, as most unsorted waste is directed to energy recovery, significantly reducing landfill disposal in line with the EU 2035 targets... The portion directed to disposal relates exclusively to residual fractions that cannot be recovered for energy or technically recycled due to contamination or material degradation" (page 111).

MSW data "are based on direct measurements obtained by weighing waste loads, which is carried out by the operator Hera S.p.A. Recovery and disposal weights have been modelled using estimates provided by Hera S.p.A., based on city averages and the actual performance of their facilities" (page 111).

A reconciliation point for readers: the separate-collection figure cited under actions is "560 tonnes in 2025, or 49.8% of the waste collected" (page 107), and waste is also a Scope 3 driver at 261 tCO2e under Category 5, up 8% (page 94).

Policies related to own workforce

Reference: pages 115-118 (paragraph 11.4 Policies); page 70.

Five documents are named (S1-1 20, 23, page 115): the Ethics Code; the Gender Equality, Diversity and Inclusion and Human Rights Policy, "which was updated in 2025 to include references to respect for human rights, including labour by adding 'Respect for human rights as the basis for effective implementation of diversity inclusion and gender equality within the AdB Group'"; the Integrated Quality, Environment, Energy and Safety Policy for health, safety and sustainable mobility; the Operational Safety Policy; and the Information Security Management System Policy.

"Both policies strongly condemn forced labour, child labour, and human trafficking, along with all forms of discrimination on the grounds of race, sex or age, political or religious beliefs, physical or social conditions" (page 115). Through the Gender Equality policy AdB "is also committed to guaranteeing the necessary economic, financial and human resources to recognise the specific needs of vulnerable groups, introducing specific measures to prevent any form of exploitation or abuse" (page 115).

The Gender Equality, Diversity and Inclusion and Human Rights Policy box (page 116) gives four objectives - equal treatment and opportunities in career, training and pay; an inclusive environment "tackling cognitive bias and encouraging decisions based on merit"; corporate welfare measures; and "Combatting discrimination, exploitation and abuse in the workplace, including child and forced labour, in line with ILO Conventions No. 29 and 138 and the International Bill of Human Rights". "Implementation is monitored through control dashboards, periodic surveys and dedicated communication channels." Oversight sits with "top management, with the direct involvement of the Board of Directors, Chief Executive Officer, and Director of People Development and Organisation (DPOD)".

The Information Security Management System Policy box (page 117) records ISO 27001 and ISO 27002 alignment, covering employee personal data. Implementation procedures include the Staff Recruitment Procedure (page 116).

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

Reference: page 114 (paragraph 11.2).

Six channels are tabulated with frequency and named responsible officer (S1-2 27 a, b, c, page 114):

Accessibility is addressed: "The survey is available in Arabic, Urdu and Bengali to better engage the diverse community of workers", and "Interviews supported by a cultural mediator are planned for those employees who have difficulties completing the survey" (page 114).

"The responsible party is the person at the highest level role within the enterprise and who has operational responsibility for ensuring that engagement takes place" (page 114, footnote 55).

Effectiveness. "The effectiveness of engagement and listening tools for staff is evaluated based on the actual use of such tools (e.g. meeting attendance rates, survey response rates, etc.) in addition to directly monitoring the feedback provided: if this is mostly positive, then the Company considers the engagement channel used to be effective" (S1-2 27 e, page 114).

On human rights specifically: "while not specifically addressing human rights, AdB has signed second-level agreements on key issues such as corporate welfare, smart working and parental rights" (S1-2 27 d, page 114). Employees and unions are also surveyed by email as part of the annual DMA update (page 114).

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

Reference: page 115 (paragraph 11.3).

Channels. A whistleblowing channel covers "administrative, accounting, civil and criminal offenses or misconduct relevant under Legislative Decree No. 231/01 and violations of the 231 Model", with a procedure that "also provides protection against any retaliatory acts taken against the reporter" (S1-3 32 b, page 115). "Each Group company has a Whistleblowing Policy that specifies the measures in place to protect users of the available channels from retaliation" (page 115, footnote 57).

For health and safety, "employees can also send reports to a dedicated e-mail address which is monitored directly by the Prevention and Protection Safety Officer (RSPP) and their team. These individuals oversee the reporting process and provide a response to the reporter within 30 days of receipt" (page 115).

Three further operational safety reporting channels are shared with the value chain - the Voluntary Safety Report (VSR), Ground Safety Report (GSR) and Operator Ground Safety Report (OGSR) (pages 115, 138).

Awareness and access. AdB cites "continuous internal communication through periodic updates; specific training and e-learning programs to ensure adequate knowledge of available channels and how to use them; use of digital platforms such as the company intranet, website and corporate e-mail" (S1-3 32 d, 33, page 115). "Actual use of the channels is the main indicator of worker awareness and trust. This assessment is supplemented by ad hoc questionnaires on knowledge and use of the tools" (page 115).

Monitoring. "Issues raised are monitored through oversight that varies depending on the type of reporting channel used. This process also helps ensure that company certifications are maintained" (S1-3 32 e, page 115).

Remediation measures are cross-referred to paragraph 11.5 Actions (page 115). The outcome is reported under S1-17: no incidents of discrimination or harassment, and no complaints received through the employee channels in 2025 (page 133).

Taking action on material impacts on own workforce

Reference: pages 118-125 (paragraph 11.5 Actions).

Negative impact - occupational health and safety (page 119): the Occupational Safety Programme including Risk Assessment Document (DVR) updates; ISO 45001 certification held "since 2011", recertified in 2025; customised PPE tested in 2025 "including, but are not limited to, tailored hearing protectors for airside workers and cooling vests to counteract hyperthermia"; an accident awareness campaign where "all employees informed by e-mail in the event of a significant work-related injury or near miss"; a counselling service "staffed by an occupational and organisational psychologist"; the Aggression Protocol signed with the Municipality of Bologna and trade unions, "From 2025, this protocol has been extended to the entire airport community"; passenger flow facilitator groups; and replacement of x-ray machines, with "a voluntary dosimetry campaign to confirm that workers are not exposed, considering that the values recorded are below the trigger threshold".

Positive impacts (pages 120-124): the new National Collective Bargaining Agreements for Air Transport signed February 2025 and the Airport Operators specific section renewed June 2025, which "doubled the period of paid leave for female victims of violence"; the Welfare Plan running since 2014, renewed in 2025 for three years; supplementary health insurance; canteen and gym; flexible 8am-11am entry; leave for religious and cultural celebrations; a 2025 salary benchmarking review that "resulted in a salary level adjustment where applicable/needed"; UNI/PDR 125:2022 gender equality certification renewed in 2025 with "the previous score of 100/100 was confirmed"; ISO 30415:2021 diversity and inclusion certification renewed in 2025 "that resulted in a score of 'Excellence'"; training on gender-based violence with Fondazione Libellula; marriage and parental leave for same-sex couples; UN Global Compact participation and the "Charter for Equal Opportunity and Equality at Work"; mobility initiatives including "Muoviamoci", Bike to Work (in 2025 employees "cycled more than 27,670 km to get to work, saving around 10 tonnes of CO2, with approximately 9% employee participation"), FIAB "Bike Friendly Company" Gold certification and 25 pedal-assisted bicycles on loan plus five more; and training programmes covering operational safety, diversity and inclusion, AI ("the multi-session 'What AI can do' training programme... was attended by 180 employees"), cyber security, strategic foresight and soft skills.

Risk actions (page 125): development plans for staff under 35, operational training, succession plans, and the ISO 27001 information security management system held since 2023.

Resources. "approximately Euro 280 thousand in 2025" in OpEx, with "approximately Euro 460 thousand" allocated for 2026-2030 (page 125).

Targets related to own workforce

Reference: pages 125-126 (paragraph 11.6 Targets).

Targets "were defined based on internal historical data", taking into account "the opinions and interests of internal and external stakeholders, including employees, trade unions, local institutions, and the airport community, as identified through surveys". A limitation is stated: "Workers are not directly involved in monitoring targets, however, they are informed of them through the annual publication of the Sustainability Statement" (S1-5 47 a, b, c, page 125).

Two targets are already met or exceeded at the reporting date (women in management at 43% against >=40%; accident frequency at 4.71 against <8.00). The pay-gap position moved from 1.6% in favour of women to 4.3% in favour of men over the period, still inside the <5% target. "On this material topic, AdB plans for 2026 to begin monitoring some KPIs regarding surveillance activities carried out by the Designated Managers" (page 126, footnote 64).

Characteristics of the undertaking's employees

Reference: pages 127-128 (paragraph 11.7 Metrics).

"number of employees" means "the number of employees with active contracts as of December 31 of the reference year, including those on maternity leave, leave of absence, sabbatical, or other forms of absence" (page 127).

Headcount by gender: male 329 (2024: 314), female 320 (289), other 0, not stated 0; total 649 (603). "At December 31, 2025, the Group has a workforce of 649 people (+8% on 2024) solely working at Bologna Airport, of which 49% are women. The data reflect an increase in both permanent and fixed-term contracts, mainly due to the increase in passenger traffic compared to 2024 and the increase in hiring among administrative staff" (page 127).

By contract type: permanent 518 (485), of which female 237 (219) and male 281 (266); temporary 131 (118), of which female 83 (70) and male 48 (48); non-guaranteed hours 0 (page 127).

By working hours: full-time 388 (446) - female 143, male 245; part-time 261 (157) - female 177, male 84; non-guaranteed hours 0 (page 128). The swing from full-time to part-time year on year is material and is not separately explained, though the narrative states "Full-time contracts account for 60% of the total" (page 127), which reconciles to the 2024 split rather than the 2025 table.

Turnover: 41 employees left (36), with an employee turnover rate of 6% (6%) (page 127).

On flexible working: "An agreement to introduce post-emergency smart working was signed on June 28, 2022, establishing the hybrid model as the new permanent organisational structure. In 2025, the instrument was also utilised for individual agreements, with approx. 27% of workers out of the total company population involved" (page 128).

No country breakdown is given because the Group operates only in Italy (page 129).

Characteristics of non-employee workers

Reference: page 128 (paragraph 11.7 Metrics).

"Total non-employee workers corresponds to the number of people on temporary staffing contracts at December 31 of the reporting year. Compared to 2024, a decrease in agency contracts (-17%) was observed, mainly due to the conversion of several agency workers into permanent or temporary employees" (page 128).

The DMA scope for own workforce is wider than the 42 agency workers counted here: "the Group's own workforce was considered to include workers on whom the Group may generate material impacts. This includes both direct employees and workers contracted by third-party companies, mainly employed in operational, passenger service, maintenance and airport services management" (SBM-3 14 a, 15, page 113).

Non-employees are covered by the reported health and safety metrics: 100% are covered by the Health and Safety Management System, one of the six 2025 work-related injuries involved a non-employee, and non-employees worked 61,020 hours (page 132). Average training hours for temporary non-employee workers were 18.32 (22.17 in 2024) (page 131). All own workers, employees and non-employees, "are covered by social protection" (page 130).

Collective bargaining coverage and social dialogue

Reference: page 129 (paragraph 11.7 Metrics).

"The percentage of employees covered by collective bargaining is 100%, broken down as follows: Executives Industrial Executives Collective Bargaining Agreement; AdB and TAG managers, white-collar and blue-collar workers: Assaeroporti Collective Bargaining Agreement; - Specific Part Managers; FFM employees: Assaeroporti/Assohandlers national collective bargaining agreements - Handlers Specific Part" (page 129).

"In addition, 100% of staff are covered by worker representation, ensuring constant dialogue between the company and employees. As a Group operating exclusively in Italy, the AdB Group adopts the National Collective Bargaining Agreements (CCNL) as the reference for regulating employment relationships" (page 129). No EEA country breakdown is therefore needed.

The DMA separately records that "child labour, forced labour and collective bargaining are strictly regulated and not significant considering the operational and geographical context of the Airport" (page 113), so the metric is reported at 100% coverage even though collective bargaining is not itself a material IRO. Social dialogue is operationalised through monthly trade union meetings with RSUs and regional unions (page 114) and through the new CCNLs signed in February and June 2025 (page 120).

Diversity metrics

Reference: pages 129-130 (paragraph 11.7 Metrics).

Senior management gender distribution. "Senior management within the AdB Group refers exclusively to the Chief Executive Officer and the Executives reporting to him/her" (page 129, footnote 65). In 2025 there were 9 senior management employees (Executives): 6 male, 3 female, identical to 2024, against a total workforce of 649 (603). Women therefore hold one third of executive posts.

Age and category distribution, 2025 (page 129):

The 2024 comparative is given on the same basis (total 603: 38 / 54 / 154 / 141 / 122 / 94) (page 130).

The figures show the distribution is uneven by category rather than overall: women are 49% of the workforce and a majority of white-collar staff (286 of 463), but only 10 of 132 blue-collar roles. AdB attributes this to "the operational area, which, due to the specific nature of the tasks, has a lower female representation" (page 132). Managers are the one category where women outnumber men in the over-50 band (15 against 14).

Board-level diversity is reported separately under GOV-1: 44% female Board, 40% female Board of Statutory Auditors (page 63).

Adequate wages

Reference: page 130 (paragraph 11.7 Metrics).

"All AdB Group employees receive wages in accordance with the standards set by the National Collective Bargaining Agreement (CCNL) and second-level supplementary agreements, ensuring equitable, competitive pay. The Company also employs a specialised third-party company to assess company positions and a carry out a salary benchmarking analysis, comparing them to the reference market in order to ensure a fair salary policy that is in line with industry best practices" (S1-10 69, page 130).

"The figure is reported as total annual pay, calculated for the lowest contractual pay category excluding trainees and apprentices. This calculation is based on the basic wage (thus the local minimum wage) added to any additional fixed payments guaranteed to all employees. As shown in the table above, the ratio of the entry wage by gender to the local minimum wage is the same for both genders represented and is adequate, as it is not less than the local minimum parameter considered" (page 130). "The local minimum wage is the lowest wage according to national collective bargaining agreements, calculated for the lowest wage category excluding trainees and apprentices" (page 130, footnote 67).

The ratio narrowed from 1.067 to 1.036 year on year, since the entry wage rose about 8.4% while the reference minimum rose about 11.5%. AdB does not comment on that movement. No non-EEA or country breakdown applies, as the Group operates only in Italy (page 129).

Social protection

Reference: page 130 (paragraph 11.7 Metrics).

A complete coverage statement against all five ESRS events: "All AdB Group own workers (employees and non-employees) are covered by social protection against loss of income due to illness, unemployment, work-related injury, parental leave, and retirement. These protections are provided either through public programmes and legislative provisions or through benefits offered by the company, e.g. non-work-related injury policy or supplementary health insurance" (S1-11 74, 76, page 130).

Because coverage is universal, no gap table or country-level exception list is required, and none is given.

Supplementary company measures are reported in the same paragraph: "In collaboration with the ANT Association, events dedicated to early diagnosis of thyroid neoplasms were organised in 2025, with more than 70 free check-ups for employees. A flu vaccination service was also provided in 2025, in co-operation with the Bologna local health service" (page 130).

Related provision is disclosed elsewhere in the chapter: the supplementary health insurance policy adopted in 2011, which "provides employees with access to broader health care than is provided under national collective bargaining agreements", with a future objective "to sign a policy at the trade association level" (page 120); and the Prevaer supplementary pension fund, to which "The company, following the latest renewal of the Collective Bargaining Agreement, contributes a 3.4% share (of which 0.4% as sole contributor) - among the highest in the industry - and also provides the option to extend enrolment to family members who are tax dependents. Employees can allocate their Performance Bonus to the fund, with a 20% surcharge borne by the company" (page 133).

Persons with disabilities

Reference: page 130 (paragraph 11.7 Metrics).

The metric is reported for the AdB Group as a whole; no gender breakdown is given, and AdB does not state whether legal restrictions on collecting such data apply (S1-12 79, page 130).

The number rose by four and the share by 0.2 percentage points year on year, against an 8% increase in total headcount.

Supporting measures are disclosed elsewhere in the chapter rather than under this metric. The Gender Equality, Diversity and Inclusion and Human Rights Policy commits AdB "to guaranteeing the necessary economic, financial and human resources to recognise the specific needs of vulnerable groups, introducing specific measures to prevent any form of exploitation or abuse" (page 115). AdB holds ISO 30415:2021 diversity and inclusion certification, awarded in 2023 as "the first airport management company" to obtain it, "reflecting the fact that AdB's policies, practices, and processes are designed to create inclusive workplaces that respect diversity (e.g. in gender, age, ethnicity, disability, sexual orientation, and cultural background)", with a 2025 audit returning "a score of 'Excellence'" (page 121). The DMA found "employment and inclusion of people with disabilities" not significant as an IRO "considering the operational and geographical context of the Airport" (page 113).

Training and skills development metrics

Reference: page 131 (paragraph 11.7 Metrics).

Average training hours per employee by category and gender (page 131):

Average hours fell from 42 to 33 overall, driven by white-collar (39 to 31) and blue-collar (43 to 26) staff, while management hours rose. The decline is not explained in the metrics paragraph. Non-employee temporary workers averaged 18.32 hours (22.17 in 2024) (page 131).

Performance reviews. "AdB's new performance management system, which was revised during 2024 and became fully operational in January 2025, engages employees based on their organisational role and position" (page 131).

White-collar coverage rose sharply from about 12% to about 75%, but no blue-collar employee received a periodic performance review in either year - 132 people, or 20% of the workforce (page 129). AdB does not comment on that gap.

Named 2025 programmes are listed under S1-4, including the "What AI can do" programme attended by 180 employees, cyber security training with "three full-participation meetings... attended by over 100 people" on NIS2, a harassment seminar "attended by around 100 people", a course on deaf culture, and operational safety proficiency checks "every 12 or 24 months, depending on the role" (pages 123-124).

Health and safety metrics

Reference: page 132 (paragraph 11.7 Metrics).

Coverage: "for both 2025 and 2024, the percentage of own workers (employees and non-employees) covered by the Group's Health and Safety Management System is 100%". AdB is certified to UNI EN ISO 45001:2018; "TAG is independently certified for Quality, Environment and Occupational Health and Safety, while FFM does not currently have an externally certified management system but carries out its activities in line with operational practices and procedures and is audited by AdB" (page 132).

Incidents: "In 2025, there were six work-related injuries among employees and non-employees, a decrease of four compared to the previous year. The most common causes of work-related injuries include collisions occurring when moving passengers, trips and falls resulting in bruises/trauma, cuts and fractures. Specifically, injuries in 2025 were caused by inattention while walking, lifting assisted passengers' luggage and workshop activities. During the year, there were no deaths or cases of work-related ill health, and of the six work-related injuries recorded during the year, none of them were 'serious work-related injuries'" (page 132).

The non-employee rate remains more than three times the employee rate despite falling from 59.87 to 16.39 - on a small base of 42 agency workers (page 128).

Days lost (employees): 98 days to work-related injuries (141 in 2024); 0 days to work-related ill health in both years (page 132).

The employee injury rate of 4.79 sits against the S1-5 target of an accident frequency index below 8.00, reported as 4.71 for 2025 (page 126) - a small difference between the two figures that a reader may wish to reconcile.

Work-life balance metrics

Reference: page 132 (paragraph 11.7 Metrics).

"Legislation provides all employees with the right to take family-related leave" (S1-15 93, page 132), so entitlement is universal.

Take-up fell from 18% to 15%, and the gender pattern reversed: in 2024 women took more leave than men (54 against 52, 19% against 17%), while in 2025 men took more (51 against 46, 16% against 14%). AdB offers no explanation for either movement.

Supporting arrangements are reported under S1-4 rather than here: the flexible 8am-11am entry time "maintained and extended to administrative staff, with exit time also flexible as a result"; for shift employees, "particularly single-parent employees, an agreement is in place that ensures work arrangements are more adaptable to their family needs"; leave "for the celebration of religious or cultural holidays"; and "marriage and parental leave for same-sex couples was formally recognised" in 2025 as in previous years (pages 120-121). The renewed national agreements introduced "solidarity leave" and "doubled the period of paid leave for female victims of violence" (page 120). Post-emergency smart working covers "approx. 27% of workers out of the total company population", and "Taking into consideration the non-shift staff to whom the tool is actually applicable, it is used by almost all those entitled to do so" (page 128).

Compensation metrics (pay gap and total compensation)

Reference: pages 132-133 (paragraph 11.7 Metrics).

Gender pay gap. "In 2025, an average gender pay gap of 3.4% was observed in favour of men, up from 0.4% in 2024. This increase is mainly due to the numerous hires of women in entry-level roles that took place in 2025, which lowered the overall average gross pay of women compared to that of men. When analysing permanent workers, the gender pay gap is 3% in favour of women" (S1-16 97, 98, page 132).

Gross hourly wages (page 133):

Women are paid more per hour than men in senior management and at manager level, and less at white-collar and blue-collar level, which is consistent with the company's explanation that the headline gap reflects entry-level hiring mix rather than unequal rates within bands.

Total remuneration ratio. Highest-paid individual 572,087 (2024: 567,024 €); median annual total remuneration excluding that individual 34,622 (32,759 €); ratio 16.52 (17.21). "In 2025, the annual total remuneration of the Group's highest-paid corporate figure was 16.52 times higher than the median annual total remuneration of all Group employees, excluding the highest-paid individual" (page 133).

"Gross hourly remuneration is calculated as the average of each employee's (excluding the Chief Executive Officer/General Manager) theoretical annual total remuneration divided by 2,076 theoretical annual hours. Annual total remuneration includes both fixed and variable pay (e.g. MBOs and performance bonuses), in addition to benefits and benefits in kind (company car, health insurance, welfare, etc.)" (page 133, footnote 70).

The 3.4% figure ties to the S1-5 target of a gap below 5%, reported there as 4.3% in favour of men (page 126) - a difference between the two figures that a reader may wish to reconcile.

Incidents, complaints and severe human rights impacts

Reference: page 133 (paragraph 11.7 Metrics).

A full nil return: "No incidents of discrimination, including harassment, against AdB Group workers were identified in 2025. As a result, during the reporting period, no complaints were received through the reporting channels set up for employees and no fines or sanctions were imposed in relation to this issue" (S1-17 103, page 133).

No severe human rights incidents involving own workers are reported, and no monetary amount of fines, penalties or compensation for damages is disclosed, consistent with the nil position.

"To create an increasingly safe environment, various training and awareness initiatives were implemented" (page 133), cross-referring to paragraph 11.5 Actions, where the relevant measures are the harassment seminar "attended by around 100 people", the in-person training on gender-based violence "with the contribution and participation of the Fondazione Libellula foundation", the annual anonymous harassment survey "revised" in 2025 which "allowed AdB to monitor the presence of potentially dangerous situations in the company or in the personal lives of workers", and the Aggression Protocol signed with the Municipality of Bologna and the trade unions and extended in 2025 "to the entire airport community" (pages 114, 119, 121).

The channels through which such complaints would arrive are described under S1-3: the whistleblowing platform with anti-retaliation protections, and a dedicated health and safety email monitored by the RSPP with a 30-day response commitment (page 115). For the value chain and affected communities, the equivalent nil statements appear separately: "No serious human rights issues and incidents relating to workers in the value chain were reported during 2025" (page 141) and no such issues for affected communities (page 149).

Policies related to value chain workers

Reference: pages 138-140 (paragraph 12.4 Policies).

Five documents plus the 231 Model are named (S2-1 14, 16, page 138): the Ethics Code; the Code of Conduct for Suppliers and Business Partners "for issues relating to working conditions, human rights, health and safety, and equal treatment of workers"; the Integrated Quality, Environment, Energy and Safety Policy; the Operational Safety Policy; and the Information Security Management System Policy. The Organisation, Management and Control Model under Legislative Decree 231/2001 "provides a further safeguard... as its provisions apply to all company subjects involved, including de facto, in company activities considered at risk under the 231 regulations, including external collaborators, suppliers and business partners" (page 138).

The Code of Conduct requires suppliers and business partners to commit to: equal employment and pay opportunities without discrimination; "ensuring a safe workplace in which there are no instances of harassment, threats or any other form of abuse"; "using fair and transparent labour recruitment practices... to protect the rights of workers, including migrant workers, from abuse and fraudulent practices during the recruitment and placement process"; "ensuring gender equality, and preventing human trafficking and forced labour"; "refraining from engaging foreign workers without residence permits"; "not using or facilitating child labour"; and "not forcing anyone to work against their will" (pages 138-139).

Enforcement is stated: where AdB "finds violations of the commitments made by suppliers and commercial partners, the contractual relationship... may be re-evaluated and corrective actions may be pursued, up to and including the pro tempore or final exclusion from the Company's roster of suppliers or commercial partners" (page 139).

"The Code of Conduct is guided by internationally relevant principles and standards, including but not limited to the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises. In this regard, the Group has not identified any incidents of non-compliance" with those instruments regarding value chain workers (S2-1 19, page 139). Suppliers "are also required to spread the principles of the Code of Conduct among their employees, suppliers, external partners and additional parties, within the supply chain" (page 138). The Board approves the Code and management applies it (page 139).

Processes for engaging with value chain workers about impacts

Reference: pages 136-138 (paragraph 12.2).

Eight channels are tabulated with frequency and named responsible officer (S2-2 20, 22 a, b, c, pages 136-137): trade union meetings with RSUs and regional unions (monthly); mobility days (2-3 times a year); the Home-Work Travel Plan questionnaire (annual); workplace safety meetings (six times a year), where "A dedicated Occupational Health and Safety Committee has also been established, with in-person meetings attended by HR managers and HSE managers (RSPPs) from AdB, its subsidiaries and the three handlers operating at Bologna Airport, together with the employee health and safety representatives (RLSs) of the respective companies"; meetings with sub-concessionaire RSPPs (annual); the Safety Committee (four times a year), bringing together "all the safety contact persons from public and private entities operating within the airport"; the Local Runway Safety Team (four times a year), involving "ATSP (Enav) - Pilots - ENAC DT - Rescue and Firefighting, (VVF) - BCI (wildlife management)"; and safety meetings for handler operational staff (four times a year).

Engagement reaches workers indirectly in most cases, through employers, representatives and committees rather than individual workers, with the Home-Work Travel Plan questionnaire the principal direct instrument. Accessibility is addressed: "The survey is available in Arabic, Urdu and Bengali to better engage the diverse community of workers", and "Interviews and listening initiatives supported by a cultural mediator are provided for those workers who have difficulties completing the survey" (page 137).

"As part of the double materiality assessment, feedback is gathered from suppliers, sub-concessionaire contractors and their workers through an email survey related to material sustainability topics" (page 137).

Effectiveness. "The effectiveness of engagement and listening tools for workers in the value chain is evaluated based on the actual use of such tools (e.g. meeting attendance rates, survey response rates, etc.). With specific reference to safety issues, the effectiveness of airport operator engagement and awareness is monitored through the findings of the Safety Management System reporting data analysis and management. This includes the trends in the SPIs (Safety Performance Indicators) defined and the impact of events on the risk levels defined during risk assessment. Monitoring allows corrective or mitigation actions to be defined proactively" (S2-2 22 e, pages 137-138).

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

Reference: page 138 (paragraph 12.3).

"Should workers in the value chain wish to express needs and concerns, a number of the engagement channels described in the previous paragraph are made available, particularly for issues related to occupational safety, operational safety (e.g. online meetings with sub-concessionaire employees, safety meetings, meetings with RSPPs, etc.)" (page 138).

Whistleblowing. "workers in the airport community and value chain can use the whistleblowing channel available on the company website, allowing them to make anonymous reports that are handled by the bodies in charge of the Whistleblowing Policy. The procedure in place for such reports also provides protection against any retaliatory acts taken against the reporter" (S2-3 27 b, c, d, 28, page 138).

Safety reporting system. "as part of the Safety Management System the Group has adopted a reporting system that includes three reporting channels to promptly communicate safety events and ensure that they are effectively managed. All reports received are treated confidentially and without disclosure of personal information, except where the report concerns a crime and in accordance with applicable regulations. The information collected through these channels is used exclusively for preventive purposes and to continuously improve airport operational safety" (page 138). The three are identified elsewhere as the "Voluntary Safety Report" (VSR), the representative "Ground Safety Report" (GSR) and the supervisory "Operator Ground Safety Report" (OGSR) (page 138, footnote 76).

Remediation processes are cross-referred to paragraph 12.5 Actions (page 138). The reported outcome for 2025: "No serious human rights issues and incidents relating to workers in the value chain were reported during 2025, so no remedial action was required" (S2-4 36, page 141).

AdB does not state whether value chain workers were consulted on the design of these channels, nor report the number of reports received through them.

Taking action on material impacts on value chain workers

Reference: pages 141-143 (paragraph 12.5 Actions).

Occupational health and safety (page 141): periodic audits, including "one conducted in a critical area where multiple operators work simultaneously, namely the basement areas where loading and unloading operations are carried out. The audit identified and introduced a number of measures to mitigate occupational health and safety risks. Specifically, vertical signage was installed and operational measures were established, and a loading/unloading vehicle bay and a pedestrian access/exit route to and from the area, including crossings, were created"; the Aggression Protocol extended in 2025 "to the entire airport community"; terminal expansion works "designed to improve operational capacity and reduce the risk of congestion and work-related stress"; joint meetings of employers, RSPPs and RLSs across AdB, TAG and FFM, which "in 2025... were expanded to include employee health and safety representatives"; and safety training programmes.

Operational safety (page 142): the Hazard log, maintained by Post Holders who "assess the safety risks within their areas of responsibility with the support of the Safety Management System... based on a predictive, proactive and reactive approach", ratified annually at the Safety Board. "The mapping focuses on activities that can impact operational and flight safety, excluding occupational health and safety and security."

Working conditions and human rights (pages 142-143): the SynESGy platform - "As of 2025, more than 150 suppliers and commercial partners have signed up... enabling the collection of crucial data to monitor the working conditions of value chain employees and the assessment of sustainability performance, including respect for human and labour rights"; a supplier ESG risk-assessment tool established in 2025, where "From 2026 and on the basis of a shortlist of suppliers and partners considered particularly critical, audits and verifications will be carried out"; tender advantages for "ESG certifications, ESG score attestations, and improved proposals"; the handlers' Site Protocol with operators, unions and ENAC, "established to safeguard handler employees' job security, ensure operational continuity, prevent contractual dumping and wage distortions", which "As of 2025... is still under negotiation, and Aeroporto di Bologna expects to finalise and sign it in the coming years"; environmental training with Hera for car rental sub-concessionaires; and soft skills training for food and beverage and retail sub-concessionaire employees.

Positive impacts (page 143): the Home-Work Travel Plan extended to "all personnel within the airport perimeter", and the "Muoviamoci" project with "discounts and concessions for all workers in the airport community". Risk actions: the ISO 27001 information security management system, recertified in 2025.

Effectiveness is assessed through "results of periodic sub-concessionaire audits, number of incidents of aggression, Airport Service Quality and Mystery Client investigation, Synesgy platform memberships, responses to the Home-Work Travel Plan questionnaire, analysis of events and inspections related to risks mapped in the hazard log, Safety Committee" (page 141). No CapEx or OpEx figure is given for S2 actions.

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

Reference: page 144 (paragraph 12.6 Targets).

A short, explicit nil return under MDR-T 81 b): "The Group does not currently have formal, measurable targets regarding workers in the value chain" (page 144).

Effectiveness tracking in place of targets is disclosed in the same paragraph: "within the scope of operational safety, the AdB SMS identifies a safety target once a year. This is used to define safety performance indicators and associated targets" (page 144), and "Regarding the value chain risk assessment analysis, specific targets are included in paragraph 15.5 Targets. The results of the analyses, workshops and audits will be used to consider the inclusion of targets concerning the employees of the companies involved" (page 144).

S2-5 is listed in the ESRS Content Index against paragraph 12.6 Targets (page 178), so the absence of targets is the reported answer rather than an omission.

The business conduct targets cross-referred to do carry supply chain measures with baselines and target years: the share of private tenders including ESG criteria (92% actual 2025 against a 50% target, rising to 75% for 2026), the number of suppliers certified on SynESGy (58%, or 256 of 440 registered, against "At least 110 certified"), and a target of at least four audits and two workshops with supply chain partners for 2026 and for 2027-2030 (page 173). None of these is expressed as an outcome for value chain workers themselves - no target on injury rates, wage levels, collective bargaining coverage or human rights performance among airport community workers is reported.

Policies related to affected communities

Reference: pages 147-148 (paragraph 13.4 Policies).

A clear statement of what is and is not in place: "While the Group does not have a policy dedicated to affected communities, issues relating to the development of the local economy, job market and sustainable mobility are covered within the Integrated Quality, Environment, Energy and Safety Policy. This provides for an Integrated Management System based on meeting local needs regarding mobility, working from a sustainable development perspective, and on developing and enacting sustainable and alternative mobility initiatives for passengers and the airport employee community" (S3-1 12, 14-18, page 147).

The Ethics Code "describes the principles that guide the company's actions in its relations with all its stakeholders, including local communities, institutions and their representatives. These actions must be based on criteria of legality, transparency and fairness" (page 147).

The Traffic Development Policy is the document closest to the material noise impact, and its limits are stated: "While the Traffic Development Policy does not contain a Policy explicitly addressing impacts and risks related to noise management, it does provide for additional incentive systems for noise abatement operations for carriers falling within certain parameters" (page 147). The policy box records three incentive programmes - long-haul routes of four hours or more, medium and short-haul routes, and "additional bonuses for noise abatement measures to reduce the impact of aircraft and support initiatives in collaboration with stakeholders and local authorities". It "is updated periodically, most recently in January 2026", is approved by the Board and is published on the airport website (page 148).

A second explicit negative: "including in relation to the context in which the Group operates, there are no specific human rights policies relevant to affected communities" (page 147).

Processes for engaging with affected communities about impacts

Reference: page 146 (paragraph 13.2).

"In line with its commitment to local accountability, a central element of the Group's strategy is involving technical representatives of local communities in the process to evaluate and decide on actions and initiatives to be undertaken" (SBM-2 7, S3-2 21 a, page 146).

Two channels are tabulated (S3-2 21 b, c, page 146):

• Airport Noise Commission, "established pursuant to Ministerial Decree 31/10/1997. This includes, in addition to AdB, representatives of the following Bodies and Authorities: ISPRA, Region of Emilia-Romagna, municipalities affected by airport acoustic zoning (Bologna, Calderara, Anzola Emilia), ARPAE, Carrier representatives and ENAV... Commission meetings are convened by ENAC and dedicated to sharing airport noise monitoring data and possible airport noise mitigation actions. In 2025, the Noise Commission met twice, in March and July." Frequency is "When called by ENAC"; the responsible officer is the Chief Executive Officer.
• Technical or working tables on sustainable mobility with "territorial public administrations (Municipality of Bologna and other neighbouring municipalities, Metropolitan City RER) TPER..., Marconi Express..., and SRM", at variable frequency, under the Mobility manager and Corporate and General Affairs department.

A limitation is stated plainly in the IRO narrative: "AdB works closely with the relevant authorities, including ENAC, ENAV... and local authorities to understand local needs relating to the management of airport noise, but without the direct involvement of the inhabitants of the exposed areas" (SBM-3 10, page 145). Engagement with affected residents is therefore mediated entirely through institutional representatives.

"Local authorities that maintain relationships with AdB are also involved in stakeholder engagement as part of the annual update of the Double Materiality assessment. This engagement takes the form of interviews and surveys" (page 146).

Effectiveness. "The effectiveness of stakeholder engagement is reflected in the memoranda of understanding and other types of agreements that are signed as a legal formalisation of the mutual commitments" (S3-2 21 d, page 146).

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

Reference: page 146 (paragraph 13.3).

"If local communities wish to express needs and concerns, they can do so via their technical and institutional representatives or by using the engagement mechanisms described above" (page 146).

Whistleblowing. "local communities can also use the whistleblowing channel, which allows them to submit anonymous reports on relevant topics such as administrative, accounting, civil and criminal offences or misconduct relevant under Legislative Decree No. 231/01 Model and violations of the 231 Model. These reports are monitored and handled by the bodies in charge of the Whistleblowing Policy, which also includes specific measures to protect people who use the channel from retaliation. the channel is made available to local communities through the company website, as no direct reference is provided within the Group's business dealings" (S3-3 27 b, c, d, 28, page 146).

Noise and environmental complaints. "With specific reference to complaints dealing with environmental and noise issues, AdB also provides both an email address and a dedicated web page where the complaint may be submitted. In both cases, reports are managed by the Sustainability Manager and his/her team, who provide feedback within 30 days of receipt of the complaint" (page 146).

"Regardless of the reporting party, the number of reports and complaints received is an indicator of the level of stakeholder awareness with regard to the channels set up to raise needs and concerns" (page 146) - though no count of complaints received in 2025 is reported.

Remediation. "For details of the processes to remediate and prevent the occurrence of significant adverse impacts on affected communities, including measures to monitor and evaluate their effectiveness, the noise containment safeguards that are being finalised are discussed in paragraph 13.5. Actions" (S3-3 27 a, page 146). The principal remedy is therefore the PCAR_BAR noise containment and abatement plan, still at proposal stage at the reporting date (pages 148-149).

The reported outcome for 2025: "there were no reported human rights issues or incidents relating to affected communities" (page 149).

Taking action on material impacts on affected communities

Reference: pages 148-150 (paragraph 13.5 Actions).

Negative impact and risk: airport noise. "in 2025, as part of the noise impact monitoring and management programme, AdB detected that the limits of airport noise zoning had been exceeded in areas falling in the western sector of the airport surroundings (municipality of Calderara di Reno), characterised by limited surface area and low population density. This exceedance confirmed the critical issues and exceedances identified in 2024 and in 2023. The same monitoring also verified the containment of emission levels within acoustic limits in high-density residential areas located to the easts of the airport. Mitigation measures predominantly targeting areas of high residential density have, conversely, resulted in a significant increase in noise on areas in the West Sector, where there is low or very low residential density" (page 148).

"in 2024 AdB initiated the technical process of preparing the PCAR_BAR (Noise Containment and Abatement Plan), in accordance with the applicable legislation on the subject (Law No. 447/95, Ministerial Decree of November 29, 2000, Regulation (EU) 598/2014). More precisely, AdB is close to presenting a proposal for measures aimed at reducing the noise impact of aircraft with a balanced approach to noise management, including: (i) promoting the introduction of aircraft with lower noise emissions, (ii) revising Runway 30 take-off procedures, (iii) decreasing the night traffic quota (11PM-6AM) with a horizon to 2030" (page 148). "In 2026, the PCAR_BAR proposal will be the subject of communication to key stakeholders and, as an immediate follow-up, of a multi-faceted regulatory process"; "The actual effectiveness of the safeguards established with the PCAR_BAR will be subject to future evaluation and monitoring once implemented" (pages 148-149). No noise mitigation action was therefore in force in 2025.

Positive impacts (pages 149-150): new routes and carriers, including "connections to Eastern Europe (e.g. Suceava, Kraków and Chisinau operated by WizzAir), the Mediterranean area (e.g. Athens and Tunis) and the Middle East (e.g. Dubai)"; two cycle-path sections of the Ciclovia del Sole - Eurovelo 7 (1,900 m and 1,600 m plus an 800 m airport connection), with the Via Triumvirato agreement "approved on December 22 by the Metropolitan City council"; the BLQ Bike Station expansion; the Marconi Express partnership, where "From February to December 2025, over 60,000 combined tickets were issued"; and Tper incentives to convert the airport-station bus line "from a 'special' to an 'urban' line" and extend service "to 22 hours a day during the winter season", with "support for the initiatives amounts to a total of Euro 150 thousand per year".

Resources. "approximately Euro 134 thousand was incurred in OpEx in 2025", with "approximately Euro 201 thousand in OpEx for the 2026-2030 period" (page 149). "In 2025, therefore, as in the previous year, there were no reported human rights issues or incidents relating to affected communities" (S3-4 36, page 149).

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

Reference: page 150 (paragraph 13.6 Targets).

"There are currently no measurable targets related to material topics for the affected communities. However, in relation to the issue of noise mitigation, with the implementation of PCAR_BAR and the annual LVA (Airport Noise Assessment Level) acoustic mapping, the goal is to reduce airport noise and the population exposed to noise levels, in line with the Balanced Approach principles enshrined in Regulation (EU) 598/2014. The actions identified in the PCAR_BAR proposal also consider the future traffic scenario projected by the 2030 Masterplan" (MDR-T 81 b, page 150).

A directional aim is stated without a number or a date: "AdB intends to reduce the population affected by LVA levels greater than 60 dB, which define the airport surroundings in accordance with Ministerial Decree of October 31, 1997" (page 150). No baseline population count, no target value and no target year are given.

Effectiveness tracking in place of a target: "To assess the effectiveness of the progress made, airport noise monitoring continued in 2025 and data and information on noise impact and air traffic were shared with local communities and their technical and institutional representatives in the appropriate venues (e.g. within the framework of Noise Commissions)" (page 150).

S3-5 is listed in the ESRS Content Index against paragraph 13.6 Targets (page 178), so this is a reported nil answer. The supporting metric is the entity-specific LVA measurement at seven monitoring stations (page 151), where the two Calderara di Reno stations remained above 60 dB(A) throughout 2022-2025 - P1 Bargellino at 67.2 dB(A) in 2025 and P4 Lippo at 63.4 dB(A) - alongside P6 via Agucchi in Bologna at 63.7 dB(A).

Policies related to consumers and end-users

Reference: pages 156-158 (paragraph 14.4 Policies).

Seven documents are named (S4-1 13, 15, page 156): the Ethics Code; the Code of Conduct for Suppliers and Business Partners; the Integrated Quality, Environment, Energy and Safety Policy "which covers issues regarding service quality, sustainable mobility and innovation"; the Operational Safety Policy; the Information Security Management System Policy; the "Innovation as a Business Strategy" Policy; and the Services Charter.

The Integrated Policy commits AdB to "high service quality standards from a customer-centric perspective and focusing on vulnerable groups" (page 156). On data, "AdB has also prepared a Privacy Policy, which is available on the company's website. This publicly sets out the privacy policy on how users' personal data are processed, managed and protected, and also reinforces their rights to access, correct, delete and transfer their data, or to object to the processing of their data under certain circumstances" (page 156), complementing the ISO 27001-certified Information Security Management System.

The "Innovation as a business strategy" Policy, adopted in 2024, "supports the adoption of AdB's Innovation Management System certified according to ISO 56001:2024 and projects under the Innovation Plan"; objectives include "to identify and apply technologies that improve the customer experience" and "to invest in technology to simplify employees' work and improve services and processes". The CEO "is responsible for enacting the Policy, reviewing and approving Plan projects" (page 157).

The Services Charter, "published in compliance with ENAC regulations, is the tool that formally defines AdB's commitment to users to constantly improve the services it offers". It "sets targets for queue times, the quality of the services offered, cleaning operations, the provision of information, and all other factors that may influence the overall travel experience of users. It also details methods for assisting persons with reduced mobility and disabilities (PRMs)". "Providers working within the airport must offer services consistent with the objectives of AdB's Services Charter." Responsibility for preparation sits with the Quality Manager, and for application with the Operational Services Manager (pages 157-158). "TAG has its own Services Charter which, being in line with ENAC Regulations, is consistent with that of the airport operator" (page 157).

"In 2025, there were no Group violations of the principles of the UN Global Compact or the OECD Guidelines for Multinational Enterprises affecting consumers and/or end-users" (S4-1 17, page 158).

Processes for engaging with consumers and end-users about impacts

Reference: pages 154-155 (paragraph 14.2).

Nine channels are tabulated with frequency and responsible department (S4-2 20 b, c, d, 21, pages 154-155):

The ASQ programme yields "a calculated ASQ index, which provides a quantitative metric for, among other matters, assessing the effectiveness of services and identifying areas for improvement, monitoring them over time" (page 154). For TAG-assisted flights, "The crews of flights with TAG assistance and sub-concessionaires also complete a questionnaire for each flight" (page 154), and TAG results "are managed independently by TAG, by the Head of Co-ordination and Management" (page 154, footnote 85).

Named recipients are disclosed for several channels: PRM interview data "are shared with the Operational Service Manager, Airfield and Terminal Performance Monitoring teams, PRM Co-ordinators and Terminal Supervisors"; innovation survey results are "presented to the Innovation Manager, who verifies their alignment with the Innovation Plan"; Mystery Client results "are then shared each month with business partners. Where particular critical issues are identified, a remedial plan is designed" (page 155).

"Passengers and business customers are also involved in stakeholder engagement carried out as part of the annual update of the Double Materiality Assessment. This is conducted through questionnaires and interviews" (page 155).

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

Reference: pages 155-156 (paragraph 14.3).

"The tools available to passengers and business customers to express concerns or raise reports are different and vary based on the type of report being made" (page 155).

Whistleblowing. "For material topics, including administrative, accounting, civil, and criminal offences or misconduct relevant under Legislative Decree No. 231/01 and violations of the 231 Model, AdB provides a whistleblowing channel that allows for anonymous reporting that is monitored and handled by the bodies in charge of the Whistleblowing Policy and also provides for specific measures to protect people who use the channel from retaliation. The channel is made available to customers and consumers through the company website" (S4-3 25 b, c, d, 26, page 155).

Engagement tools as concern channels. "The whistleblowing channel is complemented by a number of the stakeholder engagement tools illustrated in the table in the previous paragraph, including questionnaires and interviews targeting airport users and PRMs in particular, in order to express any dissatisfaction with the airport service quality or accessibility" (page 155).

Complaints procedure. "Passengers and other users can also submit complaints. At AdB, management of such complaints is governed by a specific procedure within the Integrated Management System. This involves sending e-mail reports to a dedicated PEC (certified e-mail) address or to the company's 'Need Help?' web page. Reports are recorded in the system in accordance with the guidelines of GEN06 - ENAC" and categorised as "(Dissatisfaction, Non-compliance, Refund) and categorised by area (e.g. air terminal, baggage, security, PRM, retail, website, etc.). The Customer Relationship Management department prepares and sends a response to the user, involving other functions where necessary, and once a month compiles statistics from the complaints data. These are analysed and shared at working tables such as the Management Board and Service Quality and Regularity Committee" (pages 155-156).

Three operational safety reporting channels are also available (page 156). "Regardless of the reporting party, the number of reports and complaints received is an indicator of the level of stakeholder awareness" (page 156) - and one movement is quantified under the actions paragraph: "a 64% reduction in complaints and dissatisfaction reports submitted via email" following the I CARE service (page 165). No absolute complaint count is reported.

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: pages 158-162 (paragraph 14.5 Actions).

Data security and cyber security (pages 159-160): the ISO 27001 information security management system held since 2023 and recertified in 2025, where "new projects analysed from the design phase to assess the possible involvement of sensitive data and the supplier's cyber posture" and effectiveness is "tested using various security methodologies (Disaster Recovery, Penetration Testing, Vulnerability Assessments)"; NIS2 compliance, begun in 2024 "with completion expected in 2026", where "both the new NIS2-GDPR and AI Organisational Model and the new Incident Management Plan, effective from January 2026, were approved"; a 24/7 SOC and NOC; EDR; multifactor authentication for all corporate users; ZTNA VPN; PAM for administrative access; and periodic privacy and cyber security audits, where "From 2025 onward, suppliers are also subject to second-party cyber security audits".

Operational safety (page 160): the hazard log; internalisation of the airside PRM service "since 2023", which "has significantly reduced the number of delays directly attributable to service management"; a 2024 Memorandum of Understanding "to consolidate and define shared responsibilities between AdB and handlers"; TAG procedure adaptation "even at the expense of revenue"; and FFM contractual SLAs with major carriers.

Positive impacts (pages 160-162): ISO 9001 held since 1998 and ISO 56001 since 2024, both recertified in 2025; the Business Lounge moved to a specialised partner "through a beauty contest procedure"; the iCare customer care service integrating "the physical information desk and digital channels (such as the WhatsApp channel) into a single organisational model"; a new PET Area, "accessible, free of charge and available 24/7"; the Help Service Desk brought in house in the second half of 2025; the Interfunctional Quality and Facilitation Group; the Quality Under Pressure (QUP) working table; the Marconi Living Lab, which "identified four strategic priorities: improving infrastructure for comfort and sustainability, customer experience initiatives, partnerships for inclusiveness and sustainability with carriers, and integrated mobility"; soft skills training for sub-concessionaire employees; training on celiac disease where "Around 120 employees working in the airport's food&beverage outlets participated"; the Innovation Plan "updated in 2025, covers the 2026-2030 period"; a dedicated PRM lounge completed in the Boarding Area, refurbishment of the Schengen Boarding Area "with the opening of new retail outlets and the installation of new wired seating", and "a new electric lift vehicle for PRM transport"; and the single integrated train and Marconi Express ticket.

Effectiveness. Monitoring uses "user satisfaction surveys conducted through interviews and questionnaires, mystery client investigations, and monitoring of the number and type of complaints and reports submitted through the airport's official channels" (page 158). "As in previous years, there were no serious human rights issues and incidents related to passengers' rights that can be traced directly and/or indirectly to the Group" (page 158).

Resources. "approximately Euro 654 thousand in operating expenses (OpEx) and Euro 2 million in capital expenditure (CapEx)" in 2025, with "Euro 977 thousand in OpEx and nearly Euro 8 million in CapEx" for 2026-2030, the OpEx timeframe being 2026 only (page 162).

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

Reference: page 163 (paragraph 14.6 Targets).

"To assess the effectiveness of policies and actions pertaining to service quality and information security, a number of qualitative and quantitative indicators are monitored, with short-term scheduled completion. With specific regard to the issue of service quality, AdB pursues the objectives included in the Services Charter. The targets for service quality are revised and updated annually in the review of Services Charter and Regulatory Agreement indicators, based on the results of the previous year, and on feedback from committees and round tables on specific topics" (MDR-T 81 b, page 163).

The tabulated targets are all milestone commitments rather than measured outcomes, and all fall due in 2026 (page 163):

No baseline values are given, and no target is expressed as a service-quality or satisfaction level, even though the Services Charter is said to carry such objectives and the entity-specific metrics report queue times and satisfaction percentages in detail (pages 163-164). S4-5 is listed in the ESRS Content Index against paragraph 14.6 Targets (page 179).

Business conduct policies and corporate culture

Reference: pages 167-170 (paragraph 15.2 Policies).

Five instruments are named (G1-1 7, 9, page 167): the Ethics Code, adopted by each Group company; the Code of Conduct for Suppliers and Business Partners; the Integrated Quality, Environment, Energy and Safety Policy; the Organisation, Management and Control Model (OMCM) under Legislative Decree 231/01 with its Anti-Corruption and Anti-Money Laundering annexes; and the Whistleblowing Policy.

"Each Group company has adopted an Organisation, Management and Control Model as required by Legislative Decree No. 231/01... The Group requires suppliers and business partners to provide an appropriate statement attesting to their commitment to share the principles of the 231 Model, providing a guarantee that they have not been involved in any of the offences set out under the Decree. The OMCM is approved by the Board of Directors and responsibility for its implementation is within the scope of the Chief Executive Officer and the Senior Executives" (page 167).

Anti-Corruption Policy. "Although AdB is no longer subject to public scrutiny following the IPO on July 14, 2015, the Board of Directors has confirmed its commitment to maintaining active safeguards against corruption pursuant to Law 190/2012." The policy, "Introduced in 2014 and last updated in 2024", has been "voluntarily adopted, combining the provisions set forth in Legislative Decree No. 231/01... and Law 190/2012", and "is also consistent with the principles and provisions of the United Nations Convention Against Corruption (UNCAC)". The Anti-Corruption and Ethics Committee "is responsible for monitoring and verifying the adoption of the Anti-Corruption Policy and its suitability" (pages 167-168).

Anti-Money Laundering Policy. In place since 2022, updated in 2024, "an integral part of AdB's 231 Model", covering "the system for reporting and managing information flows between the SOS manager and the FIU (Financial Information Unit)" (page 169).

Whistleblowing Policy. "Following the implementation of the updates required by Legislative Decree No. 24/2023, AdB's Whistleblowing Policy has been separated from 231 Model to further emphasise the handling of reports. The Policy provides for a range of reporting channels: the main channel is a digital platform." Reports are "monitored and managed by the Internal Audit Manager for AdB and the Supervisory Board for each subsidiary". "Reports may be made by all internal and external stakeholders", and "To protect whistleblowers, Chapter III of Legislative Decree No. 24/2023 is applied" (pages 169-170).

Two bodies oversee compliance: "the Supervisory Board under Legislative Decree No. 231/01... and the Anti-Corruption and Ethics Committee", both reporting annually to the Board (pages 66-67). "Training duration in hours" and coverage are reported under G1-3 (page 172).

Management of relationships with suppliers

Reference: pages 170-171 (paragraph 15.3).

Supply chain profile. "AdB's supply chain is complex and varied, reflecting the complexity of operations related to the management of the airport. Most suppliers are small and medium-sized enterprises, predominantly Italian (Italian turnover represented 74% of the total in 2024 and 78% in 2025). Of these Italian companies, 52% (43% in 2024) of turnover comes from local suppliers, i.e. those from the Region of Emilia-Romagna, of which most suppliers are located in the Bologna and Modena areas" (G1-2 12, 15 a, b, page 170).

Procurement framework. AdB follows the Public Contracts Code (Legislative Decree No. 36/2023) for contracts tied to airport operator activities; "For contracts that do not reach the EU threshold, AdB operates under its own internal regulations with simplified, non-public procedures"; and "Where procurement is not directly related to airport operations, AdB adopts private-sector logic, regardless of the estimated value" (page 170). "Regardless of whether the procedure adopted is public or private, AdB guarantees fairness and equity in the selection process, ensuring equal information and fair competition conditions during negotiations" (page 170).

"All Group suppliers must follow the principles and directions of the Ethics Code and the Code of Conduct for Suppliers and Business Partners. Any violation of these principles is a serious breach of contract... The Special Tender Specifications also include explicit references to compliance with collective bargaining agreements, occupational safety and social security regulations, and, where relevant, obligations related to environmental protection and energy efficiency" (page 170).

Three named tools (pages 170-171): SynESGy, CRIF Group's platform joined in 2023, where "As of 2025, more than 150 suppliers and business partners have joined"; since 2024 membership "has also included the ESG assessment of an initial group of entities in the downstream value chain (retail customers)". The "Acquisti Telematici" platform, adopted in 2022, which "makes it possible to perform and monitor vendor performance evaluation (Vendor Rating)". And a structured ESG risk assessment begun in 2025 using "a dedicated assessment tool developed based on a proprietary methodology... integrated into the SynESGy digital platform"; it "is updated annually and enables the identification of suppliers with the highest ESG risk", and "Organisations with a higher risk profile will be subject to additional verification and in-depth activities in 2026, including through ESG audits". Risk Assessment analysis of "strategic suppliers (sole/single suppliers)" has run since 2023.

"As part of the contractual relationship, the DURC (Consolidated Document of Contributory Regularity) and, when required, the DURF (Consolidated Document of Fiscal Regularity) are verified before payments are made" (page 171).

Prevention and detection of corruption and bribery

Reference: page 172 (paragraph 15.4).

Risk mapping. "As a listed company with public shareholdings, AdB has decided to partially follow the methodology of ANAC's National Anti-Corruption Plan to define its risk management methodology, with a view to drafting its own Anti-Corruption Policy. Specifically, beginning with the 231 Model and also taking into account offences in the area of corruption that do not imply administrative liability but are committed to the detriment of the company, processes and offence risks were mapped. At this stage, managers (Executives) and members of Group companies' management and supervisory bodies have been identified as 'at-risk functions', as have the managers of the company's key departments" (G1-3 16, 18 a, page 172). The same point is made under G1-1: "The enterprise functions most at risk of corruption and bribery are the management and control bodies of individual companies, corporate bodies, and Executives in charge of key corporate functions" (page 168).

Independence of investigators. "Any reports related to incidents of corruption, including potential incidents, are handled as described in the Whistleblowing Policy... Specifically, all reports are received by the Internal Audit Manager, who operates independently, and is a member of the Anti-Corruption and Ethics Committee" (G1-3 18 b, page 172).

Reporting to the board. "The administrative, management and supervisory bodies, and particularly the Board of Directors, receive annual reports from the Anti-Corruption and Ethics Committee and the Internal Audit Manager. These reports also cover the management of reports received, while always respecting the confidentiality requirements of Legislative Decree No. 24/2023" (G1-3 18 c, page 172).

Training coverage (G1-3 21 a, b, c, page 172). "In 2025, anti-corruption training involved various corporate figures. Specifically, training covered about 64% of the functions considered at risk".

Board and Statutory Auditor coverage fell sharply from 100% each in 2024 (15 of 15 and 9 of 9), while other-employee coverage rose from 43% to 62%. Topics covered are tabulated as Policy (yes for all four groups), "Procedures in the event of suspicion/detection" (yes for Executives and other employees, no for both boards) and Other (same pattern).

A forward commitment: "In 2026, the Aeroporto di Bologna Anti-Corruption Policy will be revised... to definitively disengage it from the regulatory requirements under Law 190/2012 (which is no longer applicable to AdB)... A dedicated training plan geared toward the requirements of the new Policy will then be introduced" (page 168).

Targets related to business conduct

Back-filled from the business conduct chapter (paragraph 15.5 Targets, page 173), where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

AdB does report business conduct targets with baselines, actuals and target years: "The Group has defined specific qualitative and quantitative indicators to monitor its short- and medium-term business conduct objectives. These indicators also serve as a useful tool for assessing the effectiveness of the policies and actions adopted by the Group in this regard" (MDR-T 81 b, page 173).

Two footnotes qualify the figures: "The 2025 figure is particularly high following a strong onboarding campaign on the platform", and "23/25 tenders contain ESG criteria. The other two concern services to which the criteria aren't applicable" (page 173).

Two features are worth a reader's attention. The 2026 tender target of 75% is below the 92% already achieved in 2025, so it is not an improvement commitment. And the SynESGy target, "At least 110 certified", is expressed as an absolute count while the reported actual is a percentage of registered suppliers, making the two hard to compare directly.

Incidents of corruption or bribery

Reference: page 172 (paragraph 15.4).

A complete nil return across all three limbs: "In 2025, there were no confirmed incidents of corruption or bribery. As such, no convictions or penalties were imposed for violations of corruption laws, and no action was taken for violations of procedures and regulations on the subject" (G1-4 22, 24, page 172).

Because there were no confirmed incidents, no breakdown by incident type, no number of convictions, no amount of fines and no description of outcomes is required, and none is given.

G1-4 is listed in the ESRS Content Index against paragraph 15.4, described as "Confirmed incidents of corruption or bribery" (page 179).

The nil result is carried through to the target table, where "Maintain zero incidents of corruption" is tracked against a base year of 2024 (0 incidents), an actual 2025 of 0 incidents, and a 2026 target of 0 incidents (page 173).

The detection machinery behind the result is set out under G1-3 and G1-1: reports "are received by the Internal Audit Manager, who operates independently, and is a member of the Anti-Corruption and Ethics Committee"; the Board "receive annual reports from the Anti-Corruption and Ethics Committee and the Internal Audit Manager" covering "the management of reports received" (page 172); and the whistleblowing digital platform is open to "all internal and external stakeholders of the companies" with anti-retaliation protections under Chapter III of Legislative Decree No. 24/2023 (pages 169-170). The number of whistleblowing reports received in 2025, as distinct from confirmed incidents, is not disclosed.

Payment practices

Reference: page 171 (paragraph 15.3).

"In line with current regulations, the Group grants advances on payments for work where required. In procurement contracts, mainly for works, contractors may request an advance payment on the contract amount, equal to 20% (potentially increasing to 30%). This option is designed to ensure the availability of the financial resources required to begin contractual activities. Where requested, the advance shall be disbursed upon verification of the surety bond provided by the contractor" (G1-6 31, 33 a-d, page 171).

Standard terms and actual performance. "In relation to the payment terms to its suppliers, the Group adopts the standard accounts payable cycle, which stipulates terms of 60 days from the date of invoice for all suppliers. The average payment period in 2025, calculated based on supplier invoices rather than on the balances of the Consolidated Financial Statements as in the 2024 Financial Statements, increased from an average of 61 days in 2024 to 88 days in 2025. This increase is attributable to the growth of trade payables due to the significant volume of investments made in the final part of the year, which led to a substantial rise in payables not yet due (from 72% to 82% in percentage terms), between December 31, 2024 and 2025" (page 171).

The actual average of 88 days sits 28 days beyond the company's own 60-day standard term, and the basis of calculation changed between the two years reported, so the 61-day and 88-day figures are not computed on the same basis.

Procedure and SME treatment. "AdB adopts the Procure-to-Pay Procedure, which aims to ensure compliance with regulations on late payments in commercial transactions, guaranteeing consistency, accuracy and transparency in the management of payments to suppliers and contractors. The Procedure is not specific to SMEs, as it applies to all of the Group's suppliers and contractors" (G1-6 14 tagged as G1-2 14, page 171). This matters because AdB states that "Most suppliers are small and medium-sized enterprises" (page 170).

No number of outstanding legal proceedings for late payment is disclosed.