Air France KLM

The role of the administrative, management and supervisory bodies

Reference: pages 217-219; composition and diversity datapoints incorporated by reference to Chapter 2, sections 2.1 and 2.2.2.

"Governance related to sustainability is organized at the highest levels of the Group": the Board, on the recommendation of its Sustainable Development and Compliance Committee, the CEO, the CEO Committee and the Group Executive Committee (GEC), which "is responsible for implementing the sustainable development strategy approved by the Board" (page 217).

Allocation of responsibility (page 218):

• Audit Committee: reviews the sustainability report, recommends on reporting integrity, discusses it with the auditors.
• Sustainable Development and Compliance Committee: reviews compliance and sustainable development policies, recommends to the Audit Committee.
• Group Decarbonization Committee (2021, led by the Group Sustainability Director): prepares the decarbonization roadmap, reviews the strategy "on a monthly basis".
• Environmental Centers of Expertise, set up "during the summer of 2025" for themes such as noise and waste (page 217).

Board expertise is assessed in "climate change, ethics and compliance, human resources, and governance" (page 219). Two joint Audit / Sustainability Committee meetings were held in 2025, on March 4 and December 2, with the sustainability auditors present; these "will now be held twice a year".

Information provided to and sustainability matters addressed by the bodies

Reference: page 220.

"Air France-KLM integrates sustainability issues, and particularly IROs, into the definition of its global strategy. The Group's main strategic directions and IROs are regularly discussed and reviewed by the Board of Directors, the Audit Committee and the Sustainable Development and Compliance Committee, in particular when reviewing quarterly, half-yearly and annual results and determining the budget."

A specific annual Board meeting covers strategy, where directors review "commercial and brand strategy, maintenance, cargo, alliances and partnerships, the evolution of the fleet plan, as well as the Group's decarbonization trajectory".

The 2025 IRO approval trail is dated: "For 2025, the list was updated after consultation with the Group's internal subject-matter experts, then validated by the GEC at the end of November and presented in a joint meeting to the Audit and Sustainability and Compliance Committees at a joint meeting, then to the Board of Directors in early December 2025."

Board training in 2025 included modules on "Carbon Accounting and Transition Plan", "Climate Risks" and "Responsible Procurement", plus workshops on SAF (April 17) and the decarbonization trajectory (September 29) (page 219).

Integration of sustainability-related performance in incentive schemes

Reference: page 220 and page 230 (section 4.2.1.2 "Climate governance (GOV-3)"); detail incorporated by reference to Chapter 2, sections 2.5.2 and 2.5.3.

"The compensation of company officers is set by the Board of Directors, on the recommendation of the Remuneration Committee, in accordance with the provisions of the French Commercial Code and the AFEP-MEDEF Corporate Governance Code" (page 220). The Remuneration Committee "makes recommendations on the sustainability criteria incorporated into the compensation of executive officers" (page 218).

On the incentive link itself the statement is brief: "several quantitative and qualitative sustainability performance criteria are included in the Chief Executive Officer's annual and long-term variable compensation. All these elements are detailed in Chapter 2 of the 2025 Universal Registration Document".

Observation: no percentage weighting, no named climate metric and no quantified payout linkage appears inside the sustainability statement; the GOV-3 datapoints are satisfied by cross-reference. One concrete link is disclosed elsewhere: the Employee Promoter Score "is factored into the annual evaluation of a number of managers, including senior management" (page 290).

Statement on due diligence

Reference: page 221.

The statement is the required mapping of the core elements of due diligence to paragraphs of the sustainability statement:

• a) Embedding due diligence in governance, strategy and business model - SBM-2, SBM-3, GOV-1, GOV-3, GOV-4; E1-1, G1-1, G1-3, G1-4.
• b) Engaging with affected stakeholders - SBM-2, GOV-5, IRO-1; E1-1, E2-1, E5-1; S1-1, S1-2, S1-3; S2-1, S2-2, S2-3; S3-1, S3-2, S3-3; S4-1, S4-2, S4-3; G1-3, G1-4.
• c) Identifying and assessing adverse impacts - E1-3, E2-2, E5-2; S1-4, S2-4, S3-4, S4-4; G1-1, G1-3, G1-4.
• d) Taking actions to address those adverse impacts - E1-3, E2-2, E5-2; S1-4, S3-4, S4-4; G1-1, G1-3, G1-4.
• e) Tracking effectiveness and communicating - E1-4 to E1-8; E2-3, E2-4; E5-3, E5-5; S1-5, S1-6, S1-8, S1-9, S1-10, S1-12, S1-13, S1-14, S1-16, S1-17; S2-5; S3-5; S4-5; G1-4, G1-5.

This is the most complete enumeration of disclosure requirements in the report. Two inconsistencies: element d) omits S2-4 although section 4.3.2.2.5 "Actions - Workers in the value chain (S2-4)" exists (page 312), and E1-2 appears nowhere although section 4.2.1.3.3 "Policies - Climate change (E1-2)" exists (page 236).

Risk management and internal controls over sustainability reporting

Reference: page 221; substance incorporated by reference to Chapter 3, sections "3.2 Enterprise risk management" and 3.3.2, paragraph "Evaluation and monitoring of Internal Control".

"The Air France-KLM Group has risk management and internal control systems in place, which are applicable to the preparation of its sustainability report." The cross-referenced sections are said to "detail the scope, key characteristics, and components of the existing systems", the risk assessment approach, the prioritization methodology, the significant risks identified and associated mitigation measures, plus "an explanation of how the findings from these assessments are integrated into the Group's internal functions and processes to improve the reliability of its sustainability information".

"Furthermore, the framework provides for periodic reporting of findings relating to sustainability information to the administrative, management, and supervisory bodies of Air France-KLM."

Observation: the disclosure is a cross-reference rather than a description of sustainability-specific controls. No risk assessment results, and no account of how findings fed into the 2025 reporting cycle, appear in the statement itself.

Strategy, business model and value chain

Reference: pages 210-211.

Activities are "air transport of passengers and cargo (network and low cost businesses), and maintenance activities". The ambition is "to become a leading airline company, supporting the ongoing industry-wide transformation through a Transition Plan structured with levers including inter-modality, the continuous improvement of its operational measures, the fleet renewal, and the use of SAF" (page 210).

Upstream (pages 210-211): aircraft manufacturers and lessors; MRO providers, partly internalised through Air France Industries & KLM Engineering & Maintenance; OEM spare-part makers; fuel and SAF suppliers; rail and code-share partners; freight forwarders; airports, "the meeting point of the Group's upstream and downstream value chain"; ground handlers, catering, IT and Air Navigation Service Providers.

Downstream (page 211): individual and corporate passengers through direct and indirect channels; freight forwarders as primary Cargo customers; third-party airlines buying MRO services.

Scope limits for the whole statement (page 208): the materiality assessment covers the value chain, but "policies, actions and targets do not extend to the value chain, except when stated otherwise", and "metrics do not include value chain data, except when stated otherwise".

Under SBM-1 40(d)(i), of €33,007 million net revenue, €7 million came from fossil fuel trading activities (page 246).

Interests and views of stakeholders

Reference: pages 212-216, with topic-level repeats at pages 285, 309, 313 and 317.

Eight stakeholder groups are mapped: partners, communities and NGOs, employees, customers, suppliers, public policy makers, and shareholders and investors (page 212). "Each business unit, led by its respective executive manager, is responsible for regularly reporting to governance bodies on the Group's interactions and initiatives with stakeholders", with updates to the GEC, the Decarbonization Committee, the Sustainable Development and Compliance Committee and the Board.

The 2025 engagement table (pages 213-216) gives, per group, how the Group engages, key topics, the material IROs concerned, outcomes and relevant KPIs. Named mechanisms include a Critical Friends Committee for Air France, "a multi-stakeholder dialogue platform bringing together independent external experts (NGOs, academics, industry specialists) and Air France senior executives", used for "exploration of strategic dilemmas, trade-offs and credibility challenges related to the environmental transition of aviation" (page 216); customer focus groups on sustainability topics; the AIRPro supplier initiative with EcoVadis; and noise meetings with local communities.

2025 ESG ratings are listed: "CDP: A score on Climate", "EcoVadis: Gold Medal", "MSCI: AA", "ISS-ESG: Prime Status C+" (page 215).

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

Reference: pages 224-229, repeated per topic at pages 231, 286, 288, 294, 301, 306, 309, 313, 317, 321, 325, 333 and 335.

The table gives, for each of 16 material topics, the IRO type (actual or potential negative impact, actual positive impact, risk, opportunity), a description, own operations (OO) or value chain (VC), the time horizon, and cross-references to policies, actions, targets, metrics and Chapter 3 risk factors.

Topics by standard:

• E1 Climate change mitigation; Climate change adaptation; Energy (Fuel, SAF)
• E2 Air quality management
• E5 Waste management and circularity
• S1 Social dialogue; Working conditions; Diversity, Equity and Inclusion; Talent attractiveness, development and training; Working rights and human rights
• S2 Working conditions and social dialogue for value chain staff
• S3 Noise hindrance management
• S4 Customer engagement; Operational safety and security of air transportation
• G1 Business conduct, anti-corruption, protection of whistleblowers; Cybersecurity and Data Protection; Political engagement and lobbying

Time horizons are "short term: up to 18 months; medium term: up to 5 years; long term: more than 5 years" (page 209). Climate change adaptation is the only IRO with a long-term-only horizon. No E3 (water) or E4 (biodiversity) topic appears.

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

Reference: pages 222-223; cross-referenced per topic, for example page 230 for climate.

The assessment followed "a five-step process": "Step 1: Screening the relevant sustainability matters; Step 2: Identification of impacts, risks and opportunities; Step 3: Scoring each impact, risk and opportunity; Step 4: Engagement with stakeholders to challenge the materiality assessment; Step 5: Review and validation of the material impacts, risks and opportunities by the management and the governance" (page 222), done "with the help of an specialized advisory firm".

Scoring (page 222): impact materiality used scale, scope, irremediability and likelihood, noting that "In the case of a potential negative human rights impact, the severity of the impact takes precedence over its likelihood". Financial materiality used magnitude and likelihood over short, medium and long-term horizons, "in accordance with the existing Risk Management framework in place within Air France-KLM".

2025 update (page 223): based on "a benchmark on sustainability statements published by the Group's main competitors in the European Union and key actors in its value chain", it "did not lead to significant changes in the previous double materiality assessment". No materiality thresholds are quantified.

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

Reference: page 230 and pages 338-343 (appendix 4.5.1).

Section 4.1.4.3 is one sentence: "Please refer to the detailed information provided in appendix, section 4.5.1 'Mapping of ESRS Data Points with the Requirements of EU Legislative Acts (IRO-2)'".

What the appendix contains. Pages 338-343 are the ESRS 2 Appendix B table: each row is a datapoint derived from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law) with a reference to the section where it sits. Rows cover GOV-1, GOV-4, SBM-1, E1-1, E1-4, E1-5, E1-6, E1-7, E2-4, E5-5, S1-1, S1-10, S1-12, S1-14, S1-16, S1-17, S2-1, S3-1, S3-4, S4-1, S4-4, G1-1, G1-3 and G1-4.

Finding: there is no list of the disclosure requirements the statement covers. The appendix is the EU-legislation datapoint mapping, not an ESRS content index with page references, and no table enumerates the requirements complied with or omitted. The closest substitutes are the GOV-4 due diligence mapping (page 221), the DR code printed in almost every section heading, and the GRI concordance table at pages 345-355.

One inconsistency: the appendix maps "ESRS S1-14 Number of days lost to injuries, accidents, fatalities or illness, paragraph 88 (e)" to section 4.3.1.4.7 (page 341), but that section reports coverage, fatalities, accident numbers and accident rate only (page 293).

Transition plan for climate change mitigation

Reference: pages 232-233; resources at page 244.

"Air France-KLM's ambition is to reduce by 2050 its greenhouse gas (GHG) emissions and contribute to limiting the increase in the global average temperature to 1.5°C above pre-industrial levels, in line with the Paris Agreement. This ambition is aligned with the International Civil Aviation Association's (ICAO) long-term global aspirational goal of net-zero carbon emissions by 2050" (page 232).

Structure: Avoid / Reduce / Replace / Remove, split into flight and ground operations. Five flight levers: business model (fewer short routes, rail intermodality); fleet renewal with aircraft that "consume up to 25% less fuel than an equivalent-sized, previous-generation aircraft"; operational efficiency; jet fuel upstream efficiency; and SAF under "a strict sourcing policy... RSB or ISCC+ certified, are not produced from palm oil, and reduce CO2 emissions by at least 65% over their entire lifecycle". Removals cover residual emissions and "are not included in the Group's plan to reach its 2030 target, according to SBTi methodology".

Embedding: the plan "is embedded in Air France-KLM's five-year Strategic Business Plan and is reviewed annually" and "is regularly monitored through a specific body called the Decarbonization Committee". "The Air France-KLM Group is not excluded from the EU Paris-aligned Benchmarks" (page 233).

Identification of climate-related risks and scenario analysis

Back-filled from section 4.2.1.3.2 "Material impacts and risks... Climate Change (SBM-3)", disclosed in the FY2025 report at pages 233-236, and the E1 IRO table (page 231). This requirement did not exist under the 2023 ESRS the report was prepared against. The same pages remain cited under ESRS 2 SBM-3 and IRO-1.

Physical versus transition (pages 231, 235). The E1 IRO table names a "Transition risk... as a result of fleet renewal, use of alternative fuels, CO2 pricing or compensation mechanisms and activity restriction" and "Physical risks... as a result of activity disruptions, flight procedures and routes adaptation". Page 235 splits the risk universe into chronic and acute physical risks and into policy and legal, reputational, market and technology transition risks.

Methodology (pages 233-234). The 2023 assessment was updated in 2024 "to include the company's upstream and downstream value chain", following "the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD)" over "2030, 2040 and 2050 for physical risks and 2025, 2030 and 2050 for transition risks", covering "the physical risk exposure of 61 sites... to 15 climate hazards" plus seven upstream activities and 27 destinations.

Scenarios (page 234): Orderly (RCP 2.6, 1.5°C, SSP 1), Disorderly (RCP 4.5, 2 to 2.5°C, SSP 2), Hot-House World (RCP 8.5, 3.6 to 4.4°C, SSP 5). Gap: not refreshed since 2024.

Resilience in relation to climate change

Back-filled from section 4.2.1.3.2 "Material impacts and risks and interaction with strategy and business model - Climate Change (SBM-3)", where this content is disclosed in the FY2025 report (pages 233-236). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against. The same pages remain cited under ESRS 2 SBM-3.

Where resilience sits (page 233). "The assessment of the climate change resilience of the Group's business model and its strategy is an integral part of the company's risk management strategy... It is monitored at the highest level of the Group and included in the Group's reviews of its five-year Strategic Business Plan, as well as taken into account in the assumptions used to test the recoverable value of assets."

Results (page 236). "The main physical risks identified were the impossibility to nominally operate in some airports in the future, increased flight disruptions due to storms and more frequent turbulence. These risks were not considered likely to have a significant impact on operational continuity in the short or mid-term, given the Group's balanced network between the different continents and the flexibility of its fleet."

Gaps: no quantified resilience result, no stated areas of uncertainty in the assessment, and the adaptation plan does not yet exist.

Policies related to climate change mitigation and adaptation

Reference: page 236 (section 4.2.1.3.3 "Policies - Climate change (E1-2)").

"Air France-KLM has developed a climate policy that aims to address the identified material impacts and risks related to climate change mitigation and adaptation. The Group's Transition Plan (see section 4.2.1.3.1) is an integral part of this policy. The policy further outlines the principles that inform decision making, sets goals for reducing the company's climate-related impacts and proposes levers for a Transition Plan aimed at climate impact mitigation, adaptation and energy efficiency."

Scope and review: "The policy defines the responsibilities within the Group for its implementation and is applicable to the airline business units of Air France-KLM, namely Air France, KLM Royal Dutch Airlines, Transavia France, Transavia Netherlands, and Air France KLM Martinair Cargo, including their upstream and downstream value chains. The climate policy is reviewed annually for any major events that may impact its content." "The policy is available on the Group's website."

The disclosure is short and, unlike the air pollution and waste policies, does not name the most senior level accountable for it (compare pages 263 and 267, which both name the Group Executive Committee).

Actions and resources in relation to climate change policies

Reference: pages 238-244; resources at page 244.

Intermodality (page 238): partnerships with SNCF and Eurostar allow a single ticket covering flights and trains with guaranteed connections. "The Air France 'Train+Air' product proposes 41 routes to customers traveling to and from the Paris-Charles de Gaulle and Paris-Orly airports." Air France "Air & Rail" runs on CDG-Brussels with baggage handling from train to aircraft; KLM Air&Rail serves Brussels and Antwerp Central.

Fleet renewal (page 238): Airbus A350 "consumes 25% less fuel per passenger km and has a 44% reduced noise footprint"; A320neo family 15% and 50%; A220 20% and 34%; Embraer 195-E2 "emits 31% less CO2 per passenger km and has a 63% reduced noise footprint compared to the E-190 that it is replacing". "At the end of 2025, the Group had 34.6% of its fleet composed of new-generation aircraft... compared to 26.9%... at the end of 2024. The Group plans to have up to 80%... by 2030."

Resources (page 244): "For its fleet renewal, the Group plans a yearly investment between €2.500 and €3.200 million up to 2030. This is a gross investment amount calculated before sale and leaseback operations, and it includes the right-of-use assets of new operating leases." The company states this "cannot be directly linked to the taxonomy-aligned CapEx... For this reason, it is also not possible for the Group to set any future alignment target."

Targets related to climate change mitigation and adaptation

Reference: pages 236-238.

The target (page 236): "a reduction of 17.8% in scope 1 and scope 3 jet fuel GHG emissions, per revenue ton kilometer (RTK) by 2030 from a 2024 baseline", the baseline being 928 gCO2eq/RTK. It "was defined and validated by the stringent, sector-specific methodology of the Science Based Targets initiative (SBTi)... specially the trajectory required to limiting global warming to 1.5°C above pre-industrial levels".

Coverage (page 237): validation covers "well-to-wake" emissions, "89% of Air France-KLM GHG emissions in 2025 (91% in 2024)". "The target excludes other scope 3, non-jet-fuel-related emissions (11%...), as well as scope 2 (0.03%...). SBTi considers scope 2 negligible for the aviation sector."

Absolute effect, stated plainly (page 237): "Air France-KLM estimates that its GHG emissions (scopes 1 and 3 jet fuel) in absolute value in 2030 should remain in line with its 2024 level (+/- 5% of 32,23 MTCO2e scope 1+3.3)." This is an intensity target, not an absolute reduction.

Progress (page 238): "In 2025, the GHG intensity performance was 913 gCO2eq/RTK, which represents a 1.6% decrease compared to 2024", from "Fleet Renewal 49%", "SAF 43% (+1.6pts of incorporation: from 1.25% in 2024 to 2.87% in 2025)" and "Operational measures 8%".

The previous SBTi target used a 2019 baseline and a Well Below 2°C pathway (page 209). No adaptation target is set.

Energy consumption and mix

Reference: pages 245-246; table at page 246.

"All energy consumption is reported in Mega-Watt-hours (MWh) in Lower Heating Value (LHV)... All quantitative energy-related information is reported as final energy consumption" (page 245), split between flight and ground operations.

2025 figures, total Group (page 246):

• Total energy consumption 105,202,416 MWh (102,142,552 in 2024), of which flight operations 104,695,839 and ground operations 506,576.
• Total fossil energy 101,905,334 MWh, a 96.9% share (98.5% in 2024); conventional aviation fuel is 101,740,167 MWh of that.
• Total renewable energy 3,211,335 MWh, a 3.1% share (1.4% in 2024). Renewable fuel is 3,055,686 MWh, "Of which: SAF" 3,001,720 MWh, so SAF accounts for almost the whole increase; renewable consumption more than doubled from 1,318,359 MWh.
• Nuclear 85,747 MWh, 0.1% of the total and 16.9% of ground operations energy.
• Ground operations renewable share 41.9% (38.6% in 2024).

Energy intensity (page 246): calculated on total net revenue "in accordance with the ESRS E1-5 §38 and §40 provisions", the main activity being in a high climate impact sector. Net revenue €33,007 million (€31,459 million); intensity 3.19 MWh/k€ against 3.25. Coal and other fossil sources are reported as nil.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 247-251; main table at page 249.

2025 figures in ktCO2eq against restated 2024 (page 249):

• Scope 1 total gross 26,125 (25,689, +2%): flight operations jet fuel 26,090, ground operations 35. 23% of gross scope 1 is from regulated ETS.
• Biogenic emissions from SAF 772, reported separately, with "CO2 reduction from biogenic emissions - SAF" of (685).
• Scope 2 location-based 20, market-based 10.
• Scope 3 total gross 10,618 (9,636, +10%): purchased goods and services 1,658; capital goods 1,014; fuel and energy-related activities 6,674; transportation 389; waste 17; business travel 87; employee commuting 84; investments 694.
• Total gross GHG emissions 36,762 location-based, 36,752 market-based (35,344 and 35,334, +4%).

Method (pages 247-248): flight scope 1 uses "an emission factor of 3.16 tons of CO2 emitted for 1 ton of fuel consumed (corresponding to the ICAO standard)"; scope 3 category 3 uses 0.8042 tCO2eq per tonne of fuel. Categories 4 and 9 are aggregated "due to integrated logistics operations and data limitations".

Intensity (pages 250-251): 1.11 tCO2eq/k€ (1.12). SBTi-standard intensity 913 gCO2eq/RTK (928), Air France Group 941, KLM Group 872.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 251-252.

2025 activity (page 251): "The emissions from 2024 to be covered by the projects financed in 2025 were around 633 thousand tons of CO2, of which 50% were addressed with European-based projects and the remaining 50% with international projects. 50% of the credits bought were from reduction projects and 50% from sequestration projects." Air France used OKLIMA, a subsidiary of EDF, to select projects, and "100% of the Group projects met recognized quality standards". Credits by standard: "Verra: 316,899 credits; LBC: 285,203 credits; Huella de Carbono: 31,686 credits". "In 2025, 33 out of the 65 projects financed by Air France Group benefited from the 'biodiversity bonus' granted by the French administration."

Metrics in ktons of GHG (page 252): credits from previous years cancelled in the reporting year 399 (380); credits planned to be cancelled in future years 1,374 (1,017); share under recognised quality standard 100%; share of projects within the EU 50%; share qualified as corresponding adjustments nil.

EU ETS allowances are excluded. "The Group has not yet purchased carbon credits for its future CORSIA compliance."

Internal carbon pricing

Reference: page 252.

Three schemes:

• Flight operations, regulatory price - reflects "the real cost of carbon including all regulatory costs according to destination: Article 147 in France, EU-ETS in Europe, CORSIA in international destinations and mandated SAF blending". Value up to €740 per ton of CO2, "already included in the economic evaluation of all business decisions as a mandatory cost to include in every business case".
• Flight operations, strategic price - "Cost of CO2 emissions linked to achieving Air France-KLM's decarbonization target, that is more ambition than regulation", used "as a decision-support tool". Value €120 per ton of CO2.
• Ground operations price - "Cost of CO2 emissions for ground emissions, based on industry standards". No value is printed.

Coverage: "Air France-KLM estimates that the share of its total GHG emissions covered by the internal carbon pricing schemes corresponds to around 35% (scopes 1 and 3.3)." The prices "are based on projected prices for 2030 and may be over estimated or underestimated", are consistent with the impairment testing assumptions (Note 21), and "It is an internal tool which is not validated by a third party."

Observation: no ground operations price is disclosed, and 35% coverage leaves most of scope 3 outside any internal price.

Policies related to pollution

Reference: pages 262-263 (section 4.2.2.2.1 "Policies - Air pollution (E2-1)").

"The Groups aims to mitigate the negative impacts on the health of people working and living near its airport platforms, provide transparency on air pollutants generated by its activities" and comply with applicable regulation (page 262).

Accountability and scope (page 263): "The most senior level in the Group's organization accountable for the implementation of this policy is the Air France-KLM Group's Executive Committee (GEC)." The policy "is available internally and is applicable to the overall operations", named as the four airlines, Martinair Cargo and AFI KLM E&M (page 263).

Management system (page 263): "Air France and KLM rely on their ISO 14001 environmental management systems to identify their air pollution risks and implement mitigation and protection measures in the event of abnormal thresholds." Risks are reviewed "through steering committees that meet twice a year", and "Environmental incidents are reported on a weekly basis through multi-risk event feedback committees". Communities are consulted through Environmental Consultative Committees led by French prefectures, Dutch Environmental Consultative Groups and AirParif.

The policy is scoped to air pollution only. No policy on water, soil, substances of concern or microplastics is disclosed, consistent with the single material E2 topic, "Air quality management".

Actions and resources related to pollution

Reference: pages 263-264 (section 4.2.2.2.3 "Actions - Air pollution (E2-2)").

"Air France-KLM monitors its NOx and SO2 emissions for its flight and ground operations at its main airport bases (hubs in CDG, ORY, SPL) by calculating them at low altitude (below 3,000 feet), in line with IATA Airlines Sustainability Reporting Handbook recommendations. Most of these emissions come from aircraft movements, ground services equipment and aircraft engine tests during maintenance activities" (page 263).

Named actions (page 264). In France, Air France is "reducing the use of aircraft Auxiliary Power Units (APUs)... through the installation of shore-side power supply facilities", "promoting single-engine taxiing ('n-1 taxiing')" and electrifying ground vehicles. In the Netherlands, KLM runs an exploratory study with Schiphol "into employee exposure to Ultrafine Particles (UFPs)", participates in "Minder Hinder", and from 2025 joined "the program to reduce aircraft and diesel engine emissions (VDME program)", including "Seamless Inbound Flow (SIF), Tug Release Points (TRP) and Taxitowing".

Airparif maps show regulatory values not exceeded near Paris "with the exception of NO2... along the motorway serving the airport". No spend is quantified.

Targets related to pollution

Reference: page 263 (section 4.2.2.2.2 "Targets - Air pollution (E2-3)").

The disclosure is short and is an explicit statement that no pollution-specific target exists:

"Air France-KLM has been measuring its NOx and SO2 emissions from its flight and ground operations since 2005. This monitoring, combined with its fleet renewal commitments and the implementation of operational measures, has resulted in a reduction in NOx and SO2 emissions over the period. The Group has not defined separate targets for its NOx and SO2 emissions, since these are included in the overall greenhouse gas (GHG) reduction target (see section 4.2.1.3.4 'Targets - Climate change (E1-4)')."

Assessment. This is a complete answer rather than a refusal: the company says what it has and does not have, and gives its reason. The reason is recorded as stated, but the GHG target is an intensity target in gCO2eq/RTK (page 236) and does not track NOx or SO2, so the claim that air pollutant emissions are "included in" it is one of shared levers rather than shared measurement. Reported NOx rose in 2025, from 9.4 to 9.7 thousand tonnes, while GHG intensity fell (pages 238, 265).

Effectiveness is tracked instead through the ISO 14001 framework and the annual NOx and SO2 metrics disclosed under E2-4.

Pollution of air, water and soil

Reference: page 265 (section 4.2.2.3 "Metrics - Air pollution (E2-4)").

2025 figures in ktons:

• NOx emissions, flight operations 9.5 (9.2 in 2024)
• NOx emissions, ground operations 0.2 (0.2)
• Total NOx emissions 9.7 (9.4)
• Total SO2 emissions 0.7 (0.8)

"In 2025, the total NOx emission amounted to 9.7 thousands tons (9.4 in 2024), while the total SO2 emissions amounted to 0.7 thousands tons (0.8 in 2024)."

Method. Flight NOx is reported "during the Landing and Take-Off phases (LTO) for the low-altitude emission (i.e., below 3,000 feet) phases of the flights, as recommended by the IATA's airline sustainability reporting guidelines", using "engine data communicated by the ICAO... then applied to the fuel consumed by the engines in each aircraft". Ground NOx comes "mainly from the engine test benches (ETB)... and from the fuel combustion of its ground support equipment (GSE) and runway vehicles". SO2 is calculated "based on the average sulfur content of the fuel loaded in its aircraft".

Scope limits. Only NOx and SO2 are reported. The E-PRTR Annex II pollutant list referenced in the appendix mapping (page 340) is not reproduced, no water or soil pollutant figures are given, and emissions above 3,000 feet fall outside the measured boundary, though the company acknowledges "the effects of Nitrogen Oxide (NOx) emissions at high altitude in creating ozone and decomposing methane" (page 262).

Policies related to resource use and circular economy

Reference: pages 266-267 (section 4.2.3.2.1 "Policies - Waste management and circularity (E5-1)").

"Air France-KLM follows the guiding principles of ISO 14001 for its waste management actions, that provide a framework for the company to improve its environmental performance through more efficient use of resources and reduction of waste" (page 266), a standard whose "Key elements include environmental policy, planning, implementation, monitoring, and continuous improvement".

Implementation (page 267): "To achieve the policy's objectives, action plans putting forward specific initiatives and timelines are deployed throughout Air France-KLM. The Group is continuously engaged in dialogue with local authorities and with the various suppliers in terms of the implementation of these action plans."

Observations. The policy is scoped to waste, matching the single material E5 topic. It does not address resource inflows, product design for circularity, or virgin versus secondary materials, and unlike the air pollution policy it does not name the most senior level accountable. One 2025 governance change is relevant: internal "centers of expertise dedicated to various key environmental themes, such as noise management and waste management" were created that summer and are "tasked with defining policies, setting objectives, developing action plans, and ensuring reporting in their respective areas" (page 217).

Actions and resources related to resource use and circular economy

Reference: pages 267-268 (section 4.2.3.2.3 "Actions - Waste management and circularity (E5-2)").

"Waste is managed within each Group business unit by a representative of the sustainability team and the different business departments in which the waste is actually produced are responsible for handling it" (page 267).

In-flight waste (page 267): actions "include adjusting perishable product orders and maintaining a rigorous merchandise inventory management policy to reduce wastage of unconsumed fresh products on all its flights, donating unconsumed items to charities whenever possible, and pre-selecting hot meals by customers at check-in." A regulatory constraint and the result of lobbying are both described: EU rules "restrict the recycling of most catering waste from intercontinental flights entering the EU", and "As a result of these efforts, in 2024, the European Commission published more guidance on what can be considered category 1 waste... all Group airlines can now recycle juice and drink containers and coffee grounds, instead of incinerating them."

Aircraft end-of-life (page 268): "Air France-KLM requires third parties to comply with EU regulations regarding the dismantling of aircraft at their end-of-life." No CapEx or OpEx is quantified.

Targets related to resource use and circular economy

Reference: page 267 (section 4.2.3.2.2 "Targets - Waste management and circularity (E5-3)").

"Air-France-KLM tracks the effectiveness of its policy and actions through the ISO 14001 framework with a certification audit every three years by an independent third party and yearly follow-up audits of its action plans."

Compliance-based tracking is also described: "All entities in France implement a comprehensive waste tracking system pursuant to the Decree of March 25, 2021 on waste traceability transcribed into the French Environment Code (Articles R. 541-43 and R. 541-45). All Group entities in the Netherlands are subject to the Dutch regulation on waste ('Wet Milieubeheer')."

The position on the target itself, verbatim: "Air-France-KLM is currently working on the revision of its waste management target. The waste reporting scope has indeed evolved in 2024, with new entities now included in the scope along with new waste categories (cabin and catering waste) and treatment types."

Assessment. There is no quantified waste or circularity target for FY2025, a second consecutive year in which the target is described as under revision, and the 2024 scope change is given as the reason. Measured outcomes are disclosed and moved in the right direction: non-recycled and non-reused waste fell from 39,040 tonnes and 84% of waste generated in 2024 to 36,878 tonnes and 80% in 2025 (page 270).

Resource outflows

Reference: pages 269-270 (section 4.2.3.3 "Metrics - Waste management and circularity (E5-5)", sub-heading "Resources outflow (E5-5)").

This is the section the company labels E5-5, and it is scoped to waste: "Air France-KLM reports the waste generated in its own operations, broken down into hazardous and non-hazardous waste, and by the different treatment types for these types of waste. Allocation to the different categories is based on the EURAL codes used in its waste management systems and by the waste management providers" (page 269). Unusually for this statement the boundary extends past own operations: the basis of preparation flags section 4.2.3.3 as the exception to the rule that "metrics do not include value chain data" (page 208), and catering and cabin waste at outstations is estimated from hub data and passenger numbers.

Headline outflow figures for 2025 (page 270): total waste generated 46,173 tonnes (46,742 restated); diverted from disposal 31,016 tonnes; directed to disposal 15,157 tonnes; non-recycled and non-reused 36,878 tonnes, or 80% (84% in 2024). Radioactive waste is nil.

What the section does not contain. No products-and-materials outflow datapoints: no expected durability of products, no recyclable content, no recycled content in products or packaging.

Waste

Reference: pages 269-270; inventory table at page 270.

2025 waste inventory in tonnes, with restated 2024 comparatives:

Two prior-year corrections: "Following a reporting error in the waste data directed to incineration in 2024 (reported in kilos instead of tons), the data has been corrected", and cabin waste at outstations was reclassified "from 'Incineration' to 'Other disposal operations'" after "no evidence was found to substantiate the precise waste treatment type for this stream". The superseded total was "52,217 tons, of which 44,514 tons (85%) were non-recycled and non-reused".

Policies related to own workforce

Reference: five labelled policy sections, one per material sub-topic: Social dialogue (page 286), Working conditions (page 288), Diversity, Equity and Inclusion (page 294), Talent attractiveness, development and training (page 301), Working rights and human rights (page 306). "Each policy mentioned in the following sections regarding our own workforce is under the responsibility of the EVP Human Resources of each company of the Group", and "Three core values underpin the Group's people strategy: respect, transparency, trust" (page 283).

Social dialogue (page 286): "The Group endeavors to comply with and promote the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work and its fundamental conventions", and "respects Human rights..., Labor rights, freedom of association, the right to collective bargaining and the right of all employees to form or join trade unions in accordance with local law."

Diversity, Equity and Inclusion (page 294): the Group "affirms its commitment to fostering a climate of trust and mutual respect in a work environment where no form of discrimination, microaggression, or harassment is tolerated".

Working rights (page 306): the Group "recognizes and complies with" the UN Global Compact, the OECD Guidelines, ILO fundamental conventions and "UNICEF's Rights of the Child and Business Principles", and has been a Global Compact signatory since 2003.

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

Reference: engagement sections at pages 286, 289, 295, 302 and 307; stakeholder overview at page 214.

"The Group communicates and negotiates actively with employees and their representatives to continually enhance the workplace, including through the development of collective agreements. The Human Resources leaders of each entity ensure the promotion of social dialogue" (page 286). Social dialogue "is considered essential to enable the company to adapt, maintain social peace, and ensure both operational efficiency and employee well-being in a dynamic and sometimes challenging environment."

Structures and channels: "the Group's European Works Council brings together the representatives of staff whose head offices or entities are based in the European Area" (page 286), each airline has its own works council and health and safety committee arrangements, and the Employee Promoter Score is "used by Air France, KLM and Transavia to measure employee satisfaction", alongside internal barometers and feedback channels (page 214).

One 2025 detail links engagement to this report: the European Works Council "met twice in plenary session in addition to several working sessions, including on sustainability reporting" (page 287).

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

Reference: channels sections at pages 286, 290, 295, 302 and 307; the grievance datapoint is mapped in the appendix to the DEI and working rights channels sections (page 341).

Health and wellbeing channels at Air France (page 290): "an on-site network of dedicated professionals - including doctors, psychiatrists, nurses, social workers, prevention specialists, and advisors in health, safety, and quality of life at work". Since 2021 Air France has offered "a completely anonymous and confidential psychological support and advice program with a 24/7 number (from an external company)", and a "Critical Incident Response Program" for pilots and cabin crew.

New in 2025 (page 290): "A center for the prevention and combating of workplace violence was created in July 2025. This means that every Air France employee, regardless of their job or department, can report any violence they believe they have been subjected to in the course of their professional activities... A response will always be provided."

At Transavia France there is "an alert and handling procedure as part of a charter on psychosocial risks" with a permanent hotline; at Transavia Netherlands employees report to "their Manager, HR Business Partner, Confidential Advisors or General Council" (page 296).

No disclosure is made of whether workers are aware of or trust these channels.

Taking action on material impacts on own workforce

Reference: action sections at pages 287, 290-292, 296-297, 303 and 308.

Social dialogue, 2025 activity (page 287): Air France held "2 meetings of the French Group Committee, 11 meetings of the Central Social and Economic Committee (CSEC)"; "KLM convened 10 meetings with the works councils at central level", including "10 with the Health and Safety Committees"; Transavia France held 11 Works Council meetings, Transavia Netherlands 12. Agreements concluded include an Air France wage agreement, three-year profit-sharing, professional equality, Health and Quality of Life at Work, and "a Collective Mutual Termination and End-of-Career scheme for certain Ground functions". At KLM, "To limit the social impact of the Back on Track program, mobility measures were implemented, including protective provisions for non-voluntary departures and promoting internal mobility."

DEI (pages 296-297): IATA's "25by2025" initiative; the Wo&Men network with 700 members; the Autre Cercle charter and #StOpE; a neurodiversity working group launched in 2025; Transavia France's first Diversity & Inclusion agreement.

Engagement (page 292): the "Partners for the Future" shareholding plan "attracted 17,000 participants in 19 countries... approximately 22% of the total workforce". No resources are quantified.

Targets related to own workforce

Reference: targets sections at pages 286, 290, 296, 302 and 307.

Quantified targets, DEI (page 296): "Air France-KLM has set itself a long-term objective of reaching parity between men and women within the Group Executive Committee and within the top 10% highest levels of management." Medium-term, "targets of a minimum of 40% women within the Group Executive Committee and 40% of the top 10% highest management level positions to be held by women by 2030 have also been set by the Board of Directors". Separately, "Air France is committed to recruiting at least 50 disabled people over the period 2024-2026 and carries out around 250 measures a year to maintain disabled people in employment." Progress is disclosed: women are 36% of the GEC (27% in 2024) and 37% of the top 10% of management (36%) (page 299).

Observation. Outside diversity the targets are directional: no target value is set for accident rate, absenteeism, turnover, training hours or the gender pay gap, and the accident rate rose from 34.6 to 35.8 per million hours worked in 2025 (page 293).

Characteristics of the undertaking's employees

Reference: pages 283-285 (section 4.3.1.1 "Characteristics of Air France-KLM employees (S1-6)").

Metrics are "reported in headcounts, based on the contractual relationship with the entity under which they are reported... analyzed at the reference date, which is the last day of the reporting period" (page 283).

Headcount by staff category, 2025 (page 283): total 90,128 (89,109 in 2024) - ground staff 51,826, cabin crew 27,791, flight deck crew 10,511. By airline: Air France 44,559, KLM 28,799, Transavia France 3,600, Transavia Netherlands 2,912.

By region and country (page 284): France 48,556, the Netherlands 33,239, rest of Europe 2,594, Asia and Middle East 1,894, North America 1,229, Caribbean and Indian Ocean 1,144, Central and Latin America 843, Africa 629. "France and the Netherlands, represent over 90% of the total number of employees. The remaining 10% of the workforce is based in more than 100 countries."

By employment type and gender (page 285): permanent 84,042 (93.2%, from 92.4%), temporary 5,949 (6.6%), non-guaranteed hours 137 (0.2%), "with no significant difference between female and male". Group split 41,350 female, 48,777 male, 1 other.

Turnover (page 285): 7,526 leavers against 90,128 employees, a rate of 8.4% (7.5% in 2024). No breakdown of leavers by reason is given.

Collective bargaining coverage and social dialogue

Reference: pages 287-288 (section 4.3.1.3.7 "Metrics - Social dialogue (S1-8)").

Reporting principles (page 287): "The coverage rate for collective bargaining is an indicator of the proportion of employees to whom one or more collective bargaining agreements apply. The coverage rate for workplace representation shows the proportion of employees who are represented by trade union representatives or duly elected representatives." Scope is stated explicitly: "The scope of the coverage rate for both collective bargaining and social dialogue covers the countries in the European Economic Area (EEA) where the Group has significant employment."

2025 coverage by staff category (page 288):

Observation. Employees outside the EEA, around 10% of the workforce across more than 100 countries (page 284), are outside the denominator, so near-total coverage describes the EEA population only.

Diversity metrics

Reference: pages 298-299 (section 4.3.1.5.7 "Metrics - Diversity, Equity and Inclusion (S1-9, S1-12, S1-16)").

Gender by staff category, 2025 (page 298): total 90,128 employees, 41,350 female, 48,777 male, 1 other. Ground staff 19,995 female and 31,830 male (39% / 61%); cabin crew 20,519 and 7,272 (74% / 26%); flight deck crew 836 and 9,675 (8% / 92%). Group split 46% female, 54% male.

Age distribution (page 298): under 30 years 13,075; 30 to 50 years 38,684; over 50 years 38,369. "At the end of 2025, 15% of the Air France-KLM employees were 30 years old or younger (14% in 2024), and 43% were 50 years old or older (42% in 2024)."

Top management (page 299), defined as four categories: the Group Executive Committee, the top 10% of highest management level for ground staff, cabin crew in managerial functions and flight deck crew in managerial functions.

The flight deck managerial share fell slightly year on year. Women are 8% of pilots, which the company gives as the main driver of its gender pay gap (page 300).

Adequate wages

Reference: page 292 (section 4.3.1.4.7, sub-heading "Adequate wages (S1-10)").

The disclosure is four sentences and is a compliance statement rather than a benchmark calculation:

"Air France-KLM complies with the minimum wage laws in all the countries it operates. This ensures that all employees receive at least the legally mandated minimum compensation. The Company adheres to employment standards and regulations that govern working hours, overtime pay, and other wage-related issues. Air France-KLM applies an adequate wage strategy by balancing internal equity, market competitiveness, regulatory compliance, and additional benefits."

Assessment. The company asserts that all employees are paid at or above the applicable statutory minimum, which answers the first limb of the requirement. What it does not do is state the percentage of employees paid below an adequate wage benchmark, identify the benchmark used, or break the position down by country outside the EEA. The implicit answer is nil, by reference to statutory minima rather than to a living wage benchmark.

Context: more than 90% of the workforce is in France and the Netherlands, with the remaining 10% across more than 100 countries (page 284), and collective bargaining covers 99.2% of EEA employees (page 288).

Persons with disabilities

Reference: page 300 (section 4.3.1.5.7, sub-heading "Employees with disabilities (S1-12)").

Reporting principles: "The total number of employees with disabilities within Air France-KLM's own workforce is computed based on the local definition of an employee with disabilities, and may include self-declared employees with disabilities or employees with disabilities recognized as such by the local employment law, for instance, in the context of a mandatory share of employees with disabilities in the concerned French entities."

Figure: "Percentage of employees with disabilities 3.4%" in 2025, against 4.1% in 2024.

The fall is a scope change, not a decline: "In 2025, following a clarification in the local regulation in force in the Netherlands, the number of employees with disabilities of the Dutch entities have been added to the reporting. As a consequence, the percentage of employees with disabilities stands at 3.4% at the end of 2025 (without change in scope of reporting, the total percentage of employees with disabilities would have increased from 4.1% in 2024 to 4.3% in 2025)."

The percentage is not broken down by gender or country, and the prior year is not restated on the new scope, so 3.4% and 4.1% are not directly comparable; the company supplies the like-for-like comparison in words instead.

Training and skills development metrics

Reference: page 305 (section 4.3.1.6.7 "Metrics - Talent attractiveness, development and training (S1-13)").

This is the one disclosure Air France-KLM explicitly took outside the phase-in reliefs: it uses all the relevant Appendix C provisions "except for the information on the average number of training hours (see section 4.3.1.6.7...) that is already included in this sustainability statement" (page 209).

Reporting principles: "Training hours correspond to the number of hours spent on initiatives that are aimed at maintaining and/or improving skills and knowledge. Training hours include both regulatory and non-regulatory training as well as different training types (e.g., onsite, online)."

Average training hours, 2025 against restated 2024:

Methodology change: "A revised method for calculating training hours for cabin crew has been implemented in 2025", with 2024 recalculated; the previously published 2024 total was "34.8 hours". The percentage of employees in regular performance reviews is not disclosed.

Health and safety metrics

Reference: page 293 (section 4.3.1.4.7, sub-heading "Health and Safety (S1-14)").

Reporting principles: fatalities "are reported when they are related to the work of the employees, within the boundaries set in the applicable national, local, and conventional rules". "The rate of work-related accidents is calculated as a ratio of one accident to one million hours worked (following the guidance available in the ESRS S1-14 AR 89 standard)", with hours worked using actual time or "the best estimate according to the contractual working time after deduction of paid leave or absences from work (following the guidance available in the ESRS S1-14 AR 90 standard)".

2025 figures:

• Employees covered by the health and safety management system 96.1% (95.6% in 2024)
• Number of fatalities nil (2)
• Number of work-related accidents 4,441 (4,146)
• Rate of work-related accidents per million hours worked 35.8 (34.6)

Two gaps. No days lost to injuries, accidents, fatalities or illness is reported, even though the EU-legislation appendix maps that datapoint to this very section (page 341); it falls under the Appendix C phase-in the company applies (page 209). No work-related ill health cases, and no figures for value chain workers on the Group's sites, are reported.

Compensation metrics (pay gap and total compensation)

Reference: page 300 (gender pay gap) and page 292 (total remuneration ratio).

Gender pay gap (page 300). Reporting principles: "The gender pay gap of Air France-KLM is calculated based on the average total gross hourly pay levels of male and female employees within the most significant entities. The gender pay gap is calculated based on the gap of each entity in scope, and averaged at the Air France-KLM Group level based on the relative number of employees of each entity."

Figure: unadjusted gender pay gap 36.2% in 2025, against 34.4% in 2024. The gap widened by 1.8 percentage points.

The company explains and qualifies it: "The AFKL gender pay gap of 36.2% in 2025 (34.4% in 2024) is unadjusted. It does not take into account the specificities of the different categories of employees in terms of gender representativity and remuneration schemes. This pay gap is mainly due to the fact that women are underrepresented in positions with higher remuneration levels, such as pilots (only 8% of pilots are women)."

Annual total remuneration ratio (page 292). A cross-reference: the ratio "can be found in section 2.5.2.3 'Ratios on the multiples of compensation paid to the executive officers in 2025' in the Corporate governance report." No figure and no contextual explanation appear in the sustainability statement.

Incidents, complaints and severe human rights impacts

Reference: page 308 (section 4.3.1.7.7 "Metrics - Working rights and human rights impacts (S1-17)").

2025 figures:

• Complaints filed by employees 56 (57 in 2024)
• Complaints filed to national contact points within OECD nil (nil)
• Incidents of discrimination, including harassment 16 (20)
• Severe human rights incidents nil (nil), and nil under the UN/ILO/OECD framework
• Fines, penalties and compensation for severe human rights incidents nil (nil)
• Fines, penalties and compensation for the incidents and complaints €0.1 million (€0.2 million)

Context from the same section. Harassment and workplace violence e-learning "has been mandatory for all employees since early 2025 and has been integrated into training programs for all new hires"; in 2025 "Air France also established a dedicated unit for the prevention of workplace violence and harassment and signed an agreement titled 'Preventing and Acting Against Workplace Violence and Harassment'", with in-person sessions to follow in 2026.

Policies related to value chain workers

Reference: pages 310-311 (section 4.3.2.2.1 "Policies - Value chain workers (S2-1)").

The Air France-KLM Principles, "developed in cooperation with the European Works Council and staff representatives", are "based on the United Nations (UN) Global Compact, the Universal Declaration of Human Rights, and the ILO's Conventions on Fundamental Principles & Rights at Work", and all value chain parties are encouraged "to engage with these principles and apply them to all value chain workers".

The Responsible Procurement programme runs "under the leadership of Air France-KLM SVP Procurement specifically for all upstream value chain suppliers contracted by the two largest airlines within the Group, Air France and KLM", on "a risk-based approach identifying high-risk and critical suppliers". Two instruments: "a Supplier Sustainability Code of Conduct, which is mandatory for all Air France-KLM Procurement contracted upstream suppliers", and "an EcoVadis Assessment (mandatory for all... high-risk contracted upstream suppliers)". The Code "covers social topics such as freedom of association and collective bargaining, wages and working hours, and health and safety".

Downstream coverage is narrow: "Air France-KLM and its largest downstream IT supplier have contractually agreed to comply with all rules and regulations pertaining to labor protection and working conditions" (page 311).

Processes for engaging with value chain workers about impacts

Reference: page 311 (section 4.3.2.2.2); supplier engagement overview at page 213.

"Air France-KLM buyers engage with the account manager of contracted suppliers before and after the initiation of an EcoVadis assessment (regarding Air France-KLM's expectations of suppliers and regarding the initiation of a Corrective Action Plan in the event of an insufficient score below the compliance threshold Air France-KLM applies, respectively)."

Accountability: "The ultimate responsibility for engagement with contracted Air France-KLM suppliers regarding identified risks lies with both the involved senior management (EVP/SVP/VP) as well as with the Air France-KLM Domain Procurement Officer (DPO). In the event that suppliers do not respond and/or adhere to the applicable procurement policies, these senior managers need to approve exceptions."

Engagement is with suppliers, not workers. The Group "seeks to engage with suppliers based on their EcoVadis assessment score to promote the improvement of their sustainability performance and/or discontinue suppliers that do not meet the Group's requirements through the application of a compliance threshold" (page 213). During the double materiality assessment "a group of contracted upstream suppliers from the aeronautical sector were interviewed" (page 309). The report makes no claim of direct engagement with value chain workers or their representatives.

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

Reference: page 311 (section 4.3.2.2.3).

Detection: "For contracted upstream suppliers, the Air France-KLM Procurement department has a risk screening process in place, which incorporates EcoVadis risk data, which is the basis for engagement by an Air France-KLM buyer with its formal contact with a supplier. This risk screening and assessment process is a continuous process." The limit is stated plainly: "The current risk screening and assessment process is not geared towards specifically identifying the more vulnerable value chain workers."

Remediation: "If negative impacts are detected, the Air France-KLM Procurement department will request that its regular supplier contact person develop and implement a Corrective Action Plan (CAP). During the implementation of this CAP, its effectiveness is actively monitored. A Corrective Action Plan is automatically requested in case suppliers achieve an Overall Score below the Compliance Threshold that Air France KLM Procurement maintains."

Stated gap: "As there is no formal assessment process in place yet to assess awareness and trust or to protect against retaliation, the Group expects to review its practices in the coming years". No number of value chain reports received or remediated is disclosed.

Taking action on material impacts on value chain workers

Reference: page 312 (section 4.3.2.2.5 "Actions - Workers in the value chain (S2-4)").

Three action plans are set out:

1. Empowering the buyers. "All buyers must sign a Code of Ethics, which outlines the ethical rules they must follow when dealing with suppliers. In this Code of Ethics, it is specifically stated that procurement functions must be very vigilant in ensuring that working rights and social dialogue regulations are complied with within the contracted suppliers." On training: "All new buyers attend a 'License to Buy' training, which provides a full-day classroom training, including exercises, on ESG topics with an emphasis on context, company ambitions, and the role of the buyer", and a Procurement Academy provides "a mandatory e-learning program for procurement staff".

2. Mobilizing and innovating with suppliers (supplier engagement).

Supporting change in 2025 (page 310): the Procurement department "has updated its purchase-category based risk-mapping to match the new procurement taxonomy that was introduced in the fourth quarter of 2025", which "will enable enhanced identification of specific groups of value chain workers that are most impacted/dependent or are at material risk."

The actions are upstream, supplier-facing and process-based, with no resources quantified. The GOV-4 due diligence mapping omits S2-4 from element d) even though this section exists (page 221).

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

Reference: page 312 (section 4.3.2.2.4 "Targets - Workers in the value chain (S2-5)").

Two quantified targets are disclosed with their 2025 results:

• Supplier Sustainability Code of Conduct signature. "Air France-KLM Procurement has set a target for the signing of the Air France KLM Supplier Sustainability Code of Conduct (or its equivalent) by its suppliers, registered as being in compliance with the Supplier Code of Conduct (2025 target: 85%; 2025 result: 74% in 2025)." The target was missed by 11 percentage points, and the company gives its reason: "The drop in the percentage of signed Code of Conduct can be explained by the revised definition of contracts to be included on the reporting based on the contract status and exclusion of expired codes of conduct."
• EcoVadis assessments. "the EcoVadis assessment (2025 target: 700 assessed suppliers with a score above or equal to 45; 2025 result: 700 assessed suppliers in 2025)." The count target was met; the result does not state how many of the 700 scored at or above 45.

"These targets are reviewed on a yearly basis. The responsibility for realizing these targets lies with the senior management in Air France-KLM Procurement."

Both targets measure process coverage of suppliers rather than outcomes for value chain workers.

Policies related to affected communities

Reference: page 314 (section 4.3.3.2.1 "Policies - Noise hindrance management (S3-1)").

The S3 topic is scoped to one matter: the chapter is titled "AFFECTED COMMUNITIES - NOISE HINDRANCE MANAGEMENT (ESRS S3)" (page 313). The material IRO is an actual negative impact, "Noise hindrance of Air France-KLM activities can have negative impact on living conditions of communities close to Air France-KLM hubs", plus a financial risk "as a result of noise regulations leading to activity constraints (loss of airport slots) or increase in costs", concerning communities near "Charles de Gaulle (CDG), Orly (ORY), and Schiphol (SPL)".

The policy (page 314): "Air France-KLM recognizes its responsibility to minimize noise pollution for those living near airports. This commitment, formalized in the Air France-KLM Principles, reflects the Group's dedication to balancing operational efficiency with environmental responsibility." "The most senior level in the organization accountable for the implementation of these principles is the Air France-KLM Group Executive Committee."

Observations. The policy is a one-paragraph commitment inside the Air France-KLM Principles rather than a standalone community or human rights policy, and it is the only S3 policy disclosed. Because the material topic is noise alone, nothing is disclosed on land rights, indigenous peoples, or communities' economic, social and cultural rights (page 349).

Processes for engaging with affected communities about impacts

Reference: page 314 (section 4.3.3.2.2); stakeholder overview at page 216.

"Environmental Noise Protection Plans (PPBEs), established within the framework of European Directive 2002/49/EC, are updated every five years. The mandate for the Environmental Consultative Committees (CCEs) is three years."

Netherlands: KLM participates with other airlines in the "Minder Hinder ('Less Hindrance') programme, in collaboration with Schiphol and Dutch air traffic control", whose website "also provides updates on measures deemed unfeasible or impossible to implement, ensuring transparency about expectations". "Prior to the launch of the program, approximately 1,000 responses were collected from residents and municipalities, which were used to refine and enhance the program." KLM also joins the "National Sounding Board", "a working group focused on developing a new noise management system alongside various stakeholders, including residents, municipalities, and environmental organizations".

No assessment of engagement effectiveness, and no named accountable function, is disclosed.

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

Reference: pages 314-315 (section 4.3.3.2.3).

The Balanced Approach (page 315): it "requires that all available options be evaluated to identify the most cost-effective measure or combination of measures to mitigate a specific noise problem", through four pillars: "1. Reduction of Noise at Source; 2. Land-use Planning and Management; 3. Noise Abatement Operational Procedures; and 4. as a last resort, Operating Restrictions."

Channels (page 315): "Mechanisms for affected communities to raise their concerns, such as consultative and action-oriented platforms like the Environmental Consultative Committee (CCE), Advisory Residents Assistance Commissions for Air France, and the National Sounding Board for KLM... The issues raised by these consultative platforms are considered in the Balanced Approach processes."

Financial remediation (page 316): home insulation in France is funded by the Airport Noise Tax (TNSA), which "has already reached €900 million (cumulative amount) at the national level, of which €745 million is for the Paris airports"; in 2024 the Dutch Ministry introduced "a new €25 million tax to supplement the €577 million already charged for insulating homes in the Schiphol area."

The channels are regulatory consultation bodies rather than a Group grievance mechanism, and no complaint or remediation volumes are reported.

Taking action on material impacts on affected communities

Reference: pages 315-316 (section 4.3.3.2.5 "Actions - Noise hindrance management (S3-4)").

Three classes of measure are named: "actions aiming to reduce noise at the source, such as fleet renewal"; "operational procedures such as continuous descent (approach procedure) or noise abatement procedure (take off procedure)"; and "adjustments to flight schedules (times, aircraft type)".

Operational procedures (page 315): collaboration with air traffic control "to optimize descents and takeoffs", and support for "the French and Dutch governments and the Civil Aviation departments in the swift and broad adoption of continuous descent procedures at all airports".

Regulatory packages the Group operates within (page 316). The Dutch ministry notified on December 6, 2024 a Balanced Approach package including "use of quieter aircraft at night", "exclusion of noisy aircraft at night, down to -13 EPNdB", "a maximum of 27,000 night flights" and "capacity reduction to a maximum of 477,000 to 478,000 aircraft movements per year". For Paris-Orly "a new regulatory text was published in July 2025... It gradually introduces, between 2026 and 2029, a strict curfew from 10:00 pm for the noisiest aircraft (those having a cumulative noise margin under 17 EPNdB)". "The Balanced Approach is still ongoing for Paris-CDG."

No resources are quantified for the noise actions themselves.

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

Reference: page 315 (section 4.3.3.2.4 "Targets - Noise hindrance management (S3-5)"); metric at page 316.

The target disclosed is the fleet renewal target, presented as the noise lever:

"New-generation aircraft, whose noise footprint is reduced by at least 30% and up to 60% compared to the aircraft they replace, are a powerful lever for reducing the noise footprint around airports. Air France-KLM has put in place a fleet renewal plan, progressively eliminating the oldest aircraft and aiming for up to 80% of its fleet to be new-generation by 2030."

The company explains its choice of measure: "In 2023, 100% of the Air France-KLM fleet was eligible for certification under the noise level criteria of ICAO Chapters 4 or 14. Therefore, in 2024, Air France-KLM decided to focus on Chapter 14 only, corresponding the strictest ICAO noise level criteria at the moment."

Assessment. This is a fleet composition target, not a noise outcome target: no target is set for the Chapter 14 share itself, nor for noise-exposed population, noise contour area or complaint volumes. Affected communities are not said to have been involved in setting it.

Policies related to consumers and end-users

Reference: four labelled policy sections: information and assistance for cancellations and delays (page 318), access to services for passengers with disabilities (page 320), safety and security (page 322) and cybersecurity and data protection (page 333).

Passenger rights (page 318). The policy is compliance with Regulation (EU) 261/2004, under which "airlines must provide assistance, compensation, and refunds depending on the circumstances and the length of the delay or cancellation... Compensation varies between €250 and €600 based on the flight distance and duration of the delay." The Group applies EU261 "to all flights across their global network", and also complies with local rules such as those of the US Department of Transport and the Canadian Transportation Agency.

Safety and security (page 322): "Each airline in the Group maintains and develops a Safety Management System (SMS) based on its respective Safety Policies, which hold formal approval by the Civil Aviation Authorities in each country", signed at CEO or Accountable Executive level.

Data protection (page 333): the Group "is committed to processing personal data in compliance with the General Data Protection Regulation (GDPR) and other applicable privacy laws".

Processes for engaging with consumers and end-users about impacts

Reference: engagement sections at pages 318, 320, 322 and 333.

Passenger rights (page 318): customers can access the policy "At any time on all Air France/KLM/Transavia France/Transavia Netherlands websites", file a complaint or refund request there, and "Information about passengers' rights is also pushed to any customers impacted by a disruption via emails". "The Senior Vice President Loyalty, Digital and Data oversees the management of digital platforms", while complaints and refunds sit with "dedicated care and refund teams".

Accessibility (page 320): "The Group collaborates continuously with passengers with disabilities, representative associations, and experts to better understand lived experiences and identify improvement priorities. This dialogue takes many forms: structured consultations, co-creation sessions, and ongoing feedback exchanges with a group of engaged customers who test digital platforms, assess communication clarity, and share insights on airport and on-board experiences." These interactions "directly informed several improvements within the 2025-2026 roadmap, including simplified pre-travel communication, clearer wheelchair return procedures, and enhanced staff awareness modules."

Satisfaction is measured through the Net Promoter Score, collected via the e-Score questionnaire and tracked daily (page 324).

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

Reference: remediation sections at pages 318-319, 320, 322-323 and 334.

Passenger rights (pages 318-319): "the approach to remediate negative impacts for customers includes compliance with Regulation 261/2004, which mandates assistance, compensation, and refunds for passengers in the event of cancellations and delays." On coordination: "Air France and KLM legal teams translate the content of the EU 261 obligations into compliant business guidelines to be met by Ground and Commercial operational teams, and continuously identify necessary adjustments to these obligations triggered by European case law." All agents handling complaints or refunds "have been trained with the same materials".

Accessibility (page 320): "Every incident is documented and reviewed through a central reporting structure shared across Customer Experience and Ground Operations. When mobility aids are delayed or damaged, passengers receive immediate support and tailored follow-up, including compensation where applicable. Root-cause analyses identify procedural or technical failures". An outcome is claimed without being quantified: "Over the past two years, this systematic feedback approach has led to a measurable reduction in service failures".

No complaint or incident volumes are disclosed for any of the four sub-topics.

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: action sections at pages 319, 321, 323 and 334.

Reducing disruption at source (page 319). Plans include "adaptation of the number of spare aircraft to reduce flight cancellations"; "outsourcing some maintenance activities (e.g., part of the Airbus A-check to Brussels and the Boeing 737 C-check to the UK)"; "the Right on Time program to analyze and improve the departure process from the hub and improve D-0 (departure on time) performance"; "development of data analysis/artificial Intelligence and tools to improve operational performance"; and a "common action plan with Eurocontrol and modernization of the Air Traffic Control (ATC) system in France to reduce ATC delays".

Safety and security (page 323): activities are "subject to numerous checks and certifications, in particular, via the supervisory actions carried out by the Civil Aviation Authorities in each country", supported by IOSA, ISO 14001 and ISO 50001.

Cybersecurity (page 334): annual mandatory training for all employees, a "Privacy Maturity Program" across Air France, KLM and the joint businesses, "Independent audits, automated controls, vulnerability assessments, and regular penetration testing", and ISO 27001 alignment. No spend is quantified.

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

Reference: targets sections at pages 319, 320, 323 and 334.

Accessibility carries the quantified targets (page 320). "By 2026, all Group websites, mobile apps, and self-service tools will comply with WCAG 2.1 AA digital accessibility standards"; "Air France-KLM is committed to reducing incidents involving mobility aids by at least 20% compared to the 2023 baseline, through better tracking, pre-loading verification, and stronger partnerships with ground handlers"; and "The target for 2026 is to achieve and sustain an 85% satisfaction rate, measured through post-travel surveys and dedicated NPS tracking." An "Accessibility Compliance Index, introduced in 2024, serves as an internal benchmark".

Cybersecurity and data protection (page 334): one line, "No specific targets have been set regarding data privacy."

Effectiveness measure (page 324). The Net Promoter Score is reported as annual change by brand: Air France +3 (2024: +2), KLM -2 (nil), Transavia France +10 (-8), Transavia Netherlands +9 (-8). No progress figure is yet published against the mobility-aid incident or accessibility satisfaction targets.

Business conduct policies and corporate culture

Reference: pages 325-326 (sections 4.4.1.1 "Corporate culture (G1-1)" and 4.4.1.2 "Governance - Corporate culture in business conduct (G1 - ESRS 2 GOV-1)").

The Group "adheres to leading international ethical standards, including the United Nations Global Compact, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the core conventions of the International Labor Organization, and UNICEF's Rights of the Child and Business Principles" (page 325).

Top management role (page 326). It oversees: (a) implementing an organisation and governance for compliance, including validating the appointment of the Group Compliance VP and ensuring "that such person has sufficient autonomy, influence over internal stakeholders, experience, adequate resources, and high positioning to get direct access to Top Management for reporting"; (b) validating and monitoring compliance programmes, "the control framework for the compliance programs and the reporting mechanisms (including the whistleblowing tools)", and, "In case of incidents... validat[ing] sanctions and remediation plans"; (c) fostering a culture of fair and ethical business conduct.

A "Competition Law Compliance Manual" supports the anti-competitive-practices policy, with a 2024-2025 e-learning reaching "a completion rate of 97%" against a target above 96% (page 331).

The disclosure does not state how the corporate culture is evaluated.

Prevention and detection of corruption and bribery

Reference: pages 327-330 (section 4.4.1.3 "Prevention of corruption and bribery & Protection of whistleblowers (G1-3, G1-4)").

Functions most at risk (page 327). Determined by ability to influence decisions at the highest levels, location assessed using "the Corruption Perception Index published each year by Transparency International association", the nature of tasks (procurement, sales, public affairs, sponsoring) and the corruption risk map.

Anti-Corruption Code of Conduct (pages 327-328): it binds all employees "as well as by any third parties with whom it does business", and is drafted against "the US Foreign Corrupt Practices Act, the UK Bribery Act, the French Sapin II Law, and French and Dutch Criminal Codes", covering "gifts and hospitality, conflicts of interest, facilitation payments, lobbying, sponsorship and patronage, and relations with third parties".

Risk assessment and three lines of defence (pages 329-330): "Last full corruption risk map campaign was deployed in 2024 within the Air France KLM Group. It was reviewed in 2025 to ensure it was still relevant." Level 1 sits with business units, Level 2 with Ethics Compliance Officers, Level 3 with internal audit.

Whistleblower protection (pages 328-329): "The investigators work independently from the chain of management responsible for preventing corruption and bribery", and whistleblowers are "protected against all forms of retaliation".

Targets related to business conduct

(part of MDR-T/GDR-T disclosures)

Reference: pages 330 and 331. The statement was prepared under the 2023 ESRS, where business conduct targets fell under MDR-T rather than a standalone G1 targets requirement, so no section carries a targets code. The G1 chapter nonetheless discloses targets with their completion rates.

The anti-corruption training target and its result (page 330). Top management validates "the panel of targeted employees and the contemplated completion rate". The indicator is tabled with its definition: "Completion rate of the e-learning on prevention of corruption - Number of employees with high risk exposure having completed the entire training program as of December 31 of the concerned year divided by the total number of employees invited to undertake this training", 2025 result 96.5%, being "5,804 of the individuals completing it... part of a compulsory panel of 6,016 persons".

Effectiveness tracking. "In 2025, 26 sessions have been held to cover a panel of 441 employees from Procurement, Engineering and Maintenance activities, Fleet, Network, Customer Experience, Inflight Services and Safety Departments" (page 330), and "An action plan is being implemented to address and reduce risks identified in the risk assessment" (page 329).

Observation. Both targets are training-coverage targets. No target is set for incidents, supplier screening, or any business conduct outcome.

Incidents of corruption or bribery

Reference: page 331 (section 4.4.1.3.1 "Metrics - Prevention of corruption and bribery (G1-4)").

2025 figures:

The narrative nil return is explicit: "In 2025, there was no conviction issued by any competent authority against the Air France KLM Group for violation of anti-corruption and anti-bribery laws. Nor was the Air France KLM Group requested to pay any fine for any such violations. There was no confirmed incident relating to corruption for which sanctions would have been issued against employees and corrective measures undertaken with actors in the value chain."

Consequences if an incident occurred: "sanctions and disciplinary measures can be applied to employees as stated in the Anti-Corruption Code of Conduct and the HR Internal Rules of the concerned entity". For third parties, "non-compliance with anti-corruption laws is deemed to be a material breach triggering damages and/or suspension and/or termination of the contractual relationship."

The number of reports received through the whistleblowing channels is not disclosed; employee-level complaint and discrimination counts appear under S1-17 instead (page 308).

Political influence and lobbying activities

Reference: pages 335-337 (section 4.4.3 "Political Engagement & Lobbying Activities, Economic & Social Value of Air Transportation (G1-5)").

Political contributions (page 336). "As part of its ethical principles, the Air France-KLM Group makes no direct or indirect financial contribution to any political organization or movement", footnoted as the "Disclosure requirements as per ESRS G1-5, §29. b)". Representation runs "through industry professional associations", and those with a transition-related remit "are committed to aligning their positions and actions with the Paris Agreement objective of keeping global warming below 1.5 degrees Celsius."

Contributions paid in 2025, in € million:

• Air France-KLM, HATVP scope (AFEP, MEDEF, Eden): less than 0.1
• Air France-KLM, EU scope (IATA, A4E, ENAA, E4FC): 0.4
• Societe Air France, HATVP (FNAM, MEDEF IDF, Avenir transports, Mouvement entreprises Val d'Oise, Union des marques): 0.3
• KLM (VNO/NCW): 0.2
• Transavia France (FNAM, MEDEF): less than 0.1

Governance (page 335): the Public Affairs department "represents the Air France-KLM Group in the standardization process that regulates its activities (passenger transport, cargo, maintenance)", and the Board "approves the Group's strategic orientations, including its social and environmental policies".

No EU Transparency Register entry is cited, and no revolving-door disclosure is made.