Allegro

Allegro.eu is incorporated under Luxembourg law and operates a one-tier, unitary management system in which the Board of Directors includes both executive Directors, who handle day-to-day management, and non-executive, supervising Directors, unlike most Polish companies that maintain separate management and supervisory boards. At the end of 2024 the Board comprised two executive Directors, the CEO and CFO, and eight non-executive Directors, individuals with extensive experience in leading international businesses across e-commerce, retail, and technology. The Board holds responsibility for ESG leadership, including oversight of ESG and climate strategy and flagship non-financial KPI performance, and it monitors corporate risk, defines the scope and direction of risk management, and sets risk appetite levels. It is kept informed on sustainability through three committees reporting directly to it: the Audit Committee, the Remuneration and Nomination Committee, and the ESG Committee. Detailed composition, diversity, and expertise information sits in the Management Review, chapter III.

The Board of Directors is regularly informed about sustainability matters through three committees that report directly to it, the Audit Committee, the Remuneration and Nomination Committee, and the ESG Committee. During 2024 the main topics of ESG interest and discussion covered the review of ESG impacts, risks, and opportunities including climate, the refreshed decarbonisation plan, and the ESG operational plan for 2025. Climate and ESG risks were discussed by the ESG Committee, operating as part of the former RemNomESGCo, and approved by the Board in 2024. The Board also regularly reviews key performance indicators for the satisfaction of employees, merchants, and customers, alongside security, compliance, whistleblowing, governance, and risk management updates. It approved the double materiality analysis and the stakeholders research report, and it revised and approved the list of impacts in March 2024. The ESG and Audit Committees held additional meetings on CSRD-aligned reporting, following which the Board adopted the Sustainability Reporting Policy.

Starting from 2024, sustainability-related targets are factored into the remuneration of the Executive Board of Directors and managers. When the annual bonus, referred to as the short term incentive, is determined, an ESG index is included as a key performance indicator. This index constitutes 10% of the Company Performance Index, meaning 10% of the on-target annual bonus is linked to the achievement of specific ESG-related goals. The ESG index consists of five annual targets directly tied to the Allegro Group's strategic ESG goals, with each of the five objectives carrying equal weight. The full list of ESG goals appears in the ESG 2024 performance chapter. Achieving these targets affects the size of the annual bonus, reflecting the Group's commitment to sustainability and responsible governance. The incentive system was approved by the Remuneration and Nomination Committee, which also holds the authority to update it.

The Allegro Group states that it exercises due diligence across a range of areas, including social and employee issues, environmental protection, procurement, and governance, covering corruption. A table maps the core elements of due diligence to the sections and disclosures where they are addressed. Embedding due diligence in governance, strategy, and the business model is covered under GOV-2, SBM-3, G1-1, and G1-2. Engaging with affected stakeholders in all key aspects is addressed in SBM-2, S1-2, and S4-2. Identifying and assessing adverse impacts is covered by IRO-1 and SBM-3. Taking action to address those adverse impacts is covered by E1-1, E1-3, E5-1, E5-2, S1-4, and S4-4. Tracking the effectiveness of these efforts and communicating is covered by E1-4, E1-5, E1-6, E5-4, and S1-17.

ESG risk management and climate risk management form part of the Allegro Group's Enterprise Risk Management, and non-compliance with reporting regulation is one of the risks identified in the double materiality process. The reporting scope is defined by the double materiality analysis, which is reviewed at least once every three years and double checked by the Board once a year. In 2024 the ESG and Audit Committees held additional meetings on CSRD-aligned reporting preparations, and on their recommendation the Board adopted a Sustainability Reporting Policy setting new standards aligned with the CSRD. The policy is updated regularly by the ESG team and approved by the Board at least annually. It requires at least two levels of data verification before delivery to the external auditor for limited assurance. Under the first line of defence the data controller checks accuracy, completeness, and verifiability, while the second line of defence, a central verification team, confirms data is complete and accurate and approves each metric. The four-stage process covers boundaries review, data gathering and calculation, data validation, and learning, and it is overseen by the CFO and the Chief Legal Officer.

The Allegro Group describes itself as the go-to online marketplace for consumers in Poland, the Czech Republic, Slovakia, and Hungary, and for merchants worldwide, with Allegro.eu acting as the holding company. Its business model generates revenue primarily by facilitating third-party transactions between consumers and merchants and charging commissions and other related fees, and it also runs limited-scale first-party retail operations selling products directly to consumers. Own operations include maintaining and developing the online platforms Allegro.pl, Allegro.cz, Allegro.sk, Allegro.hu, and Mimovrste, along with supporting services such as payments, technology, warehousing, and fulfilment. Downstream activities cover delivery through national providers or Allegro Delivery and Allegro One Courier, plus consumer use and end-of-life management for first-party products. The Group identifies two significant ESRS sectors, Transportation and Sales and Trade, with the remainder mainly from marketplace activity. Total revenue and other operating income for 2024 was 10,940 million PLN, comprising Transportation at 234, Sales and Trade at 1,669, and Other at 9,037. Employee numbers, gross merchandise volume, and active buyer figures are set out in the Management Review, chapter III.

For the double materiality analysis, the Allegro Group carried out a stakeholder engagement study using online surveys distributed to employees, merchants, and customers, groups selected for in-depth consultation because of their direct business relationships with the Group. The natural environment was treated as a silent stakeholder, and the perspectives of stakeholders not directly involved were assessed through publications, benchmarks, and reports, with press coverage reviewed to identify potential impacts, risks, and opportunities. The Group also analysed sustainability reports from suppliers and views stakeholder opinions as a reflection of interest in its further development, striving to integrate feedback into its strategy and business model. A stakeholder engagement table sets out the form, purpose, and outcome of engagement for employees, customers, merchants split into large, medium, small, and VIP, suppliers of products and packaging used in fulfilment, suppliers of services including IT and transport, and investors. The double materiality analysis and the stakeholders research report were approved by the Board of Directors.

During 2024 the Allegro Group conducted a double materiality analysis to determine its impacts, risks, and opportunities, all connected to its ESG strategy and business model and able to arise at any time across the value chain. The material items are organised by strategy pillar and topic, spanning All4 People with own workforce topics of equal opportunities and fairness and health and safety, consumer accessibility, and entity-specific charity, All4 Planet with climate change and resource use and circular economy, All4 Prosperity with suppliers' relations and merchants' value creation, and Good Governance with corporate governance transparency, cybersecurity, and consumer and product safety. The IROs cover own operations, upstream, and downstream across short, medium, and long term horizons, and all are covered by ESRS disclosure requirements except entity-specific items. The current and anticipated financial effects fall below the material financial thresholds, so no immediate action is required, though mitigating actions are undertaken and the Group does not plan to change its strategy or business model. A qualitative resilience analysis found the strategy and business model resilient to the identified risks.

To comply with the CSRD, the Allegro Group conducted a double materiality assessment examining sustainability matters from both impact and financial perspectives, covering each operating country: Poland as the main location, the Czech Republic, Slovakia, Hungary, Croatia, and Slovenia. The process ran in six stages: understanding the Group's context through past reports, benchmarks, internal policies, stakeholder surveys, and press coverage; conducting external and internal analyses to build a long list of potential impacts, risks, and opportunities; assessing impacts by type, scale, scope, irremediable character, and likelihood on a 1 to 5 scale, with financial materiality judged by magnitude and likelihood estimated from 0% to 100%; prioritising and validating results, treating topics scoring 3.25 and above as material and 3.8 and above as very highly material, with the Board approving the list in March 2024; a detailed assessment of risks and opportunities through the Enterprise Risk Management system; and final approval by the Risk Committees, the ESG and Audit Committees, and the Board. Time horizons were up to 1 year, 1 to 5 years, and 5 to 10 years. Topics including pollution, water, biodiversity, value chain workers, and affected communities were concluded non-material.

The 2024 Sustainability Statement discloses information resulting from the double materiality analysis and identifies the specific material topics: E1 Climate change, E5 Resource use and circular economy, S1 Own workforce, S4 Consumers and end-users, and G1 Business conduct. The full list of material disclosure requirements is presented in the Appendix. The Group applied the phased-in provisions permitted under ESRS 1 Appendix C for anticipated financial effects, specifically E1-9 and E5-6. Certain information is incorporated by reference to other parts of the Management Report, including the role of the administrative, management and supervisory bodies, the information provided to those bodies, the strategy and business model, and risk management. The Report also contains Task Force on Climate-related Financial Disclosures and Sustainable Finance Disclosures Regulation indicators, entity-specific indicators, and references to the Warsaw Stock Exchange ESG and European Bank for Reconstruction and Development ESG Reporting Guidelines, as well as to the Sustainable Development Goals.

The Allegro Group operates a decarbonization plan initially developed and approved by the Board of Directors in 2022 and updated in 2024 to meet new regulatory requirements. The plan is approved by the Science Based Targets initiative (SBTi) and aligns with limiting global warming to 1.5 degrees C under the Paris Agreement. Allegro has set a goal of reducing Scope 1 and 2 greenhouse gas emissions by 43% by 2030 compared to a 2021 base year. Within Scope 3, Allegro has committed to ensuring that suppliers representing 73% of spend on purchased goods and services, capital goods, and downstream transportation and distribution establish science-based targets by 2027. The strategy rests on five principles covering renewable electricity sourcing through Power Purchase Agreements or guarantees of origin, energy-saving initiatives, reducing shipping emissions via automated parcel machines, climate education, and offsetting unavoidable emissions only as a last resort. The plan is integrated with business strategy and financial planning, supported by Taxonomy-aligned capital expenditures, and supervised by the Chief Operating Officer.

Climate change is governed by the Allegro Group's Climate and Environment Policy, which applies to the entire Group's own operations and relates to the upstream and downstream value chain. The Policy sets out the strategy for managing impacts, risks and opportunities and minimising GHG emissions, committing the Group to maximise renewable energy use, reduce its operational carbon footprint, and work with business partners to reduce value chain emissions. It follows a three-tiered hierarchy of Emission Avoidance, Emission Reduction, and Compensation for Inevitable Emissions, with any purchased carbon offsets to be high quality and from credible, verified projects. The approach aligns with the Paris Agreement and SBTi standards and covers mitigation and adaptation themes including sustainable logistics, low emission deliveries, energy effectiveness, renewable energy, the circular economy, and education. All employees and contractors are responsible for implementation. The Policy was adopted by the Board of Directors, is overseen by ESGCo, and is reviewed and updated at least once a year. Violations trigger corrective actions reported to the CEO. The Policy is publicly available on the corporate website. A Risk Management Policy addresses climate-related risks.

Allegro pursued several decarbonization actions in 2024. Allegro Sp. z o.o. signed a virtual Power Purchase Agreement with R.Power and investment banks for 22 GWh yearly, which from mid 2025 is expected to cut CO2 emissions by nearly 12,000 tonnes yearly in Scope 2. The Group's own automated parcel machines in Poland and the Czech Republic use renewable energy confirmed by guarantees of origin, and the share of renewable energy rose from 14% to 26%. Energy efficiency actions such as closing inefficient locations improved energy intensity to 3.9 MWh/mPLN from 4.0 MWh/mPLN in 2023. As of 31 December 2024 the Group operated 5,068 automated parcel machines, and last mile delivery to these machines avoided 7,169 tCO2e. Reported avoided emissions include guarantees of origin at 6,564 tCO2e and energy effectiveness at 1,819 tCO2e in 2024, with the vPPA estimated to avoid approximately 143,000 tCO2e across 2025 to 2035. In 2024 CapEx on parcel machines amounted to mPLN 103.7 and OpEx to mPLN 11. Adaptation is not yet included as assessed risks are low.

The Allegro Group has set mid-term climate targets approved by the Science Based Targets initiative (SBTi). The main target is an absolute reduction of Scope 1 and 2 greenhouse gas emissions by 43% by 2030 compared to a 2021 base year, measured on gross emissions with no removals, carbon credits or avoided emissions. Emissions are expected to fall to about 8 thousand tonnes CO2e by 2030 from 14.2 thousand tonnes CO2e in 2021. In 2024 the Group revised the target upward from a previous 38% reduction, which had assumed a reduction from 11.7 thousand to 7 thousand tonnes CO2e, and recalculated the base year to include emissions of foreign entities acquired in 2022 (Mall Group, Mimovrste, and WE|DO). Within Scope 3, the Group commits to suppliers representing 73% of spend establishing science-based targets by 2027; in 2024 this reached 56% for the Allegro Group and 68% for Allegro Sp. z o.o. The Group does not plan to use carbon offsetting or emissions storage technologies, and achievement does not depend on new technologies.

Total energy consumption of the Allegro Group was 42,686 MWh in 2024, up 5% from 40,782 MWh in the restated 2023 figure. Total energy consumption from fossil sources was 28,682 MWh, down 9% and equal to 67% of total consumption, falling from 77% in 2023. This comprised natural gas at 4,064 MWh, crude oil and petroleum products at 1,978 MWh, and purchased electricity, heat, steam or cooling from fossil sources at 22,640 MWh. The Group does not consume coal or coal products. Total energy consumption from renewable sources rose 101% to 11,142 MWh, all from purchased electricity, heat, steam and cooling based on guarantees of origin, raising the renewable share to 26% from 14% in 2023. Nuclear sources contributed 2,862 MWh, or 7%, down from 9%. The Group does not produce renewable energy or generate self-generated non-fuel renewable energy. Energy intensity in high climate impact sectors was 59 MWh/mPLN for transportation and storage and 1 MWh/mPLN for wholesale and retail trade. The 2023 comparatives were restated after a natural gas calculation error.

For the Allegro Group in 2024, gross Scope 1 emissions were 1,301 tCO2e, none from regulated emission trading schemes. Gross location-based Scope 2 emissions were 18,893 tCO2e and gross market-based Scope 2 emissions were 12,758 tCO2e. Combined Scope 1 and 2 emissions were 20,195 tCO2e on a location-based basis and 14,060 tCO2e on a market-based basis, with a 19% reduction achieved in market-based Scope 1 and 2 during 2024. Total gross indirect Scope 3 emissions were 491,271 tCO2e, dominated by category 1 purchased goods and services at 322,634 tCO2e, followed by category 9 downstream transportation and distribution at 74,841 tCO2e, category 11 use of sold products at 61,485 tCO2e, category 2 capital goods at 18,602 tCO2e, category 4 upstream transportation at 6,999 tCO2e, category 12 end-of-life treatment at 4,563 tCO2e, and category 3 fuel and energy-related activities at 2,147 tCO2e. Categories 5, 6 and 7 were excluded as immaterial and categories 8, 10, 13, 14 and 15 are not applicable. Total Scope 1, 2 and 3 emissions were 505,331 tCO2e market-based and 511,466 tCO2e location-based. Polish operations account for about 70% of Group emissions.

Allegro has adopted a Circularity and Waste Policy to address its material impacts, risks and opportunities related to resource use and the circular economy. Its general objectives include achieving 100% sustainable packaging in own operations by 2028, reducing environmental impact and closing the loop on waste, with key elements of eco-design, reduction, reuse and recycling across the product life cycle. The policy applies to all Allegro.eu activities and subsidiaries, covering offices, warehouses, hubs and depots as well as upstream and downstream value chain activities. It emphasises secondary (recycled) materials, mono-material and sustainable packaging, defined as shipment without packaging, reused packaging, material with at least 70% recycled content, compostable packaging confirmed by certificates, or 100% recyclable packaging. It follows the waste hierarchy and references the Ellen MacArthur Foundation principles, the PPWR, the Single-Use Plastics Directive and Extended Producer Responsibility frameworks. The Operations Sustainability Team implements and monitors it, while the Board of Directors validates updates. The policy is publicly available. Allegro has not adopted a separate policy addressing overconsumption or a sustainable product range.

Allegro carries out circular economy actions within its own operations and externally, implementing the Circularity and Waste Policy, with commitments for suppliers and partners set out in the Supplier Code of Conduct. In 2024 it intensified support for merchants and customers. It launched an Eco Packaging Guide to educate merchants and customers on sustainable packaging choices and on avoiding greenwashing, and continued Allegro Pack, a store offering merchants packaging materials at bulk-negotiated prices. Own shop (1P) products are shipped under a Ship in Own Packaging principle where possible; otherwise recycled cardboard, paper tape and recyclable fillers are used. At the Adamów warehouse a machine processes post-consumer cartons into filling and cushioning material. Allegro collaborates with suppliers on eco-design and with waste management providers to improve recycling. It also expands products with certificates and, through the Allegro Lokalnie platform, promotes second-hand trade, reporting 4.96 million offers in Polish operations as of 31 December 2024. Allegro Academy educates merchants on sustainable shipping. Allegro does not disclose detailed CapEx and OpEx allocated to these plans.

Allegro's main target is to transition 100% of its own packaging, covering its 1P own shop and 1F fulfillment, to sustainable packaging by 2028. This commitment is voluntary and was set using stakeholder analysis and research among employees, merchants and customers, developed by the operation team, business owner and business sponsor and approved by the Board of Directors, drawing on Ellen MacArthur Foundation knowledge. There is no baseline year against which measurements are made. Packaging is considered sustainable when each part, whether box, tape, fillers or stretch film, meets the criteria set in the policy, and achieving the goal means Allegro will no longer use virgin materials in its packaging. In 2024 Allegro reported a 70% share of sustainable packaging in own operations, up from 49% in 2023, an increase of 21 percentage points. By decision of the Board, ESG goals are set only for the most significant areas, so no other targets related to resource use and circular economy have been established.

Various packaging materials are used for 1P shipments to protect products, sourced from renewable sources wherever possible. Total weight of packaging used was 1,647 tonnes in 2024, down 23% from 2,145 tonnes in 2023. Renewable materials totalled 1,434 tonnes, an 87% share, down 25% from 1,901 tonnes, while non-renewable materials totalled 213 tonnes, a 13% share that rose 1.6 percentage points, down 13% from 245 tonnes. The largest renewable input was cardboard packaging made from 100% recycled paper at 1,279 tonnes. Non-renewable inputs included original unrecycled stretch film at 115 tonnes and unrecycled half-pallet wood at 61 tonnes. Allegro also reports that biological materials used in its products and services, including packaging, that are sustainably sourced reached 1,452 tonnes, an 88% share, and that secondary reused or recycled components reached 1,434 tonnes, an 87% share. Data covers warehouses and sorting hubs in Poland, the Czech Republic and Slovenia. Sustainably sourced biological materials are those carrying FSC certification.

To address resource outflows, Allegro aligns its internal waste management with the EU waste hierarchy, sorting waste for four purposes: preparing for reuse, recycling, other utilization and disposal. The disclosure covers all waste generated from operational activities such as warehouses, sorting hubs and offices, together with materials introduced to the market by the group. Allegro's material outputs are largely packaging, which it designs for recyclability. It prioritises mono-material and recyclable packaging so customers can segregate waste and lift recycling rates, and it processes waste paper and post-consumer cartons into fillers, keeping materials in circulation. Outputs also include the products and packaging that Allegro places on the market, which it monitors and reports, alongside educating customers on proper product disposal and operating systems for the collection and recycling of post-consumer waste. Specific outflow tonnages, split between waste diverted from disposal and waste directed to disposal, are presented in the group's waste classification tables.

Total waste generated in 2024 was 1,429 tonnes, of which non-hazardous waste was 1,404 tonnes (98%) and hazardous waste was 25 tonnes (2%), with radioactive waste reported as zero. Of the total, 839 tonnes (59%) were diverted from disposal, all non-hazardous, comprising 804 tonnes sent to recycling (56%) and 35 tonnes prepared for reuse (3%); no hazardous waste was diverted from disposal. Waste directed to disposal totalled 591 tonnes (41%), including 566 tonnes of non-hazardous waste (39%), of which 564 tonnes went to landfill and 2 tonnes to incineration, plus 25 tonnes of hazardous waste, all sent to landfill. Non-recycled waste was 590 tonnes (41%). Waste data is collected across countries, reported in Poland through the BDO database and in the Czech Republic, Slovenia and Slovakia through external service providers. The most common waste types include wood, plastics, paper and cardboard packaging, and mixed packaging waste.

The Allegro Group operates a set of policies to manage material impacts and risks relating to employees' working conditions. These include the Code of Ethics and Conduct, the Diversity Policy, the Human Rights Policy, the Policy of Counteracting Undesirable Phenomena such as Discrimination, Harassment, Bullying and Violence, and the Whistleblowing Procedure. The Human Rights Policy applies to the own workforce as well as business partners and contractors upstream and downstream, and addresses human trafficking, forced or compulsory labour and child labour. Policies are aligned with the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines. The Group is a member of the UN Global Compact. The Diversity, Human Rights and Counteracting Undesirable Phenomena policies are approved and reviewed annually by the Board of Directors, with the Chief Security Officer responsible for implementation. Key excerpts are publicly available on the Allegro.eu website.

Allegro treats employees as the most important element of its operations and monitors their needs through an annual Engagement Survey administered in May, supported by two smaller Pulse Checks during the year. The survey, run using the external platform Culture Amp, covers all Group entities and measures engagement across five factors. Employee engagement scored 64% in 2024, up from 47% in 2023, and participation reached 91%, up from 78%. Responsibility for incorporating employee feedback into decision-making is assigned to the Chief Human Resources Officer. Employee Representations, consisting of 3 to 5 democratically elected members serving 4 year terms (2 years at Ceneo), operate in several Polish entities and consult on HR processes, remuneration, work organisation and the Social Benefits Fund. A Trade Union operates in three Polish entities, with which consultations are held as required by Polish law. The Employee Relations Manager and a Legal team member handle cooperation with employees and the Trade Union. The Code of Ethics and Conduct and Whistleblowing Procedure were consulted with the Employee Representation in 2024.

The Allegro Group operates a comprehensive whistleblowing system for managing complaints from employees and other stakeholders. For issues considered resolvable internally without fear of retaliation, an internal channel is recommended, guaranteeing confidentiality and anonymity. Internal reports can be made through a dedicated online platform at whistleblowing.allegrogroup.com, and employees can also contact the Chief Security Officer, the Employees Relationship Manager, or the Risk and Compliance Manager depending on the subject. For matters requiring escalation or relating to legal violations, reports can be directed externally to public authorities or EU institutions. The complaint handling mechanism includes several stages designed to ensure fair and confidential processing of reports. Employees and stakeholders are informed about the platform, and information forms part of the obligatory compliance training every employee should receive. Independent advisory bodies, the Employee Representations, also give employees a voice on the work environment. A more detailed presentation of the Whistleblowing Procedure appears in the G1 Business Conduct chapter.

To manage significant risks related to working conditions, Allegro implemented several actions for its own workforce. Employee needs are assessed through the annual Engagement Survey. On equal opportunities and fairness, initiatives during 2024 included the Neurodiversity Project, the AllWomen Network for female leaders, and awareness sessions on diversity, equity and inclusion including the Leadership by Design women's development programme. All employees have access to Mindgram, a mental well-being platform offering personalised content and the Well-being Vibe functionality for diagnosing well-being and detecting burnout. In 2024, 900 employees used their volunteering day off, dedicating 7,301 hours to community service. For health and safety, work safety instructions, procedures and training mitigate accident risks, supported by dedicated OHS units, an internal OHS webpage, a special communication alias and channel, and regular safety checks. The Group aims to reduce talent loss risk by narrowing the pay gap and providing benefits and training. Actions will continue in 2025 and following years, resourced by the Human Resources team.

One of the Group's main ambitions is to introduce equal pay for women and men within its own workforce, linked to the Diversity Policy. In line with its ESG strategy, the goal is to achieve an equal pay gap below 5%. In 2024 the equal pay gap was 3%, so the target is being met. Because of the nature of the goal, no base year and no intermediate targets have been set, and the goal is maintained throughout the duration of the ESG strategy. The target was set based on stakeholder analysis and research among employees, merchants and customers, developed by the operation team, business owner and business sponsor, and approved by the Board of Directors. Employees are informed about progress, for example through the Sustainability Statement. One supporting solution is a process of reviewing salaries of people returning from long term absences. No specific targets are set for other impacts, risks and opportunities, reflecting a choice to focus on one high leverage indicator. In health and safety there is no specific target, but accident numbers are strictly monitored.

As of 31 December 2024, the Allegro Group employed 5,980 people under employment contracts, up from 5,514 in 2023. The workforce comprised 3,238 men, 2,729 women and 13 classified as other or no information. By region, Polish Operations accounted for 4,659 employees, Czech Operations 967, Slovenian Operations 289, and Other Operations 65, with regions shown where more than 10% of employees are based. The headcount includes 135 individuals on Czech and Slovak agreements. By contract type, 5,044 employees (84%) held permanent contracts, of whom 2,727 were men and 2,316 women, while 936 employees (16%) held temporary contracts, of whom 511 were men and 413 women. There were no non-guaranteed hours employees, as the Group does not employ anyone without a guaranteed number of working hours. In 2024 the Group recorded a 21% turnover rate with 1,249 leavers. Data comes from the internal HR system and is consistent with the consolidated financial statements.

In addition to hiring its own employees, the Allegro Group uses non-employees in its own workforce, such as individuals collaborating under civil law contracts, B2B contractors, and workers provided through employment agencies mainly during peak periods. As of 31 December 2024 there were 907 non-employees, down from 1,110 in 2023. The figure is disclosed as headcount at the end of the reporting period. The report does not provide a further breakdown of these numbers by gender or type within the non-employee category.

Collective bargaining coverage in the Allegro Group is limited. The employees of Mimovrste spletna trgovina d.o.o. and Internet Mall d.o.o., totalling 313 employees and representing 100% of employees in those entities as of 31 December 2024, are covered by a collective bargaining agreement at the industry level. Slovenian and Croatian employees constitute 5% of Group employees. There is only one Trade Union active in the Group, with members in three Polish entities: Allegro Sp. z o.o., eBilet Polska Sp. z o.o. and Allegro Pay Sp. z o.o. All employees of those entities, representing 94% of employees in Poland, are covered by workers' representatives on collective employment matters. On individual employment matters, only Trade Union members, just over 1% of Group employees, are covered by workers' representatives.

The Group reports gender distribution across career levels as of 31 December 2024. On the Board of Directors, women held 3 of 10 seats (30%), consistent with Directive (EU) 2022/2381 on gender balance among directors of listed companies, up from 27% in 2023. Among senior managers women represented 22 of 86 (26%), up from 20%. Among middle managers women represented 250 of 781 (32%), and among experts and specialists 2,457 of 5,113 (48%). By age group, 1,697 employees (28%) were under 30, 4,072 (68%) were aged 30 to 50, 202 (3%) were over 50, and 9 (1%) were undisclosed. The Group states it increased the representation of women in leadership roles, reduced the equal pay gap to 3%, provided training on inclusion and equality, and implemented recruitment practices ensuring balanced gender representation. Career levels are defined as senior management at level 8 and above, middle management at levels 6 and 7, and experts and specialists at level 5 and below.

All wages in the Allegro Group are equal to or higher than the adequate minimum wage in all countries where the Group operates. The Group complies with local labour regulations that mandate social insurance protection for employees against significant life incidents such as illness, unemployment initiating while employed, work-related accidents, acquired disabilities, parental leave and retirement. This protection is provided by public programmes in line with local labour law, which enforces comprehensive statutory social protection for all workers. As a responsible employer, the Allegro Group states that it meets these legal requirements for all its employees.

The Allegro Group employs people with disabilities. At the end of the reporting period, 1% of employees held a disability certificate issued by the relevant authorities in their country. The employment of people with disabilities is one of the aspects addressed by the Diversity Policy, which promotes equal treatment regardless of disability or health. Alongside this, the Group ran a Neurodiversity Project in 2024 aimed at raising awareness about neurodiversity, exploring organisational needs concerning neurodiversity at both individual and leadership levels, and providing recommendations for further action to address the topic.

Allegro offers a broad selection of programmes, workshops, webinars and conferences delivered with internal and external trainers through development platforms such as MindUp. Its development approach follows a 70/20/10 learning model combining formal programmes, learning from others, and applying skills in real-world contexts. In 2024, employees received an average of 31 hours of training, comprising 38 hours for men and 23 hours for women. The Group operates a position classification system, a Talent and Performance Management Programme, Individual Development Plans, and a promotion path based on objective competency assessment reflected in The Allegro Way, supported by a Talent Acquisition Team. Regarding performance and career development, 95% of employees participated in regular performance reviews and career development, comprising 94% of men and 95% of women. Training data is sourced from the MindUp learning management system, with Ceneo included from 4 November 2024, and from the Eklektika language school, covering the entirety of 2024.

The Allegro Group complies fully with national and European occupational health and safety standards, and 100% of its own workforce is covered by OHS. Because of changes in methodology, most 2024 figures are not comparable with previous periods, except the number of fatalities. In 2024 there were no fatalities in the own workforce as a result of work-related injuries and ill health, making the year free of fatal workplace accidents. The Group recorded 32 recordable work-related accidents for its own workforce, with a rate of recordable work-related accidents of 3. There were no cases of recordable work-related ill health among employees. The number of days lost to work-related injuries and fatalities from accidents and ill health was 387. Incident data for Polish entities was taken from accident registers as of 31 December 2024, and data for non-Polish entities was provided by external parties. The accident rate is calculated by dividing cases by total hours worked and multiplying by 1,000,000.

The Group reports both an unadjusted gender pay gap and an equal pay gap as of 31 December 2024. The unadjusted gender pay gap, calculated in accordance with ESRS, was 34%, comparing gross hourly remuneration of men and women without considering job family or career level. The equal pay gap, which compares basic earnings at similar career levels and within job families, was 3%. The equal pay gap is calculated using a method accounting for job family and career level, determining weighted average scores by comparing base salaries of women to those of men at each career level within a job family, then aggregating across families. The unadjusted gender pay gap considers base salary, bonuses paid in 2024 and Allegro Incentive Plan vesting in 2024. The annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all other employees was 53.94. Total remuneration includes base salary, paid bonuses and AIP vesting, while non-cash benefits are excluded.

The Allegro Group does not identify significant risks of forced, compulsory or child labour in its own operations in the countries where it operates. In 2024, the Group did not identify any severe human rights impacts within its own workforce. The report includes a table presenting the total number of discrimination and mobbing cases filed by the Group's own workforce, alongside the number of complaints filed, broken down by reporting channel.

Allegro Group maintains policies to give all users a safe and accessible shopping experience across cybersecurity, consumer and product safety, and accessibility. Cybersecurity and data protection rest on the Security Policy and Privacy Policy, with full compliance with the GDPR, monitoring of Data Protection Authority and European Data Protection Board guidance, and rights to erasure, rectification, access and consent withdrawal. The Group holds PCI DSS v4 certification and applies standards including ISO 2700x, NIST, CIS, COBIT and OWASP. Product safety is governed by a Risk Management Plan, GPSR procedures effective 13 December 2024, and merchant Terms and Conditions. Accessibility follows the Web Content Accessibility Guidelines and internal guidelines on the safety, accessibility and aesthetics of One Box parcel lockers, ahead of the European Accessibility Act taking effect on 28 June 2025. Consumer-trust policies are approved by the Board of Directors. Accounts for users aged 13 to 18 are marked Junior with category restrictions.

Allegro Group engages consumers and end-users through several communication channels, including the contact form, Allegro chat, a dedicated contact channel for deaf users, NPS surveys, periodic surveys, and the Allegro Gadane community. These channels support ongoing interaction and let the Group collect feedback and perspectives from customers. During the double materiality analysis, the Group gathered opinions from both merchants and consumers, sending a survey at the initial stage of the process whose results inform the setting of ESG strategic goals. The Customer Experience team is responsible for maintaining customer contact channels and prepares reports drawing conclusions from the feedback received. The most important current issues are presented to the Board of Directors, and results of the analyses are communicated to the Board and, where necessary, incorporated into strategic actions. Further detail on stakeholder cooperation appears in the ESRS 2 chapter on value chain and cooperation with stakeholders.

Allegro Group provides multiple channels for consumers and end-users to raise concerns and seek remediation. For cybersecurity, a dedicated CERT and a Security Incident Commander team on duty 24 hours a day, seven days a week coordinate incident resolution, and users can report through formal paths such as ticket systems, emails and chat channels or informal ones such as phone calls. For product and content concerns, the Group operates under the Digital Services Act and offers a Report a violation button on product listing pages, with reports handled by the Trust and Safety team. Communication channels available to consumers and merchants include Allegro chat, the Allegro Gadane community and email. The Allegro Protect program provides an aftersale channel through which users can report problematic purchases. A whistleblowing system, open to everyone and allowing anonymous submissions, is also available. Effectiveness of the Trust and Safety teams is evaluated through consumer surveys.

Allegro Group takes wide-ranging actions across its three material areas. In cybersecurity it runs the cert.allegro.com website with security alerts in several languages, conducts phishing tests, Bug Bounty programs with ethical hackers, resilience tests and cybersecurity maturity audits every two years benchmarked to NIST, reaching a maturity rating of 4.42 out of 5. For product safety it fights counterfeits and dangerous or non-compliant goods through the Rights Protection Cooperation Program, AI and machine-learning monitoring, a Repeat Infringers Striking Policy, and cooperation with authorities and associations. In 2024 the Group removed 583,016,912 non-compliant and infringing offers, blocked 122,339,832 listing attempts, and eliminated 240,122 bad-actor accounts. The Allegro Protect program resolves 98 percent of reported issues, refunding funds within 48 hours up to kPLN 20. For accessibility, One Box lockers feature Braille markings and QR codes linking to a Polish Sign Language interpreter, and in 2024 78 percent of One Box lockers, being 95 percent of those audited, met accessibility requirements.

Allegro Group has set a goal to train over 90 percent of its employees in cybersecurity by 2025. No baseline year has been adopted and no intermediate goals or other assumptions have been disclosed. The target stems from the ESG strategy and relates directly to the risk of data protection and privacy breaches, reflecting that the human factor often determines the success of a cyberattack. It was established from stakeholder survey results gathered during the double materiality analysis, approved by the Board of Directors and monitored by the ESGCo. In 2024 the Group trained 89 percent of its employees on cybersecurity, up from 58 percent in 2023, an increase of 31 percentage points. By Board decision, the Group sets ESG goals only for the most significant areas, so no targets have been disclosed for the Accessibility and Product Safety impacts, risks and opportunities.

Allegro Group's corporate culture rests on three tools: the Code of Ethics and Conduct, the Code of Conduct for Suppliers and Business Partners, and The Allegro Way. These are supported by a governance, risk and compliance management system and an extensive set of policies covering corruption prevention, competition law, conflicts of interest, data protection, anti-discrimination, whistleblowing, anti-money laundering, procurement and risk management. All policies are reviewed and approved by the Board of Directors at least once a year and are available to employees, with key documents published on the Group website. The Group operates a whistleblowing system accessible to everyone, including anonymously, through whistleblowing.allegrogroup.com, which guarantees confidentiality and protection from retaliation and implements Directive (EU) 2019/1937. Reports undergo preliminary verification within three days, may lead to an Ethics Committee investigation, and are summarised quarterly to the Audit and ESG Committees. Employees complete annual training on the policies covered by the Code, and new employees train during onboarding.

Suppliers are selected under Allegro Group's Procurement Policy, which requires the economically and commercially best offer based on transparent criteria. The Code of Conduct for Suppliers and Business Partners sets social responsibility expectations reflecting the ten principles of the UN Global Compact, the UN Guiding Principles on Business and Human Rights, the ILO Declaration, the OECD Guidelines for Multinational Enterprises, and conflict minerals rules. Suppliers with contract value above PLN 15,000 receive the Suppliers Code, and those above PLN 500,000 are asked to sign it and complete a Sustainability Practices questionnaire. Key projects where annual contract value exceeded PLN 100,000 in 2024 are checked against ESG objectives by the ESG department. Suppliers undergo a verification process reviewing financial documents, registration documents and bank accounts. The Group makes efforts to avoid payment backlogs and in 2024 raised staff awareness of late payment, applying a standard 30-day payment deadline from which deviations are possible only in exceptional situations.

Allegro Group prevents and detects corruption and bribery through its Transparency (Anti-Corruption) Policy, which includes gifts and benefit regulations and conflict of interest regulations. The Policy covers all areas of the Group's activities and applies to companies within the Group and to its business partners. It is compliant with the Polish Penal Code, the Fiscal Penal Code, the Commercial Companies Code, and the Act on the Liability of Collective Entities, and also refers to the American Foreign Corrupt Practices Act, the British Bribery Act and the United Nations Convention against Corruption. Before entering any business agreement, the Group conducts documented verification of a partner's history, potential and reputation, with attention to any bribery involvement. All employees must read the Policy and complete annual anti-corruption training concluded by a test, beginning at the start of employment. There is no distinction of functions at risk, so every employee is trained. The CSO supervises training and, with the Information Security, Risk and Compliance and Loss Prevention teams, investigates irregularities and informs the Board and Audit Committee.

Allegro Group reports that in 2024 no court imposed any convictions or fines on the Group on the grounds of corruption or bribery, and no such proceedings were conducted. The Group further states that there were no actions taken to address breaches in its anti-corruption and anti-bribery procedures and standards. The number of confirmed incidents of corruption or bribery reported for the year is therefore zero.

Allegro Group keeps a record of the average time it takes to pay an invoice, which is 23 days. A standard payment deadline of 30 days has been set, from which deviations are possible only in exceptional situations, and 83 percent of all payments are made within the designated term. The Group does not differentiate its payment practices between large companies and small and medium-sized enterprises, defined as businesses typically with fewer than 250 employees and annual turnover up to mEUR 50. Longer payment terms arise mainly from formal deficiencies, such as missing documents confirming an order or prolonged internal invoice circulation. In 2024 the Group introduced a No PO no PAY policy to expedite payments and reduce late settlement, informing suppliers to include purchase order numbers on invoices. There were no concluded or ongoing proceedings related to late payment delays against the Group in 2024.