Allegro

The role of the administrative, management and supervisory bodies

Reference: page 231; also pages 212 and 330 (per the company's own ESRS index, page 343).

­Allegro.eu has a one-tier board: "a one-tier (unitary) management system in which the Board of Directors includes both executive Directors (dealing with the day-to-day management) and non-executive (supervising) Directors" (page 231). At the end of 2025 it "comprised 2 executive Directors (the CEO and CFO) and 8 non-executive Directors" (page 330), of whom 3 of 10 are women (30%, page 304).

The Board "is responsible for ESG leadership including oversight and monitoring of ESG and climate strategy and flagship non-financial KPI performance. It also monitors corporate risk (incl. ESG and climate), defines the scope of risk management... and sets risk appetite levels" (page 231). It is informed through the Audit Committee, the Remuneration and Nomination Committee and the ESG Committee. In 2025 the ESG Committee "focused on reviewing ESG impacts, risks and opportunities (including climate-related risks and opportunities previously approved by the Board in 2024), revising the decarbonization plan, and on the revision of ESG strategy and reporting approach" (page 231).

Board composition, diversity and ESG expertise are incorporated by reference to the Management Review chapter 'Corporate governance' (page 211).

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

Reference: page 231.

The Board of Directors "is regularly informed about sustainability matters" through the Audit Committee, the Remuneration and Nomination Committee and the ESG Committee (page 231). The double materiality assessment, "of which the stakeholders research report is a part, was approved by the Board of Directors", and the Board "regularly review the key performance indicators for satisfaction of employees, partners and customers as well as security, compliance, whistleblowing, governance and risk management update" (page 220).

The reporting cadence is set out topic by topic. The Chief Security Officer "briefs the Boards of Directors through the Audit Committee on information security matters regularly, at least quarterly", with separate meetings on resilience and security maturity and immediate notification of major incidents (page 314). On data protection, "The Board of Directors is informed quarterly through the Audit Committee of any significant changes, including any incidents and communications with Data Protection authorities" (page 316). Whistleblowing reports are summarised "quarterly to the AuditCo and the ESGCo" (page 338). Customer and partner feedback reports are prepared by the Customer Experience Team and "The most important current issues are presented to the Board of Directors" (page 318).

Integration of sustainability-related performance in incentive schemes

Reference: pages 231-232 and 241.

"Starting from 2024, sustainability-related targets are factored into the remuneration of the Executive Board of Directors and managers. When determining annual bonuses (short term incentive, STI), the ESG index is included in the assessment as a key performance indicator. It constitutes 10% of the CPI (Company Performance Index), meaning 10% of the annual bonus on target is linked to the achievement of specific ESG-related goals" (page 232).

"In 2025, the ESG index consists of 5 annual targets directly related to the strategic ESG goals of the ­Allegro Group. Each of the five objectives carries equal weight" (page 232). The incentive system "was approved by RemNomCo, which also has the authority to update it" (page 232).

Climate sits inside that index: "Starting from 2024, the decarbonization goal related to the absolute reduction of Scope 1 and 2 emissions has been factored into remuneration" (page 241). The five strategic goals to which the index is tied are the equal pay gap below 5%, 100% sustainable packaging in own operations, the 43% Scope 1 and 2 reduction, 177 thousand selling partners and above 90% cybersecurity training (page 213). The report does not disclose the percentage of remuneration recognised in the current period that is linked to sustainability considerations, only the 10% weighting within the annual bonus.

Statement on due diligence

Reference: page 232.

"The ­Allegro Group exercises due diligence, among others, in the following areas: social and employee issues, environmental protection, procurement, and governance including corruption" (page 232). A mapping table gives the paragraph in the Sustainability Statement for each core element of due diligence (page 232):

• Embedding due diligence in governance, strategy and business model - ESRS 2 GOV-2, ESRS 2 SBM-3, G1-1, G1-2
• Engaging with affected stakeholders in all key aspects of the due diligence - ESRS 2 SBM-2, S1-2, S4-2
• Identifying and assessing adverse impacts - ESRS 2 IRO-1, ESRS 2 SBM-3
• Taking action to address those adverse impacts - E1-1, E1-3, E5-1, E5-2, S1-4, S4-4
• Tracking the effectiveness of these efforts and communicating - E1-4, E1-5, E1-6, E5-4, S1-17

The statement also records that IROs "are also covered by the due diligence process" and that "Risk owners and risk coordinators are responsible for IRO's monitoring" (page 222). The datapoint is flagged in the EU-legislation index as ESRS 2 GOV-4 paragraph 30, derived from SFDR, at page 232 (page 348).

Risk management and internal controls over sustainability reporting

Reference: pages 232-233.

"The ­Allegro Group implements ESG risk management and climate risk management, which are part of the ­Allegro Group's ERM" (page 233). "The detailed scope of sustainability reporting is defined by double materiality assessment (DMA) that is reviewed at least once in three years and confirmed by the ESG Committee once a year. The Sustainability Reporting Policy was introduced in order to set standards for sustainability reporting in compliance with CSRD" (page 233).

The control design has two lines: the Policy "requires at least two levels of data verification before its delivery to the external auditor". "As part of the first line of defense, the data controller checks the accuracy, completeness and verifiability of data and evidence provided by data providers. Within the second line of defense, the central verification team checks to ensure that data prepared by data providers is complete and accurate" (page 233). The Policy is "approved by the Board of Directors at least once every two years".

The process runs in four stages - boundaries review, data gathering and calculation, validation by the central verification team, and a learning session to identify gaps - and "is also overseen by the Chief Financial Officer (CFO) and the Chief Legal Officer (CLO)" (page 233).

Strategy, business model and value chain

Reference: pages 211-213; value chain description pages 214-217.

"The ­Allegro Group is the go-to online marketplace for consumers in Poland, the Czech Republic, Slovakia, and Hungary for partners all over the world, with ­Allegro.eu acting as the holding company" (page 211). The Group operates across six markets - Poland, Czech Republic, Slovakia, Hungary, Slovenia and Croatia (page 214).

Revenue is disclosed by model: third-party (3P) marketplace commissions and fees are 70.6% of Group revenue, first-party (1P) retail 9.6%, advertising 11.7%, price comparison 2.1%, logistics services 3.6% and other services including payments and lending 2.4% (page 214).

"The ­Allegro Group has identified that its operations are associated with two ESRS sectors: Transportation, and Sales and Trade. The Other sector comes mainly from marketplace (3P) activities" (page 210). Revenue by significant ESRS sector for 2025: Transportation 441 mPLN, Sales and Trade 1,162 mPLN, Other 10,501 mPLN, total 12,103 mPLN (page 210).

The Group states it "does not engage in activities related to the fossil fuel sector (coal, oil, and gas), chemical production, controversial types of weapons, or the cultivation and production of tobacco" (page 211). Upstream covers technology and data centre providers, packaging suppliers, carriers and financial partners; downstream covers selling partners, consumers, logistics operators and end-of-life (pages 214-215).

Interests and views of stakeholders

Reference: pages 218-221.

The statement sets out a stakeholder table naming employees, customers, selling and ecosystem partners, suppliers of products for the 1P shop and fulfilment packaging, suppliers of services (IT, transport) and investors, with the form, purpose and outcome of engagement for each (pages 218-219).

"For the purpose of the double materiality assessment, the ­Allegro Group conducted a stakeholder engagement study distributed to employees, partners, and customers. These stakeholders were chosen for in-depth consultation due to their direct business relationships with ­Allegro Group" (page 220). "Additionally, the environment (considered a silent stakeholder) and perspectives of other stakeholders not directly involved with the ­Allegro Group were assessed through available publications, benchmarks and reports" (page 220).

The link to governance is explicit: "The double materiality assessment, of which the stakeholders research report is a part, was approved by the Board of Directors. Additionally the Board of Directors regularly review the key performance indicators for satisfaction of employees, partners and customers as well as security, compliance, whistleblowing, governance and risk management update" (page 220).

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

Reference: pages 223-227; also pages 212, 234 and 311.

The 2025 revision of the 2024 DMA produced 32 material IROs, numbered 1-32 in the value chain graphic (pages 216-217) and listed by pillar and topic on pages 223-227. They map to eleven material topics: climate change and energy (E1); sustainable packaging and more sustainable products and services (E5); working conditions and trainings, and equal opportunities and fairness (S1); accessibility, cybersecurity, and consumer and product safety (S4); corporate governance transparency and value chain (G1); plus an entity-specific Charity topic marked with an asterisk (page 227).

Every IRO is assessed as short, medium and long term (pages 223-227).

Two risks were added in 2025: "the risk of insufficient corporate governance and ethical frameworks on AI development, and the risk that environmental actions may be considered 'greenwashing' despite positive intentions and best efforts" (page 227). Material positive impacts were reduced "because some of them were reassessed as mitigating measures addressing negative environmental impacts" (page 227).

Current and anticipated effects "are below the established material financial thresholds", and the Group "does not plan to change its strategy or business model" (page 227).

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

Reference: pages 220-223; also pages 258 and 330.

The DMA "was conducted in 4 stages": defining assumptions and organisational context; external and internal analysis; assessment of IROs; and IRO prioritisation and approval (page 220). The long list came from "the list of sustainability matters of ESRS 1 AR 16" and "in-depth analysis of the sector, business relationships and the organizations included in ­Allegro's value chain" (page 220).

Thresholds are disclosed: "Impact materiality sustainability topics scoring 3.25 and above were deemed material", 3.25-3.8 highly material and 3.8 and above very highly material (page 222). "In accordance with the ERM system, ESG risks have a residual character (net, after mitigation), whereas climate risk was assessed initially on a residual level and then transposed to an inherent one (as per ESRS E1 requirements)" (page 222).

"Full double materiality assessment (DMA) cycles are conducted every three years for ESG topics and every three years for climate topics, with annual limited reviews and out-of-cycle assessments triggered by significant organizational or regulatory changes" (page 222). The ESG Committee revised and approved the 2025 IRO list (page 222).

Disclosure requirements in ESRS covered by the undertaking's Sustainability Statement

Reference: pages 210 and 342-349.

The report prints a genuine ESRS content index headed "Index of material ESRS disclosures" over pages 343-347, listing every DR in ESRS 2 and the material topical standards with a page reference, a "Non material" marker or a "Phase in" marker, alongside the mapped TCFD disclosure requirement and SDGs. "The following index includes all ESRS disclosure requirements in ESRS 2 and the material topical standards that guided the preparation of the Sustainability Statement" (page 343). A second table on pages 348-349 lists the datapoints that derive from other EU legislation (SFDR, Pillar 3, Benchmark Regulation) with their page references.

The index shows E1, E5, S1, S4 and G1 as material and E2, E3, E4, S2 and S3 as non-material in full, plus one entity-specific topic (Charity, page 327).

Incorporation by reference is used for GOV-1, GOV-2, SBM-1 and risk management, which point to the Management Review chapters 'Corporate governance' and 'Risk management system, Risk factors, and regulatory matters' (page 210).

Phase-in reliefs are declared: "We made use of the following phased-in disclosure requirements in line with ESRS 1 Appendix C: Anticipated financial effects (E1-9, E5-6)" (page 210). Note the index misnumbers the E2 rows, listing "2-4" twice and ending at "2-5"; the six E2 requirements are all shown as non-material (page 344).

Transition plan for climate change mitigation

Reference: pages 240-241.

"The ­Allegro Group has set a goal of reducing greenhouse gas emissions by 43% (Scope 1 and 2) by 2030 compared to the base year of 2021. Moreover, within Scope 3, ­Allegro has committed to ensuring that 73% of all its suppliers, measured by their spend on purchased goods & services, capital goods, and downstream transportation and distribution, establish science-based targets by 2027. The reduction targets were approved by the Science Based Targets initiative (SBTi)" (page 240).

Five principles frame the plan: renewable electricity primarily through Power Purchase Agreements or guarantees of origin; energy saving across facilities; lower shipping emissions via automated parcel machines and near-zero-emission warehouses; climate education; and offsetting only "as a last resort" (page 240).

The plan is "fully integrated with its business strategy and financial planning. The Chief Operating Officer supervises and supports the realization of the plan"; it was approved by the Board of Directors in 2022 and the revision in 2024 (page 241).

Two gaps are stated by the company. On funding, it "currently does not disclose very detailed information regarding its capital expenditures and operating expenses allocated to the action plan except those disclosed in the Taxonomy". On locked-in emissions, "Currently, it is not possible to conduct a qualitative assessment of these emissions" (page 241).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3 (pages 234-239). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 234-239.

Classification. The E1 IRO table types each climate risk explicitly as "Risk (transition)" - decarbonisation-target dependency, consumer concern about parcel machines and renewable energy cost volatility - while physical risk runs through a separate quantitative model (pages 234, 239).

Scenarios. "These scenarios are SSP1-2.6 (below 2°C), which represents the highest transition risks, and SSP5-8.5 (4°C), which represents the highest physical risks", both from the IPCC and "calibrated for local conditions and potential impacts on the sector" (pages 235-236).

Methodology. Physical risks "were assessed quantitatively, considering both acute and chronic risks to understand the financial impact in monetary terms (e.g., percentage of turnover or EBITDA)", across three horizons and both scenarios; transition risks "were assessed qualitatively", identified against the TCFD classification (pages 236-239).

Results. "None of the 66 detailed physical risks analyzed were classified as medium, high, or very high", the main low-level risks being extreme precipitation and storm winds at the Jirny and Adamow warehouses, "with average expected impairment of assets ranging from PLN 4.4 million to PLN 6.2 million" (pages 238-239).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 climate chapter (pages 235-237). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 235-237.

Results. "Under the SSP1-2.6 scenario... The results indicate that the ­Allegro Group's strategy and business model are prepared to handle these transition risks... ­Allegro has secured a vPPA, implemented good sustainability reporting practices, and set ambitious decarbonization targets" (page 237). Under SSP5-8.5 they "are resilient to these physical risks due to effective adaptation measures", including waterproof concrete buildings, redundant data centres and multiple energy supply lines (page 237).

Uncertainties. "the uncertainties include climate model variability, regulatory changes, and market and technological advancements", plus "volatility in renewable energy availability and its costs, which may affect the feasibility and timing of decarbonisation efforts", potentially touching "core assets - such as the platform, logistics network, and partners base" (page 237).

Capacity to adapt. "The ­Allegro Group's ability to adjust or adapt its strategy and business model to climate change over the short, medium and long term is a critical aspect of its resilience... Conducting a detailed scenario analysis every three years aims to identify risks to the strategy and business model at an early stage" (page 237).

Policies related to climate change mitigation and adaptation

Reference: page 242.

"The ­Allegro Group's Climate and Environment Policy outlines its strategy for managing impact, risks and opportunities and minimizing GHG emissions. Under the Policy, ­Allegro Group commits to maximise renewable energy use, reduce the carbon footprint in its operations and work with its business partners to reduce emissions across the value chain" (page 242). It "applies to its entire own operations and relates to the value chain (upstream and downstream)", and "All employees and co-workers are responsible for implementing and applying" it.

The Policy sets a three-tier hierarchy: "The first tier, termed Emission Avoidance, emphasises preventing emissions through strategic innovation and increased energy efficiency. The Emission Reduction, i.e., the second tier, focuses on reducing carbon output... The final tier, Compensation for Inevitable Emissions, involves a proactive approach to offsetting residual emissions" (page 242).

The Policy "was adopted by the Board of Directors and its implementation is overseen by ESGCo", is reviewed "at least once every two years" and "is publicly available on the ­Allegro Group's corporate website" (page 242).

On adaptation the company records a limit: "The ­Allegro Group's Climate and Environment Policy does not currently include adaptation to climate change, as the assessed risks are low" (page 245).

Actions and resources in relation to climate change policies

Reference: pages 244-245; achieved reductions page 246.

"In 2024 ­Allegro Sp. z o.o. signed a vPPA with R.Power and investment banks. This deal is for 22GWh yearly and helps ­Allegro cut down on its carbon footprint emissions by nearly 12k tons yearly in Scope 2... In May 2025, 16 photovoltaic farms in Poland covered by the contract started operations" (page 244). With landlord cooperation on renewable tariffs, "the share of renewable energy significantly increased from 26% in 2024 to 58%" (page 244).

On efficiency, energy intensity "improved to 3.7 MWh/mPLN (vs 3.9 MWh/mPLN in 2024 and 4.0 MWh/mPLN in 2023)", and ­Allegro Sp. z o.o. and ­Allegro Retail "underwent an energy audit in 2025" (page 244).

On logistics, "As of 31 December 2025, the ­Allegro Group had 9,307 automated parcel machines", and delivering to them "results in considerably fewer GHG emissions than direct delivery (i.e., courier services). On average, emissions are lower by around 30%" (page 244). A cargo-bicycle and micro-hub pilot ran in Wroclaw (page 246).

Achieved 2025 reductions are quantified and each marked "On track": guarantees of origin "13,907 tons of CO2e in 2025 mainly thanks to vPPA"; energy effectiveness "3,627 tons of CO2e"; low emission deliveries "maximum avoided emissions... 6,176 tons of CO2e" (page 246). Resources: 2025 CapEx of 426.6 mPLN and OpEx of 16.6 mPLN on parcel machines (page 246).

Targets related to climate change mitigation and adaptation

Reference: page 243.

"The SBTi-approved target assumes a 38% reduction in greenhouse gas emissions (Scope 1 and 2) by 2030 compared to 2021. In 2024, the ­Allegro Group decided to revise this target. The updated target, approved by the Board of Directors, assumes a 43% reduction in greenhouse gas emissions by 2030 (Scope 1 and 2) compared to the 2024 baseline year. The target in Scope 1 and 2 is set on absolute terms on a gross emission reduction (with no removals, carbon credits or avoided emissions). The updated target will be submitted to the Science Based Targets initiative (SBTi) for approval" (page 243).

The absolute target "is expected to be 8 thousand tons of CO2e by 2030, compared to 14.2 thousand tons of CO2e in 2024 (Scopes 1 and 2)"; the base year "was recalculated to include emissions from foreign entities acquired in 2022" (page 243).

Scope 3 is addressed by supplier engagement rather than an absolute target: 73% of suppliers by spend to "establish science-based targets by 2027"; "In 2025, there were 59% suppliers... that established science-based reduction targets (+3 p.p. vs 2024)" (page 243).

The targets were "formulated using rigorous scientific methodology defined by the Science Based Targets initiative (SBTi)... aligned with the path set to achieve the 1.5°C target" (page 243). Caution: the base year for the 43% target is given as 2021 on pages 228 and 240 but as 2024 on pages 243 and 246.

Energy consumption and mix

Reference: pages 246-248.

Table E1.1 reports total energy consumption of 43,603 MWh in 2025 against 42,686 MWh in 2024 and 40,782 MWh in 2023, up 2% (page 247). Energy from fossil sources fell 40% to 17,117 MWh, taking the fossil share from 67% to 39%; nuclear-sourced energy fell 60% to 1,138 MWh (3%); renewable sources rose 127% to 25,348 MWh, lifting the renewable share "from 14% in 2023, to 26% in 2024, to 58% in 2025" (pages 246-247).

Fossil components: coal and coal products 47 MWh, crude oil and petroleum products 2,651 MWh, natural gas 5,792 MWh, and purchased electricity, heat, steam or cooling from fossil sources 8,627 MWh, down 62%. Renewable consumption is almost entirely purchased electricity, heat, steam and cooling backed by guarantees of origin, 25,345 MWh; self-generated non-fuel renewable energy is nil (page 247).

"The ­Allegro Group does not produce renewable energy. At the same time, it burns natural gas or fuel oil in its facilities to generate thermal energy for heating the building" (page 246).

Table E1.2 gives energy intensity for the high climate impact sectors: 11 MWh/mPLN in 2025 against 8 in 2024, on 18,421 MWh and 1,602 mPLN of net revenue from transportation and storage plus wholesale and retail trade (page 248). Both tables are within the limited assurance scope (page 351).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 249-257.

Table E1.3 (page 249, tCO2e): gross Scope 1 1,803 (2024: 1,301; 2021 SBTi base year: 2,162); location-based Scope 2 17,739; market-based Scope 2 4,017, down 69%; location-based Scope 1 and 2 19,542, down 3%; market-based Scope 1 and 2 5,819, down 59% both against 2024 (14,060) and the 2021 base year (14,192). Scope 1 from regulated emission trading schemes is 0%.

Table E1.6 (page 251): Scope 3 by category - purchased goods and services 238,481; capital goods 27,038; fuel and energy-related activities 2,536; upstream transport 9,961; downstream transport 101,833; use of sold products 34,982; end-of-life 4,722. Total Scope 3 419,552, up 4%; total Scope 1, 2, 3 market-based 425,372, up 2%.

The 2024 comparatives were restated: "In 2025, the Group deepened its engagement with key business partners to improve data quality... ­Allegro Group have recalculated 2024 Purchased goods and services emissions in line with the GHG Protocol" - from 322,634 to 234,046 tCO2e (page 251). The assurance report carries an emphasis of matter on this (page 355).

Categories 8, 10, 13, 14 and 15 "are not applicable"; 5, 6 and 7 were excluded as under 1% of location-based emissions (page 255). "18% of the data regarding emissions in Scope 3 has been calculated using primary data" (page 256). Market-based Scope 1 and 2 intensity fell 63% to 0.5 tCO2e/mPLN; Scope 3 intensity fell 6% to 34.7 (pages 256-257).

Policies related to resource use and circular economy

Reference: pages 260-262.

"The ­Allegro Group has adopted the Circularity and Waste Policy to address its material impacts, risks, and opportunities related to resource use and the circular economy. The policy's general objectives include achieving 100% sustainable packaging in its own operations by 2028, reducing environmental impact, and closing the loop on waste. Key elements include adherence to principles of eco-design, reduction, reuse, and recycling throughout the product life cycle" (page 260).

It "applies to all activities within ­Allegro.eu and its subsidiaries, encompassing offices, warehouses, hubs, depots, and other operational facilities. It also includes upstream and downstream value chain activities" (page 261).

Sustainable packaging is defined operationally: "shipment without packaging, or reused packaging, or material with a minimum of 70% recycled content, or compostable packaging confirmed with certificates, or 100% recyclable packaging. Each part... must meet at least one out of the criteria" (page 261).

"The Operations Sustainability Team is responsible for the implementation and monitoring... Ultimate accountability lies with the Board of Directors" (page 262). A gap is stated: the Group "has not adopted a policy that directly addresses broader sustainability challenges, low demand for sustainable offerings, and the possibility of creating a sustainable product range" (page 262).

Actions and resources related to resource use and circular economy

Reference: pages 264-266.

On packaging, "­Allegro launched the 'Eco Packaging Guide', designed to educate both selling partners and customers (upstream and downstream of the value chain) on sustainable packaging choices... and guidance on avoiding greenwashing" (page 264). In own operations, "products from own shop (1P) are shipped according to the 'Ship in Own Packaging' principle", and "In the Adamow (Poland) warehouse, a machine processes post-consumer cartons into necessary filling and cushioning materials" (page 264).

On more sustainable products, the "Products with certificates" section requires "at least one recognized certification, such as the EU Organic Label, FairTrade, or Rainforest Alliance" (page 265). Recommerce runs through ­Allegro Lokalnie for pre-owned items, and in 2025 "­Allegro launched a new service in Poland called ­Allegro OdZyskaj (­Allegro Trade-in)... buybacks of smartphones, laptops, and wearables" which are refurbished and resold (pages 265-267).

Resources are not quantified: "The ­Allegro Group currently does not disclose detailed information regarding its capital expenditures and operating expenses allocated to the circularity and waste action plan. The plan is integrated across various parts of the organization" (page 265). The same wording is repeated for sustainable products and services (page 266).

Targets related to resource use and circular economy

Reference: pages 262-264.

"­Allegro has set an ambitious goal to transition 100% of its own packaging (in its own shop 1P and fulfillment 1F) to sustainable packaging by 2028. This commitment has been established voluntarily by ­Allegro, reflecting its proactive approach to sustainability rather than a response to regulatory requirements. There is no baseline year against which measurements are made" (page 262).

Table E5.1 reports the share of sustainable packaging in own operations at 93% for 2025 as a whole, with "(100% at the end of the year)", against 70% in 2024 and 49% in 2023, up 23 percentage points (page 263). "By the end of 2025, ­Allegro Group achieved 100% sustainable packaging in its own operations, which meant it reached its goal earlier than planned" (page 263). The figure is within the limited assurance scope (page 351).

The target "was set based on the stakeholder analysis and research among employees, partners and customers. The final goal was developed by the operation team, business owner, and business sponsor, and approved by the Board of Directors" (page 262).

No other E5 target exists: "­Allegro prioritizes its ESG actions and has decided to set ESG goals only for the most significant areas. Consequently, no other goals related to additional impacts, risks, and opportunities have been established" (page 264).

Resource inflows

Reference: pages 267-268.

Table E5.3 "Packaging materials usage" reports total packaging weight of 1,656 tonnes in 2025 against 1,647 in 2024 and 2,145 in 2023 (page 267). Non-renewable materials fell 38% to 133 tonnes: unrecycled stretch film 61 t, unrecycled half-pallet wood 22 t, duct tape 12 t, unrecycled paper labels 33 t, LDPE foil 1 t, thermoetics 2 t. Renewable materials rose 6% to 1,523 tonnes: cardboard from 100% recycled paper 1,166 t, kraft paper tape and filler 140 t, 100% recycled paper filler 131 t, recycled HDPE foil fillers 52 t, recycled wood pallets 34 t. The non-renewable share fell from 13% to 8%; the renewable share rose from 87% to 92%.

Table E5.5 reports 1,471 tonnes (89%) of "Biological materials used to manufacture the undertaker's products and services (including packaging) that is sustainably sourced" and 1,523 tonnes (92%) of "Secondary reused or recycled components, secondary intermediary products and secondary materials" (page 268).

Scope is stated: the data "pertains to the types of packaging used for shipping products from the ­Allegro Group's facilities (own operations) in Poland, the Czech Republic, and Slovenia", and sustainably sourced biological material means FSC-certified stock or a significant renewable content by mass (page 268). Inflows cover packaging only; no tonnage is reported for goods traded on the marketplace, which the Group does not own.

Resource outflows

Reference: pages 269-271.

"To tackle the issue of resource outflow in its operations, the ­Allegro Group aligns its internal waste management with the EU's waste hierarchy. This approach involves sorting waste for four specific purposes: preparing for reuse, recycling, other recovery and disposal. The disclosure pertains to all waste generated from operational activities and material impacts by the ­Allegro Group, such as warehouses, sorting hubs, offices, and that which is introduced to the market by the ­Allegro Group" (page 269).

Table E5.6: total waste 1,022 tonnes in 2025 against 1,429 in 2024, of which hazardous 4 t, radioactive 0 t and non-hazardous 1,017 t (page 269). Table E5.8: 797 t of non-hazardous waste diverted from disposal (78%), being recycling 494 t and other recovery 302 t, plus 2 t of hazardous waste (page 270). Table E5.9: 224 t directed to disposal (22%), being landfill 181 t and incineration 40 t for non-hazardous plus 3 t hazardous (page 270). Table E5.11: non-recycled waste 527 t, 52% of the total, against 487 t and 34% in 2024 (page 271).

Circularity of goods sold is described rather than weighed: ­Allegro Lokalnie carried 5.54 million offers at 31 December 2025, up 11.7% (page 267), and ­Allegro OdZyskaj refurbishes and resells smartphones, laptops and wearables (pages 266-267). Packaging is designed mono-material so it is "easier for customers to segregate waste and increase recycling rates" (page 263).

Waste

Reference: pages 269-271.

Waste is reported in five tables inside the E5-5 Resource outflows section. Table E5.6 gives total waste of 1,022 tonnes for 2025 against 1,429 tonnes in 2024, comprising 4 t of hazardous waste (0%, down from 25 t and 2%), 0 t of radioactive waste and 1,017 t of non-hazardous waste (page 269).

Table E5.8 "Hazardous and non-hazardous waste diverted from disposal": 797 t of non-hazardous waste diverted, 78% of total waste, being recycling 494 t (48%) and other recovery processes 302 t (30%), with nil prepared for reuse, plus 2 t of hazardous waste (page 270). Table E5.9 "directed to disposal": 221 t of non-hazardous waste (22%), being landfill 181 t (18%) and incineration 40 t (4%), plus 3 t of hazardous waste (page 270). Table E5.11 reports non-recycled waste of 527 t, 52% of total waste, up from 487 t and 34% in 2024 (page 271).

The 2024 comparatives were restated: "Due to methodology refinements, 2024 municipal waste classifications were updated, redistributing Volumes previously labelled as 'Landfill' in total, into 'Recycling', 'Other recovery processes', 'Landfill', and 'Incineration'... Total waste volumes remain unchanged" (page 271).

Sources are named by country - BDO in Poland, FCC Ceska republika, Surovina in Slovenia and Marius Pedersen in Slovakia - with municipal waste at some sites estimated from national statistics (page 272). The tables are within the limited assurance scope (pages 351-352).

Policies related to own workforce

Reference: pages 293-295.

"A number of policies have been implemented in the ­Allegro Group to enable effective management of material impacts and risks related to working conditions of employees. Through policies such as the Code of Ethics and Conduct, the Diversity Policy, the Policy of counteracting undesirable phenomena - discrimination, harassment and mobbing, the Transparency Policy, the Human Rights Policy and the Whistleblowing Procedure, the ­Allegro Group strives to create a fair and equal work environment" (pages 292-293).

"The Human Rights Policy... applies to both the ­Allegro Group's own workforce and business partners and contractors (upstream and downstream in the value chain). The Human Rights Policy explicitly addresses issues related to human trafficking, forced or compulsory labor, and child labor" (page 293), resting on the International Bill of Human Rights, the ILO Declaration, the UN Guiding Principles and the OECD Guidelines (page 294).

"The ­Allegro Group does not identify significant risks related to forced, compulsory, or child labor within its own workforce in its own operations" (pages 293-294).

The policies "were approved and are reviewed annually by the Board of Directors. The person responsible for the implementation of these documents is the Chief Security Officer". A Code of Ethics audit runs every three years; "The last audit was performed in 2023, there were no major findings" (page 294).

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

Reference: pages 297-298.

"To evaluate and monitor workers' needs on an ongoing basis, an Engagement Survey is held every year (the main Engagement Survey is administered in May and one smaller one, called Pulse Check, is administered at various points throughout the year). This Survey is treated as the principal source of information about the ­Allegro Group as a workplace" (page 297). "the function of incorporating employee feedback into decision-making processes and actions aimed at managing impacts on the workforce is assigned to the Chief Transformation Officer, responsible for HR issues" (page 297).

Table S1.1 reports an employee engagement score of 48% in 2025 against 64% in 2024 and 47% in 2023, on 87% participation. "The decline in engagement was primarily driven by the introduction of a new workplace policy (return to office - RTO), which impacted employees' perception of flexibility" (page 297).

Formal representation is described entity by entity. Employee Representations operate in six named subsidiaries, "consist of 3-5 members and are democratically elected by all employees in direct elections", with a four-year term and monthly meetings. "In three entities of the ­Allegro Group (­Allegro Sp. z o.o., eBilet Polska Sp. z o.o., and ­Allegro Pay Sp. z o.o.), there is a Trade Union with which consultations are also held, as required by Polish law" (page 298).

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

Reference: pages 298-299.

"The ­Allegro Group operates a comprehensive whistleblowing system aimed at efficiently managing complaints from employees and other stakeholders. For issues that are considered resolvable within the ­Allegro Group without fear of retaliation, it is recommended to use the internal channel, guaranteeing confidentiality and anonymity for the whistleblowers. For matters requiring escalation or related to legal violations, reports can also be directed externally to public authorities or EU institutions" (page 298).

"According to the Whistleblowing procedure internal and external reports can be made via the platform available at the following web address: https://whistleblowing.­Allegrogroup.com. Employees can also reach out to the Chief Security Officer (CSO), Employees Relationship Manager, or Compliance Manager... This platform is available externally for any ­Allegro Group stakeholders and ensures anonymous communication with the whistleblower" (page 298).

Remediation of the material working-conditions impact runs through training and wellbeing: "­Allegro has implemented a broad range of solutions that support employees through both benefits and various well-being initiatives. A key element is the training program" (page 298). Case handling by the Ethics Committee and anti-retaliation protection are set out under G1 (pages 338-339).

Taking action on material impacts on own workforce

Reference: pages 299-301.

"To manage the material risks related to working conditions, several actions have been implemented towards the ­Allegro Group's own workforce. To continuously assess and monitor employee needs, the ­Allegro Group conducts an annual Engagement Survey" (page 299). Benefits named include a Points Bank, private medical care, commuting and childcare allowances, a restaurant card, free ­Allegro Smart!, the KIDS&Co. nursery programme, Mindgram psychological support, cross-team mobility, sabbatical leave, a nursing room, a referral bonus and a paid volunteering day (page 299).

On equal opportunities: "One of its key priorities is to increase the participation of women in senior management, which is supported by a new succession planning process that includes objective monitoring and specific gender diversity targets among identified successors" (page 299). "In 2025, the 'Leadership by Design' program was held again, enabling 20 female employees to develop their leadership potential", and the Group "became the fourth company in Poland to receive the independent EQUAL-SALARY certification" (page 301).

On training, the mandatory firm-wide "AI Foundations Learning Path" covers practical use, ethics under the AI Act and secure usage. On health and safety, actions include safety training, a dedicated OHS channel, root-cause investigation of serious accidents and Mindgram support (page 301).

Targets related to own workforce

Reference: page 296.

"In line with the ­Allegro Group's ESG strategy, the goal is to achieve an equal pay gap of below 5%. This aim reflects the strategic intent of the ­Allegro Group to eliminate wage discrepancies, promoting a culture of equity and inclusivity within the workforce. For 2025, the equal pay gap for the ­Allegro Group is 2%, therefore fulfilling the conditions for achieving the goal" (page 296).

The metric is entity-specific: the Group "prepares the equal pay gap by calculating weighted averages per career level inside each job family, based on a basic salary... it is different from the unadjusted gender pay gap according to the ESRS" (page 296).

"Due to the nature of the goal to reduce the equal pay gap, no base year has been set. No intermediate targets have been set either. The goal is maintained throughout the duration of the ESG strategy" (page 296). It "was set based on the stakeholder analysis and research among employees, partners and customers... and approved by the Board of Directors" (page 296).

The company states plainly where it has no targets: "In the ­Allegro Group's ESG strategy there are no specific targets for other IROs, due to the idea to focus on one indicator that has high leverage on the whole equal opportunities area. In the health and safety area there is no specific target, but the number of accidents is strictly monitored" (page 296).

Characteristics of the undertaking's employees

Reference: pages 302-303.

Table S1.3 gives total headcount of 6,090 employees at 31 December 2025, against 5,980 in 2024 and 5,514 in 2023, split 3,336 men, 2,692 women and 62 other or no information. By country: Poland 5,130, Czech Republic 608, Slovenia 291 and other 61, the tables covering "regions where the company employs more than 50 employees" (pages 302-303).

Table S1.5 reports 1,129 new joiners and 1,014 leavers in 2025, with a turnover rate of 17% against 21% in 2024 (page 302). Table S1.4 splits permanent from temporary contracts, of which "The majority of the ­Allegro Group's employees hold permanent contracts" (page 302).

The scope of own workforce is wider than the headcount tables: it covers "individuals employed under an employment contract as well as those collaborating with the ­Allegro Group on B2B terms, mandate contracts, specific-task contracts, or through temporary employment agencies (mostly for warehouse positions)" (page 292), while the S1-6 tables count employment contracts only.

Two limits are recorded: Czech and Slovenian agreements "which do not have equivalents in Polish law but share some characteristics with an employment contract" are included, and gender data is not obligatory to collect in some countries. "The number of employees is consistent with the consolidated financial statements" (page 302).

Diversity metrics

Reference: pages 304-305.

Table S1.6 "Gender distribution in the ­Allegro Group" reports the Board of Directors at 3 women (30%) and 7 men (70%) of 10, unchanged from 2024 and up from 27% in 2023. "In the Board of Directors of the ­Allegro Group, 30% of the board members are women, which is consistent with the Directive (EU) 2022/2381 on improving the gender balance among directors of listed companies" (page 304).

Below board level: managers (career level 8 and above) 25 women (26%) and 71 men (74%) of 96; middle managers (levels 6 and 7) 294 women (33%) and 597 men (67%) of 891; experts and specialists (level 5 and below) 2,373 women (47%), 2,668 men (52%) and 62 other (1%) of 5,103 (pages 304-305).

Table S1.7 gives the age distribution: under 30 1,617 (27%), 30-50 4,219 (70%), over 50 197 (3%) and undisclosed 57, on a total of 6,090 (page 305).

The company links the metric to action: "the ­Allegro Group has increased the representation of women in leadership roles, reduced the equal pay gap to 2%, provided training programs on inclusion and equality, and implemented recruitment practices that ensure a balanced representation of genders" (page 304). Both tables are within the limited assurance scope (page 352), and board gender diversity is also indexed as an SFDR and Benchmark Regulation datapoint, cross-referenced to the Corporate governance chapter (page 348).

Adequate wages

Reference: page 308.

"All wages in the ­Allegro Group are equal to or higher than the adequate minimum wage in all of the countries where the ­Allegro Group operates" (page 308). The disclosure is a positive nil return: no employees are reported as paid below an adequate wage benchmark, and no country breakdown of non-compliance is given because none is claimed.

The same paragraph adds the social protection context: "The ­Allegro Group complies with the local labour regulations that mandate social insurance protection for employees against significant life incidents such as illness, unemployment initiated while employed, work-related accidents, acquired disabilities, parental leave, and retirement. Protection is provided by public programs in line with local labour law which enforces comprehensive statutory social protection for all workers. The ­Allegro Group, as a responsible employer, meets these legal requirements for all its employees" (page 308).

The report does not name the adequate wage benchmark used per country, nor the reference source against which the comparison was made.

Training and skills development metrics

Reference: pages 306-307.

Table S1.9 reports 32 average training hours per employee in 2025 against 31 in 2024, split 36 hours for men (2024: 38) and 28 for women (2024: 23) (page 307). "The ­Allegro Group's approach to development is based on a 70/20/10 learning model" (page 306).

Table S1.8 reports that 91% of employees participated in regular performance reviews and career development in 2025 against 95% in 2024, being 94% of men (unchanged) and 89% of women (2024: 95%) (page 306).

The accounting notes explain both. Training hours come "from the Mind Up tool until the end of September (on external training till October 20th), from Harmony learning management system for the period from October to December... and from a language school"; performance review coverage "shows the share of employees participating in the performance review process (excluding those hired after October 1, 2025, and those on long-term leave) relative to the total headcount as of December 31, 2025" (pages 306-307).

The supporting framework is described: structured Learning Paths, a Talent and Performance Management Programme with formalised 360-degree evaluation, Individual Development Plans, a career-level classification system and a behaviour-based Leadership Development Model (pages 301, 306). Both tables are within the limited assurance scope (page 352).

Health and safety metrics

Reference: pages 307-308.

"The ­Allegro Group complies fully with national and European OHS standards... 100% of the ­Allegro Group's own workforce are covered by OHS" (page 307).

Table S1.10 reports for 2025: 0 fatalities from work-related injuries and ill health (2024: 0); 35 recordable work-related accidents (2024: 32); a rate of recordable work-related accidents of 3 (2024: 3); 0 cases of recordable work-related ill health (2024: 0); and 532 days lost to work-related injuries and fatalities from accidents and ill health, against 387 in 2024 (page 308).

The company explains the rise: "The rise of days lost to work-related injuries is linked to the dynamic expansion of ­Allegro One Delivery. A surge in parcel volume led to the opening of new depots and mass recruitment, including the engagement of external personnel during peak sales periods, which resulted in a higher number of minor accidents" (page 307).

Method: "Incident data for Polish entities was taken from the accident registers as of December 31, 2025. Data for non-Polish entities were provided by external parties... The rate of recordable work-related injuries is counted by dividing the respective number of cases by the number of total hours worked... and multiplied by 1,000,000" (page 308). The table is within the limited assurance scope (page 352).

Compensation metrics (pay gap and total compensation)

Reference: pages 308-309.

Table S1.11 reports an unadjusted gender pay gap of 34% for 2025, unchanged from 2024, alongside an entity-specific equal pay gap of 2% (2024: 3%) (page 309).

"The (unadjusted) gender pay gap, calculated in accordance with ESRS, is at the level of 34%. This notable difference stems from the unadjusted methodology, which compares gross hourly remuneration (basic and benefits) of all men and women across the entire organization, regardless of their specific positions, seniority, or individual competencies. While the equal pay gap measures equal pay for equal work" (page 308). "To validate these efforts, ­Allegro sp. z o.o. has obtained the Equal Pay and Opportunities certification by EQUAL-SALARY foundation" (page 308).

Table S1.12 reports the annual total remuneration ratio of the highest paid individual to the median at 82 for 2025 against 54 for 2024 (page 310). "In 2024, the total remuneration for the highest-paid individual (the former CEO) was unusually low because it included only the first tranche (25%) of RSU vesting. In 2025, the remuneration figure reflects the final tranche (50%)" (page 309).

Both tables are within the limited assurance scope and are indexed as SFDR and Benchmark Regulation datapoints under S1-16 paragraphs 97(a) and 97(b) (pages 349, 352).

Incidents, complaints and severe human rights impacts

Reference: page 310.

"The ­Allegro Group does not identify significant risks of forced, compulsory or child labour in its own operations in the countries in which it operates. In 2025, the ­Allegro Group did not identify any severe incidents regarding respect for human rights and did not receive related fines or penalties. There were no Money Laundering or Insider Trading incidents" (page 310).

Table S1.13 reports for 2025: 8 filed cases of discrimination (2024: 2); 23 complaints filed through channels for people in own workforce to raise concerns, including mobbing and discrimination (2024: 9); 0 complaints to National Contact Points for OECD Multinational Enterprises; 0 severe human rights incidents; and 0 in fines, penalties and compensation for damages as a result of the incidents (page 310). The rise in discrimination cases and in total complaints is reported without commentary.

Method: "The data above is sourced from ­Allegro's platform dedicated to whistleblowing and from the National Contact Points for OECD Multinational Enterprises, aggregated cumulatively as of December 31, 2025" (page 310). The table is within the limited assurance scope, and the discrimination and UNGP/ILO/OECD non-respect datapoints are indexed as SFDR and Benchmark Regulation items under S1-17 paragraphs 103(a) and 104(a) (pages 349, 352).

Policies related to consumers and end-users

Reference: pages 313-317.

A table maps the three material S4 topics to their policies (page 313): cybersecurity to the Security Policy and the Privacy Policy; consumer and product safety to the Risk Management Plan on product safety risks, GPSR Procedures, Terms and Conditions for partners and the Competition and Consumer Protection Compliance Policy; accessibility to WCAG and internal parcel-locker guidelines.

On cybersecurity: "The Security Policy, by promoting adherence to high standards of personal data protection, reduces the risk or magnitude of a cyberattack" (page 314). The Group applies ISO 2700X, NIST, CIS, COBIT and OWASP and holds PCI DSS v4 certification, but "does not disclose its Security Strategy" (page 315).

On product safety: the Trust and Safety Policies, Risk Management Plan and GPSR procedures aim "to reduce the risk that illegal or dangerous products will enter the market", and "all consumer-trust-related policies... have been approved by the Board of Directors". The Competition and Consumer Protection Compliance Policy "prohibits practices such as unfair or misleading advertising, false promotions, unfair pricing practices, and the use of abusive contract terms" (page 316).

On accessibility, the Group "adheres to international accessibility standards, such as the Web Content Accessibility Guidelines (WCAG)" (page 317). Minors are protected by "Junior" accounts with category restrictions (page 312).

Processes for engaging with consumers and end-users about impacts

Reference: pages 318-319.

"The ­Allegro Group engages with customers through various communication channels, including the contact form, ­Allegro chat, contact channel for deaf users, NPS surveys, periodic surveys, and the ­Allegro Gadane community... During the double materiality process, the ­Allegro Group gathered both sellers and consumers opinions on its impacts" (page 318). The stakeholder table adds a Hotline for Seniors, ­Allegro Protect, social media and media relations (page 219).

"These channels facilitate ongoing interactions with consumers and allow the ­Allegro Group to collect feedback and perspectives. For impact materiality assessment, such a survey was sent at the initial stage of the double materiality process, and its results were considered when setting the ­Allegro Group's ESG strategic goals" (page 318).

Accountability is named: "The Customer Experience Team is responsible for maintaining customer contact channels and prepares reports with conclusions drawn from the feedback... The most important current issues are presented to the Board of Directors" (page 318).

Consumers were not segmented: the Group "did not differentiate customers into specific groups, assuming that the impacts, risks, and opportunities affect each customer to the same extent", other than legal restrictions on Junior accounts (page 312).

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

Reference: pages 319, 322 and 325.

On cybersecurity: "There are many ways for users to report incidents - from formal paths (ticket systems, emails, and internal chat channels) to informal ones... Consumers and sellers may use... ­Allegro chat, the ­Allegro Gadane community, or email... the information reaches the Security Incident Commander Team, whose members are on duty 24 hours a day, 7 days a week" (page 319).

On product safety: "­Allegro users can report their concerns related to the legality, potential lack of compliance with ­Allegro's Terms and Conditions, and safety of a product through the contact form and by using the 'Report a violation' button at the bottom of the product listing page. Reports are handled by the Trust and Safety Team, which is responsible for resolving reported incidents and proposing actions to prevent similar situations in the future. The effectiveness of the Trust and Safety Team is then evaluated in consumer surveys" (page 322).

Remedy is financial as well as procedural: the Buyers Protection Program "guarantees support and financial compensation (up to PLN 20,000) for problematic post-purchase situations, covering purchases for up to 2 years", addressing "non-delivery, incomplete orders, or receiving an item not as described (e.g., damaged, counterfeited)" (pages 323-324).

Taking action on material impacts on consumers and end-users

Reference: pages 319-325.

Cybersecurity. A dedicated Computer Emergency Response Team monitors security and responds to threats (pages 319-320). "­Allegro Group conducts phishing tests on employees to verify the effectiveness of cybersecurity training", with internal and external penetration testing and a Bug Bounty programme, and "conducts cybersecurity maturity audits every two years... comparing them with NIST standards" (page 320). Table S4.2 reports 1 security incident reported to supervisory authorities, 2 personal data breaches, 5 new administrative proceedings (2024: 12) and no final financial fines (page 321).

Consumer and product safety. Actions include the Rights Protection Cooperation Program, blocking branded offers shipped from outside the EEA, a Repeat Infringers Striking Policy and AI/ML-based monitoring (pages 322-323). Table S4.3 reports 111,273,204 infringing offers removed and 105,486,198 listing attempts prevented in 2025 (page 324).

Accessibility. Parcel machines have Braille markings, a QR code connecting to a Polish Sign Language interpreter, high-contrast screens and selectable locker height; "in November and December 2025, ­Allegro conducted an external accessibility audit with the Avalon Foundation" (page 325). Table S4.4 reports 88% of ­Allegro One Box machines meeting accessibility requirements, up from 78% (page 326).

Targets related to consumers and end-users

Reference: page 318.

"The ­Allegro Group set a goal to train over 90% of its employees in cybersecurity by end 2025. No baseline year was adopted for measurements and no intermediate goals or other assumptions were disclosed" (page 318).

"The goal of training employees stems from the ­Allegro Group's adopted ESG strategy and directly relates to the risk of data protection and privacy breaches. In the case of cyberattacks, it is often the human factor that determines the effectiveness of the attack" (page 318).

Table S4.1 reports 96% of employees trained on cybersecurity in 2025 against 89% in 2024 and 58% in 2023, "which exceeded the 90% ESG strategy target" (page 318). The denominator excludes "individuals without a business email address and positions without access to a computer" (page 318). The figure is within the limited assurance scope (page 352).

"The goal was established based on the analysis of survey results sent to stakeholders as part of the double materiality process. The goal was approved by the Board of Directors. The achievement of the goal is regularly monitored by the ESGCo" (page 318).

The company states where targets are absent: "The Allegro Group maintains a comprehensive set of internal objectives. To date, the Group has not extended its external disclosures to include specific goals regarding impacts, risks, and opportunities related to Accessibility and Product Safety" (page 318).

Business conduct policies and corporate culture

Reference: pages 332-335.

"All of ­Allegro Group's policies that shape the corporate culture extend to operations as well as to all employees and entities with which the ­Allegro Group works on a daily basis. To facilitate implementation of its policies, the ­Allegro Group introduced a governance, risk and compliance management system" (page 332).

Some twenty-two policies are listed, including the Transparency (Anti-Corruption) Policy, the Code of Conduct for Suppliers and Business Partners, the Whistleblowing Procedure, the Artificial Intelligence Principles and the Responsible Marketing and Communication Policy (pages 332-333). "All above policies are reviewed and approved by the Board of Directors at least once a year or once in two years", with a Code of Ethics and Conduct serving "as a guide to all policies" (page 333).

"Once a year, the ­Allegro Group's employees participate in training on all the policies mentioned above... All employees are obliged to familiarise themselves with the documents and pass a test" (page 334). Efforts "have been recognized in 2024 with the 'Ethical Company' award for the third time" (page 334).

Animal welfare sits in the platform rules: the sale of living animals is prohibited in the Czech Republic, Slovakia and Hungary, permitted elsewhere only under welfare conditions, and "The sale of live or dead protected animals (as well as their parts or derivatives) is prohibited" (page 334).

Management of relationships with suppliers

Reference: pages 340-341; supplier code pages 339-340.

"Suppliers are selected in accordance with the ­Allegro Group Procurement Policy... the selected bid/supplier must always reflect the economically and business best offer based on transparent selection criteria" (page 339). The Code of Conduct for Suppliers and Business Partners reflects the ten UN Global Compact principles, the UN Guiding Principles, the ILO Declaration and the OECD Guidelines (page 339).

Thresholds are disclosed: "All suppliers with a contract value exceeding PLN 15,000 are provided with information regarding the code... If the total annual contract value with a supplier exceeds PLN 500,000, the supplier is asked to sign the Code of Conduct" (page 339). Key projects above PLN 100,000 in 2025 are checked against ESG objectives, and a code violation "is considered a material breach of the cooperation" (page 339).

Payment practice is reported here rather than under G1-6: "A standard payment deadline of 30 days was set, from which deviations are possible only in exceptional situations... In 2024, the ­Allegro Group implemented a 'No PO no PAY' policy to both expedite and reduce the number of invoices paid late" (page 340).

Table G1.2 reports 151.1 thousand selling partners with offers in 2025 against 167.0 thousand in 2024 and 149.6 thousand in 2023, a 10% fall the company attributes to "a strategic shift toward prioritizing partner quality" (page 341).

Prevention and detection of corruption and bribery

Reference: pages 334-335.

"The ­Allegro Group does not tolerate any corruption and bribery... Therefore, the ­Allegro Group enforces the Transparency (Anti-Corruption) Policy. The policy covers all areas of the ­Allegro Group's activities and applies to both companies within the Group and its business partners" (page 334). 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" (page 334).

Counterparty diligence: "Prior to entering into any business agreement, a proper and documented verification of the commercial partner's history, business potential, and reputation must be conducted. Special attention is paid to any information concerning the potential partner's involvement in bribery or corruption activities" (page 334).

Investigation is separated from the business: the CSO with the Information Security, Compliance and Loss Prevention teams "is responsible for conducting investigations into any irregularities", and "If team members are involved in a case, they do not participate in the investigation" (page 334).

Training reaches everyone: there is "no distinction between functions-at-risk to corruption that would be covered by specific training programmes", so all employees take anti-corruption training at onboarding and at least annually, concluding with a mandatory test (pages 334-335).

Targets related to business conduct

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

Reference: page 341; effectiveness tracking pages 334-338.

One measurable target sits in the G1 chapter, attached to the material "Value chain" topic: "The goal is to have 177 thousand sellers with offers on the ­Allegro Group platforms by 2026" (page 341). It "pertains to entities within the upstream value chain", is "monitored quarterly" and was "approved by the Board of Directors". Table G1.2 reports 151.1 thousand partners in 2025 against 167.0 thousand in 2024 (page 341).

For the corporate governance transparency IROs no target is set and effectiveness is tracked instead, which is MDR-T's other limb: annual mandatory training on all Code of Ethics policies for every employee, which "concludes with a mandatory test" (pages 334-335); whistleblowing reports verified by the Ethics Committee, with "a summary is presented quarterly to the AuditCo and the ESGCo" (page 338); and a Code of Ethics audit every three years, last performed in 2023 with "no major findings" (page 294).

The company also states a general limit: "­Allegro prioritizes its ESG actions and has decided to set ESG goals only for the most significant areas. Consequently, no other goals... have been established" (page 264).

Incidents of corruption or bribery

Reference: page 336.

"In 2025, ­Allegro recorded no court convictions, fines, or proceedings related to corruption or bribery, and no corrective actions were required for breaches of anti-corruption or anti-bribery standards" (page 336). Table G1.1 "Anti-corruption and anti-bribery compliance" reports 0 court convictions and 0 fines for both 2025 and 2024 (page 336). "The data comes from the internal register of court cases and concerns reports in 2025" (page 336). The table is within the limited assurance scope and is indexed as an SFDR and Benchmark Regulation datapoint under G1-4 paragraphs 24(a) and 24(b) (pages 349, 353).

A separate regulatory matter is disclosed in the same section, on greenwashing rather than bribery: "In 2025, the President of the Office of Competition and Consumer Protection in Poland (UOKiK) initiated proceedings against ­Allegro Sp. z o.o. in connection with the communication of the ­Allegro One promotional campaign in 2024, accusing the company of misleading consumers regarding the campaign's positive environmental impact. The organization is cooperating with UOKiK to clarify the matter. The mentioned promotional campaign is not part of the ­Allegro Group's decarbonization plan" (page 336).