argenx SE

Governance roles

Reference: pages 279-281 (7.1.4.1), with composition detail incorporated by reference to Sections 3.2 "Management Structure", 3.3 "Report of the Non-Executive Directors" and Note 25.3.

argenx has a one-tier Board of Directors under Dutch law, described as "the Company's highest governance body", which "is collectively responsible for overseeing our general affairs, including governance and oversight of sustainability matters" (page 279).

Allocation of responsibility (pages 279-280):

• The Audit and Compliance Committee holds ultimate responsibility for the integrity and design of our sustainability reporting.
• Four board committees each carry a defined ESG remit: Audit & Compliance (ESG aspects of audit and compliance), Remuneration & Nomination (HR and people development), Research & Development (product research and development), and Commercialization (responsible marketing, patient access and supply chain).
• Day-to-day management is delegated to the CEO. Within the Executive Management Team, the General Counsel and Corporate Secretary has primary responsibility for management oversight of sustainability matters and guides the sustainability strategy.
• "ESG considerations form a standing part of the Global Risk Management Committee's remit."

Employees are not formally represented on the board: their perspectives are "incorporated into decision-making through various channels, including regular meetings, feedback sessions, and committee participation" (page 281). The Audit and Compliance Committee "works closely with the Ethics and Compliance function, receiving quarterly updates on anti-bribery, anti-corruption, and related business-conduct topics" (page 281).

Information provided to and matters addressed by the board

Reference: page 281.

"In 2025, the Executive Management Team provided periodic updates to the Audit and Compliance Committee and the Board of Directors, with sustainability topics regularly included on meeting agendas."

Key topics discussed in 2025 were "regulatory compliance (including the Quick Fix amendment, and more generally the EU Omnibus Simplification Package), corporate culture, scientific innovation, and product affordability and pricing". The company states that "Discussions addressed both direct and indirect matters related to material impacts, risks, and opportunities" (page 281).

On business conduct specifically, the Audit and Compliance Committee receives quarterly updates on anti-bribery, anti-corruption, and related business-conduct topics from the Ethics and Compliance function "to ensure emerging risks are effectively addressed" (page 281). Compliance investigation reports are "shared regularly with the GCC and the Audit and Compliance Committee" (page 319).

The double materiality assessment itself was "documented, reviewed by the Global Risk Management Committee and validated by the Audit and Compliance Committee, ensuring governance oversight of both the process and its outcomes" (page 281), and the DMA "process and scoring criteria were reviewed and approved by the Senior Management Team and the Board of Directors" (page 285).

No disclosure is given of the frequency with which each individual material IRO was addressed, nor of trade-offs considered.

Sustainability-related performance in incentive schemes

Reference: page 281 (7.1.4.2), with detail incorporated by reference to Section 3.4.2 "Remuneration Policy" and Section 3.4.3 "NEO Remuneration in FY25".

The disclosure is short and covers a single sustainability dimension:

"In 2025, the short-term and long-term incentive compensation for the Board of Directors and Executive Management Team included performance metrics specifically tied to talent retention. For more information on incentive schemes related to talent management, see Section 3.4.3 'NEO Remuneration in FY25'." (page 281)

The ESRS content index lists GOV-3 twice: once under ESRS 2 and again under the ESRS E1 Climate Change block, pointing to the same "Integration of Sustainability-Related Performance Incentive Schemes (GOV-3)" section (pages 275-276). No climate-related or GHG-linked component of remuneration is disclosed, and no percentage of variable remuneration tied to sustainability targets is given. The talent-retention metric is the only sustainability-related performance metric named.

Statement on due diligence

Reference: page 281 (7.1.4.3), including the mapping table of the core elements of due diligence.

"In 2025, we refined our sustainability due diligence processes to improve the identification, assessment, and management of ESG-related impacts, risks, and opportunities, in alignment with ESRS requirements." The DMA was refreshed "to ensure key topics were comprehensively covered and appropriately prioritized across our value chain", and "The process was documented, reviewed by the Global Risk Management Committee and validated by the Audit and Compliance Committee" (page 281).

Mapping of the core elements of due diligence to paragraphs in the statement (page 281):

Note the table cites S4-4, a disclosure requirement that the company then omits under the S4 phase-in relief (page 309). The company also states elsewhere that "we have not yet implemented a formal Human Rights Due Diligence process fully aligned with the six-step approach outlined in the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines" (page 295).

Risk management and internal controls over sustainability reporting

Reference: pages 281-282 (7.1.4.4).

"Our 2025 Sustainability Statement data collection process was designed to ensure compliance with ESRS requirements, and we established a governance and control framework to support the accuracy, consistency, and transparency of our reporting. We engaged our statutory auditor, EY Accountants B.V., to provide limited assurance" (page 281).

Roles: "The CFO oversees sustainability reporting and auditing as part of our integrated reporting process. Day-to-day responsibility lies with the Finance Team, which coordinates data collection and validation across the business, supported by external advisors. Internal controls are embedded in key reporting activities, including data collection, consolidation, review, and approval" (pages 281-282).

Risk assessment approach: external advisors were engaged "to identify, evaluate, and prioritize risks that could affect the quality and completeness of our reporting", using "a combination of top-down and bottom-up reviews, stakeholder interviews, and documentation analysis" (page 282).

Core risks and mitigations identified (page 282): regulatory and legal risk of non-compliance with evolving CSRD/ESRS requirements (continuous monitoring, staff training, external advisers); data accuracy and integrity, "Errors from manual inputs or inconsistent data sources" (validation checks, defined data ownership, system-based controls); IT and systems risk (a secure centralised reporting platform, regular system testing); and operational and organisational risk from unclear responsibilities (defined roles, escalation procedures, management oversight).

"Controls are refined annually based on audit results, feedback, and lessons learned" (page 282). The Board's management confirmations state that "the internal risk and control systems provide limited assurance that sustainability reporting is free from material misstatements" (page 328).

Strategy, business model and value chain

Reference: page 278 (7.1.3.1), with headcount and financial detail incorporated by reference to Sections 1.1.2, 1.3, 5.12 and 6.1. The value chain map is on page 284.

"Our business model centers on scientific innovation and co-creation, bringing together research, technology, and collaboration to engineer life-changing immunology solutions for patients. We bring antibody-engineering expertise to pioneering researchers to help advance immunology breakthroughs into differentiated medicines" (page 278).

The value chain is structured around two core components (page 278):

1. Research and Development - "early-stage research, biotechnology sourcing, pre-clinical studies, clinical trials, and collaboration with CROs and CMOs. These activities culminate in regulatory submissions that enable product commercialization."
2. Commercial Operations - "manufacturing, packaging, labeling, global distribution, patient support programs, and end-of-life product management. Sales and marketing activities engage downstream payers and stakeholders."

The value chain map (page 284) sets out own operations, upstream and downstream: upstream centres on "early-stage research, working with academic partners, sourcing of biotechnology and raw materials, and strategic partnerships"; downstream on "global distribution, patient support, and lifecycle management of its antibody therapies". Named value chain actors are CROs, CMOs, distributors, direct and indirect suppliers, regulators, healthcare providers and patients.

The appendix marks the SFDR/Benchmark datapoints on involvement in fossil fuel activities, chemical production, controversial weapons and tobacco as "Not relevant" (page 323). Turnover is reported in the EU Taxonomy tables as $4,151.3 million eligible (99.9%), with 0% aligned (page 296). Headcount at 31 December 2025 was 1,863 (page 307).

Interests and views of stakeholders

Reference: pages 282-283 (7.1.5), including the stakeholder engagement table.

"We engage with a broad range of stakeholders, including patients, healthcare providers, employees, suppliers, and (potential) investors, to understand and incorporate their perspectives into our strategy and business model." Engagement "is guided by our policy on bilateral contacts and dialogue with shareholders and stakeholders (the Bilateral Shareholders and Stakeholders Contacts Policy)", supported by the Interactions with the Healthcare Community Global Policy and the Interactions with the Patient Community Global Policy (page 282).

A limitation is stated plainly: "While external stakeholders were not directly consulted for the double materiality assessment, their perspectives were represented through business units that maintain ongoing dialogue with them" (page 282). Consistently, the DMA describes "direct consultation with internal experts and indirect consultation with credible proxies", with external perspectives incorporated "through desktop research and use of credible proxies" (page 285).

Engagement by group (page 283):

• Patients - "regular patient panels and listening sessions where patients share their experiences and challenges dealing with rare autoimmune conditions", to "identify and address unmet clinical needs".
• Healthcare providers - clinical research, advisory services and speaking engagements.
• Employees - engagement sessions including Culture Lab sessions, all-hands and town halls; employees "Are co-owners of the business".
• Suppliers - since 2024, questionnaires "to selected suppliers to gather emissions data", which "informs our GHG inventory".
• Investors - regular investor relations engagement on ESG matters.

No disclosure is made of how stakeholder views have changed the strategy or business model.

Material impacts, risks and opportunities

Reference: pages 285-286 (7.1.6.6), with the per-topic IRO tables on pages 287 (E1), 301 (S1), 309-310 (S4) and 316 (G1).

"Through this double materiality re-assessment, which addressed both impact and financial materiality in accordance with the ESRS, we identified our material sustainability topics across ESRS categories for disclosure" (page 285).

Four material topics, all in the double-materiality quadrant of the results matrix (page 286):

• E1 Climate Change
• S1 Own Workforce
• S4 Patients (with the footnote: "For reporting purposes, we are disclosing information related to the Entity Specific Topic of Innovation under the S4 Patients section")
• G1 Business Conduct

The matrix records "No topics" under financial materiality alone (page 286).

Changes from 2024 (pages 285-286):

• "New IROs were identified in 2025, and the IRO language was refined to improve relevance to our business model and operating environment."
• "Waste-related IROs were removed from scope and deemed not to be material due to the low volume of waste generated in our business model. This conclusion was informed by waste audits completed as part of the 2024 reporting process."
• "Equal treatment-related IROs (Training and Skills Development and Diversity), which were previously identified as positive impacts in 2024, have been reframed as potential negative impacts in 2025."
• "Animal welfare was added as a new material risk under G1 for 2025."

Twenty-one individually typed IRO rows are described across the four topical chapters. The company gives no consolidated count and no matrix coordinates.

Processes to identify and assess material impacts, risks and opportunities

Reference: pages 283-285 (7.1.6.1 to 7.1.6.5); climate-specific process on pages 287-288.

Scope. "In 2025, we refreshed and revalidated our DMA in alignment with ESRS and CSRD. Building on the 2024 assessment, this process ensures continued compliance and relevance across all consolidated entities within our direct operations. OncoVerity, a joint-venture in which we hold a 50% non-controlling interest, was included as part of the value chain, but remains unconsolidated" (page 283).

Value chain mapping. "The approach centered on a comprehensive value chain mapping to identify the most relevant upstream, downstream, and company-operated activities, relationships, and sectors... Tier 1 suppliers and key customer segments were evaluated by geography, and topics were mapped and clustered in line with ESRS guidelines" (pages 283-284).

Identification. IROs were "grouped by topic, type, time horizon, geographical scope, and primary impact area". "Dependencies on natural, human, and social/relationship capital were identified and validated. Potential impacts, risks and opportunities were systematically mapped to the dependencies from which they arise" (page 285).

Scoring and thresholds (page 285). "The 2024 scoring methodology was retained with minor refinements for consistency." Impact materiality scored each IRO 1-5 across "scale, scope, and irremediable character which were combined into a severity score. For negative impacts, this severity score was then multiplied by the likelihood". Financial materiality used "likelihood and potential financial impact, aligned with our Enterprise Risk Management framework". Time horizons: short term 0-2 years, medium term 3-5 years, long term more than 5 years. Thresholds were "established using a matrix-based approach grounded in the quantitative scoring results".

Approval. "The process and scoring criteria were reviewed and approved by the Senior Management Team and the Board of Directors" (page 285).

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Disclosure requirements covered by the sustainability statement

Reference: pages 274-277, the "Content" table listing disclosure requirements against the section where each is addressed. This is a genuine ESRS content index.

ESRS 2 (page 274-275): BP-1, BP-2, GOV-1, GOV-2, GOV-3, GOV-4, GOV-5, SBM-1, SBM-2, SBM-3, IRO-1, IRO-2.

Incorporation by reference (page 275): ESRS 2 BP-1, SBM-1, GOV-1-2 (board skills and expertise), GOV-3, IRO-1/IRO-2, E1-6, three EU Taxonomy denominators, S1-16, S1-6, S4 and G1 all draw on named sections and notes of the annual report and financial statements. Incorporated information "falls within the scope of the limited assurance engagement" (page 277).

ESRS E1 Climate Change (pages 275-276): ESRS 2 GOV-3, ESRS 2 SBM-3, ESRS 2 IRO-1, E1-1, E1-2, E1-3, E1-4, E1-5, E1-6. E1-7, E1-8 and E1-9 are absent from the index.

ESRS S1 Own Workforce (page 276): ESRS 2 SBM-2, ESRS 2 SBM-3, S1-1, S1-2, S1-3, S1-4, S1-5, S1-6, S1-7, S1-9, S1-13, S1-14, S1-16, S1-17. S1-8, S1-10, S1-11, S1-12 and S1-15 are absent.

ESRS S4 Patients (page 276): only ESRS 2 SBM-3 and "ESRS 2 BP 2-17 - Disclosures in relation to specific circumstances - Patients (Phase in-relief applied)". No S4 disclosure requirement is listed.

ESRS G1 Business Conduct (pages 276-277): ESRS 2 GOV-1, SBM-3, G1-1, G1-2, G1-3, G1-4, G1-6. G1-5 is absent.

A separate appendix (pages 323-325) lists the EU-legislation datapoints, marking E3, E4, E5-5, S2 and S3 rows "Not material", the SBM-1 involvement rows "Not relevant", and the E1-7 and E1-9 rows "Not stated (phase-in)".

Transition plan for climate change mitigation

Reference: page 289 (7.2.1.3).

argenx discloses that it has no transition plan. The entire E1-1 disclosure reads:

"In accordance with paragraph 17 of ESRS E1-1, we have not yet developed a climate transition plan for climate change mitigation. We are monitoring regulatory developments and may adapt our approach once clearer guidance is available." (page 289)

Nothing is disclosed on decarbonisation levers, locked-in emissions, CapEx or OpEx alignment, compatibility with limiting warming to 1.5°C, or board approval of a plan. The appendix EU-legislation datapoint table lists "ESRS E1-1 14 - Transition plan to reach climate neutrality by 2050" and "ESRS E1-1 16 (g) - Undertakings excluded from Paris-aligned Benchmarks" without a section reference and without a "not material" marking (page 323).

Related content elsewhere in the climate chapter does not amount to a plan: the company reports no GHG targets ("We currently do not have targets related to GHG emissions due to ongoing uncertainty regarding emissions data and evolving climate-related regulations", page 290), and its two disclosed actions - an EV fleet programme in Belgium and the PolyTower office retrofit in Ghent - are explicitly unquantified ("Emission-reduction impacts associated with fleet changes have not yet been quantified", page 289; "Direct energy savings cannot yet be quantified", page 290).

The transition-plan audit for this company scores 0 of 10 criteria as directly met.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate DMA subsection, where this content is disclosed in the FY2025 report (pages 287-289). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

When the analysis was done. "In 2024, we conducted a scenario-based climate risk assessment to evaluate exposure to physical and transition risks." Time horizons were "short term (0-5 years), medium term (5-15 years), and long term (15+ years), consistent with Task Force on Climate-related Financial Disclosures (TCFD) guidance. These differ from other IRO timeframes to align with best practice in climate-scenario modeling" (page 287). No refresh of the assessment in 2025 is reported.

Physical risk scenarios (page 287). Three IPCC scenarios: "SSP1 (below 2°C), SSP2 (2-4°C), and SSP5 (3.3-5.7°C), with the main focus on SSP5 as this scenario represents the highest expected impacts". CMIP models projected "hazard exposure at baseline, 2030, and 2050". Eight hazards were analysed: "extreme heat, coastal flooding, pluvial flooding, riverine flooding, wildfires, water stress, drought, and cyclones", using "IPCC AR6-aligned scenarios".

Scope of operations covered (page 288). "The assessment covered 43 key locations within our value chain, including own operations (12 office sites), suppliers (28 sites), and customers (3 sites) across North America, Europe, and Asia Pacific. The assessment was conducted at the inherent level, without considering existing adaptation or mitigation measures."

Transition risk scenarios (page 288). Assessed "qualitatively across four categories (policy and legal, market, technology, and reputation) based on the TCFD framework", with "Thirteen sub-categories including carbon pricing, emissions reporting obligations, product regulation, litigation, changing customer behavior, increased cost of raw materials, technology substitution, and reputation factors". Emissions, revenue, market presence and stakeholder priority data were analysed against IEA Stated Policies, Announced Pledges and Net Zero Emissions by 2050 scenarios for 2030, 2040 and 2050, "with the main focus on the net zero scenario".

Classification and results (page 288). Risks are labelled physical (acute and chronic) and transition. Climate-related regulations and raw materials costs "were identified as relevant but not material under our double materiality assessment". Extreme heat and water stress were "identified as potentially relevant at an inherent level". The company states: "At this stage, we have not conducted a specific assessment to identify assets or business activities that may be incompatible with a transition to a climate-neutral economy."

Gap: no global average temperature projection per scenario is stated (ESRS E1-2 ¶17(a)(iii) in the 2025 numbering), beyond the warming bands attached to the SSP labels.

Resilience in relation to climate change

Back-filled from the E1 climate DMA subsection and ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 287-289). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The company states plainly that it has not carried out a standalone resilience analysis:

"While we have not conducted a standalone resilience analysis, the climate risk assessment considered the effect of existing adaptation and mitigation measures (such as HVAC systems, heat protocols, backup generators, and diversified supply chains) when evaluating the likely operational impact of physical risks. These measures are expected to limit the potential disruption from acute and chronic climate hazards, and their effectiveness was qualitatively assessed following the scenario analysis." (page 288)

What is disclosed instead (page 288):

• Acute physical. "Some sites are expected to experience greater extreme heat under high-warming scenarios by 2030-2050. However, due to existing HVAC systems, heat protocols, and backup generators at R&D sites, the overall operational impact is expected to remain limited."
• Chronic physical. "Water stress could affect certain sites in high-warming scenarios, although impacts are expected to remain low given current adaptation measures and low water dependence in office operations. Contract manufacturers are expected to bear most potential cost increases."
• Capacity to adapt. Results "may inform strategic and risk management decisions, including contingency planning, supply source diversification, and location selection. For example, office sites were found to have low sensitivity, whereas some contract manufacturers could face greater disruption from extreme weather events" (page 288).

Implications for strategy and financial planning. "No critical climate-related assumptions have been made in our financial statements to date, and the climate scenarios used in this assessment are not reflected in asset valuations, depreciation schedules, or other financial estimates" (page 287).

Uncertainty and next steps. "Future assessments may incorporate adaptive measures to further refine understanding of climate resilience" (page 288). Anticipated financial effects are omitted under phase-in relief (page 289).

Policies related to climate change mitigation and adaptation

Reference: page 289 (7.2.2.1).

One policy is disclosed, and it is narrow. The Company Car Policy (EMEA) is the only climate-related policy presented under E1-2 (page 289):

The company then states the limit of its policy coverage directly:

"We currently do not have policies linked to managing upstream or downstream emissions." (page 289)

This matters against the emissions profile: Scope 3 is 468,212 tCO2e of 471,043 tCO2e total market-based emissions in 2025, or 99.4% (page 291). No policy is disclosed for energy efficiency, renewable energy deployment, or climate change adaptation.

Actions and resources in relation to climate change policies

Reference: pages 289-290 (7.2.2.2). Two actions are disclosed, both in own operations, both unquantified.

EV Program (page 289). "In Belgium, charging wall boxes are provided to employees with a company car, supporting the adoption of lower-emission vehicles. Fixed car lists have been implemented for all eligible employees, removing internal combustion engine vehicles and significantly reducing plug-in hybrid electric vehicles. This approach prioritizes electric vehicles and reflects our longer-term plan to transition toward a fully electric fleet in Belgium."

Scope is limited by infrastructure: "Charging infrastructure constraints in other countries of operation currently limit the applicability of similar measures outside Belgium. As infrastructure becomes more accessible, we may assess opportunities to expand these actions when feasible." The company states that "Emission-reduction impacts associated with fleet changes have not yet been quantified."

Alinso Building Retrofit (pages 289-290). A retrofit at the PolyTower offices in Ghent "to improve energy efficiency and reduce operational emissions", comprising:

1. HVAC - "Fossil-free system based on reversible heat pumps, managed through a building management system that adjusts ventilation rates based on CO₂ levels and occupancy."
2. Lighting - "100% LED lighting with timer or sensor-based controls."
3. Appliances - "All appliances installed since 2023 have energy labels between A and C, with more efficient models introduced in 2024-2025."

"Direct energy savings cannot yet be quantified because PolyTower represents an expansion rather than a replacement of existing space. A theoretical comparison indicates that expanding the Bioscape site by 3,600 m² would have resulted in approximately 30-35% higher energy costs relative to PolyTower, although this estimate is indicative only" (page 290).

No CapEx or OpEx is attached to either action, and no value chain actions are disclosed despite Scope 3 being 99.4% of the footprint (page 291). The disclosed effect that is visible in the metrics is energy: total fossil energy consumption fell from 17,499.86 MWh to 11,670.80 MWh, "primarily due to reductions in car-related fuel demand as the majority of the vehicle fleet in Europe, particularly in Belgium, continues to shift from diesel and petrol engines to electric vehicles" (page 290).

Targets related to climate change mitigation and adaptation

Reference: page 290 (7.2.2.3).

argenx has no GHG targets. The complete E1-4 disclosure reads:

"We currently do not have targets related to GHG emissions due to ongoing uncertainty regarding emissions data and evolving climate-related regulations. These regulatory developments may inform our sustainability strategy, and we continue to monitor them closely to guide our approach in this area." (page 290)

No base year, no gross reduction target for Scope 1, 2 or 3, no intensity target, no 2030 or 2050 milestone, no science-based target commitment and no SBTi validation are disclosed. The appendix lists "ESRS E1-4 34 - GHG emission reduction targets (SFDR, Pillar 3, Benchmark regulation)" without a section reference (page 323).

The stated reason - "ongoing uncertainty regarding emissions data" - is corroborated elsewhere in the chapter: Scope 3 accounts for 468,212 of 471,043 tCO2e (page 291), supplier-specific data covers only 48% of Scope 3 (page 293), Category 1 uses spend-based EEIO factors for the remainder, and Category 4 supplier-specific coverage fell from 14% to approximately 6% year on year (page 293). Two 2024 Scope 3 categories were restated upward following "an inconsistency in information directly provided by a supplier in the prior year" (page 278).

No climate adaptation target is disclosed either.

Energy consumption and mix

Reference: page 290 (7.2.2.4), with accounting policy on page 292.

"As seen in the E1-5 metrics table, 100% of the purchased electricity, heat, steam and cooling comes from fossil sources. In 2025, there was no energy consumption purchased from renewable sources or on-site self-generated" (page 292).

Driver of the 33% fall. "Total energy consumption from fossil fuels has declined, primarily due to reductions in car-related fuel demand as the majority of the vehicle fleet in Europe, particularly in Belgium, continues to shift from diesel and petrol engines to electric vehicles" (page 290).

Restatement. "In 2025, we restated our 2024 energy consumption (E1-5) metrics, due to a methodological change" (page 278); "We have revised the energy consumption calculations to only capture facilities under scope 1 and Scope 2 and subsequently restated our 2024 figures to align with this approach" (page 292).

"We do not have any biogenic emissions across our Scope 1, Scope 2, or Scope 3 categories" (page 290). No energy intensity per net revenue is disclosed; the appendix marks the high-climate-impact-sector datapoints (E1-5 ¶38 and ¶40-43) without a section reference (page 323).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: page 291, with accounting policies on pages 292-294. Scope 1 and 2 figures are incorporated by reference alongside Section 6.1 "Consolidated Statements of Profit or Loss" for the intensity denominator (page 275).

Scope 3 by category (page 291): Cat 1 Purchased goods and services 382,340 (+62%); Cat 2 Capital goods 4,216 (+121%); Cat 3 Fuel and energy-related 746 (-37%); Cat 4 Upstream transport 63,324 (+158%); Cat 6 Business travel 13,494 (+1%); Cat 7 Employee commuting 1,795 (+31%); Cat 8 Upstream leased assets 99 (+191%); Cat 9 Downstream transport 339 (+8%); Cat 14 Franchises 1,401 (+458%); Cat 15 Investments 460 (-35%).

Boundary and method. Operational control under the GHG Protocol; "we account for 100% of GHG emissions from operations under our control. Emissions from our joint venture, OncoVerity, are included in Scope 3, Category 15 - Investments" (page 292). Scope 1 is "primarily associated with leased employee vehicles"; 2025 vehicle fuel was estimated using average daily fuel consumption from 2024 (page 292). Market-based Scope 2 "reflect the residual mix where available and default to location-based factors where residuals are not available" (page 292).

Data quality. Supplier-reported data covers "48% supplier-specific data coverage, remaining consistent with 2024"; within Category 1 supplier-specific data is 57% (55% in 2024), the remainder spend-based EEIO; Category 4 supplier-specific coverage is "approximately 6% of total Category 4 emissions (down from 14% in 2024)" (page 293).

Exclusions (page 294): Cat 5 Waste ("Not relevant; our emissions related to waste is minimal"), Cat 10, Cat 11 ("our products do not consume energy"), Cat 12 and Cat 13.

Restatement. 2024 Category 1 rose from 183,781 to 236,582 tCO2e and Category 4 from 24,556 to 24,587 tCO2e after "an inconsistency in information directly provided by a supplier in the prior year" (page 278). No emissions from regulated emission trading schemes are reported.

Policies related to own workforce

Reference: pages 303-304 (equal treatment) and page 306 (health and safety).

"We uphold the right to freedom of association and maintain a zero-tolerance stance on workplace discrimination." The Code of Conduct and Business Ethics "outlines our policies for prohibiting and preventing discrimination based on categories, including but not limited to race, religion, color, political convictions, gender, sex, pregnancy, ethnicity or national origin, civil state, social status, sexual orientation, disability (or handicap), or age" (page 303).

Two named policies (page 303):

• Managing Training standard operating procedure - "Establish a uniform approach to training, including how training is managed and assigned." Scope: "All employees, consultants, interns, and contractors." Accountable: Head of Quality. Monitoring: "Quarterly Quality Management Review."
• Diversity, Equity and Inclusion Policy - scope "All global operations", accountable to the Head of HR and the General Counsel and Corporate Secretary, externally available. Monitoring: "No formal monitoring."

Stated gaps, in the company's own words (pages 303-304):

• "We do not have a separate policy or program that manages impacts related to human rights."
• "We have not conducted a direct assessment of whether any of our operations are at heightened risk of forced, compulsory, or child labor. However, our owned operations are located in geographies and involve activities that are not typically associated with elevated risks of these issues."
• On health and safety: "While we do not maintain a formal, standalone workplace accident prevention policy, our Code of Business Conduct and Ethics includes a commitment to maintaining a safe and healthy workplace. We comply with applicable health and safety regulations and have implemented processes to prevent work-related incidents" (page 306).

The company states it complies with international labour standards "including, but is not limited to, the prohibition of child exploitation and child labor, forced, bonded, or indentured labor and involuntary prison labor, harsh or inhumane treatment... or any form of modern slavery or human trafficking" (page 303). The Anti-Retaliation Policy "prohibits discrimination against employees who raise complaints" (page 303).

Processes for engaging with own workforce and workers' representatives

Reference: pages 301-302 (7.3.1.2).

"All employees are co-owners who contribute to our broader purpose and success. We engage directly with employees and encourage open dialogue through regular forums such as quarterly Company-wide meetings, focus groups, and new-hire check-ins" (page 301).

Named channels (pages 301-302):

• Employees "can contribute to the agenda of quarterly Company-wide meetings by submitting questions in advance and can also raise additional questions live during the meeting".
• "We have established a network of 'Culture Champions' - nominated employees - who host ongoing cultural dialogue sessions. Insights from these sessions inform employee programs and help guide leadership."
• "Office and campus site teams host quarterly focus groups on topics including well-being, development, health and safety, and other employee initiatives."
• New-hire check-ins by HR "after the first three months", and CEO welcome sessions.
• 'Engage', an internal social networking platform, plus weekly company-wide updates and a monthly 'In Case You Missed It' recap.

Accountability. "We assess the effectiveness of employee engagement, with oversight from the Global Head of Human Resources, by gathering feedback through focus group discussions, employee questions and comments submitted before the quarterly Company-wide meetings, and analysis of engagement with internal communication channels" (page 302).

Stated gap. "We do not currently have a separate process to gain insights into the perspectives of particularly vulnerable employee groups" (page 302). No workers' representatives, works council or global framework agreement is described, and no agreement with employee representatives on respect for human rights is disclosed.

Processes to remediate negative impacts and channels to raise concerns

Reference: page 302 (7.3.1.3), cross-referring to page 318.

"We provide multiple channels for employees to raise questions, concerns, or file reports. For health and safety related matters, employees can contact their respective HR Business Partner or contact the Global Facilities and Employee Health and Safety Lead directly if involved in an incident. For other matters, communication channels include the argenx Helpline, HR and Legal teams. These channels are introduced to all employees during onboarding" (page 302).

"Our Anti-Retaliation Policy, detailed in Section 7.4.1.3. 'Protection of Whistleblowers', strictly prohibits retaliation against anyone who raises a concern in good faith" (page 302).

Supporting detail from the governance chapter (pages 318-319): the argenx Helpline "is externally managed to allow confidential and anonymous reporting". The Ethics and Compliance Investigations Global Procedure prohibits retaliation "against any individual who reports a concern or any person assists a reporter, cooperates with an investigation, responds to a request from regulators or government authorities, or exercises a legally protected right to report evidence of violations. Any form of retaliation will result in disciplinary action, up to and including termination of employment, revocation of site access, or discontinuance of services." All employees, consultants and ad-hoc contractors take an annual e-learning module covering whistleblowing procedures, and "Employees receiving whistleblowing reports are trained on a dedicated investigations standard operating procedure".

The appendix lists the SFDR datapoint "ESRS S1-3 32 (c) - Grievance/complaints handling mechanisms" (page 324). No remedy or remediation outcome is described, and the company does not disclose whether it assesses employee awareness of, or trust in, the channels.

Taking action on material impacts on own workforce

Reference: page 304 (equal treatment and opportunities) and page 306 (health and safety).

Equal treatment, training and diversity (page 304). "At the recruitment stage, we follow a standardized process designed to promote inclusion and avoid bias. The same principle guides promotions, training, and career development, which are based on job-related criteria such as skills and experience. Our employee resource groups also help advance inclusion by fostering dialogue and supporting related educational programs."

On development: "we provide access to role-specific learning resources aligned with Personal Development Plans, which outline a strength-based development path, and formal leadership programs. Program effectiveness is evaluated through participant surveys."

On feedback: "we encourage all employees to give and request feedback year-round, rather than relying on an annual review process. To support this, we provide training on the situation-behavior-impact feedback model."

Health and safety (page 306). "We provide laboratory employees with training on safe chemical handling, waste management, and biosafety practices. As a preventative measure, we also conduct lab audits to raise awareness, verify that policies are understood and applied in daily work, and identify opportunities for improvement."

The actions map onto the three material S1 IROs: unequal opportunities for training and advancement, lack of diversity and inclusion, and "Exposure to hazardous substances and biological agents in research and operational roles" (page 301). No resources, budget or headcount are attached to any action, no timeframes are given, and effectiveness is tracked only through participant surveys and the metrics in S1-9, S1-14 and S1-17.

Targets related to own workforce

Reference: page 304 (equal treatment and opportunities) and page 306 (health and safety).

argenx has adopted no own-workforce targets. Both S1-5 entries are explicit nil returns, disclosed under MDR-T:

"We have not adopted targets in relation to own workforce metrics and instead are focused on monitoring and responding to trends in our workforce metrics." (page 304)

"We have not adopted targets in relation to workforce health and safety and instead maintain an objective to minimize incidents across our operations." (page 306)

Consistent with MDR-T's alternative limb, tracking is done through the disclosed metrics rather than against a target: employee age distribution and gender distribution of top management (page 304), work-related fatalities and injuries (page 306), headcount, turnover, geography, gender and contract type (page 307), and discrimination incidents and complaints (page 308). The Diversity, Equity and Inclusion Policy is recorded as having "No formal monitoring" (page 303).

No target is set for gender balance in top management (39 women and 39 men, 50/50 in 2025, page 304), for the gender pay gap, for training hours, or for accident rates. Employees were not stated to have been involved in setting targets, since none were set.

Characteristics of the undertaking's employees

Reference: pages 307-308, with headcount also incorporated by reference to Note 19 "Personnel Expenses" (page 275).

Headcount and turnover (page 307):

Gender (page 307): Female 1,134 (60.9%), Male 729 (39.1%); 2024: Female 957 (59.8%), Male 642 (40.2%).

Country (page 307): United States 789, Belgium 565, Japan 146, Other 363. 2024: United States 694, Belgium 466, Japan 139, Other 300.

Contract type (page 307): permanent 1,861 (1,133 female, 728 male); temporary 2 (1 female, 1 male); non-guaranteed hours nil. 2024: permanent 1,597, temporary 2.

Accounting policy (page 308). "Headcount represents the total number of employees as of December 31st, 2025. Turnover is calculated using average headcount at year-end as the denominator. Data is compiled from our internal HR system (Workday)." The geographic breakdown "includes countries with more than 50 employees, that represent at least 10% of our total workforce. Entities with fewer than 50 employees are consolidated and reported under 'Other.'" For 2025 "Other" covers Australia, Austria, Brazil, Canada, France, Germany, Greece, Ireland, Italy, Netherlands, Poland, Portugal, Spain, Sweden, Switzerland and the United Kingdom. "Within contract type by gender, 'Not reported' indicates employees who chose not to disclose this information."

Full-time versus part-time is not broken out.

Diversity metrics

Reference: page 304, with accounting policy on page 306.

Employee age distribution (page 304):

Gender distribution of top management (page 304):

Accounting policy (page 306). "Top management refers to the leadership team, including the Executive Management Team, major global and commercial leaders, major development project leaders, and key R&D leaders. 'Other' within gender distribution of top management refers to vacant top-management positions."

Top management grew from 57 to 78 positions over the year while reaching an even gender split. Across the whole workforce, women are 60.9% of headcount (page 307), so women remain under-represented in top management relative to the employee base. S1-9 is one of the metrics the company names as its means of tracking the effectiveness of due diligence actions (page 281), and it does so without a target: "We have not adopted targets in relation to own workforce metrics" (page 304).

Health and safety metrics

Reference: page 306, with accounting policy on the same page.

Zero fatalities and zero recordable accidents in 2025, against one accident in 2024. The coverage metric is reported as nil in both years, meaning no part of the workforce is covered by a recognised-standard health and safety management system that has been internally or externally audited.

Accounting policy (page 306). "Work-related fatalities and injuries reported in headcount reflect employees and do not include contractors or others from third-party companies. Percentage of own workforce who are covered by health and safety management system based on recognized standards or guidelines and which have been internally audited and/or audited or certified by an external party only reflects coverage by recognized standards and guidelines, this metric does not relate to legal requirements."

The company also states that it has no standalone accident prevention policy: "While we do not maintain a formal, standalone workplace accident prevention policy, our Code of Business Conduct and Ethics includes a commitment to maintaining a safe and healthy workplace" (page 306). The appendix lists the SFDR/Pillar 3 datapoints S1-14 88(b) and (c) (number of fatalities and number and rate of work-related accidents) and 88(e) (number of days lost to injuries, accidents, fatalities or illness) (page 324); days lost is not reported. No fatalities or accident data for other workers on sites is given.

Compensation metrics (pay gap and total compensation)

Reference: pages 305-306, presented differently from Section 3.4 "Remuneration Report and Compensation Statement", which is incorporated by reference (page 275).

Remuneration ratio. "The remuneration ratio below is defined under ESRS and is presented differently under the Remuneration and Compensation Statement in Section 3.4 of this Annual Report. The figure for 2025 is 25. In 2024, this figure was 23" (page 305).

Adjusted gender pay gap by level (page 305) - "the adjusted gender pay gap for comparable positions, responsibilities, skill sets and experiences following the ESRS methodology but clustered in the following five categories":

"Using this methodology the gender pay gaps range from -7% to +2.5% with a weighted average of 4.6% in favor of women" (page 305).

Unadjusted gap. The company discloses the ESRS-defined figure while disputing it: "We believe that examining gender pay gaps on a purely total population basis without adequate detail and precision, as required by ESRS, does not offer a meaningful metric... We believe that the unadjusted gender pay gap ratio provides an inaccurate and overly simplistic representation of a complex measure. If all relevant factors are disregarded, the value for 2025 would be 18%, as calculated under ESRS. This figure for 2024 was 18%" (page 306).

The formula is stated: "(Average gross hourly pay for male employees - Average gross hourly pay for female employees) / (Average gross hourly pay for male employees) * 100" (page 305). The appendix lists the SFDR/Pillar 3 datapoints S1-16 97(a) unadjusted gender pay gap and 97(b) excessive CEO pay ratio (page 324).

Incidents, complaints and severe human rights impacts

Reference: page 308, with accounting policy on the same page.

A footnote to both 2025 figures states: "None of the matters were substantiated as discrimination, harassment, a severe human rights incident, or any other instance of unlawful conduct or activity."

Accounting policy (page 308). "We track workforce concerns, including equal employment opportunity matters and complaints or incidents related to discrimination and harassment. In 2025, 19 such matters were reported, including 6 complaints and 13 incidents of discrimination and/or harassment. None of the 19 matters were substantiated as discrimination, harassment, a severe human rights incident, or any other instance of unlawful conduct or activity. In 2024, 11 matters were reported, all relating to discrimination or harassment, and none were substantiated."

"The Company may become aware of workforce concerns from time to time, both internally and externally. We take these matters seriously. In line with our commitment to maintaining a safe workplace, respecting human rights, and providing equal treatment and equal employment opportunities, we take prompt and appropriate action when such concerns are raised" (page 308).

Reported matters rose from 11 to 19 year on year, with none substantiated in either year. The company does not disclose whether the increase reflects a change in reporting behaviour or in conduct. S1-17 is one of the metrics named as its means of tracking the effectiveness of due diligence actions (page 281).

Business conduct policies and corporate culture

Reference: pages 316-319 (corporate culture and whistleblower protection) and page 322 (animal welfare).

"Our policies define principles and guidelines for employees, partners, collaborators, and vendors, promoting an ethical culture that supports long-term success" (page 316).

Code of Business Conduct and Ethics (page 317). Purpose: "Defines the standards of behavior expected from all individuals and provides guidance for addressing compliance-related questions or situations." Scope: "All individuals conducting business on behalf of argenx." Accountable: General Counsel and Corporate Secretary. Externally available. Monitoring: "Live and transactional monitoring and tracking of training metrics by the Ethics and Compliance team." It applies across S1, S4 and G1.

Corporate culture (page 317). Built on "five Cultural Pillars - innovation, co-creation, empowerment, excellence, and humility" and three expectations: "Follow the rules", "Exercise good judgment", "Ask questions". Culture is promoted and evaluated "through training, internal communications, targeted awareness campaigns, and engagement initiatives such as Culture Lab sessions". In 2025 "we enhanced the Code of Business Conduct and Ethics training, along with other core curriculum". Annual training applies "to all employees and to our extended workforce, except managed service providers, who instead agree to comply with our Third Party Partner Code Of Conduct". Code of Conduct training completion was 96% in 2025, up from 92% (page 318).

Whistleblower protection (pages 318-319). The Speak Up & Anti-Retaliation Policy and the Global Anti-Bribery and Anti-Corruption Policy sit alongside the Code. The argenx Helpline "is externally managed to allow confidential and anonymous reporting". Retaliation "will result in disciplinary action, up to and including termination of employment, revocation of site access, or discontinuance of services".

Animal welfare (page 322). New as a material G1 risk in 2025. The Animal Welfare Policy defines "key principles of replacement, reduction and refinement (the '3Rs')", is "assigned as a read-and-acknowledge requirement for all employees", is accountable to the Head of Pharmtox, is externally available, and is monitored through "Accreditation requirements for CROs, collaborators and vendors and a due diligence process".

The appendix lists the SFDR datapoints G1-1 10(b) (UN Convention against Corruption) and 10(d) (protection of whistleblowers) (page 325). No separate policy on animal-testing alternatives beyond the 3Rs, and no policy on the protection of whistleblowers in the value chain, is quantified.

Management of relationships with suppliers

Reference: pages 320-321 (7.4.1.5).

Policies (page 320). The Code of Business Conduct and Ethics "establishes that third parties are selected based on clear and objective criteria such as quality, capability, reputation, past performance, and price", applied together with the Third Party Partner Code of Conduct, which "Outlines standards expected of third-party partners, including guidance around anti-bribery and anti-corruption". Scope: "All global third-party partners and those engaged by third parties on behalf of argenx." Accountable: General Counsel and Corporate Secretary. Externally available. Monitoring: "Reporting via the argenx Helpline."

Payment terms as part of supplier management (page 320). "The standard payment terms, which apply to all supplier categories, are 30-days in instances where other terms have not been contractually agreed upon. While we view payment practices as a fundamental component of vendor management, we do not currently maintain a formal payment practices policy or a separate policy for preventing late payments to small or medium-sized enterprises."

Actions (page 321). "Outsourcing and co-creation are key elements of our business strategy." The vendor qualification and due diligence process "assesses new suppliers for compliance with regulatory and company standards, including reference checks, screening, and where applicable review of the third-party's own Code of Conduct. Social due diligence includes verification of adherence to mandatory regulatory requirements such as worker rights. Environmental criteria are not currently used in supplier selection."

The Global Sourcing and Vendor Alliance Management team oversees Development suppliers. "We have established a working group focused on strengthening third-party risk-management, including early risk detection, compliance control, and process simplification", and risk management is integrated "through the supply chain maps process, which visualizes the VYVGART supply chain, logistics and quality-assurance requirements". Suppliers "undergo a qualification process, periodic audits, and performance reviews". Where problems are found, "corrective action plans are implemented and monitored. Persistent under-performance without resolution may result in termination of a supplier relationship."

No supplier audit count, no percentage of suppliers screened, and no social or environmental criteria weighting are disclosed under G1-2. A related quality metric appears under S4: 92% of planned product quality audits on vendors completed, 45 of 49 (page 314).

Prevention and detection of corruption and bribery

Reference: pages 319-320 (7.4.1.4), with training metrics on pages 318 and 320.

Policies (page 319). Anti-corruption and anti-bribery are addressed "through our Code of Business Conduct and Ethics, our Global Anti-Bribery and Anti-Corruption Policy and Speak Up & Anti-Retaliation Policy, our Third Party Partner Code of Conduct, and additionally communicated via the intranet and onboarding sessions for new joiners". "We have reviewed these policies against peer practices to ensure consistency with industry standards. Further analysis is ongoing to assess alignment with the UN Convention against Corruption and Bribery."

Actions (pages 319-320). "All employees and our extended workforce, excluding managed service providers, participate in annual training related to anti-corruption and anti-bribery through an e-learning module, which includes information on the process for reporting concerns. New members of the Board of Directors are walked through the Global Anti-Bribery and Anti-Corruption Policy and the Code of Business Conduct and Ethics as part of their onboarding."

Separation of investigation from management. The Ethics and Compliance function "oversees the argenx Helpline, which serves as the central reporting channel for managing and triaging cases", transitioned to a new system in 2025 "and enhanced... through integration with other argenx systems to improve reporting efficiency". E&C "is responsible for managing compliance investigations and consults with additional stakeholders, including Legal and HR, where necessary". Investigations follow "the Ethics & Compliance Global Investigations Procedure", are "conducted by qualified personnel", and are "tracked from intake to remediation and documented in a Compliance Investigation Report". "Reports are shared regularly with the GCC and the Audit and Compliance Committee." Anonymity "will be protected to the fullest extent possible, unless disclosure is required by law".

E&C also conducts "live monitoring of speaker events and advisory boards", plus "Transaction monitoring... of sponsorships, donations, grants, donations, speaker programs, fee-for-service engagements and meals" (pages 319-320).

Metrics (pages 318, 320). Anti-Bribery Policy training completion 95% in 2025, up from 89%; Code of Business Conduct and Ethics training completion 96%, up from 92%. "Finance, HR, Procurement, Sales and Marketing and Supply Chain Management are considered to be functions at-risk... 100% of these functions-at-risk are covered by the anti-bribery and corruption training programs." Training figures "include employees, contractors and extended workforce, excluding managed service providers" (page 320).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS, so the FY2025 statement, prepared under the 2023 ESRS, has no section carrying that number.

argenx discloses no quantitative business conduct targets. The single MDR-T statement in the G1 chapter reads:

"We currently apply a qualitative approach to management of suppliers and have not yet established formal quantitative targets." (page 321, headed "Targets", tagged G1-6 MDR-T)

Consistent with MDR-T's other limb, effectiveness is tracked through metrics rather than against targets. The governance chapter's due-diligence mapping names G1-3, G1-4 and G1-6 among the means of "Tracking the effectiveness of actions" (page 281), and the chapter reports:

• Code of Business Conduct and Ethics training completion: 96% in 2025, 92% in 2024 (page 318).
• Anti-Bribery Policy training completion: 95% in 2025, 89% in 2024 (page 318).
• 100% of functions at-risk - Finance, HR, Procurement, Sales and Marketing, Supply Chain Management - "are covered by the anti-bribery and corruption training programs" (page 320).
• Convictions and fines for anti-corruption and anti-bribery violations: nil in both years (page 320).
• Payment practices: standard terms 30 days, average time to pay 35 days, 76% of invoices paid within standard terms, nil legal proceedings for late payments (page 322).

Ongoing monitoring is described rather than targeted: "Further analysis is ongoing to assess alignment with the UN Convention against Corruption and Bribery" (page 319), E&C performs "periodic monitoring which includes live monitoring of speaker events and advisory boards" (page 319), and supplier "governance structure is continuously evaluated" (page 321). No target is set for training completion, for closing the 24% of invoices paid late, or for animal welfare, which was added as a material G1 risk in 2025 (page 286).

Incidents of corruption or bribery

Reference: page 320, with accounting policy on the same page.

A nil return in both years.

Accounting policy (page 320). "Number of convictions is tracked through the argenx Helpline. Fines for violations are tracked through the argenx Helpline system, Legal team and outside counsel. Investigations are tracked in accordance with our Speak Up & Anti-Retaliation Policy and value chain violations are tracked through the argenx Helpline."

The tracking apparatus behind the figure is described under G1-3: the Helpline "serves as the central reporting channel for managing and triaging cases" and was "transitioned to a new system and enhanced in 2025 through integration with other argenx systems"; investigations are "tracked from intake to remediation and documented in a Compliance Investigation Report"; and "Reports are shared regularly with the GCC and the Audit and Compliance Committee" (pages 319-320).

Not disclosed: the number of confirmed incidents of corruption or bribery, the number of confirmed incidents in which own workers were dismissed or disciplined, the number of confirmed incidents relating to contracts with business partners, and details of public legal cases. The appendix lists the SFDR datapoints G1-4 24(a) (fines for violation of anti-corruption and anti-bribery laws) and 24(b) (standards of anti-corruption and anti-bribery) (page 325). The related S1 figure shows 19 workforce matters reported in 2025 with none substantiated (page 308).

Payment practices

Reference: pages 321-322, with accounting policy on page 322.

Process (page 321). "We follow standardized procure-to-pay processes to prevent late payments. Payment runs are conducted according to a standard payment cycle determined by country of jurisdiction. Weekly payment runs were conducted for all European and US entities, while in Japan, all duly approved invoices were paid once a month."

Average payment time slipped from 30 to 35 days, five days beyond the standard terms, while the share of invoices paid within terms held flat at 76%. No legal proceedings for late payment are outstanding.

Accounting policy (page 322). "Our payment practices, including average payment time compared to standard payment terms, were calculated using data extracted from our payment system software. The analysis covered all invoices paid to registered vendors and excluded payments to employees and intercompany payments. Standard payment terms are 30-days, unless alternative terms are contractually agreed. The average payment time was determined by dividing the total number of calendar days between invoice date and payment date by the total number of paid invoices, calculated for each business unit, region, and the entire group."

The company states it has no formal policy behind the practice: "we do not currently maintain a formal payment practices policy or a separate policy for preventing late payments to small or medium-sized enterprises, instead our standard payment terms and contractual agreements are applied to all suppliers, including small or medium-sized enterprises" (page 320). Payment practices sit inside a material G1 IRO: "Poor supplier and partner relationship management, e.g., delayed payments to CMOs or CROs, may disrupt clinical progress and access to life-changing therapies potentially impacting patient health and wellbeing" (page 316). Standard terms are not broken down by supplier category, and no SME-specific figure is given.