Arkema S.A.

Reference: pages 164-165

Arkema's CSR governance sits inside the Group's corporate governance. The CSR ambition, main challenges, impacts, risks and opportunities, related initiatives, metrics and sustainable development targets are defined and validated by the Executive Committee, presented once a year by the Director of Sustainable Development to the Audit and Accounts Committee and the Innovation and Sustainable Growth Committee, then to the Board of Directors, "46% of whose members have CSR expertise" (page 164). The Audit and Accounts Committee monitors the preparation of sustainability information, monitors the statutory auditors certifying sustainability disclosures, monitors internal control over sustainability information and "approves the double materiality assessment process". The Innovation and Sustainable Growth Committee assesses how innovation and strategy contribute to footprint reduction, climate protection and circular economy. CSR commitment is led by the Chairman and CEO and the Executive Committee; the Sustainable Development department reports to the Executive Vice-President, Industry and CSR. Three steering committees (Product Stewardship, Industrial Ecology, CSR), each chaired by the Industry and CSR EVP, meet twice a year, supported by a network of some 50 CSR leaders (pages 164-165). Board composition and director skills are incorporated by reference to section 3.2.1 (page 163).

Reference: pages 164-165

Governance bodies are informed through a defined annual cycle. The Executive Committee meets at least once a year to review progress of policies and validate the guidelines and priorities of the three steering committees; each steering committee meets twice a year (page 165). On climate: "The climate plan, monitoring metrics and targets, including those filed with the SBTi, are defined by the Executive Committee and presented at least once a year to the Board of Directors by the Sustainable Development Vice-President. The Executive Committee is informed of the evolution of GHG emissions on a quarterly basis" (page 165). In 2025 the climate plan, SBTi-validated objectives and trajectory progress were presented to shareholders at the annual general meeting of 22 May. On business conduct, the Group General Counsel and the Group Compliance Officer meet quarterly with the Chairman and CEO and the Executive Committee, and the Legal Affairs Vice-President reports annually to the Audit and Accounts Committee and periodically to the Board (page 165). The HSSEQ policy and key indicators go to the Board each year; a full review of environmental risks goes annually to the Audit and Accounts Committee, and the Group Safety and Environment Vice-President submits a quarterly report on environmental targets and outcomes to the Executive Committee (page 176).

Reference: page 165

"Sustainability results are integrated into the compensation of the Chairman and Chief Executive Officer, Comex members, senior executives and certain employees through criteria linked to the Group's CSR performance" (page 165). Quantified CSR criteria sit in the qualitative portion of the Chairman and CEO's annual variable compensation, "This portion accounts for up to 25% of the variable compensation". The annual performance share plan, allocated to around 1,800 Group employees including executives, "also include a composite CSR criterion accounting for 30% of the final allocation". Specific criteria are incorporated by reference to section 3.4.2.1 of the Universal Registration Document, and the description of the level at which incentive-scheme terms are approved and updated (GOV-3 29 e) is also incorporated by reference to section 3.4.2.1 (page 163). Two linked examples appear elsewhere in the statement: each business manager is assigned an annual environmental target that "is a criterion for their annual performance review and compensation" (page 176), and annual monitoring of the proportion of women in senior management and executive positions "is now included in the collective objectives used for calculating variable compensation" (page 228).

Reference: page 166

Arkema presents its due diligence statement as a five-row mapping table of "Core elements of due diligence" against the sections of the Sustainability Report (page 166): embedding due diligence in governance, strategy and the business model maps to 4.2.1.3 (GOV-2, GOV-3) and 4.2.1.5.2 (SBM-3); engagement with affected stakeholders at all key steps maps to 4.2.1.4.2 (SBM-2), 4.2.1.5.1 (IRO-1), 4.2.3.1.2 (S1-2), 4.2.3.2 (S2) and 4.2.4.4 (G1); identifying and assessing adverse impacts maps to section 4.2.1.5 (IRO-1) including the IRO summary (SBM-3), "supported by all the studies carried out by the Group's various departments"; taking action maps to 4.2.2 for the environment, 4.2.3 and 4.2.4 for people and 4.2.4.2 for anti-corruption, "see MDR-A for each ESRS topic"; and tracking effectiveness maps to 4.2.2, 4.2.3 and 4.2.4, "see MDR-M and MDR-T for each ESRS topic". The GOV-4 paragraph 30 datapoint is cross-referenced to this section in the Appendix B datapoint table (page 246). Due diligence is also run through the French duty of care plan in section 4.3 (page 175).

Reference: page 166

"In 2024, an assessment of the risks associated with the production of sustainability information was carried out in order to identify priority reporting processes for the formal implementation of the controls required for data reliability" (page 166). The Group has common reporting protocols and methodologies: data are entered by local teams, approved at various levels of responsibility, then consolidated by central teams who carry out consistency checks. Most data are reported annually; for certain issues interim data are reported quarterly to identify trends and trigger corrective measures, and "The interim data are not disclosed". Three named systems carry the quantitative data: environmental and energy data in REED, governed by Environmental, EFPI and Energy Reporting directives and validated at geographic and corporate level; safety data in ATLAS, entered and approved by sites then consolidated at Group level under a Monthly Safety reporting directive; workforce data in the HRIS, with other employee information recorded in AREA 2, approved by zone HR directors or subsidiary directors and consolidated at Group level. "Arkema has included sustainability reporting controls in its global internal control process, as presented in section 2.2 of this document. This new system will be gradually applied to all sites that are representative of the Group's environmental, social and societal data" (page 166).

Reference: pages 167-168

Arkema seeks a leadership position in specialty materials, organised in three segments: Advanced Materials, Adhesive Solutions and Coating Solutions, serving general industry, transportation and energy, consumer goods and electronics, building and construction, and health, water and nutrition (page 167). "The sales figure 2025 for all the Group's activities ... correspond to the ESRS 'Chemicals' sector, and more specifically to the 'production of chemical products activity' as defined in Appendix I, Division 20.2, of Regulation (EC) no. 1893/2006" (page 167). Five key high-growth markets driven by sustainability megatrends are named: green energy and electric mobility, advanced electronics, sustainable lifestyle and goods, efficient buildings and homes, and health and well-being. Workforce at 31 December 2025 was 20,704 (21,164 in 2024): France 7,058, Europe excluding France 3,833, North America 4,034, Asia 4,653, rest of world 1,126 (page 167). The value chain is scoped as "upstream of its operations: tier-one subcontractors and suppliers; and downstream of its operations: the delivery of products and services to customers", with a diagram showing the value chain and the associated material ESRS topics (page 168). Strategy, business model and value chain information is partly incorporated by reference to the Profile and Business model sections of the introductory chapter (page 163).

Reference: pages 169-170

Arkema tabulates dialogue with eight stakeholder groups, giving for each the context and purpose of dialogue, the key sustainability expectations the Group has identified, and the form of dialogue (pages 169-170). Customers: circular economy, climate change, pollution including SVHCs, ethics, addressed through global key-account management, joint innovation programmes including life-cycle assessment and a global online satisfaction survey. Suppliers: responsible procurement and climate change, through CSR performance assessments and engagement of the suppliers contributing most to raw-material purchase emissions. Research partners, and the financial community, shareholders and SRI rating agencies, through results presentations, investor days, rating-agency discussions and the annual general meeting. Group headcount and representative bodies: health and safety, attracting talent, diversity, pollution, climate change, responsible procurement, through social dialogue "that goes beyond legal requirements" and internal surveys. Neighbouring communities: water withdrawals, pollution, circular economy, through the Common Ground initiative at each site. Civil society and NGOs, including "discussions in relation to the double materiality assessment". Public authorities and professional associations.

Reference: pages 173-175

The material IRO register is a 30-row table giving, for each IRO, the material ESRS topic, the wording of the impact, risk or opportunity, the ESRS and URD section, the value chain position (upstream, own operations, downstream) and the time horizon (short, medium, long). Eight topic headings are used: Climate change including energy (ESRS E1, 4 rows), Pollution (ESRS E2, 7 rows), Water withdrawals (ESRS E3, 3 rows), Circular economy (ESRS E5, 5 rows), Employees (ESRS S1, 3 rows), Employees - health and safety (ESRS S1, 2 rows), Responsible procurement (ESRS G1 and ESRS S2, 4 rows) and Business conduct (ESRS G1, 2 rows). Eight of the 30 rows are tagged to more than one standard; ESRS E4 appears only as a co-tagged standard, never as a heading. Examples: "Negative impacts relating to greenhouse gas emissions from the Group's industrial processes and its upstream and downstream value chain" (E1 and E4, all three value chain positions, S/M/L); "Potential negative impacts related to exposure to hazardous materials or substances of concern used in chemical processes" (E2, S1 and S2); "In areas subject to water stress, the risk of restrictions on water withdrawals may result in operational disruptions" (E3, own operations). On embedding: "The results of the double materiality assessment confirmed the relevance of Arkema's CSR policy, structured around its three commitments", which "is fully integrated into the Group strategy" (page 175).

Reference: pages 171-172

"In 2025, Arkema strengthened its double materiality assessment procedure, led by the Sustainable Development department", supported by "a new dedicated tool for tracking changes in the assessment over time and documenting the process", systematically linked to the Group's other risk assessments and approved by a named steering committee of eleven functions including the EVP Strategy, the Internal Audit and Internal Control VP, the Group Compliance Officer and the Duty of Care Officer (page 171). Three phases are described: preliminary analyses drawing on GRI and SASB, the ESRS 1 AR 16 topic list, sector studies and existing internal assessments including climate risk analyses "based on the IPCC RCP 2.6 and RCP 8.5 scenarios, for the period 2021-2050", water stress analyses, the 2023 biodiversity materiality assessment, AIMS audit results and Sapin II corruption risk assessments; IRO definition and assessment in expert workshops, rated on ESRS 1 criteria (scale, scope, irremediable character and likelihood for impacts; gross potential financial scale and likelihood for risks and opportunities); and approval by the steering committee, the CSR Steering Committee, the Audit and Accounts Committee and the Group Risk Review Committee (pages 171-172).

Reference: pages 243-251

Arkema publishes a full ESRS content index in appendix 4.2.5.1, "List of disclosure requirements in ESRS covered by the undertaking's sustainability statements", split into General, Environmental, Social and Business Conduct blocks, each row giving the disclosure requirement and the chapter reference (pages 243-245). The general block lists BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3, IRO-1 and IRO-2. The environmental block lists E1-1 to E1-6 and E1-8, E2-1 to E2-5, E3-1 to E3-4, E4-2 to E4-4 and E5-1 to E5-5, each with the topic-level ESRS 2 GOV-3, SBM-3 and IRO-1 entries. The social block lists S1-1 to S1-6, S1-8 to S1-12, S1-14, S1-16, S1-17, and S2-1, S2-3 and S2-4. The business conduct block lists G1-1, G1-2, G1-3 and G1-5. E1-7, E1-9, E2-6, E3-5, E4-1, E4-5, E4-6, E5-6, S1-7, S1-13, S1-15, S2-2, S2-5, G1-4, G1-6 and all of S3 and S4 are absent from it. A second table (pages 246-251) lists the datapoints derived from other EU legislation with their SFDR, Pillar 3, Benchmark Regulation and EU Climate Law references, marking those Arkema treats as non-material, including the E1-7, E1-9, E3-1 sustainable oceans, E3-4 water consumption per revenue, E4-2 sustainable oceans, S3-1, S3-4, S4-1, S4-4 and G1-4 entries.

Reference: pages 180-186

"The Group's climate plan aligned with the Paris Agreement consists of ambitious targets for 2030 based on a 1.5C trajectory approved by the Science Based Targets initiative (SBTi) ... These targets pave the way for an ambition to reach Net-Zero by 2050", the SBTi Net-Zero criterion being "at least 90% reduction on Scopes 1 + 2 and Scope 3 compared with the baseline year", with 2019 as baseline (page 180). Scopes 1 and 2 decarbonisation rests on three quantified levers: optimising and modifying production processes, around 25% of the reduction needed; energy efficiency through the Arkema Energy program, around 25%; and low carbon energy, around 50% (page 181). "The Group has not identified any locked-in emissions that would prevent it from meeting its 2030 targets ... In 2025, the Group began identifying equipment associated with locked-in emissions" (page 181). Scope 3 levers split around 15% upstream and around 85% downstream (page 184). The plan "is supported by an envelope of investments ... which could reach a cumulative amount of 400 million euros over the 2022-2030 period, included in the recurring capital expenditure envelope", of which "around 190 million euros ... have already been made or are underway" (page 184). Each Business Line has its own decarbonisation plan and trajectory (page 181).

Identification of climate-related risks and scenario analysis

Back-filled from section 4.2.2.1.2 and ESRS 2 IRO-1 (pages 171, 178-179). This DR did not exist under the 2023 ESRS.

Classification (paragraph 15). "Arkema has identified two types of material risks related to climate change: physical risks related to extreme or chronic climate events that could cause significant damage to Group sites or to its upstream and downstream value chain; and transition risks related to regulatory and end-market evolution, the inaccessibility of energy resources and rising energy costs" (p.178).

Physical risk. A 2022-2024 study assessed six climate indicators for 165 production sites and logistics facilities. In 2025 Arkema subscribed to Swiss Re's RDS platform, which "presents climate risk scores covering nine different perils ... for three possible scenarios (SSP1-2.6, SSP2-4.5 and SSP5-8.5) and seven time horizons (current, every 10 years from 2030 to 2080)" (pages 178-179). The DMA also used "the IPCC RCP 2.6 and RCP 8.5 scenarios, for the period 2021-2050" (page 171).

Transition risk. A 2023 pilot on one activity mapped transition risks "based in particular on the Net Zero by 2050 scenario of the International Energy Agency (IEA)". "In 2025, the study of exposure to regulatory carbon pricing was extended to the entire Group" (page 179).

Gap. No temperature projection is stated per scenario and no quantified outcome is given.

Resilience in relation to climate change

Back-filled from "Business model resilience" (page 179) and section 4.2.2.1.5 (pages 185-186). This DR did not exist under the 2023 ESRS.

Results. "Issues linked to climate change, in terms of both risks and opportunities, form one of the major pillars of the Group's CSR roadmap. These issues are fully integrated into Arkema's strategy and help increase the resilience of its business model" (page 179). Four levers are named: prioritising key markets linked to decarbonisation megatrends; developing low-carbon solutions; "ensuring a secure supply of low-carbon energy through long-term contractual instruments"; and "implementing measures to prevent physical climate risks and ensure business continuity".

Capacity to adapt. Adaptation aims "to reduce the vulnerability of its assets and operations to the current and expected effects of climate change", through adapting existing facilities and crisis management systems and designing new facilities for projected extreme events (page 185). Where at least one hazard worsens on SSP5-8.5 in 2030 and 2050, a criticality analysis and site vulnerability study establish "the need to draw up an adaptation plan" (page 186).

Uncertainty. "For most of the sites, there are alternative production arrangements within the Group ... Some, however, are the only production sites for the products in question" (page 185). No quantified resilience analysis is presented.

Reference: page 179

"Arkema includes climate in its HSSEQ policy. The Group's approach focuses on two main areas: firstly, mitigation, by reducing its GHG emissions and developing solutions with a lower carbon footprint, and secondly, adapting its operations and value chain to physical risks and regulatory changes" (page 179). Alongside it sits an energy policy: "Arkema has also focused on improving its energy efficiency through its energy policy, which is fully in line with the Group's drive for operational excellence and highlights the imperatives for energy sobriety to be implemented in all the Group's activities worldwide". Implementation is governed by the Climate Committee, which "meets on a quarterly basis ... coordinated by the Sustainable Development department and comprises Group Process and Energy Procurement Vice-Presidents, industrial Vice-Presidents of various business lines and regional CSR managers. It notably leads programs to decarbonize the Group's industrial activities, and monitors progress". The parent HSSEQ policy, published on arkema.com, covers "climate, the circular economy and reduction of the Group's environmental footprint" and is set out in the Health, Safety, Security, Environment and Quality Manual underpinning the Arkema Integrated Management System (page 175). Climate plan governance is anchored at Board level through the Audit and Accounts Committee and the Innovation and Sustainable Growth Committee (page 165).

Reference: pages 180-186

Mitigation actions are named industrial projects with investment amounts and expected effects (page 183): new patented purification technology at Carling in France from 2026, "This 130 million euro investment, partly funded by the French government under the France 2030 program ... will improve the site's operational efficiency and reduce its CO2 emissions by 20%"; a sulfur-based effluent treatment unit at Lacq completed in 2025, "reducing SO2 emissions by 40% and GHG emissions by more than 10%", a 40 million euro investment; an electric boiler instead of a natural gas boiler at the new DMDS unit in Beaumont, United States, started up in 2025; and replacement of the Liquid Thermal Oxidizer at Taixing in China. Low-carbon energy actions include an ENGIE agreement for 25 GWh/year of biomethane to Bostik sites in France from 2025, following a 300 GWh/year contract signed in 2023; contracts covering "More than 70% of the electricity needs of Group sites in the United States"; two Chinese agreements cutting Scope 2 there "by around 75,000 tonnes of CO2 equivalent"; a 20-year EDF Renewables contract under which "As of 2026, 70% of the electricity consumption at eight Bostik sites in France will come from solar energy"; and a solid recovered fuel boiler at Lannemezan, operational in 2026 (pages 183-184). The Arkema Energy program carries "an annual capital expenditure budget of 8 million euros", funding 50 capital projects in 2025 (page 182).

Reference: pages 180-181

Three quantified targets are disclosed. Validated by the SBTi against a 2019 baseline: "48.5% reduction in Scopes 1 + 2 Kyoto Protocol greenhouse gas emissions compared with 2019" and "54% reduction in Scope 3 ... compared with 2019", both on an "Absolute emissions contraction approach" (page 180). "After exceeding its SBTi-approved Scope 3 emissions target in 2024, the Group has set a new, more ambitious target of a 67% reduction in Scope 3 greenhouse gas emissions by 2030 with respect to 2019", equivalent to 50 Mt CO2e (pages 180, 187). A third target: "25% reduction in net energy purchases in EFPI terms compared with 2012" by 2030. Progress in 2025: "In 2025, absolute Scopes 1 + 2 GHG emissions were down 48.7% on 2019 levels", attributed to "a reduction of activity in 2025 and the continuation of initiatives under the Group's climate plan", with the candid rider that "Achieving the SBTi target of a 48.5% reduction by 2030 is therefore partly due to the difficult economic context" (page 181). Scope 3 at constant scope was "5% lower than in 2024 and 64% lower than in the 2019 baseline year". The energy performance indicator stood at 0.88 against a 1.00 base in 2012 and a 0.75 target, "stable as a result of a deterioration linked to a drop in production level, offset by ongoing energy optimization measures" (page 181).

Reference: pages 188-189

Net energy purchases fell to 6.53 TWh in 2025, from 6.90 TWh in 2024 and 6.68 TWh in 2023, "as a result of lower production volumes" (page 188). The energy mix table (page 189) reports total energy consumption related to own operations of 6,530,000 MWh (6,900,000 MWh in 2024), of which fossil sources 4,550,000 MWh or 70% (4,860,000 MWh, 70%), comprising coal 0, crude oil fuel 70,000 MWh, natural gas 3,190,000 MWh and purchased electricity, heat, steam or cooling from fossil sources 1,290,000 MWh; nuclear 780,000 MWh or 12% (932,000 MWh, 14%); and renewable 1,200,000 MWh or 18% (1,108,000 MWh, 16%), of which renewable fuel including biomass 250,000 MWh and purchased renewable electricity, heat, steam and cooling 950,000 MWh. The whole 6,530,000 MWh falls in high climate impact sectors, with the footnote "All the Group's activities are carried out in high climate impact sectors (ESRS E1 42, 43 AR38)". Energy intensity was 0.72 MWh per thousand euros of net revenue, unchanged. Low-carbon energy was 30% of consumption; renewable electricity rose to 42% of total electricity from 32% in 2024 and 27% in 2023, and low-carbon electricity to 78% from 72% and 62%. Declared consumption "corresponds to energy purchases less sales to third parties (representing 6.4% of total energy consumption relating to own operations in 2025)".

Reference: page 187

Gross Scope 1 emissions were 1,261,000 t CO2e in 2025, down 7% on 2024 and from 2,601,000 t in the 2019 baseline, with 21% covered by a regulated emission trading scheme. Gross location-based Scope 2 was 950,000 t CO2e and gross market-based Scope 2 641,000 t CO2e, down 19%, with 30% of Scope 2 covered by contractual instruments. Total market-based Scopes 1 + 2 were 1,902,000 t CO2e, against 2,145,000 t in 2024 and 3,704,000 t in 2019, a 48.7% reduction on baseline. Scope 3 totalled 54,602,000 t CO2e, down 5% and 64% below the 152,400,000 t 2019 baseline, across nine material categories: purchased goods and services 8,650,000 t, capital goods 175,000 t, fuel and energy-related activities 552,000 t, upstream transportation and distribution 229,000 t, waste generated in operations 726,000 t, downstream transportation and distribution 271,000 t, processing of sold products 2,951,000 t, use of sold products 17,448,000 t and end-of-life treatment of sold products 23,506,000 t. Categories 6, 7, 8 and 15 are non-material and categories 13 and 14 "Not relevant". Total market-based GHG emissions were 56,504,000 t CO2e, down 6%, with market-based intensity of 6,231 t CO2e per million euros of net revenue. Out-of-scope emissions are reported separately: carbon uptake of bio-sourced energy -102,000 t, biogenic CO2 in Scope 1 85,000 t, carbon uptake from bio-based raw materials -139,000 t and biogenic CO2 in category 12 101,000 t (page 188).

Reference: page 190

"To enhance its long-term approach, the Group set an internal price for Scopes 1 and 2 GHG emissions, expressed in terms of CO2 equivalent, known as 'internal carbon price', which corresponds to a shadow price. It is used to analyze strategic industrial investments, for the whole Group, and to steer investment decisions under the operational excellence program towards the lowest carbon solutions" (page 190). The price is applied "to compare scenarios using different processes to determine their impact on product cost", and also serves "to enhance employee awareness, drive behavioral changes, promote energy efficiency, and identify and seize low-carbon opportunities". On governance and level: "The Executive Committee reviews the use of the internal carbon price, checks its relevance and, if necessary, adjusts the value. The price is currently set at 100 euros per tonne of CO2, in line with the European carbon market price" (page 190). The same price carries into the financial statements: capital expenditure decisions "factor in an internal carbon price which is validated by the Group Executive Committee and is in line with the assumptions used in impairment testing" (note 5 Climate issues, page 322). The disclosure does not state the share of emissions or of investment decisions covered by the shadow price.

Reference: pages 191, 175, 196

Pollution is governed by the HSSEQ policy, which "covers notably the management of hazardous substances, the prevention of industrial accidents, preparation of crisis management and reduction of the environmental footprint" (page 191). The policy is published on arkema.com, rests on three principles (industrial risk prevention, an integrated management system, and development of an HSSEQ culture) and is set out in the worldwide Health, Safety, Security, Environment and Quality Manual underpinning the Arkema Integrated Management System (page 175). A separate water policy commits the Group "to reduce its emissions into water, in particular chemical oxygen demand (COD), suspended solids, substances of concern and microplastics" (page 193). Product stewardship forms the substances limb: health, safety and environmental protection are taken into account "from the design stage of its products and throughout their entire life cycle", through contributing to scientific knowledge, designing products that reduce risk, risk management of existing ranges "which may lead to substitution", and clear communication to users (page 196). Improvements to production units are framed as opportunities to reduce COD, VOCs, SO2, NOx, particulates, odour and noise, and to continue soil remediation (page 191).

Reference: pages 191-197

"Arkema makes specific investments to prevent, reduce or control incidents or accidents that could impact the environment. In 2025, these specific investments totaled 104 million euros", and environmental protection operating expenses, covering external waste and water treatment and HSE personnel costs, "totaled 135 million euros" (pages 191-192). Air actions (page 192): gas vent collection, best available techniques for reducing the pollutant load of residual gases (absorption, adsorption, thermal or catalytic oxidation, selective catalytic reduction, cyclones, filters), continuous monitoring, maintenance of critical equipment, leak detection and repair campaigns, low or ultra-low sulfur fuels, and low-NOx burners. Water actions run through the Optim'O program, initiated in 2016, which optimises water use and treatment, ensures compliance with the Common Waste Water BREF and implements pretreatment of process effluent; sites contributing significantly to COD, suspended solids and water volume "are identified and submitted for monitoring through a specific audit program" (page 193). Legacy pollution is managed with prevention policies, mechanical integrity programmes, traceability and incident reporting, with provisions cross-referenced to note 11.1.2 (page 194). Microplastic actions include membership of Operation Clean Sweep and triennial certification of the French sites concerned under decree no. 2021-461 (page 195).

Reference: pages 191-196

Three quantified pollution targets are disclosed, all for 2030. On air: "65% reduction in VOC emissions in EFPI terms compared with 2012"; VOC EFPI stood at 0.44 in 2025 against 0.46 in 2024, 0.49 in 2023, a 1.00 base in 2012 and a 0.35 target, and "VOC EFPI remains on track to achieve its 2030 target thanks to the actions carried out" (page 192). On water: "70% reduction in COD emissions in EFPI terms compared with 2012"; COD EFPI was 0.34 in 2025 against 0.31 in 2024, 0.38 in 2023 and a 0.30 target (page 193). On process safety: "Achieve a process safety event rate (PSER) of 2.0"; PSER improved to 2.1 in 2025 from 2.5 in 2024 and 2.8 in 2023 (page 195). Both intensity indicators are computed on the Group's biggest emitters, "which account for more than 80% of the consolidated total" (pages 192-193). The targets are repeated in the Group-level commitments table (page 153) and in the E2 IRO summary table (page 191), where they are tied to the HSSEQ policy and to actions in sections 4.2.2.2.3 to 4.2.2.2.10. No target is set for substances of concern or substances of very high concern tonnages, for microplastics, or for the E-PRTR pollutant amounts; the only substance-related commitment is the Archimedes substitution work on "challenge" solutions (page 198).

Reference: pages 192-195, 254

Emissions to air, total Group scope (page 193): total acidifying substances 2,190 t SO2e (2,150 in 2024; 2,320 in 2023), of which SOx 1,270 t and NOx 840 t; volatile organic compounds 2,160 t (2,281; 2,520), "down due to a drop in activity and to investments in improvements, such as the installation of new equipment at the Mont site (France)"; dust 110 t (122; 112). Emissions to water (page 194): chemical oxygen demand 1,250 t O2 (1,256; 1,366) and suspended solids 390 t (421; 429). The ESRS datapoint is given in the indicators appendix, "limited to facilities exceeding the thresholds specified in Annex II of Regulation (EC) no. 166/2006 ... (E-PRTR)", listing for 2025 to air ammonia 170 t, NMVOCs 840 t, NOx as NO2 102 t, SOx as SO2 1,020 t, HCFCs 57 t, CFCs 0.16 t, halons 0.14 t, HFCs 52 t, 1,2-dichloroethane 0.00 t, dichloromethane 5.2 t, tetrachloromethane 1.65 t, 1,1,1-trichloroethane 10.30 t, trichloromethane 1.60 t, vinyl chloride 2.00 t, benzene 8.50 t, chlorine and inorganic compounds as HCl 17 t, hydrocyanic acid 2.10 t; and to water total nitrogen 0 t and total phosphorus 27 t (page 254). Microplastics are the partially disclosed limb: quantities associated with products manufactured in Europe excluding Adhesives were 66,525 t in 2025, a scope representing 26% of Group sales, with reporting for Adhesives and for raw materials "introduced in the medium term" (pages 163, 194).

Reference: pages 197-199, 163

SVHCs contained in products placed on the market (page 198): subject to REACH authorisation 9 substances, 2,829 t (2024: 11, 4,641 t); on the REACH candidate list 49 substances, 13,440 t (53, 14,032 t), including CMR category 1A/B 22 substances, 8,331 t, PBT or vPvB 9 substances, 2,117 t, and substances of equivalent concern 18 substances, 2,992 t. Of these, from raw materials used to manufacture products: authorisation 9 substances, 2,829 t; candidate list 44 substances, 5,217 t. New for 2025, SVHCs from purchased raw materials: authorisation 12 substances, 3,001 t; candidate list 60 substances, 16,832 t. The analysis covers 94% of Group sales, and "Products containing these substances ... accounted for 5.1% of sales in 2025, compared to 3.8% in 2024". Substances of concern in products placed on the market total 593,526 t, by Annex VI hazard class: carcinogenicity 44,659 t, germ cell mutagenicity 7,708 t, reproductive toxicity 20,136 t, respiratory sensitisers 4,431 t, skin sensitisers 417,791 t, chronic aquatic toxicity 187,013 t, dangerous for the ozone layer 0, target organ toxicity repeated exposure 27,668 t and single exposure 47,903 t (page 199). The outflow limb of paragraph 34 is only partly answered: "In 2025, a process was set up to collect annual industrial emissions of SVHC in Europe ... to ensure reliable reporting from 2026 onward", and SoC amounts in raw materials used "will be introduced in the medium term" (pages 163, 199).

Reference: page 200

"Water is used in the Group's manufacturing processes to cool production installations and generate steam. Arkema is convinced of the importance of responsible water management. In its water policy, it commits to reducing its water withdrawals and to adopting a sustainable water management policy across all its sites located in water-stressed areas. This worldwide policy also commits the Group to reducing its water discharges and to developing innovative solutions for sustainable use of water by its customers" (page 200). Governance is explicit: "The results and targets are set periodically by a steering committee chaired by the Executive Vice-President, Industry and CSR". Reporting coverage is stated alongside the policy: "Arkema's industrial sites that report their water withdrawals on a monthly basis account for 96% of the Group's water withdrawals. A map of the various water inflows and outflows is drawn up for each industrial site." The water policy also carries the commitments to reduce emissions into water and discharges of microplastics that are described under ESRS E2 (pages 193, 195). The Appendix B datapoint table references the E3-1 water and marine resources datapoint (paragraph 9) and the dedicated policy datapoint (paragraph 13) to this section, while marking the sustainable oceans and seas datapoint (paragraph 14) non-material (page 248).

Reference: pages 200-201

Actions run through the Optim'O program, "based on an analysis of the risks from water stress and other natural hazards resulting from climate change" (page 200). Prioritisation is quantified: "based on projections to 2030 made using the World Resources Institute's Aqueduct tool, on the analysis of the manufacturing process's dependency on water, on the analysis of the existence of alternative production sites in lower risk areas and on an analysis of the volumes of water withdrawn and the production volumes, Arkema has identified that 21 sites representing 10% of water withdrawals and 13% of production volume, warranted high or very high priority water management for 2030". Two further findings shape the programme: "90% of water withdrawn from the natural environment is returned as surface water" and "96% of Group water withdrawals are attributable to just 30 industrial sites, two of which are classified as high or very high priority for water management". Named initiatives are "the implementation of closed loops, improved monitoring of usage, the installation of flow meters, the implementation of leak detection programs, changing technologies, upgrading fire-fighting systems, recovering rainwater and recycling water from scrubbing or vapor condensates", with additional funding from the Optim'O budget or externally, "for example by French local water authorities".

Reference: page 200

One quantified target is disclosed: "Reducing water withdrawals to 76 million cu.m." by 2030, measured on net withdrawals excluding sales to third parties (page 200). Performance against it: 109 million cu.m in 2019, 86 in 2023, 82 in 2024 and 79 in 2025. The company reports that the previous target has already been met and reset: "By the end of 2025, the Group had reached its 2030 target, and has set itself a new, more ambitious target: it was established based on the level of water consumption in 2024, the impact of projects and changes in the scope of consolidation, and projected site activity between now and 2030" (page 200). The 2025 movement is attributed to a mix of action and lower activity: "In 2025, water withdrawals fell by 3 million cu.m., reflecting efforts to reduce consumption and the decline in activity at certain industrial sites, as well as the acquisition of new sites." The target is also carried in the Group commitments table under "Act as a responsible manufacturer" (page 153) and in the E3, E4 and climate IRO summary tables (pages 200-201). No separate target is set for water discharges, for water recycling and reuse, or for the 21 priority water-management sites.

Reference: pages 200-201

Net water withdrawals, the Group's headline metric, were 79 million cu.m in 2025 against 82 in 2024, 86 in 2023 and 109 in 2019 (page 200). The monitoring indicator table (page 201) adds gross water withdrawals by source, including resales to third parties: mains water 20,200,000 cu.m, groundwater 41,200,000 cu.m and surface water 23,200,000 cu.m; discharges by destination: groundwater 205,000 cu.m, surface water 61,800,000 cu.m, treatment plants 10,000,000 cu.m and seawater 1,000,000 cu.m; and total water recycled and reused of 1,090,000,000 cu.m in 2025 against 1,008,000,000 cu.m in 2024. Water consumption itself is explicitly excluded as immaterial: "The Group's water consumption therefore represents a very small proportion of water withdrawals and, as a result, is considered non-material according to the double materiality assessment" (page 200), following from the finding that 90% of water withdrawn is returned as surface water. The Appendix B datapoint table is consistent, referencing the E3-4 total water recycled and reused datapoint (paragraph 28 c) to this section while marking "Total water consumption in m3 per net revenue on own operations" (paragraph 29) non-material (page 248). No breakdown of withdrawals or consumption in areas of water stress is given, although the 21 priority sites are stated to represent 10% of withdrawals (page 200).

Reference: page 202

"Arkema is committed to protecting biodiversity and, in its Health, Safety, Security, Environment and Quality policy ... which is overseen by the Executive Vice-President, Industry and CSR, undertakes to contribute to its preservation by reducing its emissions into air, water and soil" (page 202). The policy is informed by a 2023 biodiversity materiality assessment conducted with BL Evolution using the 2019 IPBES report, the Science-Based Targets for Nature methodology, France's NF X32-001 standard, the French Biodiversity Agency guide and TNFD recommendations; it "covered the Group's entire value chain and identified the main risks, dependencies and impacts related to the five drivers on biodiversity identified by IPBES". Where the impacts sit is stated plainly: "The main impacts of the Group's activities are concentrated in the upstream value chain. They relate to water consumption, pollution and changes in land use associated with the production of the raw materials purchased by Arkema", while in own operations "water withdrawals, pollution and greenhouse gas emissions are major challenges", and "particular attention must be paid to the pollution associated with the end of life of the products sold by the Group and their packaging". Arkema signed the act4nature international charter in 2021, joined EpE in 2023 and renewed its commitment in 2024, publishing its individual commitments on the act4nature international website.

Reference: pages 202-203

Actions run on three fronts. At Group sites, biodiversity is addressed through the air, water and climate programmes: "Arkema contributes directly to the preservation of biodiversity through various actions taken by the Group's industrial sites to reduce water withdrawals, air and water emissions, and greenhouse gas emissions" (page 202). On direct site impacts, "a working group set up in 2024 along with a team of experts in biodiversity has been making progress on defining a methodology for assessing the biodiversity footprint of its sites, including mapping sites in relation to key biodiversity zones and protected areas. At end-2025, a methodology was tested at three pilot sites, and the results will be used to draw up dedicated action plans". Habitat work is given by example: "former lime production units have been replanted at the Lannemezan site (France), in collaboration with the Conservatoire Botanique National des Pyrénées et de Midi-Pyrénées, and a reed bed was created several years ago on an unused part of the Pierre-Bénite site (France) in collaboration with the NATURAMA non-profit". Awareness-raising ran through Sustainable Development Week webinars and local events on the theme "Biodiversity is life: let's take care of it", e-learning modules and a web application created in 2025.

Reference: pages 201-202

Biodiversity targets are disclosed by cross-reference to the environmental targets that address the biodiversity drivers, not as separate biodiversity metrics. "Targets relating to the Group's own operations are set out in sections 4.2.2.1, 4.2.2.2.3, 4.2.2.2.4 and 4.2.2.3, concerning climate change, air emissions, water emissions and water withdrawals, respectively" (page 202). The E4 IRO summary table makes the mapping explicit, attaching to the four biodiversity-relevant IROs: 48.5% reduction in Scopes 1 and 2 GHG emissions by 2030 versus 2019; 67% reduction in Scope 3 by 2030 versus 2019; 25% reduction in net energy purchases by 2030 versus 2012 in EFPI terms; process safety event rate down to 2.0 by 2030; 70% reduction in COD emissions by 2030 versus 2012; 65% reduction in VOC emissions by 2030 versus 2012; water withdrawals down to 76 million cu.m by 2030; and "In 2025, 80% of purchasing spend from relevant suppliers covered by a TfS assessment" (page 201). Above these sits the act4nature international commitment: the strategy "is based on nine targets that follow the SMART (Specific, Measurable, Additional, Realistic, Time-bound) guidelines", whose compliance "was reviewed and validated as a part of its act4nature international commitment renewal process" by a multi-stakeholder steering committee of public bodies, environmental NGOs, company networks and scientific partners (page 202).

Reference: pages 204-205

"Arkema strives to integrate the responsible resource management throughout the value chain, the preservation of non-renewable raw materials, and the reduction of waste from industrial processes into its HSSEQ policy" (page 204). The circular economy approach has three limbs. Preserving and responsibly managing raw materials, "notably through the incorporation of renewable and recycled raw materials in its products and packaging". Reducing the environmental impact of activities by optimising the quantity of raw materials used in production, optimising water and energy consumption, reducing waste, and "transitioning toward low-carbon energy for the Group's production sites worldwide". And keeping products and materials in use, in particular through eco-design, "by marketing products that are recyclable, or that enable the recyclability of the materials of which they are composed", "by participating in the definition of specifications and the development of new recycling channels", and "by reducing the amount of hazardous substances in its products".

Reference: pages 205-209

On renewable inputs, "Arkema is a pioneer in the use of raw materials made from biomass, as illustrated by its use of castor oil to produce Rilsan high performance polyamides", with the Singapore facility expanding the range since 2023, financed partly by the Group's first green bond in 2020 (page 205). Mass Balance work has developed since 2023: "In 2025, ten new sites were ISCC+ certified, bringing the proportion of ISCC+ certified coating solution production sites worldwide to 70%" (page 206). Named launches include KizenTM LIME adhesive "with a minimum of 80% renewable ingredients", Fast Glue Ultra+ at 60% bio-based, and Reafree 40% rPET powder coating resins. On packaging, "some industrial sites already use up to 70% recycled packaging" and "Bostik integrates a minimum of 40% PCR plastic in its cartridges, a minimum of 50% in its pails, and a minimum of 70% in its bottles and jerrycans". On channels, Bostik is active in CEFLEX, RECYCLASS, FPA, APR, CPRRA, FINAT and the Nextloopp project, and Arkema joined the Ellen MacArthur Foundation Network in 2024. The Virtucycle programme, run through the Agiplast subsidiary, regenerates high-performance polymers and markets SCS-certified recycled grades under the Rilsan, Rilsamid and Pebax brands, produced at the Agiplast site in Italy "using only renewable energy" (page 209). Waste reduction actions include the Taixing site reducing incinerated acrylic-process wastewater "by almost 460 tonnes in 2025".

Reference: page 207

Three circular economy metrics are disclosed with two carrying quantified targets (page 207). Percentage of sales from products made from renewable or recycled raw materials was 12% in 2025, 11% in 2024 and 11% in 2023, covering "products with a renewable or recycled raw material content of at least 25%"; the company notes the metric "is steady with respect to the previous year, demonstrating sustained interest from the Group's markets in solutions derived from bio-based and recycled materials", and that the 25% threshold "has been used as the baseline for the 'substantial contribution' criteria for Arkema's Taxonomy-eligible activities in the Plastics in primary form category". Waste treated without recovery, equivalent to waste disposed of, was 44.0 kg per tonne of production in 2025 against 44.1 in 2024 and 47.4 in 2023, with a 2030 target of 41. Percentage of sales covered by a life-cycle assessment reached 73% in 2025 from 68% in 2024 and 56% in 2023, against a 2030 target of 90%; LCAs follow ISO 14040-14044, ISO 14067, EN 15804+A2 and the Together for Sustainability Product Carbon Footprint Guideline, and "Their scope generally covers a cradle-to-gate analysis". A fourth target sits in the Group commitments table, 60% of ImpACT+ sales by 2030, against 57% in 2025 and 53% in 2024 (pages 153, 159). No target is set for resource inflows, for recycled content in packaging, or for total waste.

Reference: pages 207-208, 163

"Arkema's largest bio-sourced raw material by volume is castor oil" (page 207). Castor seeds are one of the Group's most strategic raw materials, making Arkema "one of the world's leading buyers of this material, and the only one for this use and for the manufacture of Rilsan"; the beans "are grown and harvested on land not designated for food crops, mostly in India", and the Pragati programme has trained, audited and certified more than 10,000 Indian farmers across more than 12,000 hectares under the SuCCESS sustainability code. Quantified weights are disclosed: "In 2025, the Group purchased the equivalent of 3,344,700 tonnes of raw materials for all its activities (compared with 3,500,000 tonnes in 2024), including 4.2% raw materials of biological origin", and "In 2025, recycled materials incorporated into finished products represented a volume of 12,200 tonnes, or 0.4% of raw material purchases" (page 208). Other biological raw materials named are soy, rapeseed and pine derivatives from the paper industry. BP-2 records the change in status: the proportion of organic raw materials (E5-4 31 b) moved from not disclosed in 2024 to disclosed in 2025, and the recycled raw materials metrics (E5-4 31 c and 36 c) from not disclosed to partially disclosed, with packaging reporting on reuse, recycled content and recyclability still being developed "in France, in the medium term followed by wider-scale application in the long term" (page 163).

Reference: pages 208-212, 207

Resource outflows are presented as eco-design, product life extension, recycling and waste reduction. Eco-design identifies "the most relevant circularity drivers, such as optimization of the quantity of materials used, extension of product lifespan, separability of materials and components, and recycling" (page 208). Life extension is quantified by example: Kercoat 500 "helps to prolong the life of glass bottles ... thereby doubling or even tripling their useful lives", and the Opticoat range "allows bottles to be used for up to 50 cycles, compared with the standard 20", with a "92% bio-based version with Opticoat 340" launched in 2024. Recyclability examples include Elium liquid thermoplastic resins, whose parts are "easy to recycle, unlike parts made from thermoset resins such as epoxy", and the US CecabaseRT and WarmGrip technologies, which "increase the recycling rate of products used to scrap bitumen road pavements by up to 50%, while lowering the manufacturing temperature by 40C". Recycling channels run through the Virtucycle programme and Agiplast (page 209). Waste recovery is quantified: "In 2025, 32% of waste produced worldwide by the Group was recycled on- or off-site to recover useful materials", and at Lacq "10,700 tonnes of desulfogypsum were recycled in this way, thereby avoiding them being sent to landfill" (pages 209-210).

Reference: pages 209-210, 207

Group waste volumes for 2025 (page 210). Hazardous waste total 189,400 t (183,400 in 2024; 178,200 in 2023), of which diverted from disposal 132,400 t, comprising recycled into materials 70,600 t and incineration with energy recovery 61,800 t; and directed to disposal 57,000 t, comprising incineration without energy recovery 51,800 t, other disposal 2,800 t and landfill 2,400 t. Non-hazardous waste total 195,400 t (209,200; 213,100), of which diverted from disposal 63,000 t, comprising recycled into materials 51,300 t and incineration with energy recovery 11,700 t; and directed to disposal 132,400 t, comprising incineration without energy recovery 110,500 t, other disposal 500 t and landfill 21,400 t. Total waste was 384,800 t against 392,600 t and 391,400 t. The company reports non-recycled waste of 189,400 t, 49%, against 273,600 t, 70%, in 2024, under the definition "Non-recycled waste corresponds to waste disposed of and waste incinerated with energy recovery"; the 2025 figure equals the directed-to-disposal total alone, so the two years do not appear to be computed on the same basis. "In 2025, the overall volume of waste fell slightly, reflecting the drop in activity at production sites. In 2025, 32% of waste produced by the Group worldwide was recycled into materials, and 19% was incinerated with energy recovery". No radioactive waste is reported.

Reference: pages 219-220, 224, 227

Arkema's commitments are formalised in a Human Rights Policy highlighting four closely monitored areas: health, safety and security; health and safety of customers and end users; suppliers and subcontractors; and anti-discrimination. "Arkema's Executive Committee is responsible for drawing up the Group's Human Rights Policy and disseminating it across all entities, while the regional entities are tasked with implementation" (page 220). The HR policy "focuses on providing safe and transparent working conditions, a compensation policy that fairly values and rewards each employee's contribution to the Group's success, and social protection that contributes to employees' quality of life. It also aims to maintain and develop skills" (page 224). Talent management "is based on the principles of workplace equality and non-discrimination". On diversity: "The Group applies a zero-tolerance policy on discrimination and has made it a major focus of its human resources policy, particularly in the areas of recruitment, compensation and training" (page 227). A Diversity and Inclusion Committee and a Junior Diversity and Inclusion Committee produced a Diversity and Inclusion Charter based on the Group's five values, with a roadmap of measurable objectives, Group and regional governance, inclusive HR processes and promotion of an inclusive culture; of the awareness e-learning, "82% of employees have completed the module since its creation in 2022".

Reference: pages 220-221

"The Group firmly believes in sustaining, under the responsibility of the Human Resources and Communication Executive Vice-President, permanent and meaningful dialogue both directly with employees and through their representatives, aimed at continuous improvement in workplace quality and safety, in work-life balance, and in workplace atmosphere and organization" (page 220). Four systems are named: the Arkema Cares engagement study, the SMART approach, social dialogue and collective bargaining agreements. "In 2025, Arkema once again conducted its global in-house survey, ARKEMA CARES. 20,143 employees were surveyed on five dimensions: engagement, the Group's strategy and values, employee experience, diversity and inclusion, and performance conditions. The response rate was 80%", and "The results showed a high level of employee engagement, with an engagement score of 76%, two points above the industry benchmark calculated by Mercer, the firm that conducted the survey. The results were analyzed and communicated to each Group entity and all employees" (pages 220-221). A 2030 target of at least 80% engagement is set. The SMART approach, part of the operational excellence programme, involves "107 sites across three continents".

Reference: pages 222-223

"In addition to its employee engagement processes, Arkema has set up a number of mechanisms to identify concerns and decisions that could have a negative impact on employees, and to remedy them, complying with applicable legislation" (page 222). Channels include management and employee representative bodies, with a monitoring process to identify situations requiring attention; "The implementation and effectiveness of remediation measures are also monitored at the appropriate operational level (Group, subsidiary, or direct management of the people concerned)". The Arkema Cares survey feeds action plans at several levels, and "The digitalization of individual interviews (EIA) in the HR Information System makes employee comments accessible to line management and the HR function, enabling risk situations to be identified and resolved". A dedicated psychological route exists: "A global psychological support and anti-harassment system was rolled out in 2023. It is accessible via Eutelmed, an online platform that allows employees to contact a psychologist, in 60 languages ... in a safe, confidential and anonymous manner." The Group whistleblowing system is open to employees and other stakeholders (page 237).

Reference: pages 229-231

"As part of a prevention and continuous improvement process, the Group is committed to ensuring a good working environment for everyone, in particular by analyzing workstation health and safety risks and studying accident typologies", with the same expectations of contractors as of employees (page 230). Training: "In 2025, 47% of the Group's employees received safety training (excluding e-learning), for an average of 17 hours of training per year per employee trained. In addition, 37% of Group employees took e-learning courses on safety." Named programmes are "Safety Always in Mind" and "Essentials", which "defines a set of rules that must be applied without compromise in every situation", plus peer observation, in place at "almost all of Arkema's industrial sites" in 2025, work with a neuroscientist since 2017 on mechanisms of human error, and digital tools including virtual reality training, smart personal protective equipment and drones for inspections. Occupational health: "In 2025, 96% of employees benefited from regular medical check-ups", and "At 31 December 2025, 72% of the Group's sites (70% in 2024) had carried out workplace risk assessment in accordance with the general basic principles set by Arkema, and 43% (41% in 2024) had applied Arkema methodology for entering the assessment data into the STARMAP system" (page 231).

Reference: pages 221, 224, 227-229

Four quantified own-workforce targets are disclosed. Safety: "Bring the total recordable injury rate (TRIR) per million hours worked down to 0.7" by 2030, a target that "covers the Group's workforce and that of contractors working on Group sites"; TRIR was 0.8 in 2025 (page 229). Gender: "The Group has set a target that 35% of senior management and executive positions across the Group should be held by women" by 2030, against 31% in 2025, 30% in 2024 and 29% in 2023 (pages 227-228). International diversity: "The Group has set a target that 50% of senior management and executive positions should be held by non-French employees" by 2035, against 41% in 2025 and 40% in each of 2024 and 2023 (page 228). Engagement: "The Group has set itself the goal of achieving an engagement score of at least 80% by 2030", against 76% (page 221). Two further commitments are stated without Group target status: "Arkema aims to increase the proportion of women on the Group management committee to 30% by 2030", against 25%, six of 24 members (page 228), and the French Rixain Act obligations of 30% and 40% by 2026 and 2029 for Arkema France and Bostik S.A. For talent the Group states the opposite position plainly: "As talent support and development must be tailored to the needs of each business line and entity, as well as to the type of employee in place, the Group has not set quantified targets for its entire scope" (page 224).

Reference: pages 222-223, 167, 162

Headcount at 31 December 2025 was 20,704, against 21,164 in 2024 and 21,125 in 2023; "This decrease was mainly due to workforce adjustment measures in response to the economic situation" (page 223). By gender: male 14,973, female 5,724, other 2, not reported 5. By major country: France 7,058, United States 3,297, China 2,453, other 7,896. By contract type: permanent 20,000, temporary 704; full-time 19,987, part-time 717, each split by gender. By region (page 167): France 7,058, Europe excluding France 3,833, North America 4,034, Asia 4,653, rest of world 1,126. Turnover (page 222): 2,689 departures excluding changes in scope against 2,742 in 2024; departures as a share of permanent and temporary headcount 13% against 12%; voluntary departures 4.7% against 4.5%, with the note that "The 2024 value was corrected following the inclusion of other reasons for departures (end of fixed-term contracts and end of trial periods)". Absenteeism, including sickness, accident, maternity leave, strikes and unpaid leave, "stood at 4.3% for 2025", against 3.7% and 4.1%. Scope: headcount data cover all companies at least 50% owned, 100% of the workforce; other employee data cover companies at least 50% owned with more than 50 employees at 30 June, 96% of total headcount (page 162).

Reference: page 221

"In addition to complying with the legal and regulatory provisions of the countries in which it operates, the Group facilitates the creation of employee representation bodies, in order to implement all appropriate collective bargaining mechanisms, as well as freedom of association. In countries where the law does not provide for employee representation, specific bodies can be set up locally" (page 221). Three structures are described. In Europe, the European Group Works Council, renewed in September 2024 with twenty members, holds a one-day plenary at least every six months covering business, financial, labour, environmental and organisational issues, and met three times in 2025. In the United States, "Employees at unionized facilities are covered by collective bargaining agreements negotiated with local and national trade unions for an average period of three years". In China, the Employee Representatives Congress of Arkema China Investment Co. Ltd has 32 members and "complements the labor unions already in place at the Group's local production plants". On agreements: "In 2025, 89 collective agreements were signed worldwide (87 in 2024). These agreements cover issues such as health and safety at work, well-being at work, social protection, pensions, working hours and conditions, gender equality, disability, compensation, forward-looking management of jobs and skills, and training."

Reference: pages 227-229

"Women accounted for 28% of the Group's total headcount at 31 December 2025 and represented 34% of new hires and 34% of managers, across all levels of the organization" (page 227), up from 27% a year earlier. At senior level: "High-responsibility positions (senior managers and executives) account for around 10% of all managerial positions across the Group. Senior managers account for about 2% of all management positions. In 2025, women accounted for 31% of all senior managers and executives across the Group, i.e., 173 women. In 2024, this was 30%, or 174 women. In 2025, men accounted for 69% (i.e., 390 men), compared with 70% (408 men) in 2024." The trend is charted at 29% in 2023, 30% in 2024 and 31% in 2025 against a 35% target for 2030 (page 228). The action plan comprises annual monitoring now included in collective variable-compensation objectives, a mentoring programme that "has benefited 163 women managers in France" since 2016 with "Nearly 83% of them" having enjoyed career development since mentoring, external female talent pools, and the Women@Arkema collective. Cultural diversity is measured alongside: "In 2025, the proportion of non-French senior managers and executives was 41%", against a 50% target for 2035, supported by an international mentoring programme "reaching 119 'mentee' participants in 21 countries since it began in 2020".

Reference: pages 226, 163

"The Group commits to ensuring that all employees receive the minimum compensation in accordance with the regulatory provisions applicable in all countries where the Group operates, and to ensure that salaries are paid on time, in full and without unjustified deductions" (page 226). The 2025 assessment extended the scope: "A study carried out by the Group in 2025 on compensation levels in France, the United States, China, Italy, Germany, Spain, the Netherlands, Mexico and the United Kingdom confirmed that employees receive an adequate wage. For this scope, which represented 79% of the workforce and 84% of the Group's payroll in 2025", the benchmark is "in the European Economic Area: the minimum wage determined by national legislation or the collective bargaining agreement applicable in France, Italy, Germany, Spain and the Netherlands" and "outside the European Economic Area: the minimum wage determined by the legislation of the country or region in the United States, China, the United Kingdom and Mexico". For 2024 the analysis covered only France, the USA and China. The limitation is declared in BP-2, which records the compensation metrics as partially disclosed in both years and states that "The scope will gradually be extended to the most significant geographies" (page 163).

Reference: pages 221, 224, 226-227

Social protection is disclosed as a feature of the HR policy and of collective bargaining rather than as a coverage table. The HR policy "focuses on providing safe and transparent working conditions, a compensation policy that fairly values and rewards each employee's contribution to the Group's success, and social protection that contributes to employees' quality of life" (page 224), and the matching positive impact in the IRO register is "The positive impact of being a responsible employer offering safe, transparent working conditions and social protection that enhance employees' quality of life" (page 174). The delivery route is collective agreement: "In 2025, 89 collective agreements were signed worldwide (87 in 2024). These agreements cover issues such as health and safety at work, well-being at work, social protection, pensions, working hours and conditions, gender equality, disability, compensation, forward-looking management of jobs and skills, and training" (page 221). The content index maps S1-11 to section 4.2.3.1.6.3 Compensation and benefits metrics (page 245), which reports that 54% of employees receive an individual bonus, 61% "are eligible for a collective bonus ... This is the case for the incentive and profit-sharing schemes in effect in France", and that at 31 December 2025 "9.7% of outstanding shares were owned by current and former employees".

Reference: pages 228-229, 241

"The Group contributes to the integration and continued employability of people with disabilities through dedicated training programs and workstation modifications. The Group's recruitment procedures make it possible to offer people with disabilities various job opportunities. The measures taken in France illustrate the approach implemented by the Group. For the other regions, similar measures have been implemented taking into account local conditions and legislation" (page 228). The French instrument is named: "Arkema France has an agreement in place covering the period 2024-2026. It reaffirms the Group's commitment to hiring, integrating, training and retaining disabled employees, raising awareness of the issue and increasing the use of social enterprises and work centers" (page 229). The metric is given with its basis and limitation: "At the end of 2025, disabled employees accounted for 2.5% of the global Group's workforce (2.4% in 2024). This calculation is based on available information and takes into account the regulations in force in the countries where Arkema operates." A linked procurement commitment runs through the sheltered employment sector in France under "the 6th disability agreement signed at the end of 2023 in France, with a target to entrust 1.5 million euros in services to these structures by the end of 2026" (page 241). No breakdown of the disability percentage by gender, country or employee category is disclosed.

Reference: pages 229-232

Follow-up indicators for 2025, 2024 in brackets (page 232): employees covered by the Group's health and safety management system 97% (96%); workforce covered by a system based on recognised standards and subject to internal audit 72% (71%); fatalities due to accidents among Group employees 0 (0) and among employees of contractors 0 (0); recordable work-related accidents 30 (27); rate of recordable work-related accidents 0.8 (0.7); "Number of cases of recordable work-related ill health, subject to legal restrictions on the collection of data" 32 (32), for current and former employees in France only; days lost due to work-related accidents 1,104 (576). Accident figures cover Group employees and non-employees (temporary workers) and exclude occupational illnesses. TRIR was 0.8 against a 2030 target of 0.7, and "2025 confirmed the ongoing improvement in the Group's results with a TRIR of 0.8" (page 229). "The lost-time incident rate (LTIR) was improved at 0.4 in 2025. An average of 61 days were lost per injury in 2025 across all Group and subcontractors employees" (page 232). Occupational illness frequency is separate: "In 2025, the rate was 3.0 per million hours worked", calculated on the France scope, "which represents 34% of the Group's workforce" (page 231). The Group states it "does not publish, on a worldwide basis, the number of occupational illnesses or deaths due to such illnesses", citing heterogeneous local legislation.

Reference: pages 226-227, 163

The gender pay gap is disclosed on two scopes. "In 2025, the gender pay gap averaged 2.5% in favor of women, account taken of the typology of Arkema's businesses, particularly in the industrial sector. The gap was calculated for France, the United States, China, Italy, Germany, Spain, the Netherlands, Mexico and the United Kingdom, which account for 79% of the Group's workforce" (page 226). On the narrower 2024 methodology covering France, the United States and China, the gap was 6% in 2025 against 5% in 2024. The total remuneration ratio is given on the same two scopes: "In 2025, the ratio between the remuneration of the Chairman and Chief Executive Officer and the median compensation ... was 90.68, account taken of the typology of Arkema's businesses, particularly in the industrial sector" (page 227); on the three-country scope it was 102.42 in 2025 against 99.84 in 2024. The definition of median compensation is given in the methodology appendix 4.2.5.6. Women accounted for 28% of the workforce at 31 December 2025, 27% a year earlier, and "Equal pay between women and men is a key factor in annual salary reviews and career reviews in all Group companies". The scope limitation is declared in BP-2, which records the compensation metrics as partially disclosed and states that "The scope will gradually be extended to the most significant geographies" (page 163).

Reference: pages 223, 236-237

"Reports received and processed under the Group's whistleblowing procedure are presented in section 4.2.4.2.5 of this chapter" (page 223). On severe human rights impacts the statement is a nil return: "Under the Group's duty of care plan, the system for monitoring the measures implemented and assessing their effectiveness has confirmed that no serious infringement to human rights and fundamental freedoms, or to employment and industrial relations, was identified within the Group in 2025", and "The Group is not aware of any claims made to an OECD National Contact Point for Responsible Business Conduct (NCP)". The incident numbers sit in the whistleblowing section: "In 2025, 38 alerts were received through this channel, eight of which were substantiated. Of these alerts, 24 (63%) were related to human resources issues (including eleven for discrimination or harassment), seven (18%) related to business integrity and fraud issues, and four (11%) concerned conflict of interest issues. As of 31 December 2025, 12 alerts were still being processed" (page 237). On consequences: "eight were substantiated and resulted in corrective measures, including disciplinary action. None gave rise to fines, penalties or the payment of damages" (page 236). The Appendix B table maps the S1-17 incidents of discrimination datapoint (paragraph 103 a) and the non-respect of UNGPs and OECD guidelines datapoint (paragraph 104 a) to this section (page 250).

Reference: pages 233, 238-239

"Arkema is firmly committed to respect for human rights and fundamental freedoms throughout its value chain, and makes every effort to prevent and identify any human rights violations against its employees or those of its suppliers, its subcontractors and other stakeholders, and to remedy any such violations that do occur. The Group's commitment is reflected in its Human Rights policy" (page 233). Three instruments cover the upstream chain: the Responsible procurement policy, "available at arkema.com ... supported by the Executive Vice-President, Industry and CSR and the Chief Operating Officer", built on social, environmental and business integrity requirements and applying "to all individual or legal entities supplying goods or services to the Group worldwide, as well as to all employees involved in managing supplier relations" (page 238); the Supplier Code of Conduct, whose "guidelines cover human and labor rights, respect for the environment, the quality and safety of the products and services provided, and business compliance and ethics" (page 239); and the conflict minerals policy. Downstream, "The Group pays particular attention to the health and safety of its customers. The HSSEQ policy ... includes product stewardship, which aims to prevent health impacts associated with the use of its products" (page 233).

Reference: pages 233, 237, 239

The remediation and grievance route for value chain workers is the Group whistleblowing system: "Dialogue with value chain workers is facilitated by the whistleblowing procedure outlined in section 4.2.4.2.5. This enables any worker in Arkema's value chain to report any malfunction and to inform Arkema of their concerns" (page 233). The system's design is set out at page 237: the procedure is published in the Ethics and Compliance section of the Group website, "has been translated into 15 languages", is "available 24/7" and "allows employees and other stakeholders (such as customers, suppliers etc.) to report any irregularities they are aware of that may be related to Arkema", with examples including "serious violations of human rights, fundamental freedoms, health, personal safety or the environment". Protections are stated: "precautions are taken to protect the confidentiality of the person making the report ... as well as to protect the whistleblower from any act or threat of retaliation by the Group as a result of the report." Reports go to the Whistleblower Committee, appointed by the Chairman and CEO from Internal Audit and Internal Control, Sustainable Development, Legal Affairs and Human Resources, which "acts in the strictest confidentiality and ensures the impartiality of the investigations carried out".

Reference: pages 233-234, 240-242

Upstream actions are three: the Supplier Code of Conduct, "covering respect for human rights and labor law, in particular"; participation in Together for Sustainability, pooling supplier assessment with other chemical companies; and the Pragati program, "which promotes respect for the fundamental human rights of castor bean farmers, such as payment of minimum wages, equal pay, non-discrimination, non-use of child labor and all forms of violence, and improved health and safety conditions" (page 233). Assessment volumes: "At the end of 2025, more than 2,600 of the Group's suppliers and subcontractors had been assessed over the past three years", the Group "has identified certain suppliers or subcontractors whose environmental, social and human rights assessments are below standard and has requested that they improve their practices", and "In 2025, CSR scores rose for 74% of suppliers whose assessments were updated" (pages 240-241). TfS-accredited third-party audits "cover key issues such as respect for human rights, working conditions, health and safety, governance and environmental practices", generally over one to three days, with corrective action plans monitored over time (page 240).

Reference: pages 235-237

"The Group places great importance on conducting its business in line with the principles and rules on business compliance and ethics ... Arkema is committed to complying with antitrust regulations and to rejecting and preventing all forms of corruption and fraud using a zero-tolerance approach" (page 235). The Business Conduct and Ethics Code specifies that "no form of violence, sexual or moral harassment is tolerated in the workplace", that employees "must not offer, provide, promise, request or accept, directly or indirectly, any undue advantage", that they must comply with antitrust law in all countries of operation, and that those in international trade must comply with export and import control laws and international economic sanctions. The Anti-Corruption Policy is set "in line with the principles of the United Nations Convention against Corruption" and defines corruption and influence peddling, gives examples of behaviours to avoid and sets rules on gifts and hospitality. "The Code of Conduct and the Anti-Corruption Policy are available in 15 languages ... and are accessible on the Group's intranet and website", are sent electronically to all employees once a year with a compliance statement to sign, and "Compliance with the rules and principles of the Code of Conduct and other Group procedures is assessed as part of the annual employee appraisal process" (page 236).

Reference: pages 238-242

"The Group integrates environmental, social, ethical and societal matters into its purchasing policy, in line with its commitments to sustainable development, human rights and responsible governance. Arkema strives to build long-term, balanced and responsible relationships with its suppliers and subcontractors, based on transparency, traceability and regulatory compliance" (page 238). Governance: purchasing is managed globally and "The Responsible Procurement Committee, comprising the Purchasing (goods and services, logistics, raw materials, packaging and energy), Legal and Sustainable Development departments, meets at least three times a year to review and guide the Group's progress in responsible procurement". Selection uses preliminary assessments on social, environmental and societal criteria, supplier interviews and external databases "in particular the EcoVadis platform", with Cybervadis and SOC reports for cybersecurity; logistics contracts are awarded on safety, security and environmental performance using SQAS and RSQAS (page 239). Monitoring uses "a periodic assessment, based on performances with regard to commitments made, the number, nature and management of any complaints, and the results of the CSR assessment carried out via the Together for Sustainability initiative" plus targeted third-party audits (page 240).

Reference: pages 235-236

The programme "primarily covers antitrust, international economic sanctions and the fight against corruption", with named components (page 236): face-to-face training on antitrust, sanctions compliance and anti-corruption; e-learning on the Code of Conduct, anti-corruption and antitrust, where "As of 31 December 2025, over 17,000 employees had taken the e-learning course on anti-corruption, including members of the Executive Committee, employees in senior management positions and employees most exposed to compliance risks, notably those in sales and purchasing"; a practical guide to competition; "integrity checks and other due diligence on third parties who interact with the Group"; verification of business intermediaries prior to appointment; rules on gifts and invitations; guidelines for conflicts of interest; prior approval for exports to restricted countries; and the whistleblowing system. A network of compliance lawyers monitors effectiveness, and a Compliance Committee appointed by the Chairman and CEO "presents the minutes of its meetings to Arkema's Executive Committee. It met three times in 2025". Internal Audit performs subsidiary audits analysing management processes "to help detect possible risks of fraud or, more generally, non-compliance". "The specific mapping of corruption risk ... is updated regularly. In 2025, the Group was not convicted of any allegations of corruption or influence peddling."

Targets related to business conduct

Back-filled from the business conduct chapter, where targets sit within MDR-T rather than a numbered DR. G1-3 became standalone only in the 2025/2026 ESRS.

No outcome target is set for the business conduct IROs themselves. In the G1 IRO summary table (page 235) the two business conduct rows carry a policy reference (4.2.4.2.1) and action references (4.2.4.2.2 to 4.2.4.2.5) but an empty Targets column.

One measurable target covers the responsible procurement IROs in the same chapter: "In 2025, 80% of purchasing spend from relevant suppliers covered by a TfS assessment" (page 235). Performance was 80% in 2025, 81% in 2024 and 77% in 2023, and "Responsible Procurement metrics rose from 68% in 2019 to 80% in 2025, achieving the set target" (page 241).

Consistent with MDR-T, effectiveness is tracked in the absence of targets:

• A network of compliance lawyers monitors the effectiveness of the business compliance and ethics programme, and a Compliance Committee overseeing application of the Code of Conduct met three times in 2025 (page 236).
• "The specific mapping of corruption risk ... is updated regularly" (page 236).
• Coverage is measured: "over 17,000 employees had taken the e-learning course on anti-corruption" at 31 December 2025, and around 75% of buyers attended responsible procurement training in 2025 (pages 236, 241).

Reference: pages 237-238

"As a responsible chemical company, the Group engages with public authorities wherever it operates. Its advocacy activities support its strategy and adhere strictly to its values and commitments, particularly in terms of social and environmental responsibility" (page 237). A new instrument was adopted in the year: "In 2025, the Group adopted a responsible lobbying policy, aimed at establishing common rules for interest representation for all relevant employees, at Group level and in all geographic regions." Registrations listed are the EU Transparency Register with its Code of Conduct, the French HATVP registry of lobbyists, and quarterly filings with both houses of Congress "as required under section 5 of the Lobbying Disclosure Act of 1995". The Institutional Relations Department is organised by region with managers in Europe, the United States and China; priority issues are business competitiveness, the circular economy, responsible product stewardship and the energy and ecological transition, and "in 2025, the public affairs department in Europe played an active role in the debate leading to the Chemical Action Plan" (page 238). On alignment: "the Group aligns its institutional policy - and its positions - with the objectives of the Paris Agreement and Arkema's carbon trajectory for 2030, validated by the SBTi".