ESG sustainability governance

Page 175 ESG sustainability governance

ESG integrated governance

Page 321 ESG integrated governance

The role of the administrative, management and supervisory bodies is addressed through ASML's corporate governance structure. The Board of Management is responsible for the management of the company, while the Supervisory Board oversees and advises the Board of Management. In 2024, Christophe Fouquet was appointed President, Chief Executive Officer and Chair of the Board of Management, succeeding Peter Wennink and Martin van den Brink.

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies are covered through our ESG sustainability governance framework as detailed on page 175 and our ESG integrated governance approach on page 321.

Integration of sustainability-related performance in incentive schemes

Roles covered

The integration of sustainability performance in incentive schemes applies to the Board of Management. The ESG Committee monitors performance on ESG LTI targets and provides recommendations to the Remuneration Committee.

Sustainability KPIs tied to remuneration

Sustainability KPIs are integrated into the Long-Term Incentive (LTI) scheme:

• ESG LTI targets: The ESG Committee reviews "Performance on ESG LTI targets and ESG LTI metrics and targets 2024–2026" and provides recommendations to the Remuneration Committee (Q1 2024)
• ESG LTI metrics and targets for 2025–2027: The ESG Committee discussed and proposed new ESG LTI metrics and targets in Q4 2024

Specific ESG sustainability KPIs monitored by the ESG Committee include:

• Energy efficiency and climate action targets
• Supplier ESG commitments: Commitment of top 80% suppliers (based on CO2e emissions) to reduce their CO2e footprint by 2030 (2026 target: 75%)
• Scope 3 emissions related to logistics: GHG neutrality target by 2030

Weighting and performance period

The excerpts confirm that sustainability metrics are part of the LTI structure with multi-year performance periods:

• 2024–2026 period metrics were reviewed in Q1 2024
• 2025–2027 period metrics were proposed in Q4 2024

Specific percentage weightings of sustainability KPIs within the total LTI are not disclosed in the provided excerpts.

Short-term vs. long-term incentive

Sustainability performance is tied to the Long-Term Incentive (LTI) scheme. The excerpts refer consistently to "ESG LTI targets" and "ESG LTI metrics."

Threshold/target/maximum performance definition

Specific threshold, target, and maximum performance levels for ESG LTI metrics are not detailed in the provided excerpts.

Payout disclosure for the reporting period

The excerpts do not disclose actual payout amounts or achievement levels against sustainability KPIs for the 2024 reporting period. The ESG Committee reviewed performance on LTI targets in Q1 and Q3 2024, but specific results are not provided in the sustainability statements excerpts.

ESG Committee oversight

The ESG Committee plays a central role in sustainability-related remuneration:

• Reviews progress on ESG sustainability KPIs quarterly
• Monitors performance on ESG LTI targets
• Provides recommendations to the Remuneration Committee on ESG LTI metrics and targets
• Proposed new ESG LTI metrics and targets for 2025–2027 in Q4 2024

Statement on due diligence is covered through our responsible value chain management and ESG governance processes.

Risk management and internal controls over sustainability reporting are integrated into our overall risk management framework and ESG governance structure.

Our business strategy

Page 40 Our business strategy

Our business model

Page 42 Our business model

Our value chain overview

Page 176 Our value chain overview

ASML's strategy is to give customers the products and capabilities they need to deliver on technology's potential to make a positive contribution to society. Our holistic approach to lithography integrates lithography systems with computational tools, metrology and inspection systems, and process control software solutions – helping chipmakers achieve their highest yields and best performance.

Our business model is based on close collaboration with customers, suppliers, and technology partners in our innovation ecosystem. We design and integrate lithography systems that are fundamental to the mass production of microchips, enabling affordable shrink and supporting the continuation of Moore's Law.

Engaged stakeholders

Page 45 Engaged stakeholders

Supporting our customers

Our stakeholder relationships – with customers, employees, suppliers, shareholders and society – are incredibly important to us and we work hard to create and maintain strong relationships with them. Trust is an essential part of partnership. We share the risks and rewards of what we do because our success is inextricably linked with our customers, who are the world's leading microchip manufacturers.

Customer satisfaction survey score: 86%

Impact, risk and opportunity management

Page 177 Impact, risk and opportunity management

Material impacts, risks and opportunities and their interaction with strategy and business model are addressed through our comprehensive impact, risk and opportunity management framework.

Impact, risk and opportunity management

Page 177 Impact, risk and opportunity management

Description of the processes to identify and assess material impacts, risks and opportunities is covered through our impact, risk and opportunity management framework detailed on page 177.

Reference table

Page 186 Reference table

Disclosure requirements in ESRS covered by the undertaking's sustainability statement are mapped in our reference table on page 186.

Transition plan for climate change mitigation

Climate Transition Plan

ASML has developed a comprehensive Climate Transition Plan as its strategic roadmap underpinning the ambition to align with the goals of the Paris Agreement to keep global warming below 1.5°C. The plan aims for GHG neutrality across the entire value chain by 2040.

Base year: 2019 (selected as not impacted by COVID-19, commonly used in guidance and governmental targets, and aligns with SBTi-approved near-term targets approved in 2021)

Scope and coverage:

• Own operations (scope 1 and 2): Manufacturing locations and owned/leased office locations worldwide (160+ buildings)
• Supply chain (scope 3 upstream): Purchased goods and services, logistics, business travel, employee commuting
• Product use (scope 3 downstream): Customer operations globally
• Value chain partners: Suppliers and customers across the semiconductor ecosystem

GHG neutrality definition: Having remaining emissions, after ASML's efforts to reach GHG emission reduction targets, compensated by the same amount of tonnes of carbon credits verified against recognized quality standards.

Target years and milestones

GHG Neutrality Targets:

• 2025: GHG neutral for scope 1 and 2 emissions from manufacturing and buildings, business travel and employee commuting
• 2030: GHG neutral in supply chain (scope 3 upstream)
• 2040: GHG neutral across entire value chain

Gross reduction targets (SBTi-aligned):

Scope 1 and 2:

• 2025: Reduce absolute scope 1 and 2 GHG emissions by 25.2% from 2019 base year (SBTi-approved near-term target, 2021)
  • 2024 progress: 33 kt CO2e (46% reduction from 2019 baseline of 60 kt)
• 2030: Reduce absolute scope 1 and 2 GHG emissions by 75% from 2019 base year
  • Target: Below 15 kt CO2e by 2030
• 2040: Reduce absolute scope 1 and 2 GHG emissions by 90.0% from 2019 base year
  • Target: Below 6 kt CO2e by 2040

Scope 3:

• 2025: Reduce scope 3 GHG emissions 35.3% per €m gross profit from 2019 base year (SBTi-approved near-term target)
  • Intensity reduction: 1.44 kt per €m gross profit
  • 2024 progress: 0.83 kt CO2e per €m gross profit
  • Target: Below 15.7 Mt CO2e by 2025
• 2030: Reduce scope 3 GHG emissions 55.0% per €m gross profit from 2019 base year
  • Target: Below 19.5 Mt CO2e by 2030
• 2040: Reduce scope 3 GHG emissions 97.0% per €m gross profit from 2019 base year
  • Target: Below 2.3 Mt CO2e by 2040

SBTi validation status:

• Near-term targets (2025) validated and approved by SBTi in 2021
• In 2025, ASML aims to submit near-term target toward 2030 and long-term target toward 2040 to SBTi for continuation/validation

Decarbonization levers and key actions

ASML's emission reduction approach follows three improvement levers in hierarchical order:

1. Reducing energy use

Scope 1 and 2:

• Expected to deliver roughly half of the 90% emission reduction needed
• Energy savings master plan 2020–2025: 100 TJ/year target (achieved in 2024)
  • 2024 projects: 53 TJ annual savings
  • Cumulative 2021-2024: 100 TJ
• Key actions:
  • Energy grid implementation in Veldhoven reusing waste heat
  • Adiabatic humidification
  • Gas reduction from 4.4 million m³ (2019) to 2.3 million m³ (2025)
  • Heat pumps replacing combustion heating
  • Improving efficiency of technical installations
  • BREEAM/LEED/G-SEED certified new buildings
  • Solar panel installations (San Diego: 6 TJ/year)
  • LED lighting and cooling optimization

Scope 3:

• Expected to contribute roughly half of scope 3 emission reductions
• Supply chain actions:
  • Supplier commitments: 9% of purchased goods & services emissions reduction by 2030 (based on commitments from top 80% suppliers)
  • Strategic Sourcing & Procurement ESG sustainability program
  • Supplier engagement and Letter of Commitment (LOC) for scope 1, 2, 3 reduction or offset by 2030
• Product use actions:
  • Energy efficiency roadmaps for EUV, DUV, metrology and inspection systems toward 2030 (with draft numbers to 2040)
  • NXE:3800 system: 5.9 kWh per wafer pass (2024); target 5.1 kWh (2025)
  • RF Sleep Mode introduced 2024 (~400kW instant saving)
  • DUV energy reduction roadmap established 2024 (first upgrade 2026)
  • High-temperature cooling water (HTPCW) compatibility for next-generation systems
• Logistics:
  • Shift from air to ocean freight for DUV and YieldStar systems
  • Return shipment optimization by sea

2. Switching to renewable energy

Scope 1 and 2:

• Expected to deliver roughly half of the 90% emission reduction needed
• 2024: 96% renewable electricity; target: 100% by 2025
• Quality attributes for renewable electricity:
  • Sustainable sources: Wind, solar, hydro, geothermal
  • Local: Close to consumption location, same grid
  • Additional capacity: Commercial operation date maximally one year ago
  • Bundled: RECs and electricity bundled in long-term contracts
• Power Purchase Agreements (PPAs):
  • Netherlands: 10-year PPA through 2030
  • Taiwan: Long-term PPA secured 2023, operational 2024
  • South Korea: Yearly contract 2024
  • Germany: Two-year contract through end of 2025
• Gas reduction and green gas sourcing exploration underway

Scope 3:

• Expected reduction potential of roughly half of scope 3 emissions toward 2040 (excluding external trends)
• Supply chain: Suppliers required to deliver carbon-neutral products as of 2030
• Product use: Active participation in Semiconductor Climate Consortium (SCC) to promote renewable electricity adoption by customers
• External trend: Global decarbonization through grid improvements (modeled using IEA database for 2030 and 2040)

3. Compensating residual emissions

Carbon credit strategy (from 2025):

• Scope of compensation:
  • 2025: Scope 1, 2, scope 3 categories 6 (business travel) and 7 (employee commuting)
  • 2030: Supply chain emissions (scope 3 categories 1, 2, 4) at supplier level
  • 2040: Remaining product use emissions (scope 3 category 11) after customer collaboration
• Quality criteria based on:
  • (Revised) Oxford Principles for Net Zero Aligned Carbon Offsetting
  • SBTi's Beyond Value Chain Mitigation report
  • Peer benchmarking and EU regulatory developments
• Initial portfolio (from 2025):
  • Only nature-based removal projects (afforestation, reforestation)
  • Tech-based options (direct air capture) excluded initially due to cost
  • Recent carbon removal impact (achieved in recent years)
  • Verified against recognized quality standards
  • In-person site visit opportunity
• As of December 31, 2024: No VERs held based on existing contractual agreements

CapEx and investment commitments

ASML commits to significant investments to achieve ESG sustainability and climate action ambitions toward 2030 and 2040:

Investment types:

• Capital expenditure: Equipment for energy efficiency in factories and facilities; lease contracts for new/renovated buildings
• Operating expenditure: Innovation, R&D to improve energy efficiency of product portfolio

Green Bond (2022):

• Established to fund renewable energy and energy-saving initiatives
• 2024 allocation: €270.9 million for:
  • Green buildings (73%): €198.4 million
  • Renewable energy (15%): €39.9 million
  • Energy efficiency (12%): €32.6 million

EU Taxonomy-aligned investments (2024):

• Total capex: €3,315.0 million
• Taxonomy-eligible: €2,842.8 million (86%)
• Taxonomy-aligned: €74.1 million (2%)
  • Activity CCM 7.7 (Acquisition and ownership of buildings): €74.1 million aligned

Internal carbon price:

• €200 per tonne CO2e (indexed at 4% per year by default)
• Purpose: Guide decision-making in business cases without direct monetary flows
• Scope: Initially investment decisions in scope 1, 2 and scope 3 category 11 emissions; to expand to other categories with value chain partners
• Reference points: EU ETS prices/forecasts, ICT industry peer benchmarks (30+ companies), IPCC and US EPA guidance
• Not used in asset valuations in Consolidated financial statements
• Annual review process
• Roll-out target: All investment decisions in intended scope by 2025

R&D investments:

• Product roadmaps incorporate energy efficiency by design
• Costs not solely attributable to GHG reduction but support strategic goals
• Energy reduction roadmaps for entire product portfolio

SS&P ESG sustainability program:

• FTEs: Increased from 2 to 5 in 2024; expected to remain stable in 2025
• Total estimated cost: €0.5 million (included in SG&A costs)

Locked-in emissions and stranded assets

Locked-in GHG emissions:

• Gas boilers at multiple locations: May take years to replace with low-carbon alternatives
• Product energy consumption: Dependent on customer adoption of renewable electricity to achieve 2040 ambitions
• Hard-to-abate supply chain emissions: Low-carbon alternatives for steel and aluminum not yet viable
  • Steel and aluminum: Most of weight in ASML machines
  • Production industries not aligned with IEA NZE 2050 Scenario

Mitigation measures under development:

• Sustainable design principles for systems, products, processes
• Mono-material components for easier reuse/recyclability
• Supplier collaboration on upgradable, refurbished, repairable materials
• Certified materials adhering to international sustainability standards
• Exploration of recycled content in raw materials

Dependencies and challenges:

• Customer uptake of renewable energy for product use emissions
• Supplier actions (compensating residual emissions from products to ASML)
• Complex supply chain with long tail of multiple tiers
• Accessibility of affordable low-carbon energy in all operational regions (ASML, suppliers, customers)
• Carbon credit availability toward 2030 and 2040 due to increasing market demand

Stranded assets:

• No significant assets or business activities considered incompatible with transition to climate-neutral economy based on scenario analysis
• Climate scenario analysis provided no indications requiring changes in asset valuations in Consolidated financial statements

Use of carbon credits and removals

Carbon credit role:

• Enables GHG neutrality but not considered substitute for emission reductions
• Separate gross emission reduction targets pursued independently of offsetting
• Phased approach starting 2025

Portfolio strategy:

• Cost-effective offset portfolio from projects with:
  • Transparent reporting
  • Strong governance
  • Opportunity for in-person site visits
  • Recent carbon removal impact
• Initial portfolio: Nature-based removal projects only (afforestation, reforestation)
• Tech-based options: Currently not included due to lack of viable alternatives

Timing of compensation:

• 2025: Own activities (scope 1, 2, scope 3 categories 6 and 7)
• 2030: Supply chain (scope 3 categories 1, 2, 4) at supplier level/expense
• 2040: Remaining product use emissions after technical elimination efforts with customers

Current status:

• As of December 31, 2024: ASML did not hold any VERs based on existing contractual agreements

Alignment with Paris Agreement and climate scenarios

Paris Agreement alignment:

• Ambition: Align with 1.5°C goal to reduce GHG emissions by 45% by 2030 and reach net zero by 2050
• ASML target: GHG neutrality across value chain by 2040 (faster than Paris timeline)
• Acknowledgment: Latest climate science suggests 1.5°C scenario slowly getting out of reach; world needs to move faster

Climate resilience analysis:

• Scenarios assessed:
  • 1.5°C scenario: IEA Net Zero Emissions by 2050 (transition risks, medium term to 2030)
  • 4.0°C scenario: IPCC RCP 8.5 (physical risks, medium term 2030 and long term 2050)
• Conclusion: Strategy and business model resilient to both scenarios based on mitigation measures
• No indications requiring changes in asset valuations
• Annual review to identify emerging risks

Material climate-related risks identified:

• Physical risks (4°C scenario):
  • Acute/chronic climate effects on customers (medium risk)
  • Acute/chronic climate effects on own operations (medium risk)
• Transition risks (1.5°C scenario):
  • Policy and legal (medium risk)
  • Market and economic (medium risk)
  • Technology (medium risk)
  • Reputation (medium risk)

Material climate-related opportunity:

• Increased market demand for low-carbon technologies (high opportunity in both scenarios)
• Semiconductors essential for wind turbines, solar panels, electric vehicles, smart grids, energy-efficient technologies

Industry collaboration:

Semiconductor Climate Consortium (SCC):

• ASML founding member (November 2022)
• Pillars:
  • Transparency: Publicly report scope 1, 2, 3 emissions annually
  • Ambition: Near- and long-term decarbonization targets, GHG neutrality by 2040
  • Collaboration: Common approaches, technology innovations, communication channels
• 2023: Published in-depth analysis of semiconductor value chain carbon footprint
• Goal: Promote renewable electricity availability in customer operating regions

EU Paris-aligned benchmarks:

• ASML is not excluded from EU Paris-aligned benchmarks

Governance and accountability

Board of Management:

• Adopted Climate Transition Plan
• Responsibility for execution lies with the business

ESG Committee (Supervisory Board):

• Reviews and discusses Climate Transition Plan
• Deep dive performed in 2024, supported by ESG Committee and Supervisory Board

Cross-functional execution:

• Actions determined in collaboration between ESG Sustainability team and business
• Embedded in financial planning cycles
• Implementation strengthened by internal carbon price
• Quarterly progress tracking in cross-functional table meetings
• Progress performance meetings with senior leadership
• SEMI S23 standard used as tool to measure and analyze energy, utilities, materials

LTI performance metrics:

• Supervisory Board applied LTI performance measure on scope 1 and 2 emissions for 2023-2025 period
• 2024: Introduced scope 3 upstream supply chain GHG neutrality target as LTI metric

Update commitment:

• Climate Transition Plan updated on (at least) annual basis
• Ensures assumptions and projections reasonable in view of latest information
• Stakeholder feedback welcomed

Societal impact and downstream effects

ICT and society:

• ASML's climate impacts extend beyond operations, supply chain, product use
• Technology enables global digitalization with potential to transform living and working
• Semiconductor applications support:
  • Sustainable living and e-mobility
  • Accessible healthcare
  • Food security (smart sensors for agriculture)
  • Climate change mitigation (renewable energy, smart grids, energy efficiency)

Customer impact:

• Approach contributes to customers' sustainability performance
• Reduces climate-related investment risk
• Enables customers to meet their carbon-reduction requirements

Supplier impact:

• Drives ESG sustainability performance
• Encourages collaboration to exchange experience and reduce emissions
• Business opportunities through reuse of materials

Metrics and performance tracking

2024 performance vs. baselines:

Product efficiency:

• NXE:3800 energy use: 5.9 kWh per wafer pass (2024); target: 5.1 kWh (2025)

Business travel and commuting:

• 2024: 101 kt CO2e (65 kt business travel + 36 kt commuting)
• 2019 baseline: 139 kt (97 kt + 42 kt)
• Target: GHG neutral by 2025

Supply chain and logistics:

• 2024: 5,354 kt (5,032 kt supply chain + 322 kt logistics)
• 2019 baseline: 3,054 kt (2,841 kt + 213 kt)
• Target: GHG neutral by 2030

Product use:

• 2024: 6,569 kt
• 2019 baseline: 4,374 kt
• Target: GHG neutral by 2040
• Positive trend: Decreasing energy use per wafer pass despite absolute growth

Policies related to climate change mitigation and adaptation

ASML has embedded climate change policies within its broader ESG sustainability strategy and Climate Transition Plan, rather than maintaining a standalone climate policy document. The company's climate-related policies are integrated into its business strategy and overseen by the Board of Management.

Climate Transition Plan

Scope: The Climate Transition Plan covers ASML's entire value chain, including scope 1, 2, and 3 emissions from manufacturing and buildings, supply chain, logistics, business travel, employee commuting, and product use.

Key content and principles:

• GHG neutrality targets: scope 1 and 2 by 2025, supply chain (including logistics) by 2030, and entire value chain by 2040
• Three improvement levers: (1) Reducing energy use, (2) Switching to renewable energy, (3) Compensating residual emissions
• Base year: 2019
• Absolute scope 1 and 2 GHG emissions reduction targets: 25.2% by 2025, 75% by 2030, 90% by 2040 (from 2019 baseline)
• Scope 3 emissions intensity reduction targets: 35.3% per €m gross profit by 2025, 55% by 2030, 97% by 2040 (from 2019 baseline)
• Internal carbon price of €200 per tonne of CO2e (indexed at 4% per year) to guide decision-making in business cases
• Use of carbon credits to compensate residual emissions starting in 2025, following Oxford Principles for Net Zero Aligned Carbon Offsetting

Governance and oversight:

• Adopted by the Board of Management
• Discussed in the ESG Committee of the Supervisory Board
• Responsibility for execution lies with the business
• Actions determined in collaboration between ESG Sustainability team and business through cross-functional meetings
• Embedded in financial planning cycles with implementation strengthened by internal carbon price
• Updated annually to ensure assumptions and projections remain reasonable

Public availability: The Climate Transition Plan is disclosed in ASML's Annual Report 2024, Sustainability statements section.

Link to international standards:

• Aligned with Paris Agreement goal to limit global warming to 1.5°C
• Near-term targets (2025) validated and approved by Science Based Targets initiative (SBTi) in 2021
• Company aims to submit near-term target toward 2030 and long-term target toward 2040 to SBTi for validation in 2025
• Carbon offsetting approach follows (Revised) Oxford Principles for Net Zero Aligned Carbon Offsetting
• Uses SBTi's Beyond Value Chain Mitigation report guidance
• Not excluded from EU Paris-aligned benchmarks

Monitoring implementation:

• Progress tracked through quarterly cross-functional table meetings
• SEMI S23 standard used as tool to measure and analyze energy, utilities and materials used
• Internal roadmaps on energy use per exposed wafer pass for DUV machines closely monitored
• ESG Committee receives deep dives on scope 3 supply chain emissions and Climate Transition Plan
• Climate-related KPIs monitored by Board of Management
• ESG LTI performance measures include scope 1 and 2 emissions targets (2023-2025 period)
• Annual updates to Climate Transition Plan
• Performance tracking through progress performance meetings with senior leadership

Energy Savings Master Plans

Scope: Five-year plans covering ASML's five largest industrial sites and own operations worldwide.

Key content:

• Target of 100 TJ/year energy savings by 2025 through projects executed 2021-2025
• Master plan 2020-2025 completed; master plan 2026-2030 in development
• Over 80 projects including: improving efficiency of technical installations, optimizing building portfolio, reducing natural gas consumption, implementing energy grids to reuse waste heat, installing solar panels, LED lighting upgrades

Monitoring implementation:

• Progress tracked through cross-functional table meetings
• Energy consumption metrics monitored in kW compared to baseline values
• Cumulative energy savings achieved: 13 TJ in 2021, 19 TJ in 2022, 15 TJ in 2023, total 100 TJ by 2024

Renewable Energy Sourcing Policy

Key content:

• Target of 100% renewable electricity for own operations worldwide by 2025
• Direct green electricity purchases from renewable sources close to premises
• Long-term power purchase agreements (PPAs)

Implementation:

• 10-year PPA for green electricity in the Netherlands toward 2030
• Long-term PPA in Taiwan (secured 2023, operational 2024)
• Yearly contract in South Korea (2024)
• Two-year contract in Germany through end of 2025
• Achieved 96% renewable electricity as of 2024

Product Energy Efficiency Roadmaps

Scope: Energy efficiency roadmaps for all main product lines: EUV, DUV, metrology and inspection systems, and computational lithography.

Key content:

• Roadmaps developed toward 2030 with draft numbers until 2040
• Focus on reducing energy consumption per wafer pass
• Updated regularly to adopt latest technologies in future products
• Specific initiatives include: sleep modes for lithography systems, improvements to EUV source efficiency, compatibility with higher-temperature cooling water

Monitoring:

• Internal roadmaps on energy use per exposed wafer pass closely monitored by relevant teams
• Metrics tracked on energy consumption per system and per wafer pass

Strategic Sourcing & Procurement (SS&P) ESG Sustainability Program

Scope: Supplier engagement program covering supply chain emissions (scope 3 categories 1, 2, and 4).

Key content:

• Letter of Commitment (LOC) requiring suppliers to reduce or offset scope 1, 2, and 3 emissions by 2030
• Requirement for suppliers to deliver carbon-neutral products by 2030
• Supplier commitments to use more renewable energy
• Training curriculum for internal teams and suppliers on GHG emissions
• Capability maturity assessment questions in supplier performance management system
• Data quality improvement initiatives with suppliers

Implementation:

• Top 80% suppliers participated in executive review meetings in 2024
• Bi-monthly online forums with average 250 supplier representatives
• 5 FTEs dedicated to SS&P ESG sustainability program in 2024
• Estimated cost: €0.5 million

Governance:

• Part of Strategic Sourcing & Procurement function
• Progress discussed with ESG Committee of Supervisory Board

ASML's approach integrates climate policies into its overall business and ESG strategy rather than maintaining separate standalone climate policy documents. The company's governance structure ensures Board-level oversight through both the Board of Management and the ESG Committee of the Supervisory Board.

Actions and resources in relation to climate change policies

ASML has defined a comprehensive set of actions to achieve greenhouse gas (GHG) neutrality across its value chain by 2040, organized by emission category and based on three improvement levers: (1) Reducing energy use, (2) Switching to renewable energy, and (3) Compensating residual emissions.

Scope 1 & 2: Manufacturing and Buildings

Energy Savings Master Plans 2020–2025 and 2026–2030

• Description: Multi-year plan covering five largest industrial sites with 80+ projects aimed at reducing energy consumption through infrastructural improvements
• Scope: Own operations (manufacturing locations and office buildings worldwide)
• Time horizon: 2020–2025 (current), 2026–2030 (continuation)
• Resources:
  • Capex 2024: €126 million (including energy grid in Veldhoven, building renovations, solar panels in San Diego)
  • Capex 2025 (expected): €63 million (building renovations, solar panels, infrastructural improvements)
  • Personnel: ~10 FTEs
  • Opex: €1.4 million (FTE costs)
• Key activities:
  • Reusing waste heat from factories for office heating through energy grids
  • Installing solar panels (target: 9,000+ panels by 2025, aiming for 20,000 in 2026–2030 period)
  • Replacing chillers and optimizing air-conditioning systems
  • Adiabatic humidification
  • LED lighting upgrades
  • Process cooling water optimization
• Expected outcomes: 100 TJ annual energy savings by 2025 (target met in 2024); equivalent to 14 kt CO2e reduction
• Link to targets: Contributes to 90% absolute scope 1 & 2 reduction by 2040; SBTi-approved 25.2% reduction by 2025

Renewable Electricity Sourcing

• Description: Shift to bundled renewable electricity through long-term power purchase agreements (PPAs) and on-site generation
• Scope: Own operations worldwide
• Time horizon: Ongoing through 2025 and beyond
• Resources:
  • Opex 2024: €4.8 million (energy attribute certificates)
  • Opex 2025 (expected): €7.3 million (EACs)
• Key agreements:
  • Netherlands: 10-year PPA for green electricity (operational)
  • Taiwan: 5-year PPA providing ~65% renewable electricity (operational 2024)
  • South Korea: Yearly contract (2024)
  • Germany (Berlin): Two-year contract through 2025
• Expected outcomes: 96% renewable electricity achieved in 2024; target 100% by 2025
• Link to targets: Contributes to scope 1 & 2 GHG neutrality by 2025

Further Gas Reduction and Green Gas Sourcing

• Description: Assessment of further natural gas reduction possibilities and evaluation of renewable gas market
• Scope: Own operations
• Time horizon: Medium to long term (assessment ongoing)
• Resources: Not quantified
• Expected outcomes: Natural gas reduction in Veldhoven from 4.4 million m³ (2019 baseline) to 2.3 million m³ by 2025

Compensating Residual Emissions (Scope 1 & 2)

• Description: Purchasing and retiring voluntary emission reduction certificates (VERs) for residual emissions starting 2025
• Scope: Own operations, business travel, employee commuting
• Time horizon: Starting 2025
• Resources: Not quantified for 2025
• Quality criteria: Nature-based removal projects (afforestation/reforestation); validated against leading third-party standards
• Link to targets: Enables GHG neutrality for scope 1 & 2 by 2025

Scope 3: Supply Chain (Purchased Goods & Services)

Supplier Commitments to Reduce Emissions by 2030

• Description: Engagement and collaboration with suppliers through Strategic Sourcing & Procurement (SS&P) ESG sustainability program
• Scope: Upstream value chain (suppliers)
• Time horizon: Near-term (commitments by 2026); medium-term (neutrality by 2030)
• Resources:
  • Personnel: Increased from 2 to 5 FTEs in 2024 (expected stable in 2025)
  • Opex: €0.5 million (FTE costs)
• Key activities:
  • Letter of Commitment (LOC) requiring suppliers to measure emissions, set reduction targets, and collaborate on remanufacturing
  • Executive review meetings with top 80% suppliers
  • Bi-monthly online forums (~250 supplier representatives)
  • Supplier capability maturity assessments
  • Training programs on GHG emissions calculation
• Expected outcomes: 75% commitment from top 80% suppliers by 2026 (9% achieved by end 2024)
• Link to targets: Enables scope 3 supply chain GHG neutrality by 2030

First CO2e Footprint Estimate Pilot

• Description: Life cycle assessment (LCA) pilot for one system to understand material-level emissions and inform design optimization
• Scope: Own operations and upstream
• Time horizon: Pilot completed 2024; scaling planned
• Resources: Not quantified
• Expected outcomes: Build internal LCA capabilities; identify high-emission materials and reduction opportunities

Scope 3: Logistics

Air-to-Ocean Freight Program

• Description: Shift transportation modes from air to ocean freight for modules, systems, tools, and packaging
• Scope: Upstream and downstream logistics
• Time horizon: Ongoing pilots; scaling toward 2030
• Resources:
  • Personnel: 14 FTEs dedicated to air-to-ocean project
  • Opex: €2.0 million (FTE costs)
  • Capex 2024: Increased leased ocean containers by 3 (€0.3 million annual increase)
  • Capex 2025 (expected): €13 million (pool of transport tools including 30 leased ocean containers)
  • Total budgeted: €10 million for transport tools pool
• Key activities:
  • Development of specialized reefer containers for safe ocean transport
  • DUV reticle-stage packaging returned to Wilton (saved ~11 kt CO2e)
  • Tools/packaging for system shipments returned to Veldhoven (saved ~50 kt CO2e)
  • Metrology packaging returned from Asia (saved 0.15 kt CO2e)
  • First new DUV and YieldStar systems shipped to customer by ocean
• Expected outcomes: 70–85% cost reduction and 95% CO2e reduction per kg shipped (vs. air freight)
• Link to targets: Contributes to scope 3 logistics GHG neutrality by 2030

Sustainable Aviation Fuel (SAF) for Logistics

• Description: Purchase of SAF to reduce emissions from unavoidable air freight
• Scope: Upstream and downstream logistics
• Time horizon: Ongoing
• Resources:
  • Opex 2024: €0.4 million (ASML contribution); €1.6 million total SAF used for ASML air freight
  • Opex 2025 (expected): Increase in line with business growth
• Expected outcomes: 4.5 kt CO2e reduction (1.4% of total freight emissions in 2024)
• Link to targets: Reduces scope 3 category 4 emissions toward 2030 neutrality

Scope 3: Business Travel

Strict Need-to-Travel Policy and Modal Shift

• Description: Reduce business travel through strict policy, encourage train travel for specific destinations (Berlin, London), switch to electric rental vehicles
• Scope: Global business travel
• Time horizon: Ongoing through 2025
• Resources: Not quantified (travel budget reductions per FTE)
• Expected outcomes: Emissions of 1.48 t per FTE in 2024 (50% reduction vs. 2019 baseline of 3.88 t per FTE)
• Link to targets: Contributes to GHG neutrality for business travel by 2025; aligned with Dutch Business Sustainable Mobility Pledge (50% reduction by 2030)

Sustainable Aviation Fuel (SAF) for Business Travel

• Description: Purchase of SAF for portion of global business air travel
• Scope: Global business travel
• Time horizon: Ongoing through 2025
• Resources:
  • Opex 2024: €3.6 million (contribution to airline SAF program)
  • Opex 2025 (expected): Similar amount
• Expected outcomes: Reduction of business travel emissions from 97 kt (2019) to 65 kt (2024)
• Link to targets: Contributes to GHG neutrality for business travel by 2025

Compensating Residual Emissions (Business Travel)

• Description: Purchase and retirement of VERs for residual business travel emissions starting 2025
• Scope: Global business travel
• Time horizon: Starting 2025
• Resources: Expected in line with current year emissions (not quantified)
• Link to targets: Enables GHG neutrality for business travel by 2025

Scope 3: Employee Commuting

Global Decarbonization Project

• Description: Seven-location pilot to understand commuting habits, improve data quality, and promote greener commute modes worldwide
• Scope: Global employee commuting
• Time horizon: Pilot in 2024; targeted interventions planned 2025+
• Resources:
  • Personnel: 2 FTEs
  • Opex: €0.3 million (FTE costs)
  • Opex 2024: €1.1 million (lease of 1,000 campus e-bikes)
  • Capex 2024: €1 million (EV chargers)
• Key activities:
  • Employee commuting survey across seven representative locations
  • Provision of national railway commuting cards (Netherlands)
  • Campus e-bikes and on-demand shuttle buses
  • Increased cycling reward from €0.21 to €0.35 per km
  • Cycling lessons for international colleagues
  • EV charging infrastructure
  • Shuttle bus services from park-and-ride locations
• Expected outcomes: Emissions reduced from 42 kt (2019) to 36 kt (2024) despite headcount growth
• Link to targets: Contributes to GHG neutrality for commuting by 2025; aligned with Dutch Business Sustainable Mobility Pledge

Compensating Residual Emissions (Commuting)

• Description: Purchase and retirement of VERs for residual commuting emissions starting 2025
• Scope: Global employee commuting
• Time horizon: Starting 2025
• Resources: Not quantified
• Link to targets: Enables GHG neutrality for commuting by 2025

Scope 3: Product Use

Energy Reduction Roadmaps 2030 (EUV, DUV, Metrology & Inspection)

• Description: System-level energy efficiency improvements across all main product lines through design optimization
• Scope: Downstream (customer operations)
• Time horizon: Roadmaps to 2030 (draft to 2040); ongoing R&D
• Resources: Not quantified (embedded in R&D)
• Key activities:
  • Introduction of sleep modes for lithography systems
  • Improved energy efficiency of EUV source
  • Higher-temperature cooling water compatibility for future EUV systems
  • Sustainable design principles for reusability and recyclability
  • Collaboration with suppliers on upgradeable, refurbish able, repairable materials
• Expected outcomes: Decreasing energy use per wafer pass (e.g., NXE:3800E: 5.9 kWh per wafer pass in 2024; target 5.1 kWh by 2025)
• Link to targets: Contributes to scope 3 product use GHG neutrality by 2040; supports 97% intensity reduction

Semiconductor Climate Consortium (SCC) Collaboration

• Description: Founding member of industry consortium to promote renewable electricity availability in customer regions and share best practices
• Scope: Downstream (customer operations) and industry-wide
• Time horizon: Long-term (ongoing)
• Resources: Not quantified
• Key activities:
  • Encourage customers to commit to transparency (annual scope 1, 2, 3 reporting)
  • Support customer targets for GHG neutrality by 2040
  • Promote renewable electricity access in regions where customers operate
  • Share technology innovations and decarbonization best practices
• Expected outcomes: Largest portion of product use emission reductions expected from customer uptake of renewable electricity
• Link to targets: Critical enabler for scope 3 category 11 GHG neutrality by 2040

Cross-Cutting: Internal Carbon Price

Internal Carbon Price Mechanism

• Description: Apply internal carbon price (€200/tonne CO2e, indexed 4% annually) to guide investment decisions and factor GHG externalities into business cases
• Scope: Initially scope 1, 2, and product use (scope 3 category 11); planned expansion to external categories
• Time horizon: Roll-out to all intended scope by 2025
• Resources: No direct financial flow; affects capex decision-making
• Expected outcomes: Increased internal awareness; support for carbon-reduction capex investments
• Link to targets: Supports achievement of all emission reduction targets through better-informed investment prioritization

Cross-Cutting: Green Bond Framework

Green Bond Issuance Platform

• Description: Established 2022 Green Bond Framework aligned with ICMA Green Bond Principles to finance/refinance green projects
• Scope: Own operations and value chain
• Time horizon: Established 2022; no issuance after 2022
• Resources: No bonds issued post-2022
• Link to targets: Platform available for financing energy efficiency and climate action investments

Summary of Total Quantified Resources

Manufacturing & Buildings:

• 2024 Capex: €126 million
• 2025 Capex (expected): €63 million
• 2024 Opex (EACs): €4.8 million
• 2025 Opex (EACs, expected): €7.3 million
• Personnel: ~10 FTEs

Supply Chain:

• Personnel: 5 FTEs
• Opex: €0.5 million

Logistics:

• 2024 Capex: €0.3 million (containers)
• 2025 Capex (expected): €13 million (containers + transport tools)
• 2024 Opex (SAF): €0.4 million (ASML); €1.6 million (total used)
• Opex (containers, SAF): Included in Cost of Sales
• Personnel: 14 FTEs (€2.0 million)

Business Travel:

• 2024 Opex (SAF): €3.6 million
• 2025 Opex (SAF, expected): Similar to 2024

Commuting:

• 2024 Capex (EV chargers): €1 million
• 2024 Opex (e-bikes): €1.1 million
• Personnel: 2 FTEs (€0.3 million)

Product Use:

• Resources: Embedded in R&D (not separately quantified)

Total estimated resources disclosed:

• 2024 Capex: ~€127 million
• 2025 Capex (expected): ~€76 million
• 2024 Opex: ~€12 million
• 2025 Opex (expected): ~€7 million (EACs only; others not quantified)
• Personnel: ~31 FTEs across programs

Targets related to climate change mitigation and adaptation

ASML has set comprehensive GHG emission reduction targets across its value chain, with Science Based Targets initiative (SBTi) validation for near-term targets.

GHG Neutrality Ambitions (Net Targets)

Gross Emission Reduction Targets (Scope 1 & 2)

Gross Emission Reduction Targets (Scope 3)

Scope 3 absolute emissions in 2024: 12.0 Mt CO2e (baseline 2019: 7.6 Mt CO2e)

Topic-Specific Targets

Energy Savings (Manufacturing and Buildings)

Supplier Commitments (Scope 3 Upstream)

Product Energy Efficiency (Scope 3 Downstream)

Business Travel

Employee Commuting

Logistics

Purchased Goods and Services

Product Use

Target Methodology

Scope 1 & 2: Absolute reduction targets aligned with 1.5°C scenario. SBTi validated near-term target (2025) using 'other industries' pathway.

Scope 3: Intensity reduction targets per €m gross profit, covering upstream (categories 1, 2, 4, 6, 7) and downstream (category 11). SBTi validated near-term target (2025).

GHG Neutrality: Remaining emissions after reduction efforts will be compensated by equivalent carbon credits verified against recognized quality standards. Offsetting begins in 2025 for scope 1, 2 and business travel/commuting; 2030 for supply chain (via suppliers); 2040 for product use.

Internal Carbon Price: €200 per tonne CO2e (2024), indexed at 4% per year, applied to investment decisions for scope 1, 2 and product use emissions.

Energy consumption and mix

Scope and reporting boundaries

ASML reports energy consumption covering all manufacturing locations and both owned and leased office locations worldwide (160+ buildings in total from 2024 onward, expanded from 20 buildings in the 2019 baseline which accounted for >95% of emissions). Scope 2 emissions arise from purchased electricity, which accounts for approximately 80% of ASML's energy use. Scope 1 emissions comprise direct CO2 emissions from natural gas use for heating and humidification, process CO2, and lease cars.

Energy consumption and mix (2024)

*Projected for 2025 in Veldhoven location only; reduced from 4.4 million m³ baseline (2019) through energy grid and other measures.

Total energy consumption

ASML does not report total energy consumption in standardized units (MWh, GWh, TJ) in a single consolidated figure. The company reports:

• Energy savings of 100 TJ/year achieved through infrastructure projects (2021-2025)
• Scope 2 electricity accounts for approximately 80% of energy use
• Scope 1 natural gas consumption represents the smaller portion

Energy intensity

Not disclosed in standardized units (e.g., MWh per million EUR revenue).

Disaggregation by energy source

ASML does not provide the full ESRS E1-7 disaggregated energy mix table showing:

• Fuel consumption from coal, crude oil/petroleum, natural gas, other fossil sources (separately)
• Purchased electricity/heat/steam/cooling from fossil vs renewable sources
• Self-generated non-fuel renewable energy
• Nuclear energy consumption
• Total fossil, renewable, and total energy consumption with percentages

The company reports:

• Renewable electricity: 96% of total electricity purchased (2024), with target of 100% by 2025
• Natural gas: Primary fossil fuel source, used for heating and humidification; ~2.3 million m³ projected for 2025 (Veldhoven only)
• Solar generation: >9,000 solar panels planned by 2025 across EMEA, US, and Asia sites (projected ~30 TJ/year savings)
• Renewable sources: Long-term power purchase agreements (PPAs) in Netherlands (10-year), Taiwan (5-year, operational 2024), South Korea (yearly contract 2024), Germany (through 2025)

Methodology notes

• Base year: 2019 (pre-COVID, aligns with SBTi-approved targets)
• 2024 reporting scope expanded to all 160+ buildings worldwide (vs. 20 buildings in 2019 baseline)
• Market-based emission factors used for scope 2 calculations
• Energy attribute certificates (EACs) purchased: €4.8 million opex in 2024
• Location-based emission factors: 14 kt CO2e equivalent for 100 TJ savings target

Gross Scopes 1, 2, 3 and Total GHG emissions

Overview

ASML reports greenhouse gas emissions across Scopes 1, 2, and 3. The company aims for greenhouse gas neutrality, defined as offsetting remaining emissions after reaching GHG emission reduction targets with the same amount of metric tons of carbon credits verified against recognized quality standards. Information is based on ASML's internal environmental management system and the Greenhouse Gas Protocol.

Scope 1 and 2 emissions (tCO2e)

Note: The report presents combined Scope 1 and 2 emissions as 32.8 kt CO2e for 2024. The 2023 figure is not explicitly stated in the excerpts provided. Market-based vs. location-based breakdown for Scope 2 is not disclosed in the available excerpts.

Scope 3 emissions (tCO2e)

The report references Scope 3 emissions and specifically mentions "Scope 3 upstream supply chain emissions" as part of the company's ambition to become greenhouse gas neutral by 2030. The excerpts note discussion of "Supply chain emissions (scope 3 upstream)" and reference to achieving greenhouse gas neutrality for scope 3 upstream supply chain emissions by 2030.

Breakdown by GHG Protocol category: Not disclosed in the available excerpts. The report references upstream supply chain (likely covering categories such as purchased goods and services, capital goods, upstream transportation, and fuel/energy-related activities) but does not provide a detailed breakdown by the 15 GHG Protocol categories.

Total GHG emissions

Calculation note: Total is the sum of Scope 1+2 (32.8 kt = 0.0328 Mt) and Scope 3 (12.0 Mt), approximately 12.03 Mt CO2e.

GHG intensity

GHG intensity metrics (e.g., tCO2e per € million revenue) are not disclosed in the available excerpts.

Biogenic CO2 emissions

Biogenic CO2 emissions reported separately from Scope 1 are not disclosed in the available excerpts.

Regulated emissions (e.g., EU ETS)

Regulated emissions under schemes such as EU ETS are not disclosed in the available excerpts.

Methodology notes

• Emissions data is based on ASML's internal environmental management system and publicly available information, including guidance from the Greenhouse Gas Protocol.
• The report notes inherent uncertainty in estimates due to data being derived from various sources and processed differently across operating subsidiaries and departments.
• The company cautions not to give undue weight to such data given the degree of uncertainty in estimations.
• The report is prepared in accordance with ESRS (European Sustainability Reporting Standards) requirements as of 2024.
• Scope 3 upstream supply chain emissions are a focus area, with initiatives on supplier data sharing and collection, cross-company and cross-industry collaboration, and identification of decarbonization levers beyond tier 1 suppliers.

GHG removals and GHG mitigation projects financed through carbon credits are addressed as part of our greenhouse gas neutrality ambition and carbon credit strategy.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Phase-in Exemption Applied

ASML has applied the phase-in provision for ESRS E1-9 (Anticipated financial effects from material physical and transition risks and potential climate-related opportunities). This disclosure requirement is not included in the 2024 sustainability statement.

As indicated in the reference table:

• ESRS E1 Climate change - E1-9: Anticipated financial effects from material physical and transition risks and potential climate-related opportunities - Not included - Phase-in provision applied

Additionally, under ESRS 2 General disclosures SBM-3, the company states: "Phase-in provision applied for DR48e and AR18 (anticipated financial effects)".

Policies related to pollution are integrated into our environmental management system and ESG sustainability framework.

Actions and resources related to pollution are addressed through our environmental programs and waste reduction initiatives.

Targets related to pollution include our waste reduction aims and environmental performance targets.

Pollution of air, water and soil is managed through our environmental management system and monitoring programs.

Substances of concern and substances of very high concern are managed through our supply chain requirements and product stewardship programs.

Anticipated financial effects from pollution-related impacts, risks and opportunities are integrated into our risk management and business planning processes.

Policies related to water and marine resources are part of our environmental management system.

Actions and resources related to water and marine resources are addressed through our environmental programs.

Targets related to water and marine resources are integrated into our environmental performance targets.

Water consumption

Water usage context

ASML uses water in three key ways in its factories:

1. To remove heat loads and maintain systems at constant temperature – internal cooling circuits are designed as 'closed-loop' (recycling) systems to limit water consumption
2. Heat loads are removed in cooling towers using evaporation of lower-quality water
3. Deep ultraviolet (DUV) systems use ultrapure water – which is currently only partially recycled – in the immersion hood

Water metrics (2024)

Total water withdrawal in 2024: 1,432,410 m³

Water-related risks

ASML's water-related risk assessment in a 4°C scenario identifies:

Customers:

• Manufacturing facilities of key customers are especially exposed to effects of water stress, droughts, storms and typhoons
• Customers are sensitive to water stress and drought due to heavy reliance on water for semiconductor manufacturing processes
• Mitigating measures: Customers implementing water efficiency retrofits; ASML working on technical solutions to reduce water needed for cooling EUV machines

Own operations:

• Droughts could result in disruption of production due to water-dependent processes
• Mitigating measures include water reserve controls and maintenance management

DNSH criteria (EU Taxonomy)

For buildings in scope for renovation (CCM 7.2), the DNSH criteria relating to water usage were not met, resulting in 0% alignment reported on CCM 7.2.

Anticipated financial effects from water and marine resources-related impacts, risks and opportunities are integrated into our risk management processes.

Circular economy

Page 234 Circular economy

Policies related to resource use and circular economy are detailed in our circular economy section, including our approach to parts reuse and refurbishment.

Circular economy

Page 234 Circular economy

Actions and resources related to resource use and circular economy include our refurbishment initiatives and recycling programs.

Targets related to circular economy

ASML has disclosed the following quantified targets related to resource use and circular economy:

Target 1: Waste intensity reduction

Progress to date (2024): 429 kg/€m revenue

Note: Waste from operations is defined as any substance or object the holder discards, or intends or is required to discard including waste from activities, resources and relationships owned or controlled by ASML (excluding construction waste). The company states this target is internal - no external stakeholders were involved in the target-setting process.

Target 2: Recycling rate

Progress to date (2024): 63%

Note: The company originally reported a 90% target for 2025 in 2023, but adjusted this to 65% in 2024 after insights revealed that waste companies were using different definitions for recycling rates. The alignment of definitions worldwide resulted in a significant decrease in the reported recycle rate. The company acknowledged that achieving a 90% recycling rate by 2025 was not realistic.

Qualitative ambition

ASML states an ambition of zero waste to landfill and incineration by 2030 worldwide, though this is not presented as a quantified target with baseline.

Waste generation 2024

In 2024, ASML generated 13,537 tonnes of PR and NPR waste (including construction waste).

ESRS E5-4 Resource Inflows

ASML discloses resource inflow data in the Circular Economy: Metrics table (page 245), covering biological materials and secondary reused/recycled components and materials.

Resource Inflow Metrics (2024)

Narrative Context

ASML reports 800 tonnes of sustainably sourced biological materials and 10,963 tonnes of secondary reused components and materials (including packaging) used in manufacturing during 2024. However, the company does not provide:

• Total overall weight of products and materials used
• Percentage splits for biological vs. non-biological materials
• Percentage of secondary materials as a proportion of total materials
• Breakdown by specific material types (metals, minerals, plastics, etc.)

The company acknowledges in its Basis for Preparation (page 170) that "resource inflows and outflows" are subject to "sources of estimation and outcome uncertainty" and that "accumulated estimation techniques may lead to either under- or overstatement of total mass flows."

ASML's scope for resource inflows includes systems, parts and tools including packaging and transport tools, as identified in their material sub-topics under circular economy (page 234).

Resource outflows

Reuse and refurbishment

ASML refurbishes and upgrades older lithography systems to extend their lives, offering associated services and support. The company currently offers refurbished PAS 5500 and first-generation AT, XT and NXT systems. ASML systems have a very long operational lifetime that often exceeds their role at the initial customer – remarkably, 95% of the systems sold in the last 30 years are still in use.

In 2024, ASML shipped the first refurbished NXT 1980Di system from the TWINSCAN factory to a customer, addressing a specific market segment. The NXT 1980Di refurbishment represents an enhancement to the portfolio, utilizing a new industrialized approach for volume, efficiency, quality and cost.

Parts reuse rate

88% reuse rate of parts returned from field and factory (2024)

This metric indicates the proportion of parts returned from customer sites and internal operations that are successfully reused rather than discarded.

System lifetime

ASML systems have demonstrated exceptional durability, with 95% of all systems sold over the last 30 years still in operational use. The company's installed base continues to grow, comprising not only new systems but refurbished ones with new owners in new markets and applications.

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Phase-in exemption applied

ASML has applied the phase-in provision for E5-6 – Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities. This disclosure requirement is not included in the 2024 sustainability statements.

Waste

Zero waste target

ASML has set a target to achieve zero waste from operations to landfill and incineration, with specific target dates established for achieving this goal.

Waste management approach

The company's environmental programs focus on waste reduction and circular economy principles. ASML's sustainability strategy includes:

• Recycling and refurbishment initiatives
• Parts reuse from field and factory operations (88% reuse rate achieved in 2024)
• Energy-saving strategies
• Assumptions underlying projections related to ESG targets
• Reliance on suppliers to meet ESG goals to enable ASML to meet its ESG objectives

ASML actively participates in the circular economy through its refurbished products business, which refurbishes and upgrades older lithography systems to extend their operational lives. This approach supports sustainable product use and ensures used systems still deliver the quality ASML stands for.

Note: Specific quantitative waste data (total waste generated, hazardous vs non-hazardous breakdown, waste diverted from disposal vs directed to disposal) is not disclosed in the available excerpts from this report.

Policies related to own workforce

ASML discloses several policies relevant to its own workforce under ESRS S1-1:

Code of Conduct

Scope: All employees, directors and officers of ASML and the ASML group of companies. The company expects third parties (any non-ASML legal entity or individual with whom ASML engages in a business relationship) to participate in a common effort toward protecting human rights of the workforce.

Key content: The Code of Conduct addresses:

• Prohibition of discrimination, harassment, bullying or retaliation
• Business ethics principles
• Human rights commitments
• Anti-bribery and anti-corruption

Links to international standards: The Code of Conduct is linked to the UN Guiding Principles on Business and Human Rights (UNGPs), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, and International Labor Organization (ILO) core conventions.

Approval and oversight: The revised Code of Conduct was reviewed by the Audit Committee in 2024.

Public availability: Available at asml.com

Monitoring: Compliance is discussed on multiple occasions during Audit Committee meetings. Violations are considered significant breaches and may lead to disciplinary measures up to and including dismissal.

Human Rights Policy

Scope: Applies to all workers – employees, directors and officers of ASML and the ASML group of companies. In some cases, the scope extends to non-employees, either working for temporary placement agencies, on behalf of ASML or as individual contractors (self-employed people).

Key content: The policy enshrines basic Human Rights due diligence principles and covers:

• Respecting fundamental human rights
• Prevention of forced labor (including bonded or indentured labor)
• Prohibition of child labor
• Freedom of association
• Non-discrimination
• Occupational health and safety
• Adequate wages and social security
• Access to grievance mechanisms
• Conflict minerals and responsible sourcing

Links to international standards: Based on:

• UN Guiding Principles on Business and Human Rights (UNGPs)
• OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
• International Labor Organization (ILO) core conventions (ILO Declaration on Fundamental Principles and Rights at Work)
• UN Declaration of Human Rights
• UN Global Compact
• International Bill of Human Rights
• UN Women's Empowerment Principles
• UNICEF's Children's Rights and Business Principles
• UN International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families

Approval and oversight:

• Human Rights Committee chaired by the Head of Ethics & Business Integrity and Human Rights
• Committee reports to the Compliance, Ethics, Security and Risk Committee (CESR), chaired by the CFO
• CESR sub-committee (CESR Ethics Committee) is facilitated by the Head of Ethics & Business Integrity and Human Rights and chaired by the Chief Legal Officer
• Overseen by the Supervisory Board through its committees

Public availability: Available at asml.com. The company plans to update the Human Rights Policy in 2025.

Monitoring:

• Human Rights Saliency Assessment conducted in 2023-2024
• Management gap analysis to identify capacity-building needs
• External stakeholder engagement with over 20 organizations
• No grievances about breaches of Human Rights received in 2024

RBA Code of Conduct

Scope: All workers at ASML. As a member of the Responsible Business Alliance (RBA), ASML has adopted the RBA Code of Conduct. The company expects suppliers to comply with the RBA Code of Conduct and cascade this requirement to their suppliers.

Key content: Standards relating to:

• Labor (human rights of all workers)
• Health and safety (minimizing work-related injury and illness)
• Environment
• Ethics
• Prohibition of forced labor, including preventing payment of improper recruitment fees

Links to international standards: The RBA Code of Conduct aligns with international standards including ILO conventions and UNGPs.

Monitoring:

• Third-party RBA audits
• RBA Self-Assessment Questionnaire (SAQ) for suppliers
• Additional controls to prevent payment of improper recruitment fees, especially for migrant workers

Attractive Workplace for All Policy

Scope: All workers – employees, directors and officers of ASML and the ASML group of companies. In some cases, the scope extends to non-employees, either working for temporary placement agencies, on behalf of ASML or as individual contractors. Where staff work at customers' sites, ASML makes reasonable efforts to ensure consistency with the policy.

Key content: The policy is based on four pillars:

• Making the organization more scalable and sustainable by ensuring clarity and knowledge-sharing
• Building a workplace that works for everyone by fostering inclusion, diversity and belonging
• Investing in people development for all employees and strengthening leadership
• Building a pipeline of future leaders

The policy covers:

• Talent attraction, employee engagement and retention
• Learning and development
• Diversity and inclusion
• Occupational health and safety
• Labor conditions
• Well-being

Links to international standards: Closely linked to the ASML Code of Conduct, RBA Code of Conduct, ASML Human Rights Policy and ASML Global Diversity and Inclusion Policy.

Global Diversity and Inclusion Policy

Scope: The company is committed to treating all employees with dignity and respect, to being an equal opportunity employer, and to cultivating a diverse and inclusive workforce.

Key content:

• Prohibition of discrimination based on age, race, color, religion, sex, gender, gender identity or expression, sexual orientation, national origin and/or other characteristics
• Reasonable accommodations for people with special needs, including neurodiversity and workers with disabilities
• Hiring, promotion and compensation without regard to protected characteristics

Approval and oversight: The ESG Committee of the Supervisory Board oversees diversity and inclusion matters. Diversity and inclusion is managed within the Human Resources department.

Public availability: Available at asml.com

Monitoring: Tracked through performance indicators covering:

• Ability to attract women from various backgrounds
• Representation of women at leadership levels
• Employee engagement survey inclusion score

Speak Up and Non-retaliation Policy

Scope: Available for employees, on-site external workers, workers across the value chain, people in affected communities, and any third party.

Key content:

• Grievance mechanism for raising concerns about potential Code of Conduct violations, including environmental impacts and human rights
• Protection against retaliation for those who speak up
• Support for employees or partners who refuse to engage in anticompetitive conduct

Public availability: The company plans to update this policy in 2025 in alignment with the updated Human Rights Policy.

Monitoring:

• Investigations overseen by CESR Ethics Committee
• Ethics cases reported to CESR
• No grievances about breaches of Human Rights received in 2024

Environment, Health and Safety (EHS) Management System

Scope: All ASML sites and customer services locations worldwide. Covers occupational health and safety of everyone whose workplace is controlled by ASML, including all employees and other workers not employed by ASML.

Key content:

• Protection of people, products, assets, and the environment
• Incident reporting requirements
• Hazard and risk evaluations
• Safety Gemba Walks
• Training and awareness

Links to international standards: Based on and compliant with ISO 45001 occupational health and safety standard.

Approval and oversight: Assessed annually as part of internal corporate EHS audit program (not externally certified).

Monitoring:

• Implemented worldwide at all sites
• Recordable incident rate tracking
• Target: achieve a recordable incident rate of 0.16 or below by 2025
• 2024 performance: 0.19 recordable incident rate

Competition Law Compliance Policy

Scope: Company-wide compliance expected from all employees and business partners (customers, suppliers, consultants, contractors and intermediaries).

Key content:

• Commitment to fair competition principles
• Prohibition of conduct illegal under applicable competition laws
• Expectation of high ethical standards from partners

Approval and oversight: The Audit Committee reviews compliance matters, including competition law.

Public availability: A public version was made available in 2020 and updated in 2021, available at asml.com.

Monitoring:

• Risk assessments of competition law focus areas
• Training (computer-based and in-person)
• Awareness promotion through multiple channels
• No fines for breaches of competition law incurred in 2024

Additional policy commitments

ASML also references:

• Tax principles and policy (outlined in Approach to Tax Report)
• Remuneration policy for the Board of Management and employees
• Data privacy policies (managed by expert teams)
• Export control policies (managed by Export Control department)

Note on US Executive Order 14173: ASML states that its diversity and inclusion targets and policy will not apply to US employees to the extent this would conflict with Executive Order 14173 or other applicable law, regulation or orders.

Processes for engaging with own workforce and workers' representatives about impacts are addressed through our employee engagement and communication channels.

Processes to remediate negative impacts and channels for own workforce to raise concerns are established through our employee feedback systems and grievance mechanisms.

Taking action on material impacts on own workforce

Diversity & Inclusion Program

Action overview:

• Since 2022, gender diversity targets have been set as part of ASML's ESG sustainability strategy and as part of the long-term incentive for the Board of Management and senior management
• ASML has set up a company-wide diversity & inclusion program

Scope: Own operations (entire workforce)

Current performance (2024):

• Gender diversity: 26% inflow of women
• Gender diversity: 12% representation of women in job grade 13+
• Women in entire workforce 2024: 21% (headcount)

Resources allocated (non-financial):

• Board of Management sets, promotes and monitors diversity and inclusion initiatives, and leads company-wide accountability for goals
• Global D&I team, including a Chief Diversity Officer, responsible for driving initiatives related to D&I across ASML

Link to policy/target:

• Gender diversity targets are part of ASML's ESG sustainability strategy
• Gender diversity targets are part of the long-term incentive for the Board of Management and senior management

Board of Management Succession and Development

Action overview:

• Supervisory Board selects candidates for Board of Management with due observance of objective to foster a diverse and inclusive working environment
• Internal development efforts for potential Board of Management members strive for participation of a diverse group of employees, specifically senior leadership
• Search firms engaged are specifically directed to include diverse candidates in general and multiple female candidates in particular

Scope: Own operations (senior leadership)

Approach:

• Fill vacancies by considering candidates that bring required expertise and contribute to diversity
• Assess candidates on merit against objective criteria and specific profile while having due regard for relevant aspects of diversity
• Continuously strive for more balanced gender representation

Targets related to own workforce

ASML has set gender diversity targets as part of its ESG sustainability strategy and long-term incentive for the Board of Management and senior management. The targets are disclosed as follows:

Gender Diversity Targets

Context:

• Gender diversity targets have been set since 2022 as part of ASML's ESG sustainability strategy
• These targets are included in the long-term incentive compensation for the Board of Management and senior management
• The Supervisory Board included performance metrics aimed at improving the representation of women in senior leadership in the Board of Management's long-term incentive compensation
• For the Board of Management specifically, ASML aims to foster a diverse and inclusive working environment and continuously strives for more balanced gender representation
• The document notes that "increasing gender diversity at the Board of Management remains challenging and is expected to take time"

Note: The excerpts reference that targets have been set but do not disclose the specific quantified target values or target years. Only current performance values for 2024 are disclosed.

Attractive workplace for all

Page 258 Attractive workplace for all

44,027 Total employees (FTEs)

• 25,848 EMEA
• 9,699 Asia
• 8,480 US

148 Nationalities

Characteristics of the undertaking's employees are detailed in our workforce data.

Characteristics of non-employees in the undertaking's own workforce

Disclosure Status

ASML has applied the phase-in provision for ESRS S1-7. As stated in the Reference table (page 286):

ESRS S1-7 – Characteristics of non-employees in the undertaking's own workforce: Not included – Phase-in provision applied.

Context on Non-employees

ASML provides definitional context for non-employees in their Definitions section (page 407):

Non-employees: Includes both individual contractors supplying labor to ASML ('self-employed people') and workers provided by ASML primarily engaged in 'employment activities' (NACE Code N78).

The company distinguishes between:

• 'Temporary employees' reported in Consolidated financial statements: comprises contractors or agency placements that meet the definition of 'non-employee' under ESRS.
• 'Temporary employees' under ESRS: refers to 'payroll employees' as reported in Consolidated financial statements that have a finite duration employment contract.

Own workforce: Aggregate of 'Employees' and 'Non-employees'.

Health and Safety Metrics (Non-employees)

The only metric partially disclosed for non-employees relates to health and safety. In the Additional disclosures section (page 286), ASML notes:

S1-14 – Health and safety metrics: Includes DR88b DR88c Number of fatalities and number and rate of work-related accidents – Phase-in provision applied for non-employees.

No quantitative data on non-employee characteristics, headcount, or breakdown by type (contractor, agency, self-employed) is disclosed for the 2024 reporting period.

Collective bargaining coverage and social dialogue

Collective bargaining coverage

Percentage of total employees covered by collective bargaining agreements: 61%

Coverage by region

The following table shows the percentage of employees covered by collective bargaining agreements and workplace representation, by significant employment regions/countries (as of December 31, 2024):

Collective labor agreements by country

The Netherlands (with Metalektro): The Metalektro collective labor agreements (CLAs) are effective for the industry in which ASML operates and applicable to all employees in the Netherlands within the scope of the CLA.

Belgium, France, Germany, Italy and South Korea:

• Belgium: Collective bargaining agreement with Paritair Committee 200
• France: Participation in the Metallurgie industry agreement (Cymer Light Sources employees fall under the scope of the CLA with Commerces de Gros)
• Germany: Company CLA negotiated with IG Metall for Berlin location (ASML Berlin GmbH)
• Italy: Employees covered by the national collective bargaining agreement (CCNL) for commerce
• South Korea: CLA negotiated with the Chemical, Textile and Food Industrial Union

Social dialogue arrangements

Works Councils: Established in the Netherlands and in Berlin, Germany. In Taiwan and South Korea, employee representatives have been duly elected in accordance with Labor Management Council requirements. In China, pre-existing Works Councils are retained at the HMI facility.

European Works Council: ASML has no existing agreements with a European Works Council (EWC), a Societas Europaea (SE) Works Council or a Societas Cooperativa Europaea (SCE) Works Council.

Meetings with Works Council:

• In the Netherlands: The Works Council meets regularly with the Board of Management and senior management, and meets annually with the delegation of the Supervisory Board. Monthly consultative meetings are held between the Works Council and the 'Bestuurder' (the ASML executive responsible for consulting with the Works Council)
• In Germany (Berlin), Taiwan and South Korea: Quarterly meetings are held between employee representatives and local management representatives

Multi-employer union plan (Netherlands)

23,082 eligible payroll employees in the Netherlands (53.9% of total payroll FTEs) participate in a multi-employer union plan. This plan is managed by PME (Stichting Pensioenfonds van de Metalektro) and covers approximately 1,566 companies and approximately 183,003 contributing members. For 2024, the contribution rate was 28.0%.

Methodology

Collective bargaining coverage: Determined based on the scope stipulated in the respective collective bargaining agreements.

Social dialogue coverage: Determined based on the number of employees within ASML's establishments where Works Council or employee representatives have been duly elected.

Coverage percentages: Calculated per significant employment country (within EEA) or region (outside EEA) in proportion to the total number of employees within the country or region.

Freedom of association

ASML has no indication that it operates in countries where the freedom of association and collective bargaining of ASML employees is restricted. The company strives to comply with the relevant legislation in every country where it operates.

Attractive workplace for all

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21% Women in entire workforce (headcount) 148 Nationalities

Diversity metrics are provided in our attractive workplace section, including gender diversity and nationality representation.

Adequate wages

Benchmark used

ASML compares its lowest base salary with both local minimum wage and local living wage in the countries and regions where it operates. The company states:

"We compare our lowest base salary with the local minimum wage and local living wage in the countries and regions where we operate."

In 2024, ASML updated its approach:

"In 2024, we updated our approach to use the higher of living wage and minimum wage levels in each location where we operate, based on independent third-party benchmarks sourced from a single non-profit organization."

The adequate wage benchmark is defined as:

"The adequate wage benchmark is based on the higher of the most recent minimum and living wage (lower-bound guidance thresholds) per location. The most recent thresholds are sourced from a reputable independent third party."

The specific non-profit organization providing the living wage benchmarks is not named in the disclosure.

Coverage

100% of ASML's employees are paid an adequate wage within all locations where the company operates:

"100% of our employees are paid an adequate wage within all locations we operate in."

Assessment methodology

ASML conducts an annual assessment:

"Adequate wage assessment: Annually at the end of the period for each location where we operate, ASML's lowest annualized wage paid to employees is compared to the adequate wage benchmark."

The ASML lowest wage is defined as:

"ASML lowest wage consists of an annual basic wage at a full-time equivalent basis and fixed payments that are guaranteed to employees at the time of the assessment."

Geographic scope

The assessment is conducted globally across all locations where ASML operates, with annual reviews performed for each location.

Targets and commitments

No specific future targets are disclosed for adequate wages. The company states it will continue to:

"continue to mature our remuneration policies and processes in line with applicable wage laws and strive to ensure our employees remuneration is fair and balanced."

For 2025, ASML indicates it will focus on pay transparency legislation compliance:

"In 2025, we will focus on preparing for pay transparency in view of current legislation in various states in the US, and preparing for upcoming legislation related to the EU Pay Transparency Directive and any other jurisdictions where such legislation might be enacted."

Compensation policy

ASML describes its commitment to fair wages:

"We are committed to paying fair and balanced salaries and benefits. Employee wages must, at a minimum, comply with all applicable wage laws, including those relating to living wages, equal wages for all genders, overtime hours and legally mandated benefits."

"We believe we have robust, longstanding compensation policies in place which aim to ensure people performing and working in similar jobs are paid similarly."

Value chain considerations

While ASML assesses living wage risks in its upstream value chain (particularly in electronics manufacturing and transport sectors), the S1-10 disclosure focuses exclusively on own workforce coverage. The company identified "risks relating to the living wage" in certain supplier sectors but does not disclose whether value chain workers are covered by adequate wage assessments.

Social protection

Disclosure statement

ASML has applied the phase-in provision for ESRS S1-11 (Social protection). The company states in its reference table:

"S1-11 – Social protection: Not included. Phase-in provision applied."

Available information on employee benefits

While comprehensive social protection metrics are not disclosed under ESRS S1-11, ASML provides information on its employee benefits arrangements:

Pension coverage (Netherlands multi-employer union plan)

• Eligible employees in Netherlands: 23,082 payroll employees (53.9% of total payroll FTEs) participate in the PME (Stichting Pensioenfonds van de Metalektro) multi-employer union plan
• Plan type: Defined benefit plan, accounted for as defined contribution
• Contribution rate (2024): 28.0% (2023: 28.0%; 2022: 28.0%)
• ASML's share of total contributions (2024): 18.2% including employee premiums (2023: 18.3%; 2022: 15.7%)
• Expected contribution (2025): €402.0 million (including employee premiums)

Total pension and retirement expenses (all employees)

Other benefits mentioned

ASML provides the following benefits to employees (as referenced in Board of Management remuneration policy, applicable to broader workforce):

• Disability insurance
• Health insurance
• Social security contributions
• Defined contribution pension plans (various locations)
• Deferred compensation plans (US senior employees): liability of €111.8 million as of December 31, 2024 (2023: €94.7 million)

Employee assistance and well-being

• Employee assistance program available in all countries, offering support for personal and work-related problems affecting mental or emotional well-being

Methodology notes

The PME multi-employer union plan covers employees in the Netherlands participating under collective bargaining agreements. ASML also maintains "various other defined contribution pension plans" covering employees inside and outside the Netherlands, but specific coverage percentages by location or employee category are not disclosed.

Persons with disabilities

Not disclosed.

ASML has applied the phase-in provision for ESRS S1-12 (Persons with disabilities) and has not included this disclosure in the 2024 sustainability statement.

Training and skills development metrics

Performance and career development review coverage

Percentage of employees that completed an annual performance and career development review against the total number of employees by gender (2024)

Percentage of employees that completed an annual performance and career development review against the total number of employees eligible for a review by gender (2024)

Average training hours

Average number of training hours per employee (2024)

Average number of training hours per employee by gender (2024)

Total investment in training

Total investment: €12.7 million relating to FTEs included within Consolidated financial statements under Selling, general and administrative costs.

Total training hours

In 2024, a total of 1,771,544 hours of learning were recorded.

Target

By 2025, 80% of all employees should have at least one development item (in progress) in their development plan. In 2024, 81% of all employees had at least one development item in their development plan, as measured at the end of the goal-setting phase of the annual cycle (March 2024).

Methodology notes

Performance and career development review: As part of ASML's Develop & Perform program, employees receive an annual performance and career development review. Employees not eligible are: employees with a hire date on or after October 1, members of the Board of Management, and employees marked as ineligible by Human Resources due to long-term absence.

Training hours methodology: Based on the number of training hours completed and registered by employees on ASML learning platforms. The average training hours per employee are reported by gender categories as defined in S1-6.

Scope: Metrics include all employees, including ASML Berlin GmbH employees from 2024 onward.

Health and safety metrics

Coverage of health and safety management system

100% of employees are covered by ASML's health and safety management system. The system is operated worldwide at all ASML sites and customer services locations, covering everyone whose workplace is controlled by ASML, including all employees and other workers not employed by ASML. The system was recertified for ISO 14001 and structured in accordance with ISO 45001 requirements.

Health and safety performance metrics

Note on work-related fatalities: In 2024, ASML did not encounter any work-related fatalities onsite. Regrettably, the company suffered the loss of a long-standing colleague who collapsed on ASML premises in Veldhoven and was taken by ambulance to hospital where he later passed away. This incident was not work-related.

Methodology notes

• The recordable incident rate target is calculated in line with OSHA guidelines (cases requiring more than first aid per 100 FTE per year), based on 200,000 hours worked. The 2025 target is 0.16 or below.
• For ESRS reporting, the rate of recordable work-related injuries is based on cases per one million hours worked (reported as 1.11 for 2024).
• The OSHA definition of 'work-related' is followed for the target, while ESRS guidance is followed for the ESRS-reported metric.
• Hours worked are estimated based on normal or standard hours of work per location, taking into account paid vacations, paid public holidays and sick leave.
• Phase-in provision applied for: non-employees (DR88b, DR88c), recordable work-related ill health (DR88d), and days lost to injuries, accidents, fatalities or illness (DR88e).
• Benchmark: ASML's recordable incident rate is below the OSHA industry average for the semiconductor industry of 1.4.

Work-life balance metrics are addressed through our employee wellbeing and flexible work arrangements.

Compensation metrics (ESRS S1-16)

Pay gap

ASML reports an unadjusted gender pay gap of 10.2% for 2024. This metric represents the difference in average gross hourly pay levels between female and male employees, expressed as a percentage of the average gross hourly pay level of male employees.

Key drivers of the pay gap:

• Underrepresentation of women in higher-paying roles (generally more senior positions)
• Higher proportion of men across all organizational levels (79% men, 21% women)
• Highest gender disparity in senior management (88% men, 12% women)
• Higher proportion of women in lower employee bands

ASML notes that this is a raw statistic that does not account for objective factors such as job level, performance, location, job family, or tenure. The company states it "cannot attribute the pay gap with pay equity issues per se."

Actions to address:

• Investment in STEM promotion at primary and secondary school levels
• Targets to increase female representation overall and in leadership positions
• Commitment to evaluate and assess pay considering objective factors
• Preparation for EU Pay Transparency Directive (effective July 2026)
• Commitment to close any unjustified pay differences between men and women

Comparability note: A comparison to previous pay gap reporting under GRI is not available due to substantial differences in methodology and underlying data required in accordance with ESRS.

Remuneration ratio

ASML reports an annual total remuneration ratio of 43:1 for 2024. This represents the ratio of the annual remuneration of the highest-paid individual to the median annual remuneration of all other employees.

The company notes that this ratio:

• Is reported on global operations in accordance with ESRS
• Is subject to currency volatility and purchasing-power differences between countries
• Reflects external market trends across the world
• Results from efforts to attract, retain, and motivate highly educated talent critical to delivering strategy and growth ambitions

Methodology difference: This metric differs from the Internal pay ratio disclosed in ASML's remuneration report in accordance with the Dutch Corporate Governance Code. The ESRS calculation uses median annual remuneration on a headcount basis, whereas the Internal pay ratio uses average personnel expenses per FTE.

Methodology

Gender pay gap calculation:

• Scope: All active employees, excluding those with ASML for three months or less at period end
• Excludes employees in 'Other' and 'Non-disclosed' gender categories
• Gross hourly pay level = annual remuneration ÷ full-time scheduled hours for the location and period
• Calculated separately for female and male employees
• No prior-period comparatives due to methodology differences

Annual total remuneration:

• Comprises four components: base salary, STI (cash bonus), LTI (share-based incentive), and pension/other benefits
• Reported on full-time equivalent basis
• Local currency translated using average exchange rates for the period
• Not adjusted for purchasing-power differences between countries

Remuneration ratio:

• Numerator: Annual remuneration of highest-paid individual (disclosed in Remuneration report)
• Denominator: Median annual total remuneration of all active employees at period end, excluding highest-paid employee and those with company for three months or less
• Headcount basis

Exclusions from remuneration metrics:

• One-off benefits (relocation allowances, severance, long service awards)
• Inconsequential benefits (e.g., meal allowances)

Incidents, complaints and severe human rights impacts

Number of complaints filed through grievance mechanisms

ASML's global Speak Up Service is available for own employees, on-site external workers, workers across the value chain and people in affected communities.

In 2024, ASML received 93 complaints filed through channels for own workforce.

Incidents of discrimination including harassment

In 2024, ASML recorded 60 incidents of discrimination including harassment.

The monetary value of fines, penalties and compensation for damages as a result of complaints or incidents of discrimination including harassment was €0.

Severe human rights impacts

ASML reported 0 severe human rights incidents in 2024.

The monetary value of fines, penalties and compensations for damages as a result of severe human rights incidents was €0.

ASML received no grievances about breaches of Human Rights in 2024.

Summary metrics table

Methodology notes

Complaints filed through channels for own workforce: Includes all Speak Up reports received in the year via internal channels for own workforce.

Incidents of discrimination including harassment: Includes complaints or incidents registered by the company through the Speak Up Service, competent authorities through formal process, or instances of non-compliance identified through established procedures including management system audits or formal monitoring programs.

Severe human rights incidents: The severity depends on assessment of gravity, how widespread it is, and its remediability. ASML recognizes any identified case of forced labor, human trafficking or child labor as a severe human rights incident. The definition is aligned with the International Bill of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises.

Policies related to value chain workers

The company references disclosure requirement S2-1 in its ESRS mapping table, indicating that policies related to value chain workers are addressed in the following sections:

• Sustainability statements – Social – Responsible value chain – How we're managing

The mapping table indicates that this disclosure includes:

• DR17 Human rights policy commitments
• DR18 Policies related to value chain workers
• DR19 Non-respect of UNGPs and OECD Guidelines and Due diligence policies on issues addressed by the fundamental ILO conventions 1 to 8

However, the excerpts provided do not contain the actual content from the referenced sections. The mapping table confirms that ASML addresses policies related to value chain workers and references alignment with:

• United Nations Guiding Principles on Business and Human Rights (UNGPs)
• OECD Guidelines
• Fundamental ILO Conventions 1 to 8

No specific policy names, scopes, governance arrangements, or implementation monitoring details are disclosed in the excerpts provided.

Processes for engaging with value chain workers about impacts are addressed through our supplier engagement and assessment programs.

Processes to remediate negative impacts and channels for value chain workers to raise concerns are established through our supplier grievance mechanisms.

Taking action on material impacts on value chain workers

Supplier Engagement Programme

Engagement mechanisms:

• ASML Suppliers' Day
• Direct interactions via supplier account teams/sourcing account leaders
• Supplier audits
• Site visits
• Supplier newsletter
• Responsible Business Alliance (RBA) self-assessment questionnaire (SAQ)
• ASML's Speak Up Service
• Knowledge sessions on ESG sustainability
• ASML's Supplier Collaboration Day

Scope: Upstream value chain - Top 35 of 5,150 suppliers make up 80% of total sourcing spend

Focus areas: Quality issues, early supplier involvement during industrialization phase, reducing cycle time and cost, planning with suppliers, and ESG sustainability

SS&P ESG Sustainability Program (Strategic Sourcing & Procurement)

Actions:

• GHG capability maturity assessment integrated into supplier performance management system
• Training program created for Supplier Audit team
• Bi-monthly online one-to-many forums (average 250 supplier representatives participate)
• Supplier engagement to reduce scope 3 emissions

Scope: Upstream value chain (purchased goods, services and logistics)

Resources: Costs accounted under Selling, general and administrative costs (specific amounts not disclosed)

Expected outcomes: Support efforts to reduce scope 3 emissions and achieve GHG neutrality for logistics by 2030

Logistics Sustainability Initiatives

Actions:

• Collaborating with logistics suppliers to improve data quality
• Investigating options to move toward more sustainable modes of transportation (e.g., from air to ocean freight)
• Purchasing sustainable aviation fuel (SAF) where ocean freight is not possible
• Rethinking shipping routes to avoid central shipping from Veldhoven
• Sourcing more materials locally

Scope: Upstream transportation and distribution (scope 3 category 4)

Time horizon: Target date 2030 for GHG neutrality

Performance tracking: Progress performance meetings with senior leadership and cross-functional table meetings

Baseline and performance:

• Base year 2019: 213 kt CO2e
• 2024: 322 kt CO2e (increase due to business growth)
• Of which 306 kt from air transportation

Target: Become GHG neutral for scope 3 emissions related to logistics by 2030

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities include our supplier ESG targets and requirements.

Policies related to affected communities

The disclosure references that S3-1 content is located in "Sustainability statements – Social – Valued partner in our communities – How we're managing" and specifically includes:

• DR16 Human rights policy commitments
• DR17 Non-respect of UNGPs on Business and Human Rights, ILO principles or OECD Guidelines

However, the provided excerpts do not contain the actual content from the "Valued partner in our communities" section. The excerpts only show:

1. A reference table mapping ESRS S3 disclosures to sections in the report
2. References to human rights policy commitments
3. References to alignment with UNGPs, ILO principles, and OECD Guidelines

No specific policy names, scopes, governance structures, or policy content related to affected communities are disclosed in the provided excerpts. The actual policy details would be found in the referenced sections that are not included in these excerpts.

Processes for engaging with affected communities about impacts are addressed through our community engagement and stakeholder consultation programs.

Processes to remediate negative impacts and channels for affected communities to raise concerns are established through our community feedback mechanisms.

Taking action on material impacts on affected communities

Overall governance and resources

Community Partnership Program (CPP)

• Created in 2023 to oversee contributions to society and local communities
• Governs all community investments
• Resources allocated:
  • Non-financial: 24 FTEs dedicated to Society & Community Engagement (S&CE)
  • Financial: Total estimated cost of €3.4 million relating to FTEs (included within Personnel expenses in Consolidated financial statements)
  • Additional financial resources outlined per focus area below
• Governance: Head of Society & Community Engagement is action owner for each material sub-topic; performance monitored at least quarterly; governing body reviews and approves proposed projects
• Scope: Own operations (main locations)

Performance and targets

2024 total investment: Approximately €45.2 million in cash and in-kind support (€1,084 per employee)

Investment breakdown by focus area (2024):

• Attractive communities: €257/employee
• Inclusive communities: €189/employee
• STEM education: €177/employee
• ESG innovation: €299/employee
• Employee giving: €162/employee

Expected outcome: Company expects to approximately double society and community investments in 2025 from 2024 levels, with target expected to be reached in 2026 (one year delay)

Actions by focus area

1. Attractive communities

Objective: Mitigate negative impact of ASML's growth and contribute to improvements and positive experiences in the community

Affordable housing

• Action: Contribute to more affordable housing for local residents within low-to-mid-income groups in Brainport Eindhoven
• Approach: Support new construction in collaboration with housing corporations, municipalities and real estate developers
• Scope: Own operations (Brainport Eindhoven region)
• Steps include:
  • Providing financial instruments to accelerate affordable housing construction that does not distort the housing market
  • Other measures (ongoing)

Green communities

• Action: Contribute to livable local communities, prevent loss of biodiversity and stop deforestation as a result of operations
• Scope: Own operations (local communities around factories and offices)
• Steps include:
  • Reducing and decarbonizing energy use by supporting the community in financing investments to reduce and/or decarbonize energy use
  • Promoting nature and green spaces by developing biodiversity enhancement and compensating for any loss of greenery driven by ASML
  • Improving the quality of green spaces by contributing to facilities in and around green spaces and assisting in their maintenance

Sustainable mobility

• Action: Mitigate negative effects on mobility in regions of operation and promote use of sustainable mobility options
• Scope: Own operations (regional)
• Steps include:
  • Supporting shared mobility options
  • Supporting safety improvements to biking in the region

Attractive sports, arts and music

• Action: Compensate for negative impact on existing local offerings
• Scope: Own operations (local communities)
• Key areas:
  • Landmark initiatives: Funding landmark events, organizations and locations highly valued by the community
  • Improving existing offers: Providing funds to improve, expand and increase the variety of local sports, arts and music offerings
  • Upfront investment for new initiatives: Providing funds to improve and support upfront investment to organizations that can be self-sustaining afterward

Cultural integration

• Action: Foster positive relationships with ASML's neighbors and support integration of international employees through local community projects
• Scope: Own operations (Veldhoven and other locations)
• Sub-actions:
  • Improving relationships with direct neighbors: Implementing projects with stakeholders in direct vicinity of factories and offices
  • Better integrating international employees: Actioning employee-integration projects for both international and local employees, including:
    • Providing onboarding and support networks for newcomers and continued support while in country
    • Promoting understanding of cultural norms and language (including language courses for employees and spouses)
    • Creating opportunities for integrating and participating in the local community
    • Supporting the local community through volunteering to create win-win situations
• Monitoring: Effectiveness monitored through structural community stakeholder feedback

2. Inclusive communities

Objective: Remove obstacles that hold back disadvantaged community members from reaching their potential and create equal opportunities

Access to basic needs

• Action: Contribute to access to basic needs including food, shelter, clothes and healthcare-adjacent support
• Scope: Own operations (regional)
• Sub-programs:
  • Food: Providing support and volunteers to regional initiatives tackling food insecurity and hunger
  • Shelter: Supporting shelter initiatives and recruiting staff or volunteers
  • Clothing: Providing support to local clothing initiatives
  • Healthcare: Providing support to regional healthcare-adjacent initiatives

Access to employment

• Action: Increase quality employment by supporting unemployed (content cut off in excerpts)
• Scope: Own operations (regional)

3. STEM education

Objective: Help increase the STEM/technical talent pool that society needs to solve key challenges

• Action: Boost STEM education for children through initiatives that provide relevant skills for their future and expand the STEM talent pool
• Expected outcome: Increase future STEM talent pipeline to enable future generations to create tech for good
• Scope: Own operations and broader community

4. ESG innovation

Objective: Support projects with great societal returns with knowledge and expertise

• Action: Invest in ideation, startups and scaleups in communities to retain a diverse innovation ecosystem attractive to world's top technical talent
• Scope: Own operations (innovation ecosystem)
• Link to other disclosures: Further detail in Sustainability statements – Social – Innovation ecosystem

5. Employee giving

Objective: Encourage employees to become involved in their local communities

• Action: Global Employee Giving program matching employee donations and volunteering initiatives
• Scope: Global (all employees)
• Resources: Commit to matching donations of up to €10,000 per employee per year
• Time horizon: Ongoing program
• 2024 performance: €162 per employee contribution
• 2025 target: €500 per employee
• Planned action for 2025: Focus efforts on communication and campaigns such as Global Volunteering month to incentivize participation

Policy linkage

All actions align with the valued partnership policy, which applies worldwide to all employees and partners across the value chain.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities include our community investment and social impact targets.

Policies related to consumers and end-users are addressed through our customer satisfaction and product quality frameworks.

86% Customer satisfaction survey score

Processes for engaging with consumers and end-users about impacts are addressed through our customer engagement and satisfaction programs.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns are established through our customer support and feedback systems.

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions are addressed through our customer solution and support programs.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities include our customer satisfaction and product performance targets.

Business conduct policies and corporate culture

ASML has established several policies governing business conduct and corporate culture, aligned with international frameworks including the UN Guiding Principles on Business and Human Rights (UNGPs), OECD Guidelines for Multinational Enterprises, ILO core conventions, and the UN Global Compact. These policies are designed to support responsible business conduct across the organization and value chain.

Code of Conduct

Scope: All employees, directors and officers of ASML and the ASML group of companies. In some cases, the scope extends to non-employees, either working for temporary placement agencies, on behalf of ASML or as individual contractors (self-employed people).

Approval and oversight: The Code of Conduct was updated in 2024 and is overseen by the Compliance, Ethics, Security and Risk Committee (CESR), which is chaired by the CFO. The CESR Ethics Committee, facilitated by the Head of Ethics & Business Integrity and Human Rights and chaired by the Chief Legal Officer, oversees the investigation of ethics cases and reports into the CESR.

Key content: The Code is aligned with the RBA Code of Conduct and focuses on:

• Respecting people: commitment to maintaining a safe and healthy working environment and respecting human rights
• Operating with integrity: fostering a strong culture of integrity and compliance
• Commitment to safety and social responsibility
• Protecting assets: valuing and protecting people and their knowledge
• Conducting business with fairness, integrity and respect
• Promoting and upholding ethical behavior and fostering a culture where speaking up is encouraged

Public availability: The Code of Conduct is publicly available at asml.com.

International frameworks: The Code of Conduct is purposefully drafted to align with the RBA Code of Conduct and supports principles laid down in the UN Guiding Principles on Business and Human Rights (UNGPs), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, and ILO core conventions.

Monitoring: By the end of 2024, 97% of employees had completed mandatory Code of Conduct training. ASML conducts an annual ethics pulse survey sent to 25% of the total employee population. In 2024, 89% of respondents agreed or strongly agreed that "ASML makes it sufficiently clear what the principles of the Code are and how to comply with them." The company tracks Speak Up reports (727 reports received in 2024, or 1.7 reports per 100 employees) and monitors completion rates of Code of Conduct training.

Human Rights Policy

Scope: The policy applies to ASML's own operations and value chain.

Approval and oversight: The Human Rights Committee, chaired by the Head of Ethics & Business Integrity and Human Rights, drives the human rights program. The Committee consists of representatives from Legal & Compliance, Strategic Sourcing & Procurement, ESG Sustainability, ESG Reporting and Human Resources. Human rights is one of the risk areas overseen by the Compliance, Ethics, Security and Risk Committee (CESR).

Key content: The policy enshrines basic Human Rights due diligence principles applying to businesses, covering fundamental human rights across ASML's operations and value chain.

Public availability: The Human Rights Policy is publicly available at asml.com.

International frameworks: The policy actively supports principles laid down in the UN Guiding Principles on Business and Human Rights (UNGPs), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, ILO core conventions, UN Women's Empowerment Principles, UNICEF's Children's Rights and Business Principles, and the UN International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families.

Monitoring: In 2023-2024, ASML conducted a Human Rights Saliency Assessment to identify the most salient potential negative impacts on employees, workers across the value chain, and affected communities. Following the completion of the Saliency Assessment, ASML carried out a management gap analysis to identify areas where capacity building is needed. External stakeholder engagement was conducted with more than 20 organizations representing the interests of rights holders.

RBA Code of Conduct

Scope: All ASML operations and suppliers. ASML has adopted the RBA Code of Conduct as a member of the Responsible Business Alliance.

Key content: A set of standards relating to:

• Labor (human rights of all workers)
• Health and safety (minimizing the incidence of work-related injury and illness)
• Environment
• Ethics

Monitoring: ASML expects suppliers to comply with the RBA Code of Conduct and to cascade this requirement to their suppliers. Higher-risk suppliers are expected to complete the RBA Self-Assessment Questionnaire (SAQ) each year. ASML reviews all RBA SAQ results, evaluates high-risk findings, and discusses them with suppliers. The company also conducts third-party Responsible Business Alliance audits.

Attractive Workplace for All Policy

Scope: All workers – employees, directors and officers of ASML and the ASML group of companies. In some cases, the scope extends to non-employees, either working for temporary placement agencies, on behalf of ASML or as individual contractors.

Key content: The policy is closely linked to the ASML Code of Conduct, RBA Code of Conduct, ASML Human Rights Policy and ASML Global Diversity and Inclusion Policy. It covers:

• Talent attraction, employee engagement and retention
• Learning and development
• Diversity and inclusion
• Occupational health and safety
• Labor conditions
• Well-being

International frameworks: The policy aligns with international instruments including the ILO Declaration on Fundamental Principles and Rights at Work and the UN Declaration of Human Rights, the UN Global Compact, the OECD Guidelines for Multinational Enterprises, and other relevant standards such as the UN Women's Empowerment Principles, UNICEF's Children's Rights and Business Principles, and the UN International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families.

Global Diversity and Inclusion Policy

Scope: ASML's workforce globally.

Key content: The policy commits ASML to being an equal opportunity employer and to cultivating a diverse and inclusive workforce. ASML does not tolerate any form of discrimination, harassment, bullying or retaliation. The company aims to hire, promote and compensate the workforce without regard to age, race, color, religion, sex, gender, gender identity or expression, sexual orientation, national origin and/or other characteristics.

Monitoring: ASML monitors the effectiveness of its D&I approach by tracking performance indicators covering the ability to attract women from various backgrounds and experiences, and the ability to strengthen representation of women at leadership levels.

Anti-Bribery and Anti-Corruption Policy

Scope: All decision-making within ASML and business relationships both upstream and downstream in the value chain.

Key content: ASML does not tolerate any form of bribery or corruption. The policy includes:

• Strict rules around giving and accepting gifts and entertainment
• Prohibition of facilitation payments or political contributions on behalf of the company
• Requirements for prior approval for particular categories of third-party gifts and entertainment

Public availability: The Anti-Bribery and Anti-Corruption Policy is publicly available at asml.com.

Monitoring: In 2024, ASML had no convictions or fines for anti-bribery or anti-corruption violations. Substantiated breaches are followed up with corrective actions, including disciplinary actions, review and enhancement of internal controls and policies, additional training or other measures. ASML expanded its third-party risk management (TPRM) efforts in 2024, screening vendors, customers and other third parties to mitigate risks.

Competition Law Compliance Policy

Scope: All ASML operations and business partners (customers, suppliers, consultants, contractors and intermediaries).

Key content: ASML is committed to the principles of fair competition and does not condone any form of conduct that is illegal under applicable competition laws or the Code of Conduct. The policy addresses competition law compliance across the organization.

Public availability: A version of the policy was made publicly available in 2020 and an updated version was published in 2021.

Monitoring: ASML regularly performs risk assessments of relevant competition law focus areas to identify risks, improve existing controls, and provide strategies on remaining risks. Competition law training is provided through computer-based and in-person sessions tailored to relevant stakeholders. ASML did not incur any fines for breaches of competition law in 2024. Any act contrary to this policy is considered a significant breach of the Code of Conduct and may lead to disciplinary measures up to and including dismissal.

Speak Up and Non-retaliation Policy

Scope: Anyone who carries out work for, or on behalf of ASML, and any other person or party ASML is involved with worldwide.

Key content: The policy encourages employees, external business partners, suppliers, contractors and others to express concerns regarding possible violations of the Code of Conduct, company policies, values or the law. ASML does not tolerate any form of retaliation against employees or third parties who raise a concern in good faith. Reporting can be done anonymously.

Public availability: The Speak Up and Non-retaliation Policy is publicly available at asml.com.

Monitoring: In 2024, ASML received 727 Speak Up reports (1.7 reports per 100 employees). The company assesses every report and acts swiftly to ensure all necessary actions are taken. ASML continuously improves the Speak Up Service to ensure employees feel safe and supported when reporting concerns.

Conflicts of Interest Policy

Scope: All ASML employees, including job candidates and new hires.

Key content: The policy, introduced in 2024 and to be implemented in 2025, offers guidance on what to do when a conflict of interest arises. It requires employees to disclose any actual, potential or perceived conflict of interest and obligates people to avoid taking actions in relation to the potential conflict while the situation is being assessed.

Privacy Policy

Scope: All individuals whose personal data is processed by ASML.

Key content: ASML respects the privacy of individuals when processing their personal data. The company protects personal data and manages it in compliance with applicable laws and regulations.

Gifts & Entertainment Policy

Scope: All ASML employees and business relationships.

Key content: ASML has strict rules around the giving and accepting of gifts and entertainment. Such activities should never influence – or even appear to influence – the integrity of business decisions and transactions, or the loyalty of any of the parties involved. The policy was updated in 2024 and includes rules around requests for prior approval for particular categories of third-party gifts and entertainment.

Monitoring: ASML launched a set of tools to capture a register of given and accepted gifts or entertainment and offer employees further guidance.

Responsible value chain

Page 287 Responsible value chain

5,150 Total suppliers

• 1,600 in the Netherlands
• 750 in EMEA (excl. NL)
• 1,400 in North America
• 1,400 in Asia

Management of relationships with suppliers is detailed in our responsible value chain approach and supplier management programs.

Prevention and detection of corruption and bribery

ASML addresses prevention and detection of corruption and bribery through its broader business conduct policies. The company references ESRS G1-3 in its sustainability statement index, directing readers to the "ESG integrated governance" section. However, the excerpts provided do not contain a dedicated policy specifically named for anti-corruption and anti-bribery.

Code of Conduct

Scope:

• Applies to all decision-making within ASML
• Covers how ASML conducts business relationships both upstream and downstream in the value chain
• Available to all employees globally

Key content / principles:

• Conduct business with fairness, integrity and respect for the law in all countries where ASML operates
• Aligned with the latest RBA (Responsible Business Alliance) standards
• Includes anti-bribery and anti-corruption elements (referenced in training programs)
• Updated in 2024 to reflect current best practices
• Accompanied by a Principles in Practice platform providing examples and practical guidance

Public availability:

• Publicly available at asml.com

Links to international standards:

• Aligned with RBA standards
• The company reports meeting minimum safeguards constituted chiefly by the OECD Guidelines and UN Guiding Principles (referenced in EU Taxonomy disclosure)
• References United Nations Convention against Corruption (DR10b)

Approval and oversight:

• Not specifically disclosed in the excerpts

Monitoring implementation:

• Annual ethics survey covering 25% of workforce (3,400 responses in 2024)
• 89% of respondents agreed or strongly agreed that "ASML makes it sufficiently clear what the principles of the Code are and how to comply with them"
• Over 70% strongly agreed or agreed that "ASML shows a commitment to ethical business decisions and conduct"
• Code of Conduct training completion tracked: 97% of employees completed training by end of 2024
• Training delivered to new employees with annual refreshers for existing staff
• Monitoring of Speak Up reports (727 reports received in 2024, representing 1.7 reports per 100 employees)
• Formal investigation guidelines for ethics complaints
• Global Ethics and Business Integrity team expanded in 2024 with representation in South Korea, Japan, China and Veldhoven
• Network of ethics liaisons grown to around 70

Speak Up and Non-retaliation Policy

Scope:

• Applies to employees and third parties

Key content / principles:

• ASML will not tolerate any form of retaliation or any other form of adverse consequences against employees or third parties who raise a concern in good faith or participate in an investigation about suspected violations of the Code of Conduct, even if the company could lose business as a result
• Aims to protect anyone Speaking Up

Public availability:

• Publicly available at asml.com

Links to international standards:

• References protection of whistle-blowers (DR10d)

Monitoring implementation:

• Continuously updated and improved
• 727 Speak Up reports received in 2024
• Formal investigation guidelines outline process from first report to remedial action and final closure

Human Rights Policy

Key content / principles:

• Referenced as part of continuous updates and improvements to meet the company's ambition for ethical business practices
• Specific content not detailed in the excerpts

Monitoring implementation:

• Continuously updated and improved

Anti-bribery and anti-corruption training programs

While not a standalone policy, ASML maintains dedicated anti-bribery and anti-corruption training programs that are continuously updated, improved and expanded.

Incidents of corruption or bribery

Confirmed incidents

ASML reported zero confirmed incidents of corruption or bribery during the reporting period 2024. The company explicitly states: "no convictions or fines against us or our employees in these areas in the reporting year."

Convictions and fines

The company reported:

• Number of convictions for violation of anti-corruption and anti-bribery laws: 0
• Monetary value of fines for violation of anti-corruption and anti-bribery laws: €0

Disciplinary actions

Substantiated breaches of anti-bribery or anti-corruption procedures and standards are generally followed up with corrective actions, including:

• Disciplinary actions
• Review and enhancement of internal controls and policies
• Additional training
• Other measures that aim to further promote a culture of ethics and professional integrity

No specific number of employees dismissed or disciplined for corruption or bribery in 2024 was disclosed.

Contracts terminated

No information was disclosed regarding the number of contracts with business partners terminated or not renewed due to corruption or bribery violations.

Investigation procedures and speak-up mechanisms

ASML maintains a comprehensive Speak Up Service that applies to anyone who carries out work for, or on behalf of ASML, and to any other person or party the company is involved with worldwide. The service:

• Is hosted online by an independent, external service company in several different languages
• Provides toll-free phone numbers available in every country where ASML operates
• Allows anonymous reporting
• Has a dedicated email address and ethics liaisons

The company commits to protecting anyone speaking up and does not tolerate any form of retaliation against employees or third parties who raise a concern in good faith or participate in an investigation, even if business could be lost as a result.

In 2024, ASML received 727 reports through its Speak Up Service (an increase attributed to workforce growth and efforts to encourage reporting). The company states this represents 1.7 reports per 100 employees and views the increase as "a positive result signaling a healthy Speak Up culture."

ASML assesses every Speak Up report received and acts swiftly to ensure all necessary actions are taken by the appropriate body. The company has improved its formal investigation guidelines in 2024, outlining the process for each phase of an investigation, from the first report to remedial action and final closure.

Governance and oversight

The Compliance, Ethics, Security and Risk Committee (CESR) is responsible for policymaking and supervision of compliance with legal and ethical requirements, receiving quarterly updates on the ethics program. The CESR Ethics Committee investigates significant notifications of potential breaches of the Code of Conduct worldwide.

Training and awareness

By the end of 2024, 97% of employees had completed the mandatory Code of Conduct training course. The company maintains comprehensive anti-fraud, anti-bribery and anti-corruption training programs, including mandatory e-learning courses and annual refresher trainings, supported by additional classroom training tailored to specific stakeholder groups.

Political influence and lobbying activities are managed through our government engagement and public policy framework.

Payment practices

ASML has identified G1-6 Payment practices as not a material sub-topic based on the outcome of their double materiality assessment (DMA).

Supply chain finance obligations

ASML operates a supply chain finance program. The amount of confirmed obligations outstanding as of December 31:

These obligations are included in Accounts payable and represent amounts confirmed as valid to third parties under supply chain finance arrangements.

No specific disclosures are provided regarding:

• Average time to pay invoices
• Standard contractual payment terms
• Legal proceedings for late payment
• Compliance with prompt payment codes