ASML Holding

Governance bodies

Reference: Sustainability statements - General disclosures - ESG sustainability governance (p.143-145); Corporate governance - Board of Management, Supervisory Board.

ASML has a two-tier governance structure. The Board of Management (BoM) sets and oversees ESG sustainability strategy and its execution, including the IROs identified through the DMA. The Supervisory Board (SB), advised by its ESG Committee, supervises, monitors and advises the BoM on ESG sustainability aspects and identifies related principal risks and opportunities. Neither body includes workforce representatives.

Sustainability-related responsibilities: CEO Christophe Fouquet is the BoM's representative focusing on ESG sustainability. The Head of ESG Sustainability is responsible, on behalf of the BoM, for preparing and monitoring progress of the ESG sustainability strategy.

The ESG Progress Review Meeting - comprising the CEO, CFO and other participants - is the delegated body responsible for oversight of impacts, risks and opportunities, meeting at least once every two months to review progress of the ESG sustainability strategy and related actions. All responsibilities are reflected in Rules of Procedure, committee charters or other formal documents.

Information flow to governance bodies

Reference: Sustainability statements - General disclosures - ESG sustainability governance (p.143-145).

The BoM sets and oversees execution of ESG sustainability aspects in ASML's integrated business strategy, including the IROs arising from the DMA, and receives quarterly ESG sustainability updates. The ESG Progress Review Meeting (CEO, CFO and other participants) meets at least once every two months to review progress of the ESG sustainability strategy, including related actions.

The SB monitors and advises the BoM on ESG sustainability aspects relevant to the company, including the principal related risks and opportunities; the ESG Committee advises the SB in carrying out this oversight.

A subset of KPIs and progress against targets is reviewed quarterly with the BoM; the full target set is subject to periodic review by business representatives to discuss progress and, where necessary, corrective actions. The BoM has also adopted the Climate Transition Plan.

Sustainability in incentive schemes

Reference: Sustainability statements - General disclosures - ESG sustainability governance (p.144); Corporate governance - Remuneration report.

Performance against key sustainability metrics forms part of the long-term incentive (LTI) plans of the BoM and senior management. There is an annual update of sustainability metrics, which currently constitute 20% of the total LTI score.

In addition, the Supervisory Board applied a specific LTI performance measure on scope 1 and 2 GHG emissions for the 2023-2025 performance period, disclosed alongside ASML's scope 1 and 2 emissions pathway in the Energy efficiency and climate action chapter.

Full detail on how sustainability has been factored into Board of Management and Supervisory Board remuneration is provided in the Remuneration report (Corporate governance section).

Statement on due diligence

Reference: Sustainability statements - General disclosures - Environmental and human rights due diligence (p.147-149).

ASML's environmental and human rights due diligence process covers five core elements: embedding due diligence in governance, strategy and business model; engaging with affected stakeholders; identifying and assessing adverse impacts; taking action to address adverse impacts; and tracking and communicating effectiveness. It is anchored in the Code of Conduct, the Human Rights Policy and the RBA Code of Conduct, in preparation for legislation such as the EU CSDDD.

A cross-functional Human Rights Committee, chaired by the Head of Ethics & Business Integrity and Human Rights, oversees the Human Rights program; in 2025 ASML built its Human Rights Roadmap on the outcomes of the 2023-2024 saliency assessment. Remediation runs through the global Speak Up Service, open to employees, on-site external workers, value chain workers and affected communities. In 2025, ASML received 111 grievances about human rights concerns, of which 15 were substantiated (diversity, work-life balance, health and safety, harassment, discrimination, privacy, secure employment). ASML dedicated four FTEs to environmental and human rights due diligence teams.

Risk management and internal controls over sustainability reporting

Reference: Sustainability statements - General disclosures - ESG sustainability governance (p.144-145).

Risks related to sustainability reporting are part of ASML's enterprise risk management (ERM) framework, using both top-down (compliant reporting against applicable disclosure requirements) and bottom-up (accuracy of content/data, accuracy of estimation results, availability and timing of data) approaches. The sustainability reporting risk and control framework is reviewed annually, or during the year for major changes.

The governance structure supporting this includes the Board of Management, the Compliance, Ethics, Security and Risk Committee (CESR), the Disclosure Committee, and Risk and Control Owners. ASML states that the maturity of its internal control framework related to sustainability reporting is expected to grow in coming years.

Strategy, business model and value chain

Reference: Sustainability statements - General disclosures - ESG sustainability at a glance, Value chain and ecosystem overview (p.145-147); Strategic report - Our business.

ASML provides holistic lithography solutions, software and services (EUV and DUV lithography systems, metrology and inspection systems, computational lithography) that help chipmakers achieve higher yields and performance. FY2025 headline figures: >44,000 total employees (FTEs), net sales EUR 32.7bn, gross margin 52.8%, R&D spend EUR 4.7bn, EUR 8.5bn returned to shareholders, 535 system sales in units, 5,100 total suppliers, 21% women in the workforce, 143 nationalities, customer satisfaction survey score 88%.

Business strategy rests on six pillars: deepen customer trust; extend technology and holistic product leadership; strengthen ecosystem relationships; create an exceptional workplace; drive operational excellence; deliver on ESG sustainability.

Value chain: ASML sources from 5,100 suppliers (900 product-related, 4,200 non-product-related; EUR 16.2bn total spend in 2025) across EMEA, the Netherlands, North America and Asia, and sells to a concentrated base of global semiconductor manufacturers. Headquartered in Veldhoven, the Netherlands, with other major sites including San Diego (US), Berlin (Germany) and Taiwan.

Interests and views of stakeholders

Reference: Sustainability statements - General disclosures - Basis for preparation, Impact, risk and opportunity management (p.142, 149); Strategic report - Our business - Engaged stakeholders (p.43).

ASML's stakeholder engagement policy identifies five main stakeholder groups: customers, employees, suppliers (including contractors), shareholders and society. ASML engages continuously through regular meetings, surveys, supplier days and investor dialogue, and considers business relationships, legal/regulatory developments, industry studies, and internal/external subject-matter expertise.

Stakeholder input feeds directly into the DMA (Step 1: 'Understanding context') and into target-setting for the ESG sustainability strategy. The global Speak Up Service and grievance mechanism are open to employees, on-site external workers, workers across the value chain, and people in affected communities; ASML received 111 human-rights-related grievances in 2025 (15 substantiated). ASML notes stakeholder engagement plays an integral role in identifying its material topics.

Material impacts, risks and opportunities

Reference: Sustainability statements - General disclosures - Impact, risk and opportunity management (p.150-151).

Based on its 2025 DMA, ASML reports on E1 (Energy efficiency and climate action), E5 (Circular economy), S1 (Attractive workplace for all), S2 (Responsible value chain), S3 (Valued partner in our communities) and G1 (ESG integrated governance), plus the entity-specific topic Innovation ecosystem. No new material topics were identified versus the prior year, though IRO descriptions were refined.

E2 (Pollution), E3 (Water and marine resources), E4 (Biodiversity and ecosystems) and S4 (Consumers and end-users) were assessed as not material.

Material IROs span: GHG emissions and climate risk/opportunity (E1); resource inflows/waste and supply-disruption risk (E5); labor conditions, well-being, health & safety and talent-retention risk (S1); human rights of supply-chain/customer-site workers and technology-misuse impacts (S2); housing/mobility/talent-pipeline pressure around Veldhoven (S3); supplier management, compliance and data-privacy risk (G1). ASML states it has not identified material risks/opportunities with current financial effects expected within the next reporting period beyond those separately quantified.

Process to identify and assess material IROs

Reference: Sustainability statements - General disclosures - Impact, risk and opportunity management (p.149-151).

ASML's DMA follows seven steps: (1) Understanding context via the five main stakeholder groups; (2) Determining potentially relevant sustainability matters from industry/peer/regulatory monitoring; (3) Identifying IROs across the value chain, informed by the ASML risk universe; (4) Assessing impact materiality - negative impacts scored on scale, scope and irremediable character (severity) and likelihood, positive impacts on scale/scope/likelihood, using 5-point scales; (5) Assessing financial materiality of risks/opportunities by magnitude and likelihood (5-point scales); (6) Deciding materiality thresholds - only IROs scoring medium or high are material; (7) Assessing strategic implications, with outcomes presented to and approved by the BoM.

The 2025 DMA updated organizational/supplier/customer inputs and integrated the 2024 human rights saliency assessment; scoring methodology changes did not alter the materiality outcome of individual IROs. For biodiversity, IROs were assessed across own sites, communities and the upstream (direct suppliers)/downstream value chain; none were identified as material, though a 2026 deep-dive assessment is planned given sites (including Veldhoven) near biodiversity-sensitive areas.

Disclosure requirements covered

Reference: Sustainability statements - Reference table (p.269-272).

ASML reports on ESRS 2 (all General disclosures), E1 (E1-1 to E1-8; E1-9 omitted under the phase-in provision), E5 (E5-1 to E5-5, including the E5-5 waste breakout; E5-6 not included, phase-in provision applied), S1 (S1-1 to S1-6, S1-8 to S1-10, S1-13, S1-14, S1-16, S1-17; S1-7, S1-11, S1-12 and S1-15 not included, 'Quick fix' over phase-in provisions applied), S2 (S2-1 to S2-5), S3 (S3-1 to S3-5) and G1 (G1-1 to G1-4; G1-5 and G1-6 assessed as not material sub-topics).

E2 (Pollution), E3 (Water and marine resources), E4 (Biodiversity and ecosystems) and S4 (Consumers and end-users) are stated as 'Not a material topic based on the outcome of our DMA.' Minimum disclosure requirements (MDR-P, MDR-A, MDR-M, MDR-T) are embedded within each topic's 'how we are managing', 'actions and resources', and 'targets and performance' sections rather than disclosed as stand-alone items.

Climate Transition Plan

Reference: Sustainability statements - Environmental - Energy efficiency and climate action - How we are managing: Climate Transition Plan (p.155-161).

ASML's Climate Transition Plan is its strategic roadmap aligned with the Paris Agreement, adopted by the BoM and reported to the Supervisory Board. Ambition: GHG neutral across the value chain by 2040, via three levers - reducing energy use, using renewable energy, and compensating residual emissions.

In 2025, SBTi validated both ASML's near-term (2030) and long-term (2040) targets: scope 1&2 absolute reduction of 75% by 2030 and 90% by 2040 (2019 base year: 60 kt); scope 3 emission-intensity reduction of 55% by 2030 and 97% by 2040 (2019 base: 1.44 kt CO2e/EUR m gross profit). ASML achieved GHG neutrality for scope 1&2 and for scope 3 business travel/commuting (categories 6&7) in 2025, ahead of its 2025 ambition.

Locked-in emissions/dependencies: continued use of gas boilers at multiple sites; hard-to-abate supply-chain emissions from steel and aluminum with no viable low-carbon alternative currently available; dependency on suppliers' and customers' own decarbonization and on affordable low-carbon energy access.

Climate policies

Reference: Sustainability statements - Environmental - Energy efficiency and climate action - How we are managing: Climate Transition Plan (p.155-157).

The Climate Transition Plan is embedded in ASML's business strategy and financial planning, strengthened by an internal carbon price, and updated annually. It rests on three levers: reduce energy use (now executing its fourth consecutive five-year energy savings master plan); use renewable energy (ASML reached 100% renewable electricity across its own premises at end-2025, sourced against sustainability, locality, additionality, bundling, risk and fair-price criteria); and compensate residual emissions (only 'removal' offsets, nature- and/or tech-based, are eligible).

ASML collaborates industry-wide through the Semiconductor Climate Consortium (SCC), which it co-founded, to raise energy efficiency and access to renewable electricity across the value chain, including at customer sites.

Actions and resources for climate change

Reference: Sustainability statements - Environmental - Energy efficiency and climate action - Manufacturing and buildings, Logistics, Business travel (p.160-170).

ASML organizes climate action around seven material sub-topics: manufacturing and buildings, purchased goods and services/capital goods, logistics, business travel, employee commuting, and product use, plus renewable-electricity sourcing.

Key actions and resources (2025): energy savings master plan delivered 148 TJ of savings 2021-2025 (vs. 100 TJ target), with EUR 126 million invested in 2025 alone (heat pumps/office renovation in Veldhoven, solar panels in San Diego; 10 FTEs plus external support) and a further 130 TJ master plan targeted through 2030; EUR 6.9 million spent on energy attribute certificates; air-to-ocean logistics shift (20 FTEs; +EUR 1.0 million in leased ocean-container costs; EUR 1.6 million combined SAF spend, cutting freight emissions by 6 kt); EUR 3.6 million contributed to a business-travel airline's SAF program (cutting residual travel emissions by 28 kt); a 2022 Green Bond, with net proceeds fully allocated to eligible green-building projects by end-2024; and energy-efficiency roadmaps per product category addressing scope 3 category 11 (use of sold products), ASML's largest single emissions category.

Climate targets

Reference: Sustainability statements - Environmental - Energy efficiency and climate action - How we are managing: Climate Transition Plan, Metrics table (p.158-159, 175).

SBTi-validated targets (2019 base year):

Both 2025 SBTi ambitions were exceeded. Additional GHG-neutrality targets: scope 1&2 plus scope 3 categories 6&7 by 2025 (achieved); scope 3 supply chain (categories 1,2,4) by 2030; scope 3 product use (category 11) by 2040. Targets are pursued independently of any offsetting.

Energy consumption and mix

Reference: Sustainability statements - Environmental - Energy efficiency and climate action: Metrics table (p.176).

Total energy consumption (MWh)

Energy intensity for activities in high climate-impact sectors: 19.6 MWh/EUR m revenue (2024: 20.6). ASML reached 100% renewable electricity for its own operations at end-2025.

Gross Scope 1, 2, 3 and total GHG emissions

Reference: Sustainability statements - Environmental - Energy efficiency and climate action: Metrics table (p.175).

GHG emissions (kt CO2e)

Scope 3 represented 99.8% of ASML's 2025 footprint; use of sold products (downstream) was its single largest category.

GHG removals and carbon credits

Reference: Sustainability statements - Environmental - Energy efficiency and climate action - How we are managing: Climate Transition Plan, Metrics table (p.157, 175).

Offsetting of residual emissions from ASML's own activities (scope 1, scope 2, and scope 3 categories 6 and 7 - business travel and commuting) began in 2025. ASML compensated 104 kt CO2e via the GreenTrees Reforestation Project in the United States, registered with the American Carbon Registry (ACR) under its Methodology for Afforestation and Reforestation of Degraded Land - covering 100% of remaining emissions from own activities.

2025 carbon-credit profile: 100% removal-project credits, 100% ACR-registered, 100% sourced from US projects, 0% corresponding adjustments. ASML plans to cancel a further 101 kt CO2e in the next reporting year under existing contractual agreements. Only nature- and/or tech-based 'removal' offsets are eligible; the initial portfolio is nature-based only, as tech-based removal (e.g. direct air capture) is currently judged to have limited availability and poor cost-effectiveness.

Internal carbon pricing

Reference: Sustainability statements - Environmental - Energy efficiency and climate action - How we are managing: Climate Transition Plan (p.161).

ASML introduced an internal carbon price in 2025 to factor GHG externalities into internal business cases without creating direct monetary flows. The initial internal carbon price for 2025 was EUR 208 per tonne of CO2 (2024: EUR 200), indexed by 4% per year by default, benchmarked against EU ETS historical/forecast prices, a peer group of more than 30 ICT companies, and IPCC/US EPA cost-to-society studies.

Scope: investment decisions in the emission categories ASML most directly controls (scope 1 and 2) and an R&D shadow price applied to product-use energy-reduction decisions (scope 3 category 11); planned to expand to external emission categories over time. In 2025, the CO2 shadow price was applied to investment decisions covering 0.8 kt CO2e (3% of total gross scope 1&2 emissions). The internal carbon price is not currently used in asset valuations in the Consolidated financial statements.

Circular economy policy

Reference: Sustainability statements - Environmental - Circular economy - How we are managing circular economy (p.189-191).

ASML's circular economy ambition: zero waste from its own operations to landfill and incineration by 2030. It covers five material sub-topics: Systems, Parts and tools, Transport materials, Non-product-related (NPR) waste (hazardous and non-hazardous), and Real estate (building renovation and construction).

The policy is built on four levers: (1) Prevent waste - design for disassembly, mono-material components and an eco-design methodology that minimizes critical raw materials; (2) Extend lifetime - Lifetime Extension Packages (LEPs), Productivity Enhancement Packages (PEPs) and System Node Extension Packages (SNEPs); (3) Reuse resources - repair and harvest parts/packaging through global and local repair centers; (4) Recycle materials - certified waste contractors only, with sustainability KPIs embedded in contracts.

Circular economy actions and resources

Reference: Sustainability statements - Environmental - Circular economy: Systems, Parts and tools (p.191-194).

Systems: In 2025, ASML sold 27 refurbished lithography systems (600+ refurbished and resold to date); 95% of all systems sold in the past 30 years remain active in the field. PAS customers are guaranteed a service roadmap until at least 2035.

Parts and tools: ASML operates a dedicated Reuse & Repair organization with repair centers in South Korea (Hwaseong), Taiwan (Linkou), China (Beijing), the US (Wilton, San Diego, Vancouver WA) and the Netherlands (Veldhoven). 2025 operating expenditure for Reuse & Repair was approximately EUR 50 million, covering around 270 FTEs; a further ~70 FTEs are invested in scaling reuse processes. In 2025 ASML launched buyback implementations with six major suppliers under a circular supplier collaboration (CSC) program to remanufacture, repair or harvest returned parts.

Circular economy targets

Reference: Sustainability statements - Environmental - Circular economy: Parts and tools, Systems (p.192-193).

Achieve a 90% reuse rate of parts returned from the field and factory by 2025 - achieved: 90% in 2025 (2024: 88%). Having reached the target, ASML expects it to remain in place until 2030.

Zero waste from operations to landfill/incineration by 2030 remains ASML's overarching circular economy ambition (Environmental at a glance, p.152). ASML states it is updating its circular economy strategy and developing new installed-base-related targets going forward; no absolute targets are yet set for minimizing primary raw materials or maximizing sustainable/renewable resource use.

Resource inflows

Reference: Sustainability statements - Environmental - Circular economy: Metrics table (p.198).

Resource inflows (tonnes)

Metrics newly reported with comparative figures per ASML's methodology note; figures cover materials used to manufacture ASML's systems, parts and packaging.

Resource outflows

Reference: Sustainability statements - Environmental - Circular economy: Metrics table (p.198).

Resource outflows (tonnes)

ASML separately reports EoL/waste-directed-to-disposal outflows under the E5-5-Waste breakout. Resource outflow performance is tracked alongside the parts reuse rate (90% in 2025) and the recycled/reused material inflow share (60% in 2025).

Waste

Reference: Sustainability statements - Environmental - Circular economy: Metrics table (p.198-199).

Waste generated by type (tonnes)

Waste diverted from disposal: non-hazardous 19,194t (2024) -> 20,527t (2025, of which 20,415t recycled); hazardous 794t -> 800t. Waste directed to disposal: non-hazardous 7,150t -> 7,186t (incineration-dominated); hazardous 230t -> 206t. Non-recycled waste: 7,562t (27.6%) in 2024 -> 7,548t (26.3%) in 2025.

ASML divides operational waste into non-hazardous, construction and demolition, hazardous (e.g. acetone, piranha acid) and radioactive (from small quantities of radioactive material in products) categories, with an ambition of zero waste to landfill/incineration by 2030.

Own workforce policies

Reference: Sustainability statements - Social - Attractive workplace for all - How we are managing (p.210-215); General disclosures - Environmental and human rights due diligence (p.147-148).

ASML's Attractive workplace for all approach applies to all employees group-wide (and in some cases to non-employees), anchored in the Code of Conduct, the RBA Code of Conduct, the Human Rights Policy and the Group Diversity and Inclusion Policy. Six material workforce sub-topics are identified: talent attraction, employee engagement and retention; learning and development; inclusion and diversity; occupational health and safety; labor conditions; well-being.

The Global Inclusion and Diversity Council (GIDC), chaired by the CEO, oversees a 14-project I&D program. An EHS and Business Continuity Committee, chaired by the COO, oversees health & safety strategy. On April 21, 2025, following US Executive Order 14173, ASML excluded US employees from the scope of its diversity targets/KPIs and removed diversity metrics from US senior-management performance share plans.

Engaging with the workforce

Reference: Sustainability statements - Social - Attractive workplace for all - How we are managing (p.213); Strategic report - Our business - Engaged stakeholders - Employees.

ASML runs an annual employee engagement survey (external validated provider; engagement score derived from a subset of five questions; scope covers all employees plus 'N1-conversion' non-employees with 3+ months' tenure) - 2025 engagement score 80.2% (2024: 78.9%), inclusion score 66% (2024: 32% per at-a-glance comparatives context). Collective bargaining coverage stood at 62% of employees in 2025 (2024: 61%); ASML states it has no European Works Council, SE or SCE works council agreements. Feedback from the survey and from workforce channels directly informs the Develop & Perform (D&P) annual performance cycle and I&D program design.

Remediation channels for the workforce

Reference: Sustainability statements - Social - Attractive workplace for all - How we are managing (p.213); General disclosures - Environmental and human rights due diligence (p.148).

ASML's global Speak Up Service - hosted by an independent external provider in multiple languages, with toll-free numbers in every country of operation and an option to report anonymously - is available to employees and other affected parties. Every report is assessed and acted on; substantiated cases trigger remedial actions such as formal apologies, enhanced oversight of working hours, respectful-workplace coaching, proportionate disciplinary measures and, where relevant, contract corrections. In 2025 ASML received 111 human-rights-related grievances, of which 15 were substantiated. ASML states it does not tolerate retaliation against anyone raising concerns in good faith, including participants in investigations.

Actions on material workforce impacts

Reference: Sustainability statements - Social - Attractive workplace for all - How we are managing, Our actions and resources (p.213-221).

Key 2025 actions by sub-topic: talent attraction/retention - annual pay-scale benchmarking against third-party peer data; learning and development - ASML Academy using a 70:20:10 (on-the-job/coaching/training) model and the Develop & Perform annual review cycle; inclusion and diversity - GIDC-led 14-project I&D program and a US I&D Council, alongside compliance changes following US Executive Order 14173; occupational health and safety - EHS management system targeting zero recordable work-related injuries/illness, overseen by the EHS and Business Continuity Committee; labor conditions - adequate-wage benchmarking against local living/minimum wage. ASML also disclosed a January 2026 announcement (post year-end) of an intended net reduction of around 1,700 Technology/IT positions, mainly in the Netherlands and the US, to be discussed with social partners during 2026.

Workforce targets

Reference: Sustainability statements - Social - Attractive workplace for all: Additional disclosures - Methodology on targets (p.233-235); ESG sustainability at a glance (p.145).

Key 2025 targets, each with a defined methodology: employer-brand ranking goals (Netherlands top 5, US top 75, China top 100, Taiwan top 5, via the Universum ranking); engagement score within 2 percentage points of the top-25%-companies benchmark - 2025 engagement score 80.2% (2024: 78.9%); attrition rate <7% by 2025 (entity-specific metric, calculated on a monthly FTE basis - distinct in scope/method from the ESRS employee turnover rate of 4.2% reported under S1-6); 80% of employees with a development item in progress by 2025; learning satisfaction score >=80%; 24% inflow of women (all job grades) by 2025 and 24% inflow of women to job grades 9+ by 2025; 14% representation of women in job grade 13+ by 2026; inclusion score within 3 percentage points of the top-25% benchmark; recordable incident rate <=0.96 by 2025 (OSHA-aligned, converted unit of measure in 2025); 100% of employees earning above the adequate wage benchmark by 2025; well-being score within 2 percentage points of the top-25% benchmark. Exact 2025 outturns for several of these entity-specific targets are presented only in dashboard-chart form in the source and were not all extractable as clean text; S1-9 and S1-16 report the underlying ESRS diversity and pay metrics.

Employee characteristics

Reference: Sustainability statements - Social - Attractive workplace for all: Metrics table (p.227-228).

Headcount by gender (as of Dec 31)

By country (2025): Netherlands 23,707; Taiwan 4,548; United States 8,242. Permanent vs. temporary (2025): 41,686 permanent, 2,489 temporary. Employee turnover: 1,847 (4.2% rate) in 2025, vs. 1,652 (3.9%) in 2024.

Reconciliation to the Consolidated financial statements: total payroll + temporary employees (Note 18) 44,209 FTE in 2025, less 689 FTE non-employees per ESRS, giving 43,520 FTE payroll employees (44,175 headcount) as the ESRS-defined workforce.

Collective bargaining and social dialogue

Reference: Sustainability statements - Social - Attractive workplace for all: Metrics table (p.228-229).

Employees covered by collective bargaining agreements: 62% in 2025 (2024: 61%). ASML reports coverage-rate bands and workplace-representation status for its significant EEA countries (the Netherlands) and non-EEA regions (North America, Asia) with more than 50 employees representing over 10% of total employees. ASML states it has no existing agreements with a European Works Council (EWC), Societas Europaea (SE) works council or Societas Cooperativa Europaea (SCE) works council.

Diversity metrics

Reference: Sustainability statements - Social - Attractive workplace for all: Metrics table (p.229).

Gender at top management level (headcount, as of Dec 31)

Age distribution (headcount)

Overall workforce was 21% women in 2025 (company-wide, per Strategic report at-a-glance); women's inflow to all job grades was in the high-20s percent range against a 24%-by-2025 target.

Adequate wages

Reference: Sustainability statements - Social - Attractive workplace for all: Metrics table (p.230); Additional disclosures - Methodology on targets (p.235).

ASML states: 'All employees earn above our adequate wage benchmark (higher of living wage and minimum wage).' This directly supports ASML's target of 100% of employees earning above the adequate wage benchmark by 2025, which the company reports as met. Benchmarks are set locally against the higher of statutory minimum wage or an independently referenced living wage.

Training and skills development

Reference: Sustainability statements - Social - Attractive workplace for all: Metrics table (p.230-231).

Performance review completion (% of total employees, by gender)

Training hours

Delivered through the ASML Academy, following a 70:20:10 model (70% on-the-job, 20% coaching, 10% formal training courses), with the annual Develop & Perform (D&P) cycle providing goal-setting, development conversations and end-of-year review.

Health and safety metrics

Reference: Sustainability statements - Social - Attractive workplace for all: Metrics table (p.231).

ASML's entity-specific 'recordable incident rate' target (<=0.96 by 2025, OSHA-aligned, covering all employees and N1-conversion non-employees, all recordable incident types including ill health) uses a different scope/unit than this ESRS metric (employees only, injuries only); ASML changed its recordable-incident-rate unit of measure in 2025, converting the 2024 comparative from 0.19 to 1.14 and the 2025 target from 0.16 to 0.96.

Remuneration metrics

Reference: Sustainability statements - Social - Attractive workplace for all: Metrics table (p.232).

Gender pay gap (unadjusted): 9.3% in 2025 (2024: 10.2%). ASML attributes the improvement mainly to a higher concentration of women in higher-earning roles and favorable currency movements (average gross hourly pay rose 6.6% for women vs. 5.5% for men in 2025). The gap remains driven by underrepresentation of women in senior roles: 84% men/16% women in senior management in 2025 (2024: 88%/12%). ASML is preparing for the EU Pay Transparency Directive.

Annual total remuneration ratio: 53 in 2025 (2024: 43), an increase ASML attributes mainly to CEO remuneration versus 2024.

Incidents, complaints and severe human rights impacts

Reference: Sustainability statements - Governance - ESG integrated governance: Metrics table and additional disclosures (p.267).

Complaints reported are Speak Up reports and National Contact Point (OECD Multinational Enterprises) complaints relating to ESRS social sub-topics within ASML's own workforce. ASML defines any identified case of forced labor, human trafficking or child labor as a severe human rights incident by definition; none were identified in either year.

Value chain worker policies

Reference: Sustainability statements - Social - Responsible value chain - How we are managing (p.238-239); General disclosures - Environmental and human rights due diligence.

ASML has identified three material sub-topics: Responsible product design, Responsible supply chain, and Responsible product use. Its responsible value chain policy sets commitments and requirements for managing environmental and human-rights risks across the value chain, following a six-step due diligence framework based on the OECD Due Diligence Guidance for Responsible Business Conduct: (1) embed in policies and management system, (2) assess and prioritize adverse impacts, (3) prevent/mitigate/manage adverse impacts, plus subsequent steps on remediation and tracking. As an RBA member, ASML has adopted the RBA Code of Conduct (labor, health & safety, environment, ethics) and requires suppliers to comply and cascade the requirement to their own suppliers, reinforced via the ASML Supplier Handbook and Conflict Minerals Program.

Engaging with value chain workers

Reference: Sustainability statements - Social - Responsible value chain - How we are managing (p.238-239); Strategic report - Our business - Engaged stakeholders - Suppliers.

ASML identifies and assesses impacts caused through its own operations, contributed to via direct business relationships, and linked to it through purchased goods/services, sold products and business relationships. This includes engaging with value-chain stakeholders or their representatives to understand actual or potential impacts, considering geography-, sector- and material-specific risk factors, and taking into account reasonably foreseeable misuse of ASML's products. Engagement channels include the RBA Self-Assessment Questionnaire (SAQ) process and direct supplier engagement (email, meetings, dedicated sessions).

Remediation channels for value chain workers

Reference: Sustainability statements - Social - Responsible value chain - How we are managing (p.239); Governance - ESG integrated governance.

ASML's global Speak Up Service is explicitly open to workers across the value chain (in addition to employees and communities), available in multiple languages with toll-free numbers and an anonymous-reporting option. Where the RBA Self-Assessment Questionnaire (SAQ) identifies supplier-side high-risk elements, ASML investigates and agrees follow-up actions directly with the supplier - in 2025, all nine suppliers flagged as overall high-risk were evaluated and follow-up actions agreed (mainly on forced-labor and health & safety risk elements).

Actions on value chain worker impacts

Reference: Sustainability statements - Social - Responsible value chain - Our actions and resources (p.241-244).

Responsible supply chain: ASML's 2025 supplier base totaled 5,100 suppliers (900 product-related, 4,200 non-product-related; EUR 16.2bn total spend - 72% product-related, 28% non-product-related). ASML asked 180 in-scope suppliers to complete the RBA SAQ in 2025 (2024: 147); results indicated generally low-to-medium supply-base risk, though the process flagged forced-labor and health & safety risks at some suppliers, which were followed up.

Responsible product design/use: Global Product Safety and Regulatory teams (within Quality and Excellence) apply ISO 12100 machinery-safety principles across the product lifecycle; every ASML-developed product shipped complies with SEMI S2 (Environmental, Health and Safety Guideline for Semiconductor Manufacturing Equipment). 2025 focus areas included supply-chain product safety, dangerous-goods management and materials/substance compliance.

Value chain worker targets

Reference: Sustainability statements - Social - Responsible value chain - Targets and performance (p.241-242).

Achieve 90% completion of the RBA SAQ by all in-scope suppliers by 2025 - actual 90% in 2025 (2024: 91%; base year 2020: 88%) - target achieved, remains in place through 2026.

Achieve 100% evaluation of, and agreed follow-up action with, suppliers identified by the RBA SAQ as overall high-risk, by 2025 - actual 100% in both 2024 and 2025 (all nine high-risk suppliers each year fully evaluated; base year 2020: 100%) - target achieved, remains in place through 2026.

For Responsible product design/use, ASML states it has not set measurable numeric targets but tracks progress qualitatively through its product-safety governance and RBA-aligned processes, per S2-5's reference-table note.

Community policies

Reference: Sustainability statements - Social - Valued partner in our communities - How we are managing (p.251-253).

ASML's Valued Partnership approach applies worldwide to all employees and value-chain partners, and is closely linked to the Code of Conduct and Human Rights Policy. It is executed through the Community Partnership Program (CPP) and an Employee Giving program (matching employee donations up to EUR 10,000 per employee per year), run by ASML's dedicated Society & Community Engagement (S&CE) team, addressing two material sub-topics: attractive communities and inclusive communities.

Engaging with affected communities

Reference: Sustainability statements - Social - Valued partner in our communities - How we are managing (p.253-255); Strategic report - Our business - Engaged stakeholders - Society.

ASML monitors the effectiveness of its Attractive communities and Inclusive communities programs through structural community stakeholder feedback and a set of pre-defined performance indicators (e.g. number of affordable homes supported). Engagement is concentrated around ASML's largest sites, in particular Veldhoven (the Netherlands), where growth-related pressure on housing, mobility, the talent pipeline and education systems is most acute.

Remediation channels for communities

Reference: Sustainability statements - Social - Valued partner in our communities - How we are managing (p.253); General disclosures - Environmental and human rights due diligence (p.148).

ASML's global Speak Up Service is explicitly available to 'people in affected communities' as well as employees and value-chain workers, hosted independently in multiple languages with toll-free numbers and an anonymous-reporting option. Substantiated concerns trigger remedial action; ASML received 111 human-rights-related grievances in 2025 (15 substantiated) across all channels, without a community-specific breakout disclosed.

Actions on community impacts

Reference: Sustainability statements - Social - Valued partner in our communities - How we are managing, Levers for action (p.253-255).

Attractive communities: affordable-housing partnerships with housing corporations, municipalities and developers; sustainable-mobility initiatives (public-private infrastructure, shared mobility, biking-safety support); cultural-integration programs for international employees (language courses, support networks); funding for local sports, arts and music; and 'green communities' measures (biodiversity, decarbonization investment, green-space quality).

Inclusive communities: access-to-employment programs (training, coaching, job-market navigation) and equal-opportunities-in-education programs (multilingual resources, in-school coaching, financial support for disadvantaged students), aimed at broadening the local STEM talent pipeline.

In 2025, ASML provided approximately EUR 75.8 million (2024: EUR 45.2 million) in cash and in-kind Community Partnership Program investment, including employee giving.

Community investment targets

Reference: Sustainability statements - Social - Valued partner in our communities - Targets and performance (p.252).

Target: EUR 2,500 invested in communities per employee (including employee giving) by 2025 (EUR 2,000 to CPP projects + EUR 500 to Employee Giving). 2025 actual: EUR 1,750 per employee (2024: EUR 1,084) - EUR 1,504 per employee to CPP projects (2024: EUR 922) and EUR 246 per employee to Employee Giving (2024: EUR 162). Target not achieved by 2025; ASML has extended the same EUR 2,500/employee target to 2030, citing the time needed to build internal capabilities and a robust investment portfolio. Absolute 2025 CPP + giving investment was approximately EUR 75.8 million (2024: EUR 45.2 million).

Business conduct policies and culture

Reference: Sustainability statements - Governance - ESG integrated governance - How we are managing (p.261-264).

ASML's integrated governance covers five sub-topics: purpose/vision/mission/values; strategy and business priorities; organization, processes and governance; ESG risk management; and responsible business conduct and compliance - underpinned by policies including Speak Up and Non-retaliation, Anti-Bribery and Anti-Corruption, Human Rights, Privacy, Responsible AI, Anti-Fraud, Export Control & Sanctions, and Competition law compliance. Corporate culture rests on ASML's values of 'challenge', 'collaborate' and 'care'. All employees and business partners are expected to adhere to the Code of Conduct. By end-2025, 94% of employees had completed Code of Conduct training (2024: 97%).

Management of supplier relationships

Reference: Sustainability statements - Governance - ESG integrated governance (material IRO table, p.151); Social - Responsible value chain.

ASML identifies 'fair management of relationships with suppliers' as a material impact on people and the environment across the supply chain (Responsible business conduct and compliance sub-topic), alongside risk of failing to comply with supply-chain due-diligence laws and regulations. Supplier relationships are governed through the ASML Supplier Handbook, risk-based ESG contract requirements, and the RBA Self-Assessment Questionnaire program (180 in-scope suppliers assessed in 2025), cross-referenced with the Responsible value chain chapter's supplier due-diligence process.

Prevention and detection of corruption and bribery

Reference: Sustainability statements - Governance - ESG integrated governance - How we are managing (p.263-265).

ASML maintains zero tolerance for bribery and corruption. Its ethics governance model comprises the Compliance, Ethics, Security and Risk Committee (CESR, policy-making and oversight, quarterly ethics-program updates), a CESR Ethics subcommittee (investigating significant Code of Conduct breaches), the Ethics and Business Integrity team (screening all reports), and country-level ethics liaisons. The Speak Up whistleblowing service is hosted independently, available worldwide with toll-free numbers, anonymous reporting, and a strict non-retaliation commitment. Mandatory Anti-Bribery and Anti-Corruption/Anti-Fraud e-learning with yearly refreshers is targeted at higher-exposure functions (BoM, Procurement, Finance, Legal, Internal Audit and others), assessed at least annually.

Incidents of corruption or bribery

Reference: Sustainability statements - Governance - ESG integrated governance: Metrics table (p.267).

Metric covers all convictions and fines for anti-corruption/anti-bribery law violations imposed during the year by a relevant enforcement authority. ASML reported zero convictions and zero fines in both FY2024 and FY2025.