Assystem

The role of the administrative, management and supervisory bodies

Reference: page 38; also pages 64 and 80.

Assystem S.A. is "a French public limited company (societe anonyme) with a Board of Directors. The Board has two specialised Committees - an Audit Committee and a Compensation and CSR (Corporate Social Responsibility) Committee" (page 80).

• Audit Committee - "responsible for carrying out controls on the process used to prepare the non-financial information included in this Sustainability Statement" (page 38).
• Compensation and CSR Committee - "reviews the Group's sustainability strategy, policies and commitments and puts forward recommendations about sustainability matters". Its work on identifying IROs "was reported to the Board, which subsequently validated the IROs after ensuring that they were in line with the Group's CSR strategy" (page 38).
• Executive Committee - "sets and drives Assystem's CSR objectives, in terms of both social and climate issues. In particular, it verifies that the measures put in place to manage the IROs deemed to be material are suitable and effective" (page 38).
• Chief Sustainability Officer - oversees the CSR strategy and "reports directly to the Executive Committee" (page 38). For own workforce a Senior Vice-President HR sits on the Executive Committee (page 64). A Compliance Committee handles whistle-blowing reports (page 80).

Membership of the Board and the Executive Committee, and each member's sustainability expertise, are incorporated by reference to Chapter 4, Sections 4.1.1 and 4.1.3 (page 38). The content index lists GOV-1 at page 38 with incorporation by reference to Section 4.1 (page 88).

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

Reference: page 35; see also page 39.

Assystem gives a dated record of what reached each body in 2025:

• 27 January 2025 - Compensation and CSR Committee reviewed the Group CSR Department's budget and HR reporting data at 31 December 2024.
• 12 March 2025 - the same Committee "validated the achievement levels of the performance criteria underlying the 2024 compensation of Assystem's executive officers and determined the 2025 compensation policies".
• 17 March 2025 - "The Sustainability Auditor presented its work to the Audit Committee", which had reviewed the Sustainability Statement alongside the 2024 financial statements.
• 20 June 2025 - the Executive Committee reviewed 2024 ESG performance, ESG awards and ratings, and "the changes in regulatory and voluntary sustainability reporting requirements (CSRD and SBTi)".
• 23 July 2025 - Compensation and CSR Committee reviewed HR data at 30 June 2025, "in particular absenteeism figures".
• 3 November 2025 - the Committee "examined the Group's diversity policy and half-year CSRD reporting, and validated the updated double materiality matrix".
• Late October 2025 - a specific presentation to the Board on the anti-corruption programme, including a comparison with benchmarks published by France's Anti-Corruption Agency and EQS.

Page 39 tabulates which material IROs were and were not reported to the governance bodies. Three are marked "This matter was not reported on to the governance bodies in 2025": corporate culture, robustness of information systems and cybersecurity, and sustainable procurement.

Integration of sustainability-related performance in incentive schemes

Reference: page 36. Incorporated by reference to Chapter 4, Sections 4.1 and 4.2.

"In 2025, only the compensation of the Deputy CEO included a variable portion contingent on performance conditions, three of which correspond to non-financial criteria based on sustainability metrics. One of these criteria is climate-related, therefore reflecting how climate-related considerations are factored into the Deputy CEO's compensation, in accordance with the requirements of paragraph 13 of ESRS E1."

"The proportion of the Deputy CEO's total variable compensation that is contingent on sustainability-related targets and/or impacts corresponds to 25%, and the proportion contingent on climate-related considerations is 10%."

Criteria are put forward by the Compensation and CSR Committee to the Board, and the executive officers' compensation policies are then submitted for shareholder approval at the Annual General Meeting.

Statement on due diligence

Reference: page 36.

Assystem discloses a cross-reference table mapping the five due diligence elements to sections of the Sustainability Statement:

• (a) Embedding due diligence in governance, strategy and the business model - Sections 3.1.2.1, 3.1.4.3, 3.2.1.4, 3.3.4, 3.3.7, 3.3.8, 3.3.9, 3.3.10, 3.3.11, 3.3.12.
• (b) Engaging with affected stakeholders in all key steps of the due diligence - Sections 3.1.2.1, 3.1.3.3, 3.3.3, 3.1.4.1, 3.2.1.3, 3.4.2, 3.2.1.2, 3.2.1.5, 3.2.1.6, 3.3.6 to 3.3.12.
• (c) Identifying and assessing adverse impacts on people and the environment - Sections 3.1.4.1, 3.2.1.3, 3.4.2, 3.1.3.4, 3.2.1.4, 3.3.5, 3.3.7 to 3.3.12.
• (d) Taking actions to address those adverse impacts - Sections 3.2.1.6, 3.3.7 to 3.3.12.
• (e) Tracking the effectiveness of these efforts and communicating - Sections 3.2.1.6, 3.2.1.4, 3.2.1.7, 3.2.1.8, 3.2.1.9, 3.3.8 to 3.3.12.

The table is a signposting exercise only; the report gives no separate narrative on due diligence outcomes under GOV-4.

Risk management and internal controls over sustainability reporting

Reference: pages 36-37. Incorporated by reference to Chapter 2, Section 2.1.1.

"Each sustainability matter has a process owner who is responsible for the information reported by all of the Group's countries and entities, and for ensuring its traceability, and the CSR Department oversees compliance with the applicable governance and internal control standards" (page 36).

"Assystem's Board of Directors is ultimately responsible for verifying that the internal control system is properly implemented and works effectively. This responsibility includes internal controls related to sustainability risks." Executive Management is described as the system's owner (page 36).

"The Group has extended its pre-existing practices relating to internal controls on financial reporting (see Chapter 2) to its sustainability reporting. These practices include measures, procedures, instructions, authorisations and delegations of responsibility designed to manage and reduce sustainability risks" (page 37). Control results are reported through business reviews and communicated to the internal and external auditors, the Board and the Audit Committee on an annual schedule.

Page 37 then sets out the Group's material sustainability risks with a description and a management process for each: climate change mitigation, training and skills development, gender equality and equal pay, health and safety, cybersecurity and robustness of information systems, client satisfaction, and sustainable procurement. Assystem closes: "the Group is not aware of any material non-financial risks other than those described in this Sustainability Statement".

Strategy, business model and value chain

Reference: pages 39-40; business model incorporated by reference to page 6.

Assystem is a French engineering and digital services group focused on the energy transition. The business model, "together with its sectors of activity and categories of clients served, inputs and outputs, and the boundaries of its upstream and downstream value chain - neither of which are extensive for the Group and are focused on essential stakeholders - are presented in the Business Model on page 6" (page 39). "In 2025, the type of services provided, and the sectors and client categories served by the Group, were the same as in 2024."

Page 6 gives the business model inputs and contributions: 7,729 employees, 20 key accounts generating around 78% of revenue, EUR 4m of investments, one acquisition, EUR 59.7m net debt, EUR 7.8m of taxes paid, 75 partnerships with universities and engineering schools. Nuclear represented 77% of 2025 revenue and France 59% (page 5).

The CSR strategy is called "Switch to ImpAct" and "integrates environmental, social, governance and financial growth objectives into the overall CSR strategy in order to contribute to creating a sustainable society capable of undertaking an effective energy transition based on the abundant production of affordable carbon-free energy and the switch from fossil fuels to electricity" (page 39). Its three commitments are driving the energy transition, building technical and scientific knowledge, and developing business responsibly, ethically and inclusively. "In accordance with the applicable laws and regulations, the Group does not sell any products or services that are banned in the markets in which it operates."

Page 40 carries the CSR performance table linking each material sub-topic to a metric, target and three years of data.

Interests and views of stakeholders

Reference: pages 41-43.

Assystem maps stakeholders on a three-level hierarchy "based on (i) their degree of influence over the Group, (ii) the perceived legitimacy of their needs and expectations, and (iii) the urgency with which these must be addressed" (page 41), plotted on a two-axis chart of stakeholders' influence on Assystem against Assystem's influence on stakeholders.

• Tier 1 (pages 42) - clients, shareholders, partners and competitors: "stakeholders that have influence over Assystem's strategy and are able to directly affect its sustainability-related decisions". Each row gives expectations, dialogue methods and the linked IRO, for example clients (annual satisfaction survey, conferences, regular CSR and Procurement discussions) mapped to climate change, carbon footprint, business ethics and integrity, health and safety, training and skills development, robustness of information systems and cybersecurity, and client satisfaction.
• Tier 2 (page 43) - states and governments, employees, job candidates. Employee dialogue runs through an "Employee engagement survey every two years", local meetings, community coordination, dialogue with employee representatives, and road shows and live chats with Management.
• Tier 3 - stakeholders with legitimate expectations but limited influence, whose expectations the Group monitors.

Assystem reports the outcome plainly: "The regular dialogue we engaged in with our stakeholders in 2025 did not reveal any factors that could jeopardise or require significant changes to the Group's strategy or business model" (page 41). Stakeholder engagement quality was also scored in the DMA on frequency, formality and whether ESG issues were discussed, with an average threshold of 7.5 separating "low quality" from "satisfactory" engagement (page 48).

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

Reference: pages 44-45. Incorporated by reference to Chapter 2, Sections 1.2 and 2.2.2.

The consolidated table of material IROs lists 21 rows, each typed (I+ positive impact, I- negative impact, R risk, O opportunity) and tagged with value chain position and time horizon:

• Climate change (E1), 4 - Scope 1 and 2 emissions (I-, long term), Scope 3 emissions (I-, short term), and two rows under "contribution to climate transition": the positive impact of "the creation and/or maintenance of low-carbon energy production facilities" (I+) and "Business growth in industry sectors which will see significant future investments in the areas of energy transition and low-carbon energy" (R).
• Own workforce (S1), 9 - secure employment and social protection (O), working time and work-life balance (O), health and safety (I-), diversity and inclusion and anti-harassment measures (O), gender equality and equal pay (R and O), training and skills development (I+, R and O).
• Business conduct (G1), 3 - business ethics and integrity (I+ and I-) and governance and corporate culture (I+).
• Specific sustainability matters, 5 - cybersecurity and robustness of information systems (I- and R), client satisfaction (R and O), sustainable procurement (R).

Assystem states that "Positive and negative impacts arise from the implementation of operations related to the Group's business model but they do not alter the business model itself", and that "As its business model is focused on services, and therefore only requires a low level of CapEx, Assystem did not identify any material direct financial impacts related to sustainability matters in 2025. The Group also expects this to be the case in 2026" (page 45).

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

Reference: pages 46-51.

The double materiality assessment starts from "the list of topics, sub-topics and sub-sub-topics in AR 16 of ESRS 1", adapted to Assystem's activities using its risk map, environmental analysis, HR data and peer benchmarking (page 46). Time horizons follow ESRS 1: "short-term: within one year; medium-term: one to five years; long-term: over five years".

Impact materiality (page 47): severity is the sum of scale, scope and irremediable character, each scored 1-4, giving a score out of 12; likelihood is scored 0 to 1. "Impact materiality score = Severity x Likelihood (resulting in a score of 12 for a negative impact and a score of 8 for a positive impact)", with all scores then weighted to a score out of 12. In line with ESRS 1 paragraph 45, severity would take precedence over likelihood for a potential negative human rights impact: "No such case was identified but this approach has been incorporated into the methodology and will be applied if the need arises."

Financial materiality (pages 47-48): magnitude scored 1-4 and likelihood 0.2 to 1, reconciled with the Group risk map, then weighted to a score out of 12. "This process was unchanged in 2025 compared with the previous reporting period."

Threshold (page 48): "All impacts, risks and opportunities resulting in a materiality score of between 6 and 12 were considered material."

Results were disaggregated through meetings with representatives of France, the United Kingdom, India and Saudi Arabia and with the CSR, Human Resources, Finance and HSE functions, then "presented to the Compensation and CSR Committee for validation". Page 49 carries the materiality matrix and page 51 the list of non-material matters with reasons.

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: page 52; index tables at pages 88-90 and 91-93.

Section 3.1.4.2 (page 52) points to the appendices: "The tables related to 'Sustainability matters and disclosures covered by the Sustainability Statement' and the 'List of datapoints that derive from other EU legislation [ESRS 2 Appendix B]' are provided in the Appendices to this Sustainability Statement (Sections 3.5.1 and 3.5.2)."

Section 3.5.1 (pages 88-89) is a genuine ESRS content index, giving for each covered disclosure requirement a title, any incorporation by reference and a page number. It lists:

• ESRS 2 - BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2 and App. B.
• Climate change - ESRS 2 IRO-1, ESRS 2 SBM-3, E1-1, E1-2, E1-3, E1-4, E1-6, E1-7, E1-8, E1-9. E1-5 is not listed.
• Own workforce - ESRS 2 GOV-1, ESRS 2 SBM-2, ESRS 2 SBM-3, S1-1 to S1-7, S1-9 to S1-17. S1-8 is not listed.
• Business conduct - ESRS 2 GOV-1, ESRS 2 IRO-1, G1-1, G1-3, G1-4. G1-2, G1-5 and G1-6 are not listed.

Page 90 adds a second table mapping each material sustainability topic and sub-topic to the section that covers it, including the three specific sustainability matters. Section 3.5.2 (pages 91-93) reproduces the Appendix B datapoints derived from other EU legislation with their SFDR, Pillar 3, Benchmark Regulation and EU Climate Law references and the section of the statement that carries each one.

Transition plan for climate change mitigation

Reference: page 53; the plan itself is described at pages 58-60.

"In line with our clear positioning in this domain, the targets of our GHG emissions reduction plan - aimed at mitigating our impact on climate change - has been submitted to and validated by the Science Based Targets initiative (SBTi). The work conducted by the Group on identifying the most appropriate actions to take based on the breakdown of its GHG emissions by scope, and in line with the pathway of limiting global warming to less than 1.5C, are summarised in a climate transition plan, which is described in Section 3.2.1.6" (page 53).

Governance and approval: "The content of the climate transition plan was drafted by an international and interdisciplinary team led by the Procurement & Sustainability Department, and was approved by the Group Executive Committee" (page 53).

Funding: "As the climate transition plan does not involve material expenditure, the Group does not seperately disclose a related capital expenditure programme in its consolidated financial statements" (page 53). No quantified climate CapEx or OpEx figure is given anywhere in the statement.

Taxonomy and benchmarks: "We have not identified any economic activities that substantially contribute to climate change mitigation within the scope of the Taxonomy Regulation"; "The Group is not excluded from the EU Paris-aligned Benchmarks" (page 53).

Note an internal inconsistency worth checking: page 37 (GOV-5 risk table) and page 67 (S1 section 3.3.5) both describe the transition plan as "currently being drawn up", while page 53 presents it as drafted and approved.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 53-55). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification. Physical and transition risks are assessed separately. Page 54 tabulates material physical risks in three groups: risks to Assystem's own working conditions in all geographies; risks to Assystem's clients and sectors in France and the UK; and risks in India and Saudi Arabia (extreme heat and heatwaves; water stress and river flooding). Each is split into chronic and acute and each is assessed Material. Page 55 records one material transition opportunity in market and services.

Methodology (page 53). The 2021 analysis was updated in 2025. "The objective of assessing our exposure to physical risks was to determine how resilient our activities would be in a global warming scenario of 4C above pre-industrial levels (the IPCC's RCP 8.5 scenario)", to 2030 for direct operations and to 2050 for the downstream value chain "due to the long lifespan of client projects". Risks were assessed per key business per region, covering nuclear and renewable energy in France and the UK and transportation and urban and industrial infrastructure in India and Saudi Arabia. "Between 25 and 50 models were used (depending on the indicator) to provide a climate signal. The granularity of the projections varied between 12.5 to 50 kms depending on the indicators, using an Assystem site (for 88% of the assessments) or a client site as the point of departure." Hazards screened were drawn from the EU Taxonomy list.

Transition risks (page 54). "The assessment was carried out using the IPCC's RCP 2.6 scenario", over horizons to 2030 and 2040, covering nuclear, renewable energy and transport infrastructure plus two cross-cutting dimensions, the electricity grid and digital technology and AI. "Information from IEA and IPCC reports was added to the transition scenarios used."

Gap: no global average temperature projection is stated per scenario (ESRS E1 paragraph 17(a)(iii)), and no 1.5C-aligned transition scenario is named - RCP 2.6 is used instead. Areas of uncertainty are disclosed for both assessments (pages 54-55).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 55-56). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results. "The results of the climate-change risks and opportunities assessment performed in 2025 using the IPCC's RCP 2.6 and RCP 8.5 scenarios suggest that the Group is exposed to physical risks whose financial impacts still need to be clarified, has low exposure to transition risks, and has a number of opportunities" (page 55). "Most of the transition-related risks mentioned in the resilience analysis had already been identified by the Group, with no identification of domains that present a significant risk."

Scope. "The resilience analysis highlighted the scenarios in which the Group could be impacted by climate events. It entails an assessment of climate-change risks and opportunities for the time horizons up to 2030 and 2050 ... and encompasses Assystem's own operations as well as the downstream part of its value chain." It covers France, the United Kingdom, Saudi Arabia and India, "which together represented 97% of the Group's consolidated revenue in 2025"; geographies with under 2% of the workforce, such as Uzbekistan and Turkiye, were excluded (page 55).

Capacity to adapt. "Vulnerability to these risks could be mitigated in France and the UK by developing specialised climate resilience engineering services if client demand for such services emerges. In India and Saudi Arabia, the Group has not currently identified any measures that would enable it to offset the effect of any business interruptions or slowdowns" (page 55).

Uncertainty and refresh. "Performing resilience analyses based on climate scenarios is an emerging discipline. Consequently, the Group intends to update its analysis in line with any major developments in its business and/or changes in scientific knowledge" (page 56). "In 2026, the Group will assess the financial impact of the risks identified in the above scenarios in order to determine the most appropriate adaptation measures" (page 55).

Policies related to climate change mitigation and adaptation

Reference: page 58.

"Assystem addresses its climate-related impacts, risks and opportunities through its overall CSR strategy called 'Switch to ImpAct'. The first pillar of this strategy is focused on climate change issues", with three stated objectives:

• Contribute to the energy transition - "Assystem firmly believes that nuclear energy must form part of the solution to climate change. With a view to adapting to climate change and continuing to create positive impacts, the Group's strategy and positioning are driven by seizing growth opportunities in energy transition sectors".
• Raise awareness about climate change among employees and other key stakeholders.
• Structure a GHG emissions reduction pathway - "Assystem applies an emissions management strategy in order to track its GHG emissions profile and identify relevant reduction measures and initiatives".

The policy table records a single Group-scope policy, "Switch To Impact", with the Chief Sustainability Officer responsible for implementation, employees and clients taken into account when establishing it, availability to employees, sub-contractors, partners and clients, and coverage of "All the IROs listed in Section 3.2.1.4".

Two limits are disclosed on the face of the policy section. "The Switch & Act for Climate programme only covers the Group's material impacts, risks and opportunities, in line with its business model and GHG emissions profile." And: "Assystem does not have specific policies related to renewable energy consumption or energy efficiency. These elements are addressed in the overall considerations related to reducing its Scope 1 and 2 emissions."

Actions and resources in relation to climate change policies

Reference: pages 59-60.

Five named action areas, several with a quantified expected contribution:

• Electrifying the vehicle fleet - a programme to reach "an all-green fleet of electric and hybrid vehicles". Company vehicles offered in France are all-electric; charging points are being installed at Assystem sites and through client partnerships; in Saudi Arabia the Group "intends to replace our fleet with lower-emission vehicles and to gradually introduce hybrid vehicles as and when local conditions allow". "These actions are expected to help reduce Scope 1 emissions by an estimated 1.3 ktCO2eq by 2030" (page 59).
• Managing electricity consumption - "In France, nearly all of our sites are supplied with low-carbon electricity thanks to Power Purchase Agreements (PPAs), which have helped to reduce emissions by 40tCO2eq since they were signed in 2024. In the United Kingdom, almost 70% of our sites are supplied with renewable energy, and we expect to see a 30 tCO2 reduction in emissions in 2026." India and Saudi Arabia focus on energy-saving measures including scheduled supply interruptions (page 60).
• Buildings and workspace organisation - selecting buildings meeting current environmental standards, right-sizing floor area, site closures in 2025, and for 2026 exploring measures "such as closing offices one day per week" (page 60).
• Business travel and employee commuting - mobility plans in France, car-pooling planned for 2026, restrictions on booking flights "when there is a lower-carbon alternative", expected to cut Scope 3 by "around 0.17 tCO2eq per FTE by 2030"; large-scale remote working in France and the UK "will enable us to reduce our carbon intensity by 0.20 tCO2eq per FTE by 2030" (page 60).
• IT infrastructure and digital technologies - a methodology change from financial estimates to physical data "led to a 42% year-on-year reduction in Scope 3 emissions related to IT infrastructure and the use of digital technologies, i.e. an emissions intensity of approximately 0.23 tCO2 eq per FTE in 2025" (page 60).

No CapEx or OpEx amounts are attached to any of these actions.

Targets related to climate change mitigation and adaptation

Reference: pages 58-59.

"In 2024, the SBTi (Science Based Targets Initiative) validated two targets set by the Group" (page 58):

1. Reduce absolute Scope 1 and 2 GHG emissions by 42% by 2030 compared with a base year of 2022. "This target is based on the Absolute Contraction Approach, and is compatible with a pathway limiting global warming to 1.5C above pre-industrial levels by 2030. The SBTi's target validation team reviewed Assystem's Scope 1 and 2 emissions reduction target and considered it as aligned with a 1.5C scenario." Organisational coverage: 95% of total Scope 1 and 2 emissions.
2. Reduce Scope 3 GHG emissions from purchased goods and services, capital goods, fuel and energy-related activities, business travel and employee commuting by 51.6% per FTE by 2030 versus a base year of 2022. It covers five of the eight relevant categories, excluding investments (3.15), waste (3.5) and upstream transportation and distribution (3.4), which together were 7% of 2025 Scope 3; organisational coverage 90% of total Scope 3.

Progress against target (page 59):

Assystem states plainly that emissions remain above the base year, attributing this to higher purchases of services, "the adoption of more granular and robust reporting practices" and "the Group's larger organisational structure following the mergers and acquisitions carried out between 2022 and 2025". "Due to the recent changes in its organisational structure, in 2026 we will establish a new base year for our SBTi targets" (page 59). No adaptation target is disclosed.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 56-57.

Scope 3 by category in 2025: purchased goods and services 22,458; capital goods 3,270; fuel and energy-related activities 1,525; upstream transportation and distribution 21; waste generated in operations 208; business travel 2,606; employee commuting 5,327; investments 2,443.

"Assystem recorded an 8% year-on-year reduction in its Scope 1 and 2 emissions in 2025, reflecting (i) lower emissions in France due to a higher proportion of EVs in the vehicle fleet and the signature of renewable energy purchase agreements, and (ii) energy efficiency measures implemented in India. Scope 3 emissions decreased by 5%, mainly attributable to (i) more granular reporting of IT-related emissions, and (ii) less business travel and improved reporting of the related emissions" (page 57).

Intensity: total GHG emissions per net revenue fell 5%, from 0.0727 to 0.0688 tCO2eq/EURk market-based and 0.0728 to 0.0689 location-based, calculated over entities representing 94% of consolidated revenue (page 57).

Check this line. The report's year-on-year column shows location-based Scope 2 as "(4)", the notation it uses elsewhere in the same table for a decrease, but 2,336 rising to 2,422 tCO2eq is an increase of about 4%. Every other line in the table reconciles to its printed percentage.

Restatement: 2024 Scope 1 data for the United Kingdom "previously included data related to Scope 3 emissions" and has been corrected (page 35).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 61. Listed in the ESRS content index at page 88.

Assystem gives a complete nil return: "To date, Assystem has not carried out or contributed to any projects for removing or mitigating GHGs financed through carbon credits" (Section 3.2.1.7, page 61).

This is consistent with the targets disclosure, which describes the SBTi-validated Scope 1 and 2 and Scope 3 targets as reduction targets with no removals or offsetting component, and with the transition plan statement that the plan "does not involve material expenditure" (page 53). No net-zero claim is made that would depend on removals or credits.

Internal carbon pricing

Reference: page 61. Listed in the ESRS content index at page 88.

A nil return: "As at the date of this report, the Group had not put in place any internal carbon pricing system, and therefore does not have any methods or assumptions related to this type of metric" (Section 3.2.1.8, page 61).

No shadow price, internal fee or implicit price is applied to investment decisions, and none is signalled as planned. Read alongside the transition plan, which carries no quantified CapEx programme (page 53), the Group's decarbonisation decisions are not disclosed as being priced.

Policies related to own workforce

Reference: page 69; individual policies described at pages 70, 71, 74, 76 and 78.

Page 69 tabulates six Group-scope policies, each with the manager responsible, the standard used, the stakeholders considered, how the policy is made available and the numbered IROs it addresses:

• Health and safety policy - Group HSE Director, ISO 45001 (IROs 3).
• Diversity and inclusion policy - Head of Diversity and Inclusion, referencing the ILO Charter, the Women's Empowerment Principles, the UN Global Compact and local legal frameworks (IROs 1, 2, 7, 8, 9).
• Training, skills development and career management policy - Head of Learning and Development, ISO 9001 and ISO 19443 (IROs 4, 5).
• Recruitment policy - Head of International Sourcing and Talent Acquisition (IROs 5, 6).
• Compensation and benefits policy - Head of Compensation and Benefits, local legal frameworks and collective bargaining agreements (IROs 1, 2, 8, 9).
• Gender equality policy - Head of Diversity and Inclusion, UN Women's Empowerment Principles and local frameworks (IROs 7, 8).

On human rights commitments, "Assystem is a member of the United Nations Global Compact, and it views the conventions of the International Labour Organisation (ILO) as a lever for action ... This comprises freedom of association and collective bargaining, the elimination of discrimination in respect of employment and occupation, the elimination of forced or compulsory labour, and the effective abolition of child labour" (page 70).

One policy gap is stated openly: "Assystem does not have a specific overall policy on social protection" (page 78).

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

Reference: page 67.

"Under the responsibility of the SVP HR, Assystem organises negotiations, consultations and discussions between management and employee representatives within its entities on human resources and financial topics relating to the Group. The topics addressed can either be entity-specific or can relate to the Group as a whole, such as financial and organisational issues, gender equality, human rights, health and safety, working hours and conditions, and pay. These are all topics that are considered material for the Group based on its business model."

"The frequency of these employee representative meetings and discussions depends on the relevant statutory requirements. This Group-level social dialogue is rounded out by local initiatives put in place by the management teams of Assystem's various entities."

"Assystem draws on these interactions with employees to help set targets, monitor performance, learn lessons and identify areas for improvement."

The wider engagement architecture is described under SBM-2, where employees are a Tier 2 stakeholder engaged through an "Employee engagement survey every two years", local office meetings, community coordination, dialogue with employee representatives, and road shows and live chats with Management (page 43). Assystem records that Social and Economic Committees are in place in France, with local employee representatives in some cases, and that Health and Safety Committees in the United Kingdom and Turkiye include employee representatives, while "The Group's other host countries do not currently have any employee representative bodies" (page 51).

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

Reference: page 67.

"The Group has put in place formal procedures (in particular for grievances and whistle-blowing) so that its employees can raise any social, psychological or administrative concerns or requirements they may have. They can also obtain responses for remediating any negative impacts through: their annual performance appraisals; and the employee support services available in most of the Group's entities."

"Any concerns raised by employees are handled on a case-by-case basis by one or more members of Management of the relevant entity. Responses are given directly to the employee, as well as to the employee representatives where appropriate."

Effectiveness is measured: "The effectiveness of the channels available for employees to raise their concerns is illustrated by the results of the 2025 employee survey (score of 7.2, up 0.2 compared with 2023)."

The Group-wide whistle-blowing channel sits under business conduct: reports are made "via a dedicated and secure website and completely anonymously" and handled by a Compliance Committee made up of the Deputy CEO, the CFO, the SVP HR and the Group Chief Legal and Compliance Officer, whose members "have a legal duty of confidentiality" (page 82). A specific psychosocial support line, "Assystem for me", is available to vulnerable employees (page 77).

Taking action on material impacts on own workforce

Reference: pages 70, 73, 75, 77, 78 and 79.

Action plans are given per sub-topic:

• Human rights and harassment (page 70) - "zero-tolerance policy in relation to bullying, sexual harassment and sexist behaviour", with communication campaigns launched in France in 2023 and extended internationally, management training in India, and UK anti-discrimination rules adapted "to the Equality Act 2010 (Amendment) Regulations 2023". Managers receive a psychosocial risk guide and dedicated training.
• Women's recruitment, retention and empowerment (page 73) - the "#IncredibleWomen" programme launched in 2010; signatory of the Syntec Ingenierie Diversity Charter and the UN Women's Empowerment Principles; support for #StOpE and Women in Nuclear in the UK; women-focused mentoring in France and the UK, with preparation in 2025 to extend it to India in early 2026.
• Disability inclusion (page 73) - a disability inclusion unit at AEOS in France since 2007 and four successive company agreements, the most recent covering 2023 to 2025, with a Disability Inclusion Charter signed for 2026 to 2028. "Assystem's disability employment rate in France was 4.97% at 31 December 2025 (pending confirmation by the relevant authorities)."
• Training (page 75) - the Assystem Induction Programme, structured learning pathways built on a Career Map with five career tracks, an e-learning platform, tutoring, mentoring and coaching, and a doctorate programme in France, the UK and Saudi Arabia.
• Health and safety (page 77) - the full launch of the Switch On Safety programme in 2025 including publication of Life Saving Rules, built on four drivers: new Life Saving Rules, a behavioural change programme, stronger management engagement, and overhauled operational preparation methods.
• Work-life balance (page 79) - a Group-level remote working agreement, a work-life balance agreement covering the right to switch off, and a Work-Life Balance Charter in France.

Resourcing is disclosed consistently as immaterial: the actions have "not required any significant OpEx or CapEx or the allocation of any current or future financial resources that need to be disclosed" (pages 71, 75).

Targets related to own workforce

Reference: pages 77 and 78; summary table page 40.

Targets are disclosed inside the metrics tables rather than in a dedicated section:

• Health and safety (page 77) - "% of employees covered by the Group's health and safety management system" target >95% (99.7% in both 2024 and 2025); "Number of fatalities as a result of work-related accidents and work-related ill health" target 0 (0 in both years); "Frequency rate of work-related accidents with lost time" target <1 (0.38 in 2024, 0.68 in 2025).
• Work-life balance (page 78) - "% of employees able to take family-related leave" target 100% (100% in both years).

The Group summary of CSR performance (page 40) repeats these and adds the training investment, gender and diversity metrics, which are reported with a dash in the target column, so no target is set for them: proportion of women in the workforce (27%), women in top management roles (20.1%), and investment in training as a percentage of payroll (1.66%).

Two sub-topics carry an explicit absence of a target. For social protection: "At this stage, the Group does not have any specific metrics for measuring its employees' social protection coverage. It is therefore not in a position to measure the effectiveness of its social protection policy, or to provide a target or a schedule for achieving the policy's objectives" (page 78). For diversity, page 96 records only that "The Human Resources Department of each entity reports their target to the Group based on their current situation and their ability to recruit or promote women to Top management positions", without a Group figure.

Characteristics of the undertaking's employees

Reference: pages 64-66; methodology page 96.

Total headcount at 31 December 2025 was 7,039, down from 7,200 in 2024.

No employees are recorded under "Other" or "Not disclosed" gender categories, because "Currently, only 'male' and 'female' gender denominations feature in the database" (page 96).

By country at 31 December 2025: France 4,320 (61%), India 1,317 (19%), United Kingdom 975 (14%), Saudi Arabia 222 (3%), Turkiye 85 (1%), Uzbekistan 60 (1%), other countries 60 (1%). By region: Europe 5,303 (75%), Asia 1,389 (20%), Middle East 319 (5%).

"Assystem's 'non-guaranteed hours employees' are all employed in the United Kingdom. There are very few of these, and they correspond to workers on 'zero-hour contracts'" (page 96). Turnover is reported under training: "In 2025, staff turnover due to resignations (voluntary departures) amounted to 13.1%, marking a decrease on the Group's customary rate of 15%", with 1,958 employees recruited (page 74).

Characteristics of non-employee workers

Reference: page 66; methodology page 96.

The methodology note defines the population: non-employees are "consultants (freelancers) in India: these non-employees are not on the payroll of a Group entity and often work on a sole trader basis, generally under a contract related to a particular project or for a fixed period", with data drawn from the Group's central Human Resources database (page 96).

"No underlying assumptions or estimates have been used for the metrics on the characteristics of non-employees, and their measurement has not been validated by an external body other than the assurance provider" (page 96).

The 2025 figure of 7,729 employees shown in the business model on page 6 reconciles to 7,039 employees plus contractors.

Diversity metrics

Reference: page 72; methodology page 96.

Top management by gender

"'Top management' means the Senior Vice-Presidents and Directors in the job maps of all Group entities" (page 96).

Employees by age group

Women were 27% of the total workforce in both 2024 and 2025 (pages 40, 64). Assystem sets the figures against the sector context it cites: "only 23% of scientific and engineering jobs in France held by women" (IESF survey, 2025, page 71). The scope for diversity metrics is the Group, and no estimates were used (page 96).

Adequate wages

Reference: page 72; methodology page 96. Listed in the ESRS content index at page 89.

The full disclosure: "In 2025, all of Assystem's employees received a salary at least equal to the statutory minimum wage or the amount set in the applicable collective bargaining agreements in each of its countries of operation. Systematic controls are regularly performed to make sure that no employee is paid below the statutory minimum wage in the country or region where they work" (page 72).

The methodology appendix records that the controls are described country by country and that "No estimates have been used for these metrics and their measurement has not been validated by an external body other than the assurance provider" (page 96).

Adequate wages sits in an unresolved position in the report. The general list of non-material matters on page 51 includes "Adequate wages" among the Own workforce sub-topics classified as non-material, while the S1 chapter's own sub-topic table marks "Gender equality, equal pay for work of equal value, adequate wages" as material (Yes, page 68) and the content index lists S1-10 with page references. The disclosure itself is present, so it is recorded here as reported.

The underlying pay policy is set out at page 71: "Our pay policy is performance-based and individualised, while being rooted in collective social dialogue in accordance with the legal frameworks that apply in each country", supplemented by health and welfare coverage reviewed in 2025/2026 with findings due later in 2026.

Social protection

Reference: page 78; methodology page 97. Listed in the ESRS content index at page 89.

Assystem discloses the policy position, the action plan and coverage, and then states expressly that the metric is omitted.

Policy: "Assystem does not have a specific overall policy on social protection. However, the various policies applied by the Group together create the foundations for secure employment and shape its overall measures for ensuring that each employee has full protection against the main social risks." Policies vary by country and "focus on essential issues, such as access to healthcare and coverage in the event of death, disability or temporary inability to work". Top-up coverage supplements state benefits, "often through private insurance policies".

Action plan: "Based on the review work carried out in 2024, the Group has assurance that it is currently compliant with the applicable local regulations related to healthcare coverage. In 2026, the review will be extended to cover the other areas of social protection for which analyses are required under ESRS S1-11." The June 2025 employee survey "showed a 6.3/10 satisfaction rate for the social protection benefits offered by the Group", and "The social protection action plan covers over 95% of the Group's workforce".

Metric: "At this stage, the Group does not have any specific metrics for measuring its employees' social protection coverage. It is therefore not in a position to measure the effectiveness of its social protection policy, or to provide a target or a schedule for achieving the policy's objectives. As permitted under ESRS S1, this metric has been omitted for 2025."

Persons with disabilities

Reference: page 72; methodology page 97.

Assystem qualifies the figure: "Each country is subject to its own laws and its own definitions of disability and employees with disabilities, and the information below takes this into account" (page 72).

A separate national figure is disclosed under the action plans: "Assystem's disability employment rate in France was 4.97% at 31 December 2025 (pending confirmation by the relevant authorities)" (page 73).

The supporting arrangements are described at page 73: Assystem Engineering and Operation Services in France "was the first engineering company to set up a disability inclusion unit, back in 2007, and since then, four company-level agreements have been signed, with the most recent covering the period from 2023 to 2025", with a Disability Inclusion Charter signed for 2026 to 2028. The unit focuses on hiring and integration, on-the-job support and workstation adaptation, and awareness campaigns. Outside France the Group works to local quotas and certifications, naming the Mowaamah certificate and the Disability Confident Scheme, and also "sub-contracts work to sheltered workshops for some assignments" in France.

Training and skills development metrics

Reference: page 74; methodology page 97.

"Training provided through the Assystem Institute and as part of skills development plans represented an average of 1.66% of total payroll in 2025 and covered 70% of the workforce. In 2025, we worked on optimising our training systems which meant that some metrics decreased year on year, although the proportion of employees who received training remained similar and in line with our operational priorities" (page 74). Training investment as a share of payroll has fallen for three years running: 2.5% in 2023, 2.2% in 2024, 1.66% in 2025 (page 40).

Assystem qualifies the appraisal metric: it "was calculated based on total headcount at 31 December 2025 (S1-6), i.e. 7,039 people. However, Assystem feels it is important to point out that, based on the Group's criteria for deciding which members of its workforce fall within the scope of the performance appraisal system, the total number of employees who actually formed part of the appraisal cycle in 2025 was 6,587. Using this figure, the percentage comes out at 96%" (page 74).

Health and safety metrics

Reference: page 77; methodology page 97.

Assystem reports the deterioration openly: "Although some metrics showed unfavourable trends in 2025, the frequency rate of work-related accidents with lost time remained low, and below the target." Accidents rose from 5 to 9 and days lost from 155 to 377.

Effectiveness is also gauged through the biennial employee survey: "The participants in the 2025 survey gave scores of 7.2 out of 10 for their sentiment about both working conditions and health and safety within the Group, up 0.2 points on the previous survey" (page 77).

Context from the policy section (page 76): "In Europe, given the nature of our activities - i.e. engineering and support services - the Group has limited exposure to the risk of serious accidents ... Physical risks mainly relate to road accidents, slipping and falling, and, to a lesser extent, repetitive strain and the working environment, while risks associated with exposure to ionizing radiation remain low." The risk prevention system is built on ISO 45001 and "covers almost all of the Group's entities, including those that do not yet have ISO 45001 health and safety certification".

Work-life balance metrics

Reference: page 78; methodology page 97.

The take-up breakdown is new in 2025; no 2024 comparative is given.

Assystem qualifies the basis: "Assystem rigorously complies with local laws and regulations regarding family-related leave in all Group entities. The information presented below is based on an interpretation of the different procedures and processes regarding work-life balance, working hours and workplace well-being in place within the Group's various subsidiaries" (page 78).

Supporting measures (pages 78-79): family-related leave, "specific working arrangements and flexible working hours", regulated overtime, with night and weekend work "strictly managed in order to protect employees' health and well-being"; a Group-level remote working agreement; a work-life balance agreement setting out "employees' rights to 'switch off' from work-related communications outside working hours"; and a Work-Life Balance Charter in France. "The responses to the 2025 employee survey were very positive on this topic (with a score of 7.5/10), illustrating the effectiveness of the policies in place."

Compensation metrics (pay gap and total compensation)

Reference: page 72; methodology pages 97-98.

Method: "(Average gross hourly pay of male employees - Average gross hourly pay of female employees) / Average gross hourly pay of male employees x 100", using a reference salary of "fixed contractual salary expressed on a full-time annual basis + bonuses + benefits", with long-term incentives excluded, divided by 52 weeks and then by the average weekly working hours in each entity (page 98).

Assystem restricts the disclosure to a single metric and says so: "in accordance with ESRS 1, which requires disclosure of relevant information about impacts, risks and opportunities that are deemed to be material, the only ESRS S1-16 metric that Assystem will henceforth report on is the gender pay gap" (page 35). No annual total compensation ratio between the highest paid individual and the median employee is disclosed. Coverage is also limited: "S1-16 disclosures cover 98% of the Group's workforce. Entities not included in the metrics are deemed to be non-material in view of their low headcount" (page 35).

The company adds a caveat on interpretation: the metric "does not factor in the inherent differences in the geographic, sectoral and organisational contexts in which the Group operates, or the specific characteristics of the employment law frameworks that apply in each country. These factors result in methodological bias which needs to be considered when interpreting the figures" (page 72). The 2024 figure was restated following a 2025 methodology change.

Incidents, complaints and severe human rights impacts

Reference: page 70; methodology page 98.

Assystem explains the doubling: "The year-on-year increase in the number of incidents is due to the growing effectiveness of the systems in place for local line managers to report incidents to their Human Resources teams, and does not in any way reflect a structural trend."

"Assystem has never been convicted of a breach of human rights. Also, Assystem has never been reported to the OECD in relation to a human rights issue and no allegations against the Group have ever been lodged with the Business & Human Rights Resource Centre" (page 70, repeated at page 61 in the EU Taxonomy minimum safeguards section).

The company flags a control limitation on the face of the metric: "The metrics below are not subject to a specific reporting procedure. However, they are treated on a case-by-case basis by the Human Resources Department of each entity and at Group level." Reporting channels named are direct reports to HR teams, site and department heads, local HR and managers, and "dialogue with trade unions and employee representative bodies in the relevant countries".

Business conduct policies and corporate culture

Reference: pages 80-82.

Assystem identifies two material business conduct matters: business ethics and integrity and anti-corruption measures, and governance and corporate culture (page 80).

Corporate culture: "Assystem's corporate culture is built on the values of transparency, agility and proximity, supported by straightforward operating processes that promote smooth communication and collaborative working." The levers named are the onboarding programme with e-learning modules and a new-hire newsletter, the monthly Group newsletter, the Viva Engage corporate social network, the intranet, Lunch and Learn sessions, the Switchers Manifesto and in-house team-building events (page 81). Effectiveness is measured through the biennial employee survey: "The results of the 2025 survey show a high level of employee buy-in to Assystem's corporate values (engagement score of 6.9/10)."

Policies (page 81): six Group-scope policies are tabulated with the responsible department, the standard used and the IROs concerned - corporate gifts and hospitality; corporate donations, sponsorship and philanthropy; assessing intermediaries; assessing third parties; whistle-blowing; and accounting and financial procedures. All but one sit with the Legal and Compliance Department, and the benchmark used is "France's Sapin II anti-corruption law and recommendations issued by France's Anti-Corruption Agency (AFA), and local regulations applicable to Group entities outside France".

Whistle-blower protection (page 82): reports can be made "via a dedicated and secure website and completely anonymously"; the Compliance Committee members "have a legal duty of confidentiality". Page 51 records that the protection of whistle-blowers sub-topic was assessed and found non-material given the IRO scores and "the low number of whistle-blowing reports received over the years in proportion to the Group's total workforce".

Tax and competition (page 82): the Group states it "has not set up any vehicles, organisations or mechanisms for the purpose of transferring profits to low-tax jurisdictions", that "its effective tax rate is consistently over 20%", and that "the Group has never been convicted of any breaches of competition law".

Prevention and detection of corruption and bribery

Reference: pages 81-82.

"The Group has a zero-tolerance policy towards all forms of corruption and bribery ... Assystem has a specific Code of Conduct on the prevention of corruption and bribery, which covers issues such as conflicts of interest and facilitation payments. There are also specific internal policies based on the Group's map of risks related to corruption and bribery, and special training and presentations are organised in subsidiaries located in countries designated in the Transparency International report as having high exposure to such risks" (page 81).

Who is treated as exposed: "people authorised to enter into binding agreements on behalf of a Group company, including, amongst others, corporate officers, finance directors, procurement and sales managers, and the legal teams" (page 81).

Training (page 82): "The Legal & Compliance Department oversees the programme's implementation and monitors the employees who are considered exposed to the risks of corruption and bribery. As at 31 December 2025, all of these people had followed the anti-corruption and bribery training." "All of the members of the extended Executive Committee have followed the mandatory anti-corruption and bribery training." Board members, "although they are not Assystem employees ... attend anti-corruption and bribery awareness-raising sessions at least once a year." In-person training is run in each geography.

Detection and investigation (page 82): alerts go to a Compliance Committee made up of the Deputy CEO, the CFO, the SVP HR and the Group Chief Legal and Compliance Officer, which "carries out the investigation itself, with assistance from specialist external teams when specific expertise is required". "The Group Chief Legal & Compliance Officer reports once a year on any whistle-blowing cases to the Executive Committee, the Audit Committee and the Board of Directors of Assystem S.A." In late October 2025 the Board received a presentation on the programme benchmarked against AFA and EQS (page 35).

Targets related to business conduct (part of MDR-T/GDR-T disclosures)

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

Assystem does disclose a measurable business conduct target. The Group CSR performance table (page 40) sets, under "Ethics and compliance", the metric "% of risk-exposed employees given anti-corruption training (at 31 December)" with a target of 100%, achieved at 100% in 2023, 2024 and 2025.

Performance against it is confirmed in the G1 chapter: "The Legal & Compliance Department oversees the programme's implementation and monitors the employees who are considered exposed to the risks of corruption and bribery. As at 31 December 2025, all of these people had followed the anti-corruption and bribery training" (page 82).

Consistent with MDR-T's second limb, effectiveness is also tracked in other ways where no numeric target is set: the anti-corruption programme is "sent to all employees each time it is updated"; the Legal and Compliance Department adjusts the training programme "for the Group's different operating countries and in line with applicable local regulations"; a project manager is appointed as compliance lead for specific projects; and the Group Chief Legal and Compliance Officer reports annually on whistle-blowing cases to the Executive Committee, the Audit Committee and the Board (page 82). For corporate culture, the biennial employee survey provides the effectiveness measure, with an engagement score of 6.9/10 in 2025 (page 81), and "The internal communication strategy is reviewed on a yearly basis by the Executive Committee" (page 81).

No target is set for the second material G1 matter, governance and corporate culture, beyond the survey score.

Incidents of corruption or bribery

Reference: page 82.

A nil return, stated in full: "To date, Assystem has not received any convictions or fines for any breach of anti-corruption or anti-bribery laws."

The same position is restated in the EU Taxonomy minimum safeguards section: "The Group has never been convicted for any issue relating to human rights, corruption, bribery, taxation, or breach of competition laws. In addition, it has never been reported to the OECD in relation to such an issue, and no allegations against it have ever been lodged with the Business & Human Rights Resource Centre" (page 61).

Assystem does not disclose the number of confirmed incidents investigated during the year, nor a breakdown of the whistle-blowing reports received, though it describes the reporting line: "The Group Chief Legal & Compliance Officer reports once a year on any whistle-blowing cases to the Executive Committee, the Audit Committee and the Board of Directors of Assystem S.A." (page 82). The volume is characterised only indirectly, in the DMA reason for treating whistle-blower protection as non-material: "the low number of whistle-blowing reports received over the years in proportion to the Group's total workforce" (page 51).