ASTM

Governance roles

Reference: pages 87-89 (index: page 195).

Traditional Italian model: a Board of Directors manages the Company, a Board of Statutory Auditors monitors it. At 31 December 2025 the Board had nine Directors, seven male (78%) and two female (22%), and 33% declared they met the independence requirements of the Borsa Italiana Self-Regulatory Code and art. 148(3) TUF. "There are no executive directors other than the CEO" (page 87). A footnote records that one Director, who chaired both the Sustainability Committee and the Audit and Risk Committee, resigned with effect from 16 December 2025 and was replaced on 11 March 2026.

Committees (page 88): the Sustainability Committee (three directors) supervises sustainability including climate and the EU Taxonomy, examines the Sustainability Plan before Board approval and reviews the Statement annually; the Audit and Risk Committee (three directors) evaluates the adequacy of the Statement and examines the double materiality analysis.

The Board "defines the strategic planning guidelines and policies, which cover topics of socio-environmental nature" and approves the Sustainability Plan, the double materiality methodology and findings, and the Consolidated Sustainability Statement (page 88).

The index adds, under paragraph 21(b), that "There are no workers' representatives among the members of the administrative, management and supervisory bodies" (page 195).

Information flows to the governance bodies

Reference: pages 87-89 (index: page 195).

"With regard to the governance of climate issues, environmental matters including metrics, targets and action plans are periodically reported to the Board of Directors" (page 88). Three climate activities are named as integrated into the governance structure: setting science-based targets and incorporating them into the financial strategy through the Sustainability-Linked Financing Framework, Bonds and Loans; defining a long-term climate strategy aligned with the Paris Agreement trajectories including a decarbonisation roadmap; and "assessing climate-related risks and opportunities on an annual basis as an integral part of the Risk Management model and the double materiality process" (page 88).

Supporting units are named (page 89): the Sustainability Unit, reporting directly to the CEO, coordinates the double materiality analysis with the Risk Management Unit and the drafting of the Statement; the Chief Sustainability Officer defines the control model for the ICSRS and issues the proof of compliance.

Directors receive "specific induction sessions which include in-depth looks at the regulatory updates regarding sustainability and the implications for the Group, as well as assessments of the main impacts on people and the environment and the appropriate management strategies (e.g. the ASTM Climate Transition Plan)" (page 89).

Sustainability in incentive schemes

Reference: page 89 (indexed under both ESRS 2 and E1, pages 195-196).

"As of 2019, the remuneration policy for executive directors and top management includes both annual variable incentive schemes (MBO - Management By Objectives) and Long-Term Incentives (LTIs). These schemes are based on the achievement of, among other things, sustainability objectives related to the environmental, social and governance spheres and including emission reduction targets. These objectives are weighted at 20% of the total variable remuneration" (page 89).

The Remuneration Committee prepares the policy, monitors its application and checks "that the performance targets, including those on sustainability, are actually achieved". The Sustainability Committee supports it "by identifying sustainability targets consistent with the Group's strategy for incorporation into the remuneration policy" (page 89).

Separately, second-level supplementary agreements with some Italian Group companies "include ESG parameters for the payment of performance bonuses" (page 165).

The disclosure gives one aggregate weighting. It does not isolate the share of remuneration tied specifically to climate considerations, nor name the individual emission targets used in the schemes.

Statement on due diligence

Reference: page 71 (index: page 195, including the paragraph 30 datapoint).

"The companies of the ASTM Group have identified and follow due diligence processes allowing them to identify and manage negative impacts arising from their activities, as well as from upstream and downstream value chains, evaluating the implementation of actions to manage and mitigate such impacts, with consideration also given to the different geographical locations where the Group operates. For further details, please refer to the paragraphs of this Consolidated Sustainability Statement indicated in the table below" (page 71).

The due diligence architecture is described elsewhere in the statement: the Human Rights Framework adopted by ASTM and its main operating subsidiaries "provides the Group companies with operational tools in order to implement due diligence processes compliant with the main international standards", built on the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, the ILO Conventions and the European Directive on Corporate Sustainability Due Diligence (page 170).

[The mapping table on page 71, which links each due diligence element to the paragraphs covering it, is rendered as a graphic in the published PDF and its cells could not be read from the document text, so the individual rows are not reproduced here.]

Internal control over sustainability reporting

Reference: pages 90-91 (index: page 195).

The Internal Control over Sustainability Reporting System (ICSRS) "is based on the COSO Framework defined by the Committee of Sponsoring Organisations of the Treadway Commission, and on the supplementary guidance for organisations published by COSO in 2023" (page 90). It has four components: Scoping, Risk Analysis and Control Assessment, Monitoring, and Evaluation and Reporting.

Scoping uses a scoring model assessing "parameters on exposure to the risk of error", approved by the Sustainability Officer. Risk analysis takes account of the qualitative characteristics of information "as laid down in Appendix B of ESRS 1". Three control types run: entity-level, process-level and IT general controls (page 90).

"The independent monitoring of the 2025 sustainability report was carried out by an independent external body", covering ASTM S.p.A. and the Italian and foreign companies in scope after Scoping, "verifying the design adequacy and effective implementation of the internal control procedures which they had adopted" (page 90).

Each in-scope company submits a certification letter, and an annual report on the ICSRS structure and adequacy goes to the Sustainability Committee, the Audit and Risk Committee and the Board (page 91). Exceptions found are "classified through an assessment of severity"; none is quantified in the statement.

Business model and value chains

Reference: pages 72-76 (index: pages 195-196, with the paragraph 40(d) datapoints at page 72).

ASTM describes a "One Company" business model covering "the development of initiatives, design, financing, construction and works management" (page 72). It had 17,065 employees at 31 December 2025 (13,964 in 2024): 4,781 Italy, 7,109 Latin America, 4,264 North America, 884 Rest of Europe, 14 Middle East, 13 Africa.

Five segments: motorway operations; motorway/EPC planning and construction (IFRIC 12); EPC; technology; minor sectors and other services. ASTM is "the world's second-largest operator in the motorway concessions segment, with a network of approximately 5,900 km under management as at 31 December 2025, between Italy (10 concessions), Brazil (12 concessions) and the United Kingdom (1 concession)", and the leading private Italian operator with about 1,100 km (page 72). EPC runs through the Itinera Group, engineering through SINA, technology through Sinelec (pages 72-73).

A footnote states "The ASTM Group is not directly involved in activities related to fossil fuels, chemicals production, controversial weapons, or the cultivation and production of tobacco" (page 72).

Strategic value chain partners are suppliers of concrete, bituminous mixes and cement, motorway contractors, and EPC and technology subcontractors (page 73). Objectives sit in the 2022-2026 Sustainability Plan (page 75).

Stakeholder interests and views

Reference: pages 76-77 (index: page 196; page 76 is also cited at the head of S1, S2, S3 and S4).

"By establishing an ongoing dialogue with its stakeholders and maintaining it over time, ASTM is able to identify the most important sustainability matters, to forge a relationship of trust on ESG topics of shared interest, and to evaluate how best to integrate them into its sustainability strategy, industrial activities and impact, risk and opportunity management plans throughout the supply chains" (page 76). Views reach the governance bodies: "the interests and perspectives of stakeholders are brought to the attention of the administrative, management and supervisory bodies, and specifically to the attention of the Board of Directors, the Committees and the Board of Statutory Auditors at the appropriate times, particularly during the approval of the methodology and findings of the double materiality analysis" (page 76).

Stakeholders consulted in the impact materiality assessment include shareholders and lenders, customers and consumer associations, business partners, universities and research centres, competitors, local community members, suppliers, contractors and subcontractors, trade unions and non-union workers' representatives, regulators, institutions and trade associations (page 80).

[The table on page 76 setting out each category's expectations and engagement methods is a graphic and its cells could not be read.]

Material IROs and their interaction with strategy

Reference: pages 78-86 (index: page 196).

"In 2025, all the macro-issues (i.e. topics) identified by the ESRS were found to be relevant, leading to the incorporation of the water-related topic, which had not been deemed relevant in 2024. Furthermore, no entity-specific topics were identified, as the area of 'innovation and sustainable mobility' falls under topic E1 - Climate Change" (page 80).

Strategy interaction (page 85): material IROs "are reflected in the pursuit of the objectives set out in the Sustainability Plan and in the implementation of the Climate Transition Plan". "Climate change and its effects on economic activities represent one of the main risk factors for the continued operation and resilience of the infrastructure managed by Group companies." A second named risk is "The recruitment and retention of professional figures essential to the development and running of the business's operations".

New in 2025 (page 86): water consumption in producing concrete and bituminous mixes, and the possible need to retrain Brazilian toll booth staff following Free Flow tolling, "a specific potential negative impact in the long term".

Climate-specific risk identification and scenario analysis is also presented under E1-2, and resilience under E1-3 (2025 ESRS numbering).

[The consolidated IRO tables on pages 81-84 are graphics; the per-topic tables in each chapter were used instead.]

The double materiality process

Reference: pages 78-84 (index: page 196; topic-level IRO-1 rows point to pages 111-113 for climate, 79 for pollution, water and resource use, 86 for business conduct).

The analysis follows Delegated Regulation (EU) 2023/2772 and "EFRAG IG 1: Materiality Assessment Implementation Guidance" (page 78). "During 2025, ASTM consolidated the process ... also taking into account the recommendations of the European Securities and Markets Authority (ESMA)", with "greater weight attributed to the assessments of strategic stakeholders".

Five steps (pages 78-80): context analysis; topic identification, where "all topics, sub-topics and sub-sub-topics put forward by the ESRS (ESRS1, AR16) were considered"; IRO identification, impacts inside-out and risks and opportunities outside-in via Enterprise Risk Management aligned to COSO and ISO 31000; assessment, with severity scored 1 (low) to 4 (extreme), likelihood 1 to 4 and financial magnitude 1 to 4; and prioritisation against "the thresholds already in use in the Enterprise Risk Management process", plotted on a severity/magnitude by probability matrix. Time horizons are short-term 2025, medium-term 2030 and long-term 2035 (page 70).

Verification runs through Internal Audit and the ICSRS, and "the methodology and findings ... were approved by the Board of Directors, after review by Top Management, the Sustainability Committee and the Audit and Risk Committee" (page 80).

ESRS content index

Reference: pages 195-205; the IRO-2 row itself points to pages 78-84 (page 196).

The statement prints a full "Table of Contents" of disclosure requirements with four columns: "Disclosure requirement and/or related datapoint", "Obligations pursuant to other EU legislation", "Immaterial / phase-in" and "Disclosure" (page 195). It is the authority used for this review.

Every ESRS 2, E1 to E5, S1 to S4 and G1 disclosure requirement is listed with either a named section and page range or an entry in the immaterial/phase-in column. Worked examples: "ESRS E1-8 Internal carbon pricing" points to "The Climate Transition Plan, page 118"; E2-5 is marked "Immaterial" with a dash in place of a page; E1-9, E2-6, E3-5, E4-6 and E5-6 are marked "Phase-in" with a dash; and E1-7 carries the note "ASTM does not use carbon credits and is not subject to regulated emission trading schemes" (pages 198-200).

The index closes: "Disclosures required by the ESRS that do not apply to the ASTM Group are not included in this Consolidated Sustainability Statement" (page 205).

Basis of preparation is Delegated Regulation (EU) 2023/2772 under Italian Legislative Decree 125/2024, with the ESRS 1 and Quick-Fix (EU) 2025/1416 transitional provisions "applied exclusively with regard to reporting the anticipated financial effects" (pages 69-70).

Climate Transition Plan

Reference: pages 113-115, with adaptation at page 126 (index: page 196).

"The Climate Transition Plan prepared based on the guidelines drawn up by the CDP ... as well as on the reporting requirements of the CSRD, and in line with the Group's Business Plan ... a long-term decarbonisation pathway has been marked out, which involves ambitious reductions in Scope 1, Scope 2 (market-based) and Scope 3 emissions from goods and services purchased by 2050, without relying on offsets" (page 113), which are capped at 10% of the baseline (page 116).

Levers for Scope 1 and 2 (page 114): low-impact fuels, electric fleet and site vehicles, LED lighting, dynamic energy management, and certified renewable energy. For Scope 3: process efficiency, sustainable materials, green procurement and supplier engagement.

Dependencies: implementation "takes into account external factors beyond the Group's direct control, such as the actual adoption of decarbonisation plans by suppliers, technological and regulatory developments ... and the approval of the Italian concessionaire companies' Economic-Financial Plans by the Granting Body". Locked-in emissions were assessed qualitatively for "offices, the vehicle fleet, and motorway infrastructure" (pages 114-115).

Funding sits in the concessionaires' Economic-Financial Plans, "totalling EUR 64.31 million in 2025 (EUR 44.6 million in 2024)", under Taxonomy activities CCM 7.3, CCM 4.1 and CCM 6.15 (page 115).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3, disclosed at pages 111-113 of the FY2025 report. This DR did not exist under the 2023 ESRS the report was prepared against.

Classification. The E1 IRO tables separate transition-side items (Scope 1, 2 and 3 emissions, energy efficiency, advanced mobility, innovation and digitalisation, pages 111 and 123) from physical-side items (intrinsic infrastructure risk "owing to reasons of force majeure and other external factors also related to climate change", and business continuity, page 126). No physical/transition column is printed.

Scenarios (pages 111-112). "As of 2020, ASTM has introduced climate-scenario analysis into its strategy." Three are named, RCP 8.5, IEA 2DS and IEA B2DS, "considering medium- and long-term time horizons, and up to 2050 for the transition scenarios". RCP8.5 covers physical risk, with effects extracted for Europe and Latin America of floods, landslides, coastal erosion, water scarcity, extreme heat and forest fires. B2DS was applied "to quantitatively assess a mitigation strategy consistent with a 'well-below-2-Degrees' trajectory" for Scope 1 and 2, and 2DS "consistent with a 2-degree trajectory" for Scope 3.

A footnote puts B2DS at 1.75 °C by 2100. No 1.5 °C-aligned scenario is named. Assumptions cited are population and economic growth and regulatory and technological development.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (pages 85-86) and the E1 adaptation section (pages 126-128). This DR did not exist under the 2023 ESRS the report was prepared against.

Strategy implications (page 85). "Climate change and its effects on economic activities represent one of the main risk factors for the continued operation and resilience of the infrastructure managed by Group companies", and each company "considers the impacts of climate change in their risk management policies, financial planning, operating activities and investment planning". A purpose of the scenario work is to "investigate the Group's resilience/robustness" (page 111); results "influence decisions regarding when and how to design new works" (page 112).

Adaptation capacity (pages 126-128). Structural health monitoring sensors, a Digital Asset Management platform built in 2025, strengthened landslide monitoring on the A6, A5 and A15, and EcoRodovias's Climate Change Adaptation Plan, "approved by the Board of Directors" in 2025. Adaptation CapEx reached EUR 731 million cumulative since 2024 against targets of +1,000 by 2026 and +2,000 by 2030.

Uncertainty is limited to delivery risk: achievement "depends on external factors beyond the Group's control, such as the approval of the concessionaire companies' Economic-Financial Plans by the Granting Body" (page 128). No separate ESRS-defined resilience analysis is presented.

Climate policies

Reference: pages 95-96, indexed as "ESRS E1-2 + MDR-P" to "The Environmental Policy, page 95-96" (page 197).

The Environmental Policy "sets out the general principles that guide the Group in protecting the material environmental issues, providing a framework for managing the impacts, risks and opportunities associated with climate change" (page 95). It "applies to ASTM S.p.A. and to its subsidiaries in Italy and abroad, which shall promote its implementation throughout their value chains, both upstream and downstream".

Three of its seven areas are climate-related: "climate change adaptation"; "climate change mitigation, including energy efficiency and renewable energy deployment"; and "innovation and sustainable mobility" (page 96).

"In particular, the Environmental Policy details the approach taken by ASTM in mitigating and managing GHG ... emissions, as well as in managing the transition risks it faces over different time horizons, both within its own operations and throughout its value chains. In addition, it addresses the issue of adaptation to climate change, explicitly undertaking to build safe and resilient infrastructure, in order to minimise the number of disruptions following weather events of medium to severe intensity" (page 96).

Commitments are framed against "the 2015 Paris Agreement, the United Nations Environment Programme (UNEP), and the European Green Deal", and the policy is published on the website and intranet (page 96).

Climate actions and resources

Reference: pages 116-118, 124-125 and 126-128, indexed as "ESRS E1-3 + MDR-A" (page 197).

Energy efficiency (page 116). LED modernisation of tunnel, car park, junction and toll station lighting continued and "will continue during 2026"; investment was EUR 1.2 million in 2025 (EUR 7.2 million in 2024) under Taxonomy CCM 7.3. Condensing boilers are planned at Itinera's main sites for 2026; EcoRodovias is replacing high-impact refrigerant HVAC units by 2030.

Renewables (pages 116-117). Photovoltaic installation for the Italian concessionaires completed, new plants designed on the SATAP A4 Torino-Milano stretch, and a solar system installed at Itinera's Tortona facility. "As at 31 December 2025, the solar panels installed have a total power of 110 MWp." Investment was EUR 19.1 million in 2025 (EUR 5.5 million in 2024) under CCM 4.1.

Low-impact fuels (page 117). XTL diesel (HVO) "guarantees the same performance as traditional fuel, but with over 80% fewer emissions"; in 2025 it covered "over 60% of the vehicles authorised in Italy", targeting "100% of light vehicles and 70% of heavy vehicles by 2030". A one-year B100 pilot on four vehicles began in Brazil.

Electrification (page 117). EcoRodovias "replaced ten combustion-type tow trucks with electric tow trucks in 2025", with 33 more electric heavy vehicles planned by 2030. Adaptation actions are set out at pages 126-128.

Climate targets

Reference: pages 113-115, 123 and 128, indexed as "ESRS E1-4 + MDR-T" plus the paragraph 34 GHG datapoint (page 197).

The 145 ktCO2eq baseline splits "of which 131 pertain to the Group and 14 to JO minority interests". "The emission reduction targets have been set in accordance with the principle of financial control ... unlike the provisions of the ESRS standards used to prepare the Consolidated Sustainability Statement, which follows the principle of operational control" (page 113).

In 2021 ASTM "became the first European motorway operator ... to set science-based targets for the reduction of emissions by 2030 validated by the Science-Based Targets initiative (SBTi) ... subsequently updated in 2023" (page 112).

Adjacent targets: 100% of service areas with EV charging by 2026 (78% in 2025) and cumulative innovation investment of +300 EUR mln by 2026, at 205 (page 123); cumulative adaptation CapEx of +1,000 EUR mln by 2026 and +2,000 by 2030, at 731 (page 128).

Energy consumption and mix

Reference: pages 119-120, indexed to "Monitoring of energy consumption and GHG emissions, page 119" with the paragraph 37, 38 and 40-43 datapoints (page 197).

"The energy consumption of the ASTM Group came to 462,948 MWh (505,900 MWh in 2024), down 8%" (page 119).

"In 2025, the total electricity consumed came to 173,576 MWh ..., 96% of which ... came from renewable sources (this was 93% ... in 2024). This is on track for the goal of using exclusively electricity from renewable sources by 2030. 100% of the purchased electricity ... was certified through Guarantees of Origin, I-RECs and PPAs" (page 119).

Energy intensity for high climate impact sectors was 0.073 (0.079 in 2024), reconciled to net revenue of EUR 6,013,616 thousand of EUR 6,186,732 thousand (pages 119-120).

GHG emissions

Reference: pages 120-122, indexed to "Monitoring of energy consumption and GHG emissions" with the paragraph 44 and 53-55 datapoints (pages 197-198).

Eight Scope 3 categories are calculated; "The remaining Scope 3 categories provided for by the GHG Protocol were considered not applicable or found not to be relevant", and "6% of Scope 3 emissions for 2025 were calculated using primary data (5% in 2024)" (page 120).

Scope 1 by gas: 55,192 CO2, 146 CH4, 959 N2O, 503 HFC; stationary combustion 10,482, mobile 45,815, process 0, fugitive 503; biogenic CO2 18,737 (Scope 1) and 168 (Scope 3) (page 122). A business unit split is given for EPC, Concessions, Technology and Holding.

Intensity: 0.368 tCO2eq per EUR thousand of net revenue market-based (0.395 in 2024); 0.373 location-based. Net revenue of EUR 6,187 million "matches the 'Total Revenue' value shown in the income statement of the Consolidated Financial Statements" (page 122).

Internal carbon pricing

Reference: page 118, indexed as "ESRS E1-8 Internal carbon pricing" to "The Climate Transition Plan, page 118" (page 198).

"In 2025, the Group consolidated a system for setting the internal carbon price in order to factor the cost of climate-related externalities into its decision-making processes and to incentivise the adoption of solutions with a lower emissions intensity, in line with its climate commitments. The price, which is to be progressively incorporated into the processes of economic-financial assessment of investments, infrastructure projects and the evaluation of new concession tenders, has been identified as a shadow cost, differentiated across the geographical areas in which the Group operates" (page 118).

The type of scheme, its purpose, its intended scope of application and its geographical differentiation are stated. The disclosure remains qualitative: it does not give the price level or range in EUR per tonne of CO2eq, the volume or share of emissions covered, or the specific 2025 decisions taken using it.

Pollution policies

Reference: pages 95-96, indexed as "ESRS E2-1 + MDR-P" to "The Environmental Policy, page 95-96"; the topic-level IRO-1 row points to page 79 (page 199).

The Environmental Policy lists "pollution of water and soil" among the seven areas on which it sets Group guidelines (page 96). "In relation to the pollution of water and soil in connection with any spills which occur during the construction of infrastructure, the Environmental Policy expresses the Group's commitment to monitoring and, where appropriate, mitigating negative impacts on water, air and soil by taking the appropriate measures to manage risks arising from potential contamination as a result of spills" (page 96).

Support comes from the Organisation, Management and Control Model under Italian Legislative Decree 231/2001, which "defines procedures, protocols and a disciplinary system in order to prevent damage and guarantee compliance with environmental regulations", and from ISO 14001 environmental management systems at the companies listed at page 92. "In addition, specific documents on the environmental management system are to be drawn up for construction sites ... in order to guarantee the adoption of all appropriate environmental mitigation measures during construction" (page 95).

The policy binds directors, managers, employees and third parties dealing with Group companies, and is published on the website and intranet (page 96).

Pollution actions and resources

Reference: pages 129-130, indexed as "ESRS E2-2 + MDR-A" to "The Group's commitment to spillage management, page 129-130" (page 199).

The two material IROs are potential negative impacts, contamination or spills into surface water and groundwater and into the soil "in the course of activities", both in own operations, for Concessions (Italy, Brazil) and Construction (page 129).

Actions (page 130): exposed companies "adopt internal procedures based on the defined objectives governing the actions to be implemented, including with the support of the emergency services operated by specialised companies", scheduled "based also on the periodic monitoring and reporting of KPIs". "In particular, along specific stretches of motorway, especially in tunnels longer than 500 metres, water drainage systems have been constructed to control the spread of liquids spilled by accidents or mechanical vehicle breakdowns."

Resourced project: a surface water collection and storage system on the Torino-Milano motorway, with resources "part of SATAP's Economic-Financial Plan, and amount to around EUR 8.5 million in 2025 and around EUR 70 million between 2026 and 2030".

For EPC, "given the temporary nature of construction sites, structural works are not generally required for spill management". For soil spills, "the affected area is immediately cordoned off and treated with absorbent material".

Pollution targets

Reference: page 129, indexed as "ESRS E2-3 + MDR-T" to "The Group's commitment to spillage management" (page 199).

"In accordance with the commitments expressed in the Environmental Policy regarding pollution, ASTM has set a target of zero spills comprising significant damage to the environment" (page 129).

Scope is own operations and downstream value chains, for Construction and Concessions (Italy and Brazil). A footnote defines the metric as spills "of substances listed in Annex II to Regulation (CE) n. 166/2006 ... (E-PRTR)", where "'significant damage to the environment' refers to the need for decontamination". The target "has been set on a voluntary basis".

Performance is explained: "Of the three spills recorded in 2025 ..., only one was attributable to the Group's own operations within the construction sector and resulted in decontamination costs of EUR 18,400 ... The remaining two cases ... were caused instead by accidents involving third-party vehicles on the Brazilian sections under management, resulting in total decontamination costs of EUR 13,049".

The 2025 outturn is above both the baseline and the target.

Pollutants released to water and soil

Reference: pages 130-131, indexed as "ESRS E2-4" to "Monitoring environmental pollution, page 130-131" with the SFDR cross-references (page 199).

"Below are the quantities of each pollutant contained in Annex II to Regulation (EC) No. 166/2006 ... (the European Pollutant Release and Transfer Register, E-PRTR) emitted into the water and soil" (page 130):

"The release of pollutants ... can be traced back to spills resulting from accidents befalling own vehicles during the construction phase (own operations). Quantification of the spilled substances is carried out by direct on-site measurement and, where it is not possible to accurately determine the actual quantity spilled, the total quantity of the material transported by the vehicle responsible for the spill is reported" (page 130).

The two 2025 releases are attributed to EPC companies: 20 kg into water from Itinera's site operations and 4 kg onto soil linked to a Halmar Group company; the 2024 soil figure is footnoted as a spill "at the Storstroem Bridge construction site". The water spill required decontamination, "whereas no decontamination was required for the spill onto soil" (pages 130-131).

Only PAHs are tabulated. No air emissions of E-PRTR pollutants and no microplastics figures are given.

Water policies

Reference: pages 95-96, indexed as "ESRS E3-1 + MDR-P" to "The Environmental Policy, page 95-96", with the paragraph 9 and paragraph 13 dedicated-policy datapoints on the same pages (page 199).

Water became material for the first time in 2025: "all the macro-issues (i.e. topics) identified by the ESRS were found to be relevant, leading to the incorporation of the water-related topic, which had not been deemed relevant in 2024" (page 80).

The Environmental Policy lists "use of natural resources, including water" among the areas it governs (page 96). "In addition to these commitments, with regard to water use, the Environmental Policy promotes the responsible use of water resources by monitoring consumption and identifying risks relating to water availability and quality at all major sites of operation. This commitment extends to water efficiency in offices, construction sites and operational areas, as well as the search for innovative solutions to reduce environmental impacts" (page 96).

The Group adds that "the risks associated with the use of water resources are monitored on a regular basis as part of the assessment of climate change-related risks, as well as within the environmental impact assessment carried out prior to the implementation of projects" (page 131).

The index marks one datapoint immaterial, "Sustainable oceans and seas, paragraph 14"; the disclosure requirement itself carries a page reference (page 199).

Water actions and resources

Reference: pages 131-132, indexed as "ESRS E3-2 + MDR-A" to "The Group's commitment to responsible water management, page 131-132" (page 199).

The single material IRO is an actual negative impact: "Water consumption for the production of concrete and bituminous mixes, used in the construction and maintenance of infrastructure", in own operations, for Concessions (Italy, Brazil) and Construction (page 131).

"The Group takes an integrated approach to the sustainable management of water resources throughout all stages of a project's lifecycle, implementing technical, management and control measures aimed at reducing consumption, preventing impacts and safeguarding bodies of water" (page 131). At design stage this means hydrological and climate analysis, "with a particular focus on activities carried out in areas experiencing water stress"; at construction stage, Environmental Management Manuals "prioritising reuse and recycling".

Named initiatives (page 132): rainwater capture on the motorway network for cleaning solar panels, heat pump use and saline antifreeze production; Itinera at Tortona, an aggregates plant water treatment and recovery system plus first-flush tanks feeding vehicle washing; and TELT on the Turin-Lyon railway, two industrial wastewater plants plus SBR domestic treatment, with treated water reused on site until works end in 2033.

No monetary amounts are attached to the water actions.

Water targets

Reference: pages 131-132, indexed as "ESRS E3-3 + MDR-T" to "The Group's commitment to responsible water management, page 131-132" (page 199).

ASTM discloses no measurable water target for 2025. It states an intention to consider one: "In view of the forthcoming update of the 2022-2026 Plan, consideration will be given to expressing the Group's water management commitments as a measurable target, in line with the Environmental Policy, so as to enable assessment of the effectiveness of initiatives aimed at reducing the negative impacts arising from the production of concrete and bituminous mixes for the construction and maintenance of infrastructure" (page 131).

Consistent with MDR-T's alternative limb, effectiveness is tracked through technical, management and control measures instead: design-stage hydrological and hydraulic assessments including interference analysis with surface water and groundwater; Environmental Management Manuals requiring water saving, reuse and recycling and the scheduling of water-intensive activities "during periods when water availability is less critical"; and additional safeguards in ecologically sensitive areas (page 131). Outcomes are then monitored through the E3-4 metrics, where recycled and reused water rose 74% to 2,585 m3 and total consumption fell 31% (page 133).

Water becoming material only in 2025 (page 80) is the stated context for the target gap.

Water consumption

Reference: page 133, indexed as "ESRS E3-4 Water consumption" to "Water consumption in the Group, page 133", with the paragraph 28(c) and paragraph 29 datapoints on the same page (page 199).

"Given the nature of the business and the use of water resources throughout the Group's value chains, it is estimated that water consumption figures are consistent with water withdrawal figures" (page 133).

The fall in total consumption is "mainly attributable to the completion of certain construction site activities in Brazil, Sweden and Denmark, as well as to the exclusion of the concessionaire companies ATIVA and SATAP A21 from the reporting perimeter"; the rise in water-scarce areas is attributed to "the refilling of cisterns, including for fire-fighting purposes, as well as to some leaking and emptying of the cisterns".

Two footnotes qualify the data: "7% of total consumption in 2025 was calculated using an estimate (4% in 2024), in the absence of direct measurement data", and stress classification used the WRI Aqueduct Water Risk Atlas and the WWF Water Risk Filter.

Biodiversity in strategy and business model

Reference: pages 134-135, indexed as "ESRS E4-1 Transition plan and consideration of biodiversity and ecosystems in strategy and business model" (page 199).

ASTM presents no separate biodiversity transition plan; it discloses how biodiversity is considered in strategy. The Group is "committed to respecting the balance of ecosystems and biodiversity, conducting impact analyses, environmental mitigation and monitoring plans appropriate to the type of intervention", through assessment of exposure to biodiversity risk, "the adoption of criteria for the minimisation of land use and landscape impacts", and "planning activities according to the mitigation hierarchy framework" (page 134).

Two material actual negative impacts are identified: "Variation in the status of ecosystems and species resulting from the Group's operational activities" and "Reduction of soil permeability resulting from the construction of infrastructure and buildings", for Concessions (Italy, Brazil) and Construction. "several of the Group's motorway stretches and some construction sites are located within or close to biodiversity-sensitive areas, including areas populated by species on the IUCN Red List" (page 134).

Biodiversity policies

Reference: pages 95-96, indexed as "ESRS E4-2 + MDR-P" to "The Environmental Policy, page 95-96", with the paragraph 24(b) land and agriculture, 24(c) oceans and seas and 24(d) deforestation datapoints on the same pages (page 200).

"The Environmental Policy goes on to express commitments to the protection of ecosystems and biodiversity, by respecting and, where necessary, restoring the balance of ecosystems, providing for appropriate environmental mitigation measures in accordance with the 'no net loss' of biodiversity principle. In particular, it sets out ASTM's commitment to the adoption of criteria for the minimisation of land use and landscape impacts in its interventions and projects, including impacts related to deforestation, the reduction of soil permeability and the contamination of natural and/or protected areas resulting from the construction of infrastructure and buildings" (page 96).

"protection of landscape and biodiversity" is one of the seven areas the policy governs. It applies to ASTM S.p.A. and its subsidiaries in Italy and abroad, "which shall promote its implementation throughout their value chains, both upstream and downstream" (pages 95-96).

The report does not state that the policy addresses traceability of raw materials to source; on offsets the biodiversity target is explicit that mapping and mitigation are pursued "without resorting to offsetting initiatives" (page 135).

Biodiversity actions and resources

Reference: pages 137-139, indexed as "ESRS E4-3 + MDR-A" (page 200).

• A33 Asti-Cuneo lot II.6a: an ecoduct, "an artificial tunnel covered with natural soil and vegetation through which wildlife can cross", and a bat bridge serving the "Santa Vittoria d'Alba" colony, due by end 2026 (page 137).
• A33 lot II.6b: a wetland around the Talloria stream, "created to compensate for an existing area that was buried during the construction of the viaduct", at EUR 6.3 million between 2025 and 2026.
• Bormida di Pallare viaduct, A6: nets, deterrents and artificial nests for two protected martin species. "Overall, the measures put in place were found to be successful, with the species in question using the nests for reproduction" (pages 137-138).
• A5 Quincinetto landslide works: hydraulic works with an environmental restoration plan, "approximately EUR 52,000" (page 138).
• Ospitaletto-Montichiari junction: fauna passageways, native vegetation and light and noise control, with post-works monitoring "to verify that there is no net loss"; EUR 0.6 million over 2020-2025. The Autovia Padana Po viaduct works added bird and plant monitoring at EUR 0.2 million and EUR 0.7 million over 2024-2029 (pages 138-139).
• EcoRodovias Biodiversity Conservation Plan formalised in 2025: EUR 4.8 million invested plus EUR 0.95 million operating expenses, within a broader plan of around EUR 18 million (page 139).

Biodiversity targets

Reference: page 135, indexed as "ESRS E4-4 + MDR-T" to "Group objectives for and commitment to biodiversity" (page 200).

"ASTM has adopted a target for contribution to the preservation of biodiversity in new projects ... the companies of the ASTM Group undertake to map biodiversity-critical areas and plan the necessary mitigation measures in all new projects undertaken, without resorting to offsetting initiatives" (page 135).

Scope is own operations plus upstream and downstream value chains, for Concessions (Italy and Brazil) and Construction. A footnote defines "critical areas for biodiversity" as "biodiversity-sensitive areas or nearby areas (including the Natura 2000 network of protected areas, UNESCO World Heritage sites and Key Biodiversity Areas, as well as other protected areas)".

The target is a process and coverage measure rather than an ecological outcome, and no baseline value is stated. It is not tied to a recognised biodiversity framework, and no separate target is disclosed for the EcoRodovias Biodiversity Conservation Plan pillars (page 139).

Biodiversity impact metrics

Reference: pages 135-137, indexed as "ESRS E4-5 + Impact metrics related to biodiversity and ecosystems change" (page 200).

"The Group's main sites which overlap with biodiversity areas consist of the road stretches operated by the concessionaire companies in Italy and in Brazil. Of these, 16 are located in or near protected areas or major biodiversity areas (17 in 2024), representing a total area of around 1,768 hectares (around 1,780 in 2024) ... 9 of these are in Italy (11 in 2024), for a total area of around 555 hectares ..., while 7 are in Brazil (6 in 2024), for a total area of around 1,213 hectares" (page 135).

In 2025 "the Italian concessionaires acquired 'Biodiversity Atlases' which identify highly sensitive areas within the territories crossed by any part of the motorway network under their management", built from Natura 2000, Italy's EUAP list, Important Bird Areas, Key Biodiversity Areas, RAMSAR wetlands and UNESCO sites.

A site-by-site table lists the 16 priority sites with net hectares of interference, from 0.4 ha (Raposo-Castelo) to 516.73 ha (Ecovias dos Imigrantes); Italian entries include A12 Sestri Levante-Livorno at 241.06 ha (page 136). Interference was gauged over "an area for analysis ... which extends 30 metres on each side with respect to the centre line of each carriageway".

No land use change, species population or ecosystem condition metrics beyond area of interference are presented.

Circular economy policies

Reference: pages 95-96, indexed as "ESRS E5-1 + MDR-P" to "The Environmental Policy, page 95-96"; the topic-level IRO-1 row points to page 79 (page 200).

"Finally, the Environmental Policy sets out the Group's commitment to promoting a circular economy model through the efficient use of resources, the reduction of non-renewable raw materials, the increased use of recycled materials, the minimisation and proper management of waste at all stages of operations, and collaboration with partners to identify solutions that encourage reuse and circularity" (page 96).

"use of natural resources, including water" and "circularity and waste" are two of the seven areas the policy governs. More broadly the Group "pays particular attention to ... the efficient use of natural resources ... and to the management of waste on construction sites", supported by Model 231 and ISO 14001 systems (page 95).

Implementation guidance sits in the actions section: "In line with the Environmental Policy, waste produced is recycled where possible, and otherwise disposed of at the most suitable sites depending on type. The Group's policy on waste management aims to guarantee sustainable waste management, while increasing the percentage of recycled waste and ensuring a responsible management of hazardous waste" (page 141).

Circular economy actions and resources

Reference: pages 141-142, indexed as "ESRS E5-2 + MDR-A" to "Group action on responsible resource management" (page 200).

Design practice: "In order to limit as far as possible the use of natural quarried materials on construction sites, new works were designed and developed to maximise the reuse of the natural terrain excavated from their intended location ... final disposal ... is always considered as a last resort" (page 141).

• A4 Torino-Milano graphene trial: a surface "made from a compound composed of graphene, polymer additives and specially selected reclaimed hard plastics"; "70% of the milled asphalt from the existing pavement was reused", with an estimated saving of "almost 23 million kg of bitumen and around 480 million kg of raw materials extracted from quarries", stated as "-40% non-renewable materials used compared to traditional technologies" (page 141).
• Bituminous mix plants: Itinera's new plant and a renewal, started 2024 with benefits expected June 2027, designed for "up to 50% recycled asphalt", temperatures "around 20% lower than traditional plants" and zero process water. Cassa Depositi e Prestiti "granted Itinera a loan of EUR 10 million for the construction of the Bene Vagienna plant" (pages 141-142).
• Ventimiglia barrier (July 2025): "100% of the material obtained from the milling of existing road surfaces was reused on site to form the sub-base layers of the new road surfaces" (page 142).

Circular economy targets

Reference: page 140, indexed as "ESRS E5-3 + MDR-T" to "Group objectives for responsible resource management" (page 200).

"It should be noted that both these targets have been set on a voluntary basis, but have also been designed in preparation for potential future obligations" (page 140). The second covers Construction (Italy) only.

The first target's arithmetic is disclosed: non-hazardous waste prepared for reuse (261,215 tonnes in 2025) plus waste recycled (613,120) over total non-hazardous waste (898,800).

The second is behind plan and the reason is given: "The performance in 2025 reveals a slight delay in relation to the target set, due in part to the protracted approval process for the new plant in Bene Vagienna. This is partly as a result of the concerns raised by local communities". The mitigation is a plan "to refurbish and modernise the Borghetto Vara plant in order to increase capacity for the recovery and recycling of milled material" (page 142).

Resource inflows

Reference: pages 143-144, indexed as "ESRS E5-4 Resource inflows" to "Monitoring of the resources managed by the Group" (page 200).

Strategic materials used, tonnes (page 143):

"The quantity of materials is calculated by direct measurement or, where this is not feasible, by comparing expenditure on a specific product category to its average price" (page 143). The rise in quarry materials is attributed to precast production for new sites "(including the Arena Milano)" and JFK International Airport works.

Secondary content: "8% of the materials used consisted of reused or recycled secondary materials (11% in 2024), representing a total of 240,400 tonnes". On biological materials, "0.3% of the wood comes from a sustainable supply chain (2% in 2024)", restated after methodology refinement.

The printed change line for the total, "(132,869) / -5%", does not reconcile to the two totals shown.

Resource outflows

Reference: pages 143-144, indexed as "ESRS E5-5 Resource outflows" with the paragraph 37(d) non-recycled waste and paragraph 39 hazardous waste datapoints (page 200).

Products. "Of the products placed on the market, only the bituminous mix sold to third parties is worth mentioning, containing quantities ranging from 15% to 35% of recycled material depending on the pavement layer concerned. The bituminous mix is in turn recyclable through the recovery process that takes place once the road surface is removed, with a 100% recyclability rate" (page 144).

Waste outflows, tonnes, 2025 (2024 in brackets), page 144: preparation for reuse 261,215 (344,299); recycling 613,388, of which 268 hazardous (719,800); other recovery 825 (441); total to recovery 875,428 (1,064,540). Incineration 251 (281); landfill 29,318 (50,636); other disposal 4,205 (15,925); total to disposal 33,774, of which 10,080 hazardous (66,842). Non-recycled waste 295,814 (411,582), being 33% of total (36%).

"The quantities of waste streams come from direct measurements of the weight of waste produced and directed to treatment and/or disposal, also in order to meet legislative and contractual requirements."

No durability, reparability or recyclable content rates are given for outputs other than bituminous mix.

Waste

Reference: pages 143-144, with the target at page 140. The index carries dedicated waste datapoint rows under E5-5, "Non-recycled waste, paragraph 37 (d)" and "Hazardous waste and radioactive waste, paragraph 39" (page 200).

"The total amount of waste produced by Group companies amounted to 909,202 tonnes (1,131,382 tonnes in 2024), a decrease of 20%. The main types of waste concerned waste from demolition activities, which include waste from the demolition of buildings and structures and waste generated by the milling of road infrastructure, as well as material from excavation activities (soil, rocks)" (page 144).

Hazardous waste: 10,402 tonnes in 2025 against 1,800 in 2024. "The increase compared to the previous year is mainly attributable to the Storstroem Bridge construction site in Denmark. As part of activities to complete the construction site, surplus foundry material was disposed of at a designated landfill site, following specific authorisation received from the competent local authorities."

Destinations (tonnes): recovery 875,428, of which preparation for reuse 261,215, recycling 613,388 and other recovery 825; disposal 33,774, of which incineration 251, landfill 29,318 and other 4,205. Non-recycled waste was 295,814 tonnes, or 33% of the total, down from 36%.

Against the target of >96% of non-hazardous waste reused or recycled by 2026, 2025 performance was 97% (page 140). No radioactive waste is reported.

Own workforce policies

Reference: pages 152, 156, 161, 164 and 170, indexed as "ESRS S1-1 + MDR-P" with the paragraph 20 to 23 datapoints at pages 152 and 161 (pages 200-201).

Diversity and Inclusion Policy (page 152): the companies "are committed to preventing all forms of discrimination concerning employment and work, and do not tolerate any type of discrimination based on ethnic or racial origin, skin colour, sexual orientation, gender, religious beliefs, nationality, age, political opinions, trade union affiliation, marital status, health, or any other social or personal characteristics". It draws on the ILO Declaration, UN Global Compact guidelines, the UN Guiding Principles, ILO Convention 111 and SDG 5, and ASTM has subscribed to the Women's Empowerment Principles since 2020. Compliance is enforced "through a disciplinary system that provides for sanctions in the event of non-compliance".

Human Rights Framework, adopted in 2024 (page 147), covers "diversity and inclusion; adequate working conditions; countering undeclared, child, forced and compulsory labour; human trafficking; freedom of association and collective bargaining; occupational health and safety; and payment practices" (page 161).

Health and safety: the commitment "is formalised through the occupational health and safety management systems, the procedures adopted by individual companies for the management of accidents and near-misses, and the Human Rights Framework" (page 161).

Engaging own workforce

Reference: pages 147-148, indexed as "ESRS S1-2" to "Processes for engaging own workforce" (page 201).

"ASTM and the Group's companies promote periodic activities for engagement with their own workforce and with workers' representatives in order to better understand the impacts that affect them ... workforce engagement takes place through internal and external communication channels (the company intranet, websites and media channels), through surveys, and through other participatory initiatives such as workshops and training sessions" (page 147).

"In particular, surveys are carried out at least annually to gather the opinions of employees on specific issues, including the identification of strengths and areas for improvement in the work experience." Effectiveness is tracked: "The Personnel Departments of Group companies monitor participation rates and survey results in order to assess employee engagement and the effectiveness of any initiatives implemented".

Trade union dialogue "also includes their involvement in the double materiality analysis and the communication of information on sustainability". In Italy, Law 300/70 (the Workers' Statute) is the framework, and responsibility sits with "ASTM's Personnel Administration and Industrial Relations Unit"; foreign companies "select a person from within the Personnel Department to be responsible for interactions with trade unions" (pages 147-148).

Remediation and grievance channels

Reference: pages 148-149, indexed as "ESRS S1-3" with the paragraph 32(c) grievance mechanisms datapoint (page 201).

"ASTM and the Group's main operating subsidiaries have adopted a Whistleblowing management system (the 'Ethics Channel' in the companies of the EcoRodovias Group) ... to allow their workers and, more generally, all stakeholders to report any concerns, defining how such concerns should be handled. The company's intranet and dedicated training activities make the workforce aware of the option of accessing this reporting mechanism via the ASTM website" (page 148).

"In accordance with the Whistleblowing Management Procedure, all reports received are analysed and categorised. If deemed unfounded, they are closed without action, while any well-founded cases are handled through the application of specific measures provided for by the legislation and the applicable national collective bargaining agreement and, where necessary, the definition of a remediation plan".

"The effectiveness of these measures is monitored through a periodic review of the cases handled, verification of the implementation of the actions taken, and analysis of indicators such as the reduction in recurring or similar reports." All reports "are guaranteed to be investigated by the competent bodies independently and with the utmost confidentiality for whistleblowers" (page 148).

Actions on own workforce

Reference: pages 153-154, 157-159, 162-163 and 165-167, indexed as "ESRS S1-4 + MDR-A" to four sections (page 201).

Diversity and inclusion (pages 153-154). ASTM joined the Disability Agenda in 2022 as "the first for-profit company" to do so and produced four training videos with CPD. The D&I Ambassador Team contributed to ASTM obtaining ISO 30415 "Diversity & Inclusion" and UNI PdR 125-2022 "Gender Equality" certifications in 2025.

Human capital (pages 157-159). The Young Talent Development Centre runs to a 2023-2026 roadmap. The Academy delivers the "School for Young Professionals", whose second edition closed with 216 participants and whose third launched with 117. "Competence Forward", the Group Learning Centre, launched in 2025 with five areas. The Leadership Program began in November 2025 and "is expected to involve over 450 staff members, totalling more than 22,000 hours of training".

Health and safety (pages 162-163). Itinera's accident and near-miss procedure, EcoRodovias's "Segurança Sempre" programme, Itinera's "Specchio di Vita" campaign continuing through 2026, and "Builders of Tomorrow", a 120-hour course drawing "around 600 applicants, 12 of whom were chosen".

Working conditions (pages 165-167). Second-level agreements renewed with Autostrada dei Fiori and Sinelec, plus the "0-18" and Care work-life balance programmes.

Own workforce targets

Reference: pages 153, 156 and 162, indexed as "ESRS S1-5 + MDR-T" (page 201).

Diversity (page 153): women in the company excluding EPC manual workers, baseline 39% (2023), >41% by 2026 and >45% by 2030, 2025: 41%; women in management, baseline 21%, 25% by 2026 and 30% by 2030, 23%; under-30 employees, baseline 18%, 25% by 2026 and 40% by 2030, 15%.

Human capital (page 156): average training hours per employee, baseline 19.9, >25 by 2026 and >30 by 2030, 21.8; employees with an annual performance evaluation including ESG parameters, baseline 29% of executives and managers, 100% by 2026, 67%; high-potential young employees in the YTDC, baseline 135, +20% by 2026, 219, +62%.

Health and safety (page 162): fatal occupational injuries of direct employees, baseline 0 (2023), target 0, 2025: 3; LTIFR of direct employees, baseline 10.1, <9.5 by 2026 and <9.0 by 2030, 8.2 (a three-year average).

Targets took account of "the results which emerged from the double materiality analysis, which also involved Group employees and their representatives" (page 153). The under-30 shortfall is explained by recruitment of manual workers aged 30 to 50 in North America and Brazil and by "the labour market context".

Employee characteristics

Reference: pages 149-152, indexed as "ESRS S1-6" to "The people of ASTM in numbers" (page 201).

"As at 31 December 2025, the ASTM Group's total number of employees was 17,065 (13,964 as at 31 December 2024). Unlike the financial statements, the number of employees of the joint operations is reported in full, without factoring in the stake held" (page 149).

By gender (page 150): men 12,453, women 4,588, other genders 22, not reported 2. By country: Italy 4,781; Brazil 7,109; USA 4,264; Denmark 566; Sweden 279; France 22; Romania 16; UAE 13; Botswana 10; Algeria 3; Russia 1; Kuwait 1.

"The variation in employees of 3,101 (+22%) is mainly attributable to the start-up of new EPC projects in the United States, with particular reference to ... New York's JFK International Airport and to progress on the construction of the Potomac River Tunnel, as well as recruitment within the EcoRodovias Group". "A total of 4,368 employees left ... resulting in a turnover rate of 31% (39% in 2024)" (page 150).

By contract (page 151): permanent 12,687, fixed-term 412, non-guaranteed hours 3,966, full-time 16,392, part-time 673, with regional splits. "Employees with non-guaranteed hours ... are represented solely by Union Workers of the US companies of the Halmar Group."

Indicators for Skanska-Halmar and CBNA Halmar Clean Rivers "have been estimated based on personnel costs incurred during the reporting period" (page 149).

Non-employee workers

Reference: page 152, indexed as "ESRS S1-7 Characteristics of non-employee workers in the undertaking's own workforce" (page 201).

"In addition to the disclosures on employees, the Group's own workforce as at 31 December 2025 also includes 417 collaborators or so-called non-employee workers (468 as at 31 December 2024), of whom 10 are self-employed workers (57 as at 31 December 2024) and 407 are from placement agencies (411 as at 31 December 2024)" (page 152).

The variance is explained: "The decrease (-51 compared to 2024) is mainly attributable to RO.S.S.'s direct recruitment of certain collaborators who had provided their work during the previous financial year, as well as to the reduced need for agency staff at certain EPC sites, including the Koge hospital in Denmark".

The own workforce is defined at page 149 as direct employees including apprentices, joint operation employees, Union Workers on Halmar payrolls in the United States, and "collaborators or so-called 'non-employee workers', which include temporary workers from recruitment, selection and supply agencies, including temporary workers and interns, and self-employed workers".

Non-employee workers also appear in the health and safety metrics, with 94% covered by a management system and 21 recordable accidents at a rate of 26.6 (pages 163-164). The disclosure gives headcount by type but no breakdown by gender or region.

Collective bargaining and social dialogue

Reference: page 167, indexed as "ESRS S1-8 Collective bargaining coverage and social dialogue" (page 201).

"The total percentage of employees covered by collective agreements is 97% (96% as at 31 December 2024), and the total percentage of employees covered by workers' representatives is 40% (43% as at 31 December 2024)" (page 167).

The coverage table presents bands rather than country percentages (page 167):

• Collective bargaining, 0-19%: Romania (EEA); Africa, Russia, Middle East (non-EEA)
• 60-79%: Denmark
• 80-100%: France, Italy, Sweden (EEA); North America, Latin America (non-EEA)
• Social dialogue (EEA workplace representation), 0-19%: Romania in 2025 (France and Romania in 2024); 60-79%: Denmark; 80-100%: Italy, Sweden, France in 2025

A footnote explains France moving band: "As at 31 December 2025, the French branch of ITINERA S.p.A. had 22 employees (2 as at 31 December 2024), exceeding the minimum threshold of 21 employees required for obligatory trade union representation".

Social dialogue itself is described under S1-2: the companies "recognise the trade union organisations which are signatories to the national collective bargaining agreements and local representatives as the 'natural' parties for all discussions and negotiations" (page 147).

Diversity metrics

Reference: page 155, indexed as "ESRS S1-9 Diversity metrics" to "Diversity in numbers" (page 201).

Gender at top management (managers of all companies in the reporting perimeter):

"Women represent 18% of top management (17% in 2024). Representation is lower in the EPC sector, though it remains in line with industry figures" (page 155).

Age distribution: under 30, 2,528 or 15% (2,222 or 16% in 2024); 30 to 50, 10,655 or 62% (8,108 or 58%); over 50, 3,882 or 23% (3,634 or 26%).

Board composition is cross-referenced rather than repeated: nine Directors, "seven of whom are male (78%) and two female (22%)" (page 87).

The related target of >41% women in the company (excluding EPC manual workers) by 2026 was met at 41% in 2025, while the 25% target for women in management stood at 23% (page 153).

Adequate wages

Reference: page 167, indexed as "ESRS S1-10 Adequate wages" to "Key indicators on working conditions" (page 201).

"All employees of Group companies are paid an adequate wage, defined pursuant to the terms of collective agreements, where any such exist. In countries where collective agreements are not applicable, adequate wages are defined by reference to the applicable minimum wage established by local legislation" (page 167).

This is a nil-exception statement rather than a benchmarked percentage: full coverage is asserted and the two reference points are named. No number or percentage of employees paid below an adequate wage benchmark is reported, no country-level exception is identified, and no external benchmark such as a living wage methodology is named.

Context sits in the surrounding disclosures. Collective agreement coverage is 97% (page 167), so the statutory minimum wage route applies to the remainder. The remuneration approach is described under S1-16: "The companies of the ASTM Group adopt a remuneration system designed to fairly recognise the skills, roles and responsibilities of each individual, in accordance with the principles of meritocracy and transparency" (page 155).

Social protection

Reference: page 167, indexed as "ESRS S1-11 Social protection" to "Key indicators on working conditions" (page 201).

"Almost all employees are covered by social protection measures, such as public programmes or benefits offered by the undertaking, against loss of income due to one of the following major life events: illness, unemployment, occupational injury and acquired disability, parental leave and retirement in accordance with local laws. The percentage of employees not covered by social protection measures is currently 0.6% (0.3% in 2024). This is due to the fact that the local legislation in some countries (including Algeria, Botswana, the United Arab Emirates, Kuwait and Russia) does not provide for certain protections such as unemployment, pensions, sickness and parental leave for all workers" (pages 167-168).

The five countries named together accounted for 28 employees at 31 December 2025 (page 150).

Supplementary company-level protection in Italy is described under S1-4: renewed second-level agreements include "supplementary pension policies", medical expense reimbursement "also in addition to that included under the relative national collective bargaining agreement", microloans, and "life and accident insurance policies" (page 165), with uptake of the pension schemes described as "consistently high" (page 166).

Persons with disabilities

Reference: page 155, indexed as "ESRS S1-12 Persons with disabilities" to "Diversity in numbers" (page 201).

"Finally, people with disabilities constituted 2.05% of the Group's total employees (2.39% as at 31 December 2024), which is to say 349 people (333 as at 31 December 2024, +5%). Of these, 212 were men (202 as at 31 December 2024), 137 were women (130 as at 31 December 2024), and 0 (1 as at 31 December 2024) belonged to the gender-neutral category" (page 155).

The headcount rose while the percentage fell, consistent with total employees rising 22% to 17,065 over the same period (page 150). The figure is Group-level with a gender split; no country breakdown is given and the report does not state which legal definitions of disability apply across the jurisdictions in scope.

Related action: ASTM joined the Disability Agenda in 2022, "an initiative promoted by the CRT Foundation and the CPD (Council for People in Difficulty)", and produced four short training videos with CPD (pages 153-154). The Diversity and Inclusion Policy commits the companies to "promoting an inclusive culture which is welcoming to people with disabilities" (page 152), and ASTM obtained ISO 30415 certification in 2025 (page 154).

Training and skills development metrics

Reference: pages 159-161, indexed as "ESRS S1-13 - Training and skills development metrics" (page 201).

"In 2025, approximately 371,000 hours of training in total were delivered to employees (280,000 hours in 2024, +33%). Of these, 212,000 hours were related to health and safety; 118,000 hours were dedicated to the development of professional technical engineering and IT skills (102,000 in 2024); and 24,000 hours focused on business ethics (23,000 in 2024)" (page 159).

Per capita hours by category, 2025 (page 160): executives 34.8 (men 33.7, women 39.8); middle managers 40.2 (37.9, 47.4); office workers 18.8 (18.2, 19.8); manual workers 21.3 (20.2, 24.9). Group total 371,431 hours at 21.8 per capita, against 279,996 at 20.1 in 2024.

Performance and career development reviews, 2025 (page 160): 2,309 of 17,065 employees, or 14% (13% in 2024), being 12% of men, 18% of women, 23% of other genders and 50% of not reported.

Against the target of >25 average hours per employee by 2026, 2025 stood at 21.8; against 100% of executives and managers receiving an ESG-inclusive annual evaluation by 2026, at 67%, the methodology having been "refined in 2025 to take into account only those employees involved in a structured assessment process" with prior years restated (pages 156, 161).

Health and safety metrics

Reference: pages 163-164, indexed as "ESRS S1-14" with the paragraph 88(b), (c) and (e) datapoints (pages 201-202).

Coverage: "62% of Group employees and 94% of non-employee workers are covered by a health and safety management system ... (71% and 94% in 2024)". The decline is attributed to headcount growth at Skanska-Halmar and Raposo Castello, "which do not currently hold this certification" (page 163).

"The 3 fatal accidents among the company's own workforce ... occurred in Brazil: 2 in the construction sector at Itinera's operating subsidiaries, and 1 at the port company belonging to EcoRodovias ... In addition, there were 2 fatal accidents involving workers from contractors at the operational sites of companies within the EcoRodovias Group ... In all cases, as things stand, no liability has been found to be attributable to the companies involved" (page 164).

A footnote explains the days-lost jump: 18,000 of the 22,953 days were "calculated by multiplying the number of cases by the standard factor of 6,000 days lost, specified in Brazilian technical standard ... NBR 14280:2001".

Work-life balance metrics

Reference: page 166, indexed as "ESRS S1-15 Work-life balance metrics" to "Renewal of second-level contracts" (page 202).

"In line with the previous year, almost all employees (99.9%) are entitled to leave for family reasons (98% in 2024), in accordance with the provisions of collective agreements and the social policy adopted by Group companies. Of these, 5.2% took advantage of it (5.7% in 2024), with slightly higher uptake among female employees" (page 166).

By gender: men 4.6% (5.2% in 2024); women 6.9% (6.7%); other genders no data; not reported 100%; total 5.2% (5.7%).

The standard asks for both the percentage entitled and the percentage who took leave, by gender. Entitlement is given as a single Group figure and is not disaggregated.

Supporting measures are in the same section: second-level agreements "incorporated" measures "relating to parenthood, organisational flexibility, care for family members and school-related bonuses", including additional paid leave for nursery and kindergarten starts, "leave for accompanying family members to the emergency room", birth bonuses, psychological support on return from maternity leave, and "solidarity leave (the option for employees to donate their days off to colleagues in need)" (page 165).

Compensation metrics

Reference: pages 155-156, indexed as "ESRS S1-16" with the paragraph 97(a) gender pay gap and 97(b) CEO pay ratio datapoints (page 202).

"During the reporting period, an overall gender pay gap of 21% was recorded (22% in 2024). This indicator is calculated as the difference between the average hourly wage level paid to female and male workers, expressed as a percentage of the average hourly wage level of male workers, excluding professional levels where either gender is not represented. For the purpose of calculating the average wage level, basic salary was added to complementary or variable components, including overtime pay" (page 155).

The company flags the aggregation caveat itself: the indicator "is calculated on an aggregate basis at Group level, without adjustments to correct for differences in average wage levels, local welfare systems and purchasing power" (page 156).

"The ratio of the highest-paid individual's annual total remuneration to the median annual total remuneration for all employees was 54 as at 31 December 2025 (68 as at 31 December 2024). The data used for this assessment is based on the annual remuneration ... of all Group workers employed as at the reporting date, excluding those who left during the year" (page 156).

Both prescribed datapoints are given with methodology. Excluding professional levels where one gender is unrepresented departs from a strictly unadjusted calculation, and is disclosed as such.

Incidents and complaints

Reference: page 149, indexed as "ESRS S1-17" with the paragraph 103(a) and 104(a) datapoints (page 202).

"During the reporting period, 0 incidents of discrimination were confirmed (4 in 2024) and 4 incidents of harassment (13 in 2024) ... all of which were attributable to companies within the EcoRodovias Group, which have drawn up remediation plans in accordance with current procedures. In addition, 128 reports were submitted ... 99 of these were closed without further action (90 in 2024), while 29 are under investigation (24 in 2024) ... With reference to the aforementioned incidents, no charges were incurred in the income statement" (page 149).

A footnote defines severe human rights incidents as "all confirmed cases of human rights violations, to be understood as cases of forced labour, human trafficking and child labour".

Value chain worker policies

Reference: pages 169-170, indexed as "ESRS S2-1 + MDR-P" with the paragraph 17, 18 and 19 datapoints (page 202).

"ASTM and the Group's companies promote respect for human rights and social responsibility throughout the supply chain, adopting policies that establish, among other things, the principles adopted regarding occupational health and safety; diversity and inclusion; adequate working conditions; freedom of association and collective bargaining; countering undeclared, child, forced and compulsory labour; and human trafficking" (page 169).

The instruments are the Supplier Code of Conduct and the Human Rights Framework, which "reaffirm and integrate the principles set out in the Group Code of Ethics and Conduct; in the Organisation, Management and Control Model pursuant to Italian Legislative Decree 231/2001 ...; in the SA8000:2014 guidance document for social accountability". They are based on "the UN Guiding Principles on Business and Human Rights, the ... (ILO) Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises" and "also include tools to identify possible instances of non-compliance".

The Framework applies regardless of "the type of contractual relationship" (page 170), and acceptance of the Supplier Code "is mandatory in order to enter into business dealings" (page 191).

Engaging value chain workers

Reference: pages 168-169, indexed as "ESRS S2-2" to "Processes for engaging value chain workers" (page 202).

"The ASTM Group is committed to sharing its values ... with its suppliers, contractors, subcontractors and business partners. It places great emphasis on the safeguarding of occupational health and safety ... The Group therefore defines and shares clear standards, actively involves contractors and subcontractors in health and safety initiatives, and organises regular coordination meetings" (pages 168-169).

"In particular, Itinera has implemented a monitoring system with feedback from the construction sites ... followed by the joint definition of plans for improvement and of follow-ups aimed at verifying their implementation. In this context, in order to better understand the point of view of workers who may be most vulnerable to impacts and/or marginalised, on the basis of findings from this monitoring, Itinera carries out additional checks and verifications via the Human Resources and Health, Safety and Environment units" (page 169).

"At the same time, training programmes are also carried out that actively engage subcontractors' workers, with a particular focus on working conditions, health and safety, and the prevention of risks."

Engagement is indirect, through contractors' management rather than through workers' own representatives; no global framework agreement or value chain workers' representative body is named.

Remediation and channels for value chain workers

Reference: pages 169-170, indexed as "ESRS S2-3" to two sections (page 202).

"Like other stakeholder categories, workers in value chains can also make reports through the dedicated channels implemented by ASTM and its main operating subsidiaries, through the same procedures described for their own workers. Furthermore, the Supplier Code of Conduct requires all suppliers to provide their employees with appropriate means of reporting irregularities. All reports received are guaranteed to be investigated by the competent bodies independently and with the utmost confidentiality for whistleblowers" (page 169).

"The general approach and processes to remediate or help remediate any material negative impacts on workers in the value chains are defined by the Human Rights Framework."

Under that framework each company integrates into its Risk Management model "identifying and assessing actual and potential negative impacts on human rights"; "defining and implementing an action plan to prevent, end and mitigate impacts"; "providing a complaints procedure and channel and implementing appropriate measures to remedy actual impacts if the organisation determines that it has caused or contributed to adverse effects"; monitoring effectiveness; and transparent reporting (page 170). Stakeholder consultation is arranged so "participants are not subject to retaliation or reprisal".

Actions on value chain workers

Reference: pages 170-173, indexed as "ESRS S2-4 + MDR-A" with the paragraph 36 human rights incidents datapoint (page 203).

Screening (page 171). "Where this work is carried out in Italy or within the European Union, documentation compliance checks are conducted in advance ... For partners operating in the rest of the world ... this initial verification ... is in addition to a rigorous assessment of issues relating to child labour, with a particular focus on the sub-contractors present at construction sites and on external manufacturers of materials, and to living conditions at the base camps."

ESG audits (pages 171-172). "In 2025, 15 of the 30 strategic suppliers operating in the construction sector underwent audits", covering "health and safety, the training of qualified personnel, working practices and respect for human rights". "No major issues emerged in 2025 that would hinder the audited suppliers from retaining their qualification."

Safety Guidelines (page 172). "In 2025, the Group developed guidelines dedicated to protecting the health and safety of workers from third-party companies operating on its sites under contract or subcontract arrangements."

Certifications (page 173). Itinera obtained ISO 20400:2017 Sustainable Procurement certification in December 2025 and an EcoVadis Platinum rating, "among the top 1% of companies assessed globally".

Value chain worker targets

Reference: page 171, indexed as "ESRS S2-5" to "Targets with positive impacts on workers in the value chains" (page 203).

"As part of its Sustainability Plan, ASTM has adopted two targets relating to workers in its supply chains" (page 171):

Both cover upstream and downstream value chains; the audit target applies to Construction. "Performance during the reporting year were in line with the target values set."

The definition of a strategic supplier is disclosed: classification "is based on an assessment of the impact that any potential non-compliance on their part might have on the company's operations, also taking into account the type of materials supplied and/or services provided, the economic significance of their turnover, and other ESG criteria (e.g., impact on carbon footprint, SA8000 risks, regulatory compliance risks)".

Both are process and coverage measures. No outcome target on incidents, remediation or working conditions in the value chain is disclosed.

Affected communities policies

Reference: pages 176-177, indexed as "ESRS S3-1 + MDR-P" with the paragraph 16 and 17 datapoints (page 203).

"The Group's commitments in terms of responsibility towards the broader community and the development of territories are expressed in the Group Code of Ethics and Conduct ... In particular, ASTM and the Group companies have defined principles and procedures for the disbursement of donations and sponsorships as part of internal procedures, in order to ensure that actions are only carried out following a positive outcome from certain checks on the validity of the target and purpose of the disbursement, and on the credibility and moral integrity of the potential beneficiary" (page 176).

The distinction is drawn: "donations are made exclusively to support initiatives of a humanitarian or social nature ..., while sponsorships represent a contractual tool to support initiatives of a social, cultural, sporting or artistic nature with the aim of promoting, enhancing and strengthening the Group's image".

Human rights commitments reaching communities sit in the Human Rights Framework, which defines "The general approach and processes to remediate or help remediate any material negative impacts for the local communities in the territories where the Group operates" (page 176). Operational safeguards include "The ISO 39001-certified road safety management systems" and the infrastructure monitoring systems (page 174).

Engaging affected communities

Reference: page 176, indexed as "ESRS S3-2" to "Processes for engaging affected communities" (page 203).

"ASTM considers its relationships with the communities living near its operating sites and construction sites to be a vital part of its business ... the Group companies maintain ongoing dialogue with representatives of local administrations, including as part of the approval processes for initiatives ... to ensure that the needs of local communities are adequately taken into account, particularly in the construction of new infrastructures" (page 176).

The formal mechanism is named: "the Services Conference provides a structured approach for acquiring opinions, authorisations and approvals in a coordinated manner from the competent institutions, local authorities and bodies ... It also makes it possible to identify in advance any potential negative impacts on the communities and areas affected, including in relation to land acquisition practices and construction." A footnote defines it as an administrative coordination mechanism under Italian Law 241/1990.

Direct engagement includes road safety "training days, interactive debates and targeted projects" and "organising meetings with local stakeholders to understand their needs and expectations". Activities are "coordinated centrally by the Communication and Public Affairs Department".

Remediation and channels for affected communities

Reference: page 176, indexed as "ESRS S3-3" (page 203).

"The Whistleblowing Management Procedure also applies to local communities which, like all other categories of stakeholders, can make reports in the same way as described for the Group's own workers. All reports received are guaranteed to be investigated by the competent bodies independently and with the utmost confidentiality for whistleblowers ... The general approach and processes to remediate or help remediate any material negative impacts for the local communities in the territories where the Group operates are defined by the Human Rights Framework" (page 176).

The nil return for the year is explicit: "It should be noted that, once again, no serious problems or incidents were reported in 2025 in relation to human rights, nor were there any cases involving non-compliance with the UN guiding principles on business and human rights, the ILO declaration on fundamental principles and rights at work, or the OECD guidelines for multinational enterprises".

The report does not state whether affected communities are aware of and trust these channels, or give a community-specific breakdown of reports received.

Actions on affected communities

Reference: pages 177-178, indexed as "ESRS S3-4 + MDR-A" to "Actions to benefit affected communities" (page 203).

ASTM for sport (page 177). ASTM has sponsored the Derthona basketball team of Tortona since 2017-2018. "In order to assess the positive effects and spin-offs of the sponsorship ..., an SROI (Social Return on Investments) analysis was conducted ... every euro invested into Derthona Basket is able to generate EUR 3.53 of socio-economic impact."

Andiamo sul sicuro (page 178). A road safety education tour run with the Italian Traffic Police. "As of 2025, 34 events had been organised, ... towards the goal of holding more than 40 events across six regions and 20 cities. Having already involved over 12,000 participants". Effectiveness is measured by questionnaire: "89% of the young people understood that road safety is a shared responsibility, while 82% would recommend the Autostradafacendo training programme to a friend".

EcoRodovias Socio-Environmental Strategic Map (page 178). Created in 2025 to guide social investment through territorial development, stakeholder relations and internal strengthening.

Affected communities targets

Reference: page 177, indexed as "ESRS S3-5 + MDR-T" to "Target for the development of affected communities" (page 203).

"As part of the process of identifying and setting the targets, the findings which emerged from the engagement of the affected communities in the materiality analysis process were taken into account. In 2025, the Group issued donations totalling approximately EUR 0.3 million (EUR 0.6 million in 2024), and sponsorships of approximately EUR 7 million (EUR 6.1 million in 2024), EUR 6.6 million of which went to supporting sports initiatives in Italy and in the United States. These costs are included in the Consolidated Financial Statements under ... Note 28 - Costs for services, and ... Note 30 - Other costs" (page 177).

The target is an input measure of spend rather than an outcome measure for communities. Outcome evidence is presented separately: the Derthona Basket SROI result and the Andiamo sul sicuro questionnaire results (pages 177-178).

Consumer and end-user policies

Reference: page 181, indexed as "ESRS S4-1 + MDR-P" with the paragraph 16 and 17 datapoints (pages 203-204).

"The Group Code of Ethics and Conduct ... lists the Group's commitments to providing the best possible service to its customers, through secure infrastructures and innovative, resilient and sustainable solutions, with a particular focus on the attention and care given to customer service in terms of quality, safety and reliability. Emphasis is placed on the importance of providing accurate, truthful and comprehensive information about the services offered by the Group, so that customers can make informed decisions" (page 181).

"The protection of customer services is pursued not only through the Group Code of Ethics and Conduct, but also through the drafting of the Service Charter. This document, which is periodically updated by all the Group's motorway concessionaires, serves as a tool for management, information, communicating targets and maintaining dialogue with motorway customers ... Finally, the document contains the quality indicators and related reference standards, compliance with which is assured."

Accountability is named: "The most senior level of management accountable for the implementation of the policy is the Board of Directors of each concessionaire company to which the Service Charter refers".

Engaging consumers and end-users

Reference: pages 180-181, indexed as "ESRS S4-2" to "Processes for engaging and listening to end-users" (page 204).

Regulatory context: "the Transport Regulatory Authority has issued Resolution 132/2024 and Resolution 211/2025 ... These resolutions set out a vast and varied amount of information and measures which must be provided to users. The concessionaire companies are working to implement these within the deadlines indicated" (page 180).

Channels: control centres "are manned around the clock by specifically trained personnel ... who take swift action on every report received through the many active channels, such as the variable message signs (VMSs) ..., websites, radio stations and press releases". In 2025 the concessionaires' websites were overhauled and the menu of the single number "800 840 708 - TRAFFIC INFO" restructured.

Listening: "the concessionaires carry out customer surveys on a regular basis, with the results analysed and used internally to identify strengths and weaknesses, plan improvement actions, and finally follow them up".

Vulnerable users: with CPD, ASTM formalised a "Manifesto" in 2024 leading to the "service areas designed for all" project, whose guidelines were presented to service providers in 2025 and published on the concessionaires' websites, addressing "the needs of those who are most vulnerable, such as women, children, people with disabilities and the elderly".

Remediation and channels for end-users

Reference: pages 180-181, indexed as "ESRS S4-3" (page 204).

"the companies adopt a structured approach to managing any negative impacts on users, based on formalised procedures for collecting and analysing complaints, issuing refunds where necessary, and managing claims transparently. These processes, which are integrated into user protection systems and reviewed periodically, enable the causes of service disruptions to be identified promptly, corrective measures to be defined, and the effectiveness of the remedies to be verified through quality indicators and continuous monitoring of the services provided" (page 180).

"In particular, the channels made available to customers in order to communicate complaints or needs and have them addressed consist of the forms available online on the websites of the various concessionary companies, within the 'Complaints and Reports' sections, as well as the Whistleblowing Management System referred to in previous chapters" (page 181).

The nil return for the year is stated: "No severe problems or incidents related to the human rights of end-users were reported in 2025". The number of user complaints received or resolved is not given.

Actions on consumers and end-users

Reference: pages 183-184, indexed as "ESRS S4-4 + MDR-A" to "The Group's commitment to protecting road safety" (page 204).

The Group applies "a multi-factor approach to road safety management ... choosing to integrate the aspects usually considered with criteria that can be used to assess and compare road user behaviour, traffic flows and the condition of infrastructure in an integrated manner" (page 183). The three criteria are "design choices geared towards safety ... devised to incorporate the human factor in design criteria"; "careful maintenance of infrastructure", where inspection technologies "foresee its future deterioration"; and "safe management of infrastructure: with careful monitoring of events on the network".

Management systems "are periodically updated in accordance with the applicable ISOs, including ISO 39001 (Road Traffic Safety (RTS) Management)". "The inspections carried out by ANSFISA ... focused both on the characteristics of management systems ... and on operational aspects ... The inspections were successfully concluded."

Each stretch is monitored by an Operational Control Centre collecting ITS data through an ATMS platform, with the Rondissone centre as "the nerve centre of the system".

Effectiveness "is evaluated through the calculation and monitoring of the accident index on the network managed by the Group".

Consumer and end-user targets

Reference: page 182, indexed as "ESRS S4-5 + MDR-T" to "Road safety targets" (page 204).

A footnote defines the rate as "the ratio between the number of fatal accidents and the mileage in millions of vehicles/km * 100".

Performance is explained. In Italy the rate "rose from 0.22 in 2024 to 0.27 in 2025; a change which is essentially attributable to a decrease in traffic volumes (-25%) disproportionate to the decrease in fatal accidents, which fell from 30 in 2024 to 28 in 2025". In Brazil it "rose from 1.69 in 2024 to 1.82 in 2025 (+8% ..., -2% compared with the 2023 baseline)", with fatal accidents up "from 613 in 2024 to 681 in 2025".

The Brazilian target was reset during the year "following the acquisition of new concessionaires after the date on which the targets were set". Cumulative road safety investment reached "EUR 1,644 million (EUR 958 million in 2024, +72%)", the 2024 figure restated.

Business conduct policies and corporate culture

Reference: pages 187, 189-190, 191-192 and 193-194, indexed as "ESRS G1-1 + MDR-P" to five sections, with the paragraph 10(b) and 10(d) datapoints at pages 189 and 187 (page 204).

Corporate culture. Values "traced back to the concepts of ambition, responsibility, innovation, reliability, sustainability and integrity" form the basis of the new Purpose, "Behind the journey, Beyond the destination", launched in 2025 from the "Brandability" project. "One of the first steps planned will be to update the Code of Ethics, in order to fully incorporate the new set of values, the Purpose, the vision and the mission" (pages 186, 188).

Group Code of Ethics and Conduct (page 187). Binding on directors, corporate bodies, managers and employees "as well as anyone who maintains any kind of relationship or business dealings with the same". It commits the Group to the Universal Declaration of Human Rights, the ILO Conventions, the UN Guiding Principles, "the 10 Principles of the United Nations Global Compact" and the OECD Guidelines.

Whistleblowing (page 187). "No retaliatory consequences of any kind against the whistleblower are tolerated", subject to legal obligations and protection of those wrongly accused.

Anti-Corruption Policy (page 189), updated by Board resolution on 18 November 2025, inspired by UNI ISO 37001:2016 and referencing "the United Nations Convention against Corruption" and the UK Bribery Act.

Management of supplier relationships

Reference: pages 191-192, indexed as "ESRS G1-2 Management of relationships with suppliers" (page 204).

"The ASTM Group recognises the importance of pursuing responsible management within its supply chains, implementing a transparent procurement process ... each Group company undertakes to select suppliers in accordance with criteria of transparency, fairness and impartiality, avoiding actual or potential conflicts of interest" (page 191).

"In this regard, a series of ESG criteria have been integrated into supplier selection processes, while climate-related requirements are included in the contracts of the Group's strategic suppliers in order to prioritise suppliers with a smaller carbon footprint."

Sector approaches differ: Italian concessionaires use a continuously updated Supplier Register and "the official ANAS price list", with costs "subject to periodic checks by the Italian Ministry of Infrastructure and Transport"; Brazilian concessionaires assess "compliance in relation to health and safety and to environmental matters ... for all service suppliers"; the construction sector runs a two-phase pre-qualification platform with site-level monitoring "through specific audits".

"acceptance of the Code by suppliers is mandatory in order to enter into business dealings", enforced "through the introduction of specific contractual clauses ... on penalty of contract termination" (page 192).

Prevention and detection of corruption and bribery

Reference: pages 189-190, indexed as "ESRS G1-3 Prevention and detection of corruption and bribery" (page 204).

"for Italian companies, the measures implemented to prevent corruption are governed by the Organisation, Management and Control Models pursuant to Italian Legislative Decree 231/2001. In addition, ASTM S.p.A., EcoRodovias Concessoes e Serviços S.A., EcoRodovias Infraestrutura e Logística S.A., Itinera (Italy, Swedish, Danish, and French branch), SINA, SEA Segnaletica Stradale, Sinelec and Tubosider have implemented a voluntary management system regarding anti-corruption with UNI ISO 37001 certification" (page 189).

Independence is disclosed: "the Internal Audit unit ... is responsible for promptly, independently and objectively investigating incidents related to business conduct, including cases of active and passive corruption in its capacity as the Anti-Corruption Officer" (page 187), a role "filled by the Manager of the Internal Audit Unit" (page 189).

Reporting: the Anti-Corruption Officer "periodically communicates with Top Management regarding the system's adequacy", and "the Chief Executive Officer presents the activities carried out for the purposes of maintaining ISO 37001 certification ... to the Board of Directors each year".

Training: "100% of the units most at risk of corruption and bribery ... are involved in the training" (page 190).

Targets related to business conduct

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

ASTM discloses three measurable business conduct targets, all part of the Sustainability Plan.

Ethics training (page 188). "The Sustainability Plan includes a target for the engagement of all employees in ESG training, also in order to disseminate the Group's set of values and the principles on which its corporate culture is founded": % of employees involved in ESG training (including business ethics, human rights), baseline 54% (2023), 80% by 2026 and 100% by 2030, 2025 performance 60%. Training covers "the Code of Ethics and Conduct, ... Italian Legislative Decree 231/2001, ... the Anti-Corruption and Diversity and Inclusion policies, and ... the Human Rights Framework". The shortfall is explained by "an increase in the total number of employees, particularly in categories not involved in these training initiatives".

Business continuity (page 193). Zero stoppage of critical IT systems due to cyber attacks, baseline 0 (2023), target 0, 2025: 0; % of data processor employees trained on data protection, baseline 76%, 80% by 2026 and 100% by 2030, 2025: 93%.

No target is set for corruption incidents, supplier payment times or lobbying.

Incidents of corruption or bribery

Reference: page 190, indexed as "ESRS G1-4 Confirmed incidents of corruption or bribery" with the paragraph 24(a) fines and 24(b) standards datapoints (page 204).

The disclosure is a nil return covering both years: "In neither 2025 nor 2024 were there any convictions for violation of anti-corruption and anti-bribery laws, nor were any fines imposed" (page 190).

The statement covers convictions and fines. It does not separately give a number of confirmed incidents short of conviction, the number in which own workers were dismissed or disciplined, or the number relating to contracts with business partners that were terminated or not renewed.

The control environment behind the nil return is set out under G1-3: Models 231 for the Italian companies; UNI ISO 37001 certified anti-corruption management systems at ASTM S.p.A., both EcoRodovias holding companies, Itinera and its branches, SINA, SEA Segnaletica Stradale, Sinelec and Tubosider; investigation by the Internal Audit unit acting as Anti-Corruption Officer; and annual CEO reporting to the Board in the presence of the Board of Statutory Auditors (pages 187, 189).

Reports of any kind are handled through the Whistleblowing system; 128 concerning the own workforce were received in 2025 (page 149).

Political influence and lobbying

Reference: page 190, indexed as "ESRS G1-5 Political influence and lobbying activities" (page 205).

"When it comes to institutional relations, ASTM relies on partner companies specialising in lobbying activities. Contractual relations with such companies are only entered into subject to the existence of adequate reliability, integrity and ethical requirements ... Activities relating to dealings with institutions are coordinated by the Communication and Public Affairs unit" (page 190).

"In addition, companies operating in the concessions sector in Italy and in Brazil actively participate in public consultations promoted by institutions in the sector ... Such participation takes place through trade associations". Those named elsewhere are PIARC's Italian National Committee, the MaSE round table on Minimum Environmental Criteria, AISCAT, ASECAP, ABCR and CEBDS (page 118).

"In 2025, a Group company made contributions in the amount of EUR 398,000 in the United States, in accordance with the forms and procedures laid down by the applicable legislation".

The disclosure does not name the contributing company or the recipients, and does not state whether ASTM appears on the EU Transparency Register.

Payment practices

Reference: page 192, indexed as "ESRS G1-6 Payment practices" (page 205).

The related material IRO is a potential negative impact, "Potential negative effects on suppliers resulting from payments made after the standard payment terms", in upstream value chains across all business units (page 186).

"The average time the undertaking takes to pay an invoice is 34 days (43 in 2024), calculated as the average of the days which elapse between the date of the invoice and the date of payment, weighted by the number of invoices paid during the period" (page 192).

"77% of the invoices analysed respected the standard payment terms (74% in 2024). On average, the concessions sector has payment terms set at 30 days, with the exception of terms relating to service contracts (60 days) and the payment terms set for EcoRodovias Group companies (45 days). The construction sector mainly has payment terms of 60 and 90 days, with the exception of zinc suppliers for whom terms of 150 days apply."

Exclusions are disclosed: "intra-group payments; compensation to members of the Supervisory and Control Bodies ...; ANAS fees for the concessions sector; and retentions for the technology sector".

"No legal proceedings were opened in 2025 due to late payment." The disclosure does not say whether standard terms give particular consideration to SMEs.