Atos

The role of the administrative, management and supervisory bodies

Composition of the Board of Directors

As of the date of this Universal Registration Document, the Board of Directors was composed of 9 members and 1 censor.

Summary statistics:

• 9 Board members
• 1 Lead Independent Director (Elizabeth Tinkham)
• 87.5% Independent Directors (excluding the Employee Director in accordance with article 10.3 of the AFEP-MEDEF Code)
• 62.5% women (excluding the Employee Director in accordance with law)
• 61 years average age
• 1 Director representing Employees (Farès Louis)
• 6 different nationalities
• 1 Censor (Mandy Metten)

Board Members (as of March 27, 2025)

Note: Jean-Jacques Morin, Laurent Collet-Billon, Sujatha (Suja) Chandrasekaran and Joanna Dziubak have sufficient financial and accounting skills by virtue of their educational and career backgrounds for the purpose of their membership in the Audit Committee.

Board Committees

The Board of Directors has established four permanent internal Committees, all chaired by an independent Director:

The Audit Committee

• Independent Chair: Jean-Jacques Morin
• 4 members
• 100% independent Directors
• Members: Jean-Jacques Morin (Chairman), Laurent Collet-Billon, Sujatha (Suja) Chandrasekaran, Joanna Dziubak

The Nomination & Governance Committee

• Independent Chair: Elizabeth Tinkham
• 4 members
• 100% independent Directors
• 1 director representing Employees
• Members: Elizabeth Tinkham (Chairwoman), Sujatha (Suja) Chandrasekaran, Joanna Dziubak, Farès Louis

The Remuneration Committee

• Independent Chair: Laurent Collet-Billon
• 4 members
• 100% independent Directors
• 1 director representing Employees
• Members: Laurent Collet-Billon (Chairman), Farès Louis, Françoise Mercadal-Delasalles, Hildegard Müller

The CSR Committee

• Independent Chair: Françoise Mercadal-Delasalles
• 3 members
• 100% independent Directors
• 1 director representing Employees
• Members: Françoise Mercadal-Delasalles (Chairwoman), Farès Louis, Hildegard Müller

Management Mode

Combination of roles from February 1, 2025

The Board of Directors, on the recommendation of the Nomination and Governance Committee, considered that a unified governance structure was the most appropriate given the specific characteristics of the Atos Group in the current context. Philippe Salle was appointed Chairman and Chief Executive Officer with effect from February 1, 2025.

This pragmatic approach, taking into account the challenges ahead, aims to ensure clear, stable, and embodied management of the Group, while optimally aligning the strategic objectives validated by the Board of Directors with their effective implementation within the organization.

Balance of Powers

In line with best governance practice, this management mode is associated with strong measures to balance powers:

• The Board of Directors is composed of 87.5% of independent Directors (excluding the Employee Director) and comprises one Employee Director
• The Board has formed four permanent internal Committees, all chaired by an independent Director and composed at least of a majority of independent members
• The Lead Independent Director (Elizabeth Tinkham) is responsible for ensuring that the Board of Directors applies the highest standards of corporate governance, and that shareholders' concerns in this area are duly taken into account. Her prerogatives and resources were strengthened by the Board of Directors on January 30, 2025
• The Internal Rules of the Board of Directors set forth the Board's reserved matters which require the Board's prior authorization
• At least once a year, Directors hold meetings, in the absence of the senior executive officers, during which they discuss the Company's affairs

Missions of the Chairman of the Board

The statutory missions of the Chairman of Atos SE's Board of Directors are as follows:

• The Chairman organizes and directs the work of the Board
• The Chairman convenes the Board meetings, determines the agenda and chairs the meetings
• The Chairman oversees the proper functioning of the Company's bodies and makes sure that the Directors are able to carry out their assignments
• The Chairman presides over General Meetings of shareholders and reports on the Board's work to the Annual General Meeting

Additional missions (as decided by the Board in 2020):

• Consulting or being consulted and holding discussions with the Chief Executive Officer or the general management on certain significant and strategic events for the Company
• Representing the Company in its high-level relations with the public authorities and the Company's strategic stakeholders, in consultation with the Chief Executive Officer
• Participating in certain internal meetings with the Company's managers and teams and, as the case may be, as well as in certain Board committees
• Maintaining the quality of relations with the shareholders, in conjunction with the Lead Independent Director
• Participating in the recruitment process for new Directors and in the development of the succession plan, in conjunction with the Chair of the Nomination and Governance Committee and the Lead Independent Director
• Ensuring the balance of the Board (in addition to its proper functioning)
• Arbitrating potential conflicts of interest, in conjunction with the Lead Independent Director

Limitations on the Powers of the Chief Executive Officer

The Board of Directors has defined, in its Internal Rules as revised at the meeting of January 30, 2025, the reserved matters requiring the prior authorization of the Board, either by a simple majority or by a two-thirds majority.

Board of Directors' Reserved Matters voted by simple majority:

• Approval of the business plan or its modification
• Approval of the annual budget and any material deviation thereof
• Capital expenditures and investments not approved in the annual budget in excess of €50 million
• Any acquisition (whether by one transaction or by a series of related transactions) of the whole or a substantial or material part of the business, undertaking or assets of any other person, in excess of €100 million of enterprise value
• Any disposal (whether by one transaction or by a series of related transactions) of a business or entity not included in the annual budget and for a total amount (including all liabilities and other off balance sheet commitments) in excess of €20 million of enterprise value
• The entering into any joint venture agreement, partnership or agreement or arrangement for the sharing of profits or assets, with committed financing or having a value in excess of €50 million
• Any material diversification of the business unrelated to the business activities previously carried on
• Approval of the group financing policy, including incurring any financing, borrowing (including refinancing of any existing borrowings) or entering into any factoring, invoice discounting or similar arrangements, guarantee, pledge, security interest or equivalent transactions (or modifying the key terms thereof) in an amount in excess of €100 million
• Any decision to buy back or redeem shares or other equity instruments (with the exception of share buybacks carried out under liquidity agreements authorized in advance by the Board)
• Any equity issuances (other than intra-group) or other variations in the issued share capital of any group company or creation of any options or other rights to subscribe for or convert into shares in such company
• Approval of the Company's financial statements and consolidated financial statements
• The appointment or dismissal of the statutory auditors
• Any proposal to the Shareholders' meeting, including allocation of profit
• Any dissolution, winding-up or liquidation of any Company's subsidiary (other than a Material Subsidiary)
• Hiring and dismissal of the Company's Chief Executive Officer, as well as any person with a gross annual remuneration in excess of €800,000
• Any change to the terms of employment/corporate mandate of the Company's Chief Executive Officer and the Company's Chief Financial Officer as well as any person with a gross annual remuneration in excess of €800,000
• Any equity profit-sharing or incentive plan
• Any non-equity profit-sharing or incentive plan exceeding €500,000 per employee
• Any related party agreement
• The initiation, engaging in, settlement or taking any material decision by a group company in relation to any litigation or arbitral proceedings where the amount at stake for the group is in excess of €20 million or which would be likely to involve criminal liability for any party thereto
• Entering into any foreign exchange contracts, interest rate swaps or other derivative instruments: (a) other than in the ordinary course of business, and (b) where the exposure to the Group could potentially exceed €100 million
• Disposal of any material group-owned intellectual property
• Making material changes to the accounting procedures, practices, policies or principles
• Delegating any authority of the board to a committee, appointing any member to such committee or making any material amendments to the terms of reference and/or rules of procedure of any such committee
• Declaring, making or paying a dividend or other distribution (whether in cash, stock or in kind) other than to another group company in the ordinary and usual course of business
• The entry by any group company into any contract or arrangement which is outside normal course of trading of the company
• The making of any submission or any business plan to any person with a view to attracting additional financing or refinancing existing debt
• Making of any non-arm's length transactions (including charitable and political donations)
• Entering into any agreement or arrangement (whether in writing or otherwise) to do any of the foregoing or to allow or permit any of the foregoing

Board of Directors' Reserved Matters voted by a two-third majority:

• Any merger, demerger, amalgamation, reconstruction contribution in kind or equivalent transaction
• Entering into any formal negotiations with a third party with respect to the sale of the group or any material part thereof
• Any material alteration (including cessation) to the general nature or strategy of the business, any business line or activity of any group company (including intra-group)
• Any dissolution, winding-up or liquidation of any Material Subsidiary or any group reorganization
• The entry into, amendment or termination by any group company of any contract that is in excess of €500 million
• The entering into any joint venture agreement with committed financing in excess of €100 million
• Any decision to initiate a procedure with a view to the admission of securities issued by a Company's subsidiaries to a financial market and/or change of listing of the Company, including delisting of the Company
• A proposal to the Company's shareholders of changes to the by-laws
• Any transaction or action that requires a prior approval from the creditors under the financing documentation
• Modification of the Internal Rules of the Board
• Entering into any agreement or arrangement (whether in writing or otherwise) to do any of the foregoing or to allow or permit any of the foregoing

Missions of the Lead Independent Director

As per the Board Internal Rules (strengthened on January 30, 2025), the Lead Independent Director is responsible for ensuring that the Board of Directors applies the highest standards of corporate governance, and that shareholders' corporate governance concerns are properly taken into account.

The appointment of a Lead Independent Director is mandatory when the Chairman of the Board of Directors is responsible for the Company's general management.

Duties:

• Prevent and manage conflicts of interest, by bringing to the attention of the Board of Directors any potential conflicts of interest he/she may have identified or been informed of
• Conduct annual assessment of the work of the Board and its committees, with the assistance of the Nomination and Governance Committee
• Be available to meet with shareholders on items pertaining to governance and report to the Board as appropriate. He/she informs the Board of any shareholder concerns relating to corporate governance that come to his/her attention
• Convene the members of the Board of Directors in executive sessions, at least once a year, without the executive corporate officers being present, on a specific agenda determined by the Board; chair the meetings
• Work with the Board Chair and the Chair of the Nomination and Governance Committee on succession planning for the Chair and other directors
• Maintain a regular dialogue with directors, in particular independent directors, to ensure that they have the means to perform their role satisfactorily and are provided with an adequate level of information
• More generally, ensure compliance with the Board of Directors' Internal Rules and with the principles/recommendations of the AFEP-MEDEF Code

Resources:

• He or she may propose to the Chairman the addition of items to the agenda of any Board meeting, and may be consulted on the agenda and schedule of Board meetings
• He or she has access to all documents and information he or she deems necessary to carry out his or her mission
• He or she is kept regularly informed of the Company's activities. He or she may also meet the Group's operational managers, at his or her request and after informing the Chairman and the Chief Executive Officer
• He or she may ask to attend meetings of committees of which he or she is not a member, with the agreement of the Chair of the Committee in question, who will inform the Chairman of the Board
• He or she is assisted by the Secretary of the Board of Directors for administrative tasks

The Lead Independent Director reports annually to the Board of Directors on his or her work and activities.

Diversity Policy at Board Level

The Board of Directors, at its meeting held on December 18, 2024, examined the composition of the Board of Directors and approved the diversity policy applicable at Board level.

Current diversity metrics (as of March 27, 2025):

Age:

• Directors' age ranged from 52 to 74 with an average of 61 years old
• The Board considered that the age average was satisfactory and decided to closely monitor the limit of one third exceeding 70 years old set in the Articles of Association

Gender:

• The Board of Directors was composed of 62.5% women Directors (5 out of 8) (excluding the Employee Director in accordance with law)
• The Board acknowledged that the ratio is satisfactory and above the legal requirement and decided to closely monitor the legal requirement for gender diversity

Diversity of skills and professional experience:

• The year 2024 was marked by a significant renewal of the Board's composition, integrating a variety of profiles, bringing expertise in key areas such as technology, finance, governance, corporate social responsibility (CSR)/Human Resources and employee management
• These adjustments align with the Board's objectives to support the Group's transformation
• The Board recognized that the diversity of skills and experience was highly satisfactory for current needs

Diversity of nationalities:

• The proportion of Directors of non-French nationality reached 67%, with six different nationalities within the Board
• The Board considered that the ratio was highly satisfactory and could be maintained to stay in line with the Group's international dimension

Directors' independence:

• The ratio of independent Directors was 87.5% (7 out of 8) (excluding the Employee Director in accordance with article 10.3 of the AFEP-MEDEF Code)
• The Board acknowledged that the ratio was satisfactory and contemplated maintaining a high ratio of independent Directors above the recommendations of the AFEP-MEDEF Code

Directors' Skills Matrix

Executive and Non-Executive Members

The Board of Directors comprises one executive member (Philippe Salle, as Chairman and CEO) and eight non-executive members.

Employee Participation at Board Level

Employee Directors

As of February 1, 2025, Atos SE's Board of Directors includes one employee director within the meaning of Article L. 225-27-1 of the French Commercial Code: Farès Louis, appointed in accordance with the procedure set out in the Articles of Association.

The Employee Director is expressly designated as a member of the Board in the Board Internal Rules. He fully participates in the meetings and deliberations of the Board. He has the same rights and obligations as any other Directors, in particular of confidentiality, save for the obligation to hold at least 500 shares of the Company.

Employee Participation System and Participatory Committee

Pursuant to an agreement dated December 14, 2012, the Company has implemented a scheme of participation of employees through the creation of the European Company Council of Atos SE and the designation of a Participative Committee composed of up to four persons, which meets with members of the Board of Directors and discusses topics on the agenda of Atos SE's Board meetings. Once a year, the Participative Committee is invited to a plenary meeting of the Board of Directors corresponding to the session on the review of compliance practices of the Company with rules of corporate governance.

Board Operation

Frequency of meetings

The Board of Directors meets at least:

• Once a month for the first 24 months following the date of completion of the financial restructuring
• Once every two months for the following 12 months
• Once every quarter thereafter

Attendance rates in 2024

Overall Board attendance: The attendance rate across all Board members varied, with most Directors achieving attendance rates above 90%.

Committee attendance: Attendance rates in committees were generally high, with most members achieving 100% attendance in their respective committees.

Directors' Training

Upon the appointment of a new Director, various sessions are offered with the main Group executives on the Group's business, organization, governance, innovation and CSR practices.

The induction program includes:

• Presentations by senior executive management on Atos' core fundamentals and its three business lines
• Board Governance training on essential corporate governance principles
• Understanding of Financials, Strategy, and Debt Structure
• Training session on Strategy and M&A, with a specific focus on the review of asset disposals
• Shareholders Dialogue and Activism
• CSR and decarbonization activities, Atos' R&D (research and development) and innovation
• Visit in Bezons of the innovations demonstrated in Atos' Business Technology and Innovation Center (BTIC)

Specific external trainings are contemplated for Directors on an ad hoc basis. Additional sessions on the new regulatory landscape in terms of CSR (in particular CSRD), led by recognized experts, are scheduled to reinforce the Board's skills on this major issue.

In accordance with the law, Employee Directors receive additional training, the content of which is determined each year by the Board of Directors, after consultation with the directors concerned.

Sustainability-Related Expertise

CSR Committee Composition and Expertise

The CSR Committee is chaired by Françoise Mercadal-Delasalles (Independent Director) and includes:

• Farès Louis (Employee Director)
• Hildegard Müller (Independent Director)

Françoise Mercadal-Delasalles has developed expertise in sustainable transition and ESG integration:

• Co-founder and President at Auxo, an integrated platform to manage extra-financial data and support companies in their transition to sustainability (since 2023)
• Former CEO of Crédit du Nord (2018-2022), where she introduced digital tools and integrated ecological concerns into the company's business model
• Co-chair of the National Digital Council (Conseil National du Numérique) since 2021

Hildegard Müller:

• President of the German Association of the Automotive Industry (VDA) since 2020
• Former Chair of the Executive Board at the Bundesverband der Energie- und Wasserwirtschaft (BDEW) in Germany (2008-2016), leading the organization on energy and water industry matters
• Chief Operating Officer for Grid, Network & Infrastructure at Innogy in Germany (2016-2019)
• Member of various Supervisory Boards including Finance, Strategy, and Sustainability Committee roles

Farès Louis:

• Business Developer Cyber Security Products
• Trade union representative and member of the CFDT corporate body
• French Labor Court judge (Conseiller Prud'homal)

Philippe Salle (Chairman and CEO) has developed in-depth expertise in the challenges of sustainable industrial transformation:

• Past positions notably with Emeria and Viridien (formerly CGG, a major player in services and technologies applied to the energy transition)
• Has managed groups operating in sectors sensitive to climate and energy issues
• Brings recognized expertise in sustainable transition and the integration of CSR issues into corporate strategies
• Expertise in decarbonization, technological innovation in the service of the environment and responsible governance models

The Chairman and Chief Executive Officer, along with the Board of Directors, supported by the CSR Committee, ensure they have the necessary expertise to oversee the Group's material sustainability topics. They draw on internal expertise (in-house experts for deep insights), can call on external specialists on specific issues, and organize targeted training programs for Directors.

Assessment of Board Work

In accordance with the AFEP-MEDEF Code requirements, the qualification of an independent Director is:

• Discussed annually by the Nomination and Governance Committee
• Examined annually on a case-by-case basis by the Board
• Discussed at each appointment of a new Director and when Directors' terms of office are renewed

The Lead Independent Director conducts annual assessment of the work of the Board and its committees, with the assistance of the Nomination and Governance Committee.

At least once a year, Directors hold meetings in the absence of the senior executive officers, during which they discuss the Company's affairs and address, among other subjects, the senior executive officers' succession plan.

Communication with Shareholders

In accordance with the AFEP-MEDEF Code, the Company has regular direct contacts with its shareholders and investors throughout the year. Measures favoring smooth shareholders' dialogue include:

• Atos' shareholders decided with 99.93% of the votes to enshrine the Company's raison d'être in its Articles of Association (April 30, 2019)
• Presentations for financial reports, investor days or General Meetings are posted on the website
• The Company conducts a governance roadshow prior to its Annual General Meeting
• The Lead Independent Director (Elizabeth Tinkham) engages with shareholders on governance matters
• Atos regularly communicates its strategy to its shareholders and provides market updates

Conflicts of Interest and Independence

Ring Fencing Measures

Pursuant to the Board Internal Rules, Board members linked to a competing company shall not:

• Have access to Atos SE's strategic or commercially sensitive information on competing markets
• Participate in meetings at which such information is discussed

If the Board considers a proposed transaction involving Atos Group activities in competition with those carried out by one of its shareholders, the director(s) appointed on the proposal of or representing the said shareholder may not, in principle, attend the debate or vote on the related resolution.

Conflicts of Interest

A Director undertakes to strictly avoid any conflict that may exist between his or her own moral and material interests and those of the Company. Directors must inform the Chairman of the Board of Directors of any conflict of interest, even a potential one. In case of conflict, he or she must abstain from participating in discussions and decisions on such matter.

To the best of the Company's knowledge, there is no conflict of interest between the duties to the Company of Directors and senior executive officers and their private interests and/or other duties.

Governance Framework

Reference Code

The Company uses the AFEP-MEDEF Code of Corporate Governance for listed companies (revised version published in December 2022) as its reference framework.

The Company's governance practices are fully compliant with the AFEP-MEDEF Code, with one exception regarding the compensation policy applicable to the Chairman and Chief Executive Officer for the 2025 financial year (Article 26.3.3 on long-term compensation of executive officers).

Governance Term Sheet

Following the accelerated safeguard plan approved on October 24, 2024, a Governance Term Sheet dated July 14, 2024 sets out governance principles, including:

General principles:

• Atos SE will remain a European company whose shares are admitted to trading on Euronext Paris
• The Company's registered office will be maintained in France
• The Company will continue to refer to the AFEP-MEDEF Code
• The Company will remain non-controlled within the meaning of Article L. 233-3 of the French Commercial Code

Composition and operation of Management bodies:

• The Company will be represented by its Chief Executive Officer, under the supervision of the Board of Directors
• The Board will comprise eight members, in addition to employee representatives
• Most Board members (at least five) will be independent directors
• The Company's Chief Executive Officer may be appointed Chairman of the Board. In this case, a Lead Director will also be appointed from among the independent directors
• The Board must meet customary professional standards and gender diversity requirements (at least 40% of directors representing each sex)

Board Committees:

• Four current committees maintained: Audit Committee, Nomination and Governance Committee, Remuneration Committee, and CSR Committee
• All committees include a majority of independent directors and are chaired by independent directors

Shareholding as of December 31, 2024

• Philippe Salle (Chairman and CEO): 1.36%
• Employees: 0.08%
• Board of Directors (excluding Philippe Salle): 0.0002%
• Free float: 98.57%

Integration of sustainability-related performance in incentive schemes

Reference to Detailed Disclosure

Please refer to Chapter 4.3 on the integration of sustainability-related performance in incentive schemes over the past years.

Climate-Related Performance Integration

As far as climate is concerned, in 2024 climate-related considerations were not factored into the remuneration of the administrative and management bodies, including the CEOs.

2025 Changes - CEO Short-Term Incentive

This was modified in January 2025, where 10% of the annual variable compensation of the CEO of Atos – Philippe Salle – is now linked to the short-term 2025 target to reduce GHG emissions (Scope 1, 2 and 3) compared to 2019 baseline.

Coverage

• Role covered: CEO (Philippe Salle)

Sustainability KPI

• Metric: GHG emissions reduction (Scope 1, 2 and 3)
• Baseline: 2019
• Target period: 2025

Weighting

• 10% of annual variable compensation (short-term incentive)

Incentive Type

• Short-term incentive (STI)

For more information, please refer to section 4.3 Compensation and stock ownership of Company officers.

Business model

Sustainable Digital Transformation

It has become mandatory for enterprises and public organizations to "future‑proof" their organizations to successfully navigate disruptions beyond their control and previously seen as outside of their sphere of influence or activity.

This is achieved through a robust digital strategy underpinned by a long‑term sense of purpose that leverages reliable, innovative and sustainable partners.

In line with our purpose of helping to design the future of the information space, Atos has a strong ambition to be recognized as one of the companies that may act as such partner. We use our expertise and services to support the development of knowledge, education and research in a multicultural approach and contribute to the development of scientific and technological excellence.

The past year has seen continued economic uncertainty, with enterprises having to take decisive action on their digital transformation, with Data and Artificial Intelligence at the heart of it. Decision makers continue to run securely the business but must accelerate their AI‑readiness. This is fully supported by our innovation and business model within the digital solutions value chain, where we leverage or integrate solutions from upstream partners—such as computing hardware providers (Dell, EMC, HPE, IBM, Intel, Nvidia, etc.), hyperscalers (AWS, Microsoft, Google Cloud, etc.), and software providers (SAP, ServiceNow, Oracle, etc.)—to deliver consulting, integration, and managed services and solutions to our downstream customers and end‑users, primarily large public and private organizations. As a world leader in cybersecurity services and a recognized player in sustainability consulting, we embed trust, security, compliance, and sustainability at the core of our business across the entire value chain.

Across the world, the Group enables its customers, employees and members of societies at large to live, work and develop sustainably, in a safe and secure information space.

The Atos raison d'être

The Atos raison d'être, as included in its articles of association on April 30, 2019 at the General Meeting of shareholders of Atos, describes how the Company's entire operations contribute to the common good. The raison d'être guides Atos to engage with its stakeholders, or its "ecosystem": employees, customers, shareholders, academia and research centers, industrial partners and public authorities.

"The purpose of Atos is to help design the future of the information space. Its expertise and services support the development of knowledge, education and research in a multicultural approach and contribute to the development of scientific and technological excellence. Across the world, the Group enables its customers and employees, and members of societies at large to live, work and develop sustainably, in a safe and secure information space."

By adopting this raison d'être, Atos pledges its responsibility to design the digital space by building it in a trusted manner, tackling climate change and contributing to scientific and technological excellence.

Architecture of Atos' contribution

Atos organized its raison d'être into three pillars with a dedicated ambition for each one:

Trust - Building a trusted digital space to provide everyone with the skills to use digital technologies confidently, and to mitigate the risk exposure of individuals, companies and states in the digital space

Environment - Tackling climate change to improve the environmental performance of digital solutions and turn new technologies into allies in the fight against global warming.

Excellence - Contributing to scientific and technological excellence to promote excellence in scientific and technological advancement, knowledge‑sharing, and research.

This organization in three pillars, illustrates Atos' commitments to its raison d'être and allows employees to better link their daily contribution to it. The ambition of the Group to be a leader in a secure and decarbonized digital space is completely aligned on the first two pillars (Trust and Environment), while leveraging the expertise and knowledge of Atos' human capital promoted by the third pillar (Excellence) to achieve it.

Atos profile

Atos is a global leader in digital transformation with c. 78,000 employees and annual revenue of c. € 10 billion. European number one in cybersecurity, cloud and high‑performance computing, the Group provides tailored end‑to‑end solutions for all industries in 68 countries.

A pioneer in decarbonization services and products, Atos is committed to a secure and decarbonized digital for its clients. Atos is a SE (Societas Europaea) and listed on Euronext Paris.

Value chain

In its mission, the Group leverages the capital it has built over years, and a business model based on distinctive expertise, technologies, platforms and business solutions.

Our Capitals

Over the years, Atos has built assets that bring the Group a distinctive position on the digital transformation market, and constitute a firm foundation, which its business model relies on:

Industrial capital with delivery teams, data centers and customer innovation labs covering 68 countries. Harnessing the latest hybrid cloud technologies and digital design, development and operation tools, processes and best practices with Gen AI at their core. These centers enable Atos to serve and support its customers 24/7 anytime, anywhere, with the ability to provide a combination of local, nearshore and offshore delivery.

Human capital of c. 78,000 business technologists. Atos experts include consultants, developers, integrators and operation specialists, sourced from tier one universities worldwide. Highly skilled on the whole spectrum of digital technologies, Atos people benefit from a steady investment in the latest technological and leadership trends through intensive and dedicated training programs.

Intellectual capital with significant Digital and Cloud R&D spending per year, leveraging the innovation of 18 R&D centers with a focus on strategic technologies. Atos excellence in R&D is illustrated by a world‑class portfolio of IP solutions and 2,400 patents. It is nurtured by a Group- wide community of experts and fellows.

Extended social and relationship capital, relying on a strong network of partners featuring leading technology providers (Amazon Web Services, Cisco, Dell Technologies, Google Cloud, Microsoft, Oracle, Red Hat, SAP, Siemens, VMware, Worldline, and many more), customers, research institutions and industry consortia. As a leading digital transformation company, Atos is committed to supporting society, with strong contributions to diversity and social inclusion programs.

Strong natural capital relying on Atos' deep commitment to sustainability. Atos involvement in sustainability is embodied in pioneering an ambitious environmental program to reduce its carbon emissions through measurement, reporting, optimization, offsetting and the use of decarbonized energy sources.

The value we create for stakeholders

As a result of its capital assets and of its business model, Atos strives to generate value for all its stakeholders:

People: Putting "people first" is the foundation of the Atos way of working and growth strategy. Atos is committed to attract and nurture today's most talented digital experts from diverse backgrounds and offer them the opportunity to build the new digital world. Atos is a responsible employer, promoting collaborative working, diversity, inclusion and well‑being at work.

Clients: Atos aims to be the trusted partner of its customers in their digital transformation journey and was the first Information and Communication Technology (ICT) Company to obtain the approval of its Binding Corporate Rules (BCR) by European data protection authorities putting data protection as a key component of its business culture, for clients, partners and suppliers.

Investors: Atos remains committed to long‑term investor and shareholder value creation.

Partners: Atos offers strong business growth and co‑innovation opportunities to its large ecosystem of partners, ranging from large Groups of startups, that are deeply supported by Atos Labs and Business Technology Innovation Centers.

Suppliers: Atos is committed to delivering high value to its networks of suppliers. The Group has built solid governance, using ethics and compliance to drive organizational processes, and business, thereby securing a sustainable supply chain.

Community & society: The group aspires to achieve excellence in its community and societal contributions. Atos ranked in the Top 5% of the S&P Global Corporate Sustainability Assessment (CSA) and was featured in the S&P Global Sustainability Yearbook for the 12th consecutive year.

Interests and views of stakeholders

Stakeholder identification

Atos is aware of the importance of engagement with its stakeholders, i.e. external and internal groups and individuals who represent clients, employees, investors, employee representatives, business partners and suppliers, as well as communities and public authorities.

Engagement approach

Atos engages in a constant dialogue with its stakeholders at all levels of the organization using a variety of interaction channels to ensure a transparent communication about its CSR programs and to align with the demand of the market and investors.

To structure its stakeholders dialogue, Atos uses international standards in alignment with the following principles: inclusivity, materiality, responsiveness, and impact. Views and interests of affected stakeholders are addressed and reported by the Group CSR Officer during meetings of the CSR Committee of the Board of Directors.

In 2024, Atos has also engaged at length with its stakeholders in the process of double materiality assessment. For a description of Stakeholders' identification and consultation in the double materiality assessment process please see section 5.1.1.3.1.3.1 Stakeholders' identification and consultation.

Key stakeholder groups, interests and views, and value created

Following the double materiality assessment process, Atos has taken into account the interests and views provided by its key stakeholders as an input in relation to its strategy and business model. The interests and views of Atos' key stakeholders and how Atos considers the stakeholders' relevant expectations to create value, following engagement with them, are described as follows.

Clients

Expectations: Atos' clients expect innovative accessible digital solutions that create value by helping them optimize their operational performance and address their own challenges such as tackling climate change or reporting according to some requirements. These solutions also need to ensure high levels of security and data protection.

Value created by Atos: Atos' business model is founded on creating value for its clients and partners through: (i) innovative, sustainable and accessible business solutions that meet clients' needs to perform in the new digital economy, and (ii) continuous products and services' improvements in line with clients' needs and increased customer satisfaction.

Employees and employees' representatives

Expectations: Atos employees expect a safe, equitable and open work environment, where their contribution is valued, their data are protected, and their ambitions and potential to grow and develop can be fully realized within the Company. Employees also expect to enjoy their freedom of association's rights and a positive and constructive social dialogue with their representatives.

Value created by Atos: Atos recognizes that being a responsible employer means providing a safe, diverse, inclusive, and rewarding work environment where differences are celebrated and individuality is respected, while preparing its people for the workplace of the future. Atos has put in place programs to train, develop and retain its employees and encourage internal hiring and promotion. Moreover, Atos engages with employees' representatives via well‑defined processes and fora both at Group level (Societas Europaea Council or SEC) and at country level.

Investors and analysts

Expectations: investors expect profitability and efficiency from Atos, in line with its carbon footprint and energy efficiency commitments to tackle climate change. They also demand clarity and transparency regarding value creation and resource management.

Value created by Atos: Atos discloses its CSR KPIs and integrates financial and non‑financial factors, providing valuable information to investors.

Partners

Expectations: collaboration with partners is key to face challenges in the IT industry and ensure the development of innovative technologies.

Value created by Atos: Atos has a unique partnership ecosystem that consists of both major IT industry players and start‑ups that work together with Atos labs and Business Technology Innovation Centers. This enables Atos to combine a disruptive mindset with best‑in‑class technologies in its digital solutions for its clients.

Suppliers and workers in supply chain

Expectations: Atos suppliers want to benefit from access to new markets, revenue growth and fair margins. They expect long‑term relationships supported by ongoing dialogue that ensures the observance of contracts, shared ethical values and trust. Workers in Atos supply chain expect respect of their health and safety as well as their human and fundamental rights.

Value created by Atos: Atos governance framework uses ethics and compliance to drive organizational processes and business thereby securing a sustainable supply chain. Atos works closely with its suppliers to ensure that they meet the required standards on environment, labor and human rights, ethics and sustainable procurement, thereby protecting also the fundamental rights and freedom of workers in its supply chain.

Affected communities and society

Expectations: Atos is expected by society and local communities to provide socio‑economic benefits through job creation, smart solutions and new technologies. Atos is also expected to reduce its environmental impact and help its clients and suppliers in doing the same. Public bodies deliver administrative authorizations and set the regulatory context in which Atos operates.

Value created by Atos: Atos is committed to generating economic value that also benefits society by addressing those stakeholders' needs and challenges by impacting local economies, creating new jobs and enhancing IT skills. As a recognized leader in CSR in the IT sector, Atos aims to minimize and offset environmental impacts and generate sustainable profits to support innovation. Through its digital IT solutions and its support for volunteer programs, university relations and corporate citizenship activities, Atos aims to have a positive and long‑term impact on local economies, support social progress and reduce the digital divide, contribute to access the digital and information space and thus further knowledge development, education and research, develop cybersecurity technology and solutions, and support organizations fighting against cyber‑criminality.

Distinction between affected stakeholders and users of sustainability information

The disclosure addresses both affected stakeholders (those impacted by the business) including own workforce, value chain workers, affected communities, and consumers/clients, as well as users of sustainability information (investors and analysts).

Material impacts, risks and opportunities

From September 2023 to March 2024, the Atos Group conducted a double materiality assessment to identify its material impacts, risks and opportunities covering the whole value chain, including providers, clients and NGOs. PricewaterhouseCoopers Advisory (French entity of PwC international network) has accompanied Atos on the methodology of the double materiality analysis. This exercise is fully aligned with the obligations set out by the ESRS. As an outcome of its double materiality assessment, Atos Group has identified 63 material IROs, covering 9 ESRS.

The complete list is to be found in section 5.1.1.3.2.

Atos sets priorities in the areas of Environment, Social and Governance (ESG) in which it can contribute, in particular with its core digital strengths.

Atos Group contributes to 10 out of the 17 Sustainable Development Goals (SDGs), which are defined by the United Nations and highlighted in the Group's double materiality assessment.

Environment

Science based actions

Approach: Aiming to reduce its GHG footprint in line with international scientific standards and contributing to limiting global warming to 1.5°C, as outlined in the Paris Agreement.

Priorities: • Reducing carbon emissions full scope (1, 2, 3) by 50% until 2025 (SBTi near-term target) • Improving energy efficiency of the Group's operations • Reducing Atos' environmental footprint (including waste)

Low footprint IT for a Sustainable Portfolio

Approach: Striving to gradually reduce the environmental impact of Atos operations and its supply chain. Developing "sustainable by design" IT solutions supporting customers in their own sustainability journey.

Priorities: • Developing digital solutions and technologies with increased energy efficiency • Developing decarbonization digital solutions and technical services to reduce clients' carbon footprint

Social

Tech for Good

Approach: Becoming an employer of choice with programs to attract and retain talents and to manage careers within an inclusive, creative, responsible and collaborative workspace.

Priorities: • Promoting diversity, equity and inclusion across the organization and supply chain. • Reinforcing key programs in talent attraction, retention and skill development to become an employer of choice • Client relationships • Digital inclusion • Data privacy & cybersecurity

Governance

Enhance trust

Approach: Being recognized as a trustworthy digital company from corporate governance, ethics and data safety perspectives.

Priorities: • Being an ethical and fair player within its sphere of influence through maintaining the highest standards in corporate governance and business conduct. • Creating value for clients and partners through innovative and secured solutions to navigate the digital space.

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

From September 2023 to March 2024, the Atos Group conducted a double materiality assessment to identify its material impacts, risks and opportunities covering the whole value chain, including providers, clients and NGOs.

PricewaterhouseCoopers Advisory (French entity of PwC international network) has accompanied Atos on the methodology of the double materiality analysis. This exercise is fully aligned with the obligations set out by the ESRS.

As an outcome of its double materiality assessment, Atos Group has identified 63 material IROs, covering 9 ESRS. The complete list is to be found in section 5.1.1.3.2.

Transition plan for climate change mitigation

Overview and status

Atos' global decarbonization plan has been largely underway since 2020. The plan is built around three pillars for Atos to build resilience in a +1.5°C future:

1. GHG emissions reduction: Atos aims to reduce its GHG footprint in line with international scientific standards, to do its part to limit global warming to 1.5°C (Paris Agreement), and to achieve carbon neutrality (net-zero) by 2050
2. Low footprint IT for a Sustainable Portfolio: Atos strives to gradually reduce the environmental impact of its operations (data centers, IT hardware, software, services, solutions, etc.) and its supply chain. This will enable Atos to develop IT solutions "sustainable by design" supporting customers in their own journey to reduce their environmental impact and fight climate change.
3. Building resilience against environmental risks: The ongoing assessment and mitigation of environmental risks to Atos' activities and business (physical and transformation risks) will enable the Group to better adapt to a +1.5°C future.

The objective is to develop the decarbonization plan to become the transition plan (as defined by ESRS E1) and to drive progressive developments in Atos' strategy and business model to make them compatible with:

1. The transition to a sustainable economy
2. The objective of limiting global warming to 1.5°C compatible with the Paris Agreement
3. Defining and validating with the SBTi long term and net zero targets by 2050

Atos is not excluded from the EU Paris‑aligned Benchmarks and has no exposure to coal, oil and gas‑related activities.

Transition plan completion timeline: Atos expects to finish building its transition plan in 2025 and to obtain approval by end 2026 by the Executive Committee and the Board of Directors of Atos. The transition plan will include quantified investments and funding requirements to support its implementation. These resources will be reflected in the taxonomy eligible and aligned CapEx of the EU Taxonomy report.

Current status: In the meantime, Atos is not in a position to comply with the following datapoints related to the transition plan: ESRS E1‑1 § 16 a to j

Scope of the plan

• Entities and geographies: The decarbonization plan covers the full scope of the entire Atos organization (100%) including all Atos entities and operations, all office sites, and data centers regardless of their location, and all geographical areas where the Group operates.
• Value chain segments: The plan covers upstream, own operations and downstream activities across all three GHG Scopes (1, 2, and 3).
• Suppliers: The Environmental Policy applies to suppliers and subcontractors through the Atos Partners' Commitment to Integrity.

Target year(s) for net zero / carbon neutral

• Net zero target year: 2050
• The Group aims to define and validate with the SBTi a long‑term and net‑zero target by 2050 (as per the Paris Agreement)

GHG reduction milestones and baseline years

Near-term Science-Based Target (SBTi validated)

• Target: Reduce by 50% all the Group's carbon emissions (GHG Protocol Scopes 1, 2 and 3) between 2019 and the end of 2025
• Baseline year: 2019 (3.303 MtCO2e total GHG emissions)
• Target year: 2025 (1.652 MtCO2e target)
• Current performance (2024): 1.788 million tCO2e, representing a reduction of -46% compared to 2019

This is an absolute target measured in million tons of CO2equivalent (MtCO2e). The 2019 baseline emissions cover all Atos emission upstream, own operations and downstream and did not exclude any geography, business line or significant activity of the Atos Group.

Scope coverage:

• The target considers all significant sources of emissions for Scopes 1, 2 and 3
• For Scope 3, all significant categories are included (categories 1 & 2 – purchased goods and services/capital goods and category 11 – use of sold products)

Alignment with 1.5°C / SBTi validation status

• Paris Agreement alignment: The target is compatible with the Paris Agreement, exceeding the minimum requirements necessary to limit global warming to 1.5 degrees
• SBTi validation: The near-term target has been officially validated by the SBTi
• Historical validation: In 2017, the SBTi validated Atos' carbon intensity target for 2050 (-86% versus 2012)
• Methodologies: The target has been defined using the GHG Protocol and the Science‑Based Target initiative (SBTi) Net‑Zero Standard criteria and methodologies
• SDG contribution: Considers and contributes to the UN Sustainable Development Goals (SDGs) 12 "Climate action"

Key levers / decarbonization pillars

The global decarbonization plan includes a series of actions which individually and collectively contribute to the Group's overall decarbonization results:

Scope 1 and 2 levers:

Offices and data centers optimization programs

• Progressively reducing the number of sites, including reduction of utilization of space (square meters) to reduce energy consumption
• In 2024, the volume of space used in Atos sites was approximately 723,000 m² (a decrease of approximately 7% against 2023)

Energy efficiency and reduction of energy consumption

• Activities to progressively improve the energy efficiency of sites (e.g. reducing Power Usage Effectiveness (PUE) in data centers)
• Reduce energy consumption (e.g. limitation of the amplitude of heating and cooling systems; automatic standby or shutdown of equipment)
• At the end of 2024, the average PUE was 1.44 for core data centers (1.44 in 2023 and 2022)

Shift to renewable and/or low carbon energy

• Progressively shifting to renewable energy through renewables purchasing agreements, buying Renewable Energy Certificates (RECs) or self‑generation energy (e.g. solar panel on sites)
• Track the share of renewable energy in the overall energy consumption with the aim to increase this share
• In 2024: 56% share of renewable sources in total energy consumption (239,567 MWh renewable from 430,016 MWh total)

Upgrade cooling systems

• Progressively replace existing cooling systems in offices and data centers with more recent technologies and lower global‑warming‑potential refrigerants (F‑Gas)
• Emissions from cooling systems in 2024: 9,214 tCO2e (vs 11,279 tCO2e in 2019 baseline, -18%)

Atos car fleet optimization (shift to electric/hybrid cars)

• Progressively shift car fleet (aiming at 100% of Atos car fleet by end of 2030) to hybrid vehicles (HV) or electric vehicles (EV) in countries where such vehicles are economically acceptable and local energy mix allows for demonstrated carbon emission reductions
• Average emissions of Atos company cars in 2024: 44.80 gCO2e/Km (vs 106 gCO2e/Km in 2019 baseline, -61%)

Scope 3 levers:

Decarbonization of Atos Supply Chain

• Large action plan launched since 2020 to decarbonize Atos supply‑chain by reviewing suppliers' contribution to GHG emissions
• Green/red/amber classification of suppliers based on environmental strategy maturity
• Atos stakeholders are encouraged to channel investments and spend towards green and amber suppliers
• In 2024, 75% of Atos Group's suppliers spend are evaluated via Ecovadis or an alternative assessment
• Reinforcement of energy consumption and CO2 emissions as key purchasing criteria for goods and services
• Supplier selection criteria including an increased weight for CSR risk and environmental topics

Promotion and sale of eco-designed IT and decarbonization solutions

• Development of digital solutions and technologies with increased energy efficiency (Low footprint IT)
• Development of decarbonization digital solutions to reduce clients' carbon footprint (Sustainability Portfolio)
• Development of decarbonization technical services to reduce clients' carbon footprint

Examples of sustainable offerings:

• EcoVadis Ratings & Scorecards: platform enabling clients to assess sustainability performance of their suppliers
• Atos CeSaR & Atos CeSaR Advanced: suite of AI-based tools helping clients optimize responsible procurement
• Atos Product Environmental Footprint (PEF) service: assesses environmental impact using EU PEF methodology
• High Performance Computing (HPC) servers for weather forecasting and climate modeling
• CeSaR Performance – Generative AI for Sustainable Procurement
• Sustainable Digital Workplace: suite of offerings to help clients decarbonize their workplace

Travel/transport optimization and waste management

Other levers impacting Greenhouse Gas emissions

• Finetuning carbon accounting methodologies in line with latest science and best practices
• Ongoing alignment with GHG Protocol, SBTi, IPCC, ISSB developments

CapEx / investment commitments

Atos is unable to report specific financial resources allocated to action plans because CapEx and OpEx are not yet tracked and reported at Group level in a manner directly linked to the decarbonization plan. Although such investments exist, they are not identified as directly linked to the decarbonization plan because they are aggregated in the investments and resources of entities, business lines etc.

Investments may also contribute indirectly to the decarbonization plan while primarily meeting other needs (e.g., renovation of lighting to improve working comfort may also generate a reduction in consumption and emissions). In such cases, the investments are not identified towards the "decarbonization plan" and are not reported as such.

The transition plan, expected to be completed in 2025 and approved by end 2026, will include quantified investments and funding requirements. These resources will be reflected in the taxonomy eligible and aligned CapEx of the EU Taxonomy report.

EU Taxonomy alignment

Atos' ambition is to use the Taxonomy regulation as a guide and roadmap for any new Atos solution or service, thereby enlarging its Sustainability Portfolio offerings which are eligible and aligned with the EU Taxonomy.

2024 EU Taxonomy CapEx results:

Locked-in emissions and stranded asset analysis

Not disclosed in the current reporting period. The company states it is not in a position to comply with ESRS E1‑1 § 16 a to j datapoints related to the transition plan.

Use of carbon credits / removals

Atos does not produce any biogenic CO2 emissions.

No information disclosed regarding the use of carbon credits or carbon dioxide removal in the current reporting period.

GHG emissions 2024 performance

Total GHG emissions (market-based):

• 2019 baseline: 3,303,236 tCO2e
• 2024: 1,787,544 tCO2e
• Evolution 2024/2023: -20%
• Evolution 2019-2024: -46%
• 2025 target: 1,651,618 tCO2e (-50% vs 2019)

By scope (2024):

• Scope 1: 17,313 tCO2e (1% of total)
• Scope 2 (market-based): 62,523 tCO2e (3.5% of total)
• Scope 3: 1,707,709 tCO2e (95.5% of total)

Energy consumption 2024:

• Total energy consumption: 430,016 MWh (vs 523,822 MWh in 2022, -17%)
• Renewable energy: 239,567 MWh (56% of total)
• Fossil energy: 190,449 MWh (44% of total)

Policies related to climate change mitigation and adaptation

Environmental Policy

Atos has implemented an Environmental Policy to serve its Environmental Program that provides high-level principles, over the short and long term, regarding the Group's main environmental challenges including climate change mitigation and adaptation.

Approval and oversight:

• Validated by the Senior Executive Vice President & Head of Partnerships & Alliances
• Owned by the Head of Global Environment Program

Scope:

• Applies to all Atos entities and operations
• Applies to all office sites and data centers regardless of their location
• Applies to the full scope of the entire Atos organization (100%) including its suppliers and subcontractors

Key content: The Environmental Policy covers IROs 1 to 15 related to climate change and applies to all levers and action plans including:

• Office and data center optimization programs
• Shift to renewable and/or low carbon energy
• Upgrade of cooling systems
• Decarbonization initiatives aligned with Science Based Targets

Link to suppliers: The policy is extended to suppliers and subcontractors through the Atos Partners' Commitment to Integrity, which sets out the ethical commitment that Atos expects its partners to take before entering in a contractual relationship. This commitment also aims to support Atos' efforts to decarbonize its supply chain in line with its carbon reduction science-based targets.

Monitoring: The document references that the policy applies to action plans and levers described in the decarbonization sections, though specific monitoring mechanisms are not detailed in the E1-2 section.

Public availability: Not disclosed in the excerpts provided.

Transition plan development: Atos expects to finish building its transition plan in 2025 and to obtain approval by end 2026 by the Executive Committee and the Board of Directors of Atos. The transition plan will include quantified investments and funding requirements to support its implementation.

Actions and resources in relation to climate change policies

Environment Management System and ISO 14001 certification

Description: The EMS enables and oversees the ISO 14001 certification of Atos main sites offices with more than 500 employees and Atos-owned core data centers, as well as other smaller sites for business or compliance needs. The EMS and ISO 14001 certification enable the evaluation of progress in reducing energy consumption and the use of renewable energy, the monitoring of energy savings targets and, where applicable, allowing local energy audits and encouraging best practices and investments in innovation to decrease energy consumption.

Scope: Own operations

Performance & Coverage:

• In 2024, 92.3% of Atos' main sites were ISO 14001 certified or in the process of being certified (vs 88.6% in 2023)
• In 2024, 95 sites were ISO 14001 certified (including but not limited to main sites, with also smaller sites and not core datacenters that joined the certification for business or compliance reasons)

Link to target: Supports the implementation of the Atos Environmental Program and the near-term SBTi target of 50% absolute GHG emissions reduction by 2025 (from 2019 baseline)

Environmental Program & EMS e-learning training

Description: Atos internal Global Compliance Trainings program integrates a dedicated mandatory training for all employees on environmental challenges and KPIs. This "Environmental Program & EMS" e-learning supports ISO 14001 certification, engages awareness for all employees on energy efficiency, climate change, waste, water, pollution and biodiversity topics, and promote eco-friendly behaviours worldwide.

Scope: Own operations

Resources (non-financial): Training delivered to entire workforce

Performance:

• In 2024, 93.66% of the total Atos workforce (active internal employees), across all sites, received this complete online training (vs 91.77% in 2023)

Finetuning carbon accounting impacting GHG emissions

Description: Atos is constantly seeking ways to improve the accuracy and completeness of its carbon footprint to remain aligned with necessary developments and best practices while ensuring multi-year stability of results. This includes:

• Impact of inflation on monetary emission factors used to convert Euros of spend in CO2e
• Geolocation of carbon emission factors
• Development of new specialized or sectorial databases or updating of existing databases offering more precise emission factors
• Progress made in carbon accounting methodologies to reduce uncertainty levels and improve the quality of carbon data
• Use of smart proxies with more precise emission data
• Use of the latest annual carbon data released by Atos suppliers
• Level of precision for emissions reported by contributors to Atos Scope 3 emissions
• Capacity of suppliers to deliver specific data for specific goods and services Atos purchases
• Gradual replacement of products and services Atos uses by new products and services with lower carbon footprint

Scope: All scopes (upstream, own operations, downstream)

Time horizon: Continuous improvement between 2019 and 2024

Low footprint IT to address clients' decarbonization challenges through digital technologies ("Sustainability Portfolio")

Description: Atos aims at continuously developing, enhancing, and delivering a sustainability portfolio of digital solutions, services and technologies for clients seeking to reduce their environmental footprint.

Scope: Downstream value chain (client solutions)

Examples of offerings:

• EcoDesignCloud for Life Cycle Assessments: Provides a trusted calculation of the environmental impact of each product, at every stage of its lifecycle. Using Artificial Intelligence algorithms, EcoDesignCloud provides an automated multicriteria measure of the environmental performance of any goods, providing 16 Product Environmental Footprint (PEF) impact indicators, including CO2 emissions, considering end-to-end supply chain activities

• High Performance Computing (HPC) servers: Used to work on medium and long-range weather forecasting and prediction and global climate modeling. This innovative technology coupled with artificial intelligence helps researchers improve the ability to forecast the occurrence and intensity of extreme weather events and other new weather phenomena triggered by climate change

• CeSaR Performance – Generative AI for Sustainable Procurement: A generative AI-based solution for sustainable procurement

E-waste management actions

Description: Actions related to e-waste management to reduce the emissions linked to waste management.

Scope: Own operations

Note: Detailed in Section 5.1.2.3.3.2 -Actions (not included in excerpts)

Overall GHG Reduction Performance

Target: Near-Term SBTi validated target: 50% absolute reduction in GHG emissions by end of 2025 (from 2019 baseline)

Baseline: 3,303,236 tCO2e (2019)

Target: 1,651,618 tCO2e (2025)

Performance achieved 2019-2024: -46% reduction (1,787,544 tCO2e in 2024)

Remaining reduction needed: -4% to reach 2025 target

Scope: All Atos activities, including own activities and upstream and downstream value chain activities in all geographical areas where the Group operates

Coverage: All Atos emission upstream, own operations and downstream, with no geography, business line or significant activity excluded

Link to SDGs: Contributes to UN Sustainable Development Goal 12 "Climate action"

Note: The target is linked to Atos' sustainability-linked bond placed in 2021 and cannot be modified

Targets related to climate change mitigation and adaptation

GHG Emissions Reduction Target – Near-Term Science-Based Target

Target metric: Total GHG emissions (all Scopes 1, 2 and 3)

Target value: Reduce by 50% (absolute)

Target year: 2025 (end of)

Baseline year: 2019

Baseline value: 3.303 MtCO2e (3,303,236 tCO2e)

Scope:

• All Atos activities, including own activities and upstream and downstream value chain activities
• All geographical areas where the Group operates
• Covers all significant sources of emissions for Scopes 1, 2 and 3
• For Scope 3, all significant categories (including categories 1 & 2 – purchased goods and services/capital goods and category 11 – use of sold products)

Type: Absolute target (measured in MtCO2e)

Validation:

• Science-based target validated by the Science Based Targets initiative (SBTi)
• Compatible with the Paris Agreement
• Defined using the GHG Protocol and the SBTi Net-Zero Standard criteria and methodologies
• Compatible with limiting global warming to 1.5°C

Progress to date:

• 2024: 1,787,544 tCO2e (1.788 MtCO2e) – representing a -46% reduction vs. 2019 baseline
• 2023: 2,230,775 tCO2e
• 2022: 2,518,478 tCO2e
• 2021: 2,406,250 tCO2e
• 2020: 2,803,128 tCO2e
• Target end of 2025: 1,651,618 tCO2e (50% reduction)
• Remaining reduction needed: -4%

Future Target Ambition (Not Yet Validated)

Atos intends to define new emission reduction targets to be submitted to the SBTi in 2026 or as soon as possible:

Baseline year: 2025 (proposed)

Near-term target: 2030

Long-term and net-zero target: 2050 at the latest

Interim targets: May include target values for 2035, 2040 and 2045 in compliance with ESRS E1-4 34(d)

Validation: To be compatible with the Paris Agreement and in line with SBTi expectations, including sector specific guidance for the ICT sector

ISO 14001 Certification Target

Target metric: Percentage of Atos' main sites that are ISO 14001 certified or in the process of being certified

2024 progress: 92.3% (vs 88.6% in 2023)

Scope: Main office sites with more than 500 employees and Atos-owned core data centers, as well as other smaller sites for business or compliance needs

Energy consumption and mix [ESRS E1-5]

Scope and methodology

Energy data covers all Atos sites (offices and data centers) within the operational control scope. Data collection is conducted twice yearly with consistency checks. Where metered data is unavailable, energy consumption may be estimated. The reporting covers the full scope of Atos Group aligned with financial reporting boundaries.

Energy consumption by source

Energy intensity

Atos does not operate in high climate impact sectors as defined by EU regulation. Energy intensity metrics reported:

Note: The decrease in total energy consumption in 2024 reflects ongoing site optimization and the impact of site consolidation. Renewable electricity includes purchased renewable energy certificates (RECs). Data covers 100% of employees and 100% of revenue perimeter for 2024 and 98.1% for 2023.

Gross Scopes 1, 2, 3 and Total GHG emissions

Total GHG emissions (2019–2024)

Scope of consolidation: The GHG emissions cover the entire Atos Group scope of consolidation, including all activities, geographies, and upstream/downstream value chain. The baseline year is 2019. The 2019 baseline covers all Atos emissions upstream, own operations, and downstream, and did not exclude any geography, business line, or significant activity.

Methodology: GHG emissions are calculated using the GHG Protocol and emission factors from internationally recognized sources (Ademe, DEFRA, IEA). Scope 3 emissions use conversion factors for value chain estimation when actual supplier data are not available (via Ademe or EcoVadis platform). The Group uses the tool Compliance Catalyst for supplier screening.

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Scope 1: Direct GHG emissions

2024 Scope 1 emissions: Not separately disclosed in the excerpts for 2024.

Sub-breakdown (where available):

Note: The company reports emissions from cooling systems (F-Gas leaks) separately. Full Scope 1 disaggregation by stationary combustion, mobile combustion, process emissions, and fugitive emissions is not provided in the excerpts.

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Scope 2: Indirect GHG emissions from purchased energy

2024 Scope 2 emissions: Not separately disclosed in the excerpts for 2024.

Location-based vs. Market-based:

Note: The report discloses total GHG emissions on both location-based and market-based approaches but does not break out Scope 2 separately from the total in the excerpts provided. The total emissions figures include Scopes 1, 2, and 3.

Energy consumption and mix (2022–2024):

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Scope 3: Indirect GHG emissions from value chain

2024 Scope 3 emissions: Not separately disclosed by category in the excerpts for 2024. The report states that "Atos GHG emissions linked to Scope 3 represent 95.5% of total emissions in 2024" (equivalent to approximately 1.707 million tCO2eq).

Scope 3 categories covered: The near-term science-based target considers "all significant sources of emissions for Scopes 1, 2 and 3, and for Scope 3, all significant categories (including categories 1 & 2 – purchased goods and services/capital goods and category 11 – use of sold products)." The double materiality assessment identified IROs covering upstream manufacturing (category 1), purchased goods and services unrelated to products (category 1), upstream transportation (implied), business travel (category 6), and downstream transportation of sold products (category 9).

GHG Protocol categories explicitly mentioned or implied:

• Category 1: Purchased goods and services
• Category 2: Capital goods
• Category 6: Business travel
• Category 9: Downstream transportation and distribution
• Category 11: Use of sold products

Business travel emissions (2019–2024):

Note: Full disaggregation of Scope 3 by all 15 GHG Protocol categories is not provided in the excerpts. The company uses emission factors from Ademe and supplier data (via EcoVadis) for upstream value chain estimation.

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Total GHG emissions and GHG intensity

Achievement against 2025 target (absolute reduction from 2019 baseline):

• 2019 baseline: 3.303 million tCO2eq
• 2024 result: 1.788 million tCO2eq (market-based)
• Reduction achieved (2019–2024): -46%
• Target (2019–2025): -50%
• Remaining to achieve target: -4%

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Biogenic CO2 emissions

Not disclosed in the excerpts.

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Regulated emissions (e.g. EU ETS)

Not disclosed in the excerpts.

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Methodology and scope notes

• Baseline year: 2019 (3.303 million tCO2eq, market-based).
• Consolidation approach: Operational control.
• Emission factors: Ademe (France), DEFRA (UK), IEA. For Scope 3, conversion factors from Ademe or supplier-reported data via EcoVadis.
• Scope 3 estimation: Real supplier data where available; otherwise, indirect Ademe factors. The company screens suppliers using EcoVadis and Compliance Catalyst.
• Exclusions: No material exclusions noted. The 2019 baseline did not exclude any geography, business line, or significant activity.
• Location-based vs. market-based: Both methods reported for total emissions (Scopes 1+2+3). Market-based reflects renewable energy procurement.
• GHG intensity denominator: Net revenue (€ million).
• Energy data: Covers Scopes 1 and 2. Does not operate in high climate impact sectors per EU regulation.
• Scope 3 coverage: Represents 95.5% of total emissions in 2024. Significant categories (1, 2, 6, 9, 11) included in the SBTi near-term target.
• Data quality: The report notes "sources of uncertainty, approximations, interpretations and assumptions" relating to emission factors, conversion factors, material inflows, and electronic waste. High uncertainty acknowledged for Scope 3 upstream value chain.

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Additional context

The report states: "In order to provide information that is as transparent as possible, various sources of uncertainty, approximations, interpretations and assumptions were made by the Group in preparing the 'data points'. They notably relate to emission factors and conversion factors (as described in sections 5.1.1.1.1. and 5.1.2.2.5), to material inflows (as described in section 5.1.2.3.2.4) and to electronic waste generated (as described in section 5.1.2.3.3.4.). Further information concerning approximations, interpretations and assumptions are documented in this report, particularly in section 5.1.1.1.2."

The company is unable to report anticipated financial effects or resilience analysis under ESRS E1 due to phase-in provisions (ESRS 2 SBM-3 §48(e) and E1-9 are not yet reported).

Policies related to pollution

Atos does not disclose a specific policy dedicated to pollution in the provided excerpts. The company's sustainability disclosures focus primarily on climate change (E1), circular economy and waste (E5), but do not contain explicit E2-1 (pollution-related) policy disclosures.

The excerpts reference the following environmental policies, but they are explicitly scoped to other ESRS topics:

Environmental Policy

The Atos Group Environmental Policy is mentioned in multiple sections (5.1.2.2.3.2, 5.1.2.3.3.1, and 5.2.4.3) but is described as covering:

• Climate change mitigation and adaptation (ESRS E1-2)
• Waste management (ESRS E5-1)
• Core principles including "prevent pollution and protect the environment by adopting appropriate procedures"

Scope:

• Applies to all Atos entities and operations, all office sites, and data centers regardless of location
• Covers the full scope of the entire Atos organization (100%) including its suppliers and subcontractors

Governance:

• Validated by the Senior Executive Vice President & Head of Partnerships & Alliances
• Owned by the Head of Global Environment Program

Key content:

• Acknowledges as core principles to "locally identify specific challenges" including waste and "prevent pollution and protect the environment by adopting appropriate procedures"
• Written in accordance with Atos Environmental Management System

Public availability:

• A summary is publicly available on the Atos CSR page of the website
• The full comprehensive Environmental Policy is shared with external stakeholders upon request

Implementation monitoring:

• Internal working documents serve as basis, including Book of Environmental Guidelines per Challenge applicable to ISO 14001 certified sites

While the Environmental Policy includes a principle to "prevent pollution," the excerpts do not provide detailed disclosure of pollution-specific policies, targets, or action plans as would be expected under ESRS E2-1. The company's environmental disclosures are primarily structured around climate change (E1) and waste/circular economy (E5) topics.

Substances of concern and substances of very high concern

Overview

Atos Group's manufacturing activities are primarily conducted by its Big Data and Security (BDS) Business Line, which produces supercomputers, servers, computing solutions, cybersecurity products (encryption solutions), and critical and embedded electronic and communication systems. The key manufacturing site is located in Angers, France, with some production in Aix-en-Provence.

Materials used in manufacturing

During 2024, BDS operations at the Angers plant used 1,421 tonnes of products and technical materials for manufacturing (845 tonnes with real data, 576 tonnes estimated). These materials include a range of substances, some of which are substances of concern.

The report identifies substances used in the manufacturing process, including:

Substances listed:

• Acids: Adipic acid, Azelaic acid, Benzoic acid, Citric acid, Dodecanoic acid, Formic acid, Hexanoic acid, Octadecanoic acid, Sebacic acid, Tartaric acid
• Metals and metal compounds: Aluminium oxide, Bismuth oxychloride, Bronze powder, Copper (Cu), Iron oxide, Lithium Manganese Oxide, Manganese dioxide, Silver (Ag), Tetramanganese tetraoxide, Vanadium, Zinc borate, Zinc compounds
• Organic compounds: Bisphenol A, Butanone, Dibutyl Sebacate, Epoxy resin, Hydrocarbons, Polyethylene glycol, Tripropylene glycol Diacrylate
• Other materials: Talc (containing no asbestiform fibers), Tetrahydromethylphthalic anhydride, Vanadium Phosphorus White

Regulatory compliance

The BDS activity complies with international regulations applicable to its manufacturing activities, including:

• European directives: Conformité Européenne (CE) standard
• REACH Directive: Registration, Evaluation, Authorization and Restriction of Chemicals, on eliminating pollutants
• RoHS Directive: Restriction of Hazardous Substances on eliminating hazardous substances
• Biocidal Products Regulation (BPR)
• ASHRAE standards: American Society of Heating, Refrigerating, and Air-Conditioning Engineers standards on maximum temperature and humidity for server functionality
• UKCA marking: United Kingdom Conformity Assessed marking (replaced CE marking on UK market since January 2023)

REACH and SCIP database compliance

From January 2021, in accordance with Article 33 of REACH regulations, companies are responsible for collecting information on the properties and uses of substances they manufacture or import above one ton per year. They must also assess the hazards and potential risks presented by the substance.

The reporting of substances of concern in the downstream supply chain is based on the list of declarable substances provided by the European Chemicals Agency (ECHA) and implemented in BOM (Bill of Material) check or Silicon Expert tools. This information is communicated to ECHA through a registration dossier (SCIP declaration in the ECHA SCIP database according to the EU waste framework directive) containing hazard information and where relevant an assessment of the risks that the use of the substance may pose and how these risks should be controlled. Atos complies with these regulations.

Conflict minerals

Since early 2013, Atos Group has embarked on a consultation process with its major suppliers on the origin of the raw materials they use, given the issue of "conflict minerals" and with the intention to prevent any use of these within the manufacturing process of BDS computers.

Supplier management

New partners are asked to disclose whether they have fundamental safeguarding practices in place regarding the protection of human rights within their own operations and supply chains during the onboarding process. This includes addressing health and safety risks related to raw material extraction or bad management of substances of concern.

The report notes: "Exposure of supply chain workers to health/safety risks related to raw material extraction or bad management of substances of concern" as a negative impact (ID 32) in the materiality assessment.

Packaging and plastic reduction

The BDS supply chain team tackles the reduction in the use of plastics in Atos packaging. Currently, Atos is investigating several solutions to reduce plastic usage in packaging. BDS clients are also offered services where packaging waste is collected upon delivery.

End-of-life management

Atos Group, as a producer, is responsible for the end-of-life of its products in accordance with the Directive 2008/98 (as modified by the Directive 2018/851) and the Directive 2012/19/EU (Waste Electrical and Electronic Equipment Directive – WEEE). This management is done at country level, according to local regulations.

In France, BDS supercomputer activity has joined, since 2013, a collective eco-organism certified by the French Ministry of the Environment (EcoLogic) to optimize the end of life of supercomputers sold to customers.

Data limitations

The report notes that data on materials used is only available for the Angers production site. Products manufactured in the Aix-en-Provence plant are not included in the calculation because this topic was not assessed as material until the double materiality conducted in 2024. The inclusion of data related to these products will be part of the action plan for 2025.

For 41% of products delivered to the Angers plant, no weight data was available from manufacturers or their transport providers; weight was estimated using an euros-per-kg ratio calculated from products where weight data was available.

Note: While the report provides extensive information on substances used in manufacturing and REACH compliance processes, it does not provide quantitative data on:

• Total tonnes of substances of concern (SoC) generated, used or procured
• Total tonnes of substances of very high concern (SVHC)
• Breakdown by hazard class (e.g. CMR, endocrine disruptor, PBT, vPvB)
• Amounts leaving facilities as emissions, products, or services

The disclosure focuses on regulatory compliance processes and the overall weight of input materials rather than specific SoC/SVHC tonnages.

Water consumption

Water not identified as material

Water and marine resources were not identified as material topics in the 2024 double materiality analysis. However, Atos monitors water usage in its sites and strives for efficient consumption.

Total water consumption

In 2024, using current Atos UK data based on metered sanitary consumption per employee, and consistent with estimations based on global water spend at the Atos Group, Atos' water consumption worldwide was estimated at around 495,565 m³ for all employees.

Water consumption by activity type

Offices: In offices, Atos' water consumption is that of the tertiary sector. Information and recommendations are regularly sent to employees to reduce water consumption. In the ISO 14001 certified data centers and office sites, data related to the volume of water is collected.

Product manufacturing and data centers:

• Big Data and Security: The main consumption of water is by upstream suppliers for the manufacture of electronic cards and processors. By design, the servers are optimized for high temperature closed loop liquid cooling which optimizes the WUE (Water Usage Effectiveness) and therefore minimizes water consumption in the testing phases on the servers, whether in R&D for prototypes or at the Angers factory for production.

• Data centers: Water is necessary for cooling, but typically is contained in a closed loop sealed circuit. During warm weather when humidity is low, water spray can also be used to support air conditioners as the resulting evaporation reduces their energy consumption.

Methodology note

This figure is calculated on the basis of estimates which have been updated in 2024.

Actions and resources related to biodiversity

Strategic partnership with WWF (2023)

Description: 3-year strategic partnership to leverage technology to support biodiversity conservation and encourage businesses to decarbonize.

Time horizon: 3 years (started 2023)

Actions under the partnership:

1. Development of responsible IT solutions for WWF and its partners

   • Scope: Downstream value chain (support to WWF)
   • Further details referenced in section 2.2.4 (not provided in excerpt)

2. Nature Impact project support

   • Description: First fund based on PES (Payments for Ecosystem Services) combining biodiversity protection and carbon sequestration in French forests
   • Scope: Own operations/support activity
   • Geographic focus: French forests
   • Focus areas: Three main measures with positive impact on biodiversity and carbon sequestration
   • Governance: Based on strong governance, transparency and selected partners and beneficiaries

3. Posidonia project support

   • Description: Aims to completely halt degradation of Posidonia meadow caused by anchoring of pleasure craft in the French Mediterranean
   • Scope: External conservation project
   • Geographic focus: French Mediterranean
   • Approach: Engaging yachtsmen through targeted communication and engagement techniques; influencing public decision-makers to set up dedicated anchorage areas

Other biodiversity-positive actions

Indirect biodiversity benefits through:

• Action plans on emissions, energy consumption, and travel
• Diffusion of environmentally friendly practices
• ISO 14001 certification
• Environmental Management System
• Continuous optimization program of sites to minimize land surface use

Note: The company states it does not produce any biogenic CO₂ emissions and that several local initiatives have been taken up worldwide (specific initiatives not detailed in excerpt).

Impact metrics related to biodiversity and ecosystems change

Materiality Assessment Outcome

Atos conducted a double materiality assessment for ESRS E4 - Biodiversity and ecosystems. The assessment covered sub-topics including land use, fresh water use, sea use change, and impact of local species and ecosystems.

The stakeholders' consultation included interviews with representatives of a worldwide NGO expert in biodiversity.

Key findings:

• No dependencies to biodiversity and ecosystems and their services were identified during the double materiality analysis
• The double materiality analysis did not conclude that it is necessary to implement biodiversity mitigation measures
• ESRS E4: Biodiversity and ecosystems was excluded from material topics as it scored below the materiality thresholds (impact materiality threshold: 1.5/3; financial materiality threshold: 2/3)

Water Consumption (Related to Biodiversity Impacts)

Water consumption worldwide was estimated at around 495,565 m³ for all employees.

Waste Generation (Indirect Biodiversity Impact)

Based on ADEME available estimations of waste per employee in the tertiary sector (120 to 140 kilograms of tertiary waste per employee), Atos' global office waste worldwide was estimated at around 10,131 tons for all employees. An average of 130 kilograms per employee was used for Atos' calculation.

Biodiversity Conservation Initiatives

In 2023, Atos and WWF entered a 3-year strategic partnership to leverage technology to support biodiversity conservation and encourage businesses to decarbonize.

As part of this partnership, Atos supports two WWF on-site biodiversity projects:

1. "Nature Impact" - The first fund based on PES (Payments for Ecosystem Services) that combines biodiversity protection and carbon sequestration in French forests

2. "Posidonia" - Aims to completely halt the degradation of the Posidonia meadow caused by anchoring of pleasure craft in the French Mediterranean

Statement on Land Use

Atos, because of its activities and because of the continuous optimization program of its sites, contributes as little as possible to the use of land surfaces. However, no quantified land use footprint is disclosed.

ESRS E5-4 Resource Inflows

Context

Atos Group's material resource inflows are found in the Big Data and Security (BDS) service line where products are designed and manufactured. The BDS Research & Development teams, in conjunction with Manufacturing teams, have set up a process for collecting and analysing inputs for their entire product range, including packaging and components assembled, using tools that guarantee the traceability of raw materials and substances used in BDS equipment.

The Full Material Declaration (FMD) is produced on the basis of the Bill of Material (BOM), which represents the specific configuration of each manufactured product. The FMD provides a list of components and details substances traced as part of REACH compliance and identified raw materials of components incorporated in equipment.

Key products coming out of Atos' manufacturing process are supercomputers, servers, computing solutions, cybersecurity products (encryption solutions) and critical and embedded electronic and communication systems. These products are manufactured in two plants located in Angers and Aix-en-Provence, France.

Methodology

This quantitative datapoint (31.a) is calculated at Group level. To calculate the value, Atos Group has considered the weight of products purchased by BDS business line and delivered at its plant in Angers (products to be used in the manufacturing process of BDS products).

Data sources:

• 59% of products are transported by Atos Group's transport providers, which communicate data about the weight of products delivered
• 41% is delivered by the products manufacturers or their transport providers. For these products no weight data is available at the date of issuance; consequently, estimation was used to calculate the weight

To calculate the total weight:

1. Used data provided by transport providers (monetary sum of products purchased and weight of these products) to calculate a euros per kg ratio
2. This ratio was then applied to calculate the weight of products purchased for which weight data is not available

Double counting is avoided by differentiating two types of products: transported by Atos' providers or transported by other providers (manufacturers or their providers) and splitting the amounts purchased based on these categories.

Reported Data

Note: The part of uncertainty corresponds to the estimated portion (41% / 576 tonnes).

Unavailable Metrics

At the time of preparing its Sustainability Statement, due to the recent identification of resource use and circular economy as a material topic for Atos, the group is not yet able to disclose the following metrics:

• ESRS E5 – 31c: Weight in both absolute value and percentage, of secondary reused or recycled components, secondary intermediary products and secondary materials used to manufacture the undertaking's products and services (including packaging)
• ESRS E5 – 36c: Rates of recyclable content in products and packaging

Further investigations are in progress with relevant BDS teams to assess how such datapoints could be calculated.

Resource outflows

Product Durability

BDS-manufactured products are designed to be maintained over a period of five years, but the industry average is not yet available. Nevertheless, the products are still usable after the maintenance duration and Atos Group can investigate on a case-by-case basis the prolongation of maintenance. Change in technology and unavailability of spare parts are the main obstacle to longer durability of the BDS products.

Repairability

To improve reparability, and consequently extend durability of the products:

• BDS' design includes:

  • FRU (Field Replacement Unit), namely subparts allowing a simple and fast repair,
  • "Plug & play" approach, allowing changing critical spare parts and redundant components, to maintain production, even if there is a breakdown,
  • standardization of the components, to improve reparability and availability of spare parts;

• BDS' Angers manufacturing site includes:

  • a repair center, used to repair returned parts in order to restore them to new condition for marketing,
  • reuses of packaging of racks suppliers to deliver Atos racks.

The metric ESRS E5 – 36b "Repairability products, using an established rating system, where possible" is not applicable to Atos Group due to the complex nature of BDS products that are not considered in existing repairability rating system.

Recyclability and Recycled Content

Not disclosed. At the time of preparing its Sustainability Statement, Atos is not yet able to disclose:

• ESRS E5 – 31c – Weight in both absolute value and percentage, of secondary reused or recycled components, secondary intermediary products and secondary materials used to manufacture the undertaking's products and services (including packaging);
• ESRS E5 – 36c Rates of recyclable content in products and packaging.

Further investigations are in progress with relevant BDS teams to assess how such datapoint could be calculated.

End of Life Management

Atos Group, as a producer, is responsible of the end-of life of its products in accordance with the Directive 2008/98 (as modified by the Directive 2018/851) and the Directive 2012/19/EU (Waste Electrical and Electronic Equipment Directive – WEEE). This management is done at country level, according to local regulations.

In France, BDS supercomputer activity has joined, since 2013, a collective eco-organism certified by the French Ministry of the Environment (EcoLogic) to optimize the end of life of supercomputers sold to customers. BDS also provides guidance to its clients to ease sorting of products and offers the possibility to return unusable sold products to Angers production site to manage their end-of life.

To optimize the use of raw material at the end of life of its products, BDS has implemented the following actions:

• offer of spare parts service managements, in its Security and Repair Center, for all servers sold;
• resale or reuse of old spare parts; and
• reuse of supercomputers to build little clusters.

Waste

Material IRO

Electronic waste generated by the Group's own operations (e.g., in offices, data centers) – Impact Negative – Own operations

Waste Categories

Atos Group waste is composed of two main categories:

• e-waste;
• other waste, that are common to tertiary companies, such as paper, plastic or food.

Atos Group operates in the ICT sector and mainly needs IT equipment to perform its activities. In this respect, the 2024 double materiality analysis defined e-waste as the only material topic related to waste.

E-waste are split in 2 categories:

• batteries and accumulators (any source of electrical energy generated by direct conversion of chemical energy and consisting of one or more primary battery cells (non-rechargeable) or consisting of one or more secondary battery cells (rechargeable));
• other types of e-waste (including computers, screens, wires, phones, USB keys etc.).

Total Electronic Waste Generated

Methodology

This quantitative datapoint "Electronic waste generated by the Group's own operations (e.g., in offices, data centers)" is calculated at Group level.

For this methodology, Atos Group considers its 2 types of sites:

• offices that generate regular tertiary e-wastes (PCs, cables, batteries, printers…);
• data centers that generate specific e-waste (old servers, electronic components, cables…).

ISO 14001 certified sites in Multi-Site Certification (MSC) cover a large part of the Atos employees and are based on Atos main sites. In 2024, ISO 14001 certified sites in the MSC represented about 60% of headcounts of the total offices of the Group and 35% of the space used (m²) in all data centers where we operate in the Group. Eventually, 49% of total e-waste's weight comes from real data reported on ISO 14001 certified sites.

To estimate the electronic waste generated by the Group's own operations, Atos extrapolates the real data of ISO 14001 certified sites in MSC to the Group scale based on (i) headcount for Office sites and on (ii) space used in m² for Data center sites.

Unavailable Metrics

At the time of preparing its Sustainability Statement, due to the recent identification of resource use and circular economy as a material topic for Atos, the group is not yet able to disclose the following metrics:

• 37.b: total amount by weight diverted from disposal, with a breakdown between hazardous waste and non-hazardous waste and a breakdown by the following recovery operation types: preparation for reuse, recycling and other recovery operations;
• 37.c: amount by weight directed to disposal by waste treatment type and the total amount summing all three types (incineration, landfill and other disposal operations), with a breakdown between hazardous waste and non-hazardous waste;
• 37.d: total amount and percentage of non-recycled waste.

Further investigations are in progress with relevant Atos Group teams to assess how such metrics could be calculated.

Waste Management Actions

Due to the recent identification of "Electronic waste generated by the Group's own operations (e.g., in offices, data centers)" as a material topic for Atos, the Atos Group has not yet defined a consolidated action plan, supported by financial resources, to manage the related IROs.

Nevertheless, Atos Group has implemented several actions that contribute to the management of this material IRO:

Concerning the e-waste generated by Atos employees in offices:

• Electric and electronic equipment owned by Atos: the collection of electronic devices that reach their end of life is done at site level. The IT and Logistics & Housing departments work together to manage the e-waste generated on site. Depending on the site context, they ensure coordination with the landlord or with the waste collection supplier to make sure e-waste and other types of waste are collected in an efficient and safe way. Agreements are entered at local level with waste managers and/or eco-organisms to ensure proper management of these types of wastes. In France, e-waste is collected through the collection scheme defined by the EU in the WEEE Directive, by waste suppliers contracting with Ecologic, one of the French State's approved eco-organisms.

• Electric and electronic equipment leased by Atos: As per EU e-waste definition and in compliance with local laws, leased goods and assets are not part of Atos' waste and their suppliers remain responsible for the management of their end of life. Atos Group's providers commit to manage this end of life according to local regulations by signing the Business Partners' commitment in the Integrity Charter defined by Atos.

Concerning the electronic equipment located in its data center (servers and related electronic equipment): Similar processes are applied by global data center practices. Atos Data Centers manage their waste following local regulations. Data Center sites have more types of waste than offices, including chemicals and fuels that are in use in the systems operating the sites.

Additionally, ISO 14001 sites certified, covering 92.3% of Atos main sites (above 500 employees) and core data centers (co-locations excluded) in 2024, are regularly audited externally on their waste management in compliance with local regulatory obligations.

Manufacturing Site (Angers)

Since 2019, BDS plant in Angers sorts waste by material to reduce residual production waste as much as possible and has set an ambition of 85% of production waste recovery in the production site considering both recycling and energy recovery.

Policies related to own workforce

Atos has implemented the following policies to promote the physical and mental safety of its workforce, support skills development and personal growth within the organization, and ensure an inclusive, diverse, and safe working environment:

Atos Human Rights Policy Statement

Scope: All entities of the group; covers employees, customers, partners, and across the supply chain

Governance: Chaired by the Senior Executive Vice President and the Chief Human Resources Officer. Initially published in 2018 and updated regularly since.

Key content:

• Commitment to respect human rights in accordance with internationally accepted standards:
  • Principles of the Universal Declaration of Human Rights of 1948
  • International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work
  • UN Human Trafficking Protocol
  • UN Slavery Convention
  • UN Global Compact
  • UN Guiding Principles on Business and Human Rights
  • UN Convention on the Rights of Persons with Disabilities
• Preventing any infringements on internationally recognized human rights
• Managers required to lead by example and ensure monitoring and alert systems are set up to detect violations of Human Rights principles

Public availability: Atos Human Rights Policy Statement (atos-human-rights-policy-statement.pdf)

International frameworks: Aligned with the UN Guiding Principles on Business and Human Rights, ILO Declaration, OECD Guidelines for Multinational Enterprises, UN Global Compact, International Bill of Human Rights, Declaration of International Labor Organization on fundamental principles and rights at work

Atos Code of Ethics

Scope: All employees across the Company's own operations in all geographies

Governance: Validated by the Group Executive Committee and the Board of Directors of Atos, chaired by the Chief Executive Officer (CEO) & Chairman of the Board. Initially adopted in 2003 and regularly reviewed since.

Key content:

• Sets Atos Human Rights commitments which every employee is expected to apply and respect
• Rejects human trafficking and all forms of human slavery, including forced, compulsory and child labour
• Abides by all applicable wage and working hours laws and regulations
• Commitment to safe workplace with safe and hygienic conditions for all employees
• Support to promote well-being at work
• Zero tolerance for harassment, bullying or discrimination in the workplace
• Commitment to maintain work environment where everyone is treated with dignity and respect
• Mandatory training on the Code of Ethics for all employees, to be retaken yearly

Public availability: Available to all employees through the Group SharePoint site; communicated via email, newsletters, and events. Attached to employment contracts.

International frameworks: Aligns with UN Global Compact principles on human rights, labor, environment and anti-corruption

Monitoring: Managers required to ensure monitoring and alert system are set up. KPIs established for employees' training. Annual mandatory training for all employees.

Atos Global Occupational Health and Safety Policy

Key content:

• Covers all internal/external and human/natural threats which can impact Atos staffs, subcontractors, clients and visitors anytime and anywhere
• Ensuring safe and hygienic conditions for all employees
• Offering support to promote well-being at work

Monitoring: Certification according to ISO 45001:2023

Atos Dignity at Work and Prevention of Sexual Harassment Policy

Scope: All employees across the Company's own operations in all geographies

Key content:

• Not tolerating any form of harassment, bullying or discrimination in the workplace
• Commitment to maintain a work environment where everyone is treated with dignity and respect

Public availability: Available to all employees through the Group SharePoint site

Atos Learning and Development Policy

Scope: All employees across the Company's own operations in all geographies

Key content: Support skills development and personal growth within the organization

Public availability: Available to all employees through the Group SharePoint site

Atos DE&I Policy

Scope: All employees across the Company's own operations in all geographies

Key content: Ensure an inclusive, diverse, and safe working environment

Public availability: Available to all employees through the Group SharePoint site

Atos Group Accessibility and Digital Inclusion Policy

Scope: All employees across the Company's own operations in all geographies

Key content: Ensure an inclusive, diverse, and safe working environment

Public availability: Available to all employees through the Group SharePoint site

Policy development and governance

All policies have been set by considering the interests of Atos employees through regular feedback sessions, surveys and focus groups to gather comprehensive insights into their needs and expectations. These policies have been approved by the Head of Function and the Function Owner. All employees across the Company's own operations in all geographies are covered by the policies. These are made available to all employees through the Group SharePoint site, and communicated to all employees via various channels, including email, newsletters, and events.

Remediation procedures

Atos employees can make their concerns and needs known:

1. Through their Line Managers, or with the functions they feel are best placed to take action to remedy the problem raised
2. Through the Group Ethics Alert System

Employees and third parties can report any matter of concern in relation to potential breaches of the Code of Ethics, or applicable laws or regulations.

Alerts can be raised through:

1. The Atos Integrity Line (web-based platform developed by EQS)
2. By emails through dedicated mailboxes (global and per RBUs)
3. By any means as preferred by the whistleblower

Anonymous alerts are considered, unless prohibited by local laws. All admissible alerts are reviewed by an Investigation Team appointed on a case-by-case basis, composed of at least two persons from various functions internally (Compliance, Internal Audit, Legal Affairs or Human Resources) or externally if needed.

Vigilance Plan

Since 2021, the Group has improved the measures adopted as part of its Vigilance plan, including:

• Risk mapping
• Evaluation procedures
• Mitigation actions
• Alert mechanisms
• Monitoring systems

The measures are implemented to cover Atos' own activities and its supply chain.

Taking action on material impacts on own workforce

Diversity, Equity & Inclusion (DE&I)

Action name: First Atos Group DE&I Policy

Scope: Own operations (all employees across 68 countries)

Time horizon: Launched H2 2024 (short-term implementation ongoing)

Action details:

• Both business Lines Tech Foundations and Eviden worked in collaboration to launch the first Atos Group DE&I Policy in H2 2024
• The Group considered feedback from employees, including extensive data from the Great Place to Work employee survey conducted in Q4 2022
• Reviewed actions, internal data, and external benchmarks
• Developed revised DE&I global framework and ambitions launched beginning of H2 2023
• Purpose: establish a consistent framework that guides Atos' approach to fostering diversity, equity, and inclusion throughout the organization

Key elements:

• Diversity: Recognizing and valuing individual differences including race, gender, age, disability, sexual orientation, religion, and background; building a workforce that reflects customer and community diversity
• Equity: Ensuring fair treatment, opportunities, and outcomes for all individuals; identifying and removing barriers; implementing policies and practices that promote fairness
• Inclusion: Creating an environment where all individuals feel valued and can contribute

Expected outcomes:

• Workplace where all employees can thrive
• Differences viewed as strengths that drive innovation and growth
• Support individuals in being their authentic selves and achieving full potential

Resources allocated: Not quantified

Link to policy: Links to Zero-tolerance policy for discrimination outlined in the Group Code of Ethics

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Accessibility Initiative

Action details:

• Adhering to relevant accessibility standards, guidelines, and regulations
• Implementing a unified governance structure to streamline and enhance accessibility efforts across the organization
• Investing in building skills and role-based trainings to reinforce accessibility competencies within the organization to deliver positive impact on own workforce
• Accessibility skills provide workforce with business relevant skills supporting career growth
• Ensuring that suppliers comply with accessibility requirements

Resources allocated: Not quantified (described as "investing in" but no amounts given)

Expected outcomes:

• Enhanced accessibility competencies
• Positive impact on own workforce
• Career growth support through business relevant skills

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Well-being and Work-Life Balance Programs

Scope: Own operations (all Atos employees across all geographies)

Action details:

• Flexible working time arrangements including remote and hybrid setups
• Support for remote work includes webinars on safety and ergonomics
• Disconnection initiatives
• Virtual Welcome Days for new employees
• Flexible work hours
• Working from home arrangements
• Part-time options
• Training opportunities
• Notice periods, paid time off, vacation allowances
• Support for parental leave and caregiving responsibilities

Resources allocated: Not quantified

Link to policy: Links to Code of Ethics value of well-being at work and Dignity at Work and Harassment Policy

Expected outcomes:

• Improve employee satisfaction
• Support long-term employee retention
• Address psychosocial risks
• Create supportive and productive work environment

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Dignity at Work and Harassment Prevention

Action name: Implementation of Dignity at Work and Harassment Policy

Scope: Own operations (all Atos employees, HR teams, and managers across all countries)

Action details:

• Provides guidance to Atos HR teams, employees and managers in handling matters related to dignity at work and harassment
• Describes standard procedure in Atos countries to be adapted according to local laws/procedures
• Protects employees' interests and ensures dignity at work
• Upholds employee's right to protection against harassment
• Actively promotes a working environment that raises awareness and deters acts of harassment

Specific actions:

• Maintain proactive program to educate all employees about the definition of harassment and/or bullying and procedures for redress
• Undertake workshops or training programs at regular intervals for sensitizing employees
• Run lessons learnt activities to check if policy and procedures are appropriate
• Take corrective actions and/or disciplinary sanctions and/or legal actions
• Conduct investigations and appropriate action based on findings on allegations of sexual harassment, subject to local regulations

Resources allocated: Not quantified

Link to policy: Links to Code of Ethics, UN Global Compact commitment, ILO Declaration on Fundamental Principles and Rights at Work, Universal Declaration of Human Rights

Expected outcomes:

• Safe environment free from all kinds of harassment and/or bullying
• Increased awareness of harassment prevention
• Support for employees who detect and report harassment

Characteristics of the undertaking's employees

78,100 employees working in 68 countries representing 137 nationalities

Employee evolution

Breakdown by Regional Business Unit

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

Disclosure Summary

Atos provides limited information on non-employee workers in its own workforce. The company defines its workforce scope primarily in terms of legal employees (permanent and temporary staff under employment contracts) but excludes certain categories from headcount calculations.

Definitions and Scope

According to the company's glossary and headcount methodology (Section 5.1.3.1.4.3):

Included in headcount:

• Permanent and temporary staff (full-time and part-time)
• Long sickness or long absence
• Long sabbatical
• Parental leave
• Employees on maternity leave

Excluded from headcount:

• Subcontractors
• Interims (agency workers)
• Apprentices
• Interns

The headcount count refers to legal staff at the end of December 2024.

Non-Employee Worker Categories

The company recognizes the following non-employee categories in its operational definitions:

Subcontractors: External third-party suppliers. Outsourced activities (e.g. printing or call center activities) and fixed price subcontracting are excluded from the recorded number of subcontractors or interims.

Interims: Staff from an agency for temporary personnel. Interims are usually used to cover seasonal peaks or for situations requiring staff for a short period of time.

Apprentices and Interns: Mentioned as excluded from legal staff counts.

Quantitative Data

No quantitative metrics are disclosed for the number of non-employee workers (contractors, agency workers, self-employed) in Atos's own workforce. The company does not report:

• Total number of non-employee workers
• Breakdown by type (contractor, agency, self-employed)
• FTE vs headcount methodology for non-employees
• Multi-year comparisons

Methodology Notes

The company defines FTE (Full-time equivalent staff) as the total number of staff calculated using information from time sheets on the basis of working time divided by standard contractual workable time per employee. For subcontractors and interim staff, potential workable hours are based on the number of hours billed by the supplier to Atos.

The company distinguishes between Direct Staff (includes permanent staff and subcontractors whose work is billable to a third party) and Indirect staff (includes permanent staff or subcontractors who are not billable to clients).

However, no actual numbers for non-employee workers are disclosed in the sustainability statement.

Collective bargaining coverage and social dialogue

Collective bargaining coverage

In 2024, 33% of Atos employees were covered by collective bargaining agreements.

Multi-year trend:

Scope exclusions: The collective bargaining agreements exclude Algeria, Burkina Faso, Egypt, Gabon, Israel, Ivory Coast, Japan, Kingdom of Saudi Arabia, Korea, Lebanon, Madagascar, Malaysia, Mali, Norway, Belgium, Luxembourg, Bulgaria, Slovakia, Qatar, Senegal, Singapore, South Africa, Brazil, Mexico, Guatemala, Taiwan, Thailand, Togo, Tunisia and United Arab Emirates.

Social dialogue arrangements

European level: Societas Europaea Council (SEC)

The SEC is a forum between Atos and its employee representatives at the European level, enabling employees through their elected or designated representatives to express their views prior to the implementation of significant decisions affecting the Group.

The SEC has a Select Committee consisting of 6 members, including the SEC Chairperson, who is selected by the SEC. This Select Committee represents the SEC in communications with management.

Communication and social dialogue between Atos management and the SEC occur both physically and remotely at least twice per calendar year or when exceptional circumstances arise that may significantly affect employees' interests.

Meetings and communication sessions with the Atos SEC are attended by dedicated Atos management representatives, such as the Group CHRO, Group Social Dialog Lead, and respective area experts. The CEO participates in at least one meeting per calendar year, and the CFO participates each quarter to present the Group's financial results.

2024 SEC engagement activities:

• Information and consultation were conducted on a sell project, which was part of the Group's strategy to dispose of assets for refinancing
• A consultation was held with representatives from the French government to provide the SEC with insights on the impact of the refinancing project
• Consultations on digital transformation for workforce management tooling; a subcommittee was established to work closely with the project team

Local level social dialogue

Beyond discussions with the SEC on European and multinational issues, regular information and/or consultations take place, where relevant, with local employee representatives in work councils and/or unions. These information and/or consultation discussions are implemented at the local level in every country impacted by a new project.

Formal joint management-worker health and safety committees typically operate at country level and formal local agreements with trade unions typically cover health and safety topics.

At a local level, Atos employees can freely contact their representatives using the usual communication channels of the Company. Atos Employees have access to dedicated SharePoint spaces where all agreements and minutes from local meetings are consistently accessible.

Works council representation

Mandy Metten was Chairman of the works council of Atos from 2010 to 2015. She also served as the Dutch delegate on Atos Societas Europaea Council (SEC) from 2012 to January 2024 and was a member of the Board Participating Committee (2017-January 2024).

Operational responsibility

The operational responsibility for ensuring that social dialogue is conducted effectively, and for informing the Group's approach or strategy, falls under the purview of the Group CHRO.

Alignment with international standards

Atos fully complies with international labor standards by following the principles of the International Labor Organization Conventions. This adherence is part of its commitment to the United Nations Global Compact, which states as principle 3 that business should uphold the freedom of association and the effective recognition of the right to collective bargaining.

Diversity metrics

Board of Directors composition

87.5% Independent Directors, 62.5% of women, 6 different nationalities, 61 years average age

Adequate wages

Materiality assessment

Atos has assessed ESRS S1-10 (Adequate wages) as not material to the organization.

Benchmark used

Atos states it is committed to paying a living wage, as referenced in the supplier assessment questions: "Is your company committed to pay a living wage covering its entire workforce?"

However, the actual wage policy is based on minimum wage compliance:

• "Atos is operating in 68 geographies and 91.3% of these countries have minimum wages dictated by law: where a minimum wage is dictated by law, Atos pays more than this level of wage."

• "The organization regularly monitors salaries to ensure compliance with all local standards."

• "Deviations from the median are specifically analyzed and evaluated and – if necessary – adjusted to comply with local minimum wages."

In the UK specifically, Atos is a "Real Living Wage Employer" as noted in the list of commitments.

Methodology

Atos uses a compensation ratio (comp ratio) methodology where "the employee's individual income is compared with the internal or external average income of employees in the same role."

No details are provided on how a living wage is calculated globally or which living wage benchmark is applied outside the UK.

Coverage and geographic scope

No coverage percentage is disclosed for living wage assessment. The UK Real Living Wage commitment appears to be country-specific.

91.3% of the 68 geographies where Atos operates have minimum wages dictated by law.

Targets

No targets or forward-looking commitments are disclosed regarding adequate wages or living wage coverage.

Value chain

The living wage question is included in supplier assessments (QCDIMS) but no data is disclosed on supplier wage practices or coverage.

Social protection

Disclosure statement:

Atos has not identified social protection (S1-11) as a material topic in its 2024 double materiality assessment. However, the company monitors social protection coverage as part of its broader Compensation and Benefits commitment.

Coverage of social protection benefits

Atos provides social protection benefits to its employees covering major life events. The following table shows the percentage of employees covered by death benefits, disability benefits, and healthcare in 2024:

Scope: The coverage metrics are reported as of December 31, 2024. The headcount includes only internal people (permanent and temporary, full time and part time), with the following rules: included are long sickness or long absence, long sabbatical, parental leave, employees on maternity leave; excluded are subcontractors, interims, apprentices and interns.

Type of scheme

Benefits are provided through a combination of public and private schemes depending on local regulations:

• Death benefits: Provided to 97.2% of permanent employees. In Austria, Germany and Switzerland, death benefits are included in pension plans and provided in the form of pension for spouse and children. In other countries, death benefits are mainly provided in the form of lump sum payments.

• Disability benefits: Offered to nearly all permanent employees (98.1% coverage in 2024).

• Health care benefits: Coverage for permanent employees was 94% in 2024. Additional occupational medical/health benefits are rare in Germany, Austria, Switzerland and Sweden where compulsory health insurance is fairly comprehensive, so supplementary medical benefits are generally not necessary.

Collective bargaining coverage

In 2024, 33% of Atos employees were covered by collective bargaining agreements. These agreements, in alignment with local legislation, cover health and safety, social protection, working time including overtime, wages, training opportunities, notice periods, paid time off, vacation allowances, as well as support for parental leave and caregiving responsibilities.

Geographic and employee exclusions

The company notes that benefits offerings vary by geography according to local regulations. In Germany, Austria, Switzerland and Sweden, supplementary medical benefits are generally not provided as compulsory health insurance in these countries is fairly comprehensive.

Benefits are centrally managed through global group contracts in most countries, though countries determine which benefits should be offered to employees considering local market requirements and employee needs.

Persons with disabilities

Policy and governance

Atos has adopted a Global Accessibility and Digital Inclusion Policy (adopted in 2019 and reinforced in 2023) which includes integrating accessibility into internal processes relevant to own workforce, providing assistive technology and workplace adjustments for Atos employees, and embedding accessibility in business processes.

The policy is monitored through the Accessibility and Digital Inclusion corporate governance, including the Atos Global Accessibility Office, which supports building local and functional action plans to deliver accessibility compliance and support careers of under-represented groups such as persons with disabilities.

Key actions

• Respect requirements for quota of hiring employees with disabilities in countries with such quotas
• Provide workplace adjustments worldwide with low administrative burden through a global process
• Support Employee Resource Groups (ERGs): Atos Adapt network and Eviden AdaptAbility network for employees with physical or mental disabilities or health conditions
• Employees can provide feedback within a ticketing system (PISA - Platform for Internal Services in Atos)

Metrics

Employees with disabilities:

Additional metrics referenced in diversity section:

• In 2024, 43.24% of women were recruited (vs 35.71% in 2023) and 31.33% of women were identified in talents pools
• Additionally, Atos monitors the percentage of employees with disabilities to encourage inclusive hiring practice. In 2024, the percentage of employees with disabilities was 1.92% (up from 1.69% in 2023)

Methodology

The definition of disability is complied with local regulations. The number of employees with disabilities data is provided by Atos local HR teams via ACROSS system. The percentage of employees with disabilities on group level is calculated by formula: Number of employees with disabilities / Total headcount in the reporting scope.

Scope and exclusions

For legal reasons, gender diversity reporting receives high global focus. The document notes that high-profile reporting obligations exist for areas like Gender Pay Gap in countries such as the UK and France, with executives making strong commitments to develop appropriate actions to improve representation for other under-served or disadvantaged communities, where permitted and encouraged (e.g. ethnicity, disability, LGBTQ+).

The 2024 perimeter covers 93.62% of employees (per employee basis) for disability metrics.

Country-specific considerations

While not explicitly listing country exclusions, the methodology notes that "the definition of disability is complied with local regulations," indicating that reporting varies by jurisdiction based on local legal frameworks and data protection requirements.

Training and skills development metrics

In 2024, we continued to invest in the training and development of our employees, empowering them with essential skills to learn, grow and advance their careers. For a total of 400,000 professional certifications achieved in the last years, our teams completed over 106,000 certifications in 2024, with 94,000 focusing on advanced digital technologies such as AI, machine learning, cloud computing and cybersecurity.

(*) Juniors are employees aged below 30 and classified within Global Capability Model (GCM) levels 0‑3.

Health and safety metrics

Metrics Table

*Other workers are not considered in the number of fatalities reported for 2024, as the data "number of fatalities of 'other workers' working on Atos sites" is not yet available for disclosure.

Additional Health and Safety Indicators (Social Performance Section)

Coverage

The percentage of Atos workforce covered by a health and safety management system is not yet available for disclosure in the 2024 Sustainability Statement. Therefore, the Group has opted to disclose the number of sites certified with a recognized health and safety management system instead (ISO 45001:2018).

Methodology Notes

The number of recordable work-related accidents excludes minor work-related accidents that did not result in any lost workdays.

The absenteeism rate is calculated as: (Short term sicknesses Hours + Long terms sicknesses Hours) / Workable Hours. This metric excludes specific entities and countries listed in the methodology notes (AppCentrica Canada, various Cloudreach entities, multiple countries including Burkina Faso, Germany, Israel, Lebanon, Peru, Qatar, Singapore, Switzerland, Turkey, UAE, and various US entities).

Work-life balance metrics

Disclosure Statement

In accordance with the phase-in provisions of CSRD, Atos does not report on the metrics related to the percentage of employees entitled to take family-related leave. However, all Atos employees covered by collective bargaining agreements are entitled to such leave.

In 2024, 33% of Atos employees were covered by collective bargaining agreements.

Parental Leave Metrics

Absentee Rate

Tracking absentee rate enables Atos to assess the effectiveness of its wellbeing and work-life balance initiatives.

In 2024, the Group's absentee rate was 2.07%.

Collective Bargaining Coverage

Methodology Notes

Headcount definition: The headcount includes only internal people (permanent and temporary, full time and part time). Included: long sickness or long absence, long sabbatical, parental leave, employees on maternity leave. Excluded: subcontractors, interims, apprentices and interns.

Calculation basis: The quantitative datapoints are calculated in headcount at the end of December 2024.

Compensation metrics

Pay gap

In 2024, on a reporting scope covering 87% of Atos employees, the salary gap between women and men was 6.95% concerning annual basic salary, and 6.59% concerning total target remuneration.

Atos uses a specific gender pay gap metric for ensuring equality and fairness in the workplace. Within Atos organization the gender pyramid is not linear. Despite efforts to encourage promotion of women, today only 19.41% of senior positions (GCM level 7+) are held by women, where 46.44% of the junior workforce (GCM 3 and below) is female.

In order to avoid mixing 'gender representation' and 'gender pay', Atos' gender pay analysis is calculated per function and GCM level and then consolidated by weighted average headcount. The formula used to calculate the gender pay gap is therefore similar to the methodology required by ESRS, with the exception that annual salary is used instead of hourly pay and that the ratio is calculated by function rather than based on all male and female employees.

Note: The specific metric used by Atos is not the unadjusted gender pay gap as required by ESRS S1-16. An unadjusted gender pay gap, as required by ESRS S1-16, would be irrelevant in the context of Atos given the non-linear gender pyramid. The specific metric used by Atos provides an accurate function-based vision that is a more powerful tool to foster gender equality.

Remuneration ratio

Not disclosed.

Methodology

The gender pay gap calculation excludes Germany, employees who do not identify as male or female, and those who are not assigned a GCM level (an internal job category classification based on the company's Global Capability Model).

The reporting scope covers 87% of Atos employees and 95% are based in France, constituting a coherent and legitimate representative perimeter.

The ESRS S1-16 unadjusted gender pay gap is listed as 'Not material for Atos' in the ESRS cross-reference table (section 5.2.2), though a gender pay gap metric is disclosed.

Incidents, complaints and severe human rights impacts

Disclosure Status

Atos states that S1-17 is not material for Atos (as indicated in the ESRS disclosure table on page 266).

Complaints and Alert Mechanisms

Atos is currently unable to provide details of alerts raised internally by its workforce or those issued externally or anonymously. Therefore, it cannot report on the number of complaints filed through channels for its own workforce at this time. However, the Group anticipates being able to provide such information in 2025.

The Group has established an alert system contained in the Code of Ethics, with all alerts directed to Human Resources and/or Compliance as relevant. Compliance Officers report half-yearly to the Group Compliance Team statistics and key data on alerts raised and investigated locally. The Group Compliance Team reports twice a year to the Audit Committee.

Incidents of Discrimination and Human Rights Impacts

No quantitative data on:

• Number of incidents of discrimination or harassment
• Number of severe human rights impacts
• Fines, penalties, or compensation related to incidents
• Status of complaints (open/resolved/under investigation)

is disclosed for 2024 or prior years.

Protection Against Retaliation

As stated in the Atos Code of Ethics, Atos will not apply any sanction or retaliatory measure or discriminate against an employee raising an alert, provided that they acted in good faith, selflessly, and without the intention to cause harm.

Policies related to value chain workers

Atos has established multiple policies governing its relationship with value chain workers, implemented through its suppliers and partners.

Atos Partner Commitment to Integrity

Scope:

• Applies to all Atos suppliers and partners
• Covers all commodities and all geographies, especially those at significant risk
• Applies to any activity delivered by a supplier, including software development, hardware provision, network management, data center operations, technical support, and consulting services

Key content and principles:

• Protection of internationally proclaimed human rights in dealing with all stakeholders
• Prohibition of child labour
• Prevention of forced, bonded or compulsory labour
• Respect of employees' individual and collective rights
• Prevention of harassment and discrimination
• Promotion of inclusion and accessibility
• Commitment to ensure suppliers are not complicit in human rights abuses
• Compliance with these requirements is a condition for supplier selection and ongoing collaboration

Public availability:

• Made available to all suppliers and Atos partners who need to accept it either through their contracts or during onboarding before starting any collaboration

Link to international standards:

• Commits partners to comply with the protection of internationally proclaimed human rights

Implementation and monitoring:

• Suppliers must accept the commitment either through contracts or during onboarding
• Third-party assessments such as Ecovadis are employed to monitor suppliers' compliance with anti-slavery requirements
• Annual performance review of globally managed suppliers (QCDIMS assessment on quality, cost, delivery, innovation, management and sustainability)
• Assessment during onboarding process on human rights-related initiatives
• Suppliers without fundamental initiatives in place are requested to implement them
• In request for proposal processes, suppliers may not be selected because of risk
• Compliance Catalyst tool provides continuous monitoring and control for CSR risks associated with value chain workers
• Suppliers with identified risk factors (geographical and industrial risk) and declared corruption history are assessed and monitored in the Compliance Catalyst tool
• High or very high risk suppliers may be requested to perform additional mitigation actions agreed separately for each case
• Non-compliance cases are addressed through corrective measures

Atos Human Rights Policy (with regard to value chain workers)

Scope:

• Applies across all areas of the value chain
• Addresses stakeholders affected by suppliers and partners' behaviour, including:
  • Workers of Atos suppliers potentially exposed to health and safety risks
  • Workers exposed to violations of fundamental rights and freedoms, mainly associated with raw material extraction activities (used for IT components)
  • Purchase of materials from high-risk sectors (use of conflict minerals by subcontractors)
  • Workers of Atos clients that could be affected by layoffs associated with job obsolescence

Key content and principles:

• Adherence to international labor standards
• Addresses modern slavery risks in the supply chain
• Prompt response protocols for any reported breaches

Link to international standards:

• Aligns with the UN Guiding Principles on Business and Human Rights
• Aligns with the ILO Declaration on Fundamental Principles and Rights at Work
• Aligns with the OECD Guidelines for Multinational Enterprises
• Follows the UN Guiding Principles in addressing modern slavery risks
• Policy mandates adherence to these standards across all areas of value chain

Implementation and monitoring:

• Implemented through Atos' Vigilance plan
• Due diligence practices employed
• Supplier compliance routinely assessed
• Instances of non-compliance identified through due diligence assessments
• Atos commits to taking corrective action for non-compliance
• Mechanisms are in place to ensure compliance across the supply chain
• Engagement with supply chain workers occurs indirectly by engaging with their employer companies, primarily during procurement and supplier evaluation stages (tender process, contract negotiation, onboarding process, annual performance review)

Taking action on material impacts on value chain workers

Atos Vigilance Plan

Description and scope:

• Developed in alignment with French regulations
• Comprehensive vigilance plan to identify, prevent and mitigate risks arising from Atos' own activities and supply chain
• Covers violations of human rights, health and safety of individuals and environmental protection
• Includes an alert system and third-party assessments to ensure human rights compliance across supply chain

Key mechanisms:

• Supplier assessments and improvement plans to uphold human rights standards
• Enables effective remedy processes for any identified human rights impacts within the value chain
• Allows both internal and external stakeholders to report human rights concerns, facilitating timely corrective actions

Link to policy: The Atos Partners' Commitment to Integrity is a key element of the Atos Vigilance Plan for acknowledging suppliers

Resources allocated: Not quantified

UK Modern Slavery Statement

Description and scope:

• Actions and approach adopted in accordance with section 54 of the Modern Slavery Act 2015 and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015
• Details the Group's stringent protocols to combat modern slavery
• Applies within the UK, across Atos Group, its global supply chains, and its industry
• Outlines forthcoming initiatives that reinforce Atos' actions in tackling modern slavery

Resources allocated: Not quantified

Ethics Alert System

Description and scope:

• Allows for confidential reporting of human rights concerns
• Ensures that corrective actions are taken
• Available to all stakeholders (internal and external)
• Forms part of Atos' overall remedy strategy for addressing human rights impacts in value chain

Resources allocated: Not quantified

Supply Chain Due Diligence and Compliance

Description and scope:

• Rigorous due diligence screenings of suppliers
• Inclusion of contractual clauses allowing Atos to address and remediate human rights impacts
• Contract termination provisions if necessary
• Risk assessments and supplier termination protocols in cases of unresolved non-compliance

Link to policy:

• Governed by the Atos Partner Commitment to integrity (supplier Code of Conduct)
• Supported by internal Global Procurement Code of Conduct for Atos employees performing procurement activities

Covered issues:

• Prohibition of child labour
• Prevention of forced, bonded or compulsory labour
• Respect of employees' individual and collective rights
• Prevention of harassment and discrimination
• Promotion of inclusion and accessibility

Scope of commodities: Covers all commodities and all activities delivered by suppliers including software development, hardware provision, network management, data center operations, technical support, and consulting services

Resources allocated: Not quantified

Taking action on material impacts on affected communities

Community Investments and Engagement

Atos undertakes various community investment initiatives, with quantified resources allocated as follows:

Resources Allocated (2024):

• Total community investments: €3,683 thousand
• Donations to Charity: €2,284 thousand
• Contribution to Commercial initiatives for good causes: €27 thousand
• Contribution to Universities and similar: €1,080 thousand
• Contribution to Responsible IT Projects: €293 thousand

Breakdown by type:

• Cash contribution: €945 thousand
• Staff time cost: €2,481 thousand
• In-kind contribution: €70 thousand
• Management Cost of Social initiatives: €187 thousand

Non-financial resources:

• Total number of employees involved in the main social initiatives: 343 employees (52% coverage per employee)

Digital Inclusion and Education Partnerships

Action: Partnerships with external organizations to extend social impact on digital inclusion, education, and community engagement

Scope: Affected communities

Description: Atos collaborates with external organizations to promote digital inclusion and education in communities. This includes:

• The Changing Face of Technology event supporting underrepresented students
• Partnerships with Google and VMware

Outcomes (2024): Over 140 students from 34 universities participated alongside 120 mentors from Atos Group and Google

Purpose: Empowering underrepresented groups to thrive in the technology sector

Community-Focused Cultural Awareness Initiatives

Action: Black History Month programming

Description: Programming themed "The Black Americans and the Arts," highlighting impacts Black Americans have made in visual arts, music, and cultural movements. Honored unsung artisans and showcased organizations that elevate artistic expression through community engagement.

Action: Juneteenth commemoration

Description: Cross-company programming with partner Microsoft featuring lunch and learn sessions celebrating trailblazers in tech and sharing culinary recipes passed down through generations.

Diversity and Community Advocacy Networks

Action: Employee Networks and partnerships for community impact

Description: Executive-sponsored employee networks with global or local presence play a pivotal role in fostering inclusion. These networks promote understanding, support policy development, and provide feedback that shapes practices affecting communities.

Initiatives include:

• Collaborative campaigns: World AIDS Day and Men's Mental Health webinars
• Pride Community advocacy for LGBTQ+ inclusion
• National Coming Out Day and Transgender Awareness Week celebrations

2025 Plans: Networks will focus on amplifying awareness, providing education on critical issues, creating spaces for sharing diverse stories and experiences, and advocating for equity while addressing challenges such as prejudice, systemic barriers, and discrimination.

Accessibility and Disability Inclusion (Planned 2025)

Action: Creation of an escalation process to address issues or risks related to accessibility and disability inclusion

Time horizon: 2025 (short-term)

Purpose: Ensuring effective inclusion of individuals with disabilities

Action: Support for Employee Resource Groups (ERG) and disability inclusion networks

Description: Active support for Atos Adapt network and Eviden AdaptAbility, supporting employees worldwide with physical or mental disabilities or health conditions as well as their allies to manage their impairment to reach their full potential in the workplace.

External Commitments and Partnerships

Memberships and signatory status:

• Member of The Valuable 500
• Partner with Business Disability Forum
• Member of Microsoft Canada's Global Partner Solutions Women's Council
• UK Signatory of: Women in Defence Charter, Race at Work Charter, Change the Race Ratio, Wellbeing of Women Menopause Workplace Pledge, Armed Forces Covenant, Employers Domestic Abuse Covenant
• UK Member of: Purple Space (Disability), Henpicked (Menopause), Tech UK (Trade Association)
• UK Real Living Wage Employer (Social Economic)
• Spain: Approval and legal registration of the I Plan for Equal Opportunities for Men and Women at Atos Holding Spain
• Spain: Authorization to collaborate with Special Employment Centers (NGOs) to comply with "General Law on the rights of people with disabilities and their social inclusion"

Business conduct policies and corporate culture

Governance priorities

Being an ethical and fair player within its sphere of influence through maintaining the highest standards in corporate governance and business conduct.

Creating value for clients and partners through innovative and secured solutions to navigate the digital space.

CSR key figures - Governance

Sustainability leadership

Atos SE achieved the following sustainability recognitions:

EcoVadis: 80/100, Top 1%, "Platinum" EcoVadis Medal for its commitment to CSR and sustainability for 5th consecutive year (Sep 2024)

S&P Global Corporate Sustainability Assessment (CSA): 74/100, Top 5%, in the S&P Global Sustainability Yearbook for 12 years in a row (February 5, 2025)

MSCI: 5.5/10, Top 26%, Atos awarded the "A" rating by Morgan Stanley Capital International (MSCI) in its July 2024 update

ISS ESG: 64/100, Top 10%, Remains awarded prime status based on the esg corporate rating letter grade meeting or exceeding the industry-specific prime threshold defined by ISS ESG's industry classification matrix.

CDP: "B" List, Atos awarded "B" score on the CDP Climate Change 2024 List

ESG scores: Atos scoring is excellent in Environmental (82 points), Social (69) and governance (69) as of July 2024

Management of relationships with suppliers

Atos is committed to delivering high value to its networks of suppliers. The Group has built solid governance, using ethics and compliance to drive organizational processes, and business, thereby securing a sustainable supply chain. Atos has put data protection as a key component of its business culture, for both customers, partners and suppliers.

Incidents of corruption or bribery

Confirmed incidents

In 2024, Atos reported 2 confirmed incidents of corruption or bribery:

1. A kick-back in a recruitment process in 1 country
2. Undue gifts provided to third parties in 1 country

Convictions and fines

0 convictions and therefore no fines were levied against Atos for violations of anti-corruption or anti-bribery laws in 2024.

The company stated: "In 2024, no significant fine for non-compliance with laws and regulations was levied against the Group. No client or supplier claim related to Atos legal compliance fields was levied against the Group."

Disciplinary actions

2 employees were subject to disciplinary action:

• 1 employee was dismissed
• 1 employee was disciplined

Actions taken to address breaches included:

• Ongoing dismissal process
• Disciplinary actions
• Action Plan (internal communication and external letter)

Contracts terminated

0 contracts with business partners were terminated or not renewed due to corruption or bribery violations in 2024.

Formal disclosure table (ESRS G1-4)

Investigation and speak-up procedures

Atos maintains a comprehensive Group Ethics Alert System that enables both employees and third parties to report concerns related to potential breaches of the Code of Ethics or applicable laws. In 2024, 94 compliance alerts were reported and monitored within the Group.

Key features of the alert system:

• Multiple reporting channels including the Atos Integrity Line (web-based platform developed by EQS), dedicated email mailboxes, and alternative means
• Anonymous reporting is permitted unless prohibited by local laws
• Investigation Teams are appointed on a case-by-case basis, composed of at least two persons from various functions (Compliance, Internal Audit, Legal Affairs, Human Resources) or external experts
• Confidentiality and protection against retaliation are guaranteed for whistleblowers acting in good faith
• The system was rolled out globally in 2024, covering Americas, India, Middle East, Africa, Turkey, Asia Pacific, and European countries (with finalization pending in Poland and the Netherlands)

The Group Compliance Team reports semi-annually to the Audit Committee of the Board of Directors on the Group Ethics Alert System, providing detailed results and figures about alerts raised, investigation results, and sanctions taken.

Atos follows a four-stage risk management cycle: risk identification and assessment, prevention, detection, and monitoring. The company completed a comprehensive Corruption Risk Mapping exercise in 2023, identifying 58 scenarios among 25 risk areas and 14 corruption mechanisms. Results and action plans were presented to the Group Management Committee and the Audit Committee.

Political influence and lobbying activities

Zero declaration

Atos does not make political contributions or engage in political lobbying activities.

As stated in the Board of Directors' Reserved Matters requiring simple majority approval:

"Making of any non-arm's length transactions (including charitable and political donations)"

This governance requirement confirms that any political donations would require Board approval, and no such donations are reported in the financial statements or sustainability disclosures for 2024.

No political contributions, lobbying expenditure, or trade association memberships related to political advocacy are disclosed in Atos' 2024 Universal Registration Document.

Payment practices

Days Payable Outstanding (DPO)

Note: 2023 DPO was restated to exclude working capital optimization actions.

The DPO decreased by 35 days at 19 days, from 54 days at the end of December 2023 (excluding working capital optimization actions), mainly driven by the overall reduced level of activity in the fourth quarter of 2024, the short payment terms required by suppliers in the context of the financial situation of the Group whilst decision was made to stop any one-off working capital optimization actions in 2024.

Standard payment terms

The standard conditions of payment of the Group are 90 days end of month. All local Terms and Conditions must be aligned to this standard or to local standard if more favorable. If a local regulation restricts duration of credit to a shorter term, local most favorable term to Atos will apply.

Information not yet available

At the time of preparing its Sustainability Statement, the Group is still engaged in further investigation to collect detailed information related to payment practices and applicable legal framework across all its countries of operation. As this information is produced locally and a global analysis could not be finalized in 2024, Atos is not yet able to disclose the following metrics from ESRS G1 / G1-6 §33:

• Average number of days to pay invoice from date when contractual or statutory term of payment starts to be calculated
• Description of undertakings standard payment terms in number of days by main category of suppliers
• Percentage of payments aligned with standard payment terms
• Disclosure of contextual information regarding payment practices

Legal proceedings

As of December 2024, there is no legal proceedings for late payment above €300,000. Below this threshold, the Group does not have the information.

Payables and receivables payment terms (Article D. 441)

Invoices received not paid at year's end closing but due:

Invoices emitted not paid at year's end closing but due:

Payment terms used: Contractual payment terms: 60 days (for received invoices) and 30 days (for emitted invoices). Legal payment terms: N/A.