Atos

Role of the governance bodies

Reference: printed page 169 (section 5.1.2.1). Board composition and expertise datapoints (21 a-e, 22, 23) are incorporated by reference to chapter 4.2, as recorded in Appendix 1 (printed page 306).

"The CSR organization is present at all levels of the company up to the board of directors which is ultimately in charge of the oversight of all material impacts, risks and opportunities and of monitoring the implementation of the CSR strategy" (printed page 169).

Committees.

• The CSR committee (created 2018) "is directly involved in defining the CSR strategy and priorities" (printed pages 169, 184).
• The audit committee "is in charge of monitoring the sustainability reporting process and the performance by the sustainability auditors of the sustainability information certification, based on the preliminary works and recommendations of the CSR committee".

Management. The head of investor relations and CSR "represents and sponsors CSR at executive committee level"; the Group CSR officer "manages the entire CSR program". For business conduct the board has appointed an ethics advisory body of independent external professionals (printed page 293).

Board diversity. At 31 January 2026 the board "was composed of 50% women directors (4 out of 8)" (printed page 237).

Information provided to and matters addressed by the governance bodies

Reference: printed page 169 (section 5.1.2.1), with datapoint 26(a)(b) incorporated by reference to chapter 4.2.

The Group CSR officer and the head of investor relations and CSR "present on a regular basis to the CSR committee of the board of directors the latest achievements and planned objectives both at global and regional levels on the environmental and social initiatives of the Group. They highlight cooperation needs by other functions, geographies or business lines" (printed page 169).

What the board addressed in 2025. "In 2025, the board of directors reviewed the relevance of the results of the double materiality analysis. The exercise resulted in adjustments made to the list of impacts, risks and opportunities ... This assessment fed into the discussions on the Group strategy" (printed page 169). The revised list of 20 material IROs "was then approved by the board of directors in December 2025", having been "presented to and controlled by the CSR committee and the audit committee" (printed page 176).

The transition plan was "validated by the board of directors in October 2025" (printed page 189). The Group head of ethics and compliance reports to the audit committee each semester and to the CSR committee yearly (printed page 293).

Sustainability performance in incentive schemes

Reference: printed page 169 (section 5.1.2.2); prior-year detail incorporated by reference to chapter 4.3 (datapoint 29(a)-(e), Appendix 1, printed page 306).

"The board of directors sets the sustainability-related criteria for the chief executive officer variable compensation, based on the recommendations of the remuneration committee and the CSR committee of the board of directors" (printed page 169).

2025. "In 2025, 10% of the annual variable compensation of the chief executive officer was linked to the short-term 2025 target to reduce greenhouse gas (GHG) emissions (Scope 1, 2 and 3) compared to 2019 baseline."

2026. "In 2026, 10% of the annual variable compensation of the chief executive officer will be based on a criterion linked to the Group's climate objectives, i.e., a reduction of Atos Group 2026 greenhouse gas emissions (scopes 1, 2 and 3) compared with a 2025 baseline, in line with the Group's transition plan."

Climate is therefore the only sustainability metric in the CEO's variable pay, tied to the same absolute Scopes 1-3 trajectory that underpins E1-1 and E1-4. Appendix 2 also lists GOV-3 under ESRS E1 (printed page 307). No sustainability-linked incentive below CEO level is disclosed.

Statement on due diligence

Reference: printed page 170 (section 5.1.2.3); the paragraph 30-32 mapping is incorporated by reference to chapter 5.7, the Vigilance Plan.

Due diligence is anchored in the French Duty of Vigilance law of 2017, under which Atos "is required to implement a vigilance plan and report on the actions taken accordingly". The plan "discloses key features of the management systems in place in terms of vigilance, which include, but are not limited to, risk mapping, evaluation procedures, mitigation actions, alert mechanisms, and monitoring systems", structured around "(i) the scope and the governance of the plan, (ii) the measures relating to the risk mapping, the evaluation procedures and mitigation actions for Atos Group's own activities and its supply chain, (iii) the alert mechanism and the monitoring system" (printed page 170).

"The risks identified as part of the vigilance plan were taken into account through the evaluation of the IROs done by Atos Group compliance team."

Third parties. "customers and prospects, suppliers and other business partners or intermediaries are thoroughly vetted using compliance screening software and databases prior to onboarding", with "specific measures for higher risk partners (e.g., integrity questionnaire)".

Risk management and internal controls over sustainability reporting

Reference: printed page 170 (section 5.1.2.4).

Two distinct processes. "The double materiality analysis and the ERM exercise are different in scope and methodology. The ERM exercise focuses on risks, while the double materiality analysis also encompasses impacts and opportunities ... the ERM exercise considers net risks while the double materiality analysis considers gross risks (i.e., without taking into account mitigation measures)" (printed page 170).

Integration in 2025. "In 2025, the results of the DMA gathering 20 IROs ... were integrated in the ERM framework to be consistent with the material topics identified for the Group in all type of risks assessments. This enables a full alignment of the outcomes and of mitigations actions." For climate, "All climate-related IROs are therefore included in the ERM framework, thereby being covered transversally" (printed page 185).

The CSR committee's preliminary work includes "monitoring the effectiveness of internal control and risk management systems with regard to procedures relating to the preparation and processing of sustainability information" (printed page 169). The Group states that internal control over sustainability information "will be progressively strengthened on the basis of the experience gained from the first reporting periods" (printed page 166).

Strategy, business model and value chain

Reference: printed page 180 (section 5.1.4.1); business model and value chain incorporated by reference to chapters 1, 2 and 6.

The Group's "purpose is to help design the future of the information space", with a strategy "to become a global AI-powered technology partner delivering secure end-to-end digital journeys for its clients" (printed page 180).

Environmental strand. "Atos Group has achieved its near term SBTi target to reduce its 2025 emissions by 50% compared to 2019", and confirmed at its May 2025 Capital Markets Day "its commitment to GHG emissions reduction to be net zero by 2050 compared to 2025 and as defined by the SBTi".

Social strand. The Group "set a target to reach 40% female representation among new hires by the end of 2025. While significant progress was made and the target was not fully achieved, the Group continues to strengthen its initiatives to improve gender balance" (36.74% achieved, printed page 243).

Scale. 63,012 employees across 63 countries at 31 December 2025 (printed page 220).

Excluded sectors (40(d)). "Atos Group is not active in the fossil fuel, chemicals production, controversial weapons sectors nor in the cultivation of tobacco"; Appendix 3 marks all four datapoints "not applicable to Atos" (printed page 311).

Interests and views of stakeholders

Reference: printed pages 181-182 (section 5.1.4.2), which serves ESRS 2 SBM-2 and the SBM-2 requirements of S1, S2, S3 and S4.

"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" (printed page 181). Seven groups are covered with expectations, value created and engagement channels: clients, employees and representatives, investors and analysts, partners, suppliers and supply chain workers, affected communities and society.

Named channels. Clients: client-facing roles and customer satisfaction surveys "that are considered in the decision-making process". Employees: the European Company Council, which "represents 31,000 employees across Europe in 18 countries"; local works councils; one employee director on the board; the Group Ethics Alert System. "An employee satisfaction survey was run for the first time since 2022 in 58 countries." Suppliers: EcoVadis and due diligence questionnaires before onboarding.

Materiality consultation (printed page 173). More than 60 stakeholders took part; 30 interviews with 45-plus stakeholders assessed impact materiality, 21 interviews assessed financial materiality. "The external stakeholders did not perform the financial materiality assessment, as they are not considered to have the appropriate perspective to assess the financial effects of risks and opportunities on the Group.

Material IROs and their interaction with strategy and business model

Reference: printed pages 182-183 (section 5.1.4.3); the list of 20 material IROs is at printed pages 177-178.

"Following the double materiality analysis exercise, in 2025 Atos Group has considered in a comprehensive way how its material positive and negative impacts affect people and environment, if and how those impacts originate from its strategy and business model, the effects of material risks and opportunities on its business model, value chain, strategy and decision-making" (printed page 182).

Environment. Negative impacts "deriving from its manufacturing activities and from the e-waste generated by its own operations"; climate risks from "business disruptions due to climate hazards (physical risks)" and from "a loss of business opportunity and revenue if it doesn't address its clients' needs for sustainable offerings" (printed page 183).

Social. Positive impacts on digital inclusion; risk of "exclusion from bid offers" on diversity and accessibility compliance; risk of "dissatisfaction and resignation" from inadequate skills programmes; cybersecurity breaches that "could cause business interruptions, data leakages". The client-relationship IRO is "the only fully entity-specific IRO".

Anticipated financial effects (48(e)) are omitted under phase-in (printed page 168), but the Group states: "In 2025, Atos Group identified financial effects associated with sustainability-related material risks and opportunities ... These effects were qualitatively assessed and determined not to be material to the undertaking's financial position, financial performance, or cash flows" (printed page 183).

Process to identify and assess material impacts, risks and opportunities

Reference: printed pages 172-179 (sections 5.1.3.1 to 5.1.3.4); environmental topical IRO-1 at printed page 175.

Base exercise. Conducted "from September 2023 to March 2024", supported "by a tier-one external consultant", covering "the entire Atos Group's scope", "fully aligned with the scope considered for the financial reporting", and the entire value chain. "The only level of disaggregation used was by business lines (Tech Foundations/Eviden)" - no country or geography split (printed page 172).

A gross list of "89 positive and negative impacts, and 107 risks and opportunities" was scored (printed page 173). Financial materiality used a 0-3 score weighted by stakeholder role ("1.5 vs. 1 for the employees") with a 2/3 threshold set in a workshop with risk and finance experts (printed pages 174-175). "Atos Group applied the defined methodology strictly and did not modify the results obtained, resulting in 63 material IROs" (printed page 176).

2025 revision. Three stages - thematic grouping, "merger and reformulation of certain IROs", and "reassessment of materiality criteria", which removed IROs "related to the specific context of fiscal years 2023 and 2024 ... when their scores fell below the thresholds" (printed page 176). The result is 20 material IROs, approved by the board in December 2025. An in-depth review "will be carried out after the revised ESRS standards ... come into force".

Climate IROs are categorised "in accordance with the TCFD recommendations" (printed page 185).

Disclosure requirements covered by the sustainability statement

Reference: Appendix 2, "Table of disclosure requirements complied with in the Sustainability Statement", printed pages 306-310; Appendix 3, datapoints deriving from other EU legislation, printed pages 311-315; Appendix 1, disclosures incorporated by reference, printed page 306.

Appendix 2 is a genuine ESRS content index: each disclosure requirement is listed against the section carrying it, with exceptions marked either "omitted in 2025 due to phase-in provisions" or "not material for Atos Group". The topical standards it contains are ESRS 2, E1, E5, S1, S2, S3, S4 and G1. ESRS E2, E3 and E4 appear nowhere in Appendix 2 or Appendix 3.

Phase-in provisions used (printed page 168): "(i) ESRS 2 SBM 3 48(e) Anticipated financial effects of the undertaking's material risks and opportunities; (ii) E1-9 ...; (iii) S1-7 Characteristics of non-employee workers in the undertaking's own workforce." Appendix 3 also phases in S1-14 paragraph 88(e) and three E1-9 datapoints, and marks S1-16 97(b), S1-17 103(a) and S1-17 104(a) not material (printed pages 312-314).

Reporting logic. "once an IRO is deemed material, the ESRS standard associated with the ESG topic to which the IRO pertains becomes material ... the reporting data from the disclosure requirements under metrics that are not material for Atos Group won't be reported" (printed page 180). Chapter 5 also carries "Information Beyond Materiality" sub-sections whose "content ... do not form part of the sustainability statement".

Transition plan for climate change mitigation

Reference: printed page 189 (section 5.2.1.3.3), with the decarbonization plan at printed page 187 and Appendix 5 at printed pages 320-321.

2025 is a hinge year: "It marks the achievement milestone for its near-term science based target initiative (SBTi) GHG emission reduction target and will be the baseline year for its future targets and transition plan" (printed page 187).

Content. "Atos Group's transition plan is built on new near, long and net zero targets which are set in accordance with SBTi corporate net zero standard, are aligned with the Paris agreement and a 1.5°C trajectory. These new targets will use 2025 emissions as their new baseline and will extend to 2050 with intermediate targets (or key milestones) every 5 years from 2030" (printed page 189).

Approval. "The transition plan was presented to the CSR committee of the board of directors of Atos Group and validated by the board of directors in October 2025." Roll-out of the lever action plans "will be performed from 2026".

Locked-in emissions, a nil return. "Atos Group has not identified any locked-in emissions in its activities due to the nature of its business and by accounting for all Scope 3 category 11 emissions (use of sold products) upfront each year."

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

Resourcing, quantified. 2025 spend supporting the plan: €12.773m (OpEx €3.012m, CapEx €9.760m) - climate governance and audit €1.995m, sustainable procurement €0.223m, EMS and ISO 14001 €0.794m, car fleet electrification €5.010m, energy efficiency €4.750m. The Group "favours a prudent and transparent approach, avoiding overestimating these amounts".

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3 as disclosed for climate at printed pages 185-187 (sections 5.2.1.2.1-5.2.1.2.2). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification. Each climate IRO carries an explicit TCFD label (printed page 185): IRO 2 (sustainability portfolio) "Transition Risk and Opportunity"; IRO 3 (GHG emissions, reputational) "Transition Risk"; IRO 4 (climate hazards on operations and supply chain) "Physical Risk".

Physical risk methodology. "Atos Group performed a climate risk assessment using an external climate risk tool ... This tool provided Atos Group with site specific exposure data for all temperature, water, wind and solid-mass related hazards as defined by the EU taxonomy regulation." Scenarios: IPCC SSP1-2.6 ("under 2° increase") and SSP5-8.5 ("circa 4° increase - business as usual"), over 2021-2040, 2041-2060 and 2081-2100. Material hazards: changing temperatures, heat stress, cold waves, wildfire, tornadoes and cyclones, water stress; "The soil related hazards have not been identified as material" (printed page 186).

Value chain. Upstream exposure via EcoVadis; downstream risk "perceived as not significant at the Group level due to the multiplicity of clients".

The gap the Group declares. No 1.5°C transition scenario analysis has been done: "Atos Group intends to launch in 2026 a formalized analysis of climate-related transition risks and opportunities considering the specificities of the TCFD recommendations ... as well as their financial impact" (printed page 187).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 as disclosed for climate at printed pages 185-187 (section 5.2.1.2.2). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The resilience work is physical and site-level. "With site exposure data available, Atos Group has started in 2025 to assess the vulnerability of its main sites ... which are labelled high/extreme exposed to climate hazards. The first wave of countries to undergo the vulnerability analysis are India, USA, Germany and Austria" (printed page 186), continuing "on a rolling basis".

Scope and horizon, with the reason. "Atos Group has chosen to focus this vulnerability analysis on the SSP5-8.5 scenario for the near term (2021-2040 term), which is a 'worst case scenario' approach ... This timeframe was selected as most relevant for the IT sector ... and because Atos Group does not have long-term dependencies relating to assets or real estate."

Result so far. "To date, the resilience analysis has not identified any material residual risk beyond low or moderate levels, based on the sites assessed and the current stage of the analysis."

Capacity to adapt. "The multiplicity of sites from which Atos Group operates, across many geographies, and strong business continuity plans in place allow for mitigating actions in emergency situations and ensure resilience against unforeseen acute events." Analysis is run locally by EMS, site and datacentre managers and integrated in the ISO 14001 EMS.

Uncertainty stated. "The vulnerability assessment's methodology is still being deployed, and Atos Group will continue to improve it in the coming years." Transition resilience is untested: the formalized transition risk and resilience analysis is only "intend[ed] to launch in 2026" (printed page 187).

Policies related to climate change mitigation and adaptation

Reference: printed page 188 (section 5.2.1.3.2, "Atos Group Environmental Policy").

Ownership and scope. The policy "is validated by the Group head of investor relations and CSR and owned by the head of global environment program, the CSR department being responsible for its implementation across the Group. It applies to all Atos Group entities and operations worldwide, all office sites, and datacentres as well as its clients and suppliers and partners through Atos Group partners' commitment to integrity" (printed page 188).

Coverage. "The environment policy covers all climate change IROs and applies to all levers and action plans covering its value chain." It is "complemented by the internal book of environmental guidelines which includes regularly updated information about the context of each environmental challenge and its main concrete instructions, ambitions, objectives, or targets at the Group and/or at the local level".

Operating system. An ISO 14001-based EMS runs at Group level and in all geographies; since 2018 Atos has run "a fully integrated ISO Multisite Certification (MSC) process with a three-year life cycle" covering ISO 14001:2015, 9001:2015, 20000-1:2018 and 27001:2022 (printed page 184). In 2025, "86.8% of Atos Group's main sites were ISO 14001 certified or in the process of being certified (vs 92.3% in 2024)", with 99 sites certified (printed page 197) - a fall worth noting.

A policy timeline is disclosed, from the 2008 environmental programme through the 2020 near-term SBT to the 2025 achievement of that target and launch of the transition plan (printed page 188).

Actions and resources in relation to climate change policies

Reference: printed pages 193-198 (section 5.2.1.5), with the resourcing table at printed page 189.

The Group "has rolled out a global action plan aiming at reducing GHG emissions across its value chain (own operations, upstream and downstream activities)". The actions "were active in 2025, and are expected to continue"; "Unless specified otherwise, the actions are not time-bound to a specific end-date" (printed page 193).

Scopes 1 and 2, with 2025 outcomes.

• Site optimisation: "the volume of space used in Atos Group sites decreased by approximately 6.4% against 2024".
• Energy efficiency: "the average PUE was 1.39 for core datacentres (1.44 since 2022) and 1.54 for all Atos Group datacentres"; approximately €5 million invested "towards an energy efficient building by renewing the lease of its offices in Timisoara, Romania".
• Renewables: "Atos Group gets its renewable energy from the grid and does not self-generate ... no contractual instruments for renewable energy such as power purchase agreements or guarantees of origin other than having purchased RECs in Hong Kong amounting to 33 594 MWh" (printed page 194).
• Cooling: refrigerant emissions 7,513 tCO2e, -18% year on year.
• Car fleet: 41.5 gCO2e/km, -61% against 2019; "100% of the Group's car fleet by end of 2030" hybrid or electric; approximately €4.8 million invested.

Scope 3 (96.6% of emissions). Since January 2025 Atos uses EcoVadis' Carbon Action Manager; "99.6% of assessed suppliers were rated on an external basis". Travel emissions 13,737 tCO2e, -74% against 2019. Environmental training completion: "87.78% of the total Atos Group workforce ... (vs 93.66% in 2024)".

Targets related to climate change mitigation and adaptation

Reference: printed pages 189-192 (sections 5.2.1.4-5.2.1.4.3), with Appendix 5 at printed pages 320-321.

Target that closed in 2025. "to reduce by 50% all the Group's carbon emissions (GHG protocol scopes 1, 2 and 3) between the end of 2019 and the end of 2025 ... defined with reference to a total of GHG emissions of 3.303 MtCO2e in 2019", SBTi-validated, covering all activities and geographies. Outturn: "by the end of 2025, Atos Group had achieved a 58% reduction ... (1.376 MtCO2e at the end of 2025 versus 3.303 MtCO2e at the end of 2019). The Group's 2019-2025 SBT has therefore been met" (printed pages 189-190).

New targets, 2025 baseline (printed page 191):

Coverage: "scopes 1 and 2 (which should contribute to less than 5%) and scope 3 categories 1 to 8 and category 11 (which should contribute to more than 95%)".

Basis. "prudent volume assumptions based on IPCC scenarios, the International Energy Agency's Zero Roadmap and the Network for Greening the Financial System Scenario Phase V". Of the 2030 reduction, approximately 33% sits in own operations and 67% in the value chain, where the chart marks control as LOW.

Two caveats. The 2025 baseline excludes the Advanced Computing business being sold to the French state, "approximately 28% of Atos Group's total footprint" (printed page 192). And "The detailed action plans and metrics supporting these new near-term and long-term targets will be disclosed in Atos Group's 2026 sustainability statement.

Energy consumption and mix

Reference: printed page 194 (section 5.2.1.5.1).

2025 against 2024, with the Group's own percentage changes (MWh):

Coal and coal products, other fossil sources, nuclear, renewable fuel including biomass and self-generated non-fuel renewable energy are all zero for every year 2022-2025.

"Atos Group does not operate in high climate impact sectors as defined by EU regulation", so the Appendix 3 datapoints on fossil energy disaggregation (paragraph 38) and energy intensity (40-43) do not bite.

The renewable share rises to 62% even though renewable MWh fell, because total consumption fell faster - a consequence of the shrinking footprint (space down 6.4%, headcount down from 77,932 to 63,012). The only contractual renewable instrument disclosed is 33,594 MWh of RECs in Hong Kong: no PPAs, no guarantees of origin, no self-generation.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: printed pages 198-201 (sections 5.2.1.6 and 5.2.1.6.2).

Accounting is on the GHG Protocol operational control boundary, "aligned with its additive approach and no significant judgements were made to complement this methodology" (printed page 198).

2025 shares: Scope 1 1%, Scope 2 market-based 2.3%, Scope 3 96.6%. Largest Scope 3 lines: category 1 purchased goods and services 780,655; category 11 use of sold products 437,092; category 7 employee commuting 27,299 (+80%); category 8 upstream leased assets 26,315. Scope 1 from emissions trading schemes 0%; "Atos Group does not produce any biogenic CO2 emissions". Intensity fell from 186.66 to 171.94 tCO2e/€ million of net revenue (printed page 201).

Limitations stated. Scope 3 is "to a large extent, measured on the basis of spend data ... and not on primary data obtained from suppliers". Categories 4 and 9, and 5 and 12, are reported together as an explicit "exception to the GHG protocol" because the spend report does not separate them (printed page 200). ADEME refrigerant factors carry "an uncertainty of ±50%"; commuting and homeworking use "sector averages ... without individualized data".

GHG removals and GHG mitigation projects financed through carbon credits

Reference: printed page 201 (section 5.2.1.7, "Carbon Credits [ESRS E1-7]").

A complete nil return: "In 2025 Atos Group did not finance GHG removals or GHG mitigation projects through carbon credits" (printed page 201).

This is consistent with the rest of the climate disclosure. The 2019-2025 target was met by an absolute 58% cut in Scopes 1, 2 and 3 with no credit component (printed page 190), and the new 2025-2050 targets are also expressed in absolute terms. Neutralisation appears only in the 2050 net-zero target, where the ambition is to "Neutralize residual 10%" of the 2025 baseline (printed page 191); Appendix 5 defers the detailed selection and timing of neutralisation measures under the SBTi Corporate Net-Zero Standard to the 2026 SBTi submission file (printed pages 320-321).

Appendix 3 lists the E1-7 datapoint "GHG removals and carbon credits paragraph 56" against section 5.2.1.7 (printed page 312), so the nil return is the company's stated answer to the disclosure requirement rather than an omission from the index.

Internal carbon pricing

Reference: printed page 201 (section 5.2.1.8).

New in 2025: "Atos Group launched a group-wide shadow Internal Carbon Price (ICP) in 2025 set at € 80/tCO2e covering 100% of emissions (Scope 1, 2, and 3). This price was set by the Group CSR department, based on the Stern/Stiglitz report (2017) and market best practices. It will be reviewed periodically considering evolving climate regulations and carbon market trends" (printed page 201).

Scope of application, stated narrowly. "This shadow ICP doesn't influence CapEx or R&D investment decisions." Deployment in 2025 was a pilot: "At the end of the 2025, this shadow ICP was rolled out in a test phase in Poland and in the Netherlands, through the EMS and CSR community of contributors. It aims to be embedded in local environmental reporting and projects to simulate the cost of carbon and drive long-term behavioral change."

Intended uses: raising internal awareness of the environmental and financial impacts of emissions; encouraging low-carbon decision-making "in procurement, investment, product development, and operations"; and driving achievement of the GHG reduction targets.

Financial treatment. "As a shadow price, this ICP, does not result in actual financial charges and therefore is not considered in the financial statements."

So the price covers the whole inventory on paper but, on the company's own account, does not yet change capital allocation and was live in only two countries at the reporting date.

Policies related to resource use and circular economy

Reference: printed page 203 (section 5.2.2.1.1, manufacturing inflows) and printed page 206 (section 5.2.2.2.1, waste).

E5 has two material IROs, and the policy position differs between them.

Manufacturing inflows - no policy, with the reason given. "Due to the recent identification of resource use and circular economy as a material topic for Atos Group and the on-going process of carve-out of the Advanced Computing activities, Atos Group has not yet adopted a policy to manage the impact related to the use of primary (strategic and non-strategic) non-renewable raw materials in its manufacturing activities. After the finalization of the carve-out process (which should be completed in 2026), the materiality of this impact may be reconsidered" (printed page 203). In its place the Group relies on regulatory compliance embedded in design: the CE standard, REACH, RoHS, the Biocidal Products Regulation, ASHRAE standards and UKCA marking.

Waste - a new policy in 2025. The environmental policy "acknowledges as core principles to 'locally identify specific challenges' including waste and 'prevent pollution and protect the environment by adopting appropriate procedures'". In addition, "In 2025, Atos Group donned the Atos Group waste management policy", applying "to its offices and datacentres worldwide, covering both hazardous and non-hazardous waste from Atos Group's own operations. It excludes notably client e-waste, and leased goods, as well as the waste generated by the products manufactured by Atos (Eviden hardware)". Implementation is overseen by the Group CIO, head of data centers and head of CSR; the objective follows the "waste hierarchy (prioritizing recovery over disposal)"; and it "is planned to be reviewed every two years" (printed page 206).

Actions and resources related to resource use and circular economy

Reference: printed pages 203-205 (section 5.2.2.1.2) and printed page 207 (section 5.2.2.2.2).

No consolidated action plan for either IRO, stated twice. For inflows: "Atos Group has not yet defined a consolidated action plan, supported by financial resources, to manage the impact of the use of primary (strategic and non-strategic) non-renewable raw materials in its manufacturing activities" (printed page 203). For e-waste: "Due to the recent identification of 'electronic waste generated by the Group's own operations' as a material topic and due to the changes affecting its target operating model, Atos Group has not yet defined a consolidated action plan, supported by financial resources" (printed page 207).

What is in place instead. Sourcing: suppliers covering 74% of spend assessed by EcoVadis; REACH article 33 reporting via the bill of material or Silicon Expert tools and SCIP declarations to ECHA; consultation with major suppliers on conflict minerals "since early 2013". Design: ECMA 370 self-declarations, metal instead of plastic facing, cardboard over plastic packaging, no glue between parts. Manufacturing: the Angers site is "certified BREEAM very good" and "designed according to an eco-manufacturing strategy". End of life: WEEE managed at country level, the supercomputer activity in the French eco-organisation EcoLogic "since 2013"; "reuse of supercomputers to build little clusters" (printed pages 204-205).

E-waste actions (printed page 207): remanufactured laptops in RFP criteria; "extension of recommended usage duration from 4 to 5 years"; repair and reallocation; revised waste clauses requiring the waste hierarchy. Leased equipment is excluded: "leased goods and assets are not part of Atos Group's waste".

Targets related to resource use and circular economy

Reference: printed page 205 (section 5.2.2.1.3) and printed page 207 (section 5.2.2.2.3).

Atos Group discloses that it has no targets for either material E5 IRO, and gives reasons for both.

Manufacturing inflows. "For the reasons detailed above, Atos Group has not yet adopted targets to manage the impact of the use of primary (strategic and non-strategic) non-renewable raw materials in its manufacturing activities. After the finalization of the carve-out process, the materiality of this impact may be reconsidered" (printed page 205). The reasons referred back to are the recent identification of the topic as material and the ongoing carve-out of the Advanced Computing activities, expected to complete in 2026.

E-waste. "Due to the recent identification of 'Electronic waste generated by Atos Group's own operations (e.g., in offices, data centres, etc.)' as a material topic, and to the changes affecting its target operating model, Atos Group has not yet adopted targets to manage the related impact and aims at adopting such targets in order to track actions effectiveness" (printed page 207).

The wider framing is given at printed page 202: "The policy, targets, actions plans and metrics implemented at date reflect the fact that these topics are newly material for Atos Group (assessed as such only since the double materiality analysis)."

So for E5 the Group has neither a consolidated action plan nor targets and says so. What it does have is the metric set: 531 tonnes of products and materials used, 338 tonnes of e-waste generated, and a 35% non-recycled e-waste rate (printed pages 205, 208).

Resource inflows

Reference: printed pages 202-205 (sections 5.2.2.1 and 5.2.2.1.4).

Where inflows sit. "Atos Group's material resources inflows can be found in Eviden service line where the products are designed and manufactured" - supercomputers, servers, encryption products and embedded electronic systems, made "in two plants located in Angers and Aix-en-Provence, France" (printed pages 202-203).

Traceability. Teams "have set up a process for collecting and analysing inputs for their entire product range, including packaging and the components assembled, using tools that guarantee the traceability of the raw materials and substances used". "An initial analysis and a report covering 80% of the product range have been carried out"; the full material declaration is built on the bill of material and names REACH-traced substances individually (cadmium, lead, lead monoxide among them) alongside rare earths, silver, copper, cobalt, lithium, manganese, nickel, beryllium and antimony.

Datapoint 31.a (printed page 205): overall total weight of products and technical and biological materials used = 531 tonnes, of which 239 actual and 292 estimated.

Method and its limits. "45% of them are transported by Atos Group's transport providers, that communicate data about the weight"; for the other "55% ... no weight data is available", so a euros-per-kg ratio from the measured half is applied to the rest. Aix-en-Provence is excluded "as no data is available for 2025 because of the on-going carve-out activities" (printed page 204). Datapoint 31.c on secondary recycled content cannot yet be produced (printed page 206).

Resource outflows

Reference: printed pages 205-206 (the product-level outflow datapoints within section 5.2.2.1.4), with circular design at printed pages 203-205.

Durability (datapoint 36.a). "The-manufactured products are designed to be maintained throughout the selling period and for a period of 3 to 5 years thereafter. 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" (printed page 206). No industry average is given for comparison.

Repairability (36.b) declared not applicable. "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 these products that are not considered in existing repairability rating system." The substantive measures are described instead: field replacement units "allowing a simple and fast repair", a "plug and play" approach, component standardisation, and a repair centre at Angers "used to repair returned parts in order to restore them to new condition for marketing" (printed pages 204-205).

Two metrics the Group cannot yet produce (printed page 206): datapoint 31.c, the weight and percentage of secondary reused or recycled components and materials including packaging, and datapoint 36.c, rates of recyclable content in products and packaging. The basis of preparation flags the same gap as a progressive disclosure (printed page 166).

Circular outflow practices disclosed include reuse of rack supplier packaging, collection of client packaging waste on delivery, return of unusable sold products to Angers, resale or reuse of old spare parts, and reuse of supercomputers "to build little clusters that can be resold".

Waste

Reference: printed page 208 (section 5.2.2.2.4, "Metrics [ESRS E5-5]"), with scoping at printed page 206.

Scope. "Considering that only e-waste is assessed as material for Atos Group, all metrics below refer only to e-waste" (printed page 208). E-waste is split into "batteries and accumulators" and "other types of e-waste (including computers, screens, wires, phones, USB keys, etc.)".

2025 results, tonnes (actual / estimated / total):

Method. "In 2025, Atos Group's team focused its efforts on the improvement of the data quality, by increasing the proportion of 'actual data' as opposed to estimations. By the end of 2025, the actual data reported by the countries covers 91.05% of Atos Group's employees." The remainder is extrapolated on a kilograms-per-employee basis, and "Double counting is avoided by differentiating countries where actual data was reported and countries where no data was reported".

Appendix 3 marks the E5-5 paragraph 39 hazardous and radioactive waste datapoint "not applicable to Atos Group" (printed page 313). Other tertiary waste, not material, is estimated at "around 8,191 tons" using an ADEME average of 130 kg per employee (printed page 219).

Policies related to own workforce

Reference: printed pages 222 and 224-225 (sections 5.3.1.1 and 5.3.1.3), with per-topic policies at 5.3.1.5.1, 5.3.1.6.1, 5.3.1.7.1 and 5.3.1.8.1.

Seven policies are named (printed page 222): the Atos human rights policy statement; the code of ethics; the global occupational health and safety policy; the dignity at work and prevention of sexual harassment policy; the people development policy; the diversity, equity and inclusion policy; and the accessibility and digital inclusion policy.

"All policies have been set by considering the interests of Atos Group's employees through regular feedback sessions surveys and focus groups ... These policies have been approved by the head of function and the function owner. All employees across the Group's own operations in all geographies are covered."

Human rights. Part of the UN Global Compact "Since 2010"; commitments to the Universal Declaration of Human Rights, the ILO Declaration, the UN Human Trafficking Protocol, the UN Slavery Convention, the UNGPs and the UN Convention on the Rights of Persons with Disabilities (printed page 224). The human rights policy statement, "first published in 2018", is "chaired by the chief human resources officer"; the code of ethics "states clearly that Atos Group rejects human trafficking and all forms of human slavery, including forced, compulsory and child labor".

New or revised in 2025. The Global Occupational Health and Safety Policy was implemented in 2025 and "provides guidance on implementing the requirements of ISO 45001:2023" (printed page 227). The DE&I policy is "now in place", called "a key achievement for 2025" (printed pages 237-238). The people development policy was "last reviewed in August 2025" (printed page 233). The accessibility policy, in place since 2019, was "reinforced in 2025".

Processes for engaging with own workforce and workers' representatives

Reference: printed pages 222-223 (section 5.3.1.2).

European Company Council (SEC). It "is composed of 27 members and as many deputies. It represents 31,000 employees across Europe in 18 countries", with a six-member select committee. It meets "at least twice per calendar year or when exceptional circumstances arise"; "The CEO participates in at least one meeting per calendar year, and the CFO participates each quarter to present the Group's financial results." Operational responsibility sits with the Group CHRO, and members "may be assisted by experts of their choice".

2025 activity. "Information and consultation were conducted on five projects", including a withdrawal project, a business unit divestment, a transfer of activities to other countries and an acquisition. "Where applicable, the local social dialogue mirrored the European social dialogue."

Feedback loop. "Feedback from the workforce is systematically recorded through various channels, including surveys, suggestion boxes, and direct communication during meetings ... Employees are informed about how their feedback has influenced decisions through follow-up communications" (printed page 223). An internal Group-wide survey ran in summer 2025 "following almost three years of extensive organizational change", with "Over 12,000 employees" responding (printed page 232).

A limitation stated. "Although employees and their representatives did not formally participate in defining the targets presented in the following sections, their feedback was taken into account by the Group" (printed page 224).

Processes to remediate negative impacts and channels to raise concerns

Reference: printed page 225 (section 5.3.1.3.2), with the mechanism set out in full at section 5.4.1.3(d) (printed pages 297-298).

"Atos Group has a Group's ethics alert system in place to enable employees across the Group, as well as third parties, to report any matter of concern in relation to potential breaches of the code of ethics, or applicable laws or regulations, particularly in connection with breaches that may have occurred in relation to human rights" (printed page 225).

Channels. The Atos Integrity Line, "a web-based platform developed by EQS and publicly available (https://atos.integrityline.app/)"; dedicated global and geography mailboxes; or "by any means as preferred by the whistleblower". In 2025 the Group "successfully finalized the digitalization of its Group alert system", now "fully operational worldwide and available in seven languages" (printed page 297).

Anti-retaliation. "Atos Group will not apply any sanction or retaliatory measure or discriminate against an employee raising an alert, provided that they acted in good faith ... even if the events relating to the alert ... prove inaccurate. If necessary, the employee's protection may be assured, on their request, by mobility within the Group" (printed page 298).

Use. "In 2025, 83% of the alerts reported through the Group's ethics alert system have been raised by Atos Group's own workforce".

Gap declared. "The Group has not yet implemented an assessment measure to monitor the workforce's awareness and trust in the Group's alert system.

Taking action on material impacts on own workforce

Reference: printed pages 228-229 (health and safety), 232 (well-being), 234-236 (skills) and 241-243 (diversity and accessibility).

Health and safety. An awareness hub with e-learning on "ergonomics, first aid, and remote working"; a Group-wide "health & safety month" in April 2025; mental health webinars and mindfulness sessions; a "harmonized 10-step health and safety strategy". For Genesis-plan site closures, "a site closure policy and checklist have been published and communicated to the target audiences, enabling the process to proceed safely". The Security Emergency Response Tool, in place since 2017, "was successfully activated in the USA, Thailand, India and in Scotland" in 2025.

Well-being (printed page 232): remote and hybrid working with "disconnection initiatives"; childcare and lactation facilities "in most of its entities"; "paid parental leave for the primary caregiver beyond the legal minimum in most of its entities"; employee assistance programmes; a YuMuuv partnership in Q4 2025 for the GAGE exercise challenge.

Accessibility (printed page 241): policy alignment "including the prohibition of 'phantom' hiring of people with disabilities"; mandatory accessibility and disability inclusion training added to the code of ethics programme; improved workplace adjustment processes with a ticketing system; the "Atos ATVisor console".

Resourcing limitation, repeated for every sub-topic. "Atos Group is unable to report specific financial resources allocated to health & safety action plans because CapEx and OpEx are not yet tracked and reported at Group level by action plan" (printed pages 229, 232, 236).

Targets related to own workforce

Reference: printed pages 229, 232, 236 and 241-242 (sections 5.3.1.5.4 to 5.3.1.8.4).

Two sub-topics have no measurable target, stated plainly. Health and safety: "Atos Group has not set measurable targets as per the ESRS 2 MDR-T, but aims at reducing work-related accidents and illnesses and uses a series of indicators ... to monitor its performance" (printed page 229); in place of targets it runs a per-country maturity model "built on four main pillars: minimum security baseline, health and safety, physical security, and operational resiliency". Well-being: "due to extensive organizational change, the Group is yet to establish measurable targets in employee satisfaction improvement as employee surveying only restarted in the summer of 2025" (printed page 232).

Skills - one met, one new. "Atos Group achieved its 2025 target of 65,000 certifications, including 55,000 digital certifications across the Group. By the end of 2026, Atos Group aims to achieve 80,000 certifications, including 70,000 digital certifications" (printed page 236).

Diversity - three quantified targets, one missed (printed page 241): 35% of women in talent pools by end Q1 2026 against a 2024 baseline of 31.33%; 25% senior-level women in leadership teams (GCM 7+) by end 2026 against 19.41%; and a 2025 target "to ensure that 40% of all new hires were women. While 36.7% was achieved, the result reflects evolving workforce needs and market dynamics where there are fewer women in the job market."

Accessibility targets include training "at least 90% of the global workforce" (printed page 242).

Characteristics of the undertaking's employees

Reference: printed pages 225-227 (section 5.3.1.4).

Headcount. "At year-end 2025, Atos Group had 63,012 employees (with an average number of 70,120 employees)", against 77,932 in 2024 and 94,231 in 2023. By gender: male 42,418, female 20,493, not reported 101; "The HR system currently offers only 'male' or 'female' options for the gender data field". Countries above 10% of the total: India 13,871 (from 17,647) and France 9,247 (from 9,813).

Contract type (printed page 226): 62,502 permanent and 510 temporary, so "99.24% of the total workforce is on permanent employment contracts"; 61,113 full-time and 1,899 part-time, 95.4% full-time. "Part-time is at the initiative of the employee, not of the Group." Non-guaranteed hours employees are "Data unavailable": "Atos Group is currently unable to report on non-guaranteed hours employees, and breakdown by gender, as this data is not yet available for disclosure in 2025. Consequently, no progress in this area is expected to be disclosed in 2026."

Turnover. "In 2025, 13,188 employees left the Group. The turnover was 18.81%, of which 13.67% was voluntary, compared to 18.85% in 2024 (14.60% voluntary)."

Accounting policies (printed page 227). Headcount "includes only the internal people"; long sickness, sabbatical, parental and maternity leave are included; "subcontractors, interims, apprentices and interns" excluded. Turnover divides leavers by average headcount and excludes "interns, subcontractors, restructuring and outsourcing" - an exclusion worth noting in a year of large-scale restructuring under the Genesis plan.

S1-6 is the one social disclosure the auditor singles out for detailed procedures (printed page 319).

Diversity metrics

Reference: printed pages 242-243 (section 5.3.1.8.5), with the chapter opening at printed page 237.

Gender at top management (GCM level 7 and above out of 11 levels):

The calculation "does not include employees at GCM 7+ without gender information working for Cloudreach entities".

Age distribution (printed page 243): 13,495 aged 30 or under (21.4%), 33,466 aged 31-50 (53.1%), 16,051 over 50 (25.5%).

Other figures (printed page 242): women as a share of the Group 32.57% (32.28% in 2024); women recruited 36.74% (43.24% in 2024), with 32.15% of talent pools female; employees with disabilities 2.27%, "up from 1.92% in 2024"; juniors recruited 2,587, "meaning 48.09% (vs 50.08% in 2024)". Of the 200-strong management community at 31 December 2025, "29% ... are women, vs. 23.35% in 2024 and only c. 13% in 2019" (printed page 237). The workforce spans 63 countries and "128 nationalities".

Scope caveat. The basis of preparation flags DE&I metrics in section 5.3.1.8.5 among the datapoints "disclosed but for a limited scope" (printed page 166).

The absolute number of women in top management fell year on year while the percentage rose, because total top-management headcount fell by 1,053.

Training and skills development metrics

Reference: printed pages 236-237 (section 5.3.1.7.5).

Participation in performance and career development reviews (%):

Employees with an individual development plan (%), a voluntary measure "highly encouraged by the Group":

Average formal training hours per employee:

Certifications (printed page 237): 529,516 digital certifications registered and 67,982 obtained in the year; 76,168 certifications obtained per year.

Measurement boundary, stated. "The average number of training hours above is calculated based only on the formal training hours that employees have completed through the learning management system (LMS). All formal learning includes proof of attendance upon completion." Other learning - "learning through experience, on-the-job activities, coaching, collaboration in communities" - is "not tracked in the LMS" but recorded in the time management system.

Individual development plan coverage fell for both genders in 2025, the female rate by 8 percentage points, in a year of restructuring under the Genesis plan. The basis of preparation flags these metrics as "disclosed but for a limited scope" (printed page 166).

Health and safety metrics

Reference: printed page 230 (section 5.3.1.5.5).

Two entity-specific metrics added in 2025. "In 2025, in order to enhance the integrity of its reporting across all countries, Atos Group decided to introduce two entity specific metrics: the number and the rate of recordable staff members seriously injured ... Seriously injured staff members are defined as those with more than three working consecutive days of sick leave, whether hospitalized or not. This applies from the fourth day of absence onward."

Partial coverage, disclosed. The recordable accidents indicator is reported "over a more limited scope, namely a sample of 8 countries (France, USA, India, Romania, Poland, UK, Netherlands, and Spain) representing a total of 42,407 employees and a coverage of 67.3% of Atos Group's own workforce. These data cover a 12-month timeframe for 3 of them (France, US, India) and on a 10-month time frame for 5 others ... This limited coverage is a first step and will be an area for future enhancement."

Two further gaps. Days lost (paragraph 88(e)) is marked "omitted in 2025 due to phase-in provisions" in Appendix 3 (printed page 314), and "'Other workers' are not considered in the number of fatalities reported for 2025".

ISO 45001 certifications fell from 41 to 30 sites while the Group reports "more than 10,500 workstations across 30 certified sites" (printed page 227).

Work-life balance metrics

Reference: printed page 233 (section 5.3.1.6.5).

The prescribed metric is not given. "In accordance with the phase-in provisions of CSRD, Atos Group does not report on the metrics related to the percentage of employees entitled to take family-related leave. However, all Atos Group employees covered by collective bargaining agreements are entitled to such leave" (printed page 233). The Group adds the coverage figure that makes that statement readable: "In 2025, 43% of the Group's employees were covered by collective bargaining agreements."

What is reported instead. "tracking absentee rate enables Atos Group to assess the effectiveness of its wellbeing and work-life balance initiatives. In 2025, the Group's absentee rate was 2.23%." The absenteeism rate is also the measure nominated in place of a target: "Atos Group has not set measurable targets but will use the absenteeism rate at Group Level in addition to regular company-wide pulse surveys to evaluate the effectiveness of these actions" (printed page 232).

Note that the family-related leave datapoint is not among the three phase-in provisions the Group declares at printed page 168 (ESRS 2 SBM-3 48(e), E1-9 and S1-7), and S1-15 is listed in Appendix 2 against section 5.3.1.6 with no qualifier (printed page 308). The statement at printed page 233 is the only place the relief is claimed.

Supporting actions at printed page 232 include remote and hybrid working, "disconnection initiatives", flexible hours and part-time options "available in most entities", childcare and lactation facilities, and "paid parental leave for the primary caregiver beyond the legal minimum in most of its entities".

Policies related to value chain workers

Reference: printed pages 246-247 (section 5.3.2.2.1), with strategy at printed page 245.

The policy. "Atos Group has created the policy Atos partners' commitment to integrity to set out the ethical commitment that the Group expects from its partners to be taken prior to entering in contractual relationship with them ... which acknowledges that any partner is expected to follow the ten principles of the UN Global Compact with respect to human rights, labor standards, protection of the environment and anticorruption" (printed page 246).

What it manages. The policy "serves Atos Group to better manage the material negative impacts on the health and safety of the workers of the supply chain that are exposed to raw material extraction or bad management of substances of concern and also to manage properly the negative impacts on the violation of the fundamental rights and freedoms of supply chain workers through the purchase of materials from high-risk sectors (use of conflict minerals by subcontractors)".

Scope widened in 2025. "Updated in 2025, the scope of the document has been redesigned and refined to apply specifically to the Atos production and value chain, i.e. Atos Group's partners' being understood as vendors, suppliers, and third-party partners, along with their employees, personnel, agents and subcontractors" (printed page 294).

The impact described. "Supply chain workers involved in raw material extraction of Atos Group's suppliers for creating IT equipment and components face significant health and safety risks. They are often exposed to hazardous chemicals, which can cause severe health issues like respiratory problems and chemical burns."

Limit acknowledged. "Although Atos Group's ability to influence clients in this regard is limited, certain policies support this effort" (printed page 245).

Processes for engaging with value chain workers

Reference: printed page 250 (section 5.3.2.2.2).

Engagement is indirect, routed through supplier assessment rather than the workers themselves. "The general processes for contributing to remedy material negative impacts already identified on supply chain workers are outlined within the context of Atos' vigilance plan. This vigilance plan is detailed annually in the Group's Universal Registration Document, as well as in other reports such as the annual compliance report and the UK modern slavery statement" (printed page 250).

"In terms of mitigation and remediation actions, Atos Group emphasize the process of encouraging suppliers at risk of labor and human rights violations to establish corrective action plans (CAPs) through the EcoVadis platform. Through these efforts, the Group contributes to remedying some of the negative impacts already identified on supply chain workers, such as health and safety risks and violations of fundamental rights and freedoms."

Direct engagement with strategic and core suppliers runs through the annual QCDIMS review, whose questions include "has your company implemented initiatives and processes to ensure that modern slavery ... are not taking place in any part of your business or supply chain?", "is your company committed to pay a living wage covering its entire workforce?" and "does your company has a whistleblowing procedure in place?" (printed page 251).

A limitation stated plainly. "at this time, the value chain workers or their representatives are not participating in setting the target, measuring effectiveness, and identifying lessons learnt according to the expectation of the European Sustainability Reporting Standard (ESRS) framework" (printed page 253).

Processes to remediate negative impacts and channels for value chain workers

Reference: printed page 250 (section 5.3.2.2.2).

"Atos Group has a Whistleblowing system in place called 'Atos Group ethics alert system' to enable workers of the chain to report any matter of concern in relation to potential breaches of the code of ethics, or applicable laws or regulations" (printed page 250). It is the same mechanism used for the own workforce and affected communities, set out at section 5.4.1.3(d) (printed pages 297-298): the publicly available Atos Integrity Line at https://atos.integrityline.app/, dedicated mailboxes, or any means the whistleblower prefers, "available in seven languages".

"Regular training sessions and awareness campaigns are conducted to ensure that all stakeholders are informed about the whistleblowing channel." The policy "complies with French anti-corruption law called 'Sapin II' and duty of vigilance Law".

Use by external parties. "In 2025, 9% of the alerts reported through the Group ethics alert system have been raised by externals and 8% raised anonymously, which did not allow Atos Group to determine whether raised by Atos Group's own workforce or externals."

Remediation route. "If they perform poorly on the labor and human rights theme ... Atos Group initiates a related corrective action plan", covering labour and human rights policies, health and safety risk assessment, career management and training, diversity and harassment, and "measures to prevent child labor, forced labor and human trafficking". "since November 2024, Atos Group published the Atos modern slavery training for suppliers which is sent to all suppliers with a low EcoVadis labor and human rights score."

The Group does not report how many supply chain workers used the channel, or the outcomes.

Taking action on material impacts on value chain workers

Reference: printed pages 250-253 (section 5.3.2.2.3). Appendix 3 maps the S2-4 paragraph 36 human rights incidents datapoint here (printed page 315).

Four named actions.

1. Assessment of all suppliers. EcoVadis is "the standard reviewer". "Around 1,100 suppliers have a valid EcoVadis scorecard, and they represent 74% of total the Group's spend. Suppliers with a low overall EcoVadis score (below 40) have a related corrective action plan initiated by Atos Group."
2. Assessment of strategic and core suppliers. "One action planned and ongoing at Atos Group over the last four years is to deeply assess the most significant suppliers ... in their labor practices and whistleblowing processes." In the annual QCDIMS review "the sustainability section represents 20% of the total score, with social topics, including diversity and human rights, accounting for 6% of the total". "Suppliers without procedures to ensure that modern slavery is not taking place ... are flagged" (printed page 251).
3. Assessment of suppliers invited to tenders, on the same basis.
4. Creating a more diverse supply chain, via the supplier diversity programme established in 2022.

Effectiveness, with evidence. "The effectiveness of Atos Group's actions in pushing suppliers to implement specific corrective action plans has led to a demonstrable positive trend in their labor and human rights scores." Average supplier scores rose: "labor and human rights: 65 (vs. 62 in 2024)", environment 66 (63), ethics 63 (60) (printed page 259). Atos' own EcoVadis score was "84/100 in 2025", "in the top 1% of best companies assessed by EcoVadis in its industry" (printed page 253).

Targets related to value chain workers

Reference: printed page 253 (section 5.3.2.2.4), with metrics on the same page.

"Regarding suppliers performing poorly overall or in specific areas, the ongoing goal is to encourage them to implement a Corrective Action Plan (CAP), aiming to ensure that 100% of the high-risk suppliers have a CAP in place. For this target, it's a continuous activity to cover 100% of suppliers every year. Note that this target is related to actions 1, 2, 3 previously described" (printed page 253).

Performance against it. "[D.D. 5_1] - Percentage of potentially at risk suppliers with corrective action initiation requested by Atos Group" was 100% in 2025, 2024 and 2023 (printed page 258). The population is small and shrinking: suppliers scoring below 40 on EcoVadis numbered 33 in 2025, 42 in 2024 and 62 in 2023, representing 1.8% of total spend (1.5% in 2024, 2.8% in 2023).

Assessment coverage target. "Atos Group has set an annual sustainability risk target to maintain or increase the level of spend covered by suppliers with valid EcoVadis (or alternative) assessments (% of spend). For 2025, this target was set at 74%" (printed page 303), rising "to 75%" for 2026 (printed page 257). Outturn was 74% of spend, against 75% in 2024 and 73% in 2023.

The limitation the Group states. "Please note that, at this time, the value chain workers or their representatives are not participating in setting the target, measuring effectiveness, and identifying lessons learnt according to the expectation of the European Sustainability Reporting Standard (ESRS) framework."

No outcome target is set for the workers themselves - none on audit findings closed, remediation for affected workers, or living wage coverage. The targets measure Atos' own assessment coverage and the initiation of corrective action plans.

Policies related to affected communities

Reference: printed pages 254-255 (section 5.3.3.2). Appendix 3 maps the S3-1 paragraph 16 and 17 datapoints here (printed page 315).

S3 is material through a single IRO shared with S2: "Supply chain workers and communities could face health and safety risks, rights violations, and adverse living conditions due to poor management of hazardous substances and the use of conflict minerals by subcontractors" (printed page 254).

Communities affected. "the communities at the end point of the Atos' supply chain which are negatively impacted by physical and chemical discharges due to proximity to the point of extraction of metals or minerals ... the extraction of raw materials by Atos Group's suppliers ... often involves extensive mining operations that could result in adverse health effects or impact the livelihoods of local communities."

Principal policy. "The most relevant policy which embed the management of the negative impact associated to the extraction of raw materials in Atos Group's supply chain is the Atos partners' commitment to integrity ... The scope was refined over 2025."

Conflict minerals, quoted from the policy. "In accordance with EU regulations on conflict minerals (2017/821) and Section 1502 of the US Dodd Frank Act ..., Atos Group's partners must not use minerals (tantalum, tin, gold and tungsten) from conflict regions (e.g. Democratic Republic of Congo, Rwanda, Tanzania, Uganda or Zambia) ... and be in a position to provide evidence, such as Conflict Minerals Reporting Template (CMRT)" (printed page 255).

Negative statement made. "Atos Group confirms that, to the best of its knowledge, no cases of severe human rights incidents nor any breaches of the UN Guiding Principles on Business and Human Rights, the ILO Declaration ... or the OECD Guidelines ... involving affected communities were reported in 2025".

Processes for engaging with affected communities

Reference: printed page 255 (section 5.3.3.2, items (iii) and (iv)).

The Group states it does not engage communities directly. "The company does not engage directly with communities affected by its negative impacts. However, Atos Group is significantly engaged with its suppliers to prevent any negative effects on these communities. This engagement is managed through the monitoring and control of supplier behaviour by a third party, EcoVadis. This engagement is based on information and occurs regularly during the process of adding new suppliers and, ideally before 36 months for existing suppliers, through the update of the EcoVadis assessment" (printed page 255).

How the Group learns about affected communities. "Atos Group gained an understanding of which communities are at risk through the supplier assessment performed by an external expert (EcoVadis) which assesses suppliers based on their activities and geographies" (printed page 254).

Controversy surveillance. "The EcoVadis 360 Watch identifies any significant controversies, fines, or penalties related to labor and human rights issues within the last five years for Atos Group's suppliers assessed by EcoVadis ... Additionally, the procurement team receives email notifications if a specific supplier has a significant controversy, fine, or penalty regarding labor and human rights issues."

The direct channel that does exist. "Affected communities can raise alerts through the Atos Group integrity line, publicly available and accessible to all on the Atos Group's website: https://atos.integrityline.app/", anonymously if preferred.

Community representatives took part in the materiality analysis: downstream stakeholders consulted included "representatives of environmental and social NGOs, member of Atos Prayas Foundation (India)" (printed page 173).

Processes to remediate negative impacts and channels for affected communities

Reference: printed page 255 (section 5.3.3.2, item (iv)).

"The main process for cooperating in remediation of negative impacts on affected communities is the Atos Group ethics alert system. It is in place to enable employees across the Group, third parties and any affected communities, to report any matter of concern in relation to potential breaches of the code of ethics, or applicable laws or regulations, particularly in connection with breaches that may have occurred in relation to bribery and corruption, competition law, fraud, financial crime, health and safety, harassment and discrimination, economic sanctions and export control, protection of personal data, serious environmental damage, human rights and conflict of interest" (printed page 255).

Accessibility. "Affected communities can raise alerts through the Atos Group integrity line, publicly available and accessible to all on the Atos Group's website: https://atos.integrityline.app/." The full mechanism is at section 5.4.1.3(d) (printed pages 297-298).

Protections. "It includes policies regarding privacy and the protection of individuals who use this channel against retaliation. The alerts are treated confidentially and with respect to rights of privacy and data protection. The affected communities are allowed to use anonymously this channel to raise concerns or needs."

Volume. "In 2025, 9% of the alerts reported through the Group ethics alert system have been raised by externals and 8% raised anonymously". The statement does not separate community reports from other external reports, nor report remediation outcomes for communities.

Taking action on material impacts on affected communities

Reference: printed pages 256-257 (section 5.3.3.3). Appendix 3 maps the S3-4 paragraph 36 datapoint here (printed page 315).

Four named actions.

1. Supporting suppliers potentially at risk (EcoVadis score below 40/100). "The Group's approach is to work with each supplier that has a score of below 40 ... and encourage them to improve their practices." "In 2025, 33 suppliers assessed by EcoVadis had an overall score below 40, generally due to a lack of understanding of the EcoVadis assessment process and platform. Those 33 suppliers represent only 1.8% of the total Atos Group spend."
2. Continuous classification of suppliers across five carbon management levels, which "includes better control over all assessed suppliers, including the ones involved in the extraction of raw materials for IT equipment production, which can lead to physical and chemical discharges that affect the living conditions of local communities". "The objective is not to terminate agreements with 'insufficient' and 'beginner' suppliers, but to help them improve." In 2025 "74% total Atos Group spend has been assessed for CSR risk and for decarbonization".
3. Improved monitoring tools. "In 2025, Atos Group acquired the IQ Plus module from EcoVadis to do the sustainability risk mapping of its entire supply chain. Approximately 13,000 Atos Group's partners are uploaded in the tool and scored on ... country risk; category risk: criticality; level of spend" (printed page 257).
4. Creating a more diverse supply chain.

Every action operates on suppliers rather than on the communities, consistent with the Group's statement that it "does not engage directly with communities affected by its negative impacts".

Targets related to affected communities

Reference: printed page 257 (section 5.3.3.4), with metrics at printed page 258.

"Concerning the monitoring and control of Atos Group's suppliers for minimizing their negative impacts on communities, the Atos Group procurement's objective is to strengthen the relationship with its top, strategic and globally managed suppliers and have all of them assessed by EcoVadis ... the aim for 2025 was to achieve 74% of the Atos Group spend with suppliers assessed though EcoVadis or alternative assessment and the objective for 2026 is to increase it to 75%" (printed page 257).

The targeted population is "top 250 suppliers by spend which represent 73% of total Atos Group spend"; strategic or core suppliers "selected based on the level of spend and criticality"; and local suppliers selected on spend.

Second target. "the ongoing goal is to encourage them to implement a Corrective Action Plan (CAP), aiming to ensure that 100% of the potentially at risk suppliers have a CAP in place."

Metrics (printed page 258): suppliers below 40 on EcoVadis 33 / 42 / 62 across 2025, 2024, 2023; share of total spend they represent 1.8% / 1.5% / 2.8%; share of spend with assessed suppliers 74% / 75% / 73%; share of at-risk suppliers with corrective action requested 100% in all three years.

The limitation stated. "at this time, the affected communities are not participating in setting the target, measuring effectiveness, and identifying lessons learnt according to the expectation of the European Sustainability Reporting Standard (ESRS) framework".

Policies related to consumers and end-users

Reference: printed pages 262 (customer satisfaction), 269 (accessibility), 274 (cybersecurity) and 285 (data privacy). Appendix 3 maps the S4-1 paragraphs 16 and 17 datapoints to section 5.3.4.2.1 (printed page 315).

S4 is material through four sub-topics: client relationship, accessibility and digital inclusion, data privacy and security/cybersecurity (printed page 259).

Who the end-users are. Four groups are defined: "Atos Group employees; Atos Group clients' employees; Atos Group clients' customers; communities where Atos Group performs social development activities". The Group is candid that "Atos Group has a very little influence on the consumers as defined in the standard" and that "Client relationship is not present in the topical standards (AR 16) but it was already considered as material in the previous materiality assessment exercise".

Customer satisfaction policy. "The general objective of this policy is to implement a consistent framework for measuring to what extent Atos Group solutions, products, services, processes and deliveries meet or exceed its customers' expectations, and then to use outcomes to drive changes" (printed page 262). Accountability sits with "the most senior role in the geography, such as the CEO or the individual delegated by the highest manager in that region".

Channel for concerns. "The specific channel in place for consumers and end-users to raise concerns about any type of misconduct or need directly with Atos Group is the whistleblowing system which is available in the next URL: https://atos.integrityline.app/."

The Group states it "did not identify consumers or end-users with specific characteristics requiring differentiated consideration".

Processes for engaging with consumers and end-users

Reference: printed pages 263-266 (section 5.3.4.2.2).

Three-level survey framework. Engagement "is conducted on a regular basis at various levels" - strategic (board and corporate purchasing, "General perception measurement on overall quality of the relation", "Personal Interviews once or twice per year"), tactical (contract and project, IT management and project managers) and transactional (printed page 263). "At the strategic level, all accounts in scope are surveyed each year (preferably each semester)" (printed page 266).

Why it is run. The framework "allows Atos Group to consistently measure customer satisfaction at consolidated account level and geographical level"; "provides baselines for each account to improve upon"; and "identifies generic areas of concern across accounts and geographies".

Reaching end-users through clients. "customer satisfaction surveys engage directly with Atos Group clients ... and indirectly with the end-users of Atos Group clients' customers ... When a client facilitates the services delivered by the Group to other users through reselling, API integration, or by integrating Atos Group products/services into their own offerings, they typically have their own procedures to gather feedback from these end-users. The Group expects to receive this information through the established feedback channels with its clients, as these clients are considered credible proxies that provide insight into the end-users' situations."

So engagement with the people who ultimately use Atos services is mediated: the Group relies on its B2B clients as proxies rather than surveying end-users itself, and says so.

Processes to remediate negative impacts and channels for consumers and end-users

Reference: printed pages 262-265 (section 5.3.4.2.2), with equivalent provisions at 5.3.4.3.2, 5.3.4.4.2 and 5.3.4.5.2.

The stated channel. "The specific channel in place for consumers and end-users to raise concerns about any type of misconduct or need directly with Atos Group is the whistleblowing system which is available in the next URL: https://atos.integrityline.app/. In that system, any consumer or end-user, as well as any internal or external stakeholder of Atos Group, can quickly and easily report concerns about actual or suspected misconduct" (printed page 262). The mechanism, admissibility rules and investigation principles are at section 5.4.1.3(d) (printed pages 297-298).

Everyday route. Concerns reach Atos through the account relationship and the survey programme; the strategic CSAT process includes formal steps to "Share plan to improve CSAT with client" and "Implement plan to improve CSAT" (printed page 266).

Accessibility remediation. Issues run through a ticketing system: the Group "improved global workplace adjustment processes to minimize administrative burden and enabled employees to submit feedback and request support via a ticketing system" (printed page 241). Reported outcomes: "15 (resolution rate 80%)" requests outside the UK, 139 UK hardware requests at 100%, and "assistive technology incident resolution: 100% resolution rate; only 5 tickets logged on accessibility issues" (printed pages 244-245).

The statement does not report the number of consumer or end-user complaints received through the whistleblowing channel, nor their outcomes.

Taking action on material impacts on consumers and end-users

Reference: printed pages 264-266 (client relationship), 271-273 (accessibility), 279-282 (cybersecurity) and 286 (data privacy). Appendix 3 maps the S4-4 paragraph 35 datapoint to all four sections (printed page 315).

Client relationship. The customer satisfaction programme is the action: surveys at strategic, tactical and transactional level, with the strategic process running from sponsor agreement and scoping through a CxO interview to agreeing, sharing and implementing a plan to improve CSAT (printed page 266).

Accessibility, 2025 actions (printed page 241): mandatory accessibility, digital inclusion and disability inclusion training added to the code of ethics programme "aligned with Valuable 500 disability inclusion KPIs"; the "Atos ATVisor console, a monitoring tool designed to proactively identify and address accessibility issues"; and "the DVA Committee in Germany implemented accessibility conformance in their IT rollout approval process".

Cybersecurity, named 2025 initiatives (printed pages 281-284): "Unification of Tech Foundation and Eviden ISMS policies, processes and services common for Atos Group (completed)", targeted for May 2025 with ISO 27001:2022 certification covering "all geographies of Atos Group as per scope document"; "Zero trust network access (ZTNA)", "allowing users to connect to internal applications without exposing them to the public Internet"; the "shadow IT remediation project SIRP (ongoing)"; vulnerability management consolidation initiated February 2025.

Resourcing limitation. "Atos Group is currently unable to report specific financial resources allocated to these action plans, as CapEx and OpEx are not yet tracked and reported at Group level by individual action plans" (printed pages 266, 273, 282).

Targets related to consumers and end-users

Reference: printed pages 266-267 (client relationship), 273 (accessibility) and 282-283 (cybersecurity).

Client relationship - a quantified target, missed. "Atos Group has set the net promoter score (NPS) as main target during the last years ... As for 2025, Tactical NPS target has been set at 74%, while actuals have reached 70% (same level as in 2024), which is significantly above market standard" (printed page 266). "The targets defined are in line with industry benchmarks and established best practices, and as such, end-users were not involved in the target-setting process." A measurement caveat is disclosed: "The measurement of this metric has not been validated in 2024 by an external body. However, its calculation remains stable since the last verification of one of the statutory auditors in 2020" (printed page 267).

Accessibility targets and outturn (printed page 273): "train at least 90% of the global workforce on accessibility, digital inclusion, and disability inclusion basics" - achieved "87.97% of employees completed accessibility and digital inclusion module of the code of ethics training"; "1,350 ACRs were received in the product accessibility compliance inventory and 57 ACRs assessed (4.2%)"; "12/54 events (22%) included explicit accessibility criteria this year".

Cybersecurity (printed page 282): "Atos Group aims at achieving a target of 90% of employees who complete their training annually", measured by "a final exam requiring a minimum passing score of at least 80%". Outturn 87.52%. The Group also states plainly where no target exists - the Charter of Trust, NIS2 ("due to uncertainties in the date of national transpositions of the directive"), vulnerability management consolidation, SIRP and ZTNA.

Business conduct policies and corporate culture

Reference: printed pages 292-294 (sections 5.4.1.1 and 5.4.1.2).

Culture. "Atos Group has developed its ethics & compliance program targeting and promoting the highest ethical standards as a competitive advantage ... This culture of compliance is embedded at all levels of the Group through the implementation of dedicated procedures, training, communication, awareness-raising, contractual obligations for all third parties, internal controls and regular audits, as described ... in the compliance annual review, a dedicated public document published every year" (printed page 292).

External validation. "In 2025, EcoVadis renewed Atos Group's 'Platinum' certificate ... achieving 91/100 in 'ethics' and 75/100 in 'labor & human rights', securing its position in the top 1% of the IT sector".

Code of ethics. First published in 2003 and "regularly reviewed since then", it "formalizes the Atos Group's zero-tolerance policy towards corruption", covers "inclusion in the workplace, human rights, data protection and the environment", and provides "a comprehensive anticorruption code of conduct in line with the latest version of the corruption risk mapping". It "has been endorsed by the board of directors and is introduced by the chairman of the board of directors and general manager" (printed page 294).

Global ethics and compliance policy. It "supplements the code of ethics and form the overarching framework of the Atos Group compliance management system", and "was subject to an in-depth review in the course of 2025".

Governance. The board has appointed an ethics advisory body "composed of independent and highly expert external professionals to advise the Group management on complex, sensitive and/or strategic compliance issues" (printed page 293).

Management of relationships with suppliers

Reference: printed pages 302-304 (section 5.4.2.1).

Policies. "Atos Group procurement team has adopted a global procurement policy and global procurement sourcing policy with a comprehensive sustainability section to manage the risk related to ethics, human rights and the environment within the supply chain ... These policies cover all Atos Group procurement activities and set expectations to all tier 1 suppliers Atos Group is engaging" (printed page 302). "The Group chief procurement officer is accountable for the implementation of these policies."

Supplier code of conduct. The Atos partners' commitment to integrity "is a supplier code of conduct included in all Atos Group tenders and all Atos Group supplier master or framework agreements", and "The supplier must comply with the Atos partners' commitment to integrity throughout the whole contract lifecycle".

Sustainability weighting, broken down (printed page 303): "Atos Group place a 20% weighting on sustainability" in tenders - "CSR risk 7%", "decarbonization 7%" and "social topics 6%". The same 20% applies to the annual QCDIMS performance survey for strategic and core suppliers.

Target and 2025 metrics. The 2025 target was 74% of spend covered by valid EcoVadis or alternative assessments. Outturn: "74% of total Atos Group spend"; "764 (1090 valid scorecards in total) suppliers were scored or reassessed by EcoVadis"; "33 suppliers assessed by EcoVadis had an overall score below 40 ... those 33 suppliers represent only 1.8% of the total Atos Group spend".

Dependency risk (IRO 20). Suppliers are "tiered based on strategic importance and risk exposure", with "escalation or phase-out procedures in cases of repeated underperformance" (printed page 304).

Prevention and detection of corruption and bribery

Reference: printed pages 294-301 (section 5.4.1.3, "Actions [ESRS G1-3]").

"Atos Group's compliance program relies on a four-stage risk management cycle, consisting of risk identification and assessment, prevention, detection and monitoring" (printed page 294).

Corruption risk mapping updated in 2025. "In 2025, Atos initiated the update of its corruption risk mapping exercise, following the established methodology from the 2023 exercise ... conducted through a comprehensive collaboration between Group compliance, Group internal audit, and Group internal control and enterprise risk management departments", following "all principles detailed in the French anticorruption agency (AFA) guidelines". "a notable increase in the number of scenarios presented to the internal respondents occurred, from 58 scenarios in 2023 to 63 scenarios in 2025 among 26 risk areas identified, along with 14 corruption mechanisms." The results "identified three functions as most exposed to risks in respect of corruption and bribery: sales, procurement and finance" (printed page 295).

Training architecture (printed page 301): a 1.5-hour annual code of ethics e-learning for all permanent employees (~60,000 invited, 100% coverage); a 45-minute biennial classroom training for sales and procurement (~2,000); and a 1-hour biennial ETO2s training for executives and managers (~2,000) covering anti-corruption, lobbying, conflict of interest, fraud, fair competition, trade regulations and dawn raids. "87.97% of Atos Group's permanent employees completed" the code of ethics training in 2025.

Detection and monitoring. "195 reports have been raised ... among which 64 reports have been flagged as alerts" (printed page 298). A three-lines-of-defence model applies, with anti-corruption controls "embedded within the BIC framework".

Targets related to business conduct

Back-filled from section 5.4.1.4 "Targets" in the business conduct chapter (printed page 300), where business conduct targets are presented as part of the MDR-T disclosures rather than under a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS, so the statement carries no section under that number.

One measurable target. "In relation with its business ethics program, Atos Group has set a specific target in the area of trainings which consists in ensuring that at least 90% of the permanent employees of Atos Group are being trained every year on the code of ethics e-learning training program. This target is set on a permanent basis and will be assessed at the end of each financial year" (printed page 300).

Performance against it. "87.97% of Atos Group's permanent employees completed" the mandatory annual code of ethics training in 2025 (printed page 297), so the 90% target was missed.

Six further "ambitions" support monitoring of the programme (printed page 300): maintaining and updating the compliance risk mappings; keeping policies "adapted to the risk profile of the Group activities and operations"; delivering "dedicated training programs to functions exposed to elevated compliance risks"; maintaining awareness and continuing to "reinforce employee awareness and trust in the alert system"; strengthening third-party due diligence; and continuing to "improve the export control assessment framework and associated expert network".

These six are directional rather than measurable, with no baselines or dates. For the supply chain limb, a separate quantified target exists: 74% of spend assessed in 2025, rising to 75% in 2026 (printed pages 257, 303).

Incidents of corruption or bribery

Reference: printed page 301 (section 5.4.1.5, "Metrics [ESRS G1-4]").

The full datapoint set, as published:

A complete nil return on every limb.

Context from the detection system. "In 2025, 195 reports have been raised by internal and external stakeholders through the channels respectively available and captured within the Group ethics alert system among which 64 reports have been flagged as alerts" (printed page 298). Alerts are routed to HR or compliance, and "the compliance officers are specifically instructed to report directly to the Group compliance team any alert related to corruption, fraud or financial integrity". "A presentation is done twice a year by the Group head of ethics and compliance to the audit committee of the board of directors regarding alerts trends and major cases ... in particular regarding corruption, fraud and financial integrity."

The statement does not disclose how many of the 64 alerts concerned corruption or bribery, nor how many were closed as unsubstantiated, so the nil return cannot be read against a denominator. Separately, "In 2025, the compliance & ethics risk was assessed and considered as 'managed'" (printed page 294).

Payment practices

Reference: printed pages 304-305 (section 5.4.2.2).

Process. "Atos Group has established a standard accounts payable process, which provides the process to pay suppliers including small and medium enterprise ('SMEs') at Group level. It states that all invoices will be processed according to contractual payment terms" (printed page 304).

Standard terms, by region (printed page 304): Benelux SMEs 30 days, Nordics 30 days by law; France "generally 60 days standard terms", with 45 days for temporary employment agencies and 30 for transport; Germany, Austria and Central Europe "predominantly 30 to 60 days"; International Markets 30 days for SMEs and government-project suppliers, otherwise 45 to 60; North America 30 to 60; UK and Ireland 30 days for SMEs and UK government-facing suppliers "due to Atos Group complying with the UK government cabinet office prompt payment code".

2025 performance (printed page 305). "In 2025, Atos Group paid 80% of all invoices early and on time or less than 5 days past the payment due date." A further 15% were late "due to suppliers' related reasons", taking the total to 95%. "The raw weighted average days to pay invoices ... equals to 33 days" - by region: Benelux/Nordics 31, France 44, Germany/Austria/Central Europe 29, International Markets 33, North America 28, UK and Ireland 33.

"As of December 31, 2025, Atos Group had no legal proceedings outstanding for late payments."

Method caveats. The computation weights each invoice by amount but "is based on invoice date, not on the date Atos Group receives the invoice from the supplier, which is on average 2 days past the stated invoice date". Yearly contracts "always paid in advance or on time" are excluded.